Journal of Environmental Assessment Policy and Management

Vol. 15, No. 4 (December 2013) 1350018 (30 pages)

© Imperial College Press
DOI: 10.1142/S146433321350018X

FIFTEEN YEARS OF ENVIRONMENTAL IMPACT

ASSESSMENT SYSTEM IN BANGLADESH: CURRENT
PRACTICE, CHALLENGES AND FUTURE DIRECTIONS

S. M. ZOBAIDUL KABIR*
Center for Environmental Management
CQUniversity, North Rockhampton
QLD-4702, Australia
*z.kabir@cqu.edu.au

SALIM MOMTAZ
School of Environmental and Life Sciences
University of Newcastle, Ourimbah
NSW 2259, Australia

Received 7 February 2013

Revised 9 July 2013
Accepted 9 July 2013
Published 26 November 2013

The aim of this article is to review the current practice of EIA system in Bangladesh. In
Bangladesh, EIA has been practiced for more than fifteen years. However, there is a lack of
scientific information about the current practice of EIA in Bangladesh. This article focused
and reviewed three key areas of EIA system in Bangladesh: institutional arrangement,
quality of EISs and implementation of mitigation measures. By using a set of good practice
criteria, this article finds that still there are shortcomings in current EIA practice despite
that fact that EIA practice in Bangladesh has been improving over the last fifteen years.
This means Bangladesh could not harness the full benefit of EIA yet. This article suggest
that in order to harness the full benefits of EIA, adequate implementation of mitigation
measures is imperative while improving the capacity of proponents, regulatory agency and
the quality of EIS.

Keywords: Environmental impact assessment; Bangladesh; performance; practice.

*Corresponding author.

1350018-1
S. M. Z. Kabir & S. Momtaz

Introduction
Environmental impact assessment (EIA) is a management tool used to identify
impacts of development projects and design subsequent mitigation measures to
address potential impacts. Literature recognises that the potential of EIA in
addressing project impacts is increasingly understood through practice. EIA is now
an integral part of the development process in both developed and developing
countries (Abaza et al., 2004; Briffett, 1999; Morgan, 2012; Thomas, 2005). EIA
is seen to fulfil a valuable role in making a project environmentally feasible and
socially acceptable (Phylip-Jones and Fischer, 2013; Arts et al., 2012; Cashmore
et al., 2004; Glasson et al., 2005; Harvey and Clarke, 2012; Sadler, 1996; Thomas,
2005). In developed countries, with a longer history of adoption, EIA systems
have been reviewed, modified and expanded in the light of past experiences to
harness the benefits of EIA (Petts, 1999). In these countries, EIA systems are now
relatively matured and advanced with comprehensive legal requirements and scope
of EIA’s application and practice. In developed countries, application of EIA at
policy and planning levels is also advancing (Fischer, 2010; Fischer and Onyango,
2012). Health and social impact assessments (HIA/SIA), also with other types of
IA are getting more and more attention. On the other hand, the circumstances of
the EIA systems in developing countries are different.
In developing countries, EIAs are in general, still weak. In most cases, EIA
systems have been adopted by developing countries later than the developed
world. EIA in developing countries is characterised by weak legal and adminis-
trative arrangement, including lack of influence of environmental agencies in
implementing EIA; poor quality of environmental impact statements (EISs);
limited involvement of affected community and other stakeholders; and inadequate
implementation of mitigation and monitoring measures (Ahmad and Wood, 2002;
Briffett, 1999; Clausen et al. 2012; Jha-Thakur, 2011; Kolhoff et al., 2013; Lee
and George, 2000; Nadeem and Fischer, 2012; Paliwal and Srivastava, 2012;
Wood, 2003). Due to these institutional and technical weaknesses, the benefits of
EIA are yet to be fully realized.
Bangladesh is a developing country in economic transition with an average of
more than 6% economic growth rate p.a. the last decade. Since the implementation
of an open market economy in the early 1990s there has been an increase in
foreign direct investment, particularly in industrial and infrastructure sectors. All
these development activities entail significant environmental and social impacts.
The government of Bangladesh formally introduced environmental impact as-
sessment (EIA) in 1995 under the Environmental Conservation Act in response to
the growing environmental concerns and the demand from donor agencies for

1350018-2
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

better environmental performance. Recently, investment has been growing in

major economic sectors, for example, oil, gas and coal mining. An effective and
up-to-date EIA regime is thus essential to efficiently manage the potential envi-
ronmental and social impacts of all resource development activities.
While EIA has been practiced for more than 15 years, there is little evidence
about the quality of EIA system in Bangladesh. In the absence of adequate and up-
to-date scientific information, the performance of EIA is largely unknown. A few
attempts have been made in order to understand the status of EIA in Bangladesh,
including Ahammed and Harvey (2004) and Momtaz (2002, 2003). However,
more comprehensive and up-to-date information is required in order to understand
the current status of EIA system. To understand the performance of EIA in
Bangladesh, we need to evaluate the EIA process, including institutional
arrangements, implementation of methodological requirements (e.g. the quality of
EISs), and implementation of mitigation measures (Momtaz, 2005).

Methodology
Conceptual approach
In order to evaluate the EIA system in Bangladesh, this research developed an
integrated-holistic framework, including examination of institutional arrange-
ments, quality of EISs and the implementation of mitigation measures. It is widely
recognized that adequate institutional arrangements, good quality EISs and ade-
quate implementation of mitigation measures are core areas of an effective EIA
system (Abaza et al., 2004; Cashmore et al., 2004; Fuller, 1999; Jha-Thakur et al.,
2009; Jha-Thakur, 2011; Lohani et al., 1997; Lee et al., 1999; Lee, 2000; Marshal,
2001; Noble and Storey, 2005; Paliwal and Srivastava, 2012; Sadler, 1996; Wilson,
1998; Wende, 2002; Wood, 1995).
Both, procedural outputs (quality of EISs) and substantive outcomes (mitigation
measures), in addition to institutional arrangements required to operate and im-
plement the EIA in practice are thus to be evaluated. The institutional arrange-
ments indicate the operational capacity of the lead environmental agency along
with legislative control. The quality of an EIS indicates to what extent the stages
and activities of the EIA process (e.g. collection of baseline data, identification and
assessment of impacts, analysis of alternative, and community participation) are
performed well by the proponents. The post-EIS stage of an EIA reflects the
substantive outcomes in terms of the implementation of mitigation measures with a
view to addressing the potential environmental impacts.

1350018-3
S. M. Z. Kabir & S. Momtaz

Evaluation criteria
Based on the conceptual framework, a set of criteria was developed to review the
EIA system in Bangladesh. Box 1 shows a brief version of review criteria.
Evaluation criteria are essentially a checklist of the requirements of an effective
EIA system. These criteria are generally said to be normative provisions with
which an EIA system should accord (Emmelin, 1998a; Fuller, 1999). These good
practice review criteria, as applied by a number of authors (such as Glasson and
Salvador, 2000; Sadler, 1996; Wood, 1995), are well established and appear to be
applicable to most jurisdictions. In general, criteria focus on the requirements and
operation of the EIA system in a jurisdiction.

Box 1. Summary of the Criteria used to Evaluate the EIA System in

Bangladesh
Institutional Arrangements
1. Clear legal basis of EIA system.
2. Provisions of EIA requirements adequately prescribed by the legislation.
3. Adequate technical and general EIA guidelines.
4. Separate environmental agencies with adequate authority.
5. Adequate resources and capacities of environmental agencies for imple-
menting EIA in practice.
6. Adequate interagency coordination between the environmental agency and
other proponents.
7. Other control mechanisms, such as an environmental court, code of conduct
for EIA consultants.

