Environmental Impact Assessment Review

22 (2002) 163 – 179

www.elsevier.com/locate/eiar

Environmental impact assessment

in Bangladesh:
A critical review
Salim Momtaz*,1
School of Applied Sciences, Centre for Sustainable Use of Coasts and Catchments, University of
Newcastle, Ourimbah, NSW 2258, Australia
Received 1 October 2001; received in revised form 1 December 2001; accepted 1 December 2001

Abstract

Bangladesh initiated environmental impact assessment (EIA) guidelines in 1992 for

the water sector development. The country enacted EIA legislation in 1995 and EIA
rules in 1997. Today, all major donor agencies working in Bangladesh have their own
EIA guidelines. This paper reveals that (a) the guidelines developed by the government
and the donor agencies are stringent, however, there is less emphasis on monitoring,
(b) proper implementation of EIAs are largely dependent on the requirements of the
donor agencies and (c) there is a lack of coordination among the various organizations
involved in environmental decision making and of adequate infrastructure to ensure
proper EIA. D 2002 Elsevier Science Inc. All rights reserved.

Keywords: Environmental impact assessment; Social impact assessment; National Environmental

Policy Act 1969; Environmental sustainability assurance; Department of Environment; Environmental
Conservation Act 1995; Environmental Conservation Rules 1997

* Tel.: +61-2-43484131; fax: +61-2-43484145.

E-mail address: smomtaz@mail.newcastle.edu.au (S. Momtaz).
1
hhttp://www.ccc.newcastle.edu.au/science/srmi

0195-9255/02/$ – see front matter D 2002 Elsevier Science Inc. All rights reserved.
PII: S 0 1 9 5 - 9 2 5 5 ( 0 1 ) 0 0 1 0 6 - 8
164 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

1. Introduction

Environmental impact assessment (EIA) is the process of assessing

the consequences that are likely to flow from a proposed development.
It is a planning and management tool for sustainable development that seeks
to identify the type, magnitude and probability of environmental and social
changes likely to occur as direct or indirect result of a project or policy
and to design the possible mitigation procedure (Vanclay and Bronstein,
1995; Harvey, 1998; Momtaz et al., 1998; Thomas, 1998). National
Environmental Policy Act 1969 is the legislative basis for EIA, which
was the result of wide spread recognition in the US in the 1960s that some
major environmental problems were created by the government’s actions.
This legislation required that all federal agencies would consider the
environmental consequences of their actions. Within a few years time,
many developed and developing countries designed their EIA legislation.
By 1990s, developing countries in Asia emerged at the forefront of EIA
practice in the developing world (Gilpin, 1995). Today, EIA is firmly
established in planning process in many of these countries. However, many
authors (see, for example, Briffett, 1999) suggest that despite the existence
of good EIA guidelines and legislation, environmental degradation continues
to be a major concern in these countries. EIAs have not been able
to provide ‘environmental sustainability assurance’ (ESA) for these countries
(Sadler, 1999). For Bangladesh, it was not until 1992 that the country
had its first EIA guidelines. This paper examines the evolution and
present status of EIA in Bangladesh, identifies the constraints and proposes
some remedies.

2. Methods

I visited Bangladesh between November 2000 and February 2001, as a

recipient of a ‘Rotary Grant for University Teachers.’ During this 3-month
period, I visited all major organizations involved in the design of EIA
procedure and implementation of EIA and had extensive discussions with
relevant personnel. These organizations are Department of Environment
(DOE) of the Government of Bangladesh, United Nation’s Development
Program (UNDP), World Bank (WB) Dhaka Office, CARE Bangladesh,
Bangladesh Centre for Advanced Studies (BCAS), and Environment and
GIS Support Project for Water Sector Planning (EGIS), Ministry of Water
Resources. I also collected and thoroughly examined relevant literature on
EIA published by these organizations. To examine the quality of EIAs
conducted in Bangladesh, a major EIA report (EGIS II, 1998) has been
reviewed using the guidelines suggested by Modak and Biswas (1999).
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 165

