Dhaka Metropolitan Development Plan Strategic Environmental Assessment

Public Disclosure Authorized
75062
FINAL REPORT
DHAKA METROPOLITAN DEVELOPMENT PLAN

STRATEGIC ENVIRONMENTAL ASSESSMENT
Prepared for:
The World Bank

Washington, DC
Prepared by:
SENES Consultants Limited

In association with
Techno Consult International Limited

Dhaka Bangladesh
July 2007
Printed on Recycled Paper Containing Post-Consumer Fibre

Dhaka-Strategic Environmental Assessment
TABLE OF CONTENTS
Page No.
EXECUTIVE SUMMARY....................................................................................... 1
1.0 INTRODUCTION ....................................................................................... 1-1
1.1 Rationale for the Strategic Assessment Study......................................................1-1
1.2 Objectives of the Study ........................................................................................1-3
1.3 Approach and Methodology of SEA....................................................................1-3
1.3.1 Analytical Component..............................................................................1-5
1.3.2 Participatory Component..........................................................................1-6
1.4 Output and Dissemination....................................................................................1-7
1.5 Report Structure ...................................................................................................1-8
2.0 SITUATION ANALYSIS OF DHAKA’S ENVIRONMENT.................... 2-1

2.1 Urbanization In Dhaka .........................................................................................2-1
2.2 Land-use and Land Management .........................................................................2-6
2.2.1 Housing, Slums & Open Spaces ..............................................................2-6
2.2.2 Industries ..................................................................................................2-9
2.2.3 Roads & Transportation .........................................................................2-10
2.2.4 Solid Waste ............................................................................................2-12
2.3 Water Resources and Quality.............................................................................2-13
2.3.1 Water Resources.....................................................................................2-13
2.3.2 Water Pollution ......................................................................................2-14
2.4 Air and Noise Quality ........................................................................................2-16
2.5 Flooding and Drainage .......................................................................................2-18
2.5.1 Illegal Filling of low lying areas ............................................................2-13
2.5.2 Illegal Filling of ditches and drainage channels.....................................2-14
2.5.3 Potential Climate Change Impacts on Dhaka.........................................2-14
2.6 Formulation of Environmental Priorities .........................................................2-222
3.0 URBAN PLANNING IN DHAKA ............................................................. 3-1

3.1 Overall Planning Process in Dhaka......................................................................3-1
3.1.1 Policy Guidance .......................................................................................3-1
3.1.2 High level Planning Focus .......................................................................3-2
3.1.3 Urban Planning for Dhaka........................................................................3-2
3.2 Regional Plans – Structure Plan & Urban Area Plan ...........................................3-5
3.2.1 Detailed Area Plans..................................................................................3-6
3.3 Sectoral Planning..................................................................................................3-7
3.3.1 Water Supply............................................................................................3-8
3.3.2 Sewerage and Sanitation ..........................................................................3-8
3.3.3 Drainage and Flood Protection ............…………… ………………… 3-10
3.3.4 Transportation ........................................................................................3-11
3.3.5 Solid Waste Management.......................................................................3-11
3.3.6 Industrialization......................................................................................3-12
3.3.7 Housing and Slum Improvement............................................................3-13
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3.4 Institutional Set up for Governance & Urban Planning .....................................3-14

3.4.1 RAJUK – An Institutional Analysis.......................................................3-17
3.5 Analyzing Stakeholder Influence in Planning & Plan Implementation Process 3-21
3.6 Analysis of Planning Framework in Context of Environmental Priorities ........3-24
3.6.1 High urban densification in certain areas ...............................................3-24
3.6.2 Surface water pollution due to discharge of untreated sewage &
effluent ...................................................................................................3-25
3.6.3 Depletion of groundwater.......................................................................3-27
3.6.4 Increasing vulnerability of floods ..........................................................3-27
4.0 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK.......... 4-1

4.1 Land and Land use Management .........................................................................4-1
4.2 Water Resources and Quality...............................................................................4-2
4.2.1 Depletion of Groundwater........................................................................4-2
4.2.2 Surface water pollution ............................................................................4-3
4.3 Flooding and Drainage .........................................................................................4-6
4.3.1 Increasing Vulnerability to Floods...........................................................4-6
5.0 SEA FINDINGS AND RECOMMENDATIONS ...................................... 5-1

5.1 Background ..........................................................................................................5-1
5.2 Summary of SEA Findings ……………………………………………………..5-2
5.3 Environmental Priorities that need to be addressed by DAP ..............................5-5
5.4 Recommendations ...............................................................................................5-7
APPENDIX A: Final Consultation Workshop Proceedings
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LIST OF TABLES
Page No.
2.1 Environmental Priorities in Dhaka.................................................................................2-24

3.1 DAP zones and categorization .........................................................................................3-5
LIST OF FIGURES
Page No.
2.1 Spatial Growth of Dhaka..................................................................................................2-2

2.2 Administrative Map of the DMDP Region ......................................................................2-4
2.3 Spatial Disposition of Development Zones......................................................................2-5
2.4 Air Pollution from Vehicles in Dhaka............................................................................2-16
2.5 Ranking Matrix for Stakeholder Perception...................................................................2-23
3.1 DMDP and DAP Planning Areas .....................................................................................3-4

3.2 Urban Governance and Flow of Authority.....................................................................3-15
3.3 Interaction between Planning Institutions ......................................................................3-16
3.4 Principal Agencies Related to Urban Planning in DMDP Region ................................3-17
3.5 RAJUK Organizational Structure...................................................................................3-19
3.6 Stakeholder Analysis Matrix..........................................................................................3-22
3.7 Proposed Flood Retention Ponds – FAP 8A ..................................................................3-29
3.8 Proposed Flood Retention Ponds –Structure Plan .........................................................3-30
3.9 Proposed Flood Retention Ponds –Eastern Bypass........................................................3-31
34445 –Final – Aug 2007 iii SENES Consultants Limited

ABBREVIATIONS
ADB Asian Development Bank
AQMP Air Quality Management Project
BLD Billion Liters per Day
BOD Biological Oxygen Demand
BUET Bangladesh University of Engineering & Technology
BWDB Bangladesh Water Development Board
BWTA Bangladesh Water Transport Authority
CETP Centralised Effluent Treatment Plant
COD Chemical Oxygen Demand
DAP Detailed Area Plan
DCC Dhaka City Corporation
DEPZ Dhaka Export Processing Zone
DIEWRMP Dhaka Integrated Environment and Water Resources Management Project
DITP Dhaka Integrated Transport Project
DMDP Dhaka Metropolitan Development Plan
DND Dhaka Narayanganj Demra
DOE Department of Environment
DMP Dhaka Metropolitan Police
DPHE Department of Public Health Engineering
DTCB Dhaka Transport Coordination Board
DUTP Dhaka Urban Transport Project
DWASA Dhaka Water and Sanitation Authority
ECA Environment Conservation Act
EPZ Export Processing Zone
FAP Flood Action Plan
GDP Gross Domestic Product
GoB Government of Bangladesh
HSD Housing and Settlement Directorate
IDA International Development Association
IGES Institute of Global Environmental Strategies
IPCC Intergovernmental Panel on Climate Change
IWM Institute of Water Modelling
JICA Japan International Cooperation Agency
JNURM Jawaharlal Nehru National Urban Renewal Mission
LGED Local Government Engineering Department
MLGRDC Ministry of Local Government, Rural Development and Co-operatives
MoW Ministry of Housing & Works
MSL Mean Sea Level
MSW Municipal Solid Waste
NWRC National Water Resource Council
PM2.5 Particulate Matter <2.5 Micron
PM10 Particulate Matter <10 micron
PSRP Poverty Strategic Reduction Strategy Paper
PWD Public Works Department
RAJUK Rajdhani Unnayan Katripakkha
REHAB Real Estate Housing Association of Bangladesh
RHD Road and Highways Department
RMG Readymade Garment Industry
SEA Strategic Environment Assessment
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SMPA Strategic Metropolitan Planning Authority

SPZ Special Planning Zones
STP Strategic Transport Plan
TMC Technical Management Committee
UDD Urban Development Directorate
UGI Urban Governance Index
UNDP United Nations Development Programme
UNCHS United Nations Centre for Human Settlement
WASA Water and Sanitation Authority
WARPO Water Resource Planning Organisation
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EXECUTIVE SUMMARY
1 RATIONALE FOR SEA STUDY
Dhaka is one of the ten mega-cities in the world. Growing at a very fast rate, the population of
Dhaka urban area is predicted to increase to about 21 million by 2015 from the current
population of 11.3 million. Dhaka’s rapid development, its fast-changing urban landscape and
the associated critical environmental challenges call for holistic urban planning, strengthening of
institutions responsible for urban development and good governance.
The rapid unplanned urbanization has raised two sets of environmental challenges in Dhaka:
♦ The first arises from urban development projects in different sectors and industries which
treat potential environmental effects as externalities and which only try to mitigate these
effects as an afterthought, not as an integral part of the project.
♦ The second stems from the acute pressure on natural resources resulting from the
indiscriminate use/misuse of these resources.
This given, a high-level Strategic Environmental Assessment (SEA) was proposed by the
Government of Bangladesh for the Dhaka Metropolitan Development Planning (DMDP) area
with the aim to:
♦ understanding the complex interactions between environmental, social, economic and

institutional factors linked to the urban planning and development of Dhaka;
♦ providing future guidance to the urban development process so that it incorporates both
urban planning and environmental priorities;
♦ providing strategic inputs to projects like the Dhaka Integrated Environment and Water
Resources Management Project (DIEWRMP) which is currently being scoped; and
♦ proposing a strategy by which environmental priorities could be incorporated in Detailed
Area Plans (DAPs) currently being executed.
The SEA was drawn up as a participative process involving extensive stakeholder consultations.
It provided a platform for dialogue between policy makers, planners, stakeholders and civil
society at large on environmental priorities; and on how and why these priorities could be
affected by the implementation of plans and policies (World Bank, 2005). The SEA findings will
enable the World Bank to conduct a policy dialogue with the Government of Bangladesh on
urban development issues in Dhaka.
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2 OBJECTIVES OF THE STUDY
The specific objectives of this SEA are to:
♦ recommend policies, institutional arrangements and governance conditions needed for

ensuring environmental sustainability of Dhaka’s urban development;
♦ provide overall direction to the DAP formulation and other sectoral projects; and
♦ ensure public participation and dialogue on urban development planning through a process of
extensive stakeholder consultations.
3 METHODOLOGY
One of the main objectives of this study is to assess the process of formulating the Detailed Area
Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the
environmental priorities identified by this study and the stakeholders could be incorporated in
these plans. As the SEA was being initiated, it became evident that the whole process of
preparing the DAPs was, from the start, handicapped by existing systemic shortcomings. Further,
it became evident that the current process of DAP preparation would not be able to deliver the
expected outcomes. The shortcomings identified were grouped under two headings:
1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated
urban planning framework. Additionally, there is a lack of any stated mechanisms for
coordinating with other sectoral agencies and their planning processes; and
2. Problems at the implementation level: these are a poorly informed plan preparation process,
inappropriate survey design and inadequate allocation of technical resources by RAJUK
(Rajdhani Unnayan Katripakkha).
In order to analyse and understand these shortcomings and to identify the environmental
priorities in the Dhaka metropolitan area, the following methodology was used. The analytical
component of the SEA was constituted of three areas of investigations:
1. An analysis of the key environmental problems in the DMDP area based on secondary
information available in various published studies and documents and an analysis of their
linkages to policies, legislation and plans.
2. An assessment of the adequacy of existing urban plans and the planning process at the
strategic level in order to make recommendations for improved planning and governance.
3. An assessment of the efficacy of the on-going DAP formulation process, review of the design
and technical planning capacity in RAJUK; and identification of the areas and needs in RAJUK
where interventions for capacity development would be beneficial to overall urban management.

The participatory component of the investigation, with inputs from all major stakeholders, helped
to prioritise the environmental concerns. It highlighted the areas of institutional failures in urban
and environmental planning and drew attention to issues of governance and the role of vested
interests.
4 FINDINGS
4.1 Shortcomings and Gaps at the Strategic Level
The Structure and Urban Area Plans do not provide any land use zoning principles which could
be applied to design subsequent development. There are contradictions and lack of clear
definitions. The Plans demarcate broad areas for future development but inherent
contradictions/loopholes have provided scope for manipulation and encroachment.
Guidelines have been provided in the Plans, but there are no directives for implementing them;
hence, the Guidelines have been ignored by the implementing agencies. The plans have become
dated and have limited relevance to resolving the present urban management problems.
The sectoral policies in the Structure Plan do not relate them to the urban planning aspects. Most
sectoral plans concentrate on finding local and short-term solutions to urban problems,
particularly within the DMDP. RAJUK by its constitution, however, has the power to coordinate
with the sectoral agencies whose plans affect the urban area. There has been a failure of
leadership. Further, the Structure and Area Plans do not contain any discussion on vertical and
horizontal transmission of the decision-making process and the decisions themselves.
Implementation of urban and regional plans needs considerable co-ordination and collective
design and decision-making by all agencies. There are no stated mechanisms for co-ordination or
any over-arching planning framework which would have enabled agencies to collaborate and co-
ordinate their plans. The result has been fractured, haphazard and environmentally unsustainable
urban spread and inadequate infrastructural development.
The strategic level plans did not tackle the problem of multiple administrative authorities within
the DMDP and how their developmental efforts could be managed at the regional level. Thus,
the overall problems noted above are exacerbated by the fact that DMDP is carved up into
smaller administrative units (municipalities and Pourashavas). Of concern is that piecemeal
planning and un-coordinated infrastructure development are taking place, often to the detriment
of long-term environmental sustainability.
The haphazard growth is further reinforced by the national funding mechanism for Annual
Development Programmes, which include urban projects. The projects are approved by the

relevant ministries or the Planning Commission on budgetary criteria. The outcome is that there
is limited urban overview of what is happening on the ground.
Urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic
approaches to development; multiplicity of agencies; collusive relations between government
agencies and vested interest groups; low levels of environmental awareness among sectoral and
local authority planners; and very limited effort to achieve real public good.
The five teams of DAP consultants appointed by RAJUK need additional guidelines for local
area plan formulation; increased information on framework for developing a coherent regional
approach; better mechanisms to coordinate the plans of adjoining local / sector authorities; and
support and coordination from RAJUK to deal with large sectoral organisations like DWASA or
with local authorities.
4.2 Plan Development and Implementation Problems
The problems at the implementation level relate to:
(i) Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened,
was gradually downgraded and to this day the Planning Department remains technically
understaffed. There has been no updating or enhancement of qualifications of the current
planners. Their notions of urban planning are techno-centric and dated, and complexities of
social planning do not sit easily in their thinking. In fact they were ill-equipped to design the
DAP preparation process. Consequently, the Terms of Reference are over-ambitious. The
technical resources allocated are inadequate and dated.
Moreover, the planners have not provided any guidelines to the consultants for demarcation of
environmentally-sensitive areas where urban development should be restricted. These include
wetlands, flood flow zones, retention ponds, canals and natural drainage channels. There is thus
the danger that the DAPs could further exacerbate the problems of urban environmental
management.
In the absence of any directives, and reflecting the generally low environmental awareness, the
DAP consultants appear to have limited understanding of the pollution-intensive nature of
industrial growth in the watershed which is greatly responsible for the degradation of the water
resources. Consequently, there is little appreciation of the need for spatial zoning of industries
which should be done in consultation with industry.
Of greater concern is that the DAP preparation is not guided by any strategic level planning
framework. This means that the five groups of consultants are each contained within their own

zones, rather than within a regional approach. This means that piecemeal development will be
continue even under the new plans.
(ii) Challenge for DAP consultants: In view of the complexities involved in formulating the
DAPs, the SEA team concludes that the local consultants selected for this purpose do not appear
to have comprehensive technical capability or the experience to complete the terms of reference.
(iii) Poor leadership of the Technical Committee: The DAP planning process was found to
have a very weak interface with the sectoral planning agencies and, as a result, is unlikely to
produce plans that can be integrated with the sectoral strategies and plans. This is because:
(a) the Technical Management Committee which is charged to oversee plan preparation has been
ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared; and (b) the
DAP consultants have also been unable to establish useful contacts with sectoral agencies to
address the sectoral issues of the local level plans.
4.3 Environmental Priorities that Need to be Addressed by DAP
The importance of getting the DAP planning process right is underscored by serious
environmental problems already affecting Dhaka and its surrounds. The environmental priorities
as identified by this study are given below.
4.3.1 Land and Land use Management
(i) Increasing overcrowding in the already developed areas: The growth within the already
developed areas has taken place in a random manner, sometimes in contravention of existing
development control legislation or by using loopholes in the legislation. As a result, land
resources within the city have been put under stress, wetlands within the city have become filled
up and drainage channels have been obstructed in favour of unplanned development. This
skewed development pattern has put the urban services under severe stress resulting in
significant strain on environmental resources.
(ii) Unplanned development in fringe areas and encroachment: With decreasing scope for inner
city growth, large areas in the environmentally sensitive fringe zone are being targeted as they
have been marked for development in the Structure Plan. Such areas have also seen an increase
in land prices as a result of speculation and land grabbing, making it difficult to accommodate
poor and vulnerable sections of the society in these areas. Indiscriminate land-filling is already
leading to loss of natural drainage channels and sink areas that increase the vulnerability to
flooding.

4.3.2 Water Resources and Quality
(i) Surface water pollution: The river systems and the water bodies in the Dhaka Watershed are
so contaminated by discharge of industrial effluents and untreated sewage that it cannot be
treated to potable standards. The role of the DAP lies in initiating a dialogue with industry and a
process to identify locations for future industries.
(ii) Reliance on and depletion of groundwater: As surface water cannot be used to supply
drinking water, DWASA has become increasingly reliant on abstracting groundwater. As the
supply is unable to meet the growing demand, there has been an increase in number of privately
owned tube wells. Local authorities outside DWASA area are also dependent on groundwater.
Continued abstraction over a long period could lead to contamination of groundwater. RAJUK
and DAP have no say in DWASA’s Master Plan. Furthermore, DWASA has made no provisions
in its plan to supply the slums areas.
4.3.3 Inadequate Sanitation and Sewage Network
At present the sewage network infrastructure being planned by DWASA only takes into account
the existing urbanised areas. There are no systematic plans to set up a network in the developing
and fringe areas which are marked for future development. In addition, the five new Sewage
Treatment Plants that are being proposed as part of DWASA’s Master Plan do not consider
additional sewage coming in from developing or fringe areas. As a result, with new areas
becoming urbanized, there will be continued discharge of untreated sewage resulting in
continued pollution of the surface water resources in and around the city.
The DAP preparation process could be used as an opportunity whereby a more comprehensive
network covering future growth areas could be designed if DWASA, RAJUK and DAP
consultants found a common platform.
4.3.4 Increasing Vulnerability to Floods
As far as the role of DAP preparation is concerned, the consultants would concentrate on their
respective areas for planning. It is unlikely that they would be able to formulate a composite
long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood
retention ponds, which are central to local area plans, would be difficult to undertake, given the
compartmentalised planning approach.

5 RECOMMENDATIONS
In keeping with the main objective of the study, the recommendations have focused on
improving the DAP planning process. These have been subsumed under two groups indicating
the urgency of action required.
5.1 Immediate Action
5.1.1 Develop DMDP Region Land Use Map and Demarcate and Publish Notification of
Ecologically/Environmentally Sensitive Areas
Loose planning guidelines and loopholes in the Structure and Urban Plans have allowed the
urban encroachment of environmentally sensitive areas which include flood flow zones, wetlands
and low-lying areas which act as sink for storm water runoff; natural drainage channels and
canals. The local area plans cannot progress unless these areas are clearly identified, demarcated
and notified. The proposals and plans on how this demarcation should take place already exist
with the responsible agencies and Boards.
To overcome this problem, the development of a DMDP Regional Land Use map should be a
priority. This map should clearly demarcate eco-sensitive areas and these should be notified
through a government gazette as a “no-development zone”. This action is required as a top
priority to ensure no more filling of wetlands, destruction of agricultural lands, and the continued
haphazard growth of the DMDP Region.
5.1.2 Resolve Conflict Arising From Multiple Functions of RAJUK
RAJUK has been very active in promoting and participating in the development of commercial
properties like shopping centres and malls. While these developments have been lucrative for
both RAJUK and the private developers, they have often overlooked the planning guidelines and
have encroached on environmentally sensitive areas. Clearly, there is conflict of interests
between RAJUK’s role as a promoter and its role as the principal agency for urban development.
To remove this conflict, to introduce sound urban planning and to enhance transparency in the
execution of its development functions, its role as a promoter needs to be re-assessed.
5.1.3 Strengthen the DAP Planning Process as there is Too Much at Risk
The planning process is incomplete; hence, there is still an opportunity to improve the process
and achieve some of the stated objectives. Real value addition to the process will take place if the
capacity for environmentally sustainable and socially sensitive planning is enhanced in RAJUK
as it is the lead agency.