Quality of Information Presented in EISs

8. All relevant stages of EIA process are adequately addressed in practice.
9. A competent authority is available to review and approve EISs.
10. The EISs are able to be understood by all stakeholders.
11. There are resources available to prepare good quality EISs (funds available,
expert EIA consultants and adequate time for EIA study).
12. There is a code of conduct and accreditation system for EIA consultants to
control the quality of EISs.
13. The review of EISs is participatory and independent of an environmental
agency.

(Continued)

1350018-4
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

Box 1. (Continued)
Implementation of Mitigation Measures
14. Recommended mitigation measures adequately implemented to address the
predicted impacts of the projects.
15. An adequate role is played by the environmental agency in successfully
implementing the mitigation measures.
16. Adequate monitoring activity during the implementation of mitigation
measures.
17. Active community participation during the implementation of mitigation
measures.
18. Role of other stakeholders (for example, donor agencies, Planning Com-
mission) available to support the implementation of mitigation measures.

Broader Contextual Factors

19. Political will favourable to environmental issues.
20. Bureaucratic and developmental culture.

Sources: Fuller, 1999; Sadler, 1996; and Wood, 1995.

Data collection
This study was undertaken to address research questions principally with respect
to three key areas of an EIA system: (1) institution and EIA practice, (2) the
quality of EISs, and (3) the implementation of mitigation measures at the post-EIS
stage of the EIA process. For each of the three key areas, suitable methods were
used to collect data (Fig. 1). For institutional arrangements of EIA, relevant
documents were reviewed and analyzed. For understanding the quality of EIA
reports, 40 EISs were systematically reviewed by using a set of review criteria.
The use of site visits and direct observation was aimed at understanding the
implementation of mitigation measures in three projects (case studies). Finally,
interviews were undertaken by using an interview schedule to substantiate the
review findings of these three key areas.

Document analysis
For institutional arrangement of EIA, a number of public documents relating to
environmental policy, legislation, planning and strategies were reviewed and ana-
lysed. The reviewed documents include Environmental Conservation Act 1995,

1350018-5
S. M. Z. Kabir & S. Momtaz

Key research areas and

methods applied

Ins
tu
onal Quality of EISs Post-EIS

Methods: Methods: Methods:
a. Document a. Review criteria a. Site visit
analysis b. Interview b. Interview
b. Interview

Fig. 1. Methods used to collect data in this study.

Environmental Conservation Rules of 1997, EIA guidelines, and Environmental

Policy 1992 in addition to concerned journal articles and reports. These documents
were analyzed to understand the adequacy and the clarity of EIA requirements.

Review of EISs and determination of the performance

of key stages of EIA process
For understanding the performance of key stages of EIA process, 40 EIA reports
from various sectoral projects were collected and reviewed. The EIA reports were
selected randomly from the 330 EISs produced between 1995 and 2010. 40 EISs
were chosen that represent the total population of EISs. The sectors represented by
the EISs include; industry, water, energy, roads and infrastructure, and urban
development.
A set of review criteria from the review package by Lee and Colley (1992) was
used to assess the adequacy of information in the EISs (Appendix B). This
package has been widely used in many jurisdictions including developed and
developing countries (Sandham and Pretorius, 2008; Badr et al., 2011). In the case
of Bangladesh, some criteria were added given the legislative requirements of EIA
process (* marked). The quality of information presented in an EIS was graded as
A ¼ excellent, B ¼ good, C ¼ just satisfactory, D ¼ poor, and E ¼ very poor.

Site visit and direct observation

In this study, three projects from three different development sectors were selected
and visited by the authors to determine the status of the implementation of major

1350018-6
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

mitigation measures proposed by the EIA reports. The projects are Jamuna Multi-
purpose Bridge Project (JMBP), Meghnaghat Power plant Project (MPPP), and
Khulna-Jessore Drainage Rehabilitation Project (KJDRP). The three projects
represent different sectors (roads, energy, and water respectively) had already been
implemented and were, therefore, ideal for investigation. These projects are large
in size, funded by donor agencies and quality of EISs appeared to be good. The
researchers observed the activities oriented to the implementation of mitigation
measures and the management of environmental impacts, for all three projects.

Face-to-face interview
Face-to-face interviews were undertaken to collect data on the EIA system in
Bangladesh. The interview schedule was designed around the three key thematic
issues: institutional arrangements of EIA system, the performance of key stages of
the EIA process, and performance of the implementation of mitigation measures
at the post-EIS stage. Also, factors influencing the EIA system were identified
from the interview.
The interviewees included EIA consultants, experts and researchers from
consulting firms, government agencies, particularly from ministries and the
Department of Environment (DOE), non-governmental organisations (NGOs),
international organisations (World Bank and Asian Development Bank), research
institutions, and university academics. A total of 30 participants responded that
they were prepared to attend a one-hour interview. Finally, a total of 25 partici-
pants were available for interview and all of them were interviewed.

Findings and Discussions

Table 1 summarizes the current status of EIA system in Bangladesh around the
three key EIA areas. This indicates that there are both, strengths and weaknesses of
the EIA system in Bangladesh. Each of the key elements has some limitations.

Institutional arrangements of EIA system in Bangladesh

Table 2 represents strengths and weaknesses of the institutional arrangements of
the EIA system in Bangladesh. The findings indicate that considerable efforts have
been made throughout the last fifteen years to establish a viable institutional set-up
for EIA practice. In response to the growing environmental problems, new laws
and subsequent supporting legal documents were developed. Furthermore, old
legislation (Environmental Protection Ordinance of 1977) was repealed and new
legislation (Environmental Conservation Act of 1995 and Environmental

