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Initial Environmental Evaluation, Northeast Regional Water Management Plan, Bangladesh Flood Action Plan 6

CHAPTER 1: INTRODUCTION

1.1  BACKGROUND

The Flood Action Plan is the first stage in the development of a long-term water management plan for Bangladesh. It is comprised of a phased programme of initiatives to control flooding, supported by special studies, surveys, and pilot projects. The Northeast Regional Water Management Project (NERP) is Component 6 of the Flood Action Plan (FAP) and one of five regional water management studies within the FAP. A map of the region is shown in Figure 1.

NERP consists of two phases. Under Phase I, recently concluded, a Regional Water Resources Development Plan was prepared, using a strategic planning process based on specialist studies of key areas including existing water resources development, hydrology, ground water, river sedimentation and morphology, agriculture, fisheries, water transport, biodiversity (wetland and upland), human resources development, and institutions.

The Regional Plan proposes a water management strategy for the development of regional water management systems through 2015. The strategy includes a portfolio of 44 specific projects for implementation over the next 20 years by a variety of government, non-governmental, and private agencies.

NERP Phase II will consist of feasibility study and implementation of one or more of these projects.

1.2  REGIONAL PLAN RATIONALE AND OBJECTIVES

The basic rationale for regional planning of water resources development is the desire to improve upon planning undertaken on a project-by-project basis. Regional planning provides the opportunity for both broader (over more disciplines and a greater area) and deeper (with more information and analysis) investigation of present conditions, likely future trends, and opportunities for intervention. In particular, regional planning provides opportunities to look at issues at a macro level, such as trade-offs between sectors, overall programme phasing, improvements common to many projects (e.g. provision of fish passes in embankments), and relationships between projects.

The overall objective of the Project, as stated in the Terms of Reference, is:

". . . to assist the GOB in planning and guiding the development of the project region and to provide criteria for the selection , design, implementation, operation and maintenance of individual water-management projects benefitting the agricultural, fisheries, and related sectors, with due attention to the growing landlessness of the rural population. In accordance with the objectives of the Action Plan, the Project is to provide the basis for the management of the Northeast Regions' water resources with a view to creating an environment for sustained economic growth and social improvement."

1.3  RELATIONSHIP OF IEE TO REGIONAL PLAN

The purpose of the IEE is to characterize the potential environmental impacts of Plan implementation, at a level of information and analysis consistent with the Plan itself.

More fundamentally, the regionally planning exercise itself requires adequate understanding of (1) current biophysical and socioeconomic conditions; (2) important future trends; and (3) the potential benefits to be gained from, and adverse effects of, potential development interventions. In the language of EIA/IEE, these are (1) baseline conditions, (2) future-without-project conditions, and (3) impacts, respectively.

Readers of the IEE are assumed to have ready access to a copy of the Regional Plan. In particular, the IEE includes references to Regional Plan figures.

1.4  TEAM, BUDGET, AND LEVEL OF EFFORT

Most of this document derives from work done as an integral part of the regional planning exercise, rather from work done separately in the service of EIA/IEE. Indeed, this IEE summarizes information and analysis generated by the NERP team as a whole during the entire two-year Phase I period. The IEE team, budget, and level of effort, then, are essentially the same as and cannot be separated out from the Phase I budget. The only input which related solely to the IEE was that required in drafting this document -- about four person-months, involving five people.

1.5  IEE METHODOLOGY

Within the context of the preparation of the Regional Plan, the main steps in undertaking this IEE were as follows. Public consultation and expert input are integral throughout.

For the portfolio as a whole, the tasks were:

  • Develop a master list of the important environmental components (IECs) that could be impacted by Plan implementation, from the mass of information generated regarding current conditions, driving forces, issues, strengths, weaknesses, opportunities, and threats, and proposed projects. The IECs used here are shown in Table 5.1.
  • Develop a master list of potential project activities that could have impacts on the environment (see Section 3.7).
  • Construct an environmental screening matrix of potential project activities vs. IECs, to be used in screening and scoping each individual project (Figure 2).
  • Devise a list of possible interactions between and among different projects in the portfolio (see Section 9.5).
  • Devise a list of external, non-Plan processes or projects whose impacts overlap with those of the Plan projects (cumulative impact assessment; see Section 10.1).
  • Devise a list of external processes or projects whose impacts could affect the infrastructure or operation of Plan projects (environment-on-project impacts; see Section 9.6).
  • Identify suitable sustainability criteria.
  • Determine which impacts can be quantified. The remaining impacts would be described qualitatively and ranked.
  • Devise a methodology for quantifying each quantifiable impact (see Chapter 7). Methodologies range from pure estimation based on subjective expert judgement based on secondary data to highly sophisticated objective (numerical) models based on data from extensive field studies.
  • Devise a methodology for scoring non-quantifiable impacts (see Section 7.2.8).
  • Devise projects for inclusion in the Plan to address important environmental management issues to ensure that the Plan is implemented in an environmentally sound manner. Examples of such projects include Northeast Region Environment Management and Research Project (NEMREP), Fisheries Management, Fisheries Engineering, Flood- and Erosion-Affected Villages Development Project, and others.
Then, for each project,
  • Screen to make a preliminary identification of potential impacts (project-on-environment, environment-on-project, project-on-project); this is done by the multi-disciplinary study teams using the screening matrix (Figure 2) and detailed IEC list (Table 5.1).
  • Establish the spatial and temporal boundaries that the assessment of each impact will include. Temporal bounds are usually closely related to the causative activity (when will the activity occur, how long will it last). Spatial bounds must include all impacted areas and communities. Particular care should be taken in bounding so as to include impacts on areas outside the nominal project area.
  • Characterize (investigate and then quantify or rate) each impact.
  • Devise project-specific environmental management activities required to ensure that the project is implemented in an environmentally sound manner. These can include mitigation, compensation, monitoring, contingency implementation-phase public participation, accountability and reporting, and institutional strengthening and training measures and recommendations.
  • Iterate through the above steps to enhance positive impacts and mitigate adverse impacts (`anticipatory planning').
  • Prepare the IEE document for each project.
Finally, for the Plan as a whole,
  • Prepare the Plan IEE document, including an analysis of the sustainability of Plan activities and impacts, in the context of the total developmental environment.
Identification of project activities, IECs, interactions between them (project-on-environment impacts), environment-on-project impacts, and cumulative impacts was initially exhaustive rather than selective. Thereafter, estimates of quantity and quality of impacts, periodically updated, were used to focus and refocus assessment efforts on the most important impacts. Impacts whose relevance or magnitude remained uncertain were carried forward rather than dropped.

1.6  LIMITATIONS

This is an IEE, not an EIA, and thus important limitations are the depth of study, the dependence on secondary information, and the restriction of environmental management planning to identification of issues and options only. These limitations should be dealt with as the FAP and individual Plan projects move forward.

Another limitation is that the IEE was prepared by the same team as that responsible for the Regional Plan. On the one hand, the planning team can make use of the in-depth understanding which has been developed during the planning period; on the other, it can be argued that an independent team would provide a fresh perspective and greater objectivity, and thus would be more able to identify possible adverse impacts and other problems.

1.7  IEE REVIEW PROCESS

The latter limitation mentioned above can in part be addressed by full and thorough review of the Regional Plan and IEE.

The Regional Plan has been accepted by FPCO contingent upon acceptance of this IEE. EIA/IEE review procedures for FAP projects are outlined in the Guidelines for Environmental Impact Assessment (FPCO and MOI, 1992):

"Project reports should be submitted jointly [study plus EIA/IEE] and should be subjected to three separate reviews by:
  • Local government agencies, community groups, and NGOs operating in the project area;
  • A Project Review Committee comprising representatives from MOI, other concerned ministries, knowledgeable NGOs working and selected professionals/academics, and
  • The Department of Environment which is the final authority to review and approve EIAs and for giving environmental clearance to all projects in Bangladesh."
The Regional Plans and their IEEs are subjected only to the latter two levels of review; the local review applies to project-level EIA/IEE reports. The Guidelines go on to provide additional details regarding this process (pp. 37-8).

1.8  REPORT STRUCTURE

The organization of this report is derived from an outline presented in the Manual for Impact Assessment (FAP 16, 1992). The major sections are:
 
Chapter  2, Regional Plan Alternatives
Chapter 3, Regional Plan Description
Chapter 4, Description of Existing Environment
Chapter 5, Scoping -- Public Consultation and Identification of Important Environmental Components
Chapter 6, Overview of Key Biophysical Response and Impact Processes
Chapter 7, Assessment Methodologies, Data Sources, Assumptions, and Information Deficiencies
Chapter 8, Assessment of Future-Without-Plan Scenario
Chapter 9, Assessment of Regional Plan Impacts
Chapter 10, Cumulative Impacts and Sustainability Analysis
Chapter 11, Environmental Management Plan (EMP)
References, and
Annex A, Figures.

1.9  GENERAL REMARKS

FCD projects profoundly alter the spatial and temporal distribution of water and have a recognized potential to produce both significant beneficial and adverse impacts across the range of water-linked systems. By contrast, the non-FCD projects in the portfolio have very limited potential for adverse impacts. Indeed, almost all of them are targeted to benefit either specific environmental systems that tend to be adversely affected by FCD development, or to enhance environmental quality directly, through non-structural or localized minor structural means.

Thus, to ensure that the most fundamental purpose of IEE is achieved, which is to identify and characterize all potentially significant adverse impacts, this document concentrates on the FCD projects.

This preoccupation with FCD, a necessary characteristic of the IEE, is not shared by the Plan itself.

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