Consultants with more appropriate competencies need to be appointed. Plan formulation needs a
team with better technical know-how, better understanding of the complexities of urban
planning, and which has a critical approach to project execution. The point is to build on the
work that has already been completed in the last two years.
One of the main problems faced by the present consultants is that they are unable to work with/
have access to, the sectoral agencies. The membership of the Technical Committee, who is
charged to provide the link, should be re-assessed for effectiveness and, if necessary, changed.
The modus operandi should be made more transparent and information on progress and
outcomes disseminated.
The leadership of RAJUK needs to be more active in the process. The inability of RAJUK to
play a leadership role in the past has led other agencies to take planning initiatives on their own
without any coordination with RAJUK. Constitutionally, it has considerable power but has rarely
used it for systematic urban management. RAJUK needs to re-direct its energy to facilitate the
work of its consultants with sectoral agencies and other local authorities. This will not be easy as
the latter are fairly antagonistic to RAJUK. It will therefore, be essential to enable and encourage
RAJUK to liase with other agencies and open doors for the DAP process.
The issues of slum area development and provision of low income housing are not being
addressed either by RAJUK or any of the other sectoral agencies. This means that land allocation
and infrastructure planning for these areas might not feature in local area plans. One of the
responsibilities of RAJUK is the provision and overview of low income housing. It will be
necessary to persuade RAJUK to execute its responsibilities.
5.1.4 Engaging Stakeholders in Urban Planning
Throughout this project it has been observed that political economy has played a huge part in the
haphazard development of the City of Dhaka. Further, the people with vested interests have been
hijacking the process of planning due to lack of transparency.
It is recommended that during the reform of the planning process including resolving the conflict
of mandate within RAJUK, a transplant process for engaging key stakeholders in the planning of
regional areas should be put in place.
• As pointed out in the workshop, the “ward committees” at the Pourashavas level have
been quite effective at engaging local community in local planning initiatives. Similar
initiatives are required at Dhaka and municipal level.

• Further, transparency can be achieved if the DMDP region landuse plan with demarcation
of ‘no development zones’ is notified and made available to the public. The public can
use this information and stop illegal development. Public can approach judiciary if
necessary to stop development in the no-development zone.
5.1.5 Bring Other Actors on Board
Crucial to the success of formulating local area plans is the participation of local authorities. An
entry point for dialogue with these authorities could be programmes for capacity building in
environmental planning and regional development. Thought needs to be given to what would be
the most efficacious way of doing this.
DWASA is one of the biggest players in the provision of urban infrastructure. There is currently
very little communication between the two organisations. It will be important to bring DWASA,
RAJUK and the DAP team to a common platform.
The flood management strategies expectedly have a regional approach. However, there are
measures which need to be put in place and actions taken at the local level to achieve overall
reduction in vulnerability to flooding. In order to incorporate such measures in DAPs, it will be
necessary for RAJUK, LGED and other principal organisations responsible for management of
water resources to work together to assist the DAP team.
5.2 Actions in Short/medium term
5.2.1 Develop Strategic Planning Directives for Urban Growth
The DAP formulation process will ultimately rely on a strategic planning framework to provide
the directives, tools and guidance. While the local area plans will be important working tools,
change will occur and new plans will have to be formed. This strategic framework would be a
point of reference for local authorities; for DAP consultants; and for future urban growth for the
stated period. It is recommended that the new framework be coherent, tight and address the
inadequacies of the past and current urban planning approaches and processes.
5.2.2 Funding Procedures for Local Development Projects
Development projects, which include urban project, initiated by local governments and local
level sectoral agencies, are funded by their ministries or sometimes the Planning Commission on
strictly budgetary criteria. There is no mechanism to appraise its environmental impact or the
sustainability of such projects. For long-term environmental sustainability, it will be important to

address this problem. However, mainstreaming environmental issues will be a pre-requisite to

initiating any systemic change.

1.0 INTRODUCTION
This section of the report establishes the basis for the SEA study. It also explains the objectives
and scope of the study and relates it to the future support for the Government of Bangladesh to
ensure sustainable urban development. The methodology adopted for the study and the rationale
behind it has also been highlighted.
1.1 RATIONALE FOR THE STRATEGIC ASSESSMENT STUDY
Dhaka is one of the 10 mega-cities in the world. Growing at a very fast rate, Dhaka’s urban
population is predicted to increase from 11.3 million today to about 21 million by 2015. In view
of Dhaka’s rapid development, changing urban landscape and critical environmental and
governance challenges, the need for institutional strengthening and requisite city planning is
becoming increasingly important.
Rapid urbanization has raised two sets of environmental challenges in Dhaka. The first arises
from specific urban development investments which treat potential environmental effects as
externalities. The second set of broad range of environmental issues stem from pressure on
water and land resources and indiscriminate use/misuse of these resources. The complex
interactions between environmental, social, economic and institutional factors linked to the urban
planning and development of Dhaka needed to be assessed in order to ensure that Dhaka’s
development follow a sustainable path. It was felt that a holistic urban planning approach that
incorporates environmental and sustainability priorities right from the local level can play a
significant role to reverse the degradation of the urban ecosystem of Greater Dhaka.
Consequently, a Strategic Environment Assessment (SEA) of the urban development plans that
focuses on key institutional planning issues — an “institution-centred” SEA (see Box 1.1) — and
one that incorporates the political economy dimension in the assessment was seen by the
Government of Bangladesh and RAJUK as adding value to the technically-oriented output of the
ongoing local level planning in the form of preparation of Detailed Area Plans (DAPs). The
understanding was that an institution-centred SEA would provide a platform for dialogue and
interaction between policy makers, planners, stakeholders and civil society at large on
environmental priorities and on how and why these priorities would be affected by the
implementation of plans and policies (World Bank, 2005) and thus formulating strategic actions
which can off set these adversities in the plans. The SEA study was launched on November 1,
2006 and is presently nearing completion.
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BOX 1.1 : INSTITUTION-CENTRED SEA
Strategic Environmental Assessment (SEA) describes “analytical and participatory approaches that aim to integrate
environmental considerations into policies, plans and programmes and evaluate their inter-linkages with economic
and social considerations.” Source: OECD (2006, p: 30)
As compared to project level EIA, SEA of a high level strategic decision making such as policies or development
plans requires understanding of institutional settings and associated “political economy” factors. In the context of
weak institutional and governance frameworks, powerful stakeholders and elites often capture policies and plans
for their benefit prevailing over other vulnerable stakeholders. An “institution-centred” SEA is a response for
environmental assessment of strategic decision making processes heavily influenced by political and institutional
factors. The Bank is currently testing and validating this approach through its pilot program on SEA and Dhaka
MDP SEA is a pilot.
The following key questions have guided the SEA team in assessing the institutional capacity to manage
environmental priorities:
• Are existing planning processes adequate for the formulation of environmentally sound spatial and urban
development plans? and,
• Why these plans do not get fully implemented or why they undergo changes during implementation?
There have been several other factors that lead to recognizing the need for conceptualizing a
Strategic Environmental Assessment of the Dhaka Metropolitan Development Plans (DMDP).
They are described below:
• RAJUK1, the Dhaka capital development authority, had commissioned five Detailed Area
Plans (DAPs) for preparation and delineation of local level urban plans. However, it was
felt that an umbrella environmental framework was required to assist in the planning
process, in integrating the environmental and stakeholder concerns and other regional and
sectoral plans in the DAPs
• The World Bank is developing the Dhaka Integrated Environment and Water Resources
Management Project (DIEWRMP) which looks at the opportunity to address urban
planning issues incorporating environmental and social dimensions to improve the quality
of life of people in Dhaka. However, the program has limited scope to address the overall
urban planning issues.
• The agencies responsible for delivering the urban services feel that the institutional
weaknesses and other political economy constraints were a major impediment in the
implementation of plans, thus resulting in adverse impacts on the environment.
1
RAJUK was established in 1987. It is the development authority for Dhaka covering an area of 1528 sq Km. The present
jurisdiction of RAJUK includes three districts (Dhaka, Narayanganj and Gazipur), five municipalities (Pourashavas of Savar,
Kadamrasul, Narayanganj, Tongand Gazipur) and the Dhaka City Corporation Area.

Therefore, RAJUK, a body setup under the aegis of the Ministry of Housing and Urban
Planning, evinced their interest in an institution-centred SEA for the DAPs.
1.2 OBJECTIVES OF THE STUDY
The SEA is a decision making tool being used for the first time by the Government of
Bangladesh (RAJUK and Ministry of Housing and Urban Planning) to strategize and provide
direction to the preparation and implementation of the DAPs. It is also a key policy instrument
which will enable the World Bank to conduct a focused policy dialogue, provide
recommendations for institutional strengthening and address political economy governance
concerns in the context of the implementation of DAPs in the Dhaka Metropolis.
The specific objectives of the SEA are to:
• recommend policies, institutional arrangements and governance conditions needed for

ensuring environmental sustainability of Dhaka’s urban development;
• provide overall direction to the DAPs for the formulation of mitigation measures of
environmental risks associated with urban development in Dhaka;
• provide inputs for the project preparation of the DIEWRMP; and
• ensure public participation and dialogue on urban development planning through a
process of wide stakeholder consultations, including weaker and vulnerable stakeholders.
The principal audience of this SEA is the Government of Bangladesh and RAJUK which will
benefit from strategic planning directions emerging from the study and the working out of an
overall environmental management framework which takes into account the environmental
opportunities and constraints within which the DAPs may be prepared and implemented. Other
Government agencies (Department of Environment, Ministry of Housing and Urban Planning),
sectoral agencies (DWASA, BWDB, etc.) and local government bodies (Dhaka City
Corporation, Pourashavas) will benefit by developing a better appreciation of the environmental
challenges and opportunities associated with the implementation of various level urban plans.
The SEA was developed as a strategic decision-aiding instrument for planners, decision makers
and stakeholders to enable them to take planning decisions more transparently in order to achieve
the common objective of better quality life of city residents and reconcile development planning
challenges with environmental protection and sustainability.
1.3 APPROACH AND METHODOLOGY OF SEA
The methodology for the study was adopted through a dynamic and flexible process in order to
focus on the key issues related to urban planning and related considerations that has led to the
present environmental degradation in Dhaka. Initially, the SEA study was supposed to focus on

the DAP planning process, presently underway, and propose an environmental management
framework through which sustainability considerations could be built into the plans thereby
helping to arrest the environmental degradation of Dhaka.
However, as the study progressed, it became evident that there were a number of gaps in the
planning framework and in the DAP process that were causing delays in the formulation of the
DAPs. Principal reasons for this slow development of the DAP formulation process are: (i) the
lack of higher level planning strategy; and (ii) over-ambitious Terms of Reference, poor process
design and inadequate allocation of technical resources by RAJUK. These findings were then
investigated. After an extensive review of the higher level planning framework and an analysis
of the institutions responsible for planning, it became evident that there were additional
constraints, such as inadequate transmission of plans, lack of regional focus, institutions working
at cross-purposes and sometimes in conflicting roles, which, if not resolved through interventions
at the higher level would prevent the mitigation of risks to the urban environment.
An examination of the Terms of Reference provided to the DAP consultants and a review of the
details of DAP formulation process showed considerable shortcomings in design and
implementation which needed to be addressed for satisfactory completion of local area land use
plans.
Consequently, it was thought prudent to focus the SEA upstream on the higher level planning
framework and develop a better understanding of the interactions and potential conflicts between
different agencies and institutions responsible for Dhaka’s planning and plan implementation
functions. As a result, the study focuses on development of an integrated strategic planning
framework in both plans and the institutions responsible for formulating them with the end
objective of promoting sustainable urban development in Dhaka.
To undertake systematic technical analysis of environmental, planning concerns and political-

economic considerations in Dhaka and at the same time incorporate the views of the stakeholders
in the development of Dhaka the SEA process comprised of the Analytical Component and
Participatory Component. The analytical component looked at measures required to incorporate
environmental and planning considerations into the preparation and implementation of the DAP;
examined how the DAP formulation process could be improved, and also looked at the need for
strategic interventions at the higher planning and institutional levels. The participatory
component, adopted through a range of deliberations with stakeholder groups, complemented the
consultative process of the DAP organized by RAJUK and the DAP consultants, thereby helping
to make the planning process for DAPs more transparent and inclusive.

1.3.1 Analytical Component
The analytical component of the SEA has three areas of investigation. One, aimed to make a
thorough analysis of the key environmental problems in the DMDP area based on secondary
information available in various published studies and documents and analyze their linkages to
policies, legislation and plans. Two, assessed the adequacy of existing urban plans and the
planning process at the strategic level in order to make recommendations for improved planning
and governance. Three, assessed the efficacy of the on-going DAP formulation process;
reviewed the design and technical planning capacity in RAJUK; and identified the areas and
needs in RAJUK where interventions for capacity development would be beneficial to overall
urban management.
Thus, the main outputs of these analyses are:

• environmental priorities identified;
• transmission mechanisms2 of existing planning and institutional arrangements to
environmental priorities assessed;
• the effects of DMDP and other sectoral plans on environmental priorities assessed, given
the institutional and planning framework in Dhaka and considering the potential reactions
of stakeholders;
• recommendations for adjustments in the planning and institutional framework for DAP to
contribute to sustainable urban development of Dhaka; and
• recommendations for improving planning capacity in RAJUK and in local authorities.
Environmental issues and stakeholders’ environmental concerns have been assessed by

environmental components: landuse and land management; water resources and quality; air and
noise quality; and drainage and flooding, and by sectors: water supply, sewage and sanitation,
solid waste, drainage and flooding, transport, industry; and spatial planning. In identifying
environmental concerns, the perceptions of key stakeholders, particularly the most vulnerable,
have been incorporated using the participatory component.
Following the identification of environmental priorities, based on stakeholder concerns in Dhaka,

these were analyzed on a two-pronged approach. On the one hand, the analytical aspects focused
on the ability of the institutional and planning framework to address the environmental concerns
as urban development was undertaken taking into account the issues of governance, role of
vested interests and complicit relations between government agencies and the private sector. On
2
The transmission mechanism from a policy or plan to a priority issue is the manner in which the confluence of institutional,
governance and political economy characteristics of a country impact on the interpretation and implementation of the policy
or plan and its associated legal instruments and regulations and, thus, will determine to a large extent the effects of the policy
or plan on the priority issue. In a situation of weak governance and institutions, changing policy or formulating plans without
addressing the underlying transmission mechanism will usually not have any significant effects on the existing outcome with
respect to the priority issue.

the other hand, the views of the stakeholders on the severity of the environmental degradation
and the need to bring transparency into the planning process were taken into account while
developing the priorities.
Issues that have been considered in the assessment comprises of the following:
• intra- and inter-institutional planning coordinating mechanisms;

• transparency and stakeholder involvement in the planning and approval process;
• institutional capacity to identify sustainable development and environmental priorities;
• ability to adapt planning processes to changing priorities;
• implementation, monitoring and enforcement capacity; and
• gaps in high level plans to address environmental priorities such as surface water
pollution and under groundwater depletion to guide the formulation of low level plans.
The analysis has been subsequently synthesized into institutional and planning strategies with
concrete proposals for the short, medium and long-term to be incorporated in the formulation and
implementation of spatial planning of DAPs. These analyses will also assist in the preparation of
the DIEWRMP and guide RAJUK in the preparation and implementation of the DAPs.
1.3.2 Participatory Component
For the SEA process to be successful, the participation of RAJUK, key urban development
agencies, and potentially affected stakeholders was considered to be important. Accordingly, the
participation of weak and vulnerable stakeholders in the SEA was ensured in order to take into
account their concerns on urban planning and how they relate it to environment protection. A
detailed inventory of stakeholders to the SEA process was prepared, the linkages that exist
between them were studied and their stake and influence on the planning process understood.
The workshops also provided important insight into the shortcomings of the DAP formulation
process and indicated serious stakeholder concerns about the overall planning and
implementation competencies. This was followed by a series of consultations to understand their
concerns about planning and environmental issues pertaining to Dhaka urban area.
Significantly, the process provided SEA stakeholders with an open and transparent dialogue
platform to discuss spatial and urban development planning issues, understand linkages with
environmental degradation that the city has experienced and thereafter set a positive direction to
the long-term strategic planning of the city. Details of stakeholder consultations are provided in
Appendix 1.

BOX 1.2: THE SEA CONSULTATION PROCESS
Appreciating the need for promoting an inclusive and transparent urban planning process for the city of Dhaka, a
focused consultation process was planned out and formed an important component the SEA study. The
consultation process of the SEA was conducted simultaneously to the consultation carried out by the DAP
consultants. While the DAP consultation focused on consultation with the public to understand and incorporate
their requirements in the plan preparation process, the SEA consultations focused more on the understanding
strategic level issues and considerations like political economy factors that were preventing the preparation or
successful implementation of holistic plans, thereby resulting in adverse impacts on the urban environment . The
consultations thus focused mainly on higher level i.e institutional/organized stakeholders. However to understand
the concerns and viewpoints of the public, especially the vulnerable groups (slum dwellers, rickshaw pullers etc)
some group consultations were conducted during the course of the study.
Individual Consultations: The individual consultations were conducted with all probable stakeholders to
understand their sphere of influence and the knowledge and skill set which they can bring into the SEA Process.
Initial Stakeholder Workshop: The initial stakeholder workshop was organized for informing the stakeholders of
the objectives of this study and to understand the perception of the citizens about the environmental concerns
facing Dhaka.
Sensitization Meeting: This meeting was intended to sensitize the members of the Technical Management
Committee overseeing the DAP preparation about the SEA.
One-on-One Meetings: One–on-One Meetings were organized at the initiation of the assessment of environmental
concerns to understand the need and aspiration of the stakeholders from the DAP and SEA process.
Sectoral Stakeholder Workshop: The sectoral stakeholder workshop was organized to identify some key action
areas and policy level initiatives for their implementation for various urban development sectors.
DAP Area Meetings: The results of the sector-wise workshop were disseminated through these meetings to be held
in each of the areas where a DAP is being formulated.
Stakeholder Workshop: This workshop was held after the completion of the Draft Final Report to broadly discuss
the possible recommendations of the SEA. It was convened with participation by the sectoral and DAP area wise
stakeholders. The workshop's main result was to draw up a consensus on the recommendations to be incorporated
in the SEA.
Final Consultation Workshop: This final consultation workshop has been planned for mobilizing the support of the
decision makers and further disseminating the recommendations of the SEA among stakeholders and taking
feedback about the findings and recommendations of the SEA study before finalizing the SEA report.
1.4 OUTPUT
The deliverable from this activity is twofold. The SEA report informs RAJUK and appropriate
government agencies with strategic issues and guidelines for the preparation and implementation
of DAPs. Secondly, it provides a tool for decision making to Dhaka’s urban development
agencies led by RAJUK to discuss and negotiate the institutional and governance requirements
for sustainable urban planning. The study will provide specific recommendations for

institutional and governance strengthening for environmental sustainability of urban

development of Dhaka Metropolitan Area.
The Technical Management Committee (TMC) set up by the Government of Bangladesh (GoB)
for supervising and managing the DAP preparation has been engaged in reviewing the results of
this study and would be tasked with implementing policies to address SEA recommendations and
monitoring of the implementation of these recommendations. The SEA will also inform the
preparation of a Policy Note from the World bank to the GOB on strategic environmental
planning in Dhaka.
1.5 REPORT STRUCTURE
The remainder of the report is structured as follows:
Chapter 2 : Situation Analysis of Dhaka’s Environment

Chapter 3 : Urban Planning in Dhaka
Chapter 4 : Risk and Opportunities of Planning Framework
Chapter 5 : Recommendations from the SEA Study
Appendix 1 : Public Consultation in SEA[iflc1]

2.0 SITUATION ANALYSIS OF DHAKA’S ENVIRONMENT
This section presents the existing environmental situation of the Dhaka urban area. It describes
the stressors on environmental resources, their components and its causes. The effect on the
various environmental components have been clustered into four subsections, viz. land-use and
land management, water resources and quality, air and noise quality, flooding and drainage. The
analysis of the present environmental condition would include the views and concerns expressed
by the stakeholders including vulnerable groups, and describe how they are impacted as a result
of unmanaged urbanization. The section concludes with a summary of prioritized environmental
issues based on technical analysis and the perspective of stakeholders gathered through several
rounds of public consultations.
2.1 URBANIZATION IN DHAKA
Dhaka, the capital city of Bangladesh, has emerged as the main economic nerve centre
contributing about one-fifth of the nation’s total GDP. However, with no alternative economic
growth centre coming up, the expansion of the city in the last few decades has been very rapid
and has been marked by huge influx of population from rural areas of the country. This rapid
development, combined with absence of any systematic urban management, primarily during the
last two decades has led to a shortfall in urban services infrastructure thereby resulting in severe
environmental degradation and strain on resources. In addition, the nature of economic growth
and urbanization is skewed resulting in about 37%3 of the city’s population living below the
poverty line and 3.4 million people are estimated to be living in slum areas. Furthermore, at
present, environmental constraints to growth in the capital city constitute a national priority as
pointed out by the Country Environmental Analysis4.
The DMDP area, covering a total of 1528 km2, lies in the delta of three major river systems of
the Indian sub-continent i.e., Jamuna, Padma and Meghna. The urbanized part of Dhaka and the
immediate peri-urban areas mainly occupy the flood plains of a number of smaller rivers which
are tributaries of these two (Padma and Meghna) larger rivers and form an intricate system of
rivers and natural drainage channels (the watershed formed by Tongi and Turag on the northern
side, Sitalakhya and Balu in the eastern side and Buriganga on the western and southern side5).
As a result, most of the land within the pear shaped delta forming the DMDP lies about 2-6 m
above MSL (Mean Sea Level) except for the Mirpur highlands located along the central axis,
where the elevations rise to about 13m. The overall slope of the area and resultantly, the flow of
these smaller rivers are from north, north-west to south, south east side.
3
Centre for Urban Studies (CUS) : Slum Studies, 2005
4
Bangladesh Country Environmental Analysis, World Bank, September 2006.
5
However, with rapid urbanization, the Metropolitan Planning Area now encompasses areas beyond the physical boundaries
set by the rivers. The areas on the other banks of these rivers, including the municipal areas, are charted for urbanization in
the planning period extending till 2015.