1350018-7
S. M. Z. Kabir & S. Momtaz
Table 1. Status of the current EIA system in Bangladesh.
Key criteria
Institutional arrangements
Clear legal basis of EIA system
Provisions of EIA requirements ad-
equately prescribed by the legis-
lation
Adequate technical and general EIA
guidelines
Separate environmental agencies
with adequate authority
Adequate resources and capacities of
environmental agencies for
implementing EIA in practice
Adequate interagency coordination
between the environmental
agency and other proponents
Other control mechanisms, such as
an environmental court, code of
conduct for EIA consultants
Quality of EISs
All relevant stages of EIA process
are adequately addressed in
practice
A competent authority is available to
review and approve EISs
The EISs are able to be understood
by all stakeholders
Scale Comments
þþþþþ The Environmental Conservation Act of
1995 and Environmental Conservation
Rules of 1997 provide clear legal basis
for EIA in Bangladesh.
þ þ þþ Some requirements are not clearly outlined
and some requirements are ambiguous.
þþþ Only four general guidelines are available,
these guidelines are not updated regu-
larly and there are lack of technical
guidelines.
þþþþþ Department of Environment is authorized
to approve EIA related applications and
enforce the EIA rules.
þþþ DOE is not adequately resourced in terms
of manpower and money given the in-
creasing number of EIA applications
and their approval process.
þþ Weak coordination between the DOE and
other government agencies in the ab-
sence of National environmental Council
and regular meetings.
þþ Environmental courts are in place but their
services are limited. There is no code of
conduct for EIA consultants, hence less
obligation.
þ þ þþ Not all stages of EIA process are
adequately addressed in practice. Spe-
cially prediction of impacts, baseline
information and analysis of alternative
are often found poorly mentioned in
EIA report.
þþþþþ DOE is available to review and approve
EISs.
þþþ The EISs are not untestable to all most all
community members since the report is
written only in English rather than na-
tional language (Bengali).
1350018-8
 Fifteen Years of Environmental Impact Assessment System in Bangladesh
Key criteria
There are resources available to
prepare good quality EISs (funds
available, expert EIA consultants
and adequate time for EIA
study).
There is a code of conduct and ac-
creditation system for EIA con-
sultants to control the quality of
EISs
The review of EISs is participatory
and independent of an environ-
mental agency
Implementation of mitigation measures
Recommended mitigation measures
adequately implemented to ad-
dress the predicted impacts of the
projects
An adequate role is played by the
environmental agency in suc-
cessfully implementing the miti-
gation measures
Adequate monitoring activity during þ þ
the implementation of mitigation
measures
Active community participation
during the implementation of
mitigation measures
Role of other stakeholders (for ex-
ample, donor agencies, Planning
Commission) available to sup-
port the implementation of miti-
gation measures
Table 1. (Continued )
Scale Comments
þþ Funds are not available particularly under-
taken by local private proponents
(industrialist), time for EIA study is
inadequate and lack of regular EIA
experts.
þ Lack of code of conduct and accreditations
system for EIA consultants.
þ There is no independent review body, re-
view is controlled by the DOE, how-
ever, the process is not systematic,
ad hoc review body formed case by case
basis but not regularly.
þþ Recommended mitigation measures for
predicted impacts are not addressed
adequately for all projects.
þþþ DOE does not have much capability to
oversee the implementation of mitiga-
tion measures, problems with philoso-
phy with regulatory versus management.
Monitoring activities is in place by both
parties (proponent and DOE) but
coverage of monitoring indicators is
limited, absence of community partici-
pation in monitoring.
þþ Community participation is limited partly
due the reluctance of proponent to in-
clude community, lack of encourage-
ment by the DOE and lack of awareness
of community members about environ-
mental pollution.
þþþ Donors support limited to develop the EISs,
no role played by the donor agencies or
Planning Commission during the im-
plementation of mitigation measures or
post-EIS stage of EIA.
1350018-9
S. M. Z. Kabir & S. Momtaz

Table 1. (Continued )

Key criteria Scale Comments

Context
Political will favorable to environ- þþ Pressure from community has been
mental issues increasing but inconsistently. Still eco-
nomic growth is prioritized over envi-
ronmental pollution by the government.
Bureaucratic and developmental þþ Bureaucrats are not well aware of envi-
culture ronmental consequences of develop-
ment projects, lack of training and
attitude among the government
agencies.
Notes: Fully met: þ þ þ þ þ; Partially (but above average) met: þ þ þ þ; Averagely (fairly)
meet: þ þ þ; Partially (but below the average) met: þ þ; Not met at all: þ.

Table 2. Key strengths and weaknesses of institutional arrangements of EIA in Bangladesh.

Strengths Weaknesses

Legislative foundations
. Clear legal basis for EIA system
including constitutional support
. Broad definition of environment
. Clear list of projects for screening
. Clear timeline for approval of EISs
and issuance of ECCs
. Provisions for penalties for the
violation of EIA approval conditions
(environmental management focus)
Administrative arrangements
. A separate environmental agency
(Department of Environment)
. Clear and adequate authority of DOE
to implement EIA
. Incorporation of EIA requirements in
national development planning and
sectoral policy making process
. Simultaneous occurrence of EIA
along with project Feasibility Study
Source: Developed by the authors.
. Lack of comprehensive legislations with
explicit requirements of key stages of EIA
. Lack of clarity in the current legislation
. No provision for expansion of new projects
and renovation of old projects
. No provision for affected community to
directly go to court
. Inadequate environmental guidelines and
current guidelines are not up-to-date
. Inadequate manpower in DOE
. Inadequate budget for the enforcement of
EIA regulations
. Stable leadership problem
. Lack of incentives for DOE staff and lack of
motivation among staff
. Inadequate interagency cooperation at na-
tional and local level

1350018-10
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

Conservation Rules of 1997) was enacted with a greater scope for environmental
management. This new legislation provides a clear legal mandate for the EIA
system in Bangladesh.
As part of the increased emphasis on environmental protection, there has also
been an initiative to reorganise the administrative arrangements for the application
of EIAs. The pollution control cell created under the Environmental Protection
Ordinance in 1977 has now grown into the Department of Environment (DOE).
Now there is a separate Ministry of Environment and Forest (MOEF) responsible
for making environmental policies and legislations. Within the MOEF, the DOE
carries out its responsibilities to implement EIAs. The DOE has the sole respon-
sibility of approval of EIA reports and enforce the EIA related rules and regula-
tions. In addition, the establishment of an environmental court in 2000 is another
step to make the EIA system effective.
There are weaknesses in the institutional arrangements too. Key shortcomings
include the lack of clear and comprehensive EIA legislations, inadequate resources
and capacity of DOE, and weak interagency coordination among the DOE and
other agencies. For example, the current EIA legislation does not explicitly pre-
scribe all generic stages of the EIA process such as assessment and evaluation of
impacts, development of mitigation measures and follow-up at post-EIS stage.
Where the current legislations in India, for example, specifies the requirements of
follow-up (Jha-Thakur, 2011; and Paliwal and Srivastava, 2012, the current EIA
legislation in Bangladesh did not mention this provision yet. Only the screening
stage is clearly stipulated (DOE, 1997b). According to one of the interviewees,
…the key stages involved in the EIA process should be clearly laid down
by the EIA legislation. This would ensure uniformity and consistency of
EIA application. Proponents may tend to avoid following all key stages of
EIA if they are not explicitly prescribed by the legislation. They (propo-
nents) may think that it is not mandatory to follow……. The current
Environmental Conservation Rules (ECR) is very general about the key
stages of EIA process. A detailed regulation for methodological and
procedural requirements of EIA process is desirable if we want a con-
sistent and widely applicable EIA practice in Bangladesh (Interview #22).
Furthermore, some provisions of the EIA requirements prescribed by the cur-
rent legislation are ambiguous in wording, therefore, difficult to implement. One of
these shortcomings is the provision of the validity of an Environmental Clearance
Certificate issued by the DOE. According to the ECR of 1997, DOE issues an ECC
for any type of projects only for one year (DOE, 1997b). This means the propo-
nents are required to apply to the DOE every year to renew the certificate during

1350018-11
S. M. Z. Kabir & S. Momtaz

the construction and operation of projects. This provision of renewing ECC for
one year may be applicable to industrial projects as it is important to check the
environmental performance of the industrial project regarding waste treatment or
emission discharge each year. The current provision of renewing the ECC every
year, however, is not suitable for certain projects, including e.g. bridges, roads or
dams (Interview #7). Interviewees expressed their concern that this provision often
raises tension between the DOE and the proponents, such as, the Water Resource
Ministry or the Ministry of Communication. In India, the validity of the ECC for a
project is for a minimum of five years and maximum of thirty years according to
the category of the projects (MOEF in India, 2000).
Another problem lies within the provision of site clearance (schedule 7 of
Environmental Conservation Regulation of 1997). The DOE approve site clear-
ance for the project proponent before issuing the Environmental Clearance Cer-
tificate (ECC). Once the proponents obtain an ECC, they are allowed to undertake
development work, such as land development on the project site. Therefore, the
importance of the receipt of an ECC is largely undermined. This is a great loophole
in the existing EIA rules. In fact, the site clearance allows the proponents to invest
their resources at the project site before the approval of EIS and the issuance of
Environmental Clearance Certificate. Since the proponent already has invested
their resources, it often becomes morally and technically difficult for the DOE to
reject the EIS despite its poor quality. Rather, the provision of site clearance opens
the avenue to force the DOE to approve the EIA report as soon as possible
(Interview #12).
In addition to legislative weaknesses, there are administrative shortcomings that
affect the EIA process too. One of the administrative weaknesses of the DOE is
inadequate resources (staff and funding). With the increase in its responsibilities
over time, the DOE has continued to be understaffed. The volume of tasks of the
DOE has increased manifold over the last 18 years, but its manpower has not
increased to accommodate this. Recently, in 2011, the government increased the
total number of staff from 244 to 627. However, this level of environmental agency
staffing is still lower compared with many other developing countries, such as
Thailand, Vietnam, Sri Lanka, and Pakistan (Personal communication with DOE,
2012). Importantly, the EIA unit of the DOE responsible for approval of EIA
reports and the issuance of ECC is highly understaffed (Personal communication,
2012).
Furthermore, while the DOE is legally empowered by the legislation to enforce
EIA, it lacks an adequate budget. Also, the lack of stable leadership and the
absence of a decentralised administration are major weaknesses. As a relatively
new organisation the DOE’s position in the government bureaucratic hierarchy is