3. Evolution of EIA in Bangladesh

3.1. Legislative and institutional framework

Legislative bases for EIA in Bangladesh are the Environmental Conser-

vation Act 1995 (ECA ’95) and the Environmental Conservation Rules 1997
(ECR ’97). DOE, under the Ministry of Environment and Forest, is the
regulatory body responsible for enforcing the ECA ’95 and ECR ’97
(BCAS, 1999). During the decades of 1970 and 1980, the government of
Bangladesh, with a view to alleviating poverty and resolving the country’s
unemployment problem, resorted to many industrial and agricultural develop-
ment projects. Much of these development activities took place without
paying any attention to their environmental consequences. As a result, the
country suffered from environmental degradation in many areas. One
burning example is the large-scale contamination of groundwater by arsenic.
However, there is a recent realization that development could not be
sustained if due consideration was not given to environmental protection.
Consequently, the government of Bangladesh, with the view of providing for
the conservation and improvement of environmental quality and controlling
and mitigating pollution in the environment, enacted the ECA ’95, which
became effective on June 1, 1995. Section 12 of this Act stipulates that
‘‘No industrial unit or project shall be established or undertaken without
obtaining environmental clearance from the Director General, DOE, in the
manner prescribed by the rules’’ (DOE, 1997, p. 1). Clause (2) (f) of
Section 20 requires that rules be made to ‘‘evaluate, review the EIA of
various projects and activities, and procedures be established for approval’’
(BCAS, 1999, p. 43). To meet these requirements, ECR ’97 was promul-
gated. Although it is the responsibility of the proponent to conduct an
EIA of development proposal, the responsibility to review EIAs for the
purpose of issuing Environmental Clearance Certificate (ECC) rests on DOE
(DOE, 1997).
Industrial projects have been divided into four categories — Green, Am-
ber A, Amber B and Red (DOE, 1997), according to the environmental
significance and location of proposed industry. Category Green projects do
not require initial environmental examination (IEE) and EIA. A no objection
certificate from the local authority is adequate for a project that fall into the
Green category. On the other extreme of the range are the Red category
projects, which require both IEE and EIA. This normative screening process
enables DOE and proponents to determine which steps to follow in the
environmental clearance process (Fig. 1). It may be mentioned here that
special emphasis is placed on site selection for industries with significant
potential for environmental impacts, and the proponents are required to
consider alternative sites keeping in view the criteria put forward by the
DOE (DOE, 1997).
166 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

Fig. 1. Steps involved in environmental clearance from DOE. (Source: DOE, 1997, p. 7).

The important stages in the development of a EIA study according to EIA

Guidelines for Industries prepared by DOE (DOE, 1997) are:

 Screening/scoping.
 Identification of significant environmental issues and how these will
be resolved.
 Adequacy of mitigative measures and the Environmental Management Plan.

Fig. 1 shows the various phases in environmental clearance, and Fig. 2

illustrates the place of EIA in project cycle. The steps in EIA recommended
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 167

Fig. 2. Project planning, its implementation and DOE’s EIA process. (Source: DOE, 1997, p. 8).

by DOE are similar to those mentioned in all major literature as follows:

baseline study (similar to scoping); impact identification; impact prediction;
impact evaluation; mitigation measures; monitoring programs; special stud-
ies, if applicable, like risk assessment, resettlement and rehabilitation study,
etc.; and documentation and communication (DOE, 1997).

3.2. Environmental geographic information systems (EGIS)

EGIS (a project under the Ministry of Water Resources, Government of

Bangladesh) looks after the conduct of the government’s EIA of projects in
the water sector. In 1991, this organization (the then Flood Action Plan or
FAP) developed 26 components in flood action plan, the sixteenth com-
ponent of which was environmental study of FAP. This organization
developed a set of guidelines for EIA of the water sector development.
The guidelines were basically based on donor guidelines, e.g., WB and
Asian Development Bank (ADB).
168 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

One important aspect of the procedure (Fig. 3) is that it places

significant emphasis on community participation. It was realized that water
infrastructure projects would have significant consequences on the local
communities, and it was important that the latter played active role in
decision making and the implementation of projects. An attempt was
made to develop formula to quantify impacts through the use of weighted
matrix method.
FAP’s draft guidelines were bitterly criticized as being a textbook
exercise, i.e., taken from donor agencies; not adapted to suit local conditions.
Western style community consultation was proposed, which would be
difficult to adopt in rural areas of Bangladesh where most people were
illiterate and did not have enough awareness of environmental impacts to
make meaningful contribution through participation. In addition, questions
were raised about the use of mathematical formula to quantify impacts. The

Fig. 3. Procedural steps in FAP’s EIA. (Source: FAP, 1992, p. 18).