The present city of Dhaka has grown from a small settlement of nearly 0.2 million people, spread
over an area of approximately 1 km2 during the pre-Moghul period (1600s), on the natural levees
of the River Buriganga and Dholai Khal. Presently it has transformed itself into a city having a
population of about 12 million. The annual average population growth rate for Dhaka has been as
high as 6.9%6 during the period 1975 to 2000 (compared with an annual average of 2.1% for
Bangladesh) and subsequently (2001 onwards) the annual growth rate is in the range of 4%7.
Experiencing high rate of development and rapid urbanisation, the city is poised to grow into the
fourth largest urban agglomeration in the world with a projected population of 21.1 million by
20158.
The spatial dimension of growth of Dhaka in the course of the last four centuries (1600-2000) is
presented in the figure below.
FIGURE 2.1: SPATIAL GROWTH OF THE DHAKA9
Moghul Period : 10 km2

British Period : 22 km2
Pakistan Period : 85 km2
Bangladesh Period (DMDP): 1528 km2
Administratively, the spatial boundary of the DMDP incorporates 3 Zillas10 (Dhaka, parts of
Narayanganj and Ghazipur), 5 Pourashavas (Savar, Tongi, Ghazipur, Narayanganj & Kadam
6
World Urbanization Prospects: 1999 Revision, UN Report.
7
Bangladesh Census (Year)
8
DMDP Structure Plan
9
DWASA Presentation
10
Bangladesh is divided into six administrative divisions, each named after their respective divisional headquarters: Barisal,
Chittagong, Dhaka, Khulna, Rajshahi, and Sylhet. Divisions are subdivided into districts (zila). There are 64 districts in
Bangladesh, each further subdivided into upazila (subdistricts) or thana ("police stations"). The area within each police
station, except for those in metropolitan areas, is divided into several unions, with each union consisting of multiple villages.
In the metropolitan areas, police stations are divided into wards, which are further divided into mahallas. There are no elected
officials at the divisional, district or upazila levels, and the administration is composed only of government officials.

Rasul) and the Dhaka City Corporation area which mainly covers the older parts of the city. A
map of the DMDP area delineating the administrative boundaries is presented in Figure 2.2
below. As can be observed, large areas in the fringes of the city covering an area of about 1000
sq kms fall within the administrative jurisdiction of the Union Porishods and are still largely un-
urbanised.
For the purposes of this SEA study, the urban development of Dhaka has been spatially clustered
into three distinct zones11 as described below:
• Developed areas: areas in the core of the city, mainly comprising of older parts of
Dhaka, where the population densities are very high and has reached near saturation.
However, certain pockets within these densely urbanised parts of the city are undergoing
redevelopment.
• Developing Areas: area adjoining the core areas of the city falling under the
administrative jurisdiction of DCC & Pourashavas which has developed as suburban
areas and still has some space available for further urbanisation.
• Fringe Areas: areas in the fringe of the DMDP area falling under the administrative
jurisdiction of the Union Porishads which consist of primarily low lying lands (flood
plains) with agricultural landuse. These areas are charted out for urbanisation in future.
The spatial extent of these three zones and the distribution of population in each of these three
areas are presented in the Table 2.1 and Figures 2.2 and 2.3 below.10,11
11
Developed Area: Old Dhaka city area covering about 186.12 sq. km area
Developing Areas: Extended areas in the DCC (part of the 6 Thanas: Demra, Sabujbagh, Uttara, Kamrangirchar,
Badda, Shyampur) and Paurashavas (Naraynganj, Kadamrasul, Savar, Tongi and Gazipur) covering an area 309.96 sq.
km
Fringe Area: Rural Areas under Union Parishad (part of Demra Thana, Sabujganj Thana, Uttara Thana, Badda Thana,
Shyampur Thana, Kamrangircahr Thana, Savar Upazila, Keraniganj Upazila, Gazipur Sadar Upazila, Rupganj Upazila,
Bandar Upazila and Narayanganj Sadar Upajila) covering an area 1032.96 sq. km.

TABLE - 2.1: POPULATION DISTRIBUTION AND DENSITIES IN 3 ZONES OF DHAKA

Density Density
2001 2006
Area (sq Population (Pop/sq Population12 (Pop/sq
kms) 2001 kms) 2006 kms)
Developed Area 186 5333571 28657 6439341 34598
Developing Area 310 1551891 5007 1873633 6045
Fringe Area 1032 3190930 3089 3852482 3730
Total 1528 10076392 6590 12165456 7956
FIGURE 2.2: ADMINSTRATIVE MAP OF THE DMDP REGION
12
Population Data : 2001 (Source : Bangladesh Bureau of Statistics, 2001); 2006 : Estimated on Projected Growth rate of 4.15%
per annum as per BBS projected Growth Rate

FIGURE – 2.3 : SPATIAL DISPOSITION OF DEVELOPMENT ZONES WITHIN DMDP

2.2 LAND-USE AND LAND MANAGEMENT
Like other developing countries in South Asia the urban population of Bangladesh has grown at
a much faster rate than the rural population. As a result, in spite of the overall low level of
urbanization in the country, there are considerable spatial imbalances, especially when seen in
context of the rapid growth of Dhaka. Dhaka as the country’s capital city is home to about 34%13
of the Bangladesh’s total urban population. This is primarily due to its central location and easy
accessibility from different parts of the country, presence of administration and government and
also being the industrial, trading and commercial hub of the country. The location factors
coupled with its high economic potential as also the lack of any alternate urban agglomeration
with similar opportunities has resulted in the influx of a large number of people from rural areas
of the country into Dhaka. The problem of urban influx is accentuated by extreme rural poverty,
uncertainties of agricultural production, landlessness and high rural-urban wage differentials.
The rate of such influx is estimated to be about 0.3 – 0.4 million people per year14.
To accommodate the increasing pressure of population mainly due to in-migration, the city area
has grown spatially over time from about 85 km2 in 1951 (Master Plan) to 1528 km2 in 1995
(DMDP). However, because of inadequate planning to manage urban landuse and its
development, most of the urban growth in the last decade has taken place in an unplanned and
haphazard manner. Resultantly, existing urban areas have witnessed high levels of population
densification with intensification of slums and vertical growth replacing horizontal expansion
even though the urban infrastructure required to support such growth has not been upgraded. On
the other hand, large parts of fringe areas designated for growth have not been developed for
planned urbanisation. This is accentuated by skewed development of the fringe areas being
developed in an unplanned manner after filling up of low lying flood plain and agricultural areas
by powerful realtor groups using their influence on the government agencies, including RAJUK.
Most of these new developments would only be catering to higher-middle and high income
groups in the city, thereby reducing the possibility of distributing the population throughout the
DMDP area and forcing the intensification of slums as poorer sections of society have no place
to go. The various aspects of land-use management and its impacts on various environmental
components are briefly discussed in the subsequent sections.
2.2.1 Housing, Slums and Open Spaces
The lack of proper housing infrastructure for various sections of the urban society is a crucial
problem in Dhaka and assumes significance from the environmental point of view. With a rapid
influx of population from the rural areas into Dhaka, the ability of the city to provide proper
13
Centre for Urban Studies (CUS) : Slum Studies, 2005
14
Rate of influx – Bangladesh Bureau of Statistics.

housing infrastructure to the migrant workers is under severe stress. Even though the Strategic
Plan requires the provision of housing for the poor by RAJUK, it was not lucrative for either the
government agency or the private sector to do so; hence many parts of the city has witnessed
intensification of slums. This increase in the number of slums in the developed parts of the city
and disproportionate distribution of residential land is reflected in the fact that 70% of the total
urban population live in only 20% of the residential land while the remaining 30% live in 80% of
the residential land in Dhaka15.
The number of slums in Dhaka has increased from 1125 in 1998 to 4,966 slum clusters in 2005
(CUS 2006). These slums are very densely populated with and average of 2,20,246 [iflc2]16 people
per km2 . Spatial analysis of the survey16 shows slums are located all over the DCC17 area, with
Zone 1 having the highest proportion (11% slum area), and Zones 2 and 10 having the lowest
with less than 1% slum area. Eighty percent (80%) of such slums are housed on privately owned
land and many of them are susceptible to flooding. The survey also indicates that a third of the
population in DCC area live below the poverty line in these slums and do not have access to
basic urban and civic services like drinking water, sanitation, education and health. It is pertinent
to add that the slums themselves led to further environmental degradation through discharge of
untreated household waste and sewage into the surrounding water bodies.
The developed parts of Dhaka and some newly developed areas has witnessed a spurt in demand
for apartments mainly targeted for high income groups who comprise a small percentage of the
urban population. These apartments are mostly constructed by private realtors who often have
high influence within the government agencies and as a result often tend to flout development
regulations like the Building Construction Rules. On the other side, the demand for such
apartments among high income group people was fuelled by government policy on money
laundering which allows undeclared income to be invested in real estate without disclosing the
source of income.
BOX 2.1: SLUMS IN DHAKA – A GLIMPSE
The common slum dwellers of Dhaka mostly comprise migrants from rural areas in Bangladesh
to Dhaka in search of a better livelihood and quality of life. Because of the high land prices and
the unavailability of housing infrastructure for low income groups, the migrants take shelter in
one of the slums within Dhaka, preferably close to their place of work. Most of the slum dwellers
work as readymade garment industry workers, rickshaw pullers, household helps, ragpickers,
etc., and make an important contribution to Dhaka’s economic growth by contributing labour to
15
Akash & Singha, 2003
16
LGED Slum Survey, 2004-2005
17
The DCC area has been divided into 10 zones Zone 1 –Zone 5 in old Dhaka and Zone 10 is Uttara township newly developed
by RAJUK.

BOX 2.1: SLUMS IN DHAKA – A GLIMPSE

business or by providing necessary urban services. The income level of slum dwellers varies
between Tk 1200- 3500 per month (for men) and Tk 300-1500 (for women).[iflc3]
Even though approximately 30% of the Dhaka’s population lives in slums, access to urban
services in squatter settlements are poor. Amongst the poorest people in the slums, only 9% of
households have a sewer line, and 27% obtain water through piped supply (compared with 83%
of the wealthiest). Spatial mapping shows that only 43 of the 1925 identified slums are within
100 meters of a public toilet. Only 7% of slums have a public health clinic and 26% have a
government school. Many of the slums have developed gradually mostly in marginal areas of
the city, and in many cases in low lying areas adjoining rivers and drainage khals or by filling up
wetlands. Therefore, they are vulnerable to flooding and associated flood risks. Additionally,
some of the slums are considered to be illegal and often evicted by government agencies from
time to time without any proper rehabilitation.
Consultation with the residents of the Karail Basti slums revealed that a parallel informal system
for providing basic urban services to slum dwellers has developed. Such services are mostly
provided by local toughs who are called mastaans. As a result, slum dwellers, in spite of being
economically disadvantaged, often end up paying higher prices in terms of rent, and other
services like drinking water supply and electricity.
These highly dense slum settlements often

have a degrading effect on the quality of
adjacent water bodies and the cleanliness of
surrounding areas. The slum dwellers area
also more prone to various vector borne
diseases because of the lack of good quality
drinking water and proper sanitation
facilities.
As a direct effect of the unplanned urbanisation and lack of development control, Dhaka has very
little open space in form of park18, gardens etc, (approximately 310 hectares)19. Of the total land
area, the developed area (primarily under DCC jurisdiction) has only 14.5% open space when
ideally such large cities should approximately have around 25% open space[iflc4]. Importantly,
some of the areas demarcated for parks have been illegally occupied by encroachers having
political influence to set up temporary markets, bus stops, slums, etc. This in spite of the fact that
18
Some other important open spaces in the city are Osmani Uddayan, Bahadur Shah Park, Botanical Garden, Suhrawardi
Uddyan, Ramna Park, etc
19
Aboriculture Department, Ministry of Housing and Public Works

Bangladesh Open Spaces and Wetland Protection Act 2000 does not allow parks open spaces and
wetland to be converted for any other uses.
2.2.2 Industries
Two important drivers of environmental degradation in the Dhaka watershed have been the
export–oriented economic growth, which has often been associated with use of inappropriate
technology and the lack of enforcement of environmental standards by the Department of
Environment. The focus of discussion here is the resultant industrial pollution.
There are two points of relevance here. One is the rapid growth in the number of industries in the
last decade; and two, the growth and dispersal of pollution intensive sub-sectors, making
management of industrial pollution difficult.
Growth of Industries: BKH20 estimated that in 1994 there were 221 industrial units in the six
clusters in Dhaka. DIEWRMP noted that in 1998 there were 2,200 industrial units in and around
Greater Dhaka. IWM (2007) notes that there are now 3,000 units in Dhaka and over 7,000 in the
watershed area. There are nearly 60 different types of industry but the base is dominated (60%)
by the garment industry. It subsumes a number of processing activities, like dying, washing and
printing of fibre and fabric, which are carried out in factories of different sizes. Other medium
and small-scale industries include: jute mills, tanneries; metal, cement, rubber, chemicals
processing units; pharmaceuticals, petroleum refining, distillery, plastics and brick
manufacturing.
These industrial units have come up alongside or adjacent to residential houses, shopping
centers, schools, play grounds, parks and hospitals. The wastes, emissions and noise from these
industries have the potential to affect the health of the residents in such areas.
Pollution intensive sub-sectors and their dispersal: Prior to independence in 1971, all
industrial activity in Dhaka was restricted to Tongi and Fatulla industrial estates. In 1995 the
Dhaka Structure Plan noted that these industrial zones where under-utilised as they were poorly
maintained and managed by BSCIC and did not provide the services required. With a change of
policy, it allowed ‘footloose’ industries to locate outside the designated areas. Given the rising
cost of land, industry was quick to disperse throughout the watershed. Review of several studies
(Dasgupta and Marr: 2007) showed that some of the most pollution-intensive industrial activities
are dyeing, printing and washing of fabrics; chemical and oil processing. A predominant number
of industries discharge untreated waste, thus externalizing the cost of cleaning up. It is useful to
20
BKH Consulting Engineers et al (2001) Techno-economic Study for Setting up a Common Effluent Treatment Plant in the
Tannery Cluster of Hazariabagh. UNIDO and Government of Bangladesh.

note that the garment and apparel industry shifted to Asia as environmental regulations in the
west made it very costly to carry out certain stages of garment production.
The end result is that industry accounts for 60% of the pollutant load in the watershed. This
pollutant load is constituted of organic and inorganic waste, including heavy metals. The gravity
of the problem lies in the fact that surface water is too polluted to be treated to potable standards.
This has meant increasing reliance on groundwater and high abstraction rates by DWASA and
the private housing developments (these are discussed in detail in section 2.3). Furthermore,
IWM (2007) have noted that geography of the watershed facilitates the interaction between
polluted surface water and groundwater, thereby increasing the threat of groundwater
contamination.
All major cities have areas designated for manufacturing and processing industries. The
implication here is the need for DAP planners and consultants to understand the issues behind
delineating industrial zones. There are two sets of problem that have to be tackled. One, is how
to control and manage the industrial clusters which have already developed; and two, how to
spatially manage future industrial growth. Discussion with industry is fundamental to developing
ideas which would work and would not impose additional costs on industry.
BOX 2.2: LOCATION OF INDUSTRIES IN DHAKA
Traditionally, the industries were located in old Dhaka Area e.g. Postagola, Laxmibazar, Imamganj,
Gandaria Farashganj, Faridbad, Shankaribazar, Nawabganj, Amingola, Tantibazar, Patuatuly, Hazaribagh
and Tejgaon areas. Recently, industrial units have also developed in Narayanganj, Fatulla, Panchabatee,
Kachpur, Rupashi, Tarabo, Hotabo, Sonargaon, Araihazar, Rupganj on the eastern and southern side of
the DMDP area and along the Dhaka-Chittagong Highway.
In addition to these, a number of designated industrial areas have also come up e.g. the Tejgaon Industrial
Area promoted by the erstwhile DIT (Dhaka Improvement Trust) and the Savar EPZ promoted by DEPZ
Authority for small and medium industries. The industrial units operating from these areas include
dyeing/printing factories, edible oil factories, paper and pulp mills, chemical industries, jute mills, textile
mills, printing, garment manufacturing, engineering, moldings, welding, repairing, chemicals, packaging,
used lubricant processing, washing, water bottling and many others.
2.2.3 Roads & Transportation
As in many major cities, transportation corridors play an important role in defining directions of
growth of a city. In Dhaka, most of the major transportation corridors have developed in a north-
south direction. This is primarily because of the growth of the city along the central highland

axis. However, at present to create space for urbanization, the low-lying areas in the eastern and
western sides are also planned to undergo urbanisation.
The transportation system in Dhaka is predominantly road based. However, the roads of Dhaka
still occupy only 8%21 of the total area, even after the implementation of the Dhaka Urban
Transport Project (DUTP) and the Dhaka Integrated Transport Project (DITP), whereas ideally at
least 25% of the total city area is required as road space to facilitate a smooth transport system in
a modern city. Further, the growth of road space has been slower than growth of vehicles (80%
in the last decade). In addition, the mixing of different modes of transport i.e. both motorized and
non-motorized transport (rickshaws 3,00,00022 in number accounting for 15.2% of the traffic and
occupying 73% of the road space) has been cited as a major reason for congestion in the city.
The congestion is further aggravated by incidences of on-street parking in absence of adequate

off-road parking spaces in the city. The problem is acute in old high-density area of the city like
Dhanmondi and the Central Business Districts causing severe congestion in these areas. It has
also been reported that the tendency to construct multi-storey buildings along the major transport
corridors without adequate arrangements for parking of construction vehicles, storage of
constructions materials etc. in contravention to the building rules23, has resulted in aggravating
congestions on certain important corridors.
In addition to the road-based transportation, there are two other major transport systems
operating in the city. A railway line operates in the north south direction of the city. Bangladesh
Railway operates standard gauge passenger trains on this route but the frequency of operation of
this mass rapid transport system is relatively low. The BWTA operates ferry service to transport
passengers from areas south of Dhaka till Sadar Ghat but this system has no extensions in the
north. The potential of these two modes of transport have not been fully utilized. Further the
inter-linkages between the three modes of transport, Railway, Roadways and Waterways is poor.
As a result the passenger dispersal system from the railways and waterways is dismal and results
in localized problems. This also contributes to these systems not being used as a preferred mode
of transport in Dhaka.
The main points emerging from this analysis are the lack of collaboration and co-ordination
between different transport agencies and an absence of an integrated transport planning
approach.[iflc5]
21
National Encyclopedia of Bangladesh (Banglapedia),
22
Officially records with DCC indicate the total number of rickshaws in Dhaka to be around only 88,000
23
The Building Construction Rules 1996, and The Building Construction Rules 2006

2.2.4 Solid Waste
It is estimated that the Dhaka city area generates approximately 350024 tonnes/day of residential,
commercial and institutional Municipal Solid Waste (MSW). With rapid urbanization, increasing
per capita incomes and changing lifestyles, the rate of increase of MSW generation is also likely
to increase. At present, biodegradable organic matter constitute approximately 60% of the waste.
The city corporation and Pourashavas are responsible for providing urban services related to
solid waste in their respective areas. DCC has established a Solid Waste Management Division
to manage the solid waste but this has still to affect its solid waste management strategy. The
Pourashavas are still dependant on a conservancy-based approach25. There has been very little
effort both at the city as well as in Pourashavas to minimize (recycle/ reuse) the waste.
It was reported that about 50% of the waste being collected and disposed from the city, i.e.
approximately 1400 tonnes/ day of waste are delivered to dumping sites from the city. Till
recently, DCC had one authorized dumping site at Matuial (3 km south-east of the DCC central
office) and remaining were dumped on private lands in Berri Bund and Uttara. DCC has recently
acquired a new site at Amin Bazar and is in the process of converting the open dumping at
Matuial into a sanitary landfill. The principal dump site Matuial is more than 25 km from many
parts of the city. Even though the “Clean Dhaka Master Plan” recommended upgrading of the
Matuial site and acquisition of a new disposal sites at Amin Bazar, the siting of these landfills
remains an issue of concern even though these sites have been cleared by both DOE & RAJUK.
The DMDP Urban Area Plan questions the feasibility of the selected sites considering the spatial
growth projections suggested in the Structure Plan. Thus scarcity of land is leading to selection
of landfill sites for waste disposal which are environmentally unfeasible.
Further, there is no comprehensive system for collection and management of bio-medical waste
and industrial waste. Most of these special wastes are either disposed into the public waste bins
or are disposed off in open areas and in watercourses. The JICA (?) study26 indicates that
industrial wastes are not categorized as hazardous or non-hazardous and are disposed at the
Matuial dumpsite together with ordinary municipal waste.
The environmental concerns associated with landuse and land management are:
24
JICA Clean Dhaka Master Plan Study assuming population of 6.3 million and waste generated is 0.56 kg/capita/day.(2004)
25
The conservancy based approach primarily depends on collection of solid waste from secondary location and disposal at a
some other location.
26
The Study on the Solid Waste Management in Dhaka City, JICA, 2005.