1350018-12
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

not well established as yet. Hence the DOE has limited influence over politically
influential proponents. The weaknesses of institutional arrangements (legal and
administrative) identified in this study are, however, not unique to Bangladesh.
Previous studies in developing countries (ADB, 2007; Ahmad and Wood, 2002;
Briffett, 1999; Glasson and Salvador, 2000; Lee and George, 2000; Paliwal and
Srivastava, 2012; Sadler, 1996; Wang et al., 2003) had similar findings.
The lack of clarity and comprehensiveness in the EIA legislation (ECR) can be
attributed to the fact that the EIA is relatively new in Bangladesh. In addition, after
the introduction of EIA laws in 1995, there were no comprehensive reviews by the
government or academics and there were no major amendments or modifications
made to the laws. It is, therefore, not surprising that some deficiencies in terms of
comprehensiveness and clarity of provisions exist in current EIA legislations. In
other developing countries, including China, Brazil, Taiwan, Sri Lanka, Sudan and
India the EIA legislation also had various deficiencies when first introduced. The
legislations in these countries were amended after a decade of their introduction to
make the EIA system more effective (Ali, 2007; Glasson and Salvador, 2000; Jou
and Liaw, 2006; Paliwal and Srivastava, 2012; Vidyratne, 2006; Wang et al.,
2003).

Quality of information presented in the EISs

In order to assess the performance of key stages of the EIA process, information
contained in the EIA reports were reviewed against a set of criteria. The findings
show that a significant number of EIA reports (35% of EISs reviewed) are not of a
satisfactory standard and fail to present adequate information on the key steps of
the EIA process satisfactorily (Fig. 2). The findings indicate that deficiencies
occurred at various stages of the EIA process, including the collection and

40%
35%
35%
30%
Number of EISs

25%
25%
20%
20%
15%
10% 10%
10%
5%
0%
0%
A= B= Good C= Just D= Poor E= Very F= Fail
Excellent sa
sfactory poor

Fig. 2. Performance of EISs in Bangladesh.

1350018-13
S. M. Z. Kabir & S. Momtaz

presentation of baseline data, identification and prediction of impacts, lack of

analysis of alternative options, and poor design of mitigation measures. These
findings are similar to previous evaluations of EIA systems (for example, Badr
et al., 2011; Barker and Wood, 1999; Cashmore et al., 2002; Glasson et al., 1997;
Sandham and Pretorius, 2008).
With regards to key shortcomings, for some EISs, baseline data collected
appear to be inadequate and inconsistent. For example, in order to identify po-
tential impacts of a gas pipe line or power transmission line, it is necessary to
collect detailed baseline information on soil quality and wildlife characteristics.
However, the EISs of these types of projects are often found to be deficient (GOB,
2001b; 2005a; 2008). In the case of socio-economic data, much of the data
collected are often not relevant and therefore, not useful for impact prediction. On
the other hand, data relating to vulnerable groups such as children, aged people,
female-headed households, and indigenous households are were not consistently
collected. In rural Bangladesh, female-headed households (male-absent house-
holds) for example, are likely to have lower levels of income male-headed
households due to low literacy rate, asset holdings and access to employment
compared to men (Joshi, 2004; Mallick and Rafi, 2010). Therefore, the intensity
of potential impacts experienced by these vulnerable groups can be more severe
than others.
Furthermore, the identification and prediction of impacts is the most important
stage of the EIA process as it contains the results of an EIA study. However, this
stage is often found to be poorly performed. Common deficiencies include; a
failure to provide adequate explanations of methods or techniques used to predict
and evaluate impacts, inadequate coverage of impacts, lack of quantification of
impacts where applicable, and poor evaluation of impact significance.
All of the EISs reviewed in this study identified social and bio-physical impacts
but most of them failed to identify health impacts on the affected people in general
and the vulnerable groups, such as children, pregnant women, and the poor in
particular. Assessment of health impacts within EIA is a requirement in Bangla-
desh (DOE, 1997b, p. 42). Furthermore, hardly any EIS explicitly mentions cu-
mulative impacts (CIs) despite the assessment of CIs being one the requirements
(DOE, 1997b). Bangladesh is a land-hungry country and projects are often located
closely together, particularly industrial projects. Therefore, CIs should be properly
identified and assessed.
Another shortcoming within the EIA process is a failure to assess the signifi-
cance of impacts clearly and precisely. Few EISs in this study interpret the basis of
the determination of significant impacts. Surprisingly, many EISs in this study fail
to recognise that impact prediction and the assessment of significant impacts are

1350018-14
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

two different stages. The EISs in this review scarcely define “significant impact” or
provide any clear description as to why an impact is significant or insignificant.
These findings concur with the findings of previous studies (for example,
Fuller, 1999; Glasson et al., 1997; Sadler, 1996; Sandham and Pretorius, 2008).
Even in a mature EIA system, the quality of EISs suffers from inadequacies,
especially with regard to impact prediction, determination of significant impacts,
and design of mitigation measures (Fuller, 1999; Sadler, 1996). The implication of
this weakness is that there is the potential risk of poor decision making in the
planning and approval of projects.

Implementation of mitigation measures and monitoring

To understand the performance of EIA at its follow-up stage, the extent of the
implementation of mitigation measures was investigated for three projects. In
relation to the key predicted impacts, proposed mitigation measures and actual
implementation of mitigation measures (Appendix B). In the case of the three
projects, the findings (Fig. 3) show that there is a clear gap between the mitigation
measures recommended by the EIA reports and the mitigation measures actually
implemented by the proponents. In general, mitigation measures have only been
partially implemented in each of the three projects. It can therefore be assumed that
environmental protection targets of the projects were not fully achieved which is
the ultimate aim of an EIA. For these three projects, it is also found that that the
performance at post-EIA stages varies among them in relation to the extent of
monitoring and the extent of mitigation measures implemented. This variation in
performance is a topic of further research in relation to the type of sectors, pro-
ponents, sources of funding (donors’ funded or public funded) and the size of
projects.

70% 63%
58%
60%

50%
38% 38%
40% Fully

30% 25% 26% Par
ally

24%
16% Not at all
20%
12%
10%

0%
KJDRP MPPP JMBP

Fig. 3. Performance of mitigation measures implemented for three projects.