 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 169

criticisms were well taken, and revised guidelines were experimentally

applied to four different cases in four regions, namely, the Sylhet and
Tangail districts and two other places in the coastal region. These were all
concerned with the development of water infrastructure, such as embank-
ments, regulators, sluice gates, etc. EIA’s main emphasis was on biophysical
environment but, generally, impacts on four areas were considered — land
resources, water resources, biological and socioeconomic.
Many modifications were made to the draft through trial and error process.
After a number of workshops and the adoption of DOE’s suggestions, the
final version was published in 1992 (FAP, 1992). A number of weaknesses
still remained in the guidelines, for example, legal aspects of project impacts
were not considered. Although in all cases, initial environmental evaluation
was to be conducted before EIA, there were no separate guidelines for IEE.
However, DOE (1997) has clearly outlined the IEE process, which is likely to
fill this gap.
In February 2001 (the field work period), EGIS was in the process of
reviewing its EIA guidelines with a view to eliminating the weaknesses still
remained. A revised and improved version is expected in late 2001.

3.2.1. Review of a major EIA and SIA conducted by EGIS

To get a feel for the quality of EIA in Bangladesh, a brief review of
the Environmental and Social Impact Assessment of Khulna – Jessore Drain-
age Rehabilitation Project (KJDRP) (EGIS II, 1998) has been conducted
here (Fig. 4). The KJDRP is located in the southwestern part of Bangla-
desh and comprises parts of both Khulna and Jessore districts. The total
project area is 127,800 ha with an estimated population of 1.1 million in
1997 (EGIS II, 1998). It comprises numerous tidal rivers and creeks, which
provide a drainage network to a system of embanked hydrological units
or polders in which the in- and outflow of water can be controlled
through regulators.
The construction of embankments in the sixties greatly reduced the tidal
volumes entering and leaving the project area during the tidal cycles. This
resulted in gradual siltation of the drainage networks. About 20% of the land
had been taken out of agricultural production, and many households had to
migrate to other places. In 1995, the Government of Bangladesh (GOB), with
financial support from the ADB, initiated the KJDRP to find permanent relief
to the suffering of the local people. In 1997, EGIS was appointed by the
Ministry of Water Resources for an independent environmental and social
impact assessment study of two technical alternatives: a regulator at either
Shibnagar or Madhukhali.
The assessment team was a balanced one, consisting of local and
international experts with backgrounds in water resource planning, agronomy,
sociology, economics, ecology, fisheries, biology and GIS. Local communities
were extensively consulted through rapid rural appraisal, workshops and
170 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

Fig. 4. Review of a major EIA and SIA conducted by EGIS.

group discussions in the development of the preferred option to ensure the

acceptability of the project. Review of the EIA report for this project (Fig. 4)
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 171

reveals that it satisfies most of the review criteria developed by Modak and
Biswas (1999).
This sophisticated and highly technical study was conducted for 3 months
and was supported by a number of international and national agencies. It would
be interesting to know how much money was spent on this study and how the
project was to be implemented and monitored.

3.3. CARE Bangladesh, Local Government Engineering Department (LGED)

and the United States Agency for International Development (USAID)