BOX 2.3: LANDUSE AND LAND MANAGEMENT ENVIRONMENTAL CONCERNS
• Incompatible development patterns leading to environmental stresses

• High urban densification in certain areas resulting in strain on urban services
• Intensification of slums resulting in environmental & health risks
• Selection of environmentally unsound solid waste dumping sites due to non availability
of suitable land parcels
• Low ecological diversity as a result of degraded habitats
2.3 WATER RESOURCES AND QUALITY
2.3.1 Water Resources
Even though Dhaka is surrounded by rivers on all sides and fall within the watershed of three
major rivers of the Indian subcontinent, the water supply of the city is predominantly based on
groundwater resources for reasons already explained in section 2.2.2.
The demand for potable water in the city is estimated to be over 1.5 billion litres per day (BLD)
of which about 20% is supplied from the Sitalakhya river via two water treatment plants located
at Chandighat and Saidabad. The rest of the water is supplied by 453 borewells operated by
DWASA for supplying water to the city. In addition, there are also a number of privately
established borewells which supply water to numerous apartments distributed throughout the city
and it is estimated that approximately about 1300 privately owned deep tube wells operate within
the city. In the fringe areas, water supply is from bore wells operated by Pourashavas, private
operators and industries.
Thus, cumulatively more than 80% of the total water requirement in the DMDP area is
dependent on groundwater. The over dependence on groundwater for supply results partially
from the lack of infrastructure to treat and distribute surface water, but essentially the poor
quality of surface water in the Dhaka watershed. Such intensive use of groundwater throughout
the Dhaka watershed has resulted in depletion of the groundwater levels by approximately
2-3 m/year27.
In addition to the concerns of the rapidly depleting water table established through a number of
studies28, the stakeholders in Dhaka have expressed serious apprehensions about the quality of
water supplied from both surface and groundwater sources. Recent reports indicate that
27
Dhaka State of Environment Report 2005
28
Industrial Environmental Compliance & Pollution Control in Greater Dhaka –Phase I, IWM March 2007

groundwater has been found to be contaminated by chemicals (mainly heavy metals) and
dissolved solids, in the upper aquifers near Hazaribagh and other industrial clusters strongly
indicating contamination from industrial sources. In addition, high levels of organics in influent
water at the intake of the Saidabad treatment plant affects the plants capability to treat water to
levels which adhere to drinking water standards29.
The water supply to the slums and poorer sections of the society is limited with only about 27%
having access to piped water supply, mostly through standposts. Consequently, large sections of
slum dwellers are forced to buy water from local tube well owners either at high prices30 or use
polluted surface water for their daily needs resulting in serious health concerns.
2.3.2 Water Pollution
The rivers and streams flowing adjacent to Dhaka are highly polluted. The surface water quality
in the rivers and other surface water bodies e.g. khals and ponds, etc have very high BOD31,
COD and e-coli content indicating discharge of untreated industrial effluents and sewage in these
water bodies (khals, ponds). As a result of the high pollution levels, many sections of the rivers
and canals in the city and surrounding areas are biologically dead during the dry season, and the
water available is unfit for any human use, or even for irrigation. As a result, surface water
pollution from discharge of untreated effluents impacts a considerable section of Dhaka’s
residents either in terms of higher health care costs associated with water borne disease or
because of lost productivity. It is estimated that loss of amenity associated with contaminated
surface water amounts to about 0.5% of the region’s GDP32.
One of the prime reasons for high organic pollution of the rivers and water bodies is the poor
state of sewerage and sanitation system of the Dhaka urban area. Presently, the underground
sewer network covers only 30% of the area of the existing urban areas of the city, and 20% of the
population residing in it. For the remaining areas, especially areas lying in the developing areas,
which are witnessing rapid development recently, are mostly serviced by localized sanitation
facilities like septic tanks and soak pits. During consultations, it was reported by stakeholders
that in number of cases the sanitation facilities like septic tanks and soak pits are poorly or
inadequately designed33. The sanitation facilities in slum are even poorer. A large amount of
domestic and human waste is held in situ these areas, some of which gets washed into the water
29
Country Environmental Analysis, 2006, WB
30
Slum dwellers reported paying as much as Tk. 2 per bucket of water, several times the price paid by those who had legal
connections (the official price charged to consumers in Dhaka was Tk. 4.33 per 1,000 litres).
31
IWM study on Industrial Pollution (2007) indicates 330,000 kg of BOD5 are discharged into the river systems in the Dhaka
watershed everyday.
32
Bangladesh Country Environment Analysis - Para 89, page 29.
33
The supernatant waste from these units is often drained into adjacent storm-water channels and drains. In addition, for these
facilities, there is no systematic way of collection of sludge and often the same is drained into nearby water bodies polluting
them.

bodies during the wet season. Access and adequacy to sanitation facilities have been a serious
concern expressed by the vulnerable stakeholders.
Only a small percentage of sewage is collected by the underground sewer network, mostly from
the southern parts of the city and is transported to the Pagla Treatment Plant. The Pagla Sewage
treatment plant runs on non-conventional treatment technology of facultative ponds and
treatment in such ponds is aided by “duckweeds”. The plant has an installed capacity of
120 MLD and presently operates at a third of its capacity. As the existing sewer system is
blocked and/or leaking, only a small portion of the collected sewage is treated in the Pagla
Sewage Treatment Plant and the rest either leaks into or is discharged without treatment into the
surface water system. There are 19 primary discharge points to the rivers and at least
41 secondary discharge points within the city. Many of these discharge points also drain mixed
effluent including untreated wastes from industrial units like tanneries, dying and bleaching
units.
The efficiency of treatment in this particular system is not very high and the BOD load in
effluent from the plant has been recorded to be as high as 200 mg/lit in previous studies
undertaken34. It is understood that being a biological treatment system, the efficiency of
treatment plant is hindered by toxic wastes which flow into the system from industrial units,
especially tanneries in the Hazaribagh area, where effluents are discharged without treatment
into the sewer system.
BOX 2.5: WATER POLLUTION FROM INDUSTRIES IN DHAKA WATERSHED[iflc6]
Water bodies in Dhaka are polluted by a number of industry sectors, some

of which are in the unorganized[iflc7] sector. The main sectors discharging
untreated effluents into water bodies, rivers and streams are tanneries,
dyeing and bleaching units. The discharged effluents consist of high organic
loads or toxic chemical constituents which are used for tanning, dyeing and
bleaching.
There are 270 registered tanneries in Bangladesh with 90%of them being
located at Hazaribag on about 25 hectares of land. Most of these are non- or
semi-mechanized units using old processing methods and produce effluents
having high organic and toxic loads. The dyeing and bleaching units are
distributed throughout the present urban area, with concentrations in Narayangang, Tongi and Savar. Some of
the industries also drain effluents directly into agricultural fields thereby polluting them.
The main industrial clusters and effluent hotspots of the rivers are:
Buriganga River - tanneries at Hazaribagh, Sayampur and Fatullah industrial clusters in Dhaka South and
Narayanganj;
Balu River - Tejgaon Industrial Area;
Tongi Khal - Tongi Industrial Area,
Sitalakhya River - currently developing heavy industry strip.
34
Study conducted by JICA in November, 1997.

In addition to sewage and untreated industrial effluents, inefficient solid waste management
system resulting in open dumping of municipal and industrial wastes also contributes to pollution
of surface water bodies and shallow groundwater aquifers.
The concerns influencing the water quality and resources of can thus be summarized as:
BOX 2.6: WATER QUALITY ENVIRONMENTAL CONCERNS

• Depletion of groundwater due to overdependence on groundwater resources
• Surface water pollution due to discharge of untreated sewage and effluent
• Contamination of land and shallow aquifers due to open dumping of municipal & industrial
solid waste
2.4 AIR AND NOISE QUALITY
Like other major metropolises in developing countries, deterioration of air quality in the Dhaka
area is a key environmental concern. Though considerable policy level initiatives were
undertaken during the last decade to improve the air quality of Dhaka, the air quality
improvements achieved through initiatives like the baby-taxi ban are being rapidly offset with
increasing urbanization. The results from continuous monitoring of the air quality obtained from
the AQMP project indicate that PM10 and PM2.5 levels are considerably above standards,
especially in dry season, and they also show an increasing trend. Studies35 have revealed that
while motor vehicles, re-suspended dust, biomass burning (in brick kilns and by low income
groups as fuels), and fugitive emissions
are major contributors to PM10,
transport is the major source of PM2.5.
Unplanned development and siting of
air polluting industries in areas
adjoining the residential area and
location of the brick kilns adjacent to
the DMDP area have aggravated the
situation. Contribution of air pollution
FIGURE 2.4: AIR POLLUTION from different sectors is summarised

FROM VEHICLES IN DHAKA below:
TRANSPORT: Analysis of the emission inventory presented in figure above indicate that the
diesel vehicles contribute approximately 80% of the air pollution from mobile sources. The
ageing fleet of diesel vehicles along with the high sulphur content in diesel is considered as
prime reasons for such high levels of air pollution. CNG Taxis and 3-wheelers also contribute to
35
Begum et al 2005below

the NOx load. Poor maintenance coupled with poor fuel quality, traffic congestion, poor transport
infrastructure planning and lack of coordination between the agencies involved in planning and
executing of land use and transport planning add to the vehicular air pollution in the city.
SOLID WASTE: The practice of burning of a part of the municipal solid waste collected
contributes to air pollution. The existing municipal solid waste landfill sites (both temporary and
permanent) are sometimes put on fire and emit fumes and gases contributing to air pollution
including methane and non-methane organic compounds, for example benzene, etc.
BRICK KILNS: Large number of brick kilns has been setup in the fringe areas of the city,
especially in the northern parts and all along Tongi and Turag river banks. The significantly high
levels of air pollution from these kilns has substantial impacts on the air quality especially during
dry winter months
INDUSTRIES: Industries in Tejgaon Industrial Area are a major source of industrial air
pollution. Also, the Tanneries and hide dealers in Hazaribagh area, which is a predominantly
residential area, discharge effluent and emit foul odour (decaying carcasses and treatment
chemicals), impacting the health of workers and residents. The rolling mills in Fatullah also
pollute the air in this region.
BOX 2.7: ROLE OF RICKSHAW PULLERS IN URBAN TRANSPORTATION

Rickshaw pullers form an important constituent of the transport system of Dhaka and they form the single
most important mode of non-motorized transport which does not directly cause pollution. They mostly serve
the needs of short to medium distance transportation, especially providing feeder services from houses to the
arterial routes. At the same time though, this mode of transport has been identified as the main cause of
traffic congestion on city roads.
During discussions with rickshaw pullers in the Gulshan area, it was revealed that most of them are landless
labourers and have migrated to the city for livelihood leaving their families behind. Living in Theks
(Bachelor Hostels), they rent the rickshaw on a daily basis from an owner at a daily rent of around TK 50-
80/day. During consultations with them, it came to light that their income ranges between TK 200 – 300
/day and they usually remit most of the income to their families either weekly or fortnightly. The remittance
of income is usually carried out through a network of local telephone booth networks. The concerns
expressed by the rickshaw pullers are:
• They complained that their livelihood suffer because they are not allowed to ply on certain
portions of some of the main roads.
• They are usually unaware of the traffic restrictions and face inconvenience because of any sudden
change of these restrictions.
• They do not receive any training on traffic rules and signs from any authority.

The air and noise pollution related issues are:
BOX 2.8: AIR AND NOISE ENVIRONMENTAL CONCERNS
• Deterioration of air quality due to vehicular & industrial emissions
2.5 FLOODING AND DRAINAGE
Because of its location in the flood plains of three major river systems, the urban areas of Dhaka,
most of which are low-lying areas except for the Mirpur highlands, have historically been
flooded during periods of heavy rainfall in the upper catchments of these rivers. Once the rivers
reach their hydraulic draining capacity, they tend to backflow into the city through the
interconnected drainage channels and the peripheral rivers (Turag, Tongi, Sitalakhya, and Balu)
thereby flooding the low-lying areas in and around the city. As a result, the Dhaka urban area
has repeatedly witnessed flooding events. Severe river floods have occurred periodically during
1954, 1955, 1974, 1987, 1988 and 1998. In 1988, most of Dhaka was inundated by the flood
except for the DND area, which was protected by embankment constructed earlier and the part of
the city near Mirpur. Following the floods of 1988, the western embankment was constructed
under FAP 8B (Dhaka Integrated Flood Protection Project). After construction of western
embankment, the western portion of Dhaka i.e. west of the central highland has now become
almost flood free, but the eastern fringes of the city is still very much vulnerable to floods
resulting from the backflow of primarily the Balu River. Due to the flooding from the Balu River
in 2004, 40% of the area on the eastern side of the city was inundated for approximately a
fortnight.
The urban flooding problem in Dhaka may get aggravated because of two main causative factors
and they are briefly discussed below:
2.5.1 Illegal Filling of Low Lying Areas
The DMDP fringes areas mainly comprise of riverine flood

flow zones. As most areas in the city i.e. the DCC areas have
already been urbanized the fringe areas would have to be
developed for making space for future growth (accelerated
Growth Policy as per DMDP). Most of these areas are low
lying areas and are presently inundated annually during the
monsoon months as the water level in the rivers around
Dhaka rises. To make these areas suitable for urbanization,
these areas have to be raised by filling up to 2-3 m. As per

existing regulation, development permission from RAJUK is mandatory before developing any
land as per the Land Development Act for Private Housing 2004. However, the weak institutional
structure and the lack of political will of RAJUK to implement the provisions of the act (regulated
filling and protection of low-lying areas etc) have resulted in unplanned land filling in these fringe
areas of Dhaka for the purpose of setting up large real estate projects, targeted only at the affluent
sections of the society who comprise about 5 - 10% of Dhaka’s population.
Most of these proposed real estates do not have

required approvals from appropriate authorities,
including the RAJUK or have obtained the same using
their political influences or using unfair practices. In
addition, without there being any systematic plans by
RAJUK for land development and development control
in such fringe areas, the intrinsic ability of these flood
flow zones to retain or store excess water during periods of high rainfall is getting reduced. As a
consequence, the risk of flooding continues to increase in Dhaka and adjoining low lying areas
which are now being charted for future development.
The private developers' body (REHAB) through a public appeal had suggested to regularize
through the Detailed Area Plans (DAPs) all the ongoing housing projects in such areas, many of
which are in violation with provisions of law. This move had been strongly criticized by the civil
society and environmental groups but still no action has been taken against the erring land
developers by RAJUK. Even though the law permits action against the land developers who
violate the provisions of the act or even publish public advertisement without obtaining clearance
from RAJUK under the Land Development Act, cases have been booked against only a few errant
land developers.
It was reported by an expert from BUET in one of the workshops that in a recent study
conducted in Boro Beraid, Santarkul, Kathaldia and Dumni moujas in the city's eastern fringe
areas, severe socio-economic impacts have been reported on the original residents due to the
earth filling. These people now face forced displacement from their ancestral homes as well as
their traditional livelihood based on agriculture. Even though they are provided compensation
amounts, in the absence of any comprehensive rehabilitation policy and with the low skill sets of
the displaced people, the signs of impoverishment are even more pronounced. It has even been
reported that due to the unlawful modalities adopted by the land developers, 53.2% of the
affected locals are forced to sell their lands due to the tactics adopted by the developers, while
25.8% were compelled to sell just because their lands were turned into enclaves within areas
filled up by developers.

2.5.2 Illegal filling of ditches and drainage channels
Dhaka is surrounded on all side by river systems and crisscrossed by drainage channels. The
highland areas within the city have already been developed. Population pressures and requirement
for more urban land within the city boundaries have resulted in encroachment of the water canals
and wetlands which acted as flood retention ponds.
These facts were highlighted at the stakeholder consultations during the Cross Sectoral Workshop
where the representatives for civil societies
presented the case of encroachments in the
Hatirjheel and Begun Bari Khal, two
important wetlands in the central and
southern parts of the city. These two canals
are linked to the Norai Khal which drains
water from a large part of the city. Both
these wetlands have already been
encroached; approximately 1200 illegal
encroachments have been enumerated by RAJUK in Hatirjheel area. Most of these were
constructed by influential people. In addition, during the tenure of the last elected government, land
was allocated to Hotel Hilton International, Federation of Bangladesh Chambers of Commerce and
Industry (FBCCI), International Arbitration Centre and a few CNG filling stations for setting up
offices etc. even though the Wetland Protection Act 2000 prohibits filling up of low lands. It has
been reported that land was allotted to Federation of Bangladesh Chambers of Commerce and
Industry (FBCCI) at nominal price of Tk 1 lakhs[iflc8] without any public bidding even though it is
mandatory as per the procedures of the Government of Bangladesh.
Some government agencies, including RAJUK, DWASA, and Dhaka City Corporation (DCC),
have also submitted proposals for constructing a link road or a circular road in the area to reduce
traffic congestion in the city. The proposals also include constructing other structures over these
wetlands. Implementation of these projects would result in greater inundation of the city’s central
areas.
2.5.3 Potential Climate Change Impacts on Dhaka
The city of Dhaka lies at the focal point of three of the largest rivers of the Indian subcontinent in
South Asia. Lying in the lower flood plains of the rivers Bramhaputra, Ganga and the Meghna,
this area in central Bangladesh itself forms a part of a dynamic and active delta system. Such
deltaic systems involve complex interaction between climate, catchments, deltaic deposition,
tectonic subsidence and coastal regimes. At the same time, this region in Bangladesh supports an
immense human population and contributes strongly to the regional and national economy.

