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



Scoping is the process by which the important environmental issues, project alternatives, and important environmental components are identified by the interested parties (p. 6-4, Manual for Environmental Impact Assessment; FAP 16, 1992). It is an early step of environmental assessment which is designed specifically for public involvement. Public consultation, in addition to providing access by the public to the assessment process, is also intended to create the opportunity for a two-way information exchange between the project team and interested parties outside it (p. 3-10).


5.2.1 Introduction
The preparation of the Northeast Regional Water Management Plan is an initial phase in a longer term development process that aims to improve the region's water management systems and infrastructure, and to ensure that they are responsive to the needs of the region's people. The regional water management plan process was carried through pre-feasibility analysis of the various identified initiatives. Subsequent phases of this process will include inter alia feasibility level analysis, detailed design, implementation, and operation and maintenance of water management projects.

In this context, the goal of the public consultation undertaken during the regional planning exercise was to lay the foundation for an ongoing dialogue between the public and the technical and policy-making entities involved in water development planning. The elements of this foundation are:

Obtain local knowledge and ideas relating to the development of the project plan;

Provide local people with the opportunity to have a voice in the exploration, planning, implementation, monitoring, and evaluation of the projects;

Involve people in assessing likely project impacts and in anticipating unexpected outcome or side-effects;

Uncover potential social conflicts arising from the project interventions early and gauge the likelihood of satisfactory resolution through negotiation; and,

Identify a framework for appropriate institutions and procedures to enable local people to participate in the planning, construction, operation, and maintenance phases of the project.

The consultation process involved interaction with regional water management stake holders at various levels and included: case studies, public seminars, FAP interim conferences, informal field meetings between multi-disciplinary teams and residents, and specialist seminars. These are described in the following paragraphs. In addition, NERP planning took into consideration the results of the National Conservation Strategy, National Environment Management Action Plan, and the Forestry Master Plan, each of which had its own public consultation inputs and ran concurrently with NERP.

5.2.2 Case Studies
Social Anthropology
The first level of interaction was through four detailed social anthropology case studies, each in a different agro-ecological zone; two of which were conducted within the boundaries of existing water management projects, and two of which were conducted in areas not directly associated with any infrastructure. This exercise involved placing a team composed of approximately half male and half female researchers within the area under study for a period of three months at each location. The researchers worked to a certain extent with structured survey instruments, but the primary intent was that informal relationships be established within the communities in which they were involved. Through these relationships, the complex interactions among the various groups were examined and analyzed in an effort to better understand how people interacted with their immediate physical environment and what was considered of highest priority in terms of attempting modifications to this environment. This intensive level of interaction involved between 300 and 500 people at each study location. Because of the gender composition of the research teams, women constituted about one-half of the constituents with whom the research team interacted. Other major (and sometimes overlapping) categories of constituents included landless persons, farmers, and fishermen.
Wetland Resource Utilization and Management
As input to the Wetland Resources Specialist Study, village-level case studies of wetland resource utilization and management were carried out over a period of three months at six sites in three of the key wetlands, by a team of three female and four male field workers.
5.2.3 Public Seminars
The second level of interaction was through a series of seven public seminars organized in the major communities within the region. While these were open to the general public, invitations were issued to community leaders and representatives of special interest groups. For each community these included: the members of Parliament, deputy commissioners, officials from the various government and semi-government agencies with offices in the community, thana nirbahi officers, chairmen of farmer cooperatives, union parishad chairmen, the press, teachers, and NGO representatives. On average, about 150 persons were invited to each of the public seminars; actual attendance ranged from 200 to 300 persons at each.

In preparation for each meeting, a technical brief was prepared and circulated in both English and Bangla, along with formal letters of invitation. Each meeting had a duration of one day (about seven hours). Following a short inaugural session, the study team would present, based on the technical analysis, what they considered priority intervention points in local surface water systems. Each of the members of Parliament then formally responded to these suggestions and in many cases countered with other suggestions. This was followed by an open discussion session. Following a break for lunch, the plenary would be divided into four or five small groups and these smaller groups would undertake a more detailed discussion on various aspects of the problems and solutions which had been defined in the earlier sessions. This was followed by a session in which the representatives of the small groups reported back to the plenary.

The sessions were mainly conducted in Bangla. In all cases, the sessions were audio-taped (in some cases they were also videotaped) and the audiotapes were transcribed and published in a series of proceedings. Prior to finalizing the proceedings, drafts were circulated back to the key speakers to ensure that the proceedings accurately reflected the discussions. Copies of the proceedings were then made available to participants.