The Ministry of Relief and Rehabilitation initiated the Food for Work
Program in 1975. This program employed landless people in earthen road
construction in rural areas in exchange for food. It became a major works
program at a later stage (Integrated Food For Work Program, IFFW)
employing 500,000 people in rural areas during slack season (Nakashima
and Khan, 1994). CARE Bangladesh played a supervisory role in this
USAID funded project. In 1990, a programmatic environmental assessment
(PEA) was conducted to assess the success of IFFW. A social soundness
analysis was also conducted. These two studies revealed that, on the one
hand, the programs negatively impacted upon the Bangladesh environment
through damaging wetland ecosystems, flooding, loss of agricultural land and
declining numbers of fish species. On the other hand, they contributed
towards polarization of power and resources and inequality in rural areas.
Benefits of FFWP were not only undermined by this but also the outcomes
were inconsistent with the country’s sustainable development goals (Khan
and Fitzcharles, 1998).
Against this background, CARE took initiative to improve the sustain-
ability of its projects. An environmental review is incorporated in the early
planning process. In 1991, CARE founded an Environmental Management
Unit and formalized the Environmental Action Plan. The plan required that
every road construction plan must undergo IEE, which would allow the
identification of projects that would require EIA. In 1994, CARE Bangladesh
and USAID joined the Ministry of Local Government and Rural Devel-
opment (LGRD) to start the next phase of the FFWP -Integrated Food For
Development Program (IFFD). LGED performed the administrative arm for
the Ministry of LGRD.
Environmental concerns are very well incorporated in the IFFD envir-
onmental policy which says: (a) every road under the program will require
IEE before the work can be authorized — at this stage, roads requiring full
EIA are identified; (b) roads passing through unprotected forest areas must
obtain a ‘no objection certificate’ from the concerned authority before any
work proceeds; (c) for road rehabilitation in forested areas, no trees can be
removed without the permission of the owners; and (d) no new roads are to
be constructed. The existing route densities in most rural areas are found to
172 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

Fig. 5. The IFFD environmental work cycle.

be sufficient, but many roads need rehabilitation such as earth filling,

structure construction and maintenance. The IFFD environmental work cycle
is shown in Fig. 5.
The salient features of the policy are that road improvements cannot go
ahead without considering their negative and positive environmental conse-
quences, and the policy also considers no development option — an important
but neglected area in EIA — by deciding not to construct any new roads.
Local communities are widely consulted using a range of methods, i.e.,
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 173

questionnaire survey, public meetings, leaflets, etc. for information gathering

and feedback.

3.4. WB and its environmental strategy

WB has been a development partner of Bangladesh for a long time. It has

developed its own EIA procedures for projects funded by it. Since 1989, bank
staff are required to screen all proposed new investment projects with respect to
their potential environmental impacts and to classify them accordingly. For this
purpose, projects are classified in three categories:

1. Category A: Projects that are likely to have significant long-term

impacts. A full assessment is required.
2. Category B: Projects that are likely to create site-specific impacts and
would not affect human population and environmentally sensitive areas.
A partial environmental assessment is required.
3. Category C: A project that is unlikely to have impacts on society
and environment. EA is not required for such projects (The World
Bank, 1997).

WB has effectively incorporated EIA into project cycle (see Fig. 6). EIAs
are conducted by the organizations that are implementing projects. However,
WB has an environmental section that examines EIAs for approval. WB
stringently follows its regional environmental strategies and guidelines in
funding projects (The World Bank, 2000). For this reason, this organization
is often perceived as being an organization, which is putting unnecessary
hurdle in the smooth implementation of development projects in Bangladesh.
WB conducted its first EA review in 1993, which covered the period
from October 1989 until June, 1992 (The World Bank, 1993). In 1997 WB
conducted the 2nd review of its environmental assessment experience in WB
funded projects worldwide (The World Bank, 1997). It revealed that (a) the
EA process was operative and produced results, (b) performance could still
improve in a number of areas, such as, more attention in scoping, site
alternatives were not adequate, mitigation and monitoring and management
plans were insufficiently developed by the borrowers and (c) early experi-
ence gave rise to new issues in regard to resource needs for EA, training
needs within the Bank and consideration of sectoral and regional EAs.

3.5. Asian Development Bank (ADB)

ADB has been a major development partner in Bangladesh since her

independence in 1971. In 1999, it provided four loans amounting to US$332
million and approved 15 technical assistance grants totaling US$10.9 million
(ADB, 2001). It had a major involvement in the construction of the Jamuna
174 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

Fig. 6. WB’s environmental assessment and the project cycle.

Bridge — the largest infrastructure project in the history of Bangladesh. ADB

has recently developed a new environment operational strategy (EOS) for
Bangladesh in order to address the major environmental problems.
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 175

Like WB projects, ADB projects are also classified into Category A (significant
impacts), Category B (some impacts) and Category C (no impacts). In addition to
IEE and EIA, an initial social impact assessment is required for every development
project in order to identify their consequences on people (ADB, 2001).

4. Discussion and recommendations

4.1. Major issues in the application of EIA in Bangladesh

(1) Scoping is an important phase in conducting EIA. It is the stage when

geographic region and issues to be considered in an EIA are determined. At the
initial stage of EIA application in Bangladesh, the scoping stage was not clear to
the individuals and groups involved in the conduct of EIA. The understanding
was that all components/sectors examined in major projects should also be taken
into consideration in smaller projects. However, later, it was clarified that only
components relevant to the project should be considered in the scoping phase.
For example, if public health is not an issue for a road construction project, then
no time should be spent on examining that issue. Scoping is now well placed in
all IEE and EIA.
(2) It is difficult or impossible to quantify many impacts in many cases,
especially in the assessment of social impacts, although without quantification,
the extent of magnitude cannot be properly explained or made credible. As a
result, the practitioners used scales, such as high impact (scores 8, 9 or 10),
medium impact (4, 5 or 7), low impact (1, 2 or 3) and 0 for no impact (FAP,
1992). In addition, multicriteria analysis and matrix methods in the evaluation of
impacts were used (EGIS II, 1998). USAID also devised a method of scoring
impacts. The impacts are measured on a seven-point scale ranging from  1,  2
and  3 representing low, moderate or high negative impacts, respectively,
0 representing no impact to + 1, + 2 and + 3 representing low, moderate and
high positive impacts, respectively (Khan and Fitzcharles, 1998). Although these
methods of quantification can be used subjectively, the officials are instructed to
take special care to estimate the degree of impacts in comparison with the present
situation. Magnitudes of the impact are generally determined by multidiscipli-
nary teams using these scales, which are clarified in the reports. Use of these
techniques increased the credibility of results derived from EIA.
(3) There have been debates in developed countries as to the responsibility of
EIA (Thomas, 1998). It has been observed that benefits of EIA conducted by
proponents outweigh the arguments in favour of independent bodies conducting
EIA. This is due to the fact that proponents are in the best position to conduct EIA
in the most effective manner. They have all the relevant information regarding the
project, which places them in an advantageous position to identify and assess
potential impacts with better confidence. In Bangladesh, however, there is a
strong opinion in favour of independent bodies to conduct EIA. The general
176 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

perception is that EIAs are conducted only because they are required by the
government legislation and donor agencies, not to ensure sustainability of projects
or to develop better management plans. In many cases, EIA is seen by proponents
as an impediment to the implementation of development projects. It is regarded as
a tool to justify projects rather than using it as a means to derive best decision.
(4) DOE is the authority that observes the implementation of ECA ’95 and
ECR ’97. It is the approval authority for development projects. However, there
is a lack of skilled EIA and SIA professionals within this department to make
meaningful judgement on EIAs conducted to acquire ECC. Lack of implemen-
tative capacity — ability to conduct proper EIA and ability to implement
mitigation measures — has been identified by WB as the biggest constraint to
effective EAs (Goodland and Mercier, 1999).
(5) There is a lack of coordination among the agencies involved in EIA. There is
no standard EIA procedure to be observed by all practitioners. The presence of
donor agencies as organizations parallel to the DOE in project approval may lead to
the creation of dual standard in EIA quality. In addition, there is no mechanism in
place to ensure monitoring of project impacts to identify and rectify impacts that
were not picked up by the EIA.
(6) Developers or proponents hire consultants to conduct EIA of develop-
ment projects that they are proposing. Their intention is to get an EIA done
that would highlight the benefits and justify the proposal in order to obtain
environmental clearance from the DOE or from the donor agencies for the
purpose of fund clearance. It is therefore the job of the consultants to satisfy
the proponent’s requirements rather than carrying out objective EIAs to ensure
environmental and social soundness of projects. In addition, there are no codes
of conduct by which the activities of the consultants are governed.
(7) Recent development in the EIA arena is the emphasis on strategic
environmental assessment (SEA) or policy level assessment (Petts, 1999). That
means that rather than conducting project level impact assessment, it is more
advantageous to conduct EIA at the policy development level. This will provide the
decision makers with more time to consider environmental consequences at an
early stage. SEA would also allow the consideration of cumulative impacts of
various projects (Canter, 1999). There is a need for SEA in a country like
Bangladesh where major development programs are being implemented by a
number of local and international agencies.

4.2. Recommendations

(1) ECA ’95 and ECR ’97 are milestones for the country in its efforts to
create sustainable society where there would be a balance between develop-
ment and environmental protection. However, enforcement of legislation is not
an easy task in a country where corruption is all pervasive. It is important that
NGOs and donor agencies play a major role in monitoring the conduct of EIA
in collaboration with DOE.
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 177

(2) A number of agencies are involved in environmental assessment. They

have developed their own guidelines. In most cases, these are good guidelines.
Despite the rigorous application of guidelines, it is apparent that there is no
coordination among these agencies; and there are no standardized guidelines. A
set of guidelines should be developed for all sectors that would help avoid
duplication and establish links between organizations. It is important to note
that in order for EIAs to be effective, guidelines should pay due attention to
the local social, economic and political setting. Monitoring is a major ongoing
phase in EIA process, and it is important that emphasis is placed on
monitoring postproject impacts.
(3) Independent bodies should review the EIAs prepared by independent
consultants. This will ensure the quality of EIAs. It may be noted here that despite
the stringent regulations, some Western countries (for example, Australian state of
Western Australia) have established bodies — independent of the government and
the proponents — to review EIAs for approval purposes (Conacher and Conacher,
2000). DOE should develop codes of conduct for the consultants.
(4) Although community participation is enshrined in legislation and in the
guidelines of EIA, often, it is neglected and starts at a later stage of project
development, rather than early, only to meet legislative requirements (Petts,
1999). Community participation and consultation should be incorporated at
every stage of project development. Consultation with local people and their
representation in project development process will ensure better decision
making. Through community consultation and incorporation of local knowledge
in project development, it is possible to gain trust of the local communities.
This will facilitate smooth implementation of projects. In the EIAs conducted
by CARE and EGIS, community participation has been ensured through RRA
and participatory rural appraisal (PRA) in the entire project cycle. DOE has also
placed adequate emphasis on public participation (DOE, 1997). One of its EIA
review criteria is to see if the concerns expressed by community are genuine
and if the project EIA has addressed these concerns adequately. However,
ensuring effective community participation in the EIAs conducted by consulting
firms for private developers will remain a contentious issue.
(5) It is time that DOE considers developing SEA and regional impact
assessment (RIA) guidelines. SEA and RIA would enable the identification of
regional level impacts of policies and the adoption of a holistic approach to
environmental planning. The Bangladesh government is embarking on a number of
multifaceted projects, such as housing for low income earners, sending the villagers
back to their villages who migrated to big cities. These programs will embrace
many aspects of rural life and have a potential to affect biophysical system at
regional level. It is therefore imperative that the government becomes fully aware
of the environmental and sustainability issues associated with a particular policy,
program or plan (PPP) (Therivel and Brown, 1999) in order to avoid, minimize or
mitigate the likely consequences. A parallel initiative should be taken in the area of
skills development in EIA. This should be done in collaboration with the donor
178 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179

agencies (e.g., CARE, WB) that are already running EIA training programs and
workshops as part of their capacity strengthening initiative.
(6) Questions may be raised whether costly EIA exercises like the one
reviewed earlier in this paper is viable and pragmatic in a poor country like
Bangladesh. There is a need to develop simplified EIA procedures that would be
consistent with the availability of resources within the country. Dependence on
donor agencies to meet the cost of EIA undermines the whole idea of using EIA
as a tool for sustainable development.
Some authors (for example, Wood, 1995; Briffett, 1999) have identified that the
biggest constraint to effective EIA in developing countries is the lack of political
will. This statement does not hold good for Bangladesh, as the politicians have
already spoken in favour of EIA by passing EIA legislation. Institutional capacity
and inadequate resources are probably the major constraints that prevent proper
implementation of EIA. Moreover, having relevant legislation is not enough
unless the political willingness is bolstered by a thorough understanding of the
relationship between EIA and environmental sustainability assurance.

5. Conclusion

Bangladesh is on the right path in its effort to develop environmental

guidelines and adopt EIA in decision-making process. DOE has the potential
to play a significant role in guiding the nation towards environmental sustain-
ability. However, to be more effective, this organization requires more resources
to hire skilled manpower to enforce the implementation of ECA ’95 and ECR ’97.
International donor agencies and NGOs are making significant contributions to
the application of EIA at project level. A coordinated effort between all agencies
involved would enable the country to pursue the path of sustainable development
through the development and application of strategic assessment.