However, being a part of such a complex natural system also means that this region is extremely
vulnerable to natural events like floods, cyclones and coastal surges. The vulnerability in case of
Dhaka is heightened because of the large and concentrated population that it supports and the
rapid urbanization that has already caused immense stress on environmental resources. Climate
change effects are anticipated to add to such stress with possible adverse impacts on city’s
population, especially the economically disadvantaged sections of the society.
The onset of potential climate change effects in near future as predicted in the recently published
IPPC report may result in a number of interrelated adverse impacts in Bangladesh involving
complex interactions between physical processes. The combined effects of subsidence and sea
level rise could result in increasing vulnerability to flooding events, serious drainage and
sedimentation problems, in addition to coastal erosion and land loss. These changes may result in
more frequent tidal surges which may potentially affect many coastal areas, cause inland fresh
water resources to be affected by salinity causing serious drinking water supply concerns and
limit irrigation over large areas because of reduced flow of fresh water resources from the rivers
having sources in the Himalayan glaciers. A combination of such effects will have immense
socio-economic impacts in the region. In quantitative terms, for example, a one metre rise could
flood almost 30,000 km2 of Bangladesh, affecting over 13% of the population, mostly in the
lower deltaic regions of the south.36
At the Dhaka level, the height of the DMDP area varies between 2- 6 m above sea level. The
area is also known to be undergoing tectonic subsidence at an average rate of 0.62 mm/year, but
can reach up to 20 mm/year37, thus effectively lowering height compared to the sea level. In
addition, a large part of the fringe areas of Dhaka comprising about two-thirds of the DMDP area
are characterized as flood flow zones. These areas are extremely prone to flooding and remains
under water for most parts of the monsoon season due to overflow of the channels of the rivers as
discussed before.
As a result of climate change effects, Dhaka may get adversely impacted in the following way:
• Increase in flood vulnerability in the surrounding low-lying areas would act as a

disincentive for the city to expand spatially and disperse the urbanization process to
accommodate the rising urban population thereby coming in the way of expansion of the
city which may in turn impede the economic growth linked with the capital city;
36
Source: IPCC Special Report on The Regional Impacts of Climate Change An Assessment of Vulnerability, Bert
Bolin, Robert Watson, Marufu Zinyowera, Narasimhan Sundararaman, Richard Moss,1996
37
Alam, 1996

• The increase in flooding potential would aggravate flooding problems within the city. It
has been established during earlier flood events that the aggravation of flood situation in
the city has been as a result of backflow from the larger rivers which again could not
drain out excess water because of tidal influences. In the case of an increase in sea water
levels, this problem may get more severe thus putting the present and proposed flood
management system of the city under risk; and
• The associated problems of climate change leading to loss of land and livelihood for
economically disadvantaged people residing in the surrounding regions of Dhaka is
expected to result in creation of a large inflow of refugees into Dhaka, which is the only
large city in the area that can provide them alternative livelihood opportunities.
The concerns influencing the flood and drainage of can thus be summarized as:
BOX 2.11: FLOODING AND DRAINAGE ENVIRONMENTAL CONCERNS

• Increasing vulnerability of floods due to unplanned filling up of drainage
channels, wetlands, low lying areas and climate change.
The analysis above has helped to formulate the environmental priorities discussed below. It was
also clear from the above discussion that main causal links leading to environmental degradation
are institutional failures, lack of enforcement, policies which provide disincentives for
environmental conservation and governance constraints. These issues are discussed in Chapter 3.
2.6 FORMULATION OF ENVIRONMENTAL PRIORITIES
The situation analysis informed the identification of environmental priorities associated with
urban development in Dhaka that guided the SEA. As per the methodology adopted, the
shortlisting of priorities is the outcome of an analysis of the key environmental issues affecting
urban development in Dhaka, which were discussed in this chapter, and the degree of concern
attached to them by the stakeholders.
As said before, Dhaka’s environmental issues associated with urban development were identified
based on review of secondary information, visual surveys and discussions with stakeholders.
These issues summarized in boxes 2.3, 2.6, 2.8 and 2.11 were analytically assessed against the
following criteria:
• spatial and temporal extent of pollution;

• reversible/irreversible depletion of environmental resources;
• impacts of environmental degradation on vulnerable groups;
• existence and effectiveness of pollution control mechanisms.

This analysis led to a categorization of environmental issues as of having high, medium and low
level priority (see third column 3, table 2.1) These issues were also considered by the SEA
stakeholders that ranked them as high, medium and low priority concerns (see second column,
table 2.1). For the identification of priority environmental concerns, the perceptions of key
stakeholders, particularly the most vulnerable to environmental degradation, were assessed
through one-to-one meetings, focus group discussions and workshops following a public
participation and consultation plan for the SEA. At the Interim Workshop the stakeholders
ranked the concerns based on the order of priority of the concern. The stakeholders’ perception
was subsequently ranked into high, medium and low. Subsequently, environmental priorities
were categorized as high, medium or low priorities applying the criteria presented in the ranking
matrix of figure 2.5 (see fourth column, table 2.1)
FIGURE 2.5
RANKING MATRIX FOR STAKEHOLDER PERCEPTION[iflc9]
Analysis of stress on environmental
receptors
High Medium Low
Stakeholder
perception of High
dergree of
concern
Medium
Low
High Priority
Medium Priority
Low Priority
Table 2.1 shows the results of the prioritization exercise. The following are, therefore, the high
environmental priorities associated with urban development in Dhaka identified in this SEA:
• Surface water pollution due to discharge of untreated sewage & effluent.

• Depletion of ground water due to overdependence on ground water resources.
• Increasing vulnerability of floods due to unplanned foiling up of wetlands, low lying
areas and climate change.
• High urban densification in certain areas resulting in strain on urban services.

TABLE 2.1: ENVIRONMENTAL PRIORITIES IN DHAKA

3.0 URBAN PLANNING IN DHAKA
Urban planning can be closely linked with the improvement of quality of life of citizens in a city.
The quality of life again has a direct relate to the condition of environmental resources in an
urban area and the footprint that intense developmental pressure have on them. Urban planning
and the implementation of these plans through an appropriate institutional setup are critical to
influencing environmental priorities highlighted in the previous section. The soundness of the
overall urban development strategies, plans and programs and the effectiveness of their
implementation through an efficient and improved institutional setup would govern the success
of how environmental priorities will be addressed through a strategic planning framework as also
DAP level planning for Dhaka.
This chapter of the SEA would analyse the overall urban planning approach that has been
adopted for the Dhaka urban and peri-urban area comprising the DMDP area, the focus of the
regional plans in the form of the DMDP and the sectoral plans like strategic transport plan,
sanitation and sewerage master plan etc. along with the hierarchy of institutions involved, their
strengths and weaknesses. The existing coordination between the various institutions to take into
account cross-sectoral issues in the planning process has also been dealt with. This has been
followed by a discussion of the key stakeholders involved in the planning process and an
analysis of their influence on key aspects of planning. This chapter concludes with the analyses
of the plans and the institutions involved with reference to plan transmission mechanisms,
including governance considerations, institutional weaknesses as well as political economy
issues and how these factors affect the key environmental priorities.
3.1 OVERALL PLANNING PROCESS IN DHAKA
3.1.1 Policy Guidance
At the apex, the planning approach for development in Bangladesh flows from various high level
policies which are complemented by a host of legislations, strategies, plans and programs.
However, the Government of Bangladesh is yet to formulate a definite policy with the intent of
providing broad based guidance for urban development for key urban centres like Dhaka and
Chittagong. Presently, though an effort is being made through an ADB supported urban reform
program to formulate a National Urban Sector Policy to delineate the approach to be followed in
the process and guide the pattern of urbanization in Bangladesh.
There are certain other national and regional level policies which can be related to various other
aspects of urbanisation and are listed below:
• National Water Policy
• The Industrial Policy

• National Housing Policy

• National Environment Policy
• National Policy for Safe Water Supply and Sanitation
3.1.2 High level Planning Focus
The Bangladesh Planning Commission through the Five Year Development Plans (FYPs)38 also
played a role for setting the overall planning direction for growth and development of the
urbanized areas in the country. The Planning Commission acted under the general guidance and
control of the National Economic Council (NEC), which is the highest policy-making body in
matters of socio-economic development. The development planning of the country including
urban development was done through Annual Development Programmes (ADP) within the FYP.
Additionally, development projects initiated at the level of government agencies, divisions,
departments, local government bodies are channelled upward through the relevant ministries to
the Planning Commission. The administrative ministries concerned are authorized to approve
(under recommendation from the Planning Commission) projects involving costs up to a
designated level. Projects involving costs beyond that level are recommended to the Planning
Commission for consideration, approval and allocation of funds. However, at present Five Year
Planning has now been discontinued in favour of a long-term perspective plan.
3.1.3 Urban Planning for Dhaka
In Bangladesh, the concept of regional planning co-exists with a primary sector planning
approach. Regional plans in the form of Master Plans were first developed for large metropolitan
regions like Dhaka and Chittagong in the late 1950’s and 1960’s. The first Master Plan for
Dhaka was prepared in 1959, for 20 year period covering roughly 830 km2 with a target
population little over one million assuming an average annual population growth rate of 1.75%
in the city areas. However, the rate of growth of population of the city surpassed the plan targets
by almost three times even during the planning period i.e., in 1981 the population of Dhaka was
3 million. So by the time the thinking for a new master plan was initiated in the early nineties,
the earlier Master Plan had long become irrelevant.
During this time, RAJUK was established as a development and planning authority for Dhaka in
April 30, 1987 by replacing the Dhaka Improvement Trust (DIT) and was given the
responsibility for the metropolitan area of Dhaka covering an area of 1528 km2. During the early
nineties, RAJUK delineated a broad based Dhaka Metropolitan Development Plan (DMDP) with
38
After the fifth Five-Year Plan covering 1996–2001, the five-year development planning has been discontinued and planning has
been guided by a poverty reduction strategy paper or PRSP that was adopted in October 2005 for 2005–2015. However, unlike
the Five-Year Plans, the PRSP does not make any provision for urban and regional planning nor does it place any emphasis on
comprehensive development of cities.

assistance from the UNDP/UNCHS. The development plan for DMDP, prepared in 1995, has a
three-tier structure. They include: i) The Structure Plan - a long-term strategy (1995 – 2005);
ii) Urban Area Plan- interim mid-term strategy (1995 – 2005); and iii) Detailed Area Plans –
providing detailed planning proposals for specific sub-areas. The Structure Plan and the Urban
Area Plan was developed subsequently and notified in 1995.
The Detailed Area Plan (DAP) was conceived as the third and lowest tier of the DMDP planning
hierarchy shown in Figure 3.1. As per the design laid down in the TAPP document for
“Preparation of Structure Plan, Master Plan and Detailed Area Plan for Dhaka: (BGD/88/052)”
prepared with assistance from UNDP in 1990, the DAPs were to be prepared in house within
RAJUK after building adequate capacity planning in the planning department. However, due to
institutional failures and inability to develop internal capacity, the DAP preparation process had
been set back by more than ten years. Ultimately, the DAP preparation was outsourced to
consultants about two years back and is expected to be completed by August 2007. For the
purpose of DAP preparation, the entire DMDP area was divided into 26 Special Planning Zones
(SPZs) which was later consolidated in the form of five planning areas (see Table 3.1) after
combining the SPZs and the planning work has been awarded to four firms of consultants.

FIGURE 3.1: DMDP AND DAP PLANNING AREAS

TABLE 3.1: DAP ZONES AND CATEGORISATION
Specific Area Area (km2)

DAP Zones Covered Developed Developing Fringe Total
Tongi, Gazipur
Pourashava, Gazipur
Sadar and Rupganj
Group A Upazila 103 341 445
Narayanganj
and Kadamrasul
Pourashava, Bandar
Group B Upazila 26 198 224
Group C Most of the DCC area 186 21 207
Keraniganj Upazila
Group D 181 181
Savar Pourashava and
Group E Savar Upazila 62 254 316
Restricted Airport & Cantonment
Area39 69
Total 186 213 976 1445
3.2 REGIONAL PLANS – STRUCTURE PLAN & URBAN AREA PLAN
The Structure Plan and the Urban Area Plan (UAP) form the higher and middle level plans of the
DMDP planning framework and were completed in the early 1990s with the objective of
recommending measures for promoting balanced growth within the DMDP area. It was to be
followed up by the formulation of an extensive set of micro level detailed area plans (DAPs) for
different zones of the city. At the middle level though, the original intent was to actually prepare
a Master Plan, but that got altered to a UAP during the plan preparation process for reasons that
have not been fully explained in the planning documents. The non-preparation of a Master Plan
meant that higher level area wise development control was not incorporated into the planning
process thereby making the task of preparations of DAPs more difficult.
The intent of the Structure plan was to provide a long-term strategy (20 years) for the
development of the DMDP Area with a population target of 15 million. The Structure Plan thus
provides a policy level approach at two levels:
Spatial Policies: a set of policies that were attributed by geographic areas like pre-established
areas, urban fringe areas and areas demarcated for new development and looking into their uses
like agriculture, flood flow zones, flood retention ponds, special areas, etc. The Structure Plan
provided neither land use zoning nor any policy prescriptions that would direct subsequent urban
39
Restricted area comprises of the Cantonments and Airports.

development. In fact it was a series of guidelines which were either not mandatory nor were
instruments for implementation specified.
Sectoral Policies: a set of polices listed under their subject or sectoral headings like industrial
area development, informal sectors, institutional and public administration, transportation, etc.
The Urban Area Plan was subsequently prepared as a strategy document that was intended to
provide mid-term directions i.e. ten years for the planning of Dhaka. It was expected to be an
interim development management solution until the Detailed Area Plans were prepared. The
UAPs covered the areas of Flood Action Plan (FAP) components 8A and 8B as well as the
Tongi-Gazipur and Savar-Dhamsona areas.
Both planning documents emphasized suitable capacity building within RAJUK or the creation
of a new planning organisation for effective implementation of the DMDP planning concept. The
ambiguities and imprecision in the Plans, combined with the powers bestowed on RAJUK by its
constitution, allowed the latter to ignore the Plans and to engage with the private sector
developers to the benefit of both, but to the detriment of the environment. In the absence of any
institutional support for the Plans from RAJUK or any other planning agency, both have
remained static paper documents and have become redundant with time. Consequently, as a
fallout of non-implementation of the higher level plans, the preparation of the lower level plans
in the form of the DAPs have also got jeopardised.
3.2.1 Detailed Area Plans
The Detailed Area Plans (DAPs) which are currently under preparation for five sub-areas within
the DMDP are supposed to build more detailed planning provisions for each specific sub-area
and be in compliance with the Structure Plan and the Urban Area Plan. At the same time, the
DAPs are expected to forge close linkages with various sectoral plans as may be relevant to the
specific area. Importantly, till the DAPs are prepared for each sub-area and notified, land use
management functions are supposed to be exercised through the policies, guidelines, and rules
found in the Structure Plan and the Urban Area Plan. However, with more than ten years of gap,
these guidelines and rules at the higher level have become irrelevant because of fast paced
unplanned development witnessed by Dhaka. Furthermore, RAJUK did not undertake any in-
house planning capacity enhancement as recommended in the UAP. As a result, the DAPs are
now being executed by RAJUK through external consultants mainly as a standalone project.
Reviews of the current DAP planning process have brought to light the following issues:
• The DAP preparation is not guided by appropriate strategic level planning framework as
the Structure Plan and the Urban Area Plan do not have any relevance at present. As a

result, the DAPs for the five zones would not reflect a regional development approach for
the overall development and growth within the DMDP area.
• The DAP planning process was found to have a very weak interface with the sectoral
planning agencies and as a result, is unlikely to produce a plan that can be seamlessly
integrated with the sectoral strategies and plans. This is because, on one hand the
Technical Management Committee which was charged to oversee plan preparation was
ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared. On
the other hand, the DAP consultants have also been unable to establish useful contacts
with sectoral agencies for formulating respective sectoral aspects of the local level plans.
In addition, as many of the sectoral plans do not have coverage over the entire DMDP
area, especially the fringe areas, and therefore the DAPs for these fringe areas do not
have any sectoral planning guidance at all.
• In our assessment, the Terms of Reference for the preparation of the DAPs are extremely
ambitious and under-resourced; and the local consultants selected for plan formulation do
not appear to have the technical capability or expertise to complete the task.
• The DAP consultants have not been provided any guidelines on demarcation of sensitive
areas where urban development should be restricted because of environmental and flood
related sensitivities (wetlands, flood flow zones, retention ponds, canals and drainage
channels) which may lead to faulty demarcation on land use maps and thus putting such
zones at risk.
• Furthermore, the DAP consultants appear to have limited understanding of the pollution-
intensive nature of industrial growth in the watershed which is greatly responsible for the
degradation of the water resources. Consequently, there is little appreciation of the need
for spatial zoning of industries which should be done in consultation with industry.
3.3 SECTORAL PLANNING
Sectoral planning in the urban areas of Bangladesh run mostly as a parallel process with a weak
interface to urban or regional development plans. As a result, most of the sectoral plans
concentrate on finding localised and short term solution to urban problems in a particular area
within the DMDP. In many cases, the sectoral organisations do not have the mandate to provide
services throughout the entire DMDP area resulting in exclusion of some areas like those falling
under Municipalities and Pourashavas. As a result, these bodies formulate disjointed and
fragmented sectoral plans for their own areas which often do not conform to the higher level
sectoral policy and planning guidelines. In the section below, the key sectoral plans that relate to
the environmental issues of concern are briefly discussed.

3.3.1 Water Supply
The Dhaka Water Supply and Sanitation Authority (DWASA) is responsible for providing water
supply within the DCC and Narayanganj municipal areas. In the remaining four municipalities
i.e. Savar, Tongi, Gazipur and Kadal Rasul, the responsibility is with the respective urban local
bodies. The DPHE is responsible for planning and commissioning of water supply schemes in
areas outside DWASA areas. DWASA is also planning to include Gazipur, Savar, Tongi Ruganj
and Purbachal in its service area.
The DWASA water supply strategy aims at providing clean water supply in its service area i.e.
DCC & Narayanganj and presently provides for about 1.5 BLD of water to the Dhaka water
supply system. The strategy proposed for the water sourcing in the short term (till 2010) is
primarily dependant on groundwater sources. It has proposed that 231 MLD would be extracted
from the deeper aquifers, to be implemented under the Dhaka Water Supply Project; while 131
MLD would be extracted from the arsenic free aquifers of Singair Upazila (25 km from Dhaka).
However in the medium term (till 2015), DWASA intends to rehabilitate and augment the
Saidabad WTP to increase treatment to 675 MLD from the present 275 MLD. In addition, to
meet the additional supply requirements DWASA plans to develop four new treatment plants at
Purbachal, Khilkhat, Keranigonj and Pagla I as also source water from Padma and Meghna.
As a long-term strategy, the authority plans to source water from Meghna (17 km) and Padma
(45 km) by 2015 and 2020 respectively. The plan also aims at providing 100% water supply
coverage to the urban poor as indicated in the Dhaka Water supply guidelines recently published
by the Government of Bangladesh (GoB). Further in an effort to manage water resources,
DWASA intends to reduce the operational losses from leaks in pipes and has made roof top
rainwater harvesting mandatory in the clearance provided to private housing and land
developers.
The urban local bodies in the DMDP region intend to extend the coverage area of the water
supply network to the entire municipal/jurisdictional areas. However they have not yet developed
any master plan for this purpose. There are also no current plans to utilize surface water sources
in the pourashava areas and fringe areas.
3.3.2 Sewage and Sanitation
Planning for sewerage and sanitation sector has been traditionally a weak area compared to other
aspects of urban planning in Dhaka and its adjoining areas. The Dhaka Master Plan of 1951
prepared by Dhaka Improvement Trust (DIT) or the DMDP Structure / Urban Area Plans did not
lay emphasis on the sewerage sector and did not take into account the extensive urbanization of

the city and related contextual problems that may arise in this sector. More recently, the National
Water Policy 1999, mandated that relevant public agencies would be responsible for
management of the sewerage and sanitation facilities in cities and urban areas and the emphasis
on building necessary sewerage and sanitation infrastructure was also reiterated by the
Millennium Development Goal set by the Bangladesh Government.
Similarly, when the DWASA was set up in 1963, as a public sector utility to cater for potable
water, sewerage and storm water drainage for the city, it prepared a Sewerage Master Plan on the
basis of maximum of 2-story housing which became irrelevant with time and rapid rate of rise of
population. In the late nineties DWASA carried out a number of feasibility studies to look into
ways of improving the sewage management in the city and based on the results has subsequently
launched a number of augmentation projects, both for increasing the sewer network and also for
treatment of sewage at new sewage treatment plants to be set up. As part of these efforts to
augment the sewer system in the city, five new sewage treatment plants (Diabari, Tongi,
Uttarakhan, Baderteik and Kamrangir Char) along with pipelines and ancillary structures are
planned to be developed. An initiative has also been undertaken to promote integrated water
pollution management in the watershed of the DMDP region. Recently two initiatives namely
Dhaka-Chittagong Water Supply & Sanitation Project and Dhaka Integrated Environmental
Water Resources Management Project (DIEWRM) are being undertaken with assistance from
the World Bank. Under these projects the sewage master plan would be updated along with
improvement and rehabilitation of the sewage system in Dhaka along with construction of new
sewer lines and treatment plants. A number of other activities would also be undertaken for
improvement of the storm water drainage and treatment of industrial effluent under these two
funding initiatives.
However, till date, there is no updated Master Plan for waste water management of Dhaka that
takes a comprehensive look at the problems of sewage management in the Dhaka urban area. A
bidding process has currently been initiated by DWASA under funding support from
International Development Association (IDA), to prepare a Master Plan for this sector.
In terms of providing low cost sanitation for the economically disadvantaged section of
population, the sanitation policy40 recommends the development of individual and community
latrines for providing sanitation facilities in slums and other informal settlements but such efforts
are yet not prominent in the DMDP areas. The development of such sanitation facilities have
been further emphasized in the National Water Management Plan, 2001 which recommends
individual and local community facilities e.g. pit latrines, household latrines with septic tanks,
community sanitation facilities and small bore sewerage system. However, no major initiatives
40
National Policy for Safe Water Supply & Sanitation, 1998

