National Environment Policy: Promises need to follow with action

The Ministry of Environment and Forestry (MoEF) of the Government of Bangladesh (GoB) has published the Draft National Environment Policy (NEP) 2013 on their webpage and solicited public opinion. The constitution of Bangladesh recognises general public as the sole source of power, and clearly puts them in charge of all natural resources in the country. The 15^th amendment to the constitution pledged to protect and develop all aspects of the environment for current and future generations, and assured to conserve and sustain natural resources, biodiversity, wetlands, forests, and animals. If a government puts its mouth where the money is, then this constitutional guarantee can go a long way in preserving and developing all aspects of the environment in a sustainable manner. The draft NEP 2013 is a revision of the NEP 1992 in the context of the new reality of climate change. The NEP 2013 also outlines a more up to date understanding of the extent and magnitude of environmental degradation that has become a fact of life in the world in general, and in Bangladesh in particular. The NEP 2013 outlines the problems of population growth, poverty, illiteracy, lack of awareness and healthcare services, limitation of arable land, unplanned development and urbanisation, and industrialisation as the major impediments to the conservation of the environment.

However, putting all impediments in the same category actually camouflages the relative contribution of individual factors. For example, although poverty, lack of awareness, and illiteracy definitely contribute to environmental degradation, it is the unplanned urbanisation, uncontrolled industrial effluent, both at domestic and global scale, are dominant drivers of environmental degradation. More emphasis should be directed in controlling urban sewage and storm water run-off;  industrial discharges without being treated by effluent treatment plants;  unplanned development of roads, housing complexes, polders in coastal areas, flood control structures that fringes upon the wetlands and ecosystems;  land grabbing and encroachment on flood flow zone; degradation of  the quality of soil by application of excessive fertilizers and pesticides; overdraft of groundwater in major cities;  and indiscriminate disposal of solid waste.

In addition to domestic challenges in protecting the environment, Bangladesh also faces serious threats to her survival from sources outside of the border. The menace of climate change is already a ground reality in many spheres of life, including increased flooding, drought, storm surges, water-logging, salinity intrusion, crops damage, depletion of drinking water, problems with sanitation, and challenges to meet the food security. With large-scale inundation of coastal Bangladesh due to continuing rise in sea level, and likely displacement of huge population, Bangladesh confronts an impending mega-disaster. A large area of Bangladesh belongs to floodplain and coastal plain, which were built by deposition of river-borne sediments over thousands of years.  However, upstream control of water and sediment influx to the coastal areas of Bangladesh is proving to be formidable for well-being of natural environment and ecosystems in coastal areas in keeping pace with the rising sea level. A key determinant of coastal wetland and mangrove forests vulnerability is whether the land surface elevation can keep pace with sea level rise. Since the source of the surface  water and sediments that act as the lifeline for Bangladesh lies outside of the territory of the country, special efforts need to be directed in achieving treaties and agreement with all co-riparian nations in the Ganges-Brahmaputra-Meghna (GBM) Basins. Without a guarantee of natural flow of water and sediments to floodplain and coastal plains, the country will face a long-term vulnerability to the environment, ecosystems, biodiversity, agriculture, navigation, drinking water supply, sanitation, and overall survival of the country.  The draft NEP 2013 correctly emphasizes the threat of climate change to agriculture, water resources, public health, biodiversity, and infrastructure; however, it falls short in identifying the importance of guaranteeing the natural flow of surface water and sediments from upper reaches. The NEP 2013 alerts about the danger of recent flow-reduction in upper catchment areas (section 3.2.2), and expresses a desire to restructure water development plan in the country.  Bangladesh being at the receiving end of the GBM basins has limitations in terms of negotiation powers for her fair share in natural flow of rivers.  Nevertheless, GoB needs to make water diplomacy her top priority in dealing with her co-riparian neighbours.  If necessary, Bangladesh needs to involve international organisations in achieving fair share of water and sediments from upper catchment areas in the GBM basins.  In addition to the NEP 2013, the GoB  has addressed the issues of environmental degradation and  adverse impacts of climate change in national policies pertinent to agriculture, landuse, forestry, industry, sustainable development strategy, and five-year planning.  As a measure to adapt to the current reality of climate change, the GoB has developed Bangladesh Climate Change Strategy and Action Plan (BCCSAP) in 2009.  The BCCSAP places tremendous emphasis on structural solutions to climate change that include building and repairing of coastal polders, which in turn reduce natural tidal flow and sedimentation to coastal plain that located behind those structures. Coastal polders provide a false sense of security to people living in the low lying areas.

The NEP 2013 is riddled with empty promises, redundancies and repetitions of concepts.  For example, several clause in the section that lists main considerations for the NEP, repeatedly reiterates the need for sustainable development of natural resources and the protection of the environment.   The NEP 2013 also emphasizes on the need to make the "Polluters Pay Principles" and to adopt the "3R:  Recycle-Reduce-Reuse" in all spheres of life.  However, the GoB has hardly ever set any precedence in these regards in their planning and decision making in the country.  For example, the industrial polluters continue to degrade the rivers in and around Dhaka City without encountering penalties or fines imposed by the authority.  The NEP 2013 also promises to carry out assessment of effectiveness and adverse impacts of already implemented projects to manage floods, drainage, and irrigation in the country.  Despite the construction of 123 polders and 1000s of miles of flood control embankments in the country, the flooding intensity, magnitude, and frequency have increased in recent decades.  The NEP 2013 also promises to keep the rivers, creeks, wetlands free from pollution, yet most of the surface water bodies remain highly polluted.  The document emphasizes the need for increasing the uses of surface water in the place of groundwater in agriculture, industry, and drinking water; however, surface water becomes very scarce in major rivers during lean season, and is rendered unusable due to pollution.

In summary, the NEP 2013 is a timely revision of the old policy in the context of new reality of the climate change. It recognises the significance for managing all aspects of the environment in a sustainable manner; however, the policy falls short in making a commitment by the government to ensure the quality of the environment for various beneficial uses. It is hoped that the draft NEP 2013 will be revised to address the shortcomings, and that the promises outlined in the document will be followed with action.

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Md. Khalequzzaman is a Professor of Geology at Lock Haven University, USA.