5.2.4 FAP Interim Conferences
The third level of public consultation occurred in the context of two interim conferences which were organized by the Flood Plan Coordination Organization and held in Dhaka. Each had a duration of about five days and were conducted to allow interaction among interested members of the national and international community with an interest in the issues surrounding the Flood Action Plan. Conference participants included the prime minister, ministers, members of Parliament, senior representatives from the various governments and funding agencies actively involved in the Flood Action Plan, representatives from the international and national NGO community, representatives from various government agencies directly and indirectly associated with the Flood Action Plan, the press, and independent scholars and professionals.

Each forum consisted of presentations followed by a question period; different topics were covered each year. The proceedings of these conferences were audio-taped, transcribed, and copies made available to conference participants.

5.2.5 Informal Meetings
The concerns identified in the more formal consultations described above (and in other ways) were followed up at the pre-feasibility study stage through informal personal interviews, group discussions and meetings with various cross sections of people. These discussions were undertaken by the pre-feasibility study multi-disciplinary teams, which were composed of a mix of water resource planners, sociologists, fisheries specialists, river engineers, agriculturalists, and environmental scientists. A significant amount of their time in the field was spent in dialogue with local residents. These discussions formed the basis for the intervention concepts for each of the initiatives. The meetings took place in villages, farmers fields, fishermen communities throughout the impacted area. A decided advantage of this approach was that immediate physical verification of information was often possible.

Some of the specialist study field investigations, in particular the fisheries, wetland resources, and existing water resources development studies, also made significant use of informal meetings, in the field with local residents and with other interested parties, to gather information and identify issues.

5.2.6 Specialist Seminars
Fisheries Seminar
A seminar was organized with an explicit focus on (and participation by representatives of) the community who either earn their livelihood directly or indirectly from open water capture fisheries or who had a strong and vested interest in the sector. The general format of this meeting was similar to that of the public hearings. As with the public hearings, discussions were documented, proceedings were published and made available to interested persons or groups. An estimated 200 people attended this seminar which was held in Sylhet.
Aquatic Wastewater Treatment Seminar
A half-day seminar on aquatic wastewater was organized in early 1993, which was attended by about 20 representatives of government agencies and NGOs.
Seminar on Biodiversity, Wetlands, and Surface Water Quality of the Northeast Region
This seminar in April 1994 was organized to present NERP's findings and recommendations in these areas to the policy-making and technical community for their information and comments. The meeting was attended by about 150 persons, including the Minister of Irrigation and the Minister of Environment and Forests, other government officials, NGO and donor representatives, and others.


Through the process described above, there were a number of common themes which emerged in relation to water management requirements. These are summarized below.
Prevent crop damage resulting from flooding and drainage congestion
Damage occurs mainly to boro, aus and b aman rice due to flash floods in the pre-monsoon season and to aman rice due to monsoon flooding. The effect of the floods is further aggravated by inadequate drainage of localized rainfall and slow drainage in the post-monsoon season. The latter inhibits production of rabi crops and delays transplanting boro seedlings exposing the crop to damage from early flash floods. Where farmers are unable to transplant boro seedlings by the end of January because of poor drainage, the land remains fallow throughout the year.
Reduce silting of rivers and beels
Rivers and channels are losing their conveyance capacity as they infill with sediment. In addition to inhibiting drainage, this restrict fish migration and hampers navigation. In some hydraulic regimes, this phenomena results in rivers or channels avulsing and considerable damage is caused as the river assumes a new course. Beel siltation reduces the volume and area of dry season aquatic habitat, and has effectively converted some beels from a permanent wetland status to a seasonal status. This loss of habitat negatively affects fish production. Agricultural production is also negatively impacted in these areas since farmers, because of a shortage of water for irrigation, are compelled to shift from boro which potentially has high yields to b aman which produces lower yields.
Control sand deposition on cultivated land
Sand deposition on agricultural land which occurs during flash floods, destroys standing crops and negatively impacts on soil fertility. The end result is that the affected land is no longer suitable for crop production.
Recognize the importance of navigation
Concern was repeatedly expressed that boat transportation between the haors and the rivers was being disrupted at critical points. A major cause of this included past embankments which were constructed without regard for navigation. To accommodate the need for navigation, embankments are frequently cut but this can have adverse impacts on other production sectors. The need to improve and maintain river transportation along the alluvial fans was also regarded as a high priority.
Improve openwater fisheries management
Poor fishermen have been badly affected by their exclusion from open water fishing which is imposed by powerful jalmohal lease-holders who are frequently not part of the local community. It has generally been found that local fishermen will ensure the sustainability of a local resource and that the system should afford some preference to local lease-holders. Fishermen considered that de-watering of jalmohals was one of the major causes of long term declining trends in fish production.
Provide treatment for industrial effluent
Fishermen expressed concern that the industrial effluent being dumped into the Surma River at Chhatak by the Sylhet Pulp and Paper Mill and into the Kushiyara River at Fenchuganj by the fertilizer factory(2) is affecting their livelihood. Introduction of these chemicals into the river system is killing fish or rendering them unfit for human consumption.
Assist in protecting homesteads from wave action
Damage to homesteads by monsoon season wave action was reported as a major problem, particularly in the deeply flooded area. Many villages in deeply flooded areas are eroding rapidly.
Reduce disruption of fish migratory routes
Indiscriminate road construction was identified as disrupting the natural drainage system and obstructing fish movement. Closures and embankments were also identified as being responsible for disrupting fish migratory routes. This is contributing to declining fish production.
Introduce measures to conserve wetlands
The need for conserving the remaining wetlands and fish sanctuaries were highlighted by the local people.


As described above, water management problems and potential remedial interventions were broadly discussed at the more formal public hearings. Intervention concepts were then refined based on a combination of technical analysis and field investigations, including dialogue organized on an informal basis with individuals or community groups.

The results of these discussions were reflected in each of the pre-feasibility studies prepared around the various intervention concepts as part of the regional planning process. These were distributed to community representatives for their information. Public concerns were integrated into intervention concepts in numerous ways, some novel for Bangladesh.

To protect crops from flooding and drainage congestion, structural and non-structural measures are used, often in combination depending on the situation in each location. Structural measures include water control structures, dwarf embankments, bottom-open embankments, high embankments, re-excavation of rivers and khals. Non-structural measures include improved flood forecasting and warning, flood proofing, and institutional strengthening. Given that structural measures introduce negative as well as positive impacts, these are suggested only in circumstances where they are considered essential. Bottom-open embankments are generally a preferred option since they protect crops from upstream early monsoon flooding with minimal disruption to navigation and fish. Structural measures are designed to reduce silting in beels and to protect cultivated areas from sand deposition. Fish pass structures are proposed on a pilot basis to reduce the disruption to migratory fish. If successful, these could become an integral part of many existing and new structural initiatives.

Mechanical dredging of rivers and manual re-excavation of rivers and khals was suggested in places where these were considered to be beneficial. The dredging and channel re-excavation would make a substantial contribution to improved drainage and improved navigability in the region, but would need to be carried out in concert with other structural measures such as embankments and river training works to be fully effective. Utilization of dredged material could be used to construct embankments or to raise village platforms. Lowland afforestation has been identified as a means to reduce erosion of village platforms. This would improve fisheries habitat leading to increased fish production.

The Regional Plan includes several initiatives that are expected to increase fish production. The objective of the Fisheries Management Programme is to improve biological management of the floodplain fishery through direct interventions in fisheries habitats and indirectly through assistance to New Fisheries Management Policy (NFMP) fishermen associations leading to improvements in management of community fisheries. Fisheries Engineering Measures would maintain or re-establish migration routes by providing fish pass structures in embankments; and protect selected beels from sedimentation and increase beel water by constructing protective embankments. Pond Aquaculture is expected to increase fish production through concentrated and highly supervised demonstration ponds, and to improve the socio-economic situation of small and landless farmers.

The Northeast Region Environment Management, Research, and Education Project (NEMREP) includes several initiatives aimed at biodiversity protection, surface water quality management, including institutional issues in these two areas. The concerns expressed in respect of conservation of key wetland sites and pollution from industrial effluent are addressed through these initiatives. The biodiversity initiatives include restoration and improved management of key habitats, reflecting the close relationship between biodiversity and forestry.


IECs are simply those components of the biophysical or socioeconomic environment of importance to one or more of the interested parties (including future interested parties who cannot participate in the scoping) that could be impacted by the proposed intervention.

Impacts of a proposed intervention on the total set of IECs are typically represented using a subset of selected IECs, chosen such that the range of important effects will be captured. The use of such a subset allows an impact assessment to be more focused and manageable for both its preparers and audience. Particularly useful types of IECs include those which function as indicators for a number of other components, species, or characteristics (including surrogate measurements), those key to systemic structures or functions, and those related to rare, endangered, sensitive, unique or other biophysical or socioeconomic (including ecological, cultural, aesthetic, scientific, and biodiversity) assets (p. 3-9, Manual for Environmental Impact Assessment; FAP 16, 1992).

A preliminary set of IECs, grouped under ten major headings, was defined for use in the FCD pre-feasibility studies; these are listed in Table 5.1. The major groups appear as the column headings in the environmental screening matrix used by the pre-feasibility study teams (Figure 2). IECs were added to this core set as the need arose in individual project studies and in assessing the Plan.

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