have yet been taken in the city or in the peri-urban areas for development of community latrines
and other sanitation facilities in slums and other informal settlements.
3.3.3 Drainage and Flood Protection
Planning for flood prevention and mitigation has been an area of high priority in Bangladesh
because of the country’s high vulnerability to floods during the monsoon season. The causes for
such vulnerability can be mostly attributed to natural causes with topography in a large part of
the city being 2-3 metres above sea level and the high rainfall the area receives from the
southeast monsoon system. This vulnerability is likely to increase with impacts of Climate
Change being felt all around the world. Most of the low lying areas in Bangladesh are likely to
be submerged or remain under water for several months in a year. This calls for urgency in
implementing coordinated flood prevention and mitigation programs to combat this issue.
The National Water Management Plan41 drawn up by the Water Resources Planning
Organization (WARPO) has clearly indicated that gravity-based drainage should be given
preference for draining storm water from complex urban centres like Dhaka. The same principles
have been reiterated in the DMDP Structure Plan42, where special emphasis has been laid on the
protection of the natural drainage systems e.g. water channels and ponds and reduce dependence
on the mechanical systems e.g. pumping out of water after flooding being a reactive response to
the problem.
To protect the city against floods, a number of other plans and programs have been prepared.
Prominent among them are FAP-8A & FAP-8B prepared for the BWDB by consultants under
funding support in the early 1990’s. After the floods of 1988, the FAP 8B was implemented and
as a result the western embankment was prepared under the Dhaka Integrated Flood Protection
Project. In addition to the embankment, three pumping station were constructed and one
retention pond have also been developed.
However, the FAP 8A has not yet been implemented due to lack of funds. To reconsider the
project, the BDDW has recently conducted a study that looks at the integration of the Eastern
Bypass Multipurpose Project with the Eastern Embankment Project.
The principal organisations responsible for flood control are NWRC, WARPO, BWDB, LGED,
RAJUK, and IWM. In addition to the above institutions, the organisations responsible for urban
flood also are DWASA, Pourashavas and DPHE as they are involved in the storm water
management in their respective areas of control. In the case of river floods even though there are
41
National Water Management Plan, 2001, WARPO
42
The DMDP Structure Plan (1995-2015)

a number of institutions who have authority, no coordination between these organisations exist
because of the absence of an apex organization coordinating these efforts.
3.3.4 Transportation
The Strategic Transport Plan (STP) documents i.e. DITP and DUTP have stressed on the need
for development of a road based transportation system for the city. Similarly the Structure Plan
in 1995 has also stressed on a road based transport system, but considering a long-term strategy
it has also highlighted the need for development of inland water transport as a parallel mode of
transportation.
Moreover, in 2005 the apex planning document43 recognizing the major role played by the road
sector in expanding44 the passenger movement in Bangladesh stressed on the need for shifting
the focus of promotion of transport infrastructure in urban centers from road based surface
modes. It points out the limitations of expanding the surface modes of transport in an urban
center like Dhaka where the ownership of vehicles is increasing more rapidly than the population
growth of the city. Taking into consideration the regional focus, the Strategic Transport Plan was
developed for the entire Greater Dhaka Region45. The plan was formulated to bring about a
coordinated planning in the transportation sector in the region. The plan has stressed on
development of a multi-modal transport system for the city with a combination of roads, bus
rapid system and a rail based mass rapid system. A number of new roads have been proposed
including a major east-west link and peripheral roads which would reduce the transportation
problems in the city. However, due to the high cost involved in developing an underground
metro system, it is not presently considered to be a priority.
Even though the transport sector has developed a regional approach in planning with the
development of the Strategic Transport Plan and formulation of the Dhaka Transport
Coordination Board some of the municipalities in the DMDP region have developed their local
transport master plan, under the UGI Project funded by the ADB, without any interaction with
the DTCB. Such misdirected planning would severely affect the gains from the regional plan.
3.3.5 Solid Waste Management
The Dhaka City Corporation Ordinance, 1983 and The Pourashava Ordinance, 1977 have
entrusted these institutions with the function of removal and disposal of solid waste in their
respective areas. These regulations however do not make it binding upon the institution to
43
Unlocking the Potential , The National Strategy For Accelerated Poverty Reduction, October 2005
44 The passenger movement has increased from 35 billion passenger km. in 1984/85 to 72 billion passenger km. in 1996/97
45
It consists of the area between the Padma and Meghna Rivers . The area contained between the V shape formed by the
confluence of the two rivers is wholly contained within the Dhaka division and comprises of six district namely Dhaka,
Ghazipur, Narsingdihi, Manki ganj, Munshiganj and Narayanganj.

undertake house-to-house collection, transportation, treatment and disposal of waste. Thus,

management of solid waste has been weak in the city and also in the fringe areas. There are no
regulations in Bangladesh for management of either Municipal Solid Waste or Hazardous and
Bio-Medical Waste.
The apex-planning document46 recognizes solid waste management and untreated industrial
waste disposal as major problems of urban environment and emphasizes the development of a
solid waste management system for reduction of environmental problems. The regulatory
framework must be strengthened and implemented strictly with provisions for proper and
adequate incentives to entrepreneurs to ensure that all industrial wastes are properly treated
before disposal.
The Clean Dhaka Master Plan 2005 that has been adopted by DCC encourages collection of solid
waste from households but does not place any added emphasis on segregation of waste and
treatment/ recovery of the waste. Composting as a method of disposal is well recognized and has
been successfully implemented by “Waste Concern” an environmental NGO. It has introduced
Barrel Type composting in slums and traditional composting in non-slum areas in two wards in
the DCC area. However in other areas, no such initiatives have been taken or have been
encouraged by the Clean Dhaka Master Plan. Many of these areas still depend on dumping of
MSW directly to the existing dumping sites.
3.3.6 Industrialization
Though there are no heavy manufacturing industries in the DMDP area, the number of pollution
intensive industries has grown rapidly in the last decade. The effluent and emissions from the
existing small and medium scale industries are a major reason for water and air pollution in
Dhaka. The Environment Policy 1992 and the Environment Conservation Act 1995 has laid
strong emphasis on the control of industrial pollution. The policy states that a systematic
environment assessment has to be undertaken before starting any industrial operation. Guidelines
for project level Environmental Impact Assessment were also established drawing power from
the Environmental Conservation Rules, 1997.
All projects are categorized into one of four groups: Green, Orange A, Orange B and Red. The
environmental clearance applications submitted by the project proponent are verified47 by the
46
Unlocking the Potential , The National Strategy For Accelerated Poverty Reduction, October 2005
47
For Green and Orange A category projects, once the inspector submits his report (typically within 5-7 days) the divisional head
makes a decision within three days of receiving the report. Files for Orange B and Red category projects are sent to the Senior
Chemist/Assistant Director.

divisional offices and sent to the Environmental Clearance Committee of the DOE48 in Dhaka
and then passed on to the Director General for clearance. The clearance conditions make it
mandatory to renew the environmental clearance annually, but this aspect of legislation has not
been enforced. The Environment Assessment process also requires the project proponent for
industries to obtain site clearance before initiating any construction activity on the ground.
However, the process has proved to be ineffective because of technical in-competencies in DOE
and due to collusive relationships between industry and the DOE.
Even though the DOE has initiated some modification to the legislations e.g. Environment Court
Act 2000 (amended 2002) to ensure stricter compliance with environmental legislation, there has
been no initiative by the department to enact legislation in some important areas e.g. Treatment
and Disposal of hazardous waste, Siting Guidelines of Industries, Management of Solid Waste
(Municipal and Industrial), Effluent Discharge Standards for various types of industries etc.
3.3.7 Housing and Slum Improvement
The need to provide housing for the low income group was recognised in the Structure
Development Plan. Annex-B of the Plan provides the principles for Guided Land Development.
Among others, it notes that the demand for low income housing should be met. Clearly this has
not happened.
More recently, for low income groups, the National Strategy for Accelerated Poverty Reduction
(PSRP) links inadequate housing as one of the reasons for poverty. It considers housing problem
of the poor as an integral part of poverty reduction programme and recommends a number of
strategies like provision of housing loan at cheaper rates and stress on implementation of
program for resettlement of slum-dwellers, the disadvantaged, the destitute and the shelter less
poor. The government has also initiated a housing loan scheme, called the Housing Fund with
the intent of improving the quality of life of the poor people by providing loans to construct safe
and durable houses. However, even though the apex plan and programs lays stress on the
housing problem, there have been no follow up action at the action plan level to address the
requirements of housing for the urban poor and vulnerable sections of the society. NGOs and
Civil Society Groups have also not taken up any worthwhile programme in this regard.
In several Asian countries and in the UK the problem is being tackled more directly and
effectively. Real estate developers are required to allocate a specified proportion of land being
developed for low income housing. RAJUK, as the main urban development authority, has set no
48
DOE offices in each of the six divisions receive applications and issue Environmental Clearance Certificates for proposed
investments within that division. The divisional offices verify supporting documents and pass it on to the divisional head,
who assigns an inspector for follow-up

such stipulations on the developers. This is explicable by the fact that it is not so profitable to get
involved in the provision of low income housing.
3.4 INSTITUTIONAL SET UP FOR GOVERNANCE & URBAN PLANNING
Bangladesh is a parliamentary democracy with the president as the head of state and prime
minister and council of ministers in charge of the executive functions49. The ministries and its
associated bodies responsible for policy formulation and execution are presented in Figure 3.2.
At the same time, local self-governance is also encouraged in the constitution.
A number of ministries and associated departments are involved in the planning and
administration of Dhaka. As many as 55 organizations of national, sectoral and local levels are
effectively involved in planning and development of urban affairs in Dhaka Metropolitan
Development Area.
The key functions of urban planning and development is with two ministries and a wide range of
central department’s, utility agencies, development authorities and urban local bodies. The two
ministries primarily responsible are Ministry of Housing & Public Works (MoW) and Ministry
of Local Government, Rural Development and Cooperatives (MLGRD). Physical planning,
development, control, and housing functions are under the MoW, while urban utilities,
infrastructure and urban administration are the responsibility of the MLGRD. Urban programs of
the MOW are implemented through the Public Works Department (PWD), the Urban
Development Directorate (UDD), and the Housing and Settlement Directorate (HSD).
Among the other institutions involved in planning and implementation of the city management,
the more comprehensive responsibilities lie with RAJUK and DCC. Other organizations have
specific sectoral roles and responsibilities e.g. National Housing Authority - housing, Dhaka
Water Supply and Sanitation Authority (DWASA) - water and sewerage, Road and Highways
Department (RHD) - major intra and inter city roads, the Dhaka Metropolitan Police (DMP) -
traffic management and maintenance of law and order; and the Department of Environment
(DOE) - Environment.
49
Interim Government: Bangladesh is presently being governed by an Interim Caretaker Government which is headed by the last
retired Chief Justice of the Supreme Court as its Chief Advisor (with status of Prime Minister) and advisors with status of
ministers assisting him with governance.

Figure 3.2 : Urban Governance Setup & Flow of Authority[iflc10]
The design and development of water supply and sanitation systems is the responsibility of the
Department of Public Health Engineering (DPHE), except for Dhaka and Chittagong, where
autonomous Water Supply and Sewerage Authorities (WASAs) are operational. These
authorities are independent of the local municipal governments and their Chairman reports
directly to the Secretary of the MLGRD. Maintenance responsibilities of most of the physical
infrastructure built by the developmental authorities are passed on to the local governments.
In addition, two kinds of local government institutions operate in the urban areas of Bangladesh
and share responsibilities with the other department and agencies for the urban planning and plan
implementation functions. Municipalities (locally called Pourashavas) or Corporations form the
urban local body and operate under the jurisdiction of the MLGRD. In addition, special purpose
developmental authorities like the Rajdhani Unnayan Kattripakha (RAJUK) for the larger cities
have been created under the MoW and are charged with the preparation of master plans and have
legal powers covering developmental planning and execution. [iflc11]These development
authorities can also undertake infrastructure works and land development together with estate
management of commercial and residential schemes. The interactions between the planning and
administrative institutions have been illustrated in the Figure 3.3 below.

FIGURE 3.3 : INTERACTION BETWEEN PLANNING INSTITUTIONS
RAJUK Pourashavas, City

Corporation,
Union Porishods
Sectoral Agencies
(DWASA, BTWA,
DOE, etc
However, in practice, coordination and sharing of information pertaining to planning and plan
implementation between various agencies have been very weak and non-transparent. Though the
mandate of RAJUK was to build such coordination between various other departments and local
bodies and develop common strategies for urban development in Dhaka, RAJUK has been
unable to perform its role in this direction because of absence of leadership.

FIGURE 3-4 : PRINCIPAL AGENCIES RELATED TO URBAN PLANNING IN DMDP REGION
3.4.1 RAJUK – An Institutional Analysis
RAJUK was established in April 30, 1987 by replacing Dhaka Improvement Trust (DIT) as the
development authority for Dhaka Metropolitan Development Plan area and has been accorded
legal powers for developmental planning and execution.
At present, RAJUK is the key urban agency responsible for overall planning for the DMDP area in
coordination with other sectoral agencies. It is also responsible for the formulation and monitoring
of the Detailed Area Plans (DAPs) in accordance with the overall guidance provided by the higher
level plans (Structure and Urban Area Plans).
The main functions of RAJUK include:

• Responsibility for planning and development of the city in consideration of the existing
policies and the multi-sector investment programs of different related agencies.
• Undertake activities like construction of roads, culverts and bridges and also development,
excavation, and filling of land as required for the development of Dhaka.

• Project level planning and design (including conceptual design, selection of materials,
design and construction codes and standards, etc.), feasibility studies, project programming
and time scheduling etc.
• Exert development control as per the provisions of the Building Construction Rules; this
includes providing approval for new area development, land filling, etc.
• Approve any use of land or any type of construction by issuing land use clearances from its
authorized sections.
• Provide metropolitan development management leadership, and is entrusted with
development of strategic planning function and promotion of poverty alleviation-oriented
programs.
RAJUK is now a public body managed by a board comprising of a chairman and not more than
five members. The chairman is the principal executive of RAJUK and the other members are
government officials. All members of the Board are full time officials with specific responsibilities
within the broad framework of the organization set-up having five different divisions. The
approved organization structure of RAJUK along with estimated number of staff per division is
presented in Figure 3-5 below:
A review of the organizational setup of RAJUK indicates that the division responsible for
development has staff strength of about 50% of the total staff followed by the planning department
with about 28% staff. However, within the planning division, only the planning department is
primarily responsible for the DMDP plans and therefore for formulation of the DAPs. Though
there are 51 approved staff for this department, in effect, there are only 4 planners in RAJUK to
plan and also oversee the DAP planning process for an area as large as 1,500 km2.

FIGURE 3-5
RAJUK ORGANIZATIONAL STRUCTURE
RAJUK - SWOT ANALYSIS

STRENGTHS
• Mandated to be principal planning authority for the entire DMDP region and have been
legally accorded powers to fulfill the mandate.
• Broad based regional level planning has already been undertaken under RAJUK and
notified in the form of Structure Plan and Urban Area Plan. The plans are supposed to
govern urban development of Dhaka till 2015.
• It is a cash rich organisation as its collection rate is high. Its main sources of income are
from selling and developing commercial plots; land auctions; interests from deposits put
down by prospective buyers; fees for providing planning permission; penalties levied on
illegal construction; and from interest earned when fees and fines are not paid on time.
WEAKNESSES
• Weak ownership of the DMDP plans.
• The planning department of RAJUK is under-resourced and not appropriately staffed.
• The five members of RAJUK are direct central government appointees, some of whom have
little background in urban planning and development. These direct appointments have led to
the politicization of membership.
• It has transformed into a centralized organisation with limited reach at the ground level
resulting in weak implementation and supervision of the plans.

• RAJUK was mandated to build coordination between various departments and local bodies
and develop common strategies for urban development in Dhaka. It has been unable to
perform its role in this direction because of absence of leadership.
• Has a poor track record of coordination with the other planning and implementing agencies.
• Has been ineffective in formulating detailed development control guidelines on number of
critical aspects, including demarcation of areas to be land filled, sensitive zones, etc.
• There is an un-questioning and uncritical approach to implementation among the senior
bureaucrats and professionals.
OPPORTUNITIES
• Has been provided the authority to sanction plans in the entire DMDP area under the
Building Construction Rule 2006.
• The Planning wing is being gradually revived and currently DAPs are being prepared under
the supervision of this department.
• The formulation of DAPs is an opportunity to amend policies and improve overall urban
environmental management.
THREATS
• Acts both as planner and developer, resulting in conflicting roles.
• Has conflicting roles with Pourashavas and DCC with respect of land development and
permitting;
• In perception of the stakeholders, it has not taken adequate initiatives in improving the
city’s environment or the quality of life of the citizens, especially the poor and the
vulnerable.
• Stakeholders are of the opinion that the organization’s actions favour the powerful sections
of the society with political influences and its staff is therefore prone to engaging in corrupt
practices.
In addition, an analysis of the overall institutional setup for urban planning highlighted the
following weaknesses in the system which impedes effective planning for the DMDP area:
• While the Planning Commission is responsible for allocating government expenditure

and approving high value urban development projects, it generally does not coordinate at
a level below the national level. As a result, funds for urban development within DMDP
area are allocated to multiple agencies, including the urban local bodies, leading to some
plans working at cross-purposes.
• Major urban functions are distributed between two different ministries (MOHW and
MLGRD), neither possessing lead powers for urban development. As a result, a major
institutional conflict arises from the distribution of key urban activities between these
ministries. Even though planning, housing, development control and certain land
development functions are carried out by the MOHW through RAJUK, some of these
activities are also undertaken by the urban local bodies which are under the MLGRD.
Thus in absence of a body with appropriate legal and financial powers, there are no over-
all planning and implementing mechanisms.

• The inability of RAJUK to play a leadership role in urban planning and exercise strategic
influence on other sectoral agencies has resulted in other agencies taking up planning
initiatives on their own without any coordination with RAJUK. In addition, coordination
between the various agencies (more than 55 in number) is very poor in spite of having
overlapping responsibilities and a role to play in terms of planning or plan
implementation in Dhaka.
• The government agencies and urban local bodies who have jurisdiction of the DMDP
area have inadequate capabilities of urban governance and lack of transparency in terms
of planning and project implementation. In many cases distinct vested influences in
governance can be observed in favour of interest of people close to power and especially,
the members of the ruling political party.
• The Ministry of Environment and Forests in general and the Department of Environment
in particular, lack the resources and trained manpower to effectively monitor compliance
with environment management and pollution control legislation, even at the Dhaka level.
They also do not have the power to play the role of a watchdog agency, especially when
other government agencies (for example DWASA) are in non-compliance with standards.
3.5 ANALYZING STAKEHOLDER INFLUENCE IN PLANNING AND PLAN IMPLEMENTATION

PROCESS
The prevailing urban planning process did not attach much importance to the views and opinions
of key stakeholders thus promoting a system that was neither transparent nor accountable to the
stakeholders of concern. As one of the objectives of the SEA process is to factor in the opinions
and concerns of relevant stakeholders into the planning process and make it more responsive to
their needs, it was planned to carry out a systematic analysis to understand their stakes or
interests, the importance of their priorities and the extent of influence they can bear upon the
urban planning process.
The analysis can also be considered to be significant because for the first time, the DAPs
currently being prepared in parallel emphasize on establishing a more inclusive planning process
for local level plans through a process of consultations with all stakeholders who may benefit or
may be affected by implementation of such plans. Hence, it was felt that the stakeholder analysis
would provide a clearer understanding of the current status of the stakeholders, vis-à-vis the
planning process while at the same time equip the SEA process with vital information on their
capacity to facilitate or oppose reform in urban planning and bring about environmental
improvements through recommendations that emerge from this study.
The result of the stakeholder analysis is presented in the form of a Stakeholder Matrix in Figure
3.6 and main stakeholder-wise findings are also briefly discussed in the section below.