1350018-15
S. M. Z. Kabir & S. Momtaz

As a part of successful implementation of mitigation measures, monitoring is an

integral part of the post-EIS stage (Jha-Thakur, 2011). Interviews with local
community and key informants and direct observation during site visits by the
authors reveal that monitoring programs were inadequate. The proponents of three
projects set up monitoring and evaluation units, however the coverage of moni-
toring of impacts was limited. Each of the projects had largely ignored the
monitoring of ecological impacts (loss of vegetation and local wildlife species).
Monitoring was mostly limited to physical impacts. For example, in the case of
KJDRP, monitoring was limited to hydrological and morphological changes such
as the depth of rivers, sedimentation rate, and salinity. There were no adequate
arrangements to monitor the loss of aquatic biodiversity or loss of fish production.
The proponents addressed some social impacts (for example, resettlement of
displaced people by the Jamuna Multi-Purpose Bridge project or cash compen-
sation for acquisition of land by the KJDRP project). This was however, due to the
pressure from donor agencies.
The DOE, despite its strong legal authority, cannot enforce the application of
EIAs due to a shortage of staff, political intervention, and, sometimes, the lack of
sincerity of DOE officials. Given the infrequent site visit and inspection by the
DOE, the monitoring data (for example, water quality data) sent by the proponents
to the DOE has often found to have been manipulated and misleading (Interview
#6). The donor agencies, namely the Asian Development Bank and the World
Bank, and the highest project approval authority, namely the Planning
Commission, did not show much interest in the environmental performance of
proponents during the implementation and operation of projects. The donor
agencies usually think that it is the responsibility of the government to force
proponents to mitigate potential impacts.
The findings indicate that the practice of EIA in Bangladesh is still largely pre-
occupied with the preparation of EIA reports despite the fact that the ultimate
effectiveness of an EIA system depends on the effective implementation of miti-
gation measures or broadly follow-up of EIA (Gachechiladze-Bozhesku and Fischer,
2012; Cashmore et al., 2004; Jha-Thakur et al., 2009; Jha-Thakur, 2011; Morrison-
Saunders and Bailey, 1999; Noble and Storey, 2005; Sadler, 1996; Sanchez and
Gallardo, 2005; Shepherd, 1998; Wood, 1999). However, the inadequate imple-
mentation of mitigation measures is not unique to Bangladesh. A number of similar
studies conducted in the past, for example, that of the ADB (1998), Jha-Thakur et al.
(2009), Jha-Thakur (2011), Marshal (2001), Morrison-Saunders and Bailey (1999),
Morrison-Saunders et al. (2003), Ortolano and May (2004), and Wilson (1998) have
also demonstrated that the implementation of mitigation measures and other activ-
ities are poorly performed at the follow-up stage of EIA.

1350018-16
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

Conclusions and Recommendations

In this paper the EIA system in Bangladesh was reviewed by analysing three key
areas: institutional arrangements, the quality of EIA reports, and the performance
of EIA at post-EIS stage. This study reveals that, in general, the EIA system in
Bangladesh appears to be on the right track. Indeed, the current situation of the
EIA system in Bangladesh is better than it had been in the past. There has been
legislation for EIAs since 1995. The DEO is well mandated by the EIA legislation
(ECA) to exercise its power in implementing the EIA. The capacity of the DOE is
better than it was fifteen years ago. The quality of EISs is in general satisfactory
and has been improving over time albeit slowly. Project proponents take initiatives
to implement the mitigation measures and monitor the impacts of the projects.
Despite this progress, the EIA system is still far from representing good practice:
the EIA legislation is not comprehensive, the DOE is not well funded (yet) and there
is a shortage of staff. In addition, the function of the DOE is not decentralized. Some
of the EISs are still deficient in quality information due to poor identification, pre-
diction and assessment of impacts and analysis of alternatives. Moreover, mitigation
measures are not satisfactorily implemented and, therefore, predicted impacts of a
project are not addressed adequately. Given these shortcomings, the following
recommendations are made for improving the EIA system in Bangladesh:

. The ECR must clearly indicate the requirements of key stages of the EIA
process and existing ambiguous provisions of some requirements must be
amended. This will ensure consistent operation of EIA in Bangladesh.
. The DOE should be equipped with adequately trained staff, budget, and stable
leadership with a view to enforcing the proponents’ efficient and practical
compliance with EIA requirements. Decentralization of the DOE’s function and
administration at district and Upa-Zilla (Sub-district) levels (two important ad-
ministrative tiers of central government) is needed.
. EISs should be published in Bengali language in order to make them easily
understandable to the wider public in Bangladesh. At the very least, the non-
technical summary should be published in Bengali.
. To improve the quality of information relating to identification and assessment
of impacts, review mechanisms must be improved by the DOE in addition to the
introduction of a code of conduct for consulting firms. In India, for example,
only accredited firms are allowed to undertake EIA (Paliwal and Srivastava,
2012). This provision is yet to be in force in Bangladesh.
. To improve the performance of the implementation of mitigation measures at the
post-EIS stage of EIA process, proponents’ commitment is necessary in addition
to regular surveillance by the DOE.
1350018-17
S. M. Z. Kabir & S. Momtaz

. For the donor funded projects, donors need to control the release of funds based
on environmental performance of the proponents. This will enforce the propo-
nents to properly implement the mitigation measures and monitoring activities.
It is often difficult for the DOE to prosecute government proponents (mainly for
political reason), but sanctions by the donor agencies may help overcome this
problem.
. Cooperation and coordination among the core stakeholders (the DOE, donor
agencies, the community and the proponent) is essential for improving EIA
practice in Bangladesh. Regular meetings within the National Environmental
Council (NEC) may facilitate the cooperation between the DOE and other
sectoral agencies. Pressure from donors on proponents for the involvement of
community at the implementation of mitigation measures can be supportive.

Appendix A. Review Criteria Developed

in the Context of Bangladesh

1. Description of the development and baseline 1.5 Environmental baseline

1.1 Description of development
1.1.1 Background and objectives of project
1.1.2 Design and size of the project
1.1.3 Some indication of physical presences
1.1.4 Nature of production process
1.1.5 Nature and quantities of raw materials
1.1.6* Policy and legal framework for EIA
1.1.7* EIA aim and objectives
1.1.8* Limitation of study
1.2 Description of site
1.2.1 Land area taken by the development site
1.2.2 The use of land taken
1.2.3 Estimated duration of project alternatives
1.2.4 Number of workers and means of
transport
1.2.5 Means of transporting raw materials
1.3 Waste generation
1.3.1 Types and quantities
1.3.2 Production process and waste generation
1.3.3 Treatment of wastes generated
1.4 Environmental description
1.4.1 Environment expected to be affected
1.4.2 Offsite impacts
1.5.1 Description of important components
1.5.2* Natural of physical environment
1.5.3* Biological environment
1.5.4* Socio-economic environment
1.5.5 Methods and sources of data with
justification
1.5.6 Future state of environment without
project
2. Identification and evaluation of key
impacts
2.1 Definition of impacts
2.1.1 Impact types
2.1.2 Impacts with regard to human,
ecology etc.
2.1.3 Impacts of accidents
2.1.4 Impacts as the deviation of baseline
2.2 Identification of impacts
2.2.1 Methods used for impacts
2.2.2 Justification of methods used
2.3 Scoping
2.3.1 Arrangements for scoping
2.3.2 Methods of collection of opinions
2.3.3 Inputs from stakeholders

1350018-18
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

(Continued )

2.3.4 Selection of key impacts to be investigated 3.2.2 Mitigation measures with

2.4 Prediction of impacts justification
2.4.1 Data gaps and uncertainty 3.2.3 Residual impacts
2.4.2 Methods used with justification 3.3 Commitment to mitigation
2.4.3 Quantitative expression where 3.3.1 Implementation arrangements
possible 3.3.2 Monitoring program
2.4.4* Uncertainty 3.3.3* Parameters to be monitored
2.5 Assessment of impact significance 3.3.4* Feedback and reporting mechanism
2.5.1 Significance of impact on 4. Presentation of EIS and
community and environment communication
2.5.2 Methods used for evaluation of 4.1 Layout
impacts 4.1.1 Introduction and brief description
2.5.3 Justification of methods used 4.1.2 Logical arrangements of information
2.6* Community involvement 4.1.3 List of references
2.6.1 Description of community affected 4.2 Presentation
2.6.2 Involvement of community 4.2.1 Comprehensible to non-specialist
2.6.3 Methods of community involvement 4.2.2 Defining technical terms
2.6.4 Inputs from community 4.2.3 Presented as an integrated whole
3. Alternatives and environmental mitigation 4.3 Emphasis
3.1 Alternatives 4.3.1 Potentially severe adverse impacts
3.1.1 Alternative sites 4.3.2 Unbiased statements
3.1.2 Alternative process, design and activities 4.4 Executive summary
3.1.3 Selection of alternatives 4.4.1 Findings presented in a non-technical
3.2 Scope and effectiveness of mitigation way
measures 4.4.2 Recommendations
3.2.1 Description of adverse impacts to be
mitigated

1350018-19
 Appendix B. Implementation of Mitigation of Measures of Three Projects

Proposed mitigation Actual implemented

Key predicted impacts measures mitigation measures Comments

Project: Khulna-Jessore drainage rehabilitation project

S. M. Z. Kabir & S. Momtaz

Loss of open-water fish habitat and re- Protection of open water fish habitat þ Proponent installed vertical structure at
duction of fish production, disrup- from loss by keeping more water and a very limited scale to facilitate fish
tion of fish migration due to realising fingerlings in the regulator migration. Also the proponents did
regulatory option. area; and operating regulators in not operate the vertical slots in a
fish-friendly way. fish-friendly way (example,
Madhukhali and Shibnagar reg-
ulators). No fish passes were built.
Disruption of agricultural production Use of dredged materials for homestead þ Most dredged and excavated soils were

1350018-20
due to the disposal of dredging
material in both sides of the river.
Deterioration of quality of water during
dredging and disturbance of fish
breeding.
Potential loss of aquatic habitat for
plants and wild life due to imple-
mentation of regulators for water
control.
purpose and evenly distribution of
dredged- soil on the agricultural land
to reduce disruption of agriculture.
Carry out dredging in the rainy season
only and no dredging activity during
fish breeding season and dry season.
Implementation of tidal basin manage-
ment (TBM) option instead of reg-
ulator option. Basins (beels) will be
maintained as sanctuaries for plants,
fish and wildlife.
piled up on agricultural land at both
sides of the river. Local community
used the dredged soil for homestead
purpose but at their own.
þþ The proponent did follow this provi-
sion. Contractor dredged during dry
season and breeding seasons.
þ TBM option was not implemented in
the whole project areas and there-
fore, the aquatic habitat was not
fully protected.

Key predicted impacts
Possible death of Bhadra River and
Hamkura River due to regulatory
option that discourages normal flow
of water.
Loss of shrimp production due to non-
availability of brackish water under
regulator option.
1350018-21
Loss of farmers’ livelihood in the TBM
option area due to suspension of
firming for one/two years.
Loss of income by the land owners due
to land acquisition in TBM area.
(Continued )
Proposed mitigation
measures
Prevention of Bhadra and Hamkura
River from dying by creating a tidal
basin in the Singha beel.
Protection of the loss of shrimp pro-
duction in the project area with the
support of agricultural officers.
Compensation for acquisition of firming
land from farmers by the
government
Protection of farmers’ livelihood in the
TBM area through financial support
for the affected farmers till the land
becomes fully cultivable.
Actual implemented
mitigation measures Comments
¡ Implementation of the TBM option,
particularly in the Singha beel,
would keep the Upper Bhadra River
and lower part of the Hamkuri river
active but TBM option was not
implemented.
¡ The fishery office was reluctant to ex-
tend their services for the affected
shrimp farmers. The office imparted
training to few community members
on shrimp culture but no other ma-
terial supports.
þ Initially, the Water Development Board
paid some cash compensation but
then there was no support from the
Government.
þ Although the proponent implemented
compensation program satisfactorily,
the process did not end in time. Land
owners had to experience a lengthy
and complex bureaucratic process
and high transaction costs in order to
receive compensation for their land.
Fifteen Years of Environmental Impact Assessment System in Bangladesh
 (Continued )

Proposed mitigation Actual implemented

Key predicted impacts measures mitigation measures Comments

Project: Meghnaghat power plant project

Loss of terrestrial and aquatic habitat Creation of green belt areas in the ¡ Green belt was not created in the project
and fish species during construction project site and habitat for terrestrial site to protect the habitat for terres-
and operation of power plant. and riparian wildlife species. trial and riparian species.
S. M. Z. Kabir & S. Momtaz

Noise pollution and disturbance for Implement noise management measures
neighbour residents and other sensi- to protect neighbouring community
tive receptors. from noise pollution.
Air quality deterioration due to emission Use of dry-low NOx burner for the gas
of NOx and SOx. turbines. Use of natural gas. Use of
60 metre high stack to optimise
dispersion of exhaust gases.
þþ Proponent built a muddy wall and
planted trees to protect the neigh-
bours from noise made by the power
plant.
þþ Proponent installed dry-low-NOx gas
turbines. Two stacks of 60 meters in
height each were also built to emit
the NOx into the air. Used natural

1350018-22
Decrease of fish population due to the
release of cooling waste/water in the
nearby river by the plant.
Impact of solid waste generated in the
form of sludge that contains heavy
metals on soil and water.
An effluent disposal system will be
installed to effectively treat and dis-
charge of water. Temperature will be
control to reduce effect on aquatic
biota.
Regular analysis of sludge, lubricants
and hydraulic oil and treatment, re-
cycle and dumping of waste by
licensed contractors.
gas, hence less emission of SOx.
þþ Proponent installed an effluent disposal
system to treat the hot waste water
generated from cooling process.
Release of hot water into the
Meghna River after proper
treatment.
þ Proponent established an Environmental
Health and Safety Unit including a
laboratory for testing solid and
liquid waste. Employed licenced
contractor to dispose the treated
waste.

Key predicted impacts
Involuntary resettlement of households
due to land acquisition and devel-
opment.
Water quality of the river would dete-
riorate during dredging in the
Meghna River.
1350018-23
Loss of vegetation due to development
of project site.
Project: Jamuna multi-purpose bridge project
Loss of aquatic biodiversity and dis-
ruption of navigating due to closure
of Northern intake of Dhaleswari
River.
(Continued )
Proposed mitigation
measures
Adequate cash compensation to the
affected people. Training for alter-
native jobs and livelihoods.
Close monitoring to observe the water
quality during dredging. During the
dry season dredging will be sus-
pended.
Trees will be planted in the open space
of the project area to compensate for
the loss of vegetation and habitat for
birds and other wildlife.
Protection of aquatic biodiversity and
disruption of navigation by provid-
ing alternative intake (channel) and
enlargement of southern intake.
Actual implemented
mitigation measures Comments
þ The compensation for the loss of land
was paid on time to all affected
individuals. However, the recipient,
were not too happy since the pay-
ment was lower than the actual
market price.
þþ There was close monitoring to observe
the water quality. During the dry
season dredging activity was sus-
pended. The Bangladesh Inland
Water Authority (BIWTA) regularly
supervised this activity.
þ Plantation of trees covered only a little
area of the project site. The vast
amount of land of the project site has
been left open with no plantation.
þ The proponent did not create an alter-
native channel and no enlargement
of the Southern intake. A new off-
take opened naturally nearby after
three years from the start of the
construction work of the project but
it was not adequate to offset the re-
duced flow of water.
Fifteen Years of Environmental Impact Assessment System in Bangladesh

Key predicted impacts
Loss of agricultural production and
aquatic habitat due to land acquisi-
tion and disruption of water flow a
river.
Loss of fish production in the project
area due to closure of Northern
intake.
1350018-24
Loss of wildlife during construction,
and the loss of food and shelter for
birds due to reduction of vegetation
habitat.
(Continued )
Proposed mitigation
measures
Provide training to affected farmers and
provision of credit facilities to com-
pensate for the loss of agricultural
production.
Creation of new and improvement of
existing ponds in the areas, supply of
fish fry and fingerlings to affected
community, alternative employment
generation training to offset the loss.
Awareness building program among
community and workers about the
value of wildlife species, plantation
at both sides of approach roads for
migratory birds, and the establish-
ment of a permanent sanctuary/
protected area.
Actual implemented
mitigation measures Comments
¡ A few farmers were trained and farmers
were not adequately compensated
for the disruption and loss of agri-
cultural production during the four
S. M. Z. Kabir & S. Momtaz
year construction of the bridge.
¡ Ponds created for fish production were
not suitable for fish culture since
most of the ponds were dried up and
required re-excavation. Lack of
timely supply of basic inputs for fish
production relating to eggs, fish
feeds, fish fingerlings and fish fries.
þ Proponent did not create any sanctuary
for the potentially affected wildlife
species. Also, the proponent did not
run effectively such an awareness
program.

Key predicted impacts
Disruption of boat navigation due to
lack of water and loss of livelihood
of boat people.
Loss of vegetation and fuel wood for
local community.
1350018-25
Permanent displacement of affected
people due to land acquisition.
Pollution of river water due to dredging
during winter season
Notes: Fully: þþ; Partially: þ; Not at all: ¡.
(Continued )
Proposed mitigation
measures
Cash compensation for affected boat-
men during the days they have to
abstain from boating, provision of
training to pursue alternative em-
ployment.
Plantation and social forestation en-
hancement along both sides of ap-
proach roads, in resettlement areas
and open used land acquired for the
project
Resettlement for displaced families near
the Jamuna Bridge and provision of
income generation training.
Maintenance of river water quality
during construction, seasonal varia-
tion will be followed.
Actual implemented
mitigation measures Comments
¡ The proponent did not implement these
actions on the grounds. The propo-
nent argued that ‘the channel that
opened up naturally shortly after the
closure of northern intake of
Dhalewsari would offset the loss or
damage’ (JMBP-Istiaq) but it did not
happen.
þ One NGO called Grameen Bank was
awarded the plantation task for im-
plementation. Project site visits
revealed that two-thirds of the total
land acquired for the project was left
open at both ends of the bridge.
þþ The implementation of the Resettlement
Action Plan (RAP) was satisfactory
and, the proponent recruited them in
different construction jobs depend-
ing on their skill levels.
þþ Seasonal variation was followed by the
proponent, continuous monitoring
was in place.
Fifteen Years of Environmental Impact Assessment System in Bangladesh
S. M. Z. Kabir & S. Momtaz

Acknowledgements
The authors are thankful to two anonymous reviewers and Professor Thomas B
Fischer made valuable comments on the previously submitted drafts of this paper.
In addition, the authors acknowledge the support from Professor John Rolfe,
Director of Centre for Environmental Management, CQUniversity, Australia.

References

Abaza, H, R Bisset and B Sadler (2004). Environmental Impact Assessment and Strategic
Environmental Assessment: Towards an Integral Approach. Geneva, Switzerland:
United Nations Environmental Program.
ADB (2007). The Philippines Environmental Impact Statement System: Framework,
Implementation, Performance and Challenge. The Philippines.
Ahammed, AKMR and N Harvey (2004). Evaluation of environmental impact assessment
procedures and practice in Bangladesh, Impact Assessment and Project Appraisal,
22(1), 63–78.
Ahmad, B and C Wood (2002). A comparative evaluation of the EIA systems in Egypt,
Turkey and Tunisia. Environmental Impact Assessment Review, 22, 213–234.
Ali, OMM (2007). Policy and institutional reforms for an effective EIA system in Sudan,
Journal of Environmental Assessment Policy and Management, 9(1), 67–82.
Arts, J, H Runhaar, TB Fischer, U Jha-Thakur, F van Laerhoven, P Driessen and
V Onyango (2012). The effectiveness of EIA as an instrument for environmental
governance — a comparison of the Netherlands and the UK, Journal of Environmental
Assessment Policy and Management, 14(4), 1250025-1–40.
Badr, E, AA Zahran and M Cashmore (2011). Benchmarking performance: Environmental
impact statements in Egypt, Environmental Impact Assessment Review, 31(3), 279–285.
Bailey, J (1997). Environmental impact assessment and management: An unexplored
relationship. Environmental Impact Assessment Review, 21(3), 317–327.
Barker, A and C Wood (1999). An evaluation of EIA system performance in eight EU
countries, Environmental Impact Assessment Review, 19, 387–404.
Briffett, C (1999). Environmental impact assessment in East Asia. In Handbook of En-
vironmental Impact Assessment: Environmental Impact Assessment in Practice-Impact
and Limitations, J Petts (ed.), Vol. 2, pp. 143–167. Oxford: Blackwell.
Cashmore, M, E Christophilopoulos and D Cobb (2002). An evaluation of the quality of
environmental impact statements in Thessaloniki, Greece, Journal of Environmental
Assessment Policy and Management, 4(4), 371–395.
Cashmore, M, R Gwilliam, R Morgan, D Cobb and A Bond (2004). The interminable
issue of effectiveness: Substantive purposes, outcomes and research challenges in the

1350018-26
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

advancement of environmental impact assessment theory, Impact Assessment and

Project Appraisal, 22(4), 295–310.
Clusen, A, H Hoa and M Pedrono (2011). An evaluation of environmental impact as-
sessment in Vietnam: The gap between theory and practice, Environmental Impact
Assessment Review, 31, 136–143.
Department of Environment (1997a). The Environmental Conservation Act, Ministry of
Environment and Forest, Dhaka, Bangladesh.
Department of Environment (1997b). The Environmental Conservation Rules, Ministry of
Environment and Forest, Dhaka, Bangladesh.
Emmelin, L (1998). Evaluating environmental impact assessment systems — part 1:
Theoretical and methodological considerations, Scandinavian Housing & Planning
Research, 129–148.
European Commission (2009). Study Concerning the Report on the Application and
Effectiveness of the EIA Directive, Final Report, COWI, Denmark.
Fischer, TB (2010). Reviewing the quality of strategic environmental assessment reports for
English spatial plan core strategies, Environmental Impact Assessment Review, 30, 62–69.
Fischer, TB and V Onyango (2012). Strategic environmental assessment-related research
projects and journal articles: An overview of the past 20 years, Impact Assessment and
Project Appraisal, 30(4), 253–263.
Fuller, K (1999). Quality and quality control in environmental impact assessment. In
Handbook of Environmental Impact Assessment, J Petts (ed.), Vol. 2, Chapter-4, pp.
55–84. Oxford: Blackwell Science Ltd.
Gachechiladze-Bozhesku, M and TB Fischer (2012). Benefits of and barriers to SEA
follow-up, EIA Review, 32(4), 22–30.
Glasson, J and NNB Salvador (2000). EIA in Brazil: A procedure-practice gap. A com-
parative study with reference to the European Union, and especially the UK, Envi-
ronmental Impact Assessment Review, 20, 191–225.
Glasson, J, R Therivel and A Chadwick (2005). Introduction to Environmental Impact
Assessment. London: Taylor and Francis Group.
Glasson, J, R Therivel, J Weston, E Wilson, and R Frost (1997). EIA-learning from
experience: Changes in the quality of environmental impact statements for UK planning
projects, Journal of Environmental Planning and Management, 40(4), 451–464.
Government of Bangladesh (GOB) (2001). EIA of Gorai River Restoration Project,
Bangladesh Water Development Board, Ministry of Water Resource Development,
Government of Bangladesh.
Government of Bangladesh (GOB) (2005). Nakla, Harikumut-Bonara-Ishwardi-Veramara
101 Km Gas Transmission Pipeline Project. Ministry of Energy, Power and Mineral
Resources, Dhaka.
Government of Bangladesh (GOB) (2008). Bakharabad-Siddhirganj Gas Transmission
Pipeline Project. Ministry of Energy, Power and Mineral Resources, Government of
Bangladesh.

1350018-27
S. M. Z. Kabir & S. Momtaz

Harvey, N and B Clarke (2012). Environmental Impact Assessment in practice. Oxford

University Press.
Jha-Thakur, U (2011). Environmental impact assessment follow-up in India: Exploring
regional variation, Journal of Environmental Assessment Policy and Management,
13(3), 435–458.
Jha-Thakur, U, TB Fischer and A Rajvanshi (2009). Reviewing design stage of envi-
ronmental impact assessment follow-up: Looking at the open cast coal mines in India,
Impact Assessment and Project Appraisal, 27(1), 33–44.
Joshi, S (2004). Female households-headship in rural Bangladesh: Incidence, determinants
and impact on children’s schooling. Centre Discussion Paper No. 894, Yale University,
USA.
Jou J-J and S-L Liaw (2006). A study on establishment of EIA system in the Taiwan
region, Journal of Environmental Assessment Policy and Management, 8(4), 479–494.
Kolhoff, AJ, PPJ Driessen and HAC Runhaar (2013). An analysis framework for char-
acterising and explaining development of EIS legislations in developing countries-
Illustrated for Georgia, Ghana and Yemen, Environmental Impact Assessment Review,
38, 1–15.
Lee, N (2000). Environmental assessment in its developmental and regulatory context. In
Environmental Assessment in Developing and Transitional Countries: Principals,
Methods and Practice. N. Lee and C. Gorge (eds.), John Wiley & Sons, Ltd.
Lee, N and C George (eds.) (2000). Environmental Assessment in Developing and
Transitional Countries: Principles, Methods and Practice. New York: John Wiley &
Sons, Ltd.
Lee, N and R Colley (1992). Reviewing the Quality of Environmental Assessments,
Occasional Paper No 24, Environmental Impact Assessment Centre, University of
Manchester, UK.
Lohani, BN, JW Evans, RR Everitt, H Ludwig, RA Carpenter and S Tu (1997). Envi-
ronmental Impact Assessment for Developing Countries in Asia, Volume 1, Asian
Development Bank, Manilla, pp. 1–356.
Mallick, D and M Rafi (2010). Are female-headed households more food insecure? Evi-
dence from Bangladesh, World Development, 38(4), 593–605.
Marshal, R (2001). Application of mitigation & its resolution within environmental impact
assessment: An industrial perspective, Impact Assessment and Project Appraisal, 19(2),
195–204.
Momtaz, S (2002). Environmental impact assessment in Bangladesh: A critical review,
Environmental Impact Assessment Review, 22, 163–179.
Momtaz, S (2003). The practice of social impact assessment in a developing country: The
case of environmental and social impact assessment of Khulna-Jessore drainage
rehabilitation project in Bangladesh, Impact Assessment and Project Appraisal, 21(2),
125–132.

1350018-28
 Fifteen Years of Environmental Impact Assessment System in Bangladesh

Momtaz, S (2005). Institutionalizing social impact assessment in Bangladesh resource

management: Limitations and opportunities, Environmental Impact Assessment Review,
25, 33–45.
Morgan, RK (2012). Environmental impact assessment: The state of art, Impact Assess-
ment and Project Appraisal, 30(1), 5–14.
Morrison-Saunders, A and J Bailey (1999). Exploring the EIA/Environmental manage-
ment relationship, Environmental Management, 24(3), 281–295.
Nadeem, O and TB Fischer (2011). An evaluation framework for effective public par-
ticipation in EIA in Pakistan, Environmental Impact Assessment Review, 31, 36–47.
Netherlands Commission for EIA (1994). EIA Methodology in the Netherlands: Views of
Commission for EIA, Utrecht.
Noble, B and K Storey (2005). Towards increasing the utility of follow-up in Canadian
EIA, Environmental Impact Assessment Review, 25, 163–180.
Ortolano, L and CL May (2004). Appraising effects of mitigation measures: The grand
Coulee Dam’s impacts on Fisheries. In Assessing Impact: Handbook of EIA and SEA
Follow-up. A Morrison-Saunders and J Arts (eds.), Earthscan: London.
Paliwal, R and L Srivastava (2012). Adequacy of the follow-up process in India and
barriers to its effective implementation, Journal of Environmental Planning and
Management, 55(2), 191–210.
Petts, J (1999). Introduction to environmental impact assessment in practice: Fulfilled
potential or wasted opportunity? In Handbook of Environmental Impact Assessment.
J Petts (ed.), pp. 3–9. Blackwell Science: London.
Phylip-Jones, J and TB Fischer (2013). EIA for wind farms in the United Kingdom and
Germany, Journal of Environmental Assessment Policy and Management, 15(2),
1340008.
Sadler, B (1996). International Study of the Effectiveness of Environmental Assessment:
Final Report, Canadian Environmental Assessment Agency/International Association
for Impact Assessment.
Sanchez, LE and CF Gallardo (2005). On the successful implementation of mitigation
measures, Impact Assessment and Project Appraisal, 23(3), 182–190.
Sandham, LA and HM Pretorius (2008). A review of EIA report quality in the North
West province of South Africa, Environmental Impact Assessment Review, 28(4-5),
229–240.
Thomas, I (2005). Environmental Impact Assessment in Australia: Theory and Practice,
Sydney, Australia: The Federation Press.
Vidyratne H (2006). EIA theories and practice: Balancing conservation and development
in Sri Lanka, Journal of Environmental Assessment Policy and Management, 8(2),
205–222.
Wang, Y, RK Morgan and M Cashmore (2003). Environmental impact assessment of
projects in the people’s republic of China: New law, old problem, Environmental
Impact Assessment Review, 23(5), 543–579.

1350018-29
S. M. Z. Kabir & S. Momtaz

Wende, W (2002). Evaluation of the effectiveness and quality of environmental impact

assessment in the Federal Republic of Germany, Impact Assessment and Project
Appraisal, 20(2), 93–99.
Wilson, L (1998). A practical method for environmental impact assessment audits,
Environmental Impact Assessment Review, 18, 59–71.
Wood, C (1995). Environmental Impact Assessment—A Comparative Review, London:
Prentice Hall.
Wood, C (2003). Environmental impact assessment in developing countries, International
Development Planning Review, 25(3), 301–321.

1350018-30