Acknowledgments

I thank the Rotary Foundation of Rotary International, Newcastle District,

Australia, which funded this study under the Rotary Grant for University Teachers.
I am grateful to the two unknown reviewers for their constructive comments
on an earlier draft of this article.

References

Asian Development Bank (ADB). 2001; www.adb.org.

Bangladesh Centre for Advanced Studies (BCAS). Guide to the Environmental Conservation Act
1995 and Rules 1997. Dhaka: BCAS, 1999.
 S. Momtaz / Environmental Impact Assessment Review 22 (2002) 163–179 179

Briffett C. Environmental impact assessment in East Asia. In: Petts J, editor. Handbook of environ-
mental impact assessment: vol. 2. Environmental impact assessment in practice: impact and
limitations. Oxford: Blackwell, 1999. pp. 143 – 67.
Canter L. Cumulative effects assessment. In: Petts J, editor. Handbook of environmental impact
assessment: vol. 1. Environmental impact assessment: process, methods and potential. Oxford:
Blackwell, 1999. pp. 405 – 40.
Conacher A, Conacher J. Environmental planning and management in Australia. Oxford: Oxford
Univ. Press, 2000.
Department of Environment (DOE). EIA guidelines for industries. Dhaka: DOE, 1997.
Environmental and GIS Support Project for Water Sector Planning (EGIS II). Environmental and
social impact assessment of Khulna – Jessore Drainage Rehabilitation Project. Dhaka: EGIS, 1998.
Flood Action Plan (FAP). Guidelines for environmental impact assessment. Dhaka: FAP, 1992.
Gilpin A. Environmental impact assessment (EIS): cutting edge for the twenty-first century. Cam-
bridge: Cambridge Univ. Press, 1995.
Goodland R, Mercier JR. The evolution of environmental assessment in the World Bank: from
‘‘approval’’ to results. Washington, DC: The World Bank, 1999.
Harvey N. Environmental impact assessment: procedures, practice, and prospects in Australia.
Oxford: Oxford Univ. Press, 1998.
Khan MH, Fitzcharles K. Environmental management field handbook for rural road improvement
projects. Dhaka: CARE International Bangladesh, 1998.
Modak P, Biswas AK. Conducting environmental impact assessment for developing countries.
Tokyo: United Nations Press, 1999.
Momtaz S, Taylor B, Lockie S. Independent social impact assessment: proposed castle hope dam —
Calliope River and Awoonga Dam upgrade, Queensland. Rockhampton: Central Queensland
University, 1998.
Nakashima S, Khan MH. A basic guide to understanding the environmental impacts of rural
roads on the wetlands of Bangladesh. Dhaka: United States Agency for International Develop-
ment, 1994.
Petts J. Environmental impact assessment — overview of purpose and process. In: Petts J, editor.
Handbook of environmental impact assessment: vol. 1. Environmental impact assessment:
process, methods and potential. Oxford: Blackwell, 1999. pp. 3 – 11.
Sadler B. A framework for environmental, sustainability assessment and assurance. In: Petts J,
editor. Handbook of environmental impact assessment: vol. 1. Environmental impact assessment:
process, methods and potential. Oxford: Blackwell, 1999. pp. 12 – 32.
Therivel R, Brown AL. Methods of strategic environmental assessment. In: Petts J, editor. Hand-
book of environmental impact assessment: vol. 1. Environmental impact assessment: process,
methods and potential. Oxford: Blackwell, 1999. pp. 441 – 64.
The World Bank. Annual review of environmental assessment 1992. Washington, DC: The World
Bank, 1993.
The World Bank. The Impact of Environmental Assessment, A Review of World Bank Experience
World Technical Paper No. 363. Washington, DC: The World Bank, 1997.
The World Bank. South Asia environment strategy — main report: work in progress. Dhaka: The
World Bank, 2000.
Thomas I. Environmental impact assessment in Australia. Sydney: Federation Press, 1998.
Vanclay F, Bronstein DA, editors. Environmental and social impact assessment. New York:
Wiley, 1995.
Wood C. Environmental impact assessment. Harlow, UK: Longman, 1995.