DHAKA METROPOLITAN DEVELOPMENT PLAN STRATEGIC ENVIRONMENTAL ASSESSMENT

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

Table of Contents ABBREVIATIONS...I EXECUTIVE SUMMARY...I CHAPTER 1 INTRODUCTION... 1-1 1.1 Rational for the Strategic Assessment Study... 1-1 1.2 Objectives of the Study... 1-3 1.3 Approach and Methodology of SEA... 1-3 1.4 Output... 1-7 1.5 Report Structure... 1-8 CHAPTER 2 SITUATION ANALYSIS OF DHAKA S ENVIRONMENT... 2-1 2.1 Urbanization in Dhaka... 2-1 2.2 Land-use and Land Management... 2-6 2.3 Water Resources and Quality... 2-12 2.4. Air and Noise Quality... 2-16 2.5. Flooding and Drainage... 2-17 2.6 Formulation of Environmental Priorities... 2-21 CHAPTER 3 URBAN PLANNING IN DHAKA... 3-1 3.1 Overall Planning Process in Dhaka... 3-1 3.2 Regional Plans Structure Plan & Urban Area Plan... 3-5 3.3 Sectoral Planning... 3-7 3.4 Institutional Set up for Governance & Urban Planning... 3-13 3.5 Analyzing Stakeholder Influence in Planning and Plan Implementation Process3-20 3.6 Analysis of Planning Framework in Context of Environmental Priorities... 3-23 CHAPTER 4 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK... 4-1 4.1 Land and Land use Management... 4-1 4.2 Water Resources and Quality... 4-2 4.3 Flooding and Drainage... 4-5 CHAPTER 5 SEA FINDINGS AND RECOMMENDATIONS... 5-1 5.1 Background... 5-1 5.2 Summary of SEA Findings... 5-1 5.3 Environmental Priorities that Need to be Addressed by DAP... 5-4 5.4 Recommendations... 5-6 BIBLIOGRAPHY.... B-1 GLOSSARY.... G-1 APPENDIX... A-1 34445 Final Aug 2007 i SENES Consultants Limited

List of Tables Table 2-1 Environmental Priorities in Dhaka... 2-24 Table 2-2 DAP Zones and Categorisation...3-5 List of Figures Figure 2-1 Spatial Growth of the Dhaka...2-2 Figure 2-2 Administrative Map of the DMDP Region...2-4 Figure 2-3 Spatial Disposition of Development Zones within DMDP... 2-5 Figure 2-4 Air Pollution from Vehicles in Dhaka... 2-16 Figure 2-5 Ranking Matrix for Stakeholder Perception...2-22 Figure 3-1 DMDP and DAP Planning Areas...3-4 Figure 3-2 Urban Governance Setup and Flows of Authority...3-14 Figure 3-3 Interaction between Planning Institutions...3-15 Figure 3-4 Principal Agencies Related to Urban Planning in DMDP Region... 3-16 Figure 3-5 RAJUK Organizational Structure...3-18 Figure 3-6 Stakeholder Analysis Matrix...3-21 Figure 3-7 Proposed Flood Retention Ponds as Demarcated in FAP 8A... 3-28 Figure 3-8 Proposed Flood Retention Ponds as Demarcated in DMDP Structure Plan... 3-29 Figure 3-9 Proposed Flood Retention Ponds as Demarcated in Eastern Bypass Project...3-30 List of Boxes Box 1-1 Institution-Centered SEA... 1-2 Box 2-1 Slums in Dhaka A Glimpse... 2-7 Box 2-2 Location of Industries in Dhaka...2-10 Box 2-3 Land Use and Land Management Environmental Concerns...2-12 Box 2-4 Water Pollution from Industries in Dhaka Watershed...2-15 Box 2-5 Water Quality Environmental Concerns...2-15 Box 2-6 Role of Rickshaw Pullers in Urban Transportation... 2-17 Box 2-7 Air and Noise Environmental Concerns...2-17 Box 2-8 Flooding and Drainage Environmental Concerns...2-21 Box 3-1 RAJUK SWOT Analysis... 3-18 34445 Final Aug 2007 ii SENES Consultants Limited

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- 34445 Final Aug 2007 i SENES Consultants Limited

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 34445 Final Aug 2007 ii SENES Consultants Limited

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. 34445 Final Aug 2007 i SENES Consultants Limited

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. 34445 Final Aug 2007 ii SENES Consultants Limited

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 34445 Final Aug 2007 iii SENES Consultants Limited

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. 34445 Final Aug 2007 iv SENES Consultants Limited

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. 4.3.1 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. 4.3.2 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. 4.3.3 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 34445 Final Aug 2007 v SENES Consultants Limited

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. 4.3.4 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 5.1.1 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. 5.1.2 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 34445 Final Aug 2007 vi SENES Consultants Limited

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. 5.1.3 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. 5.1.4 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. 34445 Final Aug 2007 vii SENES Consultants Limited

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. 5.1.5 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 5.2.1 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. 5.2.2 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. 34445 Final Aug 2007 viii SENES Consultants Limited

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 2015. In view of Dhaka s rapid development, changing urban landscape and critical environmental and governance challenges, the need for institutional strengthening and requisite city planning is becoming increasingly important. 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. 34445 Final Aug 2007 1-1 SENES Consultants Limited

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 1987. It is the development authority for Dhaka covering an area of 1528 sq Km. The present jurisdiction of RAJUK includes three districts (Dhaka, Narayanganj and Gazipur), five municipalities (Pourashavas of Savar, Kadamrasul, Narayanganj, Tongand Gazipur) and the Dhaka City Corporation Area. 34445 Final Aug 2007 1-2 SENES Consultants Limited

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. 34445 Final Aug 2007 1-3 SENES Consultants Limited

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. 34445 Final Aug 2007 1-4 SENES Consultants Limited

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. 34445 Final Aug 2007 1-5 SENES Consultants Limited

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. 1.3.2 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 1. 34445 Final Aug 2007 1-6 SENES Consultants Limited

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. 34445 Final Aug 2007 1-7 SENES Consultants Limited

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 34445 Final Aug 2007 1-8 SENES Consultants Limited

Chapter 2 Situation Analysis of Dhaka s Environment 25 This section presents the existing environmental situation of the Dhaka urban area. It describes the stressors on environmental resources, their components and its causes. The effect on the various environmental components have been clustered into four subsections, viz. landuse and land management, water resources and quality, air and noise quality, flooding and drainage. The analysis of the present environmental condition would include the views and concerns expressed by the stakeholders including vulnerable groups, and describe how they are impacted as a result of unmanaged urbanization. The section concludes with a summary of prioritized environmental issues based on technical analysis and the perspective of stakeholders gathered through several rounds of public consultations. 2.1 Urbanization in Dhaka 26 Dhaka, the capital city of Bangladesh, has emerged as the main economic nerve centre contributing about one-fifth of the nation s total GDP. However, with no alternative economic growth centre coming up, the expansion of the city in the last few decades has been very rapid and has been marked by huge influx of population from rural areas of the country. This rapid development, combined with absence of any systematic urban management, primarily during the last two decades has led to a shortfall in urban services infrastructure thereby resulting in severe environmental degradation and strain on resources. In addition, the nature of economic growth and urbanization is skewed resulting in about 37%3 of the city s population living below the poverty line and 3.4 million people are estimated to be living in slum areas. Furthermore, at present, environmental constraints to growth in the capital city constitute a national priority as pointed out by the Country Environmental Analysis4. 27 The DMDP area, covering a total of 1528 km2, lies in the delta of three major river systems of the Indian sub-continent i.e., Jamuna, Padma and Meghna. The urbanized part of Dhaka and the immediate peri-urban areas mainly occupy the flood plains of a number of smaller rivers which are tributaries of these two (Padma and Meghna) larger rivers and form an intricate system of rivers and natural drainage channels (the watershed formed by Tongi and Turag on the northern side, Sitalakhya and Balu in the eastern side and Buriganga on the western and southern side5). As a result, most of the land within the pear shaped delta forming the DMDP lies about 2-6 m above MSL (Mean Sea Level) except for the Mirpur highlands located along the central axis, where the elevations rise to about 13m. The overall slope of the area and resultantly, the flow of these smaller rivers are from north, north-west to south, south east side. 28 The present city of Dhaka has grown from a small settlement of nearly 0.2 million people, spread over an area of approximately 1 km2 during the pre-moghul period (1600s), on the natural levees of the River Buriganga and Dholai Khal. Presently it has transformed itself into a 3 Centre for Urban Studies (CUS) : Slum Studies, 2005 4 Bangladesh Country Environmental Analysis, World Bank, September 2006. 5 However, with rapid urbanization, the Metropolitan Planning Area now encompasses areas beyond the physical boundaries set by the rivers. The areas on the other banks of these rivers, including the municipal areas, are charted for urbanization in the planning period extending till 2015. 34445 Final Aug 2007 2-1 SENES Consultants Limited

city having a population of about 12 million. The annual average population growth rate for Dhaka has been as high as 6.9%6 during the period 1975 to 2000 (compared with an annual average of 2.1% for Bangladesh) and subsequently (2001 onwards) the annual growth rate is in the range of 4%7. Experiencing high rate of development and rapid urbanisation, the city is poised to grow into the fourth largest urban agglomeration in the world with a projected population of 21.1 million by 20158. 29 The spatial dimension of growth of Dhaka in the course of the last four centuries (1600-2000) is presented in the figure below. Figure 2-1 Spatial Growth of the Dhaka 9 Moghul Period : 10 km 2 British Period : 22 km 2 Pakistan Period : 85 km 2 Bangladesh Period (DMDP): 1528 km 2 30 Administratively, the spatial boundary of the DMDP incorporates 3 Zillas10 (Dhaka, parts of Narayanganj and Ghazipur), 5 Pourashavas (Savar, Tongi, Ghazipur, Narayanganj & Kadam Rasul) and the Dhaka City Corporation area which mainly covers the older parts of the city. A map of the DMDP area delineating the administrative boundaries is presented in Figure 2.2 below. As can be observed, large areas in the fringes of the city covering an area of about 1000 sq kms fall within the administrative jurisdiction of the Union Porishods and are still largely unurbanised. 6 7 8 9 World Urbanization Prospects: 1999 Revision, UN Report. Bangladesh Census (Year) DMDP Structure Plan DWASA Presentation 10 Bangladesh is divided into six administrative divisions, each named after their respective divisional headquarters: Barisal, Chittagong, Dhaka, Khulna, Rajshahi, and Sylhet. Divisions are subdivided into districts (zila). There are 64 districts in Bangladesh, each further subdivided into upazila (subdistricts) or thana ("police stations"). The area within each police station, except for those in metropolitan areas, is divided into several unions, with each union consisting of multiple villages. In the metropolitan areas, police stations are divided into wards, which are further divided into mahallas. There are no elected officials at the divisional, district or upazila levels, and the administration is composed only of government officials. 34445 Final Aug 2007 2-2 SENES Consultants Limited

31 For the purposes of this SEA study, the urban development of Dhaka has been spatially clustered into three distinct zones11 as described below: Developed areas: areas in the core of the city, mainly comprising of older parts of Dhaka, where the population densities are very high and has reached near saturation. However, certain pockets within these densely urbanised parts of the city are undergoing redevelopment. Developing Areas: area adjoining the core areas of the city falling under the administrative jurisdiction of DCC & Pourashavas which has developed as suburban areas and still has some space available for further urbanisation. Fringe Areas: areas in the fringe of the DMDP area falling under the administrative jurisdiction of the Union Porishads which consist of primarily low lying lands (flood plains) with agricultural landuse. These areas are charted out for urbanisation in future. 32 The spatial extent of these three zones and the distribution of population in each of these three areas are presented in the Table 2.1 and Figures 2.2 and 2.3 below. 10,11 11 Developed Area: Old Dhaka city area covering about 186.12 sq. km area Developing Areas: Extended areas in the DCC (part of the 6 Thanas: Demra, Sabujbagh, Uttara, Kamrangirchar, Badda, Shyampur) and Paurashavas (Naraynganj, Kadamrasul, Savar, Tongi and Gazipur) covering an area 309.96 sq. km Fringe Area: Rural Areas under Union Parishad (part of Demra Thana, Sabujganj Thana, Uttara Thana, Badda Thana, Shyampur Thana, Kamrangircahr Thana, Savar Upazila, Keraniganj Upazila, Gazipur Sadar Upazila, Rupganj Upazila, Bandar Upazila and Narayanganj Sadar Upajila) covering an area 1032.96 sq. km. 34445 Final Aug 2007 2-3 SENES Consultants Limited

TABLE - 2.1: POPULATION DISTRIBUTION AND DENSITIES IN 3 ZONES OF DHAKA Density 2001 (Pop/sq kms) Density 2006 (Pop/sq kms) Area (sq kms) Population 2001 Population 12 2006 Developed Area 186 5333571 28657 6439341 34598 Developing Area 310 1551891 5007 1873633 6045 Fringe Area 1032 3190930 3089 3852482 3730 Total 1528 10076392 6590 12165456 7956 Figure 2-2 Administrative Map of the DMDP Region 12 Population Data : 2001 (Source : Bangladesh Bureau of Statistics, 2001); 2006 : Estimated on Projected Growth rate of 4.15% per annum as per BBS projected Growth Rate 34445 Final Aug 2007 2-4 SENES Consultants Limited

Figure 2-3 Spatial Disposition of Development Zones within DMDP 34445 Final Aug 2007 2-5 SENES Consultants Limited

2.2 Land-use and Land Management 33 Like other developing countries in South Asia the urban population of Bangladesh has grown at a much faster rate than the rural population. As a result, in spite of the overall low level of urbanization in the country, there are considerable spatial imbalances, especially when seen in context of the rapid growth of Dhaka. Dhaka as the country s capital city is home to about 34% 13 of the Bangladesh s total urban population. This is primarily due to its central location and easy accessibility from different parts of the country, presence of administration and government and also being the industrial, trading and commercial hub of the country. The location factors coupled with its high economic potential as also the lack of any alternate urban agglomeration with similar opportunities has resulted in the influx of a large number of people from rural areas of the country into Dhaka. The problem of urban influx is accentuated by extreme rural poverty, uncertainties of agricultural production, landlessness and high rural-urban wage differentials. The rate of such influx is estimated to be about 0.3 0.4 million people per year 14. 34 To accommodate the increasing pressure of population mainly due to in-migration, the city area has grown spatially over time from about 85 km 2 in 1951 (Master Plan) to 1528 km 2 in 1995 (DMDP). However, because of inadequate planning to manage urban landuse and its development, most of the urban growth in the last decade has taken place in an unplanned and haphazard manner. Resultantly, existing urban areas have witnessed high levels of population densification with intensification of slums and vertical growth replacing horizontal expansion even though the urban infrastructure required to support such growth has not been upgraded. On the other hand, large parts of fringe areas designated for growth have not been developed for planned urbanisation. This is accentuated by skewed development of the fringe areas being developed in an unplanned manner after filling up of low lying flood plain and agricultural areas by powerful realtor groups using their influence on the government agencies, including RAJUK. Most of these new developments would only be catering to higher-middle and high income groups in the city, thereby reducing the possibility of distributing the population throughout the DMDP area and forcing the intensification of slums as poorer sections of society have no place to go. The various aspects of land-use management and its impacts on various environmental components are briefly discussed in the subsequent sections. 2.2.1 Housing, Slums and Open Spaces 35 The lack of proper housing infrastructure for various sections of the urban society is a crucial problem in Dhaka and assumes significance from the environmental point of view. With a rapid influx of population from the rural areas into Dhaka, the ability of the city to provide proper housing infrastructure to the migrant workers is under severe stress. Even though the Strategic Plan requires the provision of housing for the poor by RAJUK, it was not lucrative for either the government agency or the private sector to do so; hence many parts of the city has witnessed intensification of slums. This increase in the number of slums in the developed parts of the city and disproportionate distribution of residential land is reflected in the fact that 70% of 13 Centre for Urban Studies (CUS) : Slum Studies, 2005 14 Rate of influx Bangladesh Bureau of Statistics. 34445 Final Aug 2007 2-6 SENES Consultants Limited

the total urban population live in only 20% of the residential land while the remaining 30% live in 80% of the residential land in Dhaka 15. 36 The number of slums in Dhaka has increased from 1125 in 1998 to 4,966 slum clusters in 2005 (CUS 2006). These slums are very densely populated with and average of 0.2 million 16 people per km 2. Spatial analysis of the survey 16 shows slums are located all over the DCC 17 area, with Zone 1 having the highest proportion (11% slum area), and Zones 2 and 10 having the lowest with less than 1% slum area. Eighty percent (80%) of such slums are housed on privately owned land and many of them are susceptible to flooding. The survey also indicates that a third of the population in DCC area live below the poverty line in these slums and do not have access to basic urban and civic services like drinking water, sanitation, education and health. It is pertinent to add that the slums themselves led to further environmental degradation through discharge of untreated household waste and sewage into the surrounding water bodies. 37 The developed parts of Dhaka and some newly developed areas has witnessed a spurt in demand for apartments mainly targeted for high income groups who comprise a small percentage of the urban population. These apartments are mostly constructed by private realtors who often have high influence within the government agencies and as a result often tend to flout development regulations like the Building Construction Rules. On the other side, the demand for such apartments among high income group people was fuelled by government policy on money laundering which allows undeclared income to be invested in real estate without disclosing the source of income. Box 2-1 Slums in Dhaka A Glimpse The common slum dwellers of Dhaka mostly comprise migrants from rural areas in Bangladesh to Dhaka in search of a better livelihood and quality of life. Because of the high land prices and the unavailability of housing infrastructure for low income groups, the migrants take shelter in one of the slums within Dhaka, preferably close to their place of work. Most of the slum dwellers work as readymade garment industry workers, rickshaw pullers, household helps, ragpickers, etc., and make an important contribution to Dhaka s economic growth by contributing labour to business or by providing necessary urban services. The income level of slum dwellers varies between US$ 17 50 per month (for men) and US$ 4-21 18 (for women). Even though approximately 30% of the Dhaka s population lives in slums, access to urban services in squatter settlements are poor. Amongst the poorest people in the slums, only 9% of households have a sewer line, and 27% obtain water through piped supply (compared with 83% of the wealthiest). Spatial mapping shows that only 43 of the 1925 identified slums are within 15 Akash & Singha, 2003 16 LGED Slum Survey, 2004-2005 17 The DCC area has been divided into 10 zones Zone 1 Zone 5 in old Dhaka and Zone 10 is Uttara township newly developed by RAJUK. 34445 Final Aug 2007 2-7 SENES Consultants Limited

100 meters of a public toilet. Only 7% of slums have a public health clinic and 26% have a government school. Many of the slums have developed gradually mostly in marginal areas of the city, and in many cases in low lying areas adjoining rivers and drainage khals or by filling up wetlands. Therefore, they are vulnerable to flooding and associated flood risks. Additionally, some of the slums are considered to be illegal and often evicted by government agencies from time to time without any proper rehabilitation. Consultation with the residents of the Karail Basti slums revealed that a parallel informal system for providing basic urban services to slum dwellers has developed. Such services are mostly provided by local toughs who are called mastaans. As a result, slum dwellers, in spite of being economically disadvantaged, often end up paying higher prices in terms of rent, and other services like drinking water supply and electricity. These highly dense slum settlements often have a degrading effect on the quality of adjacent water bodies and the cleanliness of surrounding areas. The slum dwellers area also more prone to various vector borne diseases because of the lack of good quality drinking water and proper sanitation facilities. 38 As a direct effect of the unplanned urbanisation and lack of development control, Dhaka has very little open space in form of park19, gardens etc, (approximately 310 hectares)20. Of the total land area, the developed area (primarily under DCC jurisdiction) has only 14.5% open space when ideally such large cities should approximately have around 20%21 open space. Importantly, some of the areas demarcated for parks have been illegally occupied by encroachers having political influence to set up temporary markets, bus stops, slums, etc. This in spite of the fact that Bangladesh Open Spaces and Wetland Protection Act 2000 does not allow parks open spaces and wetland to be converted for any other uses. 18 1 USD =TK 70 19 Some other important open spaces in the city are Osmani Uddayan, Bahadur Shah Park, Botanical Garden, Suhrawardi Uddyan, Ramna Park, etc 20 Aboriculture Department, Ministry of Housing and Public Works 21 Green Factor would change urban landscape design, By Marieke Lacasse and Shaney Clemmons. GGLO 34445 Final Aug 2007 2-8 SENES Consultants Limited

2.2.2 Industries 39 Two important drivers of environmental degradation in the Dhaka watershed have been the export oriented economic growth, which has often been associated with use of inappropriate technology and the lack of enforcement of environmental standards by the Department of Environment. The focus of discussion here is the resultant industrial pollution. 40 There are two points of relevance here. One is the rapid growth in the number of industries in the last decade; and two, the growth and dispersal of pollution intensive sub-sectors, making management of industrial pollution difficult. 41 Growth of Industries: BKH 22 estimated that in 1994 there were 221 industrial units in the six clusters in Dhaka. DIEWRMP noted that in 1998 there were 2,200 industrial units in and around Greater Dhaka. IWM (2007) notes that there are now 3,000 units in Dhaka and over 7,000 in the watershed area. There are nearly 60 different types of industry but the base is dominated (60%) by the garment industry. It subsumes a number of processing activities, like dying, washing and printing of fibre and fabric, which are carried out in factories of different sizes. Other medium and small-scale industries include: jute mills, tanneries; metal, cement, rubber, chemicals processing units; pharmaceuticals, petroleum refining, distillery, plastics and brick manufacturing. 42 These industrial units have come up alongside or adjacent to residential houses, shopping centers, schools, play grounds, parks and hospitals. The wastes, emissions and noise from these industries have the potential to affect the health of the residents in such areas. 43 Pollution intensive sub-sectors and their dispersal: Prior to independence in 1971, all industrial activity in Dhaka was restricted to Tongi and Fatulla industrial estates. In 1995 the Dhaka Structure Plan noted that these industrial zones where under-utilised as they were poorly maintained and managed by BSCIC and did not provide the services required. With a change of policy, it allowed footloose industries to locate outside the designated areas. Given the rising cost of land, industry was quick to disperse throughout the watershed. Review of several studies (Dasgupta and Marr: 2007) showed that some of the most pollution-intensive industrial activities are dyeing, printing and washing of fabrics; chemical and oil processing. A predominant number of industries discharge untreated waste, thus externalizing the cost of cleaning up. It is useful to note that the garment and apparel industry shifted to Asia as environmental regulations in the west made it very costly to carry out certain stages of garment production. 44 The end result is that industry accounts for 60% of the pollutant load in the watershed. This pollutant load is constituted of organic and inorganic waste, including heavy metals. The gravity of the problem lies in the fact that surface water is too polluted to be treated to potable standards. This has meant increasing reliance on groundwater and high abstraction rates by DWASA and the private housing developments (these are discussed in detail in section 2.3). Furthermore, IWM (2007) have noted that geography of the watershed facilitates the interaction between 22 BKH Consulting Engineers et al (2001) Techno-economic Study for Setting up a Common Effluent Treatment Plant in the Tannery Cluster of Hazariabagh. UNIDO and Government of Bangladesh. 34445 Final Aug 2007 2-9 SENES Consultants Limited

polluted surface water and groundwater, thereby increasing the threat of groundwater contamination. 45 All major cities have areas designated for manufacturing and processing industries. The implication here is the need for DAP planners and consultants to understand the issues behind delineating industrial zones. There are two sets of problem that have to be tackled. One, is how to control and manage the industrial clusters which have already developed; and two, how to spatially manage future industrial growth. Discussion with industry is fundamental to developing ideas which would work and would not impose additional costs on industry. Box 2-2 Location of Industries in Dhaka Traditionally, the industries were located in old Dhaka Area e.g. Postagola, Laxmibazar, Imamganj, Gandaria Farashganj, Faridbad, Shankaribazar, Nawabganj, Amingola, Tantibazar, Patuatuly, Hazaribagh and Tejgaon areas. Recently, industrial units have also developed in Narayanganj, Fatulla, Panchabatee, Kachpur, Rupashi, Tarabo, Hotabo, Sonargaon, Araihazar, Rupganj on the eastern and southern side of the DMDP area and along the Dhaka-Chittagong Highway. In addition to these, a number of designated industrial areas have also come up e.g. the Tejgaon Industrial Area promoted by the erstwhile DIT (Dhaka Improvement Trust) and the Savar EPZ promoted by DEPZ Authority for small and medium industries. The industrial units operating from these areas include dyeing/printing factories, edible oil factories, paper and pulp mills, chemical industries, jute mills, textile mills, printing, garment manufacturing, engineering, moldings, welding, repairing, chemicals, packaging, used lubricant processing, washing, water bottling and many others. 2.2.3 Roads & Transportation 46 As in many major cities, transportation corridors play an important role in defining directions of growth of a city. In Dhaka, most of the major transportation corridors have developed in a north-south direction. This is primarily because of the growth of the city along the central highland axis. However, at present to create space for urbanization, the low-lying areas in the eastern and western sides are also planned to undergo urbanisation. 47 The transportation system in Dhaka is predominantly road based. However, the roads of Dhaka still occupy only 8% 23 of the total area, even after the implementation of the Dhaka Urban Transport Project (DUTP) and the Dhaka Integrated Transport Project (DITP), whereas ideally at least 25% of the total city area is required as road space to facilitate a smooth transport system in a modern city. Further, the growth of road space has been slower than growth of vehicles (80% in the last decade). In addition, the mixing of different modes of transport i.e. both motorized and 23 National Encyclopedia of Bangladesh (Banglapedia), 34445 Final Aug 2007 2-10 SENES Consultants Limited

non-motorized transport (rickshaws 3,00,000 24 in number accounting for 15.2% of the traffic and occupying 73% of the road space) has been cited as a major reason for congestion in the city. 48 The congestion is further aggravated by incidences of on-street parking in absence of adequate off-road parking spaces in the city. The problem is acute in old high-density area of the city like Dhanmondi and the Central Business Districts causing severe congestion in these areas. It has also been reported that the tendency to construct multi-storey buildings along the major transport corridors without adequate arrangements for parking of construction vehicles, storage of constructions materials etc. in contravention to the building rules 25, has resulted in aggravating congestions on certain important corridors. 49 In addition to the road-based transportation, there are two other major transport systems operating in the city. A railway line operates in the north south direction of the city. Bangladesh Railway operates standard gauge passenger trains on this route but the frequency of operation of this mass rapid transport system is relatively low. The BWTA operates ferry service to transport passengers from areas south of Dhaka till Sadar Ghat but this system has no extensions in the north. The potential of these two modes of transport have not been fully utilized. Further the inter-linkages between the three modes of transport, Railway, Roadways and Waterways is poor. As a result the passenger dispersal system from the railways and waterways is dismal and results in localized problems. This also contributes to these systems not being used as a preferred mode of transport in Dhaka. 50 The main points emerging from this analysis are the lack of collaboration and co-ordination between different transport agencies and an absence of an integrated transport planning approach. There are implications of traffic and congestion to deteriorating air quality and noise pollution in Dhaka. Detailed studies on the noise and air quality especially due to vehicular pollution have not been carried out. This aspect is discussed in Section 2.4. 2.2.4 Solid Waste 51 It is estimated that the Dhaka city area generates approximately 3500 26 tonnes/day of residential, commercial and institutional Municipal Solid Waste (MSW). With rapid urbanization, increasing per capita incomes and changing lifestyles, the rate of increase of MSW generation is also likely to increase. At present, biodegradable organic matter constitute approximately 60% of the waste. 52 The city corporation and Pourashavas are responsible for providing urban services related to solid waste in their respective areas. DCC has established a Solid Waste Management Division to manage the solid waste but this has still to affect its solid waste management strategy. The Pourashavas are still dependant on a conservancy-based approach 27. There has been very little effort both at the city as well as in Pourashavas to minimize (recycle/ reuse) the waste. 24 Officially records with DCC indicate the total number of rickshaws in Dhaka to be around only 88,000 25 The Building Construction Rules 1996, and The Building Construction Rules 2006 26 JICA Clean Dhaka Master Plan Study assuming population of 6.3 million and waste generated is 0.56 kg/capita/day.(2004) 27 The conservancy based approach primarily depends on collection of solid waste from secondary location and disposal at a some other location. 34445 Final Aug 2007 2-11 SENES Consultants Limited

53 It was reported that about 50% of the waste being collected and disposed from the city, i.e. approximately 1400 tonnes/ day of waste are delivered to dumping sites from the city. Till recently, DCC had one authorized dumping site at Matuial (3 km south-east of the DCC central office) and remaining were dumped on private lands in Berri Bund and Uttara. DCC has recently acquired a new site at Amin Bazar and is in the process of converting the open dumping at Matuial into a sanitary landfill. The principal dump site Matuial is more than 25 km from many parts of the city. Even though the Clean Dhaka Master Plan recommended upgrading of the Matuial site and acquisition of a new disposal sites at Amin Bazar, the siting of these landfills remains an issue of concern even though these sites have been cleared by both DOE & RAJUK. The DMDP Urban Area Plan questions the feasibility of the selected sites considering the spatial growth projections suggested in the Structure Plan. Thus scarcity of land is leading to selection of landfill sites for waste disposal which are environmentally unfeasible. 54 Further, there is no comprehensive system for collection and management of bio-medical waste and industrial waste. Most of these special wastes are either disposed into the public waste bins or are disposed off in open areas and in watercourses. The Solid Waste Management study 28 indicates that industrial wastes are not categorized as hazardous or non-hazardous and are disposed at the Matuial dumpsite together with ordinary municipal waste. 55 The environmental concerns associated with landuse and land management are: Box 2-3 Land Use and Land Management Environmental Concerns Incompatible development patterns leading to environmental stresses High urban densification in certain areas resulting in strain on urban services Intensification of slums resulting in environmental & health risks Selection of environmentally unsound solid waste dumping sites due to non availability of suitable land parcels Low ecological diversity as a result of degraded habitats 2.3 Water Resources and Quality 2.3.1 Water Resources 56 Even though Dhaka is surrounded by rivers on all sides and fall within the watershed of three major rivers of the Indian subcontinent, the water supply of the city is predominantly based on groundwater resources for reasons already explained in section 2.2.2. 57 The demand for potable water in the city is estimated to be over 1.5 billion litres per day (BLD) of which about 20% is supplied from the Sitalakhya river via two water treatment plants located at Chandighat and Saidabad. The rest of the water is supplied by 453 borewells operated by DWASA for supplying water to the city. In addition, there are also a number of privately 28 The Study on the Solid Waste Management in Dhaka City, JICA, 2005. 34445 Final Aug 2007 2-12 SENES Consultants Limited

established borewells which supply water to numerous apartments distributed throughout the city and it is estimated that approximately about 1300 privately owned deep tube wells operate within the city. In the fringe areas, water supply is from bore wells operated by Pourashavas, private operators and industries. 58 Thus, cumulatively more than 80% of the total water requirement in the DMDP area is dependent on groundwater. The over dependence on groundwater for supply results partially from the lack of infrastructure to treat and distribute surface water, but essentially the poor quality of surface water in the Dhaka watershed. Such intensive use of groundwater throughout the Dhaka watershed has resulted in depletion of the groundwater levels by approximately 2-3 m/year 29. 59 In addition to the concerns of the rapidly depleting water table established through a number of studies 30, the stakeholders in Dhaka have expressed serious apprehensions about the quality of water supplied from both surface and groundwater sources. Recent reports indicate that groundwater has been found to be contaminated by chemicals (mainly heavy metals) and dissolved solids, in the upper aquifers near Hazaribagh and other industrial clusters strongly indicating contamination from industrial sources. In addition, high levels of organics in influent water at the intake of the Saidabad treatment plant affects the plants capability to treat water to levels which adhere to drinking water standards 31. 60 The water supply to the slums and poorer sections of the society is limited with only about 27% having access to piped water supply, mostly through standposts. Consequently, large sections of slum dwellers are forced to buy water from local tube well owners either at high prices 32 or use polluted surface water for their daily needs resulting in serious health concerns. 2.3.2 Water Pollution 61 The rivers and streams flowing adjacent to Dhaka are highly polluted. The surface water quality in the rivers and other surface water bodies e.g. khals and ponds, etc have very high BOD 33, COD and e-coli content indicating discharge of untreated industrial effluents and sewage in these water bodies (khals, ponds). As a result of the high pollution levels, many sections of the rivers and canals in the city and surrounding areas are biologically dead during the dry season, and the water available is unfit for any human use, or even for irrigation. As a result, surface water pollution from discharge of untreated effluents impacts a considerable section of Dhaka s residents either in terms of higher health care costs associated with water borne disease or because of lost productivity. It is estimated that loss of amenity associated with contaminated surface water amounts to about 0.5% of the region s GDP 34. 29 Dhaka State of Environment Report 2005 30 Industrial Environmental Compliance & Pollution Control in Greater Dhaka Phase I, IWM March 2007 31 Country Environmental Analysis, 2006, WB 32 Slum dwellers reported paying as much as Tk. 2 per bucket of water, several times the price paid by those who had legal connections (the official price charged to consumers in Dhaka was Tk. 4.33 per 1,000 litres). 33 IWM study on Industrial Pollution (2007) indicates 330,000 kg of BOD5 are discharged into the river systems in the Dhaka watershed everyday. 34 Bangladesh Country Environment Analysis - Para 89, page 29. 34445 Final Aug 2007 2-13 SENES Consultants Limited

62 One of the prime reasons for high organic pollution of the rivers and water bodies is the poor state of sewerage and sanitation system of the Dhaka urban area. Presently, the underground sewer network covers only 30% of the area of the existing urban areas of the city, and 20% of the population residing in it. For the remaining areas, especially areas lying in the developing areas, which are witnessing rapid development recently, are mostly serviced by localized sanitation facilities like septic tanks and soak pits. During consultations, it was reported by stakeholders that in number of cases the sanitation facilities like septic tanks and soak pits are poorly or inadequately designed 35. The sanitation facilities in slum are even poorer. A large amount of domestic and human waste is held in situ these areas, some of which gets washed into the water bodies during the wet season. Access and adequacy to sanitation facilities have been a serious concern expressed by the vulnerable stakeholders. 63 Only a small percentage of sewage is collected by the underground sewer network, mostly from the southern parts of the city and is transported to the Pagla Treatment Plant. The Pagla Sewage treatment plant runs on non-conventional treatment technology of facultative ponds and treatment in such ponds is aided by duckweeds. The plant has an installed capacity of 120 MLD and presently operates at a third of its capacity. As the existing sewer system is blocked and/or leaking, only a small portion of the collected sewage is treated in the Pagla Sewage Treatment Plant and the rest either leaks into or is discharged without treatment into the surface water system. There are 19 primary discharge points to the rivers and at least 41 secondary discharge points within the city. Many of these discharge points also drain mixed effluent including untreated wastes from industrial units like tanneries, dying and bleaching units. 64 The efficiency of treatment in this particular system is not very high and the BOD load in effluent from the plant has been recorded to be as high as 200 mg/lit in previous studies undertaken 36. It is understood that being a biological treatment system, the efficiency of treatment plant is hindered by toxic wastes which flow into the system from industrial units, especially tanneries in the Hazaribagh area, where effluents are discharged without treatment into the sewer system. 35 The supernatant waste from these units is often drained into adjacent storm-water channels and drains. In addition, for these facilities, there is no systematic way of collection of sludge and often the same is drained into nearby water bodies polluting them. 36 Study conducted by JICA in November, 1997. 34445 Final Aug 2007 2-14 SENES Consultants Limited

Box 2-4 Water Pollution from Industries in Dhaka Watershed Water bodies in Dhaka are polluted by a number of industry sectors, some of which are in the informal sector. The main sectors discharging untreated effluents into water bodies, rivers and streams are tanneries, dyeing and bleaching units. The discharged effluents consist of high organic loads or toxic chemical constituents which are used for tanning, dyeing and bleaching. There are 270 registered tanneries in Bangladesh with 90%of them being located at Hazaribag on about 25 hectares of land. Most of these are nonor semi-mechanized units using old processing methods and produce effluents having high organic and toxic loads. The dyeing and bleaching units are distributed throughout the present urban area, with concentrations in Narayangang, Tongi and Savar. Some of the industries also drain effluents directly into agricultural fields thereby polluting them. The main industrial clusters and effluent hotspots of the rivers are: Tongi Khal - Tongi Industrial Area, Sitalakhya River - currently developing heavy industry strip. Buriganga River - tanneries at Hazaribagh, Sayampur and Fatullah industrial clusters in Dhaka South and Narayanganj; Balu River - Tejgaon Industrial Area; 65 In addition to sewage and untreated industrial effluents, inefficient solid waste management system resulting in open dumping of municipal and industrial wastes also contributes to pollution of surface water bodies and shallow groundwater aquifers. 66 The concerns influencing the water quality and resources of can thus be summarized as: Box 2-5 Water Quality Environmental Concerns Depletion of groundwater due to overdependence on groundwater resources Surface water pollution due to discharge of untreated sewage and effluent Contamination of land and shallow aquifers due to open dumping of municipal & industrial solid waste 34445 Final Aug 2007 2-15 SENES Consultants Limited

2.4. Air and Noise Quality Dhaka-Strategic Environmental Assessment 67 Like other major metropolises in developing countries, deterioration of air quality in the Dhaka area is a key environmental concern. Though considerable policy level initiatives were undertaken during the last decade to improve the air quality of Dhaka, the air quality improvements achieved through initiatives like the baby-taxi ban are being rapidly offset with increasing urbanization. The results from continuous monitoring of the air quality obtained from the AQMP project indicate that PM 10 and PM 2.5 levels are considerably above standards, especially in dry season, and they also show an increasing trend. Studies 37 have revealed that while motor vehicles, re-suspended dust, biomass burning (in brick kilns and by low income groups as fuels), and fugitive emissions are major contributors to PM 10, transport is the major source of PM 2.5. Unplanned development and siting of air polluting industries in areas adjoining the residential area and location of the brick kilns adjacent to the DMDP area have aggravated the situation. Contribution of air pollution from different sectors is summarised below: Figure 2-4 Air Pollution from Vehicles in Dhaka 68 TRANSPORT: Analysis of the emission inventory presented in figure above indicate that the diesel vehicles contribute approximately 80% of the air pollution from mobile sources. The ageing fleet of diesel vehicles along with the high sulphur content in diesel is considered as prime reasons for such high levels of air pollution. CNG Taxis and 3-wheelers also contribute to the NO x load. Poor maintenance coupled with poor fuel quality, traffic congestion, poor transport infrastructure planning and lack of coordination between the agencies involved in planning and executing of land use and transport planning add to the vehicular air pollution in the city. \ 69 SOLID WASTE: The practice of burning of a part of the municipal solid waste collected contributes to air pollution. The existing municipal solid waste landfill sites (both temporary and permanent) are sometimes put on fire and emit fumes and gases contributing to air pollution including methane and non-methane organic compounds, for example benzene, etc. 70 BRICK KILNS: Large number of brick kilns has been setup in the fringe areas of the city, especially in the northern parts and all along Tongi and Turag river banks. The significantly high levels of air pollution from these kilns has substantial impacts on the air quality especially during dry winter months 37 Begum et al 2005 34445 Final Aug 2007 2-16 SENES Consultants Limited

71 INDUSTRIES: Industries in Tejgaon Industrial Area are a major source of industrial air pollution. Also, the Tanneries and hide dealers in Hazaribagh area, which is a predominantly residential area, discharge effluent and emit foul odour (decaying carcasses and treatment chemicals), impacting the health of workers and residents. The rolling mills in Fatullah also pollute the air in this region. Box 2-6 Role of Rickshaw Pullers in Urban Transportation Rickshaw pullers form an important constituent of the transport system of Dhaka and they form the single most important mode of non-motorized transport which does not directly cause pollution. They mostly serve the needs of short to medium distance transportation, especially providing feeder services from houses to the arterial routes. At the same time though, this mode of transport has been identified as the main cause of traffic congestion on city roads. During discussions with rickshaw pullers in the Gulshan area, it was revealed that most of them are landless labourers and have migrated to the city for livelihood leaving their families behind. Living in Theks (Bachelor Hostels), they rent the rickshaw on a daily basis from an owner at a daily rent of around TK 50-80/day. During consultations with them, it came to light that their income ranges between TK 200 300 /day and they usually remit most of the income to their families either weekly or fortnightly. The remittance of income is usually carried out through a network of local telephone booth networks. The concerns expressed by the rickshaw pullers are: They complained that their livelihood suffer because they are not allowed to ply on certain portions of some of the main roads. They are usually unaware of the traffic restrictions and face inconvenience because of any sudden change of these restrictions. They do not receive any training on traffic rules and signs from any authority. 72 The air and noise pollution related issues are: Box 2-7 Air and Noise Environmental Concerns Deterioration of air quality due to vehicular & industrial emissions 2.5. Flooding and Drainage 73 Because of its location in the flood plains of three major river systems, the urban areas of Dhaka, most of which are low-lying areas except for the Mirpur highlands, have historically been flooded during periods of heavy rainfall in the upper catchments of these rivers. Once the rivers reach their hydraulic draining capacity, they tend to backflow into the city through the interconnected drainage channels and the peripheral rivers (Turag, Tongi, Sitalakhya, and Balu) thereby flooding the low-lying areas in and around the city. As a result, the Dhaka urban area has repeatedly witnessed flooding events. Severe river floods have occurred periodically during 1954, 1955, 1974, 1987, 1988 and 1998. In 1988, most of Dhaka was inundated by the flood except for the DND area, which was protected by embankment constructed earlier and the part of 34445 Final Aug 2007 2-17 SENES Consultants Limited

the city near Mirpur. Following the floods of 1988, the western embankment was constructed under FAP 8B (Dhaka Integrated Flood Protection Project). After construction of western embankment, the western portion of Dhaka i.e. west of the central highland has now become almost flood free, but the eastern fringes of the city is still very much vulnerable to floods resulting from the backflow of primarily the Balu River. Due to the flooding from the Balu River in 2004, 40% of the area on the eastern side of the city was inundated for approximately a fortnight. 74 The urban flooding problem in Dhaka may get aggravated because of two main causative factors and they are briefly discussed below: 2.5.1 Illegal Filling of Low Lying Areas 75 The DMDP fringes areas mainly comprise of riverine flood flow zones. As most areas in the city i.e. the DCC areas have already been urbanized the fringe areas would have to be developed for making space for future growth (accelerated Growth Policy as per DMDP). Most of these areas are low lying areas and are presently inundated annually during the monsoon months as the water level in the rivers around Dhaka rises. To make these areas suitable for urbanization, these areas have to be raised by filling up to 2-3 m. As per existing regulation, development permission from RAJUK is mandatory before developing any land as per the Land Development Act for Private Housing 2004. However, the weak institutional structure and the lack of political will of RAJUK to implement the provisions of the act (regulated filling and protection of low-lying areas etc) have resulted in unplanned land filling in these fringe areas of Dhaka for the purpose of setting up large real estate projects, targeted only at the affluent sections of the society who comprise about 5-10% of Dhaka s population. 76 Most of these proposed real estates do not have required approvals from appropriate authorities, including the RAJUK or have obtained the same using their political influences or using unfair practices. In addition, without there being any systematic plans by RAJUK for land development and development control in such fringe areas, the intrinsic ability of these flood flow zones to retain or store excess water during periods of high rainfall is getting reduced. As a consequence, the risk of flooding continues to increase in Dhaka and adjoining low lying areas which are now being charted for future development. 77 The private developers' body (REHAB) through a public appeal had suggested to regularize through the Detailed Area Plans (DAPs) all the ongoing housing projects in such areas, many of which are in violation with provisions of law. This move had been strongly criticized by the civil 34445 Final Aug 2007 2-18 SENES Consultants Limited

society and environmental groups but still no action has been taken against the erring land developers by RAJUK. Even though the law permits action against the land developers who violate the provisions of the act or even publish public advertisement without obtaining clearance from RAJUK under the Land Development Act, cases have been booked against only a few errant land developers. 78 It was reported by an expert from BUET in one of the workshops that in a recent study conducted in Boro Beraid, Santarkul, Kathaldia and Dumni moujas in the city's eastern fringe areas, severe socio-economic impacts have been reported on the original residents due to the earth filling. These people now face forced displacement from their ancestral homes as well as their traditional livelihood based on agriculture. Even though they are provided compensation amounts, in the absence of any comprehensive rehabilitation policy and with the low skill sets of the displaced people, the signs of impoverishment are even more pronounced. It has even been reported that due to the unlawful modalities adopted by the land developers, 53.2% of the affected locals are forced to sell their lands due to the tactics adopted by the developers, while 25.8% were compelled to sell just because their lands were turned into enclaves within areas filled up by developers. Illegal filling of ditches and drainage channels 79 Dhaka is surrounded on all side by river systems and crisscrossed by drainage channels. The highland areas within the city have already been developed. Population pressures and requirement for more urban land within the city boundaries have resulted in encroachment of the water canals and wetlands which acted as flood retention ponds. 80 These facts were highlighted at the stakeholder consultations during the Cross Sectoral Workshop where the representatives for civil societies presented the case of encroachments in the Hatirjheel and Begun Bari Khal, two important wetlands in the central and southern parts of the city. These two canals are linked to the Norai Khal which drains water from a large part of the city. Both these wetlands have already been encroached; approximately 1200 illegal encroachments have been enumerated by RAJUK in Hatirjheel area. Most of these were constructed by influential people. In addition, during the tenure of the last elected government, land was allocated to Hotel Hilton International, Federation of Bangladesh Chambers of Commerce and Industry (FBCCI), International Arbitration Centre and a few CNG filling stations for setting up offices etc. even though the Wetland Protection Act 2000 prohibits filling up of low lands. It has been reported that land was allotted to Federation of Bangladesh Chambers of Commerce and Industry (FBCCI) at nominal price of approx US $ 1500 without any public bidding even though it is mandatory as per the procedures of the Government of Bangladesh. 34445 Final Aug 2007 2-19 SENES Consultants Limited

81 Some government agencies, including RAJUK, DWASA, and Dhaka City Corporation (DCC), have also submitted proposals for constructing a link road or a circular road in the area to reduce traffic congestion in the city. The proposals also include constructing other structures over these wetlands. Implementation of these projects would result in greater inundation of the city s central areas. Potential Climate Change Impacts on Dhaka 82 The city of Dhaka lies at the focal point of three of the largest rivers of the Indian subcontinent in South Asia. Lying in the lower flood plains of the rivers Bramhaputra, Ganga and the Meghna, this area in central Bangladesh itself forms a part of a dynamic and active delta system. Such deltaic systems involve complex interaction between climate, catchments, deltaic deposition, tectonic subsidence and coastal regimes. At the same time, this region in Bangladesh supports an immense human population and contributes strongly to the regional and national economy. 83 However, being a part of such a complex natural system also means that this region is extremely vulnerable to natural events like floods, cyclones and coastal surges. The vulnerability in case of Dhaka is heightened because of the large and concentrated population that it supports and the rapid urbanization that has already caused immense stress on environmental resources. Climate change effects are anticipated to add to such stress with possible adverse impacts on city s population, especially the economically disadvantaged sections of the society. 84 The onset of potential climate change effects in near future as predicted in the recently published IPPC report may result in a number of interrelated adverse impacts in Bangladesh involving complex interactions between physical processes. The combined effects of subsidence and sea level rise could result in increasing vulnerability to flooding events, serious drainage and sedimentation problems, in addition to coastal erosion and land loss. These changes may result in more frequent tidal surges which may potentially affect many coastal areas, cause inland fresh water resources to be affected by salinity causing serious drinking water supply concerns and limit irrigation over large areas because of reduced flow of fresh water resources from the rivers having sources in the Himalayan glaciers. A combination of such effects will have immense socio-economic impacts in the region. In quantitative terms, for example, a one metre rise could flood almost 30,000 km 2 of Bangladesh, affecting over 13% of the population, mostly in the lower deltaic regions of the south. 38 85 At the Dhaka level, the height of the DMDP area varies between 2-6 m above sea level. The area is also known to be undergoing tectonic subsidence at an average rate of 0.62 mm/year, but can reach up to 20 mm/year 39, thus effectively lowering height compared to the sea level. In addition, a large part of the fringe areas of Dhaka comprising about two-thirds of the DMDP area 38 Source: IPCC Special Report on The Regional Impacts of Climate Change An Assessment of Vulnerability, Bert Bolin, Robert Watson, Marufu Zinyowera, Narasimhan Sundararaman, Richard Moss,1996 39 Alam, 1996 34445 Final Aug 2007 2-20 SENES Consultants Limited

are characterized as flood flow zones. These areas are extremely prone to flooding and remains under water for most parts of the monsoon season due to overflow of the channels of the rivers as discussed before. 86 As a result of climate change effects, Dhaka may get adversely impacted in the following way: Increase in flood vulnerability in the surrounding low-lying areas would act as a disincentive for the city to expand spatially and disperse the urbanization process to accommodate the rising urban population thereby coming in the way of expansion of the city which may in turn impede the economic growth linked with the capital city; The increase in flooding potential would aggravate flooding problems within the city. It has been established during earlier flood events that the aggravation of flood situation in the city has been as a result of backflow from the larger rivers which again could not drain out excess water because of tidal influences. In the case of an increase in sea water levels, this problem may get more severe thus putting the present and proposed flood management system of the city under risk; and The associated problems of climate change leading to loss of land and livelihood for economically disadvantaged people residing in the surrounding regions of Dhaka is expected to result in creation of a large inflow of refugees into Dhaka, which is the only large city in the area that can provide them alternative livelihood opportunities. 87 The concerns influencing the flood and drainage of can thus be summarized as: Box 2-8 Flooding and Drainage Environmental Concerns Increasing vulnerability of floods due to unplanned filling up of drainage channels, wetlands, low lying areas and climate change. 88 The analysis above has helped to formulate the environmental priorities discussed below. It was also clear from the above discussion that main causal links leading to environmental degradation are institutional failures, lack of enforcement, policies which provide disincentives for environmental conservation and governance constraints. These issues are discussed in Chapter 3. 2.6 Formulation of Environmental Priorities 89 The situation analysis informed the identification of environmental priorities associated with urban development in Dhaka that guided the SEA. As per the methodology adopted, the shortlisting of priorities is the outcome of an analysis of the key environmental issues affecting urban development in Dhaka, which were discussed in this chapter, and the degree of concern attached to them by the stakeholders. 34445 Final Aug 2007 2-21 SENES Consultants Limited

90 As said before, Dhaka s environmental issues associated with urban development were identified based on review of secondary information, visual surveys and discussions with stakeholders. These issues summarized in Boxes 2.3, 2.6, 2.8 and 2.11 were analytically assessed against the following criteria: spatial and temporal extent of pollution; reversible/irreversible depletion of environmental resources; impacts of environmental degradation on vulnerable groups; existence and effectiveness of pollution control mechanisms. 91 This analysis led to a categorization of environmental issues as of having high, medium and low level priority (see third column 3, table 2.1) These issues were also considered by the SEA stakeholders that ranked them as high, medium and low priority concerns (see second column, table 2.1). For the identification of priority environmental concerns, the perceptions of key stakeholders, particularly the most vulnerable to environmental degradation, were assessed through one-to-one meetings, focus group discussions and workshops following a public participation and consultation plan for the SEA. At the Interim Workshop the stakeholders ranked the concerns based on the order of priority of the concern. The stakeholders perception was subsequently ranked into high, medium and low. Subsequently, environmental priorities were categorized as high, medium or low priorities applying the criteria presented in the ranking matrix of figure 2.5 (see fourth column, table 2.1) Figure 2-5 Ranking Matrix for Stakeholder Perception Stakeholders perception of the degree of concern HIGH MEDIUM LOW Risk associated with environmental issues HIGH MEDIUM LOW High Priority Medium Priority Low Priority 92 Table 2.1 shows the results of the prioritization exercise. The following are, therefore, the high environmental priorities associated with urban development in Dhaka identified in this SEA: 34445 Final Aug 2007 2-22 SENES Consultants Limited

Surface water pollution due to discharge of untreated sewage & effluent. Depletion of ground water due to overdependence on ground water resources. Increasing vulnerability of floods due to unplanned foiling up of wetlands, low lying areas and climate change. High urban densification in certain areas resulting in strain on urban services. 34445 Final Aug 2007 2-23 SENES Consultants Limited

Table 2-1 Environmental Priorities in Dhaka 34445 Final Aug 2007 2-24 SENES Consultants Limited

Chapter 3 Urban Planning in Dhaka 93 Urban planning can be closely linked with the improvement of quality of life of citizens in a city. The quality of life again has a direct relate to the condition of environmental resources in an urban area and the footprint that intense developmental pressure have on them. Urban planning and the implementation of these plans through an appropriate institutional setup are critical to influencing environmental priorities highlighted in the previous section. The soundness of the overall urban development strategies, plans and programs and the effectiveness of their implementation through an efficient and improved institutional setup would govern the success of how environmental priorities will be addressed through a strategic planning framework as also DAP level planning for Dhaka. 94 This chapter of the SEA would analyse the overall urban planning approach that has been adopted for the Dhaka urban and peri-urban area comprising the DMDP area, the focus of the regional plans in the form of the DMDP and the sectoral plans like strategic transport plan, sanitation and sewerage master plan etc. along with the hierarchy of institutions involved, their strengths and weaknesses. The existing coordination between the various institutions to take into account cross-sectoral issues in the planning process has also been dealt with. This has been followed by a discussion of the key stakeholders involved in the planning process and an analysis of their influence on key aspects of planning. This chapter concludes with the analyses of the plans and the institutions involved with reference to plan transmission mechanisms, including governance considerations, institutional weaknesses as well as political economy issues and how these factors affect the key environmental priorities. 3.1 Overall Planning Process in Dhaka 3.1.1 Policy Guidance 95 At the apex, the planning approach for development in Bangladesh flows from various high level policies which are complemented by a host of legislations, strategies, plans and programs. However, the Government of Bangladesh is yet to formulate a definite policy with the intent of providing broad based guidance for urban development for key urban centres like Dhaka and Chittagong. Presently, though an effort is being made through an ADB supported urban reform program to formulate a National Urban Sector Policy to delineate the approach to be followed in the process and guide the pattern of urbanization in Bangladesh. 96 There are certain other national and regional level policies which can be related to various other aspects of urbanisation and are listed below: National Water Policy The Industrial Policy National Housing Policy National Environment Policy National Policy for Safe Water Supply and Sanitation 34445 Final Aug 2007 3-1 SENES Consultants Limited

3.1.2 High level Planning Focus 97 The Bangladesh Planning Commission through the Five Year Development Plans (FYPs) 40 also played a role for setting the overall planning direction for growth and development of the urbanized areas in the country. The Planning Commission acted under the general guidance and control of the National Economic Council (NEC), which is the highest policy-making body in matters of socio-economic development. The development planning of the country including urban development was done through Annual Development Programmes (ADP) within the FYP. Additionally, development projects initiated at the level of government agencies, divisions, departments, local government bodies are channelled upward through the relevant ministries to the Planning Commission. The administrative ministries concerned are authorized to approve (under recommendation from the Planning Commission) projects involving costs up to a designated level. Projects involving costs beyond that level are recommended to the Planning Commission for consideration, approval and allocation of funds. However, at present Five Year Planning has now been discontinued in favour of a long-term perspective plan. 3.1.3 Urban Planning for Dhaka 98 In Bangladesh, the concept of regional planning co-exists with a primary sector planning approach. Regional plans in the form of Master Plans were first developed for large metropolitan regions like Dhaka and Chittagong in the late 1950 s and 1960 s. The first Master Plan for Dhaka was prepared in 1959, for 20 year period covering roughly 830 km 2 with a target population little over one million assuming an average annual population growth rate of 1.75% in the city areas. However, the rate of growth of population of the city surpassed the plan targets by almost three times even during the planning period i.e., in 1981 the population of Dhaka was 3 million. So by the time the thinking for a new master plan was initiated in the early nineties, the earlier Master Plan had long become irrelevant. 99 During this time, RAJUK was established as a development and planning authority for Dhaka in April 30, 1987 by replacing the Dhaka Improvement Trust (DIT) and was given the responsibility for the metropolitan area of Dhaka covering an area of 1528 km 2. During the early nineties, RAJUK delineated a broad based Dhaka Metropolitan Development Plan (DMDP) with assistance from the UNDP/UNCHS. The development plan for DMDP, prepared in 1995, has a three-tier structure. They include: i) The Structure Plan - a long-term strategy (1995 2005); ii) Urban Area Plan- interim mid-term strategy (1995 2005); and iii) Detailed Area Plans providing detailed planning proposals for specific sub-areas. The Structure Plan and the Urban Area Plan was developed subsequently and notified in 1995. 100 The Detailed Area Plan (DAP) was conceived as the third and lowest tier of the DMDP planning hierarchy shown in Figure 3.1. As per the design laid down in the TAPP document for Preparation of Structure Plan, Master Plan and Detailed Area Plan for Dhaka: (BGD/88/052) prepared with assistance from UNDP in 1990, the DAPs were to be prepared in house within 40 After the fifth Five-Year Plan covering 1996 2001, the five-year development planning has been discontinued and planning has been guided by a poverty reduction strategy paper or PRSP that was adopted in October 2005 for 2005 2015. However, unlike the Five-Year Plans, the PRSP does not make any provision for urban and regional planning nor does it place any emphasis on comprehensive development of cities. 34445 Final Aug 2007 3-2 SENES Consultants Limited

RAJUK after building adequate capacity planning in the planning department. However, due to institutional failures and inability to develop internal capacity, the DAP preparation process had been set back by more than ten years. Ultimately, the DAP preparation was outsourced to consultants about two years back and is expected to be completed by August 2007. For the purpose of DAP preparation, the entire DMDP area was divided into 26 Special Planning Zones (SPZs) which was later consolidated in the form of five planning areas (see Table 3.1) after combining the SPZs and the planning work has been awarded to four firms of consultants. 34445 Final Aug 2007 3-3 SENES Consultants Limited

Figure 3-1 DMDP and DAP Planning Areas 34445 Final Aug 2007 3-4 SENES Consultants Limited

Table 3-1 DAP Zones and Categorisation Specific Area Area (km 2 ) DAP Zones Covered Developed Developing Fringe Total Group A Tongi, Gazipur Pourashava, Gazipur Sadar and Rupganj Upazila 103 341 445 Group B Narayanganj and Kadamrasul Pourashava, Bandar Upazila 26 198 224 Group C Most of the DCC area 186 21 207 Keraniganj Upazila Group D 181 181 Group E Savar Pourashava and Savar Upazila 62 254 316 Restricted Area 41 Airport & Cantonment 69 Total 186 213 976 1445 3.2 Regional Plans Structure Plan & Urban Area Plan 101 The Structure Plan and the Urban Area Plan (UAP) form the higher and middle level plans of the DMDP planning framework and were completed in the early 1990s with the objective of recommending measures for promoting balanced growth within the DMDP area. It was to be followed up by the formulation of an extensive set of micro level detailed area plans (DAPs) for different zones of the city. At the middle level though, the original intent was to actually prepare a Master Plan, but that got altered to a UAP during the plan preparation process for reasons that have not been fully explained in the planning documents. The non-preparation of a Master Plan meant that higher level area wise development control was not incorporated into the planning process thereby making the task of preparations of DAPs more difficult. 102 The intent of the Structure plan was to provide a long-term strategy (20 years) for the development of the DMDP Area with a population target of 15 million. The Structure Plan thus provides a policy level approach at two levels: 103 Spatial Policies: a set of policies that were attributed by geographic areas like preestablished areas, urban fringe areas and areas demarcated for new development and looking into their uses like agriculture, flood flow zones, flood retention ponds, special areas, etc. The Structure Plan provided neither land use zoning nor any policy prescriptions that would direct subsequent urban development. In fact it was a series of guidelines which were either not mandatory nor were instruments for implementation specified. 34445 Final Aug 2007 3-5 SENES Consultants Limited

104 Sectoral Policies: a set of polices listed under their subject or sectoral headings like industrial area development, informal sectors, institutional and public administration, transportation, etc. 105 The Urban Area Plan was subsequently prepared as a strategy document that was intended to provide mid-term directions i.e. ten years for the planning of Dhaka. It was expected to be an interim development management solution until the Detailed Area Plans were prepared. The UAPs covered the areas of Flood Action Plan (FAP) components 8A and 8B as well as the Tongi-Gazipur and Savar-Dhamsona areas. 106 Both planning documents emphasized suitable capacity building within RAJUK or the creation of a new planning organisation for effective implementation of the DMDP planning concept. The ambiguities and imprecision in the Plans, combined with the powers bestowed on RAJUK by its constitution, allowed the latter to ignore the Plans and to engage with the private sector developers to the benefit of both, but to the detriment of the environment. In the absence of any institutional support for the Plans from RAJUK or any other planning agency, both have remained static paper documents and have become redundant with time. Consequently, as a fallout of non-implementation of the higher level plans, the preparation of the lower level plans in the form of the DAPs have also got jeopardised. 3.2.1 Detailed Area Plans 107 The Detailed Area Plans (DAPs) which are currently under preparation for five sub-areas within the DMDP are supposed to build more detailed planning provisions for each specific subarea and be in compliance with the Structure Plan and the Urban Area Plan. At the same time, the DAPs are expected to forge close linkages with various sectoral plans as may be relevant to the specific area. Importantly, till the DAPs are prepared for each sub-area and notified, land use management functions are supposed to be exercised through the policies, guidelines, and rules found in the Structure Plan and the Urban Area Plan. However, with more than ten years of gap, these guidelines and rules at the higher level have become irrelevant because of fast paced unplanned development witnessed by Dhaka. Furthermore, RAJUK did not undertake any inhouse planning capacity enhancement as recommended in the UAP. As a result, the DAPs are now being executed by RAJUK through external consultants mainly as a standalone project. 108 Reviews of the current DAP planning process have brought to light the following issues: The DAP preparation is not guided by appropriate strategic level planning framework as the Structure Plan and the Urban Area Plan do not have any relevance at present. As a result, the DAPs for the five zones would not reflect a regional development approach for the overall development and growth within the DMDP area. The DAP planning process was found to have a very weak interface with the sectoral planning agencies and as a result, is unlikely to produce a plan that can be seamlessly 41 Restricted area comprises of the Cantonments and Airports. 34445 Final Aug 2007 3-6 SENES Consultants Limited

integrated with the sectoral strategies and plans. This is because, on one hand the Technical Management Committee which was charged to oversee plan preparation was ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared. On the other hand, the DAP consultants have also been unable to establish useful contacts with sectoral agencies for formulating respective sectoral aspects of the local level plans. In addition, as many of the sectoral plans do not have coverage over the entire DMDP area, especially the fringe areas, and therefore the DAPs for these fringe areas do not have any sectoral planning guidance at all. In our assessment, the Terms of Reference for the preparation of the DAPs are extremely ambitious and under-resourced; and the local consultants selected for plan formulation do not appear to have the technical capability or expertise to complete the task. The DAP consultants have not been provided any guidelines on demarcation of sensitive areas where urban development should be restricted because of environmental and flood related sensitivities (wetlands, flood flow zones, retention ponds, canals and drainage channels) which may lead to faulty demarcation on land use maps and thus putting such zones at risk. Furthermore, the DAP consultants appear to have limited understanding of the pollutionintensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. 3.3 Sectoral Planning 109 Sectoral planning in the urban areas of Bangladesh run mostly as a parallel process with a weak interface to urban or regional development plans. As a result, most of the sectoral plans concentrate on finding localised and short term solution to urban problems in a particular area within the DMDP. In many cases, the sectoral organisations do not have the mandate to provide services throughout the entire DMDP area resulting in exclusion of some areas like those falling under Municipalities and Pourashavas. As a result, these bodies formulate disjointed and fragmented sectoral plans for their own areas which often do not conform to the higher level sectoral policy and planning guidelines. In the section below, the key sectoral plans that relate to the environmental issues of concern are briefly discussed. 34445 Final Aug 2007 3-7 SENES Consultants Limited

Water Supply 110 The Dhaka Water Supply and Sanitation Authority (DWASA) is responsible for providing water supply within the DCC and Narayanganj municipal areas. In the remaining four municipalities i.e. Savar, Tongi, Gazipur and Kadal Rasul, the responsibility is with the respective urban local bodies. The DPHE is responsible for planning and commissioning of water supply schemes in areas outside DWASA areas. DWASA is also planning to include Gazipur, Savar, Tongi Ruganj and Purbachal in its service area. 111 The DWASA water supply strategy aims at providing clean water supply in its service area i.e. DCC & Narayanganj and presently provides for about 1.5 BLD of water to the Dhaka water supply system. The strategy proposed for the water sourcing in the short term (till 2010) is primarily dependant on groundwater sources. It has proposed that 231 MLD would be extracted from the deeper aquifers, to be implemented under the Dhaka Water Supply Project; while 131 MLD would be extracted from the arsenic free aquifers of Singair Upazila (25 km from Dhaka). However in the medium term (till 2015), DWASA intends to rehabilitate and augment the Saidabad WTP to increase treatment to 675 MLD from the present 275 MLD. In addition, to meet the additional supply requirements DWASA plans to develop four new treatment plants at Purbachal, Khilkhat, Keranigonj and Pagla I as also source water from Padma and Meghna. 112 As a long-term strategy, the authority plans to source water from Meghna (17 km) and Padma (45 km) by 2015 and 2020 respectively. The plan also aims at providing 100% water supply coverage to the urban poor as indicated in the Dhaka Water supply guidelines recently published by the Government of Bangladesh (GoB). Further in an effort to manage water resources, DWASA intends to reduce the operational losses from leaks in pipes and has made roof top rainwater harvesting mandatory in the clearance provided to private housing and land developers. 113 The urban local bodies in the DMDP region intend to extend the coverage area of the water supply network to the entire municipal/jurisdictional areas. However they have not yet developed any master plan for this purpose. There are also no current plans to utilize surface water sources in the pourashava areas and fringe areas. 3.3.2 Sewage and Sanitation 114 Planning for sewerage and sanitation sector has been traditionally a weak area compared to other aspects of urban planning in Dhaka and its adjoining areas. The Dhaka Master Plan of 1951 prepared by Dhaka Improvement Trust (DIT) or the DMDP Structure / Urban Area Plans did not lay emphasis on the sewerage sector and did not take into account the extensive urbanization of the city and related contextual problems that may arise in this sector. More recently, the National Water Policy 1999, mandated that relevant public agencies would be responsible for management of the sewerage and sanitation facilities in cities and urban areas and the emphasis on building necessary sewerage and sanitation infrastructure was also reiterated by the Millennium Development Goal set by the Bangladesh Government. 34445 Final Aug 2007 3-8 SENES Consultants Limited

115 Similarly, when the DWASA was set up in 1963, as a public sector utility to cater for potable water, sewerage and storm water drainage for the city, it prepared a Sewerage Master Plan on the basis of maximum of 2-story housing which became irrelevant with time and rapid rate of rise of population. In the late nineties DWASA carried out a number of feasibility studies to look into ways of improving the sewage management in the city and based on the results has subsequently launched a number of augmentation projects, both for increasing the sewer network and also for treatment of sewage at new sewage treatment plants to be set up. As part of these efforts to augment the sewer system in the city, five new sewage treatment plants (Diabari, Tongi, Uttarakhan, Baderteik and Kamrangir Char) along with pipelines and ancillary structures are planned to be developed. An initiative has also been undertaken to promote integrated water pollution management in the watershed of the DMDP region. Recently two initiatives namely Dhaka-Chittagong Water Supply & Sanitation Project and Dhaka Integrated Environmental Water Resources Management Project (DIEWRM) are being undertaken with assistance from the World Bank. Under these projects the sewage master plan would be updated along with improvement and rehabilitation of the sewage system in Dhaka along with construction of new sewer lines and treatment plants. A number of other activities would also be undertaken for improvement of the storm water drainage and treatment of industrial effluent under these two funding initiatives. 116 However, till date, there is no updated Master Plan for waste water management of Dhaka that takes a comprehensive look at the problems of sewage management in the Dhaka urban area. A bidding process has currently been initiated by DWASA under funding support from International Development Association (IDA), to prepare a Master Plan for this sector. 117 In terms of providing low cost sanitation for the economically disadvantaged section of population, the sanitation policy 42 recommends the development of individual and community latrines for providing sanitation facilities in slums and other informal settlements but such efforts are yet not prominent in the DMDP areas. The development of such sanitation facilities have been further emphasized in the National Water Management Plan, 2001 which recommends individual and local community facilities e.g. pit latrines, household latrines with septic tanks, community sanitation facilities and small bore sewerage system. However, no major initiatives have yet been taken in the city or in the peri-urban areas for development of community latrines and other sanitation facilities in slums and other informal settlements. Drainage and Flood Protection 118 Planning for flood prevention and mitigation has been an area of high priority in Bangladesh because of the country s high vulnerability to floods during the monsoon season. The causes for such vulnerability can be mostly attributed to natural causes with topography in a large part of the city being 2-3 metres above sea level and the high rainfall the area receives from the southeast monsoon system. This vulnerability is likely to increase with impacts of Climate Change being felt all around the world. Most of the low lying areas in Bangladesh are likely to be submerged or remain under water for several months in a year. This calls for urgency in implementing coordinated flood prevention and mitigation programs to combat this issue. 42 National Policy for Safe Water Supply & Sanitation, 1998 34445 Final Aug 2007 3-9 SENES Consultants Limited

119 The National Water Management Plan 43 drawn up by the Water Resources Planning Organization (WARPO) has clearly indicated that gravity-based drainage should be given preference for draining storm water from complex urban centres like Dhaka. The same principles have been reiterated in the DMDP Structure Plan 44, where special emphasis has been laid on the protection of the natural drainage systems e.g. water channels and ponds and reduce dependence on the mechanical systems e.g. pumping out of water after flooding being a reactive response to the problem. 120 To protect the city against floods, a number of other plans and programs have been prepared. Prominent among them are FAP-8A & FAP-8B prepared for the BWDB by consultants under funding support in the early 1990 s. After the floods of 1988, the FAP 8B was implemented and as a result the western embankment was prepared under the Dhaka Integrated Flood Protection Project. In addition to the embankment, three pumping station were constructed and one retention pond have also been developed. 121 However, the FAP 8A has not yet been implemented due to lack of funds. To reconsider the project, the BDDW has recently conducted a study that looks at the integration of the Eastern Bypass Multipurpose Project with the Eastern Embankment Project. 122 The principal organisations responsible for flood control are NWRC, WARPO, BWDB, LGED, RAJUK, and IWM. In addition to the above institutions, the organisations responsible for urban flood also are DWASA, Pourashavas and DPHE as they are involved in the storm water management in their respective areas of control. In the case of river floods even though there are a number of institutions who have authority, no coordination between these organisations exist because of the absence of an apex organization coordinating these efforts. 3.3.4 Transportation 123 The Strategic Transport Plan (STP) documents i.e. DITP and DUTP have stressed on the need for development of a road based transportation system for the city. Similarly the Structure Plan in 1995 has also stressed on a road based transport system, but considering a long-term strategy it has also highlighted the need for development of inland water transport as a parallel mode of transportation. 124 Moreover, in 2005 the apex planning document 45 recognizing the major role played by the road sector in expanding 46 the passenger movement in Bangladesh stressed on the need for shifting the focus of promotion of transport infrastructure in urban centers from road based surface modes. It points out the limitations of expanding the surface modes of transport in an urban center like Dhaka where the ownership of vehicles is increasing more rapidly than the population growth of the city. Taking into consideration the regional focus, the Strategic 43 National Water Management Plan, 2001, WARPO 44 The DMDP Structure Plan (1995-2015) 45 Unlocking the Potential, The National Strategy For Accelerated Poverty Reduction, October 2005 46 The passenger movement has increased from 35 billion passenger km. in 1984/85 to 72 billion passenger km. in 1996/97 34445 Final Aug 2007 3-10 SENES Consultants Limited

Transport Plan was developed for the entire Greater Dhaka Region 47. The plan was formulated to bring about a coordinated planning in the transportation sector in the region. The plan has stressed on development of a multi-modal transport system for the city with a combination of roads, bus rapid system and a rail based mass rapid system. A number of new roads have been proposed including a major east-west link and peripheral roads which would reduce the transportation problems in the city. However, due to the high cost involved in developing an underground metro system, it is not presently considered to be a priority. 125 Even though the transport sector has developed a regional approach in planning with the development of the Strategic Transport Plan and formulation of the Dhaka Transport Coordination Board some of the municipalities in the DMDP region have developed their local transport master plan, under the UGI Project funded by the ADB, without any interaction with the DTCB. Such misdirected planning would severely affect the gains from the regional plan. 3.3.5 Solid Waste Management 126 The Dhaka City Corporation Ordinance, 1983 and The Pourashava Ordinance, 1977 have entrusted these institutions with the function of removal and disposal of solid waste in their respective areas. These regulations however do not make it binding upon the institution to undertake house-to-house collection, transportation, treatment and disposal of waste. Thus, management of solid waste has been weak in the city and also in the fringe areas. There are no regulations in Bangladesh for management of either Municipal Solid Waste or Hazardous and Bio-Medical Waste. 127 The apex-planning document 48 recognizes solid waste management and untreated industrial waste disposal as major problems of urban environment and emphasizes the development of a solid waste management system for reduction of environmental problems. The regulatory framework must be strengthened and implemented strictly with provisions for proper and adequate incentives to entrepreneurs to ensure that all industrial wastes are properly treated before disposal. 128 The Clean Dhaka Master Plan 2005 that has been adopted by DCC encourages collection of solid waste from households but does not place any added emphasis on segregation of waste and treatment/ recovery of the waste. Composting as a method of disposal is well recognized and has been successfully implemented by Waste Concern an environmental NGO. It has introduced Barrel Type composting in slums and traditional composting in non-slum areas in two wards in the DCC area. However in other areas, no such initiatives have been taken or have been encouraged by the Clean Dhaka Master Plan. Many of these areas still depend on dumping of MSW directly to the existing dumping sites. 47 It consists of the area between the Padma and Meghna Rivers. The area contained between the V shape formed by the confluence of the two rivers is wholly contained within the Dhaka division and comprises of six district namely Dhaka, Ghazipur, Narsingdihi, Manki ganj, Munshiganj and Narayanganj. 48 Unlocking the Potential, The National Strategy For Accelerated Poverty Reduction, October 2005 34445 Final Aug 2007 3-11 SENES Consultants Limited

3.3.6 Industrialization 129 Though there are no heavy manufacturing industries in the DMDP area, the number of pollution intensive industries has grown rapidly in the last decade. The effluent and emissions from the existing small and medium scale industries are a major reason for water and air pollution in Dhaka. The Environment Policy 1992 and the Environment Conservation Act 1995 has laid strong emphasis on the control of industrial pollution. The policy states that a systematic environment assessment has to be undertaken before starting any industrial operation. Guidelines for project level Environmental Impact Assessment were also established drawing power from the Environmental Conservation Rules, 1997. 130 All projects are categorized into one of four groups: Green, Orange A, Orange B and Red. The environmental clearance applications submitted by the project proponent are verified 49 by the divisional offices and sent to the Environmental Clearance Committee of the DOE 50 in Dhaka and then passed on to the Director General for clearance. The clearance conditions make it mandatory to renew the environmental clearance annually, but this aspect of legislation has not been enforced. The Environment Assessment process also requires the project proponent for industries to obtain site clearance before initiating any construction activity on the ground. However, the process has proved to be ineffective because of technical in-competencies in DOE and due to collusive relationships between industry and the DOE. Even though the DOE has initiated some modification to the legislations e.g. Environment Court Act 2000 (amended 2002) to ensure stricter compliance with environmental legislation, there has been no initiative by the department to enact legislation in some important areas e.g. Treatment and Disposal of hazardous waste, Siting Guidelines of Industries, Management of Solid Waste (Municipal and Industrial), Effluent Discharge Standards for various types of industries etc. 3.3.7 Housing and Slum Improvement 131 The need to provide housing for the low income group was recognised in the Structure Development Plan. Annex-B of the Plan provides the principles for Guided Land Development. Among others, it notes that the demand for low income housing should be met. Clearly this has not happened. 132 More recently, for low income groups, the National Strategy for Accelerated Poverty Reduction (PSRP) links inadequate housing as one of the reasons for poverty. It considers housing problem of the poor as an integral part of poverty reduction programme and recommends a number of strategies like provision of housing loan at cheaper rates and stress on implementation of program for resettlement of slum-dwellers, the disadvantaged, the destitute and the shelter less poor. The government has also initiated a housing loan scheme, called the 49 For Green and Orange A category projects, once the inspector submits his report (typically within 5-7 days) the divisional head makes a decision within three days of receiving the report. Files for Orange B and Red category projects are sent to the Senior Chemist/Assistant Director. 50 DOE offices in each of the six divisions receive applications and issue Environmental Clearance Certificates for proposed investments within that division. The divisional offices verify supporting documents and pass it on to the divisional head, who assigns an inspector for follow-up 34445 Final Aug 2007 3-12 SENES Consultants Limited

Housing Fund with the intent of improving the quality of life of the poor people by providing loans to construct safe and durable houses. However, even though the apex plan and programs lays stress on the housing problem, there have been no follow up action at the action plan level to address the requirements of housing for the urban poor and vulnerable sections of the society. NGOs and Civil Society Groups have also not taken up any worthwhile programme in this regard. 133 In several Asian countries and in the UK the problem is being tackled more directly and effectively. Real estate developers are required to allocate a specified proportion of land being developed for low income housing. RAJUK, as the main urban development authority, has set no such stipulations on the developers. This is explicable by the fact that it is not so profitable to get involved in the provision of low income housing. 3.4 Institutional Set up for Governance & Urban Planning 134 Bangladesh is a parliamentary democracy with the president as the head of state and prime minister and council of ministers in charge of the executive functions 51. The ministries and its associated bodies responsible for policy formulation and execution are presented in Figure 3.2. At the same time, local self-governance is also encouraged in the constitution. 135 A number of ministries and associated departments are involved in the planning and administration of Dhaka. As many as 55 organizations of national, sectoral and local levels are effectively involved in planning and development of urban affairs in Dhaka Metropolitan Development Area. 136 The key functions of urban planning and development is with two ministries and a wide range of central department s, utility agencies, development authorities and urban local bodies. The two ministries primarily responsible are Ministry of Housing & Public Works (MoW) and Ministry of Local Government, Rural Development and Cooperatives (MLGRD). Physical planning, development, control, and housing functions are under the MoW, while urban utilities, infrastructure and urban administration are the responsibility of the MLGRD. Urban programs of the MOW are implemented through the Public Works Department (PWD), the Urban Development Directorate (UDD), and the Housing and Settlement Directorate (HSD). 137 Among the other institutions involved in planning and implementation of the city management, the more comprehensive responsibilities lie with RAJUK and DCC. Other organizations have specific sectoral roles and responsibilities e.g. National Housing Authority - housing, Dhaka Water Supply and Sanitation Authority (DWASA) - water and sewerage, Road and Highways Department (RHD) - major intra and inter city roads, the Dhaka Metropolitan Police (DMP) - traffic management and maintenance of law and order; and the Department of Environment (DOE) - Environment. 51 Interim Government: Bangladesh is presently being governed by an Interim Caretaker Government which is headed by the last retired Chief Justice of the Supreme Court as its Chief Advisor (with status of Prime Minister) and advisors with status of ministers assisting him with governance. 34445 Final Aug 2007 3-13 SENES Consultants Limited

Figure 3-2 Urban Governance Setup and Flows of Authority 138 The design and development of water supply and sanitation systems is the responsibility of the Department of Public Health Engineering (DPHE), except for Dhaka and Chittagong, where autonomous Water Supply and Sewerage Authorities (WASAs) are operational. These authorities are independent of the local municipal governments and their Chairman reports directly to the Secretary of the MLGRD. Maintenance responsibilities of most of the physical infrastructure built by the developmental authorities are passed on to the local governments. 139 In addition, two kinds of local government institutions operate in the urban areas of Bangladesh and share responsibilities with the other department and agencies for the urban planning and plan implementation functions. Municipalities (locally called Pourashavas) or Corporations form the urban local body, which are elected by the citizens and operate under the jurisdiction of the MLGRD. In addition, special purpose developmental authorities like the Rajdhani Unnayan Kattripakha (RAJUK) for the larger cities have been created under the MoW and are charged with the preparation of master plans and have legal powers covering developmental planning and execution. The development authorities such as RAJUK are appointed by the government and are also entrusted to undertake infrastructure works and land development together with estate management of commercial and residential schemes. The interactions between the planning and administrative institutions have been illustrated in the Figure 3.3 below. 34445 Final Aug 2007 3-14 SENES Consultants Limited

Figure 3-3 Interaction between Planning Institutions RAJUK Pourashavas, City Corporation, Union Porishods Sectoral Agencies (DWASA, BTWA, DOE, etc 140 However, in practice, coordination and sharing of information pertaining to planning and plan implementation between various agencies have been very weak and non-transparent. Though the mandate of RAJUK was to build such coordination between various other departments and local bodies and develop common strategies for urban development in Dhaka, RAJUK has been unable to perform its role in this direction because of absence of leadership. 34445 Final Aug 2007 3-15 SENES Consultants Limited

Figure 3-4 Principal Agencies Related to Urban Planning in DMDP Region 3.4.1 RAJUK An Institutional Analysis 141 RAJUK was established in April 30, 1987 by replacing Dhaka Improvement Trust (DIT) as the development authority for Dhaka Metropolitan Development Plan area and has been accorded legal powers for developmental planning and execution. 142 At present, RAJUK is the key urban agency responsible for overall planning for the DMDP area in coordination with other sectoral agencies. It is also responsible for the formulation and monitoring of the Detailed Area Plans (DAPs) in accordance with the overall guidance provided by the higher level plans (Structure and Urban Area Plans). 143 The main functions of RAJUK include: Responsibility for planning and development of the city in consideration of the existing policies and the multi-sector investment programs of different related agencies. Undertake activities like construction of roads, culverts and bridges and also development, excavation, and filling of land as required for the development of Dhaka. 34445 Final Aug 2007 3-16 SENES Consultants Limited

Project level planning and design (including conceptual design, selection of materials, design and construction codes and standards, etc.), feasibility studies, project programming and time scheduling etc. Exert development control as per the provisions of the Building Construction Rules; this includes providing approval for new area development, land filling, etc. Approve any use of land or any type of construction by issuing land use clearances from its authorized sections. Provide metropolitan development management leadership, and is entrusted with development of strategic planning function and promotion of poverty alleviation-oriented programs. 144 RAJUK is now a public body managed by a board comprising of a chairman and not more than five members. The chairman is the principal executive of RAJUK and the other members are government officials. All members of the Board are full time officials with specific responsibilities within the broad framework of the organization set-up having five different divisions. The approved organization structure of RAJUK along with estimated number of staff per division is presented in Figure 3-5 below: 145 A review of the organizational setup of RAJUK indicates that the division responsible for development has staff strength of about 50% of the total staff followed by the planning department with about 28% staff. However, within the planning division, only the planning department is primarily responsible for the DMDP plans and therefore for formulation of the DAPs. Though there are 51 approved staff for this department, in effect, there are only 4 planners in RAJUK to plan and also oversee the DAP planning process for an area as large as 1,500 km 2. 34445 Final Aug 2007 3-17 SENES Consultants Limited

Figure 3-5 RAJUK Organizational Structure Box 3-1 RAJUK SWOT Analysis STRENGTHS Mandated to be principal planning authority for the entire DMDP region and have been legally accorded powers to fulfill the mandate. Broad based regional level planning has already been undertaken under RAJUK and notified in the form of Structure Plan and Urban Area Plan. The plans are supposed to govern urban development of Dhaka till 2015. It is a cash rich organisation as its collection rate is high. Its main sources of income are from selling and developing commercial plots; land auctions; interests from deposits put down by prospective buyers; fees for providing planning permission; penalties levied on illegal construction; and from interest earned when fees and fines are not paid on time. WEAKNESSES Weak ownership of the DMDP plans. The planning department of RAJUK is under-resourced and not appropriately staffed. The five members of RAJUK are direct central government appointees, some of whom have little background in urban planning and development. These direct appointments have led to the politicization of membership. It has transformed into a centralized organisation with limited reach at the ground level resulting in weak implementation and supervision of the plans. 34445 Final Aug 2007 3-18 SENES Consultants Limited

RAJUK was mandated to build coordination between various departments and local bodies and develop common strategies for urban development in Dhaka. It has been unable to perform its role in this direction because of absence of leadership. Has a poor track record of coordination with the other planning and implementing agencies. Has been ineffective in formulating detailed development control guidelines on number of critical aspects, including demarcation of areas to be land filled, sensitive zones, etc. There is an un-questioning and uncritical approach to implementation among the senior bureaucrats and professionals. OPPORTUNITIES Has been provided the authority to sanction plans in the entire DMDP area under the Building Construction Rule 2006. The Planning wing is being gradually revived and currently DAPs are being prepared under the supervision of this department. The formulation of DAPs is an opportunity to amend policies and improve overall urban environmental management. THREATS Acts both as planner and developer, resulting in conflicting roles. Has conflicting roles with Pourashavas and DCC with respect of land development and permitting; In perception of the stakeholders, it has not taken adequate initiatives in improving the city s environment or the quality of life of the citizens, especially the poor and the vulnerable. Stakeholders are of the opinion that the organization s actions favour the powerful sections of the society with political influences and its staff is therefore prone to engaging in corrupt practices. 146 In addition, an analysis of the overall institutional setup for urban planning highlighted the following weaknesses in the system which impedes effective planning for the DMDP area: While the Planning Commission is responsible for allocating government expenditure and approving high value urban development projects, it generally does not coordinate at a level below the national level. As a result, funds for urban development within DMDP area are allocated to multiple agencies, including the urban local bodies, leading to some plans working at cross-purposes. Major urban functions are distributed between two different ministries (MOHW and MLGRD), neither possessing lead powers for urban development. As a result, a major institutional conflict arises from the distribution of key urban activities between these ministries. Even though planning, housing, development control and certain land development functions are carried out by the MOHW through RAJUK, some of these activities are also undertaken by the urban local bodies which are under the MLGRD. Thus in absence of a body with appropriate legal and financial powers, there are no overall planning and implementing mechanisms. 34445 Final Aug 2007 3-19 SENES Consultants Limited

The inability of RAJUK to play a leadership role in urban planning and exercise strategic influence on other sectoral agencies has resulted in other agencies taking up planning initiatives on their own without any coordination with RAJUK. In addition, coordination between the various agencies (more than 55 in number) is very poor in spite of having overlapping responsibilities and a role to play in terms of planning or plan implementation in Dhaka. The government agencies and urban local bodies who have jurisdiction of the DMDP area have inadequate capabilities of urban governance and lack of transparency in terms of planning and project implementation. In many cases distinct vested influences in governance can be observed in favour of interest of people close to power and especially, the members of the ruling political party. The Ministry of Environment and Forests in general and the Department of Environment in particular, lack the resources and trained manpower to effectively monitor compliance with environment management and pollution control legislation, even at the Dhaka level. They also do not have the power to play the role of a watchdog agency, especially when other government agencies (for example DWASA) are in non-compliance with standards. 3.5 Analyzing Stakeholder Influence in Planning and Plan Implementation Process 147 The prevailing urban planning process did not attach much importance to the views and opinions of key stakeholders thus promoting a system that was neither transparent nor accountable to the stakeholders of concern. As one of the objectives of the SEA process is to factor in the opinions and concerns of relevant stakeholders into the planning process and make it more responsive to their needs, it was planned to carry out a systematic analysis to understand their stakes or interests, the importance of their priorities and the extent of influence they can bear upon the urban planning process. 148 The analysis can also be considered to be significant because for the first time, the DAPs currently being prepared in parallel emphasize on establishing a more inclusive planning process for local level plans through a process of consultations with all stakeholders who may benefit or may be affected by implementation of such plans. Hence, it was felt that the stakeholder analysis would provide a clearer understanding of the current status of the stakeholders, vis-à-vis the planning process while at the same time equip the SEA process with vital information on their capacity to facilitate or oppose reform in urban planning and bring about environmental improvements through recommendations that emerge from this study. 149 The result of the stakeholder analysis is presented in the form of a Stakeholder Matrix in Figure 3.6 and main stakeholder-wise findings are also briefly discussed in the section below. 34445 Final Aug 2007 3-20 SENES Consultants Limited

Figure 3-6 Stakeholder Analysis Matrix IMPORTANCE Low Medium High Land Developer REHAB High RAJU Urban Elites INFLUENCE Medium Industry Association Local Bodies - Administrative DAP Consultants Academic & Tech. Inst Env. Lawyers Association; Env. Interest Groups Sectoral Agencies Local Bodies - Political DOE Vulnerable groups Low RAJUK: Though RAJUK was mandated to play the role of the apex planning institution for the Dhaka DMDP area, it did not build up internal capacity to undertake urban planning for a rapidly growing and complex city like Dhaka. As a result of this inability to mature into an institution for formulating strategic and regional level plans for the DMDP area and continually adjusting them when required according to ground realities, it has been unable to exercise its leadership role and bring about coordination between the numerous sectoral agencies and departments responsible for urban development in Dhaka. Gradually the focus and the priorities of the organisation have shifted to the more lucrative functions and it now takes more interest in development and approving related work, in the process it has downgraded its own position as the apex planning authority for DMDP area. Consequently, it is now accorded considerably lower importance in the planning process of the DMDP region. In addition, though RAJUK is successful in exerting some influence on the development pattern of Dhaka because of powers vested in it through legislation, stakeholders consider such influence to be primarily favouring powerful and economically stronger sections of the society, thereby weakening its neutral standing and credibility as a planning and development organisation. Urban Elites and Realtor Groups: The urban elites and the realtor lobby have been able to incorporate their priorities into the planning process, sometimes by circumventing 34445 Final Aug 2007 3-21 SENES Consultants Limited

legislative provisions which do not favour them. This is in spite of the fact that they form a small percentage of the urban population. They have also been able to leverage the planning process in their favour by maintaining close ties with the elected representatives and by influencing the administrative setup, sometimes by using unfair means and tactics. Technical / Academic Institutions: The technical and academic institutions who could have played a important advisory role by providing technical support to urban planning process and also at the same time, could have played a neutral role in monitoring their implementation, have been unable to do so because they lack influence on the administrative setup. For example, important institutions like the Bangladesh University of Engineering and Technology (BUET) or its alumni have been unable to make any significant contribution in the DMDP or DAP plan preparation process or its monitoring and supervision in spite of having a regional planning department. Department of Environment (DOE): DOE is mandated to be the agency responsible for protecting the environment, but lacks the importance that should be accorded to a monitoring and watchdog institution as per various environment legislations, including the Environment Conservation Act. This is largely because DOE has failed to be an effective monitoring agency. Moreover, given the low priority that is accorded to environmental issues by various other government agencies and other stakeholders like industrial operators, and lack of internal capacity to highlight such issues to the stakeholders of concern for taking priority action, it is also unable to exert its influence to implement environmental protection measures in general and specifically those which are related to urban development in Dhaka. Vulnerable and Economically Disadvantaged Groups: In spite of forming the majority of Dhaka s urban population, they have traditionally been accorded very low importance and bear minimal influence on Dhaka s urban planning process. The reason can be attributed to the fact that a significant percentage of them are migrants to Dhaka and do not have voting rights 52. As a result, in spite of making a considerable contribution to Dhaka s economic growth and making provision for much needed urban services at very low costs (housemaids, waste pickers, rickshaw pullers) their efforts are often not recognised by stakeholder groups who are powerful and influential and are considered to be a part of a large informal system. They can exert little or no bargaining power with the political and governance system to win their basic rights pertaining to housing, water, sanitation, health, electricity etc. for living decently within the city. 52 These people are immigrants to Dhaka and are unable to prove their residential status in Dhaka and thus are not enlisted as voters in Dhaka. Thus they cannot cast their votes in Dhaka but do have the right to cast their votes in their native place. 34445 Final Aug 2007 3-22 SENES Consultants Limited

Civil Society Organisations: The Civil Society Organisations have not yet been able to build a strong case for environmental protection and improvements and get sufficient support from the masses or affected stakeholder groups to build pressure on the government setup or on players contributing to environmental degradation. Part of the problem seems to be the low levels of education and environmental awareness among a large section of Dhaka s urban population. 3.6 Analysis of Planning Framework in Context of Environmental Priorities 150 Analyses in the previous sections have shown that a large number of institutions and sectoral agencies can influence the nature of urban growth and the environmental priorities in Dhaka. It is necessary to understand the strengths and weakness of the different plans and institutions. Additionally, an insight is required into the causative institutional and governance factors which have prevented the formulation and/or the implementation of most plans; thus leading to environmental degradation. These understandings will inform the design of interventions that address the weaknesses and governance issues. 151 This section analyzes the linkages between different components of the planning framework, their associated institutions and the perception of stakeholders with respect to the environmental priorities. 3.6.1 High urban densities and strain in urban services 152 The DMDP Structural Plan has provided directives to optimize land resource development through infilling of under-utilized land, redevelopment of land in lower density communities and upgrading of the physical and social infrastructure to affordable and appropriate levels in accordance with densities. The Structural Plan has also emphasized the densification targets which accompany infrastructure consolidation targets for development of fringe areas and new urban growth areas. Though the onus of directing the development was primarily with RAJUK, being the apex planning authority in DMDP, these policies have failed. RAJUK has found it inconvenient to prioritize any development area for improvements in Developing and Fringe Areas as most illegal land-filling are found in these areas. Majority of the urban growth is only restricted in the developed area, as a result there is severe stress on physical and social infrastructure in the already over-crowded area. 153 Coordination with different sectoral agencies for development of physical and social infrastructure in the Developing and Fringe Areas and planned urban growth in these areas was to be carried out by RAJUK. The sectoral agencies being under different ministries, RAJUK has very little influence over these agencies, hence, the inputs of these agencies in the planning process has not been available. The absence of any agency in DMDP, which wields powers cross-cutting all ministries has resulted in comprehensive regional plans not being developed for Dhaka. 154 Local level plans i.e. DAPs, which are expected to delineate the land use, infrastructure development etc., have been delayed by more than ten years. Thus, the city has developed 34445 Final Aug 2007 3-23 SENES Consultants Limited

without micro-level planning during the last decade. Therefore, certain areas within the city have witnessed increased overcrowding; new areas developed in the Fringes Areas are mainly low lying and are inundated each year by floods. Furthermore, land development activities have resulted in filling up of wetland and low lying areas with consequent loss of natural features e.g. sink for storm water runoff. 155 Legislations have been developed in Dhaka to control problems through the Building Construction Rules 2006 and the Land Development Act 2004. Even though the Rules are comprehensive and can be effective instruments for controlling development throughout the watershed, the implementation of the Rules has been delayed. Stakeholders feel that the influences of vested interests on the implementing agency as well as the conflict between jurisdictions of the local bodies and RAJUK have set back the planned development process. The conflicts in jurisdictions of the agencies arises from the planning and approval powers provided to the local government under the Town Improvement Act and the Building Construction Rules which have designated RAJUK as the sole authority for issuing permits within DMDP area. 156 To control development of the Fringe Area the Land Development Act makes it mandatory for the private housing infrastructure developers to take permission from RAJUK after clearly delineating the level of filling required and demarcating and developing appropriate plans for protecting natural drainage channels. This act could have been effectively used for regulating the unplanned filling in fringe areas and address the associated problems due to changes of topography of the area. However, lack of political will of the implementing agency has resulted in these legislations being unable to control the unplanned development in the fringe areas. 3.6.2 Surface water pollution due to discharge of untreated sewage & effluent 157 The issue of surface water pollution in Dhaka which has been identified as a priority in the SEA has been addressed through the existing planning framework primarily through the spatial plans (e.g. DMDP Structure Plan), Sectoral plans (e.g. DWASA Sewerage Master Plan, ad hoc sanitation plans of Pourashavas) and national level policies and legislations. 158 National Policies have mandated treatment of sewage before discharge and have directed local bodies to develop sanitation facilities within their areas of jurisdiction to protect surface water bodies from pollution. The DMDP Structure Plan stresses the prevention of pollution of surface water sources around Dhaka so that they can be used as a sustainable source of drinking water. However, no regional plans have been formulated for abatement of surface water pollution in the Dhaka Watershed. Though some sectoral plans like the DWASA Sewerage Master Plan have been formulated and this has planned for coverage of the DWASA service area through sewer networks and also for construction of five new STPs. Since this infrastructure has only been planned for the DWASA service area (developed area) it would cover only 30% of the DMDP area. In areas outside DWASA service area, under the local bodies 53 (developing and fringe areas) ad hoc plans based on low cost sanitation facilities are being prepared because of the institutional incapability in formulating plans for sewerage of the area under their jurisdiction. Thus large areas of the DMDP comprising of the developing and the fringe areas do 53 Kadam Rasul, Gazipur Pourashava and the union Porishads in DMDP area 34445 Final Aug 2007 3-24 SENES Consultants Limited

not have any plans for treatment of sewage clearly indicating that transmission of policies into plans in DMDP has been weak, and also indicating that no single agency is responsible for planning for sewerage in the entire area. 159 Some programs e.g. Dhaka Chittagong Water supply & Sanitation Program which includes the construction of a CETP for Tejgaon have been formulated. Even though these are positive steps, it has been observed in the past that lack of incentives for involvement of stakeholders in these programs has often resulted in limited success of these projects. A case at point is the scheme launched recently by DOE whereby the industries have been provided with incentives in the form of reduced duties on imported equipment for installation of effluent treatment mechanism. The scheme met with limited success, as there were no disincentives for the industries to discontinue from the present process whereby they can externalize the cost of treatment. 160 The Environment Conservation Act 1995 (amended) also emphasizes control and abatement of environmental pollution. Even as part of the permitting process of real estate development DWASA has developed guidelines which make it mandatory for developers of housing projects to develop sewage infrastructure at every housing project. The multiplicity of organisations involved in permitting (RAJUK and DWASA), weak institutional setup of RAJUK and DOE as well as no clear mandate of a single organisation for supervision of the permitting conditions seriously limits the effectiveness of DWASA guidelines. Even though the surface water pollution could be restricted by the Act of 1995 weak institutional setup of DOE, prevents effective monitoring, and also curtails the effectiveness of this legislation. 34445 Final Aug 2007 3-25 SENES Consultants Limited

3.6.3 Depletion of groundwater 161 Depletion of groundwater resource due to over dependence on groundwater has been identified as a priority environmental problem in Dhaka. Under the existing planning framework the National Polices (National Water Policy 1999), regional plans (DMDP Structure Plan), Sectoral plans (e.g. DWASA Sewerage Master Plan, ad-hoc sanitation plans of Pourashavas) and legislations have provided directions for addressing the concern of over use. 162 The National Water policy and the DMDP structure plan specifically emphasize that the groundwater resource should be protected and the main source for water supply to urban areas should be surface water. It also directs the government to identify the scarce groundwater zones and restrict abstraction in such areas. In spite of such stringent policy level guidelines, no regional plans demarcating the groundwater conservation areas have been developed in the DMDP. Even the DWASA master plan is dependent on groundwater, for the short term (till 2010) and medium term (2010-2015) for water supply. The dependence on groundwater would reduce in the long-term (beyond 2015) with the sourcing of water from Meghna and Padma but considerable amount would still be extracted from groundwater sources. However, outside the DWASA service area, no comprehensive plans for water supply have been developed. The water supply is still based on ad hoc plans which are dependent on groundwater as source. 163 To restrict the abstraction of groundwater, The Groundwater Management Ordinance, 1985, was promulgated which mandates the licensing of tube wells by the Thana Parishad. However the Thana Porishads as other institutions in DMDP, did not have the institutional capability for implementation of such legislation. 164 In the absence of a single planning authority for water supply in the DMDP, comprehensive water supply master plan for the entire area cannot be undertaken. 3.6.4 Increasing vulnerability to floods 165 The issue of increasing vulnerability to flooding due to unplanned filling up of wetlands and low lying areas, which has been identified as a priority in the SEA, has also been addressed through the existing planning framework. This is primarily through the spatial plans (e.g. DMDP Structure Plan), sectoral plans (e.g. Eastern Embankment Project, ad-hoc drainage plans of Pourashavas) and national level policies and legislations. 166 The National Water Management Plan has given emphasis on gravity based drainage system. However, none of the major projects like Flood Action Plans or Detailed Area Plans have stressed on the protection of the natural drainage system. In the already developed areas, encroachment has occurred on a number of natural drainage channels by the land developers with the help of their powerful political influences. At times the natural drainage system has been lost due to wrong implementation plans by the sectoral agencies. These deviations to the DMDP Structural Plan have occurred even though the plan restricts the land development to avoid obstructions to flood flow, within the designated flood plain areas. This has been possible as agencies mandated with the task (BWDB, RAJUK) have not developed guidelines for 34445 Final Aug 2007 3-26 SENES Consultants Limited

preparation of lower level plans (e.g. demarcation of flood flow zones on RS & CS maps) and formulate a mechanism for restricting development of these areas. 167 The DAPs, as being prepared presently, may also result in shrinkage of flood retention as the terms of reference for the DAPs suggest gradual phasing out of major retention ponds. Shrinkage of flood retention ponds would result in emphasis on engineering solution like pumping. The lack of appropriate technical capability of the planning process would further reduce the effectiveness of the plans even as they are prepared. 168 The proposed eastern embankment project has been formulated for the construction of embankment only along the western side of the Balu River. However, a large portion, area between the Balu and Sitalakhya Rivers would still remain unprotected, and is vulnerable to flooding. Other than these mega projects, local level drainage projects have been undertaken by local bodies for the problem of water logging purely on an ad-hoc basis. Only in few cases technical expertise of specialized organisations for water modelling and flood control e.g. IWM have been utilised, but in most other cases, these projects have been developed with the local knowledge and myopic vision of the elected representatives who are inclined to develop short term solutions as they need to keep the electorate happy. 169 To protect the wetlands and open spaces, the Urban Areas Open Space and Natural Wetland Protection Act, 2000, also has provision for demarcation and notification of wetland. However, agencies responsible or having ownership of these areas (RAJUK, Land Revenue Department, Fisheries Department, BIWTA, DWASA) have neither demarcated wetlands nor notified on the RS & LS maps. In the absence of legal notification, numbers of wetlands are filled up by the developers and also allowed encroachment by the slums. It is felt that political economy considerations have played a part in the delay of notification of the wetlands. 170 The following three pictures represent the flood retention ponds being retained or created based on three different plans. They highlight the inherent problem of coordination between regional agencies and line ministries and the lack of a single planning authority responsible for flood prevention and control in the DMDP area. Both the FAP 8A and the Structure Plan prepared in the early 1990 s identified flood retention ponds in the low lying areas on the western side of Dhaka. Even though these flood retention ponds were planned, the space for these ponds was not reserved by the respective agencies. As a result much of these ponds/lowlying areas were filled up and occupied by land developers. As eastern embankment project could not be developed in reasonable time, the project is once again being updated and it is apparent from the figure above that location identified for the flood retention ponds have been designed along the embankment contrary to the inland water bodies identified in the earlier studies. 34445 Final Aug 2007 3-27 SENES Consultants Limited

Figure 3-7 Proposed Flood Retention Ponds as Demarcated in FAP 8A 34445 Final Aug 2007 3-28 SENES Consultants Limited

Figure 3-8 Proposed Flood Retention Ponds as Demarcated in DMDP Structure Plan 34445 Final Aug 2007 3-29 SENES Consultants Limited

Figure 3-9 Proposed Flood Retention Ponds as Demarcated in Eastern Bypass Project 34445 Final Aug 2007 3-30 SENES Consultants Limited

Chapter 4 Risks and Opportunities of Planning Framework 171 This section of the SEA report analyses the risks associated with the environmental priorities given the existing planning framework and institutional weaknesses identified. The focus of analysis would be (i) on the gap that exists between the higher and lower level planning mechanisms and the risks that have resulted because of the absence of Detailed Area Plans in the city to control and regulate the urban development process; and (ii) the possible environmental threats that may emerge in future because of the lack of coordination between governmental agencies responsible for urban development and their inability to integrate regional and sectoral plans into a holistic planning framework. 4.1 Land and Land use Management 172 High urban densification and strain on urban services - One of the key environmental priorities that has been identified through the systematic environmental analysis and stakeholder consultation process pertains to the high densification of population in already developed areas while leaving out fringe areas from the ambit of planned and structured development. Because of the weak implementation of higher level strategies and absence of proper landuse plans, the growth within the already developed areas have taken place in a random manner, sometimes in contravention of existing development control legislation or by using loopholes in them. As a result, land resources within the city have been put under stress, wetlands within the city have got filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress thereby resulting in a consequent strain on environmental resources and components. 173 Unplanned development in fringe areas and encroachment - With decreasing scope of large area development within the already developed parts of the city, large areas in the developing and fringe areas are being taken up in line with the overall direction set by the higher level urban policies (accelerated growth and new area development in fringe areas). However, in the absence of specific and systematic growth plans for this very large fringe area (compared to the existing urbanised area), the new development runs the risk of being mismanaged. Such development will also happen without the provision of adequate urban services and infrastructure thereby in contravention of the lower level planning framework to be prepared for these areas. As a result, the following would exacerbate the existing priority environmental risks: Lack of proper urban services and infrastructure for newly developed areas that will prevent its ability to urbanise to the optimal level. Increase of land prices as a result of speculation and land grabbing making it difficult to accommodate poor and vulnerable sections of the society in these areas. Indiscriminate land filling could further affect natural drainage channels and sink areas. 174 Thus, the opportunity for planned and systematic growth is being lost and appropriate intervention at this stage would be beneficial in the long term. 34445 Final Aug 2007 4-1 SENES Consultants Limited

4.2 WATER RESOURCES AND QUALITY 4.2.1 Depletion of Groundwater 175 It has emerged from the analysis that RAJUK has little or no control on the regional level planning of water supply formulated by DWASA. In the absence of a more integrated planning approach the water supply strategy would primarily be based on the DWASA s existing plans of continuing dependence on groundwater sources in the short to medium term within the DWASA service area. Outside this area, in the adjoining developing and fringe areas, planning for water supply would continue to be ad hoc in nature and primarily dependant on groundwater sources. In addition, a considerable section of population in these areas would not have access to safe drinking water. Therefore, without integrated planning and enhancing the capability of DWASA to serve larger population across a wider area, there is a high risk of not meeting the total requirement of supplying clean potable water to a large section of the population in the DMDP area. 176 With present short and medium term plans for water sourcing, depletion of groundwater resources would continue to occur at a very fast rate both within the DMDP and adjoining areas (Singair area to the west of DMDP). This may result in further lowering of levels of groundwater aquifers, a natural resource already under high stress and which will take very long time to recover its original state, if proper remedial measures are adopted. The high rate of withdrawal of groundwater may also result in contamination of sourced water by naturally occurring minerals like arsenic, as is prevalent in many parts of Bangladesh due to underlying geology of the gangetic delta region. The continuous sourcing of groundwater from underlying aquifers may also affect the water sourcing potential of tube wells which play an important role in supplying water to large sections of unprivileged people living in slum squatters. 177 Long-term plans relating to sourcing of surface water usage may increase the risk of providing unsafe water to end-users, if the river systems from which such water is sourced is polluted from discharge of industrial pollutants or sewage upstream of the intake point. The clean-up of rivers would have to be planned and it would have to include all sources in the river watersheds. If successful, this would lead to greater reliance in water supply from surface water sources which would also reduce the dependence of vulnerable sections of society on shallow groundwater often contaminated, thereby resulting in decreasing environmental health risks. 178 With the current DWASA master plans, no special provision has been made for supply of clean drinking water to the vulnerable population living in the slums. These slum-dwellers are forced to pay higher prices for sourcing potable water. Without a specific targeted scheme for water supply to this section of the society their vulnerability to water borne diseases increases, affecting livelihoods and increasing health costs. 4.2.2 Reducing water pollution 179 As discussed in earlier sections, due to critical gaps in planning, institutional weaknesses and lack of resources, the surface and groundwater resources of Dhaka have been severely impacted by industrial growth and urbanisation. If adequate efforts are not made to correct or address the present gaps in the higher plans for treating sewage, industrial effluents and sound 34445 Final Aug 2007 4-2 SENES Consultants Limited

disposal of wastes, the risk to the water environment, a key environmental priority, would continue be very high in terms of scale and severity in the short, medium and long term. Some of these impacts, like the contamination of groundwater, would also be irreversible, or would take a very long time to remediate through natural processes. Some of the specific risks to the water environment are briefly presented below: At present the sewerage network infrastructure being planned by DWASA only takes into account the existing urbanised areas and there are no systematic plans to set up sewerage infrastructure in the developing and fringe areas which are charted for rapid development in the near future. In addition, the five new Sewage Treatment Plants that are being proposed as a part of the DWASA Master Plan are not holistic and do not consider additional sewerage coming in from developing or fringe areas. With new areas getting urbanized, the sewage treatment capacity will soon be overwhelmed resulting in continual pollution of the surface water resources in and around the city increasing the existing risks on surface water quality in the medium to long run. The approach for effluents treatment presently adopted only looks at end-of-the-pipe treatment after sewage is collected by a dedicated sewerage network. Other nonconventional methods of sewage treatment like oxidation ponds, biological treatment through pisciculture ponds, etc. which are being practiced in similar socio-economic conditions in cities like Kolkata, India could be considered for replication. Furthermore, experiences of operating conventional treatment plants by sector agencies such as DWASA in developing economies have not yielded desired results and many such plants are not run efficiently because of lack of monitoring or proper maintenance of the facilities. This also aggravates the risks of water degradation in the medium to long run. Presently, the plans for industrial effluent treatment and water pollution control being formulated by the industry associations and the Department of Environment stresses on combined treatment of effluents generated by industry clusters. If implemented properly, this arrangement would enable industrial sectors like tanneries and dyeing units to treat their wastes in a common facility against payment of user charges and thus create a system to reduce pollution load being discharged into surface water. However, as a strong institutional setup will be required to construct, operate and maintain such common effluent treatment infrastructure along with proper monitoring from DOE, there remains a risk to surface water contamination. Without the implementation of adequate capacity building and institutional strengthening for management water and urban development. There are number of small and medium units which are not clustered and discharge their effluents into common sewers. A CETP is not feasible and relocation of these small and 34445 Final Aug 2007 4-3 SENES Consultants Limited

medium units would also be difficult considering their limited financial capacity. Thus these units would continue to pollute unless some concrete measures are taken to rehabilitate them in areas with adequate infrastructure to treat their wastes before discharge into surface water bodies or schemes developed to help these units to adopt cleaner technology. To ensure efficient management of solid waste DCC has undertaken the Clean Dhaka project which targets collection and disposal of solid waste. This would improve efficiency of collection of solid waste thus positively impacting the water quality of the inland water bodies. However, the Clean Dhaka project is limited to the DCC area and no similar initiatives have been taken in the remaining parts of the DMDP. Thus risks of pollution of surface water from improperly managed waste dumps and open landfills would continue in such areas. In addition, the absence of guidelines for management of municipal solid waste as well as for biomedical and hazardous waste seriously impedes the development of technically sound waste disposal systems. The risks of pollution of both surface and groundwater would thus continue in the DMDP region even though the Clean Dhaka project is implemented. The Clean Dhaka SWM project places an overall stress on the landfill based approach which might turn counterproductive as most of the land in the region is prone to floods. The risks would further be aggravated since the local bodies other than DCC have limited technical and financial resources to undertake initiatives of such nature. Regional cooperation involving City Corporation and the Pourashavas for solid waste management however is difficult because of political-governance reasons. As a result, though there would only be limited opportunities from better collection of waste and lesser littering, the risk to surface and groundwater resources would continue due to improper waste disposal practices. 180 Though the DAPs are expected to plan for local level sewage and wastewater collection systems before being drained into surface water bodies, the risk to surface water bodies cannot be reduced without proper integration or interface with the larger DWASA collection and treatment systems within their service area. This would require the DAP consultants to work in close collaboration with DWASA before giving shape to local level sewerage and waste water treatment systems. In areas outside the purview of DWASA, DAP consultants would have to suggest a combination of treatment suited to the respective DAP zone concerned. The onus of cleaning up existing clusters of polluting industries lies with the DOE and industrial associations. The formulation of DAP is an opportunity to initiate dialogue between DOE and industry as to the appropriate location of future industrial zones. An opportunity that, thus far, has not been taken advantage of due to lack of institutional coordination and an integrated development planning framework for Dhaka. 34445 Final Aug 2007 4-4 SENES Consultants Limited

4.3 FLOODING AND DRAINAGE 4.3.1 Increasing Vulnerability to Floods 181 The physical location of most of the low lying areas within the DMDP and the proneness of adjacent riverine systems to flooding exposes Dhaka to high flood risks. Engineering plans in the form of embankments have been able to considerably reduce the effect of flooding in the main city. New proposals to build more such embankments on the eastern side of the city are presently under consideration. Though this engineering solution has certain inherent advantages, other factors discussed below continue to increase the risk of flooding in Dhaka. Effects of climate change may also appear and long-term impacts of related phenomena are likely to be higher water levels and more frequent incidences of flooding and submergence. The proposed flood management plans in the form of the eastern embankment cum multi purpose project overemphasize engineering solutions without adequately considering the capacity of natural water bodies to absorb excess flood water and the need to establish some kind of connectivity among existing water bodies for water within the city area to flow out during floods. The implementation of the embankment will impede natural drainage patterns and will intensify flooding in the areas within DMDP lying to the east of the Balu River. Similar effects have been experienced in Tongi River where the intensity of flooding has increased on the other side after the construction of the western embankment. Therefore, the eastern embankment may help to reduce flood risk for a limited area (west of the Balu) in the short term, but may prove counterproductive in the long term from the point of view of other areas located on the fringes of the DMDP. Also, in the case that this embankment is breached because of a high intensity flooding event, it would result in severe flooding within the city. The cause of urban floods in Dhaka is also as a result of the city loosing its capacity to absorb high intensity rainfall. The loss of the low-lying areas, progressive blocking of inland water bodies and drainage channels to drain excess water have together resulted in the city loosing its sink capacity. Implementation of the regulation for protection of these areas has been weak as most of these wetlands and drainage channels have not been demarcated and notified primarily due to political-economy considerations. Even though the DAPs are expected to demarcate the water bodies, open spaces and playgrounds absence of clear guidelines for identifying them would limit the identification process. Thus, with the loss of existing wetlands and low lying areas, resultant risks associated with water logging and urban flooding would continue to aggravate. 182 As the DAPs would concentrate on their respective areas for planning, it is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risk in the entire DMDP area. Even the identification of flood retention ponds which figure in the scope of the DAPs would be difficult to undertake on a compartmentalised planning area basis without proper 34445 Final Aug 2007 4-5 SENES Consultants Limited

regional studies that take into account the extent of urbanisation and an assessment of land that can be made available for development of such retention ponds. 34445 Final Aug 2007 4-6 SENES Consultants Limited

Chapter 5 SEA Findings and Recommendations 5.1 BACKGROUND 183 One of the main objectives of this study was to assess the process of formulating the Detailed Area Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the environmental priorities identified by this SEA could be incorporated in these plans. As the SEA progressed, it became evident to the SEA consultants that the whole process of preparing the DAPs, was from the start, handicapped by existing systemic shortcomings. These shortcomings were grouped under two headings: 1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated urban planning framework. Additionally, there is a lack of any stated mechanisms for coordinating with other sectoral agencies and their planning processes; and 2. Problems at the implementation level: These are poorly informed plan preparation process; inappropriate survey design and inadequate allocation of technical resources by RAJUK. This has led to over-ambitious Terms of Reference for DAP preparation. 184 Extensive review of these categories of shortcomings was undertaken. This informed the identification of environmental priorities to establish the scope of building into the DAPs, strategies to address these priorities. Institutional and plan analyses, the review of the DAP planning process, and the complexity of environmental problems led the SEA team to conclude that the current process of DAP preparation would not be able to deliver the expected outcomes. By August 2007, progress would have been made on demarcation of plan boundaries, but no plans would have been formulated. 185 This chapter first gives a summary of the findings of the SEA relating to the shortcomings and policy gaps at strategic, urban and local levels which will continue to prevent the satisfactory development of local area plans. It then highlights the environmental priorities that need to be addressed by DAP. The chapter concludes with the recommendations which are based on the findings of this study and flags the issues which need attention. 186 Contribution of this Strategic EA: This study has shown that successful completion of most of the tasks assigned to DAP consultants is contingent on strategic decisions being taken at institutional and regional level. Concurrently, it has identified areas for capacity development; provided pointers to inform/reform the planning process; and to improve the links so that planning at DAP level can successfully complete the tasks assigned. 5.2 SUMMARY OF SEA FINDINGS 187 The findings are presented under the two groups noted above. 34445 Final Aug 2007 5-1 SENES Consultants Limited

5.2.1 Shortcomings and Gaps at the Strategic Level 188 The Structure and Urban Area Plans do not provide land use zoning principles and guidelines that are currently applicable. There are contradictions and lack of clear definitions. The Plans demarcate broad areas for future development. However, there are inherent contradictions/loopholes as in some cases the areas marked for development are low-lying and act as sinks during the wet season. Since there are few notifications of land-use of fringe areas, it provided scope for manipulation and encroachment. Guidelines have been provided in the Plans with respect to development of housing for the low income groups and community participation in planning. However, there are no directives in the Structure Plan for implementing these guidelines; hence they have been ignored by the implementing agencies. Moreover, these plans have become dated and have limited relevance to resolving the present urban management problems. 189 The sectoral policies in the Structure Plan do not relate to the urban planning aspects. As result the sectoral policies run as a parallel process with a weak interface to urban and regional development plans. Most sectoral plans concentrate on finding localised and short term solutions to urban problems, particularly within the DMDP. RAJUK by its constitution, however, has the power to coordinate with the sectoral agencies whose plans affect the urban area. There has been a failure of leadership. 190 Implementation of urban and regional plans needs considerable co-ordination and collective design and decision making with all agencies working together. There are no stated mechanisms for co-ordination or any over-arching planning framework which would have enabled agencies to collaborate and co-ordinate their plans. The result has been fractured, haphazard and environmentally unsustainable urban spread and inadequate infrastructural development. 191 The strategic level plans did not tackle the problem of multiple administrative authorities within the DMDP and how their developmental efforts could be managed at the regional level. Thus, the overall problems noted above are exacerbated by fact that DMDP is carved up into smaller administrative units (municipalities and Pourashavas). In many instances, sectoral agencies do have the mandate to provide services throughout plan area. A result some areas get excluded. However, of greater concern is that piecemeal planning and un-coordinated infrastructure development is taking place, often to the detriment of long-term environmental sustainability. 192 The haphazard growth is further reinforced by the national funding mechanism. Development planning, including urban projects, in Bangladesh is done through the Annual Development Programmes (ADP) for each financial year. Development projects are initiated at the level of government agencies, divisions, departments, local government bodies. These are then channelled upward to the relevant ministries, and then to the Planning Commission if necessary. The administrative ministries concerned are authorized to approve projects involving costs up to a designated level. Projects involving costs beyond that level are recommended to the Planning Commission for consideration, approval and allocation of funds. The outcome of both these procedures is that no one has an urban overview of what is happening on the ground. 34445 Final Aug 2007 5-2 SENES Consultants Limited

193 Clearly urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic approaches to development; multiplicity of orthocentric agencies; collusive relations between government agencies and vested interest groups; low levels of environmental awareness among sectoral and local authority planners; and very limited effort to achieve real public good. 194 The five teams of DAP consultant appointed by RAJUK have no higher level guidelines for local area plan formulation; no framework for developing a coherent regional approach; no mechanism to coordinate the plans of adjoining local authorities; and limited ability to deal with large sectoral organisations like DWASA or with local authorities who are antagonistic to RAJUK. 5.2.2 Plan Development and Implementation Issues 195 The Detailed Area Plans were conceived as the third and lowest tier of the DMDP planning hierarchy. As per the design laid down in the preparation document of Structure Plan, Master Plan and Detailed Area Plan for Dhaka, the DAPs were expected to be prepared in-house by RAJUK after adequate planning capacity had been built up. Due to institutional failures and reluctance to develop its internal planning capacity, there has been a 10-year delay. 196 DAP preparation was finally outsourced to consultants in 2005 and is expected to be partially completed by August 07. For the purpose of DAP preparation, the entire DMDP area had been divided into 26 Special Planning Zones (SPZs) and was later consolidated to form 5 planning areas (see Table 3.1). The work has been awarded to four firms of consultants. 197 The problems at the implementation level relate to (i) planning capacity. These include insufficient groundwork, inadequate research and understanding of urban planning in RAJUK; and poor design of the DAP process; (ii) the competence of the DAP consultants; and (iii) poor support and leadership from the Technical Committee charged to oversee the plan preparation process. Each of these is briefly summarised below. 198 Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened, was gradually downgraded and to this day the Planning Department remains technically understaffed. Moreover, there has been no updating or enhancement of qualifications of the current planners. Their notions of urban planning are technocentric, dated and complexities of social planning do not sit easily in their thinking. In fact they were ill-equipped to design the DAP preparation process. Consequently, the Terms of Reference are overambitious. The technical resources allocated are inadequate and behind the times; for example, the Geographical Positioning System is not used to determine coordinates of boundaries; it was done manually leading to mismatch of boundaries drawn by two groups of consultants and consequent delays. 199 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, 34445 Final Aug 2007 5-3 SENES Consultants Limited

the danger that the DAPs could further exacerbate the problems of urban environmental management. 200 Furthermore, in the absence of any directives, and reflecting the generally low environmental awareness, the DAP consultants appear to have limited understanding of the pollution-intensive nature of industrial growth in the watershed which is greatly responsible for the degradation of the water resources. Consequently, there is little appreciation of the need for spatial zoning of industries which should be done in consultation with industry. 201 Of greater concern is that the DAP preparation is not guided by any strategic level planning framework. This means that the five groups of consultants are each contained within their own zones, rather than within a regional approach. This means that piecemeal development will continue even under the new plans. 202 Challenges of DAP consultants. In view of the complexities involved in formulating the DAPs, the team concludes that the local consultants selected for this purpose do not appear to have comprehensive technical capability and the experience to complete the tasks. What is also surprising is that the consultants did not question the Terms of Reference or whether the outputs were achievable in the given timeframe and with the resources allocated. 203 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. In addition, many of the sectoral plans do not cover the entire DMDP area, especially in the fringe areas. The DAP consultants working in these areas do not have access to any sectoral planning guidelines. 5.3 ENVIRONMENTAL PRIORITIES THAT NEED TO BE ADDRESSED BY DAP 204 The importance of getting the DAP planning process right is underscored by serious environmental problems already affecting Dhaka and its surrounds. The environmental priorities as identified by this study are given below. 5.3.1 High Urban Densification and Land use Management 205 Increasing overcrowding in the already developed areas: The growth within the already developed areas has taken place in a random manner, sometimes in contravention of existing development control legislations or by using loopholes in them. As a result, land resources within the city have been put under stress, wetlands within the city have got filled up and drainage channels have been obstructed in favour of unplanned development. This skewed development pattern has put the urban services under severe stress resulting in significant strain on environmental resources. 34445 Final Aug 2007 5-4 SENES Consultants Limited

206 Unplanned development in fringe areas and encroachment: With decreasing scope for inner city growth, large areas in the environmentally sensitive fringe zone are being targeted as they have been marked for development in the Structure Plan. Additionally, in the absence of any detailed and systematic growth plans the new developments run the risk of being mismanaged. It is expected that these developments will also be without adequate provision of urban services and infrastructure. 207 Such areas have also seen an: Increase in land prices as a result of speculation and land grabbing making it difficult to accommodate poor and vulnerable sections of the society in these areas; and Indiscriminate land filling which could lead to loss of natural drainage channels and sink areas and increase the vulnerability to flooding. 5.3.2 Water Resources and Quality 208 Surface water Pollution: The river systems and the water bodies in the Dhaka Watershed are so contaminated by discharge of industrial effluents and untreated sewage that it cannot be treated to potable standards. The problem of industrial pollution has to be addressed by DoE. It is also being addressed by the World Bank under DIEWRMP. The role of the DAP lies in initiating a dialogue with industry and a process to identify locations for future industries. 209 Reliance on, and Depletion of Groundwater: As surface water cannot be used to supply drinking water, DWASA has become increasingly reliant on abstracting groundwater. Additionally, as the supply is unable to meet the growing demand, there has been an increase in number of privately owned tube wells. Local authorities outside DWASA area are also dependent on groundwater. Continued abstraction over a long period could lead to contamination of groundwater. RAJUK and DAP have no say in DWASA s Master Plan. Furthermore, DWASA has made no provisions in its plan to supply the slums areas. 5.3.3 Inadequate Sanitation and Sewage Network 210 At present, the sewage network infrastructure being planned by DWASA only takes into account the existing urbanised areas. There are no systematic plans to set up a network in the developing and fringe areas which are marked for future development. In addition, the five new Sewage Treatment Plants that are being proposed as part of DWASA s Master Plan do not consider additional sewage coming in from developing or fringe areas. As a result, with new areas becoming urbanized, there will be continued discharge of untreated sewage resulting in continued pollution of the surface water resources in and around the city. 211 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. 34445 Final Aug 2007 5-5 SENES Consultants Limited

5.3.4 Increasing Vulnerability to Floods 212 The increased vulnerability to flooding as been documented in this report and elsewhere. As far as the role of DAP preparation is concerned, the consultants would concentrate on their respective areas for planning. It is unlikely that they would be able to formulate a composite long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood retention ponds, which are central to local area plans, would be difficult to undertake, given the compartmentalised planning approach. 5.4 RECOMMENDATIONS 213 In keeping with the objectives of the study, the recommendations have focused on improving the DAP planning process. These have been subsumed under two groups indicating the urgency of action required. Action in Short Term 1 Develop a DMDP region landuse map; demarcate and publish notification of ecologically/environmentally sensitive areas 214 It was heard several times during the final consultation workshop from all quarters that there was no comprehensive land-use map of DMDP Region and there was a definite need to create a document that depicts all the land uses, demarcates eco-sensitive areas, and indicates potential development areas with different landuses like industrial, agricultural, residential, mixed landuse, etc. 215 Further, loose planning guidelines and loopholes in the Structure and Urban Plans have allowed the urban encroachment of environmentally sensitive areas which include flood flow zones, wetlands and low-lying areas which act as sink for storm water runoff; natural drainage channels and canals. The local area plans cannot progress unless these areas are clearly identified, demarcated and notified. The proposals and plans on how this demarcation should take place already exist with the responsible agencies and Boards. 216 To overcome this problem, the development of a DMDP Regional Land Use map should be a priority. This map should clearly demarcate eco-sensitive areas and these should be notified. This action is required on top priority to ensure no more filling of wetlands, destruction of agricultural lands, and continued haphazard growth of the DMDP Region. This comprehensive exercise should be undertaken immediately as the DMDP development with existing outdated Structure and Area Plan and under development DAPs will not be comprehensive and will likely repeat mistakes of the past planning processes. This DMDP Region Plan should be developed in consultation with all the sectoral and local planning bodies. However, the local plans will be only guidelines and will be finalised by individual local governments like Pourashavas, Union Porishads at the local level. 34445 Final Aug 2007 5-6 SENES Consultants Limited

2 Resolve conflict arising from the multiple functions of RAJUK 217 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 encroached on environmentally sensitive areas. Clearly, there is conflict of interests between RAJUK s role as a promoter and its role as the principal agency for urban development. 218 This issue can be resolved only by either divesting RAJUK of all its developmental responsibility and making it an exclusive planning and monitoring body; or, RAJUK can be a development body and a new authority should be created to carry out the planning and monitoring function. An institutional assessment needs to be carried out to define the mandate of the proposed agency, its location within the myriads of agencies, ministries and authorities that exist in Dhaka/ Bangladesh and how it will function. However, this authority has to be able to get support and cooperation of various sectoral agencies and should be able to control and monitor the planning of entire DMDP region. 3 Strengthen the DAP planning process as there is too much at risk 219 The detailed area planning process is incomplete, hence, there is still an opportunity to improve the process and achieve some of the stated objectives. Real value addition to the process will take place if the capacity for environmentally sustainable and socially sensitive planning is enhanced in RAJUK as it is the lead agency. Additionally, consultants with more appropriate skill sets need to be appointed. Plan formulation needs a team with better technical know-how, better understanding of the complexities of urban planning, and which has a critical approach to project execution. The point is to build on the work that has already been completed in the last two years. 220 One of the main problems faced by the present consultants is that they are unable to work with/ have access to, the sectoral agencies. The membership of the Technical Committee, who is charged to provide the link, should be re-assessed for effectiveness and if necessary, changed. The modus operandi should be made more transparent and information on progress and outcomes disseminated. This can be achieved by engaging stakeholders more effectively and communicating decisions at various levels to public and key stakeholders so that the process remains open and accessible. 221 The leadership of RAJUK needs to be more active in the process. The inability of RAJUK to play a leadership role in the past has led other agencies to take planning initiatives on their own without any coordination with RAJUK. It is clear that constitutionally the organisation has considerable power but has rarely used it for systematic urban management. RAJUK needs to redirect its energy to facilitate the work of its consultants with sectoral agencies and other local authorities. This will not be easy as the latter have developed their internal procedures and these procedures exclude any interaction with RAJUK. It will therefore, be essential to enable and encourage RAJUK to liaise with other agencies and open doors for the DAP process. 34445 Final Aug 2007 5-7 SENES Consultants Limited

222 The issues of slum area development and provision of low income housing are not being addressed either by RAJUK or any of the other sectoral agencies. This means that land allocation and infrastructure planning for these areas might not feature in local area plans. One of the responsibilities of RAJUK is the provision and overview of low income housing. This issue will be part of the institutional reform of RAJUK and will have to be dealt within the scope of that process. 4 Engaging stakeholders in urban planning 223 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. 224 It is recommended that during the reform of the planning process including resolving the conflict of mandate within RAJUK, a transplant process for engaging key stakeholders in the planning of regional areas should be put in place. o As pointed out in the workshop, the ward committees at the Pourashavas level have been quite effective at engaging local community in local planning initiatives. Similar initiatives are required at Dhaka and municipal level. o Further, transparency can be achieved if the DMDP region landuse plan with demarcation of no development zones is notified and made available to the public. The public can use this information and stop illegal development. Public can approach judiciary if necessary to stop development in the no-development zone. 5 Bring other actors on board 225 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. 226 DWASA is one of the biggest players in the provision of urban infrastructure. Currently there is very little communication between the two organisations and RAJUK has little say in the Master Plans developed by DWASA. It will be important to bring DWASA, RAJUK and the DAP team to a common platform. 227 The flood management strategies expectedly should have a regional approach. However, there are measures which need to be put in place and actions taken at the local level to achieve overall reduction in vulnerability to flooding. These include among others, freeing up encroached canal systems, rehabilitating flood retention ponds, improving connectivity between waterbodies etc. In order to incorporate such measures in the DAPs, it will be necessary for RAJUK, 34445 Final Aug 2007 5-8 SENES Consultants Limited

LGED and other principal organisations responsible for management of water resources to work together to assist the DAP team. Actions in Medium Term 6 Develop strategic planning directives for urban growth 228 The DAP formulation process will ultimately rely on a strategic planning framework to provide the directives, tools and guidance. While the local area plans will be important working tools, change will occur and new plans will have to be formed. This strategic framework would be a point of reference for local authorities; for DAP consultants; and for future urban growth for the stated period. It is hoped that the new framework will be coherent, tight and address the inadequacies of the past and current urban planning approaches and processes. 7 Funding procedures for local development projects 229 It has been noted in the report that development projects, which include urban projects, initiated by local governments and local level sectoral agencies are channelled up to the relevant ministry for funding, and further up to the Planning Commission if they are beyond a designated cost level. In either case, the funding provided is based on budgetary criteria. There is no mechanism to ensure that the project has been environmentally appraised or the sustainability of such projects has been established. Furthermore, there could be duplication of effort in two adjoining authorities leading to waste of valuable resources. For long-term environmental sustainability, it will be important to address this problem. This requires the mainstreaming environmental issues prior to initiating any systemic change. The Environmental Assessment regulations already exist in Bangladesh and linking funding to the EA approvals maybe one of the approaches that maybe considered. 34445 Final Aug 2007 5-9 SENES Consultants Limited

BIBLIOGRAPHY 1. Bangladesh Water Development Board, Ministry of Water Resource, Government of Bangladesh, Updating/Upgrading the Feasibility Study of Dhaka Integrated Flood Control Embankment cum Eastern Bypass Road Multipurpose Project, 2006 2. Bangladesh Census, Bangladesh Bureau of Statistics, 2001 3. Centre for Urban Studies (CUS), Slum Studies, 2005 4. Department of Environment, Government of Bangladesh, UNEP, BCAS, Dhaka City State of Environment Report, 2005 5. Dhaka City Corporation, The People s Republic of Bangladesh, Japan International Cooperation Agency, Clean Dhaka Master Plan, 2005 6. DWASA, Interim Workshop Presentation, 2007 7. Green City, Green City Report Dhaka, 2005 8. Ghazipur Pourashava, Municipal Infrastructure Development Plan with Update Landuse Plan,2006 9. International Protocol for Climate Change (IPCC), Special Report on the Regional Impacts of Climate Change An Assessment of Vulnerability, http://www.grida.no/climate/ipcc/regional/282.htm 10. Institute of Water Modelling, Concept Paper on Improvement of Sewerage System In Dhaka City, Sewerage Master Plan for Dhaka City, Dhaka Water Supply and Sewerage Authority, 2004 11. Industrial Environmental Compliance & Pollution Control in Greater Dhaka Phase I, IWM March 2007 12. Japan International Cooperation Agency, Updating Study on Storm Water Drainage System Improvement Project in Dhaka City( Main Report), 1990 13. Ministry of Communications, Government of Bangladesh, Strategic Transport Plan, 2005 14. Mappa Publications, RAJUK Plan (Future Dhaka City), 2006 15. National Encyclopedia of Bangladesh (Banglapedia), 16. OECD, Applying Strategic Environmental Assessment: Good Practice Guidance for Development Cooperation, DAC Guidelines and Reference Series, 2006 17. Planning Commission, Government of Bangladesh, Unlocking the Potential, The National Strategy For Accelerated Poverty Reduction, October 2005 18. Rajdhani Unnayan Katripakahha, Dhaka Metropolitan Development Plan (1995-2015), Volume I (Dhaka Structure Plan), 2005 19. Rajdhani Unnayan Katripakahha, Dhaka Metropolitan Development Plan (1995-2015), Volume I (Urban Area Plan), 2005 20. Rajdhani Unnayan Katripakahha, Bid Document for Preparation of Detailed Area Plan (DAP) for Dhaka Metropolitan Development Planning (DMDP) Area, 2003 21. Scottish Executive, Welsh Assembly Government, A Practical Guide to the Strategic environmental Assessment Directive, 2005. 34445 Final Aug 2007 BIB-1 SENES Consultants Limited

22. Slum Studies: Centre for Urban Studies, 2005. 23. UN Report, World Urbanization Prospects: 1999 24. United Nations Development Program, Technical Assistance for Plan Preparation: Detailed Area Plan for Greater Dhaka and Chittagong,1990 25. United Nations Center for Human Settlement (Habitat), Tools to Support Participatory Urban Decision Making, Urban Governance Toolkit Series. 26. UNIDO and Government of Bangladesh, Techno-economic Study for Setting up a Common Effluent Treatment Plant in the Tannery Cluster of Hazariabagh, 2001 27. Water Resource and Planning Organisation, Ministry of Water Resources, Government of Bangladesh, National Water Management Plan Development Strategy, 2001 28. World Bank, Bangladesh Country Environmental Assistance, Bangladesh Development Series Paper No 12, 2006. 29. World Bank, Bangladesh Country Water Resource Assistance Strategy, 2005. 30. World Bank, Dhaka: Improving Living Conditions for the Urban Poor, 2007. 34445 Final Aug 2007 BIB-2 SENES Consultants Limited

GLOSSARY Zillas Pourashavas Union Parishod Bangladesh is divided into six administrative divisions, each named after their respective divisional headquarters: Barisal, Chittagong, Dhaka, Khulna, Rajshahi, and Sylhet. Divisions are subdivided into districts (zila). There are 64 districts in Bangladesh, each further subdivided into upazila (subdistricts) or thana ("police stations"). The area within each police station, except for those in metropolitan areas, is divided into several unions, with each union consisting of multiple villages. In the metropolitan areas, police stations are divided into wards, which are further divided into mahallas. There are no elected officials at the divisional, district or upazila levels, and the administration is composed only of government officials. Urban areas have a separate set of local governments. The Bangladesh Census Commission recognized 522 urban areas in 1991 (with a minimum population of about 5000 or more) but only about 269 of the larger urban areas among these have urban local governments. The six largest cities urban local governments are known as City Corporation status, while the rest are known as Pourashavas or Municipalities Bangladesh s administrative structure has several tiers and is complex. At the lowest level, about 100-300 households representing 300-800 people are organised into Villages (grams) which are the primary rural unit. Villages are organised into Wards, which are the lowest unit of local government. The number of villages in each Ward is determined by the total number of people. 9 Wards comprise a Union. Bangladesh has an estimated 4,451 Unions which are organised into Sub-districts (called Upazilas or Thanas). These sub-districts are organised into 64 Districts which are organised at national level into 6 Divisions. The upazilas or unions are administered by elected bodies called Union Parishods. 34445 Final Aug 2007 G-1 SENES Consultants Limited

APPENDIX PUBLIC CONSULTATION IN SEA 34445 Final Aug 2007 A-1 SENES Consultants Limited

STAKEHOLDER CONSULTATIONS The SEA process places considerable importance on the involvement of stakeholders in the process. SEA provides a platform for all the stakeholders including the vulnerable stakeholders to express their concerns and also participate in the formulation of strategies for the community and the City. An elaborate consultation schedule had thus been drawn out to ensure involvement of the stakeholders at all the steps in the SEA. For identification of stakeholders a comprehensive stakeholder analysis was carried out. The stakeholder analysis is a was designed as an ongoing process. At the initial phase the analysis identified stakeholders and provide details of various stakeholders viz. NGOs, public institutions, non-profit groups etc working in the sector. Therefore, keeping an open policy facilitates inclusion of stakeholders at any stage of the SEA study. This section describes the process adopted for the stakeholder consultation at various stages till date and stakeholder opinions/ comments/ recommendations voiced at various meetings/ workshops. The consultations carried out during the various stages of the study i.e. i) Inception Stage ii) Interim Stage iii) Draft Final Stage have been discussed below. The discussions further presents the consultation plans till the conclusion of the SEA process THE INCEPTION STAGE As part of initial consultations, three stages of consultations have been conducted. Mobilization consultations were held with RAJUK and World Bank to develop an understanding of their perceptions and expectations from the study. Subsequently individual consultations were held with both government departments and civil society groups to develop an understanding of their areas of influence, strengths and weakness so that their involvement as stakeholders could be determined at sectoral intervention during the later stages of the project. Their perception of the planning and environmental issues and constraints of Dhaka City were also understood during these consultations. These individual consultations were followed by a stakeholder workshop at the culmination of the Inception stage. The objective of the workshop was to understand the issues and concerns in Dhaka city and also prioritize these issues. Mobilisation Meetings Mobilisation meeting were held with RAJUK and the World Bank. Both these organisations stressed that they expected SEA to identify some areas where strategic intervention would be required. Discussions with RAJUK pointed out that the SEA has been initiated by them to bring the decision making higher in the plan preparation process. Thereby they would like SEA would supplement the efforts of the DAP consultants. RAJUK expected the SEA to provide some guidance to the DAP preparation process. 34445 Final Aug 2007 A-2 SENES Consultants Limited

Individual consultations Individual level consultations were carried out with number of organisation both government departments and NGO s. Important among them were Department of Environment, Centre for Urban Studies, Bangladesh Centre for Urban Studies, Bangladesh Environmental Lawyers Association, IUCN. These discussions were primarily aimed at developing understanding of the strengths and weaknesses of these organisations and their perception of the environmental concerns in Dhaka. Summary of important issues highlighted are presented below: Department of Environment, Government of Bangladesh: The Department is entrusted with the responsibility of protecting and preserving the environment and has been involved in policy formulation and advocacy, implementation of plans and programs, monitoring of the environment and enforcement of the legislations. They also admitted that there has been a deterioration of the environment of Dhaka mainly because of the rapid urbanization. They were concerned about: Non enforcement of land use classification resulting in mixing of industrial and residential areas; Discharge of untreated sewage and lack of sewer infrastructure in the DMDP has been a major reason for the pollution of the rivers; Unplanned real estate development in the city - the development is not coordinated with the planning and construction of appropriate infrastructure; The over dependence on ground water has resulted in fast depletion of ground water in the DMDP; DAP Consultants: The DAP consultants were consulted in presence of RAJUK Project Director. The SEA study and methodology of conducting the study was discussed with them. It was explained that the SEA process: would be used for developing the higher-level decision making for planning purposes; and the outputs from the SEA would be useful in preparation of DAPs. Thus the SEA would be supplement the efforts of the DAP consultants. Initial Stakeholder Workshop The World Bank s representative outlined the initiatives that the World Bank has taken towards the improvement of the quality of life in city of Dhaka. Dhaka is the growth engine of the Bangladesh economy, and WB indicated that inaction on the developmental and environmental issues in Dhaka may impact the Bangladesh economy. Some other environmental and infrastructure issues were also highlighted: surface water & ground water pollution from the industry; air pollution from certain industries; flooding and surface water pollution etc. 34445 Final Aug 2007 A-3 SENES Consultants Limited

The DAP Project Director (RAJUK) described the hierarchy of plans for Dhaka and importance of the DAP. It was also pointed out the key focus area of the DAP: Flood Protection, Safe Drinking water, Sanitation, Solid Waste Management, Industrial Waste Management and Traffic Congestion. It was mentioned that DAP consultants were also responsible for looking after some micro-level environmental issues and consequently the SEA should highlight the environmental opportunities and constraints present in their respective areas and accordingly they would formulate mitigation measures for their proposed DAPs. The SEA consultant team explained the SEA objectives and its possible benefit as a policy planning tool, and how bringing the decision making process upstream through policy level intervention can help in mitigating environmental impacts of future urban development. The need for stakeholder involvement for the SEA process and the outline of the consultation process planned for the SEA process was also discussed. The major concerns discussed in the meeting by the participants from the different stakeholders were: ineffectiveness of the project level EIA; little scope of environmental mitigation measures though the project level EIAs; detail urban sector projects require higher level EIA, i.e., SEA; little involvement in the project level EIA- need for increasing stakeholder involvement in the decision making process; and sector specific stakeholder discussion will be effective and SEA team also agreed to ensure sectoral discussions were held. After the discussion, the participants were divided into three groups and requested to identify and prioritize environmental concerns in the DMDP area. The stakeholder groups identified the issues and concerns in Dhaka. In addition, each group prioritized the issues based on importance accorded and discussed possible plans/options to mitigate these issues. Subsequently, each group then presented the group exercise results in the workshop. These issues have been included in individual sectoral reports under issues identified by stakeholders. THE INTERIM STAGE The consultations during this stage were focused on developing an input strategy from different stakeholders and developing a plan for getting inputs for mitigating the issues which have been identified. Two sets of consultation were held during the stage -a one-on-one consultation with each stakeholder followed by a cross sectoral workshop. One on One Consultation One-on-one consultations were organized as a continuation of the stakeholder consultations held during the Inception Stage of the Project. On one hand it informed the stakeholders of the 34445 Final Aug 2007 A-4 SENES Consultants Limited

outcomes of the Inception stages i.e. the six key sectors which were identified for the SEA and sectoral issues which were identified both from the analytical and the participatory component. Having provided the stakeholders the information, the discussions mainly focused on strategies the stakeholders felt should be undertaken for solving the issues. The stakeholders were consulted and a summary of the discussions are provided below: DCC: DCC informed that the implementation of the Clean Dhaka Program under JICA Assistance has been initiated. It was also pointed out that there are no environmental guidelines for siting of landfill. DCC has only one dumping site at Matuial, which has been converted into a landfill. In addition DCC has initiated actions for construction of the landfill at Amin Bazar. DTCB: The Strategic Transport Plan has laid emphasis on mass rapid transport system. Even though suggestions are flowing in for developing BRTS in Dhaka, implementation of the scheme would be quite difficult. Pourashavas: They informed about their plans in each of the six priority sectors. They also pointed out need for a comprehensive regional master plan in each of the sectors. They had also pointed out the need for mechanism to effectively implement the Building Control Rules 2006, as in its present form, it has a conflict with the Pourashava Ordinance 1977. NGOs: They pointed out that there was need to change the urban governance in all the sectors as institutional arrangements and governance were key problems in the implementation of various infrastructure projects. Industry Association: They stressed on the need to change the present approach of the regulatory agencies form a monitoring body to a government agency which was there to assist the industry in complying with the standards and worked hand-in-hand to raise the overall awareness and compliance by industries. Cross Sectoral Stakeholder Workshop As culmination of these consultations a cross-sectoral stakeholder workshop was conducted. This two day workshop also marked the culmination of the Interim stages of the project. The objectives of the workshop were: to identify key areas within each sector that would be the focus of planning and implementation in the city; identify key policy level initiatives which should be taken to mitigate the issues identified in the six priority sectors; and identify concerns which cannot be mitigated by technical solutions and other that would require legal or institutional interventions; For identifying the key sectors in Dhaka, the issues and concerns that were identified during the Inception stage were analyzed. The rationale behind developing the key sectors was discussed and the participants were later requested to prioritize these action areas. There were substantial discussions on sectoral issues, existing problem areas, proposed planning and the existing gaps 34445 Final Aug 2007 A-5 SENES Consultants Limited

as also the recommendations to address them. This was then followed by an open discussion. Sector wise issues discussed and highlighted are summarized and presented below. Transport: The key note address highlighted broad objectives of the Strategic Transport Plan (STP), importance of Mass Rapid Transit system, especially the metro rail and proposed alignment of the STP. The major issues raised in the discussion were: any regional initiative taken by Pourashavas for development of the transport should be in tune with the STP. better utilization of inland waterways by removing the encroachment and developing the waterways; preservation of Right of Way (RoW) through DAP for proper implementation of transport plan; conceptual design differences for STP & Eastern Embankment & Bypass project the stakeholders felt that the design were not harmonized and needed to be revisited; information sharing among the planning organizations; and integration of the recommendations of STP in the DAPs. Water Supply, Sewage & Sanitation: Since the stakeholders involved in Water supply, Sewage & Sanitation sectors are same, so these two sectors were combined into a single session. The key note address highlighted the water demand and supply plan from surface water sources (Padma & Meghna river), ground water source at Singair for DWASA a area, sewage network masterplan and proposed treatment plants. The major issues raised during the discussion by the participants focused on: Feasibility of sourcing of ground water in the Short term from Lower Duppitila Aquifers and Singair; Ground water recharge was a problem in Dhaka because of the thick impermeable layer and stakeholder recommended technical investigation of this issue; DOE should not be the only responsible agency for water pollution control; Agencies like DWASA should also be made responsible for this; and Provision of water supply by DWASA in the slums & discourage supply of unauthorized connection and illegal trade in urban services in these areas. Solid Waste: The key note address highlighted the solid waste management problem in DCC and other DMDP areas, conservancy approach in solid waste management, DCC s landfill site under the Clean Dhaka project, additional dumping site & no siting criteria for landfill site and importance of the 3Rs approach for waste management. It was also highlighted the importance of proper landfill sites for hazardous waste and bio-medical waste. The major issues raised during the discussion were 34445 Final Aug 2007 A-6 SENES Consultants Limited

Development technical siting guidelines for landfill site considering the geology/ hydrogeology of the region; Enactment of legislation for waste management all types of wastes; and Need for a regional approach to solid waste management in DMDP area. Flood & Drainage: The key note address highlighted the flooding problem in the DMDP area related to river flood and urban flood, encroachment of natural drainage canals, dumping of solid waste in the canals, structural flood protection measures, filling up of the retention ponds. The key concerns raised were: Demarcation of canals and water bodies according to CS and RS maps should be done immediately and notified for preservation; Removal of encroachment using the existing legislations; Land development should be allowed only after RAJUK s clearance that the property has not encroached on any demarcated open area or water body; Development control zone in the DAP; Water body & canals, encroachment by the Govt. agency should be stopped; and Raising awareness of stakeholders of various water bodies and their responsibility for preservation. Spatial Planning : The key note address highlighted the importance of proper urban landuse planning in the DMDP area, benefit of mixed land use plan, information dissemination to the public and institutional strengthening especially the planning organization RAJUK, better coordination between RAJUK and other Govt. agencies. The major issues raised during the discussion were: conflict in jurisdiction between the Building Construction Rules and the Pourahsava Ordnance has to be resolved for effective functions of the Building Construction Rules 2006; functions of RAJUK should be decentralized; large size of the DAP might hinder effective planning; Consideration & incorporation of the master plans prepared by the Paurashavas into the DAPs; and Institutional reform of RAJUK. Industries: The key note address highlighted the environment & regulatory issues related to industries, present environmental regulation for different types of industries, synergies between the DOE and different industries organization and revising of the Environmental Court Act. The salient features of the discussions were: absence of any legislation of hazardous waste management; effectiveness of present EIA procedure is poor; need to change the EIA process; delegation of power to the Pourashava for pollution control measures; and 34445 Final Aug 2007 A-7 SENES Consultants Limited

incorporation EIA guidelines for housing in the SEA recommendation. The DAP AREA CONSULTATION As a outcomes of the discussions from the sectoral workshops directions to develop a planning framework had emerged. During the preparation of the Draft Final report consultation were held each of the DAP areas to i) disseminate the learning of the SEA till date and ii) obtain feed back form local area representatives their expectation from the DAPs. The outcomes of the consultations are summarized below: Pourashavas and local urban bodies admit that the implementation of the plans have been the major reason for the plans not achieving the desired objectives. Non involvement of local level officials in supervision has been the major cited as a major reason. The local government institutions has to be strengthened. For undertaking preparation of local level planning and supervision lack of man power and expertise were also considered as major impedance. Multiplicity of organizations and the lack of transparency and coordination between them was considered by local elected representatives. To increase transparency and coordination in planning there should be a code for sharing of information between all organization. In most case the planning decisions both at the local level as well as sectoral and regional levels are taken on an ad hoc basis. This results in myopic plans which does not capture the entire gamut of problems and focuses on providing immediate or localized solutions to the environmental concerns. The Western Embankment was constructed to make The myopic vision of the project planners and tendency to provide short term localized solutions has resulted in number of problems that are there in DMDP area e.g. the western embankment has increased the flooding in areas of Tongi. The areas which would be required for development of infrastructure should be acquired immediately. Areas preserved as green zone has to be widely publicised. 34445 Final Aug 2007 A-8 SENES Consultants Limited

The Draft Final Report Consultation FINAL STAGES OF CONSULTATION This workshop would was held to discuss the draft recommendations with the stakeholders before finalisation of the Draft Final Report. The feedback of the the stakeholder their feedback on the recommendation was included in the Draft Final report. A summary of the comments on the recommendations and the processes is presented below along with the response. Comments Methodology of the Study Dr Golam Rabbani, queried about the nature and extent of the primary data collected as also the authenticity of the data used for the SEA study Ms Ishrat Islam of Urban Planning Department of Dhaka University was interested to know about the methodology used for the prioritization of environmental concerns Mr Khairul Islam Superintending Engineer, Tongi Pourashava pointed out that consultations carried out in the DAP preparation process has been very limited in the Union porishad areas. He enquired that since SEA was focusing on higher level stakeholders how would the views of these people be accounted in the planning process Risk and Opportunities to the Environment in DMDP Prof Amanatullah Khan of the University of Dhaka admitted that filling of low lying areas in a haphazard manner was indeed going to affect the topography of the region but we should be go over board and point the land filling would Response The SEA study being a higher level policy document has limited scope for primary data collection. The data and information used in the study are primarily from published project report and document accepted by the Government of Bangladesh. However, to fill up data gaps mainly socio-economic data consultations were held with all the community or the respective agencies. A cross analysis of the stakeholders perceptions and analytical assessment was used for the prioritization. This has been described in details in the report It was pointed out that SEA is a higher level study and has mainly focused on higher level stakeholder, further since there are no organized stakeholder in the union parishad areas representation for these areas have been limited. It was pointed out that understanding the potential for development of these areas i.e. fringe areas (mainly under jurisdiction of union parishads) separate guidelines have been proposed in the DAP s. The SEA recommends that a guidelines be developed development of the land filling 34445 Final Aug 2007 A-9 SENES Consultants Limited

Comments pose a grave risk as such activities would affect the development process. Mr. Tawfique Ali, Staff reporter, The Daily Star pointed out that the eastern fringes number of tranditional fishes have been found as wells a the network of canals which acted as a communication network has been destroyed Institutional Governance Issues Md Moinul Islam, Town Planner Tongi Pourashava pointed out that the apparent conflicts between the jurisdictions institutions as responsible for much of the environmental problems Responding to a query by house Mr. Neaz Rehaman, Team Leader, SEA pointed out that decisions taken by the predecessor government for investment of undisclosed money into real estate was resulting in un warranted political economic interferences. Continuing with the discussions Ms Islam, BUET pointed out that to curb the speculation over real estate which was cause of much of the problems in the city the taxation should be revised. Strategic Recommendations Kazi Hasiba Jahan, Geographer, Dhaka City Corporation enquired that with development of a regional system for development and maintenance of urban services, how would the cost for maintenance of the service be recovered? Appreciating the SEA consultants efforts to interact with the DCC regarding the Solid Waste Management issue Dr Tariq Bin Yosuf, Project Director :Clean Dhaka project in DCC pointed out that the consultants should have ensured collaboration been formed between RAJUK and DCC Involvement of the local government agencies is essential for successful enforcement of the environmental Response The SEA has given specific recommendation for guidelines for land filling as well as demarcation and preservation of wetland and canals in the DAP level recommendation. The SEA has highlighted the issues and recommendations have been made for policy level interventions in this regard. It was pointed out that even though the political economic influences in land development has been highlighted but the scope of the SEA limits the study from making recommendation on taxations and governance related issues. Maintenance cost for urban services and cost recovery mechanism were part of an administrative process and the SEA cannot provide solutions to these as these needed administrative interventions The SEA is a dialogue platform for all the stakeholders and the SEA had initiated this but collaboration between the two organisation belonging to two different ministries have to be taken up by the respective organisation and the ministries Specific provisions have been made in the SEA for capacity building of these institutions 34445 Final Aug 2007 A-10 SENES Consultants Limited

Comments legislations. To ensure this, capacity development of the local government agencies have to be enhanced. Md Moinul Haque, General Secretary, BAPA welcomed the recommendations of separation of planning, permitting, land development and monitoring to different agencies. He insisted that the SEA team should also make other Civil Society Organisations Hosne Ara Begum, Deputy Chief, MoHW pointed out that the SEA has number of strategic recommendation which requires consultation with the decision makers. She insisted that a round of consultation be held with the decision maker. Response The SEA team accepted the invitation and requested for a meeting between BAPA and SENES.. The SEA team aged with the proposal and requested that the ministry or the World Bank to organize such meeting for discussion of the SEA recommendation. 34445 Final Aug 2007 A-11 SENES Consultants Limited

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Stakeholder Analysis: Work Sheets IDENTIFICATION OF STAKEHOLDER GROUPS, THEIR INTERESTS, IMPORTANCE AND INFLUENCE Stakeholder Groups Department Environment (DoE) Water Planning (WARPO) Bangladesh Development (BWDB) of Resources Organization Water Board Dhaka Water Supply and Sanitation Agency (DWASA) Department of Public Health Engineering (DPHE) Interest(s) at Stake in Relation to planning in the DMDP region Responsible for formulating guidelines legislations etc are to be formulated for protection of the environment. The department is also responsible for enforcement of the environmental legislations and standards. The organisation is also responsible for providing environmental clearance for projects. It has been ineffective in controlling the environmental degradation in the city Apex organisation responsible for planning for exploitation of water resources would be important for sourcing surface water for water supply. Its influence on the DMDP has been limited Responsible for development of flood protection structures required for prevention of the flooding of the eastern fringe. Can play an important role in the protection of the wetlands in the eastern fringe as also the development in the region. The influence of the organisation on the planning and development process as low lying areas are filled up to reduce the risks of flooding Organisation responsible for water supply & sanitation in DCC & Narayanganj. Would play an important role in the prevention of contamination of surface and ground water from sewage. Its influence is limited to only to ist service areas Planning and installation of water supply & sanitation in areas except DCC & Narayanganj in DMDP area. Would be important for developing a sustainable surface water system in the fringe areas Effect of SEA on Interest(s) + 0 - Importance of Stakeholder for Urban Planning/Environment Protection U Unknown 1 Little/No Importance 2 Some Importance 3 Moderate Importance 4 Very Important 5 Crucial Player Degree of Influence of Stakeholder over the Planning and implementation process U Unknown 1 Little/No Influence 2 Some Influence 3 Moderate Influence 4 Significant Influence 5 Crucial Player + 4 3 + 4 2 + 3 2 + 5 3 + 4 3 34445 Final Aug 2007 A-13 SENES Consultants Limited

Stakeholder Groups Dhaka Coordination (DTCB) Transport Board Rajdhani Unnayan Katripokaha (RAJUK) Dhaka City Corporation (DCC) Pourashavas (POU) Union Parishods (UP) Bangladesh (BR) Railways Geological Survey of Bangladesh (GSB) Interest(s) at Stake in Relation to planning in the DMDP region The organisation is proposed to take over the coordination of transportation planning in Greater Dhaka. The involvement of the board is essential for development of efficient public transport system in DMDP. Its influence is limited as the local bodies develop their own transport plans Entrusted with the planning development and development control in DMDP. The organisation has limited presence in the region and has been under strong political-economic influence and has thus been ineffective in performing its functions The city corporation is responsible for providing urban services other than water supply and sewerage but is responsible for solid waste management but only in the DCC areas These five organisation are responsible for providing urban services (water supply, sewerage, solid waste management) in the pourashava areas. They are also involved with planning within their respective jurisdiction Most of the areas in the DMDP are under the jurisdiction of these local bodies but they have very little capability and influence over the planning process The development, management and operation of railways. They can play a very crucial role in the development of a mass rapid transport system in the DMDP. The organisation does not have any plans for expansion of the railway network in the DMDP region The organisation is entrusted with conducting geological investigations in Bangladesh. They can help in providing information on sustainable development planning but the organisation can only perform advisory functions Effect of SEA on Interest(s) + 0 - Importance of Stakeholder for Urban Planning/Environment Protection U Unknown 1 Little/No Importance 2 Some Importance 3 Moderate Importance 4 Very Important 5 Crucial Player Degree of Influence of Stakeholder over the Planning and implementation process U Unknown 1 Little/No Influence 2 Some Influence 3 Moderate Influence 4 Significant Influence 5 Crucial Player + 3 2 + 5 2 + 4 3 + 5 3 + 5 1 + 2 1 0 2 1 34445 Final Aug 2007 A-14 SENES Consultants Limited

Stakeholder Groups Bangladesh Centre for Advanced Studies (BCAS) Bangladesh Environmental Lawyers Association (BELA) Bangladesh Environment Movement (BAPA) Bangladesh Unnayan Parishad (BUP) Center for Natural Resources Studies (CNRS) Center for Urban Studies (CUS) Waste Concern (WC) Society for Environment and Human Development (SEHD) Interest(s) at Stake in Relation to planning in the DMDP region The NGO is active on issues of water pollution etc. They have been effective in developing awareness but has very little influence on the planning process there is very little involvement of the public directly or indirectly The NGO is at the forefront of the environmental legislative activism in Bangladesh. They have been able to obtain decrees against most of the environmental degradation process but has very little influence in stopping them because of lack of administrative support The NGO has been leading the environmental movement in Bangladesh and has been able to raise aawareness. In many cases they have helped in formulation of he opinion among the decision makers Effect of SEA on Interest(s) + 0 - Importance of Stakeholder for Urban Planning/Environment Protection U Unknown 1 Little/No Importance 2 Some Importance 3 Moderate Importance 4 Very Important 5 Crucial Player Degree of Influence of Stakeholder over the Planning and implementation process U Unknown 1 Little/No Influence 2 Some Influence 3 Moderate Influence 4 Significant Influence 5 Crucial Player + 2 2 + 3 4 + 3 4 The NGO undertakes environmental activities along with activities in other areas 0 2 2 The organisation operates in areas of natural resource management in Bangladesh 0 1 1 The organisation has been for along time taken up urban environmental issues in Bangladesh. They paly an important role in formulation of the opinion among the decision makers The NGO was the first to take collection of municipal solid waste from house holds and start composting. They have considerable influence on the policy makers on the aspect of waste management only The organisation has some activities with workers in tanneries They have limited influence in policy formulation and planning 0 3 4 + 3 3 0 1 2 34445 Final Aug 2007 A-15 SENES Consultants Limited

Stakeholder Groups Coalition for Urban Poor (CUP) Dhaka Chamber of Commerce & Industry (DCCI) Real Estate Housing Association of Bangladesh (REHAB ) Bangladesh Textile Manufactures Association (BTMA) Bangladeh University of Engineering and Technology (BUET) Detailed Area Plan Consultants (DAP) Consultants Institutue of Water Modelling (IWM) Vulnerable groups (VG) Interest(s) at Stake in Relation to planning in the DMDP region This is a coalition of NGO working in slums on issues such as access to basic services, and other issue of slums. They are responsible for The chamber of comers is a representation of the business in Dhaka. The two main industries in Dhaka garment and tanneries have their own associations so the influence of the chamber is limited in the DMDP region The association for real estate and land developers. The association has very litte role in the planning directly but due to political-economic reasons they influence the planning process This is an association of textile and dyeing units in Bangladesh. The industry association has been responsible for representing the interest of the industry owners against any measures for environment protection and relocation which would cause risk to their business interest The University provides technical expertise in different areas of planning. They are not part of the planning process in Dhaka but provide advisory services to the policy makers for formulation of the policies and plans They are involved in development of the detailed areas plans. They would be responsible for formulation of the plans the policies would be dictated by RAJUK. Thus they would have very little influence on the planning process The institute has developed expertise in hydrological modelling for the city but they can only provide advisory services if requested Thus they have vey little importance and influence on the planning process These people donot have secure tenure right s and are the wok hose of the Dhaka s economy are very poorly paid but contribute significantly to the GDP. They do not have access to proper access to urban services and procure the services at very high prices. Effect of SEA on Interest(s) + 0 - Importance of Stakeholder for Urban Planning/Environment Protection U Unknown 1 Little/No Importance 2 Some Importance 3 Moderate Importance 4 Very Important 5 Crucial Player Degree of Influence of Stakeholder over the Planning and implementation process U Unknown 1 Little/No Influence 2 Some Influence 3 Moderate Influence 4 Significant Influence 5 Crucial Player 0 1 3-1 4-2 4 0 2 3 + 2 2 + 2 2 1 1 34445 Final Aug 2007 A-16 SENES Consultants Limited

Stakeholder Groups Industry Workers (IW) Interest(s) at Stake in Relation to planning in the DMDP region These workers would be affected if there re are any relocation of industry but would not have any influence in the process of relocation Effect of SEA on Interest(s) + 0 - Importance of Stakeholder for Urban Planning/Environment Protection U Unknown 1 Little/No Importance 2 Some Importance 3 Moderate Importance 4 Very Important 5 Crucial Player Degree of Influence of Stakeholder over the Planning and implementation process U Unknown 1 Little/No Influence 2 Some Influence 3 Moderate Influence 4 Significant Influence 5 Crucial Player 1 2 34445 Final Aug 2007 A-17 SENES Consultants Limited

Step 3 of Stakeholder Analysis (continued): Mapping Key Stakeholders Relative Influence and Importance IMPORTANCE OF ACTIVITY TO STAKEHOLDER INFLUENCE OF STAKEHOLDER Unknown Little/No Some Significant Unknown U Little/No Importance 1 Some Importance 2 Moderate Importance 3 Much Importance 4 Critical Player 5 Unknown U Unknown Little/No Influence 1 Some Influence 2 Little / No Influence CNRS, VG, IW BRS, GSB UP REHAB BCAS, BUP,DAP,IWM BWDB,DTCB, BUET WARPO,BTMA RAJUK Moderate Influence 3 Significant Influence 4 Somewhat Influence CUP, DCCI WC DoE, DWASA, DPHE, DCC, POU BELA, BAPA, CUS Very Influential 5 Significant Influence Note: Insert key stakeholders in the appropriate cell: 34445 Final Aug 2007 A-18 SENES Consultants Limited

Final Consultation Workshop on Strategic Environmental Assessment of Dhaka Metropolitan Development Plan 16 August 2007 Venue: Dhaka Sheraton Hotel WORKSHOP PROCEEDINGS The Final Consultation Workshop on the SEA was held on 16 August 2007 at Dhaka as the final round of consultations with key stakeholders to discuss the draft Final Report of Strategic Environmental Assessment of DMDP and to seek concluding feedback. Workshop Objectives The principal objectives of the workshop were as follows: Apprise stakeholders of the findings and recommendations of the Strategic EA study; Develop broad consensus on the recommendations with the stakeholders of concern; Explore potential for assessing whether a consensus existed for setting up a regional (DMDP wide) strategic planning authority; and Discuss ways to kick-start institutional reform and carry out strengthening of key urban planning agencies responsible for planning and plan implementation in the DMDP region. Inaugural Session The workshop commenced with a recitation of the Holy Quran. This was followed by the inaugural address of Chief Guest, Mr A S M Rashidul Hai, Secretary, Ministry of Housing and Works. Mr Hai accepted in his speech that urban planning in Dhaka is presently constrained by a number of systemic shortcomings including lack on planning capacity within the apex planning agency RAJUK; inadequate coordination between various agencies; absence of land use zoning; and the non-existence of an overarching planning guidelines and planning document to guide urban development. This has resulted in fractured, haphazard and environmentally unsustainable urbanisation of Dhaka City. He also opined that it was unlikely for the DAPs planning process alone to solve the present problems of lack of urban infrastructure and associated environmental degradation until some action is taken at the strategic level to provide overall direction to urban planning in Dhaka. He said that such strategic planning needs to consider the entire DMDP area for dispersal of population, setting up of crucial infrastructure like sewage treatment plants or looking at ways for flood protection and control, keeping in mind long term scenarios. He also pointed out current scenario was unacceptable and the proposed changes provided an opportunity 34445 Final Aug 2007 A-19 SENES Consultants Limited

to build improvements that promote environmentally sustainable and socially sensitive planning. Importantly, he also conveyed that the Government was prepared to consider appropriate reform in the institutions that play a key role in urban planning for Dhaka and also improve their planning capabilities through systematic strengthening and capacity building. He noted that the workshop was represented by members of key stakeholder groups and wanted it to be the platform to discuss the need for such new approaches and try and arrive at a consensus for taking the recommendations forward. Chief Guest Mr A S M Rashidul Hai delivering his address in the Inaugural session In her welcome address to the workshop by Ms Nayeema Khatun, Project Director SEA, she provided a brief outline of the planning process within the DMDP area and the presently ongoing DAP plan preparation process. She stressed on the need for environmentally-sound planning and underlined that this has prompted RAJUK in initiating this study with support from the World Bank. She explained that the SEA study was intended to undertake a detailed review of the existing DMDP and sectoral plans, understand their linkages with priority environmental issues and complement the DAP preparation process by providing an overall environmental framework for the DAPs. She requested the participants to come forward with opinions on the findings and recommendations of the study after reviewing the Executive Summary provided to the participants. She also expressed hope that the deliberations of the workshop would go a long way in drawing up inclusive and participative Detailed Area Plans in close collaboration with various other sectoral agencies and administrative authorities and would help the city to grow and prosper in an environmentally sustainable way. Dr A K Ghosh, Senior Environmental Specialist of SENES briefly outlined the approach taken by the study team and explained the key conclusions reached. He explained that the that the priority environmental issues and constraints in the city of Dhaka were related primarily to the use of land and water resources and how their management have been factored into the recommendations that have been proposed by the study. He stressed on the need for drawing up a regional planning perspective taking the entire DMDP area and the immediate need for mapping of the present landuse and the establishment of a landuse control system for the city. 34445 Final Aug 2007 A-20 SENES Consultants Limited

In his inaugural speech, special guest to the workshop Mr A H M Rezaul Kabir ndc, Secretary Ministry of Environment & Forest briefly referred to the magnitude of the environmental problems present in Dhaka city and pointed out that many of these environmental problems being encountered were a direct result of decades of unplanned and haphazard growth that the city has witnessed with scant regard to environmental considerations and issues. He noted that though the country had established project level EIA system, it has not worked to the satisfaction of the Ministry to be an effective mechanism because of the lack of proper monitoring and enforcement machinery within the government. In this context, he observed that higher-level (strategic) environmental assessments can play an important role to help decision makers to take important urban planning decisions that would help in arresting further environmental degradation in Dhaka and make progress towards building a cleaner and sustainable city that will provide it residents with a better and healthier quality of life. In his inaugural speech, the Guest of Honour, Mr Xian Zhu, Country Director, The World Bank expressed his satisfaction at the way that Bangladesh is making steady progress with regard to a number of development indicators and said that the World Bank is extremely happy to be a partner in its advancement. He observed that the SEA study has played a crucial role in highlighting the gaps in the planning process and the institutional weaknesses that have hindered the planned development of the city in accordance with DMDP formulated in the early nineties and have brought into focus high potential risks to the environment and the vulnerable sections of the society. For example, he said that the study has pointed out the high risk of flooding to certain fringe areas of the DMDP can be further aggravated by climate change impacts in the medium to long term and has consequently highlighted an urgency to draw up integrated regional plans accounting for the entire DMDP area. He also noted that the study has also pointed out a need for institutional reforms and strengthening of key planning agencies like RAJUK in order to ensure that urban planning in Dhaka is undertaken in a holistic manner and factoring the requirements of the weaker sections of the society whose interests have been neglected in the current planning process. The World Bank, he said, would be happy to support the Government of Bangladesh in this process. After this, a detailed presentation was made by Mr Debanjan Bandyopadhyay, Deputy Team Leader of the SEA Team on the findings and recommendations that have emerged from the study. He explained the specific objectives of the study and the methodology adopted. In doing so, he explained the reasons for the study to have metamorphosed into an institution-centric study from an environmental one. He elucidated the four priority issues that were short listed based on technical analysis and after receiving inputs from stakeholders on the environmental issues. Subsequently, the significant risks arising as a result of the gaps in the existing planning framework, weaknesses in the institutional setup and political economy considerations were explained. The high risk of progressing with the DAPs without having a higher level strategic planning guidelines based on current landuse and proposed landuse were also highlighted. This was followed by a presentation of the recommendations and requested the participants to freely speak up as the SEA team was open to receiving suggestions and feedback on both the findings and the recommendations of the study. Subsequently, Mr M A Qasem, Director General, Local Government and Rural Development said in his speech that he agreed with the findings of the SEA and many of the key environmental problems are 34445 Final Aug 2007 A-21 SENES Consultants Limited

influenced by political economy factors and little coordination between institutions responsible for plan implementation and monitoring. He observed that until some interventions were made at high level, finding solutions through end-of-the-pipe methods after the problems have already been created as result of faulty planning or inadequate coordination between institutions would only be superficial and is unlikely to solve the issues. He concluded by saying that there is a need to explore ways through which such coordination between RAJUK and the Dhaka City Corporation, Pourashavas and Sectoral Agencies like DWASA can be effected and agree on whether the Government should consider setting up of a higher level body to provide leadership in this regard or strengthen existing institutions appropriately to improve their planning capabilities and establish better systems for bringing about effective collaboration between all concerned departments and agencies. The inaugural session of the workshop was chaired by Mr K A M Haroon, the Chairman of RAJUK. In his concluding remarks to the inaugural session, he thanked the distinguished speakers for being present at this important workshop and for expressing their views on the SEA study. He noted that the deliberations at the inaugural session have confirmed that if proper thought is given at the planning and decision making level, many of the environmental problems of Dhaka can be solved more effectively. He also observed that if the strategic assessment had been undertaken earlier, it may have resulted in better understanding of the weaknesses in the planning system and prevent some of the environmental damages that have already taken. After taking note of the earlier discussions, he was in broad agreement with the study s recommendations and hoped that they can help in making necessary corrections in the DAP preparation process that are presently underway and also requested considering the establishment of a regional planning authority to guide the DAP consultants and associated sectoral agencies in carrying out the planning task effectively and efficiently. Before concluding the session, he also thanked the World Bank to support such a study. Technical Session The participants were divided into two groups to discuss the following two topics. After an hour and half of discussion the groups came back and presented their consensus on taking this study forward: Group A: Strategic Environmental Planning Framework for Dhaka The need for a higher level urban policy for delineating broad directions of growth, based on assessment of existing landuse in the DMDP, was felt required to adequately guide the local level DAP planning process. It was discussed that the present DAP consultants would be able to complete the DAP formulation process with existing capabilities, in spite of certain hurdles being faced. The participants requested the SEA consultant to bring out the positives of the DAP planning process. Opinion was expressed by the DAP consultants that the Terms of Reference for the DAP planning studies need to be modified taking into consideration ground level planning requirements and constraints. 34445 Final Aug 2007 A-22 SENES Consultants Limited

The planning capabilities of RAJUK should be strengthened and in spite of the apparent weaknesses, it was agreed that with proper capacity building, it can play an important role in the urban planning process of Dhaka. However, the group also agreed that RAJUK should not be responsible for both planning in the area as well as in developing projects. This was viewed as being in conflict of interest. It was pointed out RAJUK was more keen on development as it yielded more revenues. A pressing need was felt by the group to improve coordination between RAJUK and the various sectoral and utility organisations that play a role for the development of Dhaka city. Group discussions as a part of the Technical Session in progress Group B: Engagement of Stakeholders in Urban Planning Three levels of engagement were proposed by the group: National level for developing policies and guidelines in urban planning for the country; Regional Level DMDP for developing regional level plans based on a national strategy; and Lastly, local level engagement through ward-committees and other mechanism; There was consensus that Television was the media of choice for creating awareness amongst the Bangladesh masses and this media was never used to let people know what was being proposed for DAPs. The recommendation was to make se of this media for awareness building and seeking feedback. Other media like Internet websites should also be effectively utilized for seeking feedback.\ There was a strong need felt for building awareness among all sections of society including government agencies, NGOs and public on environmental sensitive areas and how the unplanned infrastructure development was causing problems on several front including water pollution, floods, poor air quality etc. 34445 Final Aug 2007 A-23 SENES Consultants Limited

This was felt necessary for the public to effectively provide feedback as well as fight the system to ensure this does not go on. PANEL DISCUSSION Professor Nazrul Islam, the Chair for the panel and a distinguished urban planner, set the tone for the discussions by briefly relating his appreciation of the progression of urban plans for the city of Dhaka. Taking part in the discussions, Mr Md. Nasiruddin, RAJUK, Member Planning accepted the weaknesses in RAJUK that were pointed out in the study and the need to take the opinion of experts present to bring in necessary reforms in the planning system and within RAJUK. He said that in spite of the apparent lapses, with appropriate support from other agencies and with proper reinforcement of planning capacity, RAJUK as the key agency can play an important role to undo some of the environmental damage that has already been done. Expressing his views, Dr. Ainun Nishat, Director - IUCN pointed out that the SEA consultations should have been more encompassing and thorough. He expressed the need for protecting existing environmentally sensitive areas like wetlands and other natural habitats with the city through proper landuse zoning and implementation of landuse control plans. Prof Nazrul Islam expressing his views at the Panel Discussion Dr A K Ghosh referred to a case study from Kolkata where the east Kolkata wetlands, now a Ramsar declared protected site, and adjoining agricultural fields, played an important role in the urban ecology of a large metropolitan city. He expressed the opinion that such approaches need to be considered at the highest strategic level before deciding upon the development and landuse of about 1000 sq kms of fringe areas of Dhaka city which comprise primarily of agricultural areas, flood flow zones and wetlands. Mr K M Minnatullah from the World Bank noted that the World Bank is planning to take an integrated program for improvement of water quality in the entire Dhaka watershed through the DWINRP project and the overall urban plans of the city has to be drawn up in a manner that it complements the project. As a result, he felt that the RAJUK would have to play the role of an important stakeholder in the project and 34445 Final Aug 2007 A-24 SENES Consultants Limited

the World Bank is ready to extend support to RAJUK and build necessary capacity within the organisation. Mr Murali Ganapathy from SENES clarified requests of various stakeholders on why only four priorities were presented in the Executive Summary and that air quality, noise, transportation and industrial pollution were all discussed in the detailed report. He further highlighted that implementing a strong environmental impact assessment system and procedure for infrastructure projects can address key environmental impacts of key urban infrastructure projects and at the same time result in increasing public awareness and participation in the development process. The panel discussion concluded with Prof Nazrul Islam summarizing the individual speakers and stressed on the following key issues: Developing a regional urban planning guidelines to ensure uniformity all across the region; The need to draw up a landuse plan for DMDP region highlighting all key sensitive areas; Removing the current conflict of planning and development by the same agency; and Carry out adequate reform of RAJUK and reinforce its capacity to undertake planning and monitoring effectively. The Workshop was concluded with a Vote of Thanks by Mr Neaz Rahman, SEA Team Leader. He thanked all the distinguished guests and the stakeholders for providing the SEA team with the benefit of their views and felt that this feedback will immensely help in further refining the final report of the study. 34445 Final Aug 2007 A-25 SENES Consultants Limited

FINAL STAKEHOLDER WORKSHOP PARTICIPANTS LIST STRATEGIC ENVIRONMENTAL ASSESSMENT HELD ON 16 AUGUST 2007 SL No. Name of Participant Designation Organisation 1 Abdullah Mamun Prothom Alo Staff Reporter 2 Abu Kaur Sanchar Senior Reporter 3 Abul Rahim Ajker Kagoj Staff Reporter 4 AHM Rejaul Kobir Secretary Environment and Forest Ministry of Environment and Forest, GoB 5 Ainul Nishant IUCN Country Representative 6 Akhtar Ahmed M/O Housing and Public Works Joint Secretary(Administration) 7 Amanat ullah Khan RAJUK GIS Specialist 8 Aminul Islam Amader Shomoy Staff reporter 9 Aminur Rehman CSB News Staff REporter 10 Amzad Hussain LGED Project Director M/O Housing and Public 11 Ayesha Begum Works 12 Badirul Alam AEJB/Mddin 13 Chairman RAJUK 14 Dr. Jahirul Islam LG Division Deputy Chief 15 Dr. Md. Rezaul Karim KUET Prof. CE Department 16 Dr. Mostafa Kamal Farooqui DOE DD(NRM) 17 Dr. Tariq Bin Yousuf DCC Project director,swm,dcc 18 Dr.AKM Golam Rabbani Dhaka University Professor 19 Dr.Salehuddin DTCB Additional Executive Director 20 Engr.Mumitur Rahman IMED Assistant director 21 Ezaz Hossain Janakatha Sr Reporter 22 Farhan rahman EPC Assistant Town Planner 23 Hosne Ara Begum M/O Housing and Public Works Deputy Chief 24 Ishrat Islam BUET Assistant professor 25 Jahrool Hoon RAJUK TPCL 26 Jane Crowder DFID Infrastructure Advisor 27 Kahim Akther VNB Staff correspondent 28 Kamran Reza Chowdhury bdnews24.com Senior Staff correspondent 29 Katherine Davis UNDP Environmental Planner 30 Kazi hasiba Jahan DCC Geographer 31 Kh. M. Ansar Hussain EPC Senior Planner 32 Kh. Neaz Rahman Team Leader TCIL-SEA Team 33 Lailun Naher Eknon WAEPA Chairperson 34 M Inamul Haque WARPO DG 35 M.Ariful Islam Sheltech Assistant manager 36 M.Salem Suleiman DCCI Director Director 37 Mahbubur Rahman DDC Ltd. Director& DAP Gr. ATL 38 Mahiuddin Ahmed BCAS Senior Environment Specialist 39 Mamunul Khan UNDP Programme Officer 40 Md Ashraful Islam EPC Assistant Planner 41 Md Karul haque Roads & Highways Department Executive Engineer 34445 Final Aug 2007 A-26 SENES Consultants Limited

42 Md Khairul Islam Tongi Pourasabha SE 43 Md. Alkasuddin DWASA SE(P&D) 44 Md. Amirul GBL Town Planner 45 Md. Delwar Hussain DWASA SE 46 Md. Golam Mustafa Peng DDC Environment Specialist 47 Md. Junayed Ibne-Shariff RAJUK GISO 48 Md. Munsur Ali Sikder RAJUK Member(Dev) 49 Md. Nashiruddin RAJUK Member(Planning) 50 Md. Sazid Suleiman Focus Bangla Photo Journalist 51 Md. Shah Alam RAJUK Chief Engineer 52 Md. Shahjahan Fire Service and Civil Defence Assistant Director 53 Md. Shamim Jahangir The Independent Staff Reporter 54 Md. Sirajul Islam RAJUK PM. DAP 55 Md. Suiduz Rahman NSI Field Officer 56 Md. Tarek haider BUET Architect Advisor 57 Md. Taufiqul Islam Gazipur Pourasabha Town Planner 58 Md.Abdul Hakim Day Shangbad Staff reporter 59 Md.Akter Mahmud JU Associate Professor 60 Md.Ashraf Ali Akhand RAJUK DTP 61 Md.Moinul Islam Narayan gunj Municipality Town Planner 62 Md.Nahmadul Hasan DTCB Senior Town Planner Bangladesh Power Development 63 Mirza Shah pier Jalil Board Architect Advisor Mohammad Tasharuf 64 Hossain Farazi Local Govt. Division Senior Assistant chief 65 Monirul Haque Azal Inquilab Sr Reporter 66 Moushumi Ahmed Waste Concern Architect Advisor 67 Murali Ganapathy SENES Project director SEA 68 Nayeema Khatun RAJUK Project director 69 Nurul Amin Kadam Rasul Pourashava Assistant Engineer 70 Omar Faruqui CSB News Reporter 71 Prof. Dr.Golam Rahman Gani Bangla Ltd. Team Leader 72 Rafiqul Islam Savar Pourasahva X-EN 73 Rezvi Newaz Channel-I Staff Correspondent 74 Rezwan Alam World Bank SCO Director, Environmental 75 Rita Sutradhar EPC Ltd. specialist 76 Saiful Alor Diganta Staff reporter 77 Salahauddin Babbar Inquilab Senior Reporter 78 Shafiqul UNICEF UDS 79 Sheikh Sabina Alam The Daily Star StaffCorrespondent 80 Sohrab Hussain BUET Professor 81 Sonia Nowrin LGED Assistant Engineer 82 Sunil Baran Debroy BWDB Project Director 83 Swapan poddar TCIL Environmentist 84 Swarna Kazi World Bank PA 85 T K Nath Ex WHO Ex Project officer 34445 Final Aug 2007 A-27 SENES Consultants Limited

86 Taufique Ali The Daily Star Staff Reporter 87 Tutul Rahim Manabzamen Reporter 88 Xian Zhu World Bank Country Director 89 Yasuo Fujita JBIC Chief Representative 34445 Final Aug 2007 A-28 SENES Consultants Limited

NEWS COVERAGE OF WORKSHOP The Daily Star Incorporate environmental issues into city's dev process Speakers tell workshop Staff Correspondent Speakers at a workshop have underscored the need for incorporating environmental issues into the city's overall development process to enhance the quality of life of its dwellers. The workshop titled 'Strategic Environmental Assessment of Dhaka Metropolitan Development Plan' was held at a city hotel on Thursday to disseminate the objectives of Strategic Environmental Assessment (SEA). The government has proposed the SEA for Dhaka Metropolitan area to shed light to complex interactions between environmental, social, economic and institutional factors linked to urban planning and development. World Bank is supporting the government in framing the draft SEA, and Rajuk would be the implementing agencies. Terming the urban planning of Dhaka a 'quagmire' of poor planning process and plans, Dr AK Ghosh, senior environmental specialist, said low level of environmental awareness among sectoral and local planners and very limited efforts to achieve real public good were evident in the urbanisation process. Stressing on bringing other actors like the utility service providers on board, he further said as Rajuk is active in the development of commercial areas like shopping centres and malls, it very often overlooks the planning guidelines and encroaches on environmentally sensitive areas. AHM Rezaul Kabir, secretary to environment and forest ministry, laid emphasis on regional consensus on environmental issues and said a strategic plan to this end may act as baseline policy for future planning of the city. Lauding the timely approach of the government, Zhu Xian, country director of the World Bank, said as urban plans are being formulated for six regions of Dhaka Metropolitan area, it is considered to be an ideal time to undertake an independent assessment about the possible environmental consequences of the implementation of such plans and build corrective measures wherever required. MA Qasem, director general of LGRD, laid emphasis on coordinated and concerted efforts by all the concerned institutions. ASM Rashidul Hai, secretary to housing and public works ministry, KAM Haroon, chairman of Rajuk and Nayeema Khatun, project director of SEA also spoke on the occasion. Debanjan Bandyopadhyay, team leader, made a presentation on draft SEA report. 34445 Final Aug 2007 A-29 SENES Consultants Limited

The Daily Independent, Bangladesh Dhaka-Strategic Environmental Assessment Unplanned urbanisation responsible for water crisis in city STAFF REPORTER Speakers at a workshop yesterday said that unplanned urbanisation and in discriminate use of underground water are responsible for the recent natural disaster like water logging and water crisis in the city. "The capital city expanded without planning and eighty per cent of the people of Dhaka city lifted their usable water from underground. So, the excessive use of underground water has brought down water level day by day", experts at the workshop said. "Violating laws and the lack of coordination between RAJUK and Dhaka City corporation (DCC) for development activities in city are the main reasons for environmental disaster, the environmental specialists also said. They made their remarks at a workshop on "Strategic environmental assessment of the detailed area plan," held at Sheraton Hotel in the city. The RAJUK and World Bank jointly organised the daylong workshop before publishing its final report. ASM Rashidul Hai, secretary of housing and public works was present as chief guest while AHM Rezaul Kabir, secretary of ministry of environment and forest, Muhammed Abul Quasem, director general of local government division also addressed the inaugural session. KAM Haroon, chairman of RAJUK chaired in the inaugural session. Housing and public works secretary Rashidul Hai said that the political economy of the then governments has created this manmade natural disaster like water logging in the city. "We have taken necessary steps to stop artificial natural disaster like water logging in the city", he added. World Bank country director Xian Zhu presented the keynote paper at the workshop on the draft report of the Strategic Environmental Assessment (SAE) and said that all the residents of Dhaka are to some extent impacted by the deteriorating water level. "The poor people have few options for accessing clean water are the most vulnerable", Xian Zhu said. The overall urban planning process should take strategic planning to prevent the high risk of the flooding in certain areas of the Dhaka", Xian Zhu told the workshop. Dhaka is undergoing massive expansion and its current population of 12 million will increase to 20 million by 2020, making it the world's third largest city, Khawaja Minnatullah, senior environmental specialist of the World Bank said. Speakers at the workshop suggested introduction of strategic urban planning for Dhaka to promote environmentally sustainable growth of the capital. "Unplanned growth, uncoordinated activities and also unabated environmental pollution-the economic cost associated with environmental degradation may amount to more than four per cent of the total GDP", he added. He pointed out that institutional reforms and strengthening of the key planning agencies like RAJUK is urgent for sustainable urban planning in Dhaka. 34445 Final Aug 2007 A-30 SENES Consultants Limited

THE FINANCIAL EXPRESS, DHAKA Dhaka-Strategic Environmental Assessment Strategic urban planning must for sustainable growth FE Report Strategic urban planning is urgently needed for Dhaka to promote environmentally sustainable growth of the country as well as of the capital city, according to the World Bank (WB). "Greater Dhaka currently represents more than 40 per cent of Bangladesh's national gross domestic product (GDP). The overall urban planning process should take strategic planning principles into account to prevent the high risk of flooding to certain fringe areas of the Dhaka Metropolitan Development Plan. Such floodings are likely to be further aggravated by climate change impacts in the medium to long term", said World Bank (WB) Country Director Xian Zhu during a workshop Thursday. A S M Rashidul Hai, Secretary, Ministry of Housing and Public Works, was present as Chief Guest of the workshop on "Strategic Environment Assessment of Dhaka Metropolitan Development Plan," jointly organised by RAJUK and the WB. A H M Rezaul Kabir, Secretary, Ministry of Environment and Forest and Muhammad Abul Quasem, Director General, Local Government Division, also spoke in the inaugural session, chaired by K A M Haroon, Chairman, RAJUK. Dhaka is also undergoing a massive expansion and its current population of 12 million will reach 20 million by 2020, making it the world's third largest city with unplanned growth, uncoordinated activities and unabated environmental pollution. The economic costs associated with environmental degradation may amount to more than 4 per cent of GDP, said WB's senior environmental specialist. The unplanned urbanisation has raised two sets of environmental challenges in Dhaka city. The first arises from urban development projects in different sectors and industries which treat potential environmental effects as externalities and only try to mitigate these effects as an afterthought and do not include it as an integral part of their project. The second set of environmental issues stem from the acute pressure on natural resources resulting from the indiscriminate use/misuse of these resources. The government undertook the Strategic Environmental Assessment (SEA), supported by the WB and implemented by RAJUK, to underpin the complex interactions between environmental, social, economic and institutional factors linked to the urban planning and development of Dhaka city. The study found the urgent need for institutional reforms and strengthening of key planning agencies like RAJUK, to ensure that urban planning in Dhaka is undertaken in a holistic manner. 34445 Final Aug 2007 A-31 SENES Consultants Limited