FIGURE 3.6: STAKEHOLDER ANALYSIS MATRIX[iflc12]
• RAJUK: Though RAJUK was mandated to play the role of the apex planning institution
for the Dhaka DMDP area, it did not build up internal capacity to undertake urban
planning for a rapidly growing and complex city like Dhaka. As a result of this inability
to mature into an institution for formulating strategic and regional level plans for the
DMDP area and continually adjusting them when required according to ground realities,
it has been unable to exercise its leadership role and bring about coordination between the
numerous sectoral agencies and departments responsible for urban development in
Dhaka. Gradually the focus and the priorities of the organisation have shifted to the more
lucrative functions and it now takes more interest in development and approving related
work, in the process it has downgraded its own position as the apex planning authority for
DMDP area. Consequently, it is now accorded considerably lower importance in the
planning process of the DMDP region. In addition, though RAJUK is successful in
exerting some influence on the development pattern of Dhaka because of powers vested
in it through legislation, stakeholders consider such influence to be primarily favouring
powerful and economically stronger sections of the society, thereby weakening its neutral
standing and credibility as a planning and development organisation.
• Urban Elites and Realtor Groups: The urban elites and the realtor lobby have been
able to incorporate their priorities into the planning process, sometimes by circumventing

legislative provisions which do not favour them. This is in spite of the fact that they form
a small percentage of the urban population. They have also been able to leverage the
planning process in their favour by maintaining close ties with the elected representatives
and by influencing the administrative setup, sometimes by using unfair means and tactics.
• Technical / Academic Institutions[iflc13]: The technical and academic institutions who

could have played a important advisory role by providing technical support to urban
planning process and also at the same time, could have played a neutral role in
monitoring their implementation, have been unable to do so because they lack influence
on the administrative setup. For example, important institutions like the Bangladesh
University of Engineering and Technology (BUET) or its alumni have been unable to
make any significant contribution in the DMDP or DAP plan preparation process or its
monitoring and supervision in spite of having a regional planning department.
• Department of Environment (DOE): DOE is mandated to be the agency responsible for

protecting the environment, but lacks the importance that should be accorded to a
monitoring and watchdog institution as per various environment legislations, including
the Environment Conservation Act. This is largely because DOE has failed to be an
effective monitoring agency. Moreover, given the low priority that is accorded to
environmental issues by various other government agencies and other stakeholders like
industrial operators, and lack of internal capacity to highlight such issues to the
stakeholders of concern for taking priority action, it is also unable to exert its influence to
implement environmental protection measures in general and specifically those which are
related to urban development in Dhaka.
• Vulnerable and Economically Disadvantaged Groups: In spite of forming the majority

of Dhaka’s urban population, they have traditionally been accorded very low importance
and bear minimal influence on Dhaka’s urban planning process. The reason can be
attributed to the fact that a significant percentage of them are migrants to Dhaka and do
not have voting rights. [iflc14]As a result, in spite of making a considerable contribution to
Dhaka’s economic growth and making provision for much needed urban services at very
low costs (housemaids, waste pickers, rickshaw pullers) their efforts are often not
recognised by stakeholder groups who are powerful and influential and are considered to
be a part of a large informal system. They can exert little or no bargaining power with the
political and governance system to win their basic rights pertaining to housing, water,
sanitation, health, electricity etc. for living decently within the city.
• Civil Society Organisations: The Civil Society Organisations have not yet been able to
build a strong case for environmental protection and improvements and get sufficient

support from the masses or affected stakeholder groups to build pressure on the
government setup or on players contributing to environmental degradation. Part of the
problem seems to be the low levels of education and environmental awareness among a
large section of Dhaka’s urban population.
3.6 ANALYSIS OF PLANNING FRAMEWORK IN CONTEXT OF ENVIRONMENTAL PRIORITIES
Analyses in the previous sections have shown that a large number of institutions and sectoral
agencies can influence the nature of urban growth and the environmental priorities in Dhaka. It is
necessary to understand the strengths and weakness of the different plans and institutions.
Additionally, an insight is required into the causative institutional and governance factors which
have prevented the formulation and/or the implementation of most plans; thus leading to
environmental degradation. These understandings will inform the design of interventions that
address the weaknesses and governance issues.
This section analyzes the linkages between different components of the planning framework,
their associated institutions and the perception of stakeholders with respect to the environmental
priorities.
3.6.1 High urban densities and strain in urban services
The DMDP Structural Plan has provided directives to optimize land resource development
through infilling of under-utilized land, redevelopment of land in lower density communities and
upgrading of the physical and social infrastructure to affordable and appropriate levels in
accordance with densities. The Structural Plan has also emphasized the densification targets
which accompany infrastructure consolidation targets for development of fringe areas and new
urban growth areas. Though the onus of directing the development was primarily with RAJUK,
being the apex planning authority in DMDP, these policies have failed. RAJUK has found it
inconvenient to prioritize any development area for improvements in Developing and Fringe
Areas as most illegal land-filling are found in these areas. Majority of the urban growth is only
restricted in the developed area, as a result there is severe stress on physical and social
infrastructure in the already over-crowded area.
Coordination with different sectoral agencies for development of physical and social
infrastructure in the Developing and Fringe Areas and planned urban growth in these areas was
to be carried out by RAJUK. The sectoral agencies being under different ministries, RAJUK has
very little influence over these agencies, hence, the inputs of these agencies in the planning
process has not been available. The absence of any agency in DMDP, which wields powers

cross-cutting all ministries has resulted in comprehensive regional plans not being developed for
Dhaka.
Local level plans i.e. DAPs, which are expected to delineate the land use, infrastructure
development etc., have been delayed by more than ten years. Thus, the city has developed
without micro-level planning during the last decade. Therefore, certain areas within the city have
witnessed increased overcrowding; new areas developed in the Fringes Areas are mainly low
lying and are inundated each year by floods. Furthermore, land development activities have
resulted in filling up of wetland and low lying areas with consequent loss of natural features e.g.
sink for storm water runoff.
Legislations have been developed in Dhaka to control problems through the Building
Construction Rules 2006 and the Land Development Act 2004. Even though the Rules are
comprehensive and can be effective instruments for controlling development throughout the
watershed, the implementation of the Rules has been delayed. Stakeholders feel that the
influences of vested interests on the implementing agency as well as the conflict between
jurisdictions of the local bodies and RAJUK have set back the planned development process. The
conflicts in jurisdictions of the agencies arises from the planning and approval powers provided
to the local government under the Town Improvement Act and the Building Construction Rules
which have designated RAJUK as the sole authority for issuing permits within DMDP area.
To control development of the Fringe Area the Land Development Act makes it mandatory for
the private housing infrastructure developers to take permission from RAJUK after clearly
delineating the level of filling required and demarcating and developing appropriate plans for
protecting natural drainage channels. This act could have been effectively used for regulating the
unplanned filling in fringe areas and address the associated problems due to changes of
topography of the area. However, lack of political will of the implementing agency has resulted
in these legislations being unable to control the unplanned development in the fringe areas.
3.6.2 Surface water pollution due to discharge of untreated sewage & effluent
The issue of surface water pollution in Dhaka which has been identified as a priority in the SEA
has been addressed through the existing planning framework primarily through the spatial plans
(e.g. DMDP Structure Plan), Sectoral plans (e.g. DWASA Sewerage Master Plan, ad hoc
sanitation plans of Pourashavas) and national level policies and legislations.
National Policies have mandated treatment of sewage before discharge and have directed local
bodies to develop sanitation facilities within their areas of jurisdiction to protect surface water
bodies from pollution. The DMDP Structure Plan stresses the prevention of pollution of surface

water sources around Dhaka so that they can be used as a sustainable source of drinking water.
However, no regional plans have been formulated for abatement of surface water pollution in the
Dhaka Watershed. Though some sectoral plans like the DWASA Sewerage Master Plan have
been formulated and this has planned for coverage of the DWASA service area through sewer
networks and also for construction of five new STPs. Since this infrastructure has only been
planned for the DWASA service area (developed area) it would cover only 30% of the DMDP
area. In areas outside DWASA service area, under the local bodies50 (developing and fringe
areas) ad hoc plans based on low cost sanitation facilities are being prepared because of the
institutional incapability in formulating plans for sewerage of the area under their jurisdiction.
Thus large areas of the DMDP comprising of the developing and the fringe areas do not have any
plans for treatment of sewage clearly indicating that transmission of policies into plans in DMDP
has been weak, and also indicating that no single agency is responsible for planning for sewerage
in the entire area.
Some programs e.g. Dhaka Chattagong Water supply & Sanitation Program which includes the
construction of a CETP for Tejgaon and the Dhaka Integrated Environmental Water Resources
Management Project[iflc15] for management of industrial wastewater in Dhaka watershed have
been formulated. Even though these are positive steps, it has been observed in the past that lack
of incentives for involvement of stakeholders in these programs has often resulted in limited
success of these projects. A case at point is the scheme launched recently by DOE whereby the
industries have been provided with incentives in the form of reduced duties on imported
equipment for installation of effluent treatment mechanism. The scheme met with limited
success, as there were no disincentives for the industries to discontinue from the present process
whereby they can externalize the cost of treatment.
The Environment Conservation Act 1995 (amended) also emphasizes control and abatement of
environmental pollution. Even as part of the permitting process of real estate development
DWASA has developed guidelines which make it mandatory for developers of housing projects
to develop sewage infrastructure at every housing project. The multiplicity of organisations
involved in permitting (RAJUK and DWASA), weak institutional setup of RAJUK and DOE as
well as no clear mandate of a single organisation for supervision of the permitting conditions
seriously limits the effectiveness of DWASA guidelines. Even though the surface water pollution
could be restricted by the Act of 1995 weak institutional setup of DOE, prevents effective
monitoring, and also curtails the effectiveness of this legislation.
50
Kadam Rasul, Gazipur Pourashava and the union Porishads in DMDP area

3.6.3 Depletion of groundwater
Depletion of groundwater resource due to over dependence on groundwater has been identified
as a priority environmental problem in Dhaka. Under the existing planning framework the
National Polices (National Water Policy 1999), regional plans (DMDP Structure Plan), Sectoral
plans (e.g. DWASA Sewerage Master Plan, ad-hoc sanitation plans of Pourashavas) and
legislations have provided directions for addressing the concern of over use.
The National Water policy and the DMDP structure plan specifically emphasize that the
groundwater resource should be protected and the main source for water supply to urban areas
should be surface water. It also directs the government to identify the scarce groundwater zones
and restrict abstraction in such areas. In spite of such stringent policy level guidelines, no
regional plans demarcating the groundwater conservation areas have been developed in the
DMDP. Even the DWASA master plan is dependent on groundwater, for the short term (till
2010) and medium term (2010- 2015) for water supply. The dependence on groundwater would
reduce in the long-term (beyond 2015) with the sourcing of water from Meghna and Padma but
considerable amount would still be extracted from groundwater sources. However, outside the
DWASA service area, no comprehensive plans for water supply have been developed. The water
supply is still based on ad hoc plans which are dependent on groundwater as source.
To restrict the abstraction of groundwater, The Groundwater Management Ordinance, 1985, was
promulgated which mandates the licensing of tube wells by the Thana Parishad. However the
Thana Porishads as other institutions in DMDP, did not have the institutional capability for
implementation of such legislation.
In the absence of a single planning authority for water supply in the DMDP, comprehensive
water supply master plan for the entire area cannot be undertaken.
3.6.4 Increasing vulnerability to floods
The issue of increasing vulnerability to flooding due to unplanned filling up of wetlands and low
lying areas, which has been identified as a priority in the SEA, has also been addressed through
the existing planning framework. This is primarily through the spatial plans (e.g. DMDP
Structure Plan), sectoral plans (e.g. Eastern Embankment Project, ad-hoc drainage plans of
Pourashavas) and national level policies and legislations.
The National Water Management Plan has given emphasis on gravity based drainage system.
However, none of the major projects like Flood Action Plans or Detailed Area Plans have
stressed on the protection of the natural drainage system. In the already developed areas, number

of natural drainage channels has been encroached by the land developers with the help of their
powerful political influences. At times the natural drainage system has been lost due to wrong
implementation plans by the sectoral agencies. These deviations to the DMDP Structural Plan
have occurred even though the plan restricts the land development to avoid obstructions to flood
flow, within the designated flood plain areas. This has been possible as agencies mandated with
the task (BWDB, RAJUK) have not developed guidelines for preparation of lower level plans
(e.g. demarcation of flood flow zones on RS & CS maps) and formulate a mechanism for
restricting development of these areas.
The DAPs, as being prepared presently, may also result in shrinkage of flood retention as the
terms of reference for the DAPs suggest gradual phasing out of major retention ponds. Shrinkage
of flood retention ponds would result in emphasis on engineering solution like pumping. The
lack of appropriate technical capability of the planning process would further reduce the
effectiveness of the plans even as they are prepared.
The proposed eastern embankment project has been formulated for the construction of
embankment only along the western side of the Balu River. However, a large portion, area
between the Balu and Sitalakhya Rivers would still remain unprotected, and is vulnerable to
flooding. Other than these mega projects, local level drainage projects have been undertaken by
local bodies for the problem of water logging purely on an ad-hoc basis. Only in few cases
technical expertise of specialized organisations for water modelling and flood control e.g. IWM
have been utilised, but in most other cases, these projects have been developed with the local
knowledge and myopic vision of the elected representatives who are inclined to develop short
term solutions as they need to keep the electorate happy.
To protect the wetlands and open spaces, the Urban Areas Open Space and Natural Wetland
Protection Act, 2000, also has provision for demarcation and notification of wetland. However,
agencies responsible or having ownership of these areas (RAJUK, Land Revenue Department,
Fisheries Department, BIWTA, DWASA) have neither demarcated wetlands nor notified on the
RS & LS maps. In the absence of legal notification, numbers of wetlands are filled up by the
developers and also allowed encroachment by the slums. It is felt that political economy
considerations have played a part in the delay of notification of the wetlands.
The following three pictures represent the flood retention ponds being retained or created based
on three different plans. They highlight the inherent problem of coordination between regional
agencies and line ministries and the lack of a single planning authority responsible for flood
prevention and control in the DMDP area[ad16]

FIGURE 3.7: PROPOSED FLOOD RETENTION PONDS

AS DEMARCATED IN FAP 8A


AS DEMARCATED IN DMDP STRUCTURE PLAN


AS DEMARCATED IN EASTERM BYPASS PROJECT

4.0 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK
This section of the SEA report analyses the risks associated with the environmental priorities
given the existing planning framework and institutional weaknesses identified. The focus of
analysis would be (i) on the gap that exists between the higher and lower level planning
mechanisms and the risks that have resulted because of the absence of Detailed Area Plans in the
city to control and regulate the urban development process; and (ii) the possible environmental
threats that may emerge in future because of the lack of coordination between governmental
agencies responsible for urban development and their inability to integrate regional and sectoral
plans into a holistic planning framework.
4.1 LAND AND LAND USE MANAGEMENT
High urban densification and strain on urban services - One of the key environmental
priorities that has been identified through the systematic environmental analysis and stakeholder
consultation process pertains to the high densification of population in already developed areas
while leaving out fringe areas from the ambit of planned and structured development. Because of
the weak implementation of higher level strategies and absence of proper landuse plans, the
growth within the already developed areas have taken place in a random manner, sometimes in
contravention of existing development control legislation or by using loopholes in them. As a
result, land resources within the city have been put under stress, wetlands within the city have
got filled up and drainage channels have been obstructed in favour of unplanned development.
This skewed development pattern has put the urban services under severe stress thereby resulting
in a consequent strain on environmental resources and components.
Unplanned development in fringe areas and encroachment - With decreasing scope of large
area development within the already developed parts of the city, large areas in the developing
and fringe areas are being taken up in line with the overall direction set by the higher level urban
policies (accelerated growth and new area development in fringe areas). However, in the absence
of specific and systematic growth plans for this very large fringe area (compared to the existing
urbanised area), the new development runs the risk of being mismanaged. Such development will
also happen without the provision of adequate urban services and infrastructure thereby in
contravention of the lower level planning framework to be prepared for these areas. As a result,
the following would exacerbate the existing priority environmental risks:
• Lack of proper urban services and infrastructure for newly developed areas that will prevent
its ability to urbanise to the optimal level.
• Increase of land prices as a result of speculation and land grabbing making it difficult to
accommodate poor and vulnerable sections of the society in these areas.
• Indiscriminate land filling could further affect natural drainage channels and sink areas.

Thus, the opportunity for planned and systematic growth is being lost and appropriate
intervention at this stage would be beneficial in the long term.
4.2 WATER RESOURCES AND QUALITY
4.2.1 Depletion of Groundwater
• It has emerged from the analysis that RAJUK has little or no control on the regional level
planning of water supply formulated by DWASA. In the absence of a more integrated
planning approach the water supply strategy would primarily be based on the DWASA’s
existing plans of continuing dependence on groundwater sources in the short to medium
term within the DWASA service area. Outside this area, in the adjoining developing and
fringe areas, planning for water supply would continue to be ad hoc in nature and
primarily dependant on groundwater sources. In addition, a considerable section of
population in these areas would not have access to safe drinking water. Therefore,
without integrated planning and enhancing the capability of DWASA to serve larger
population across a wider area, there is a high risk of not meeting the total requirement of
supplying clean potable water to a large section of the population in the DMDP area.
• With present short and medium term plans for water sourcing, depletion of groundwater
resources would continue to occur at a very fast rate both within the DMDP and
adjoining areas (Singair area to the west of DMDP). This may result in further lowering
of levels of groundwater aquifers, a natural resource already under high stress and which
will take very long time to recover its original state, if proper remedial measures are
adopted. The high rate of withdrawal of groundwater may also result in contamination of
sourced water by naturally occurring minerals like arsenic, as is prevalent in many parts
of Bangladesh due to underlying geology of the gangetic delta region. The continuous
sourcing of groundwater from underlying aquifers may also affect the water sourcing
potential of tube wells which play an important role in supplying water to large sections
of unprivileged people living in slum squatters.
• Long-term plans relating to sourcing of surface water usage may increase the risk of
providing unsafe water to end-users, if the river systems from which such water is
sourced is polluted from discharge of industrial pollutants or sewage upstream of the
intake point. The clean-up of rivers would have to be planned and it would have to
include all sources in the river watersheds. If successful, this would lead to greater
reliance in water supply from surface water sources which would also reduce the
dependence of vulnerable sections of society on shallow groundwater often
contaminated, thereby resulting in decreasing environmental health risks.

• With the current DWASA master plans, no special provision has been made for supply of
clean drinking water to the vulnerable population living in the slums. These slum-
dwellers are forced to pay higher prices for sourcing potable water. Without a specific
targeted scheme for water supply to this section of the society their vulnerability to water
borne diseases increases, affecting livelihoods and increasing health costs.
[iflc17]
4.2.2 Reducing water pollution[iflc18]
As discussed in earlier sections, due to critical gaps in planning, institutional weaknesses and
lack of resources, the surface and groundwater resources of Dhaka have been severely impacted
by industrial growth and urbanisation. If adequate efforts are not made to correct or address the
present gaps in the higher plans for treating sewage, industrial effluents and sound disposal of
wastes, the risk to the water environment, a key environmental priority, would continue be very
high in terms of scale and severity in the short, medium and long term. Some of these impacts,
like the contamination of groundwater, would also be irreversible, or would take a very long time
to remediate through natural processes. Some of the specific risks to the water environment are
briefly presented below:
• At present the sewerage network infrastructure being planned by DWASA only takes into
account the existing urbanised areas and there are no systematic plans to set up sewerage
infrastructure in the developing and fringe areas which are charted for rapid development
in the near future. In addition, the five new Sewage Treatment Plants that are being
proposed as a part of the DWASA Master Plan are not holistic and do not consider
additional sewerage coming in from developing or fringe areas. With new areas getting
urbanized, the sewage treatment capacity will soon be overwhelmed resulting in
continual pollution of the surface water resources in and around the city increasing the
existing risks on surface water quality in the medium to long run.
• The approach for effluents treatment presently adopted only looks at end-of-the-pipe
treatment after sewage is collected by a dedicated sewerage network. Other non-
conventional methods of sewage treatment like oxidation ponds, biological treatment
through pisciculture ponds, etc. which are being practiced in similar socio-economic
conditions in cities like Kolkata, India could be considered for replication. Furthermore,
experiences of operating conventional treatment plants by sector agencies such as
DWASA in developing economies have not yielded desired results and many such plants
are not run efficiently because of lack of monitoring or proper maintenance of the
facilities. This also aggravates the risks of water degradation in the medium to long run.

• Presently, the plans for industrial effluent treatment and water pollution control being
formulated by the industry associations and the Department of Environment stresses on
combined treatment of effluents generated by industry clusters. If implemented properly,
this arrangement would enable industrial sectors like tanneries and dyeing units to treat
their wastes in a common facility against payment of user charges and thus create a
system to reduce pollution load being discharged into surface water. However, as a
strong institutional setup will be required to construct, operate and maintain such
common effluent treatment infrastructure along with proper monitoring from DOE, there
remains a risk to surface water contamination Without the implementation of adequate
capacity building and institutional strengthening for management water and urban
development.
• There are number of small and medium units which are not clustered and discharge their
effluents into common sewers. A CETP is not feasible and relocation of these small and
medium units would also be difficult considering their limited financial capacity. Thus
these units would continue to pollute unless some concrete measures are taken to
rehabilitate them in areas with adequate infrastructure to treat their wastes before
discharge into surface water bodies or schemes developed to help these units to adopt
cleaner technology.
• To ensure efficient management of solid waste DCC has undertaken the “Clean Dhaka”
project which targets collection and disposal of solid waste. This would improve
efficiency of collection of solid waste thus positively impacting the water quality of the
inland water bodies. However, the Clean Dhaka project is limited to the DCC area and no
similar initiatives have been taken in the remaining parts of the DMDP. Thus risks of
pollution of surface water from improperly managed waste dumps and open landfills
would continue in such areas. In addition, the absence of guidelines for management of
municipal solid waste as well as for biomedical and hazardous waste seriously impedes
the development of technically sound waste disposal systems. The risks of pollution of
both surface and groundwater would thus continue in the DMDP region even though the
“Clean Dhaka” project is implemented.
• The Clean Dhaka SWM project places an overall stress on the “landfill based approach”
which might turn counterproductive as most of the land in the region is prone to floods.
The risks would further be aggravated since the local bodies other than DCC have limited
technical and financial resources to undertake initiatives of such nature. Regional
cooperation involving City Corporation and the Pourashavas for solid waste management
however is difficult because of political-governance reasons. As a result, though there
would only be limited opportunities from better collection of waste and lesser littering,

the risk to surface and groundwater resources would continue due to improper waste
disposal practices.
Though the DAPs are expected to plan for local level sewage and wastewater collection systems
before being drained into surface water bodies, the risk to surface water bodies cannot be
reduced without proper integration or interface with the larger DWASA collection and treatment
systems within their service area. This would require the DAP consultants to work in close
collaboration with DWASA before giving shape to local level sewerage and waste water
treatment systems. In areas outside the purview of DWASA, DAP consultants would have to
suggest a combination of treatment suited to the respective DAP zone concerned. The onus of
cleaning up existing clusters of polluting industries lies with the DOE and industrial associations.
The formulation of DAP is an opportunity to initiate dialogue between DOE and industry as to
the appropriate location of future industrial zones. An opportunity that, thus far, has not been
taken advantage of due to lack of institutional coordination and an integrated development
planning framework for Dhaka.

4.3 FLOODING AND DRAINAGE
The physical location of most of the low lying areas within the DMDP and the proneness of
adjacent riverine systems to flooding exposes Dhaka to high flood risks. Engineering plans in the
form of embankments have been able to considerably reduce the effect of flooding in the main
city. New proposals to build more such embankments on the eastern side of the city are presently
under consideration. Though this engineering solution has certain inherent advantages, other
factors discussed below continue to increase the risk of flooding in Dhaka. Effects of climate
change may also appear and long-term impacts of related phenomena are likely to be higher
water levels and more frequent incidences of flooding and submergence.
• The proposed flood management plans in the form of the eastern embankment cum multi
purpose project overemphasize engineering solutions without adequately considering the
capacity of natural water bodies to absorb excess flood water and the need to establish
some kind of connectivity among existing water bodies for water within the city area to
flow out during floods. The implementation of the embankment will impede natural
drainage patterns and will intensify flooding in the areas within DMDP lying to the east
of the Balu River. Similar effects have been experienced in Tongi River where the
intensity of flooding has increased on the other side after the construction of the western
embankment. Therefore, the eastern embankment may help to reduce flood risk for a
limited area (west of the Balu) in the short term, but may prove counterproductive in the
long term from the point of view of other areas located on the fringes of the DMDP.
Also, in the case that this embankment is breached because of a high intensity flooding
event, it would result in severe flooding within the city.
• The cause of urban floods in Dhaka is also as a result of the city loosing its capacity to
absorb high intensity rainfall. The loss of the low-lying areas, progressive blocking of
inland water bodies and drainage channels to drain excess water have together resulted in
the city loosing its sink capacity. Implementation of the regulation for protection of these
areas has been weak as most of these wetlands and drainage channels have not been
demarcated and notified primarily due to political-economy considerations. Even though
the DAPs are expected to demarcate the water bodies, open spaces and playgrounds
absence of clear guidelines for identifying them would limit the identification process.
Thus, with the loss of existing wetlands and low lying areas, resultant risks associated
with water logging and urban flooding would continue to aggravate.
As the DAPs would concentrate on their respective areas for planning, it is unlikely that they
would be able to formulate a composite long-term strategy to reduce flood risk in the entire

DMDP area. Even the identification of flood retention ponds which figure in the scope of the
DAPs would be difficult to undertake on a compartmentalised planning area basis without proper
regional studies that take into account the extent of urbanisation and an assessment of land that
can be made available for development of such retention ponds.

5.0 SEA FINDINGS AND RECOMMENDATIONS

5.1 BACKGROUND
One of the main objectives of this study was to assess the process of formulating the Detailed
Area Plans (DAPs) that has been underway since 2005 and to propose a strategy by which the
environmental priorities identified by this SEA could be incorporated in these plans. As the SEA
progressed, it became evident to the SEA consultants that the whole process of preparing the
DAPs, was from the start, handicapped by existing systemic shortcomings. These shortcomings
were grouped under two headings:
1. Gaps at the strategic level in Structure and Urban Plans and the absence of a clearly stated
urban planning framework. Additionally, there is a lack of any stated mechanisms for
coordinating with other sectoral agencies and their planning processes; and
2. Problems at the implementation level: These are poorly informed plan preparation process;
inappropriate survey design and inadequate allocation of technical resources by RAJUK.
This has led to over-ambitious Terms of Reference for DAP preparation.
Extensive review of these categories of shortcomings was undertaken. This informed the
identification of environmental priorities to establish the scope of building into the DAPs,
strategies to address these priorities. Institutional and plan analyses, the review of the DAP
planning process, and the complexity of environmental problems led the SEA team to conclude
that the current process of DAP preparation would not be able to deliver the expected outcomes.
By August 2007, progress would have been made on demarcation of plan boundaries, but no
plans would have been formulated.
This chapter first gives a summary of the findings of the SEA relating to the shortcomings and
policy gaps at strategic, urban and local levels which will continue to prevent the satisfactory
development of local area plans. It then highlights the environmental priorities that need to be
addressed by DAP. The chapter concludes with the recommendations which are based on the
findings of this study and flags the issues which need attention.
Contribution of this Strategic EA: This study has shown that successful completion of most of
the tasks assigned to DAP consultants is contingent on strategic decisions being taken at
institutional and regional level. Concurrently, it has identified areas for capacity development;
provided pointers to inform/reform the planning process; and to improve the links so that
planning at DAP level can successfully complete the tasks assigned.

5.2 SUMMARY OF SEA FINDINGS
The findings are presented under the two groups noted above.
5.2.1 Shortcomings and Gaps at the Strategic Level
The Structure and Urban Area Plans do not provide land use zoning principles and guidelines
that are currently applicable. There are contradictions and lack of clear definitions. The Plans
demarcate broad areas for future development. However, there are inherent
contradictions/loopholes as in some cases the areas marked for development are low-lying and
act as sinks during the wet season. Since there are few notifications of land-use of fringe areas, it
provided scope for manipulation and encroachment. Guidelines have been provided in the Plans
with respect to development of housing for the low income groups and community participation
in planning. However, there are no directives in the Structure Plan for implementing these
guidelines, hence they have been ignored by the implementing agencies. Moreover, these plans
have become dated and have limited relevance to resolving the present urban management
problems.
The sectoral policies in the Structure Plan do not relate to the urban planning aspects. As result
the sectoral policies run as a parallel process with a weak interface to urban and regional
development plans. Most sectoral plans concentrate on finding localised and short term solutions
to urban problems, particularly within the DMDP. RAJUK by its constitution, however, has the
power to coordinate with the sectoral agencies whose plans affect the urban area. There has been
a failure of leadership.
Implementation of urban and regional plans needs considerable co-ordination and collective
design and decision making with all agencies working together. There are no stated mechanisms
for co-ordination or any over-arching planning framework which would have enabled agencies to
collaborate and co-ordinate their plans. The result has been fractured, haphazard and
environmentally unsustainable urban spread and inadequate infrastructural development.
The strategic level plans did not tackle the problem of multiple administrative authorities within
the DMDP and how their developmental efforts could be managed at the regional level. Thus,
the overall problems noted above are exacerbated by fact that DMDP is carved up into smaller
administrative units (municipalities and Pourashavas). In many instances, sectoral agencies do
have the mandate to provide services throughout plan area. A result some areas get excluded.
However, of greater concern is that piecemeal planning and un-coordinated infrastructure
development is taking place, often to the detriment of long-term environmental sustainability.

The haphazard growth is further reinforced by the national funding mechanism. Development
planning, including urban projects, in Bangladesh is done through the Annual Development
Programmes (ADP) for each financial year. Development projects are initiated at the level of
government agencies, divisions, departments, local government bodies. These are then
channelled upward to the relevant ministries, and then to the Planning Commission if necessary.
The administrative ministries concerned are authorized to approve projects involving costs up to
a designated level. Projects involving costs beyond that level are recommended to the Planning
Commission for consideration, approval and allocation of funds. The outcome of both these
procedures is that no one has an urban overview of what is happening on the ground.
Clearly urban planning in Dhaka is a quagmire of poor planning processes and plans; myopic
approaches to development; multiplicity of orthocentric agencies; collusive relations between
government agencies and vested interest groups; low levels of environmental awareness among
sectoral and local authority planners; and very limited effort to achieve real public good.
The five teams of DAP consultant appointed by RAJUK have no higher level guidelines for local
area plan formulation; no framework for developing a coherent regional approach; no
mechanism to coordinate the plans of adjoining local authorities; and limited ability to deal with
large sectoral organisations like DWASA or with local authorities who are antagonistic to
RAJUK.
5.2.2 Plan Development and Implementation Issues
The Detailed Area Plans were conceived as the third and lowest tier of the DMDP planning
hierarchy. As per the design laid down in the preparation document of Structure Plan, Master
Plan and Detailed Area Plan for Dhaka, the DAPs were expected to be prepared in-house by
RAJUK after adequate planning capacity had been built up. Due to institutional failures and
reluctance to develop its internal planning capacity, there has been a 10-year delay.
DAP preparation was finally outsourced to consultants in 2005 and is expected to be partially
completed by August 07. For the purpose of DAP preparation, the entire DMDP area had been
divided into 26 Special Planning Zones (SPZs) and was later consolidated to form 5 planning
areas (see Table 3.1). The work has been awarded to four firms of consultants.
The problems at the implementation level relate to (i) planning capacity. These include
insufficient groundwork, inadequate research and understanding of urban planning in RAJUK;
and poor design of the DAP process; (ii) the competence of the DAP consultants; and (iii) poor
support and leadership from the Technical Committee charged to oversee the plan preparation
process. Each of these is briefly summarised below.

(i) Inadequate Planning Capacity: Planning capacity in RAJUK, instead of being strengthened,
was gradually downgraded and to this day the Planning Department remains technically
understaffed. Moreover, there has been no updating or enhancement of qualifications of the
current planners. Their notions of urban planning are technocentric, dated and complexities of
social planning do not sit easily in their thinking. In fact they were ill-equipped to design the
DAP preparation process. Consequently, the Terms of Reference are over-ambitious. The
technical resources allocated are inadequate and behind the times; for example, the Geographical
Positioning System is not used to determine coordinates of boundaries; it was done manually
leading to mismatch of boundaries drawn by two groups of consultants and consequent delays.
Moreover, the planners have not provided any guidelines to the consultants for demarcation of
environmentally sensitive areas where urban development should be restricted. These include
wetlands, flood flow zones, retention ponds, canals and natural drainage channels. There is thus,
the danger that the DAPs could further exacerbate the problems of urban environmental
management.
Furthermore, in the absence of any directives, and reflecting the generally low environmental
awareness, the DAP consultants appear to have limited understanding of the pollution-intensive
nature of industrial growth in the watershed which is greatly responsible for the degradation of
the water resources. Consequently, there is little appreciation of the need for spatial zoning of
industries which should be done in consultation with industry.
Of greater concern is that the DAP preparation is not guided by any strategic level planning
framework. This means that the five groups of consultants are each contained within their own
zones, rather than within a regional approach. This means that piecemeal development will
continue even under the new plans.
(ii) Challenges of DAP consultants. In view of the complexities involved in formulating the
DAPs, the team concludes that the local consultants selected for this purpose do not appear to
have comprehensive technical capability and the experience to complete the tasks. What is also
surprising is that the consultants did not question the Terms of Reference or whether the outputs
were achievable in the given timeframe and with the resources allocated.
(iii) Poor leadership of the Technical Committee: The DAP planning process was found to have
a very weak interface with the sectoral planning agencies and as a result, is unlikely to produce
plans that can be integrated with the sectoral strategies and plans. This is because (a) the
Technical Management Committee which is charged to oversee plan preparation has been
ineffective in bringing in sectoral inputs to the draft DAPs that have been prepared; and (b) the
DAP consultants have also been unable to establish useful contacts with sectoral agencies to

address the sectoral issues of the local level plans. In addition, many of the sectoral plans do not
cover the entire DMDP area, especially in the fringe areas. The DAP consultants working in
these areas do not have access to any sectoral planning guidelines.
5.3 ENVIRONMENTAL PRIORITIES THAT NEED TO BE ADDRESSED BY DAP
The importance of getting the DAP planning process right is underscored by serious
environmental problems already affecting Dhaka and its surrounds. The environmental priorities
as identified by this study are given below.
5.3.1 High Urban Densification and Land use Management
Increasing overcrowding in the already developed areas: The growth within the already
developed areas has taken place in a random manner, sometimes in contravention of existing
development control legislations or by using loopholes in them. As a result, land resources
within the city have been put under stress, wetlands within the city have got filled up and
drainage channels have been obstructed in favour of unplanned development. This skewed
development pattern has put the urban services under severe stress resulting in significant strain
on environmental resources.
Unplanned development in fringe areas and encroachment: With decreasing scope for inner city
growth, large areas in the environmentally sensitive fringe zone are being targeted as they have
been marked for development in the Structure Plan. Additionally, in the absence of any detailed
and systematic growth plans the new developments run the risk of being mismanaged. It is
expected that these developments will also be without adequate provision of urban services and
infrastructure.
Such areas have also seen an:

• Increase in land prices as a result of speculation and land grabbing making it difficult to
accommodate poor and vulnerable sections of the society in these areas; and
• Indiscriminate land filling which could lead to loss of natural drainage channels and sink
areas and increase the vulnerability to flooding.

5.3.2 Water Resources and Quality
Surface water Pollution: The river systems and the water bodies in the Dhaka Watershed are so
contaminated by discharge of industrial effluents and untreated sewage that it cannot be treated
to potable standards. The problem of industrial pollution has to be addressed by DoE. It is also
being addressed by the World Bank under DIEWRMP. The role of the DAP lies in initiating a
dialogue with industry and a process to identify locations for future industries.
Reliance on, and Depletion of Groundwater: As surface water cannot be used to supply drinking
water, DWASA has become increasingly reliant on abstracting groundwater. Additionally, as the
supply is unable to meet the growing demand, there has been an increase in number of privately
owned tube wells. Local authorities outside DWASA area are also dependent on groundwater.
Continued abstraction over a long period could lead to contamination of groundwater. RAJUK
and DAP have no say in DWASA’s Master Plan. Furthermore, DWASA has made no provisions
in its plan to supply the slums areas.
5.3.3 Inadequate Sanitation and Sewage Network
At present, the sewage network infrastructure being planned by DWASA only takes into account
the existing urbanised areas. There are no systematic plans to set up a network in the developing
and fringe areas which are marked for future development. In addition, the five new Sewage
Treatment Plants that are being proposed as part of DWASA’s Master Plan do not consider
additional sewage coming in from developing or fringe areas. As a result, with new areas
becoming urbanized, there will be continued discharge of untreated sewage resulting in
continued pollution of the surface water resources in and around the city.
DAP preparation process could be used as an opportunity whereby a more comprehensive

network covering future growth areas could be designed if DWASA, RAJUK and DAP
consultants found a common platform.
The increased vulnerability to flooding as been documented in this report and elsewhere. As far
as the role of DAP preparation is concerned, the consultants would concentrate on their
respective areas for planning. It is unlikely that they would be able to formulate a composite
long-term strategy to reduce flood risks in the entire DMDP area. Even the identification of flood
retention ponds, which are central to local area plans, would be difficult to undertake, given the
compartmentalised planning approach.

5.4 RECOMMENDATIONS
In keeping with the objectives of the study, the recommendations have focused on improving the
DAP planning process. These have been subsumed under two groups indicating the urgency of
action required.
Action in Short Term
1 Develop a DMDP region landuse map; demarcate and publish notification of

ecologically/environmentally sensitive areas
It was heard several times during the final consultation workshop from all quarters that
there was no comprehensive land-use map of DMDP Region and there was a definite
need to create a document that depicts all the land uses, demarcates eco-sensitive areas,
and indicates potential development areas with different landuses like industrial,
agricultural, residential, mixed landuse, etc.
Further, loose planning guidelines and loopholes in the Structure and Urban Plans have
allowed the urban encroachment of environmentally sensitive areas which include flood
flow zones, wetlands and low-lying areas which act as sink for storm water runoff;
natural drainage channels and canals. The local area plans cannot progress unless these
areas are clearly identified, demarcated and notified. The proposals and plans on how this
demarcation should take place already exist with the responsible agencies and Boards.
To overcome this problem, the development of a DMDP Regional Land Use map should
be a priority. This map should clearly demarcate eco-sensitive areas and these should be
notified. This action is required on top priority to ensure no more filling of wetlands,
destruction of agricultural lands, and continued haphazard growth of the DMDP Region.
This comprehensive exercise should be undertaken immediately as the DMDP
development with existing outdated Structure and Area Plan and under development
DAPs will not be comprehensive and will likely repeat mistakes of the past planning
processes. This DMDP Region Plan should be developed in consultation with all the
sectoral and local planning bodies. However, the local plans will be only guidelines and
will be finalised by individual local governments like Pourashavas, Union Porishads at
the local level.
2 Resolve conflict arising from the multiple functions of RAJUK
RAJUK has been very active in promoting and participating in the development of
commercial properties like shopping centres and malls. While these developments have

been lucrative for both RAJUK and the private developers, they have often overlooked
the planning guidelines and encroached on environmentally sensitive areas. Clearly, there
is conflict of interests between RAJUK’s role as a promoter and its role as the principal
agency for urban development.
This issue can be resolved only by either divesting RAJUK of all its developmental
responsibility and making it an exclusive planning and monitoring body; or, RAJUK can
be a development body and a new authority should be created to carry out the planning
and monitoring function. An institutional assessment needs to be carried out to define the
mandate of the proposed agency, its location within the myriads of agencies, ministries
and authorities that exist in Dhaka/ Bangladesh and how it will function. However, this
authority has to be able to get support and cooperation of various sectoral agencies and
should be able to control and monitor the planning of entire DMDP region.
3 Strengthen the DAP planning process as there is too much at risk
The detailed area planning process is incomplete, hence, there is still an opportunity to
improve the process and achieve some of the stated objectives. Real value addition to the
process will take place if the capacity for environmentally sustainable and socially
sensitive planning is enhanced in RAJUK as it is the lead agency. Additionally,
consultants with more appropriate skill sets need to be appointed. Plan formulation needs
a team with better technical know-how, better understanding of the complexities of urban
planning, and which has a critical approach to project execution. The point is to build on
the work that has already been completed in the last two years.
One of the main problems faced by the present consultants is that they are unable to work
with/ have access to, the sectoral agencies. The membership of the Technical Committee,
who is charged to provide the link, should be re-assessed for effectiveness and if
necessary, changed. The modus operandi should be made more transparent and
information on progress and outcomes disseminated. This can be achieved by engaging
stakeholders more effectively and communicating decisions at various levels to public
and key stakeholders so that the process remains open and accessible.
The leadership of RAJUK needs to be more active in the process. The inability of
RAJUK to play a leadership role in the past has led other agencies to take planning
initiatives on their own without any coordination with RAJUK. It is clear that
constitutionally the organisation has considerable power but has rarely used it for
systematic urban management. RAJUK needs to re-direct its energy to facilitate the work
of its consultants with sectoral agencies and other local authorities. This will not be easy

as the latter have developed their internal procedures and these procedures exclude any
interaction with RAJUK. It will therefore, be essential to enable and encourage RAJUK
to liaise with other agencies and open doors for the DAP process.
The issues of slum area development and provision of low income housing are not being
addressed either by RAJUK or any of the other sectoral agencies. This means that land
allocation and infrastructure planning for these areas might not feature in local area plans.
One of the responsibilities of RAJUK is the provision and overview of low income
housing. This issue will be part of the institutional reform of RAJUK and will have to be
dealt within the scope of that process.
4 Engaging stakeholders in urban planning
Throughout this project it has been observed that political economy has played a huge
part in the haphazard development of the City of Dhaka. Further, the people with vested
interests have been hijacking the process of planning due to lack of transparency.
It is recommended that during the reform of the planning process including resolving the
conflict of mandate within RAJUK, a transplant process for engaging key stakeholders in
the planning of regional areas should be put in place.
o As pointed out in the workshop, the “ward committees” at the Pourashavas level
have been quite effective at engaging local community in local planning
initiatives. Similar initiatives are required at Dhaka and municipal level.
o Further, transparency can be achieved if the DMDP region landuse plan with
demarcation of ‘no development zones’ is notified and made available to the
public. The public can use this information and stop illegal development. Public
can approach judiciary if necessary to stop development in the no-development
zone.
5 Bring other actors on board
Crucial to the success of formulating local area plans is the participation of local
authorities. An entry point for dialogue with these authorities could be programmes for
capacity building in environmental planning and regional development. Thought needs to
be given to what would be the most efficacious way of doing this.
DWASA is one of the biggest players in the provision of urban infrastructure. Currently
there is very little communication between the two organisations and RAJUK has little

say in the Master Plans developed by DWASA. It will be important to bring DWASA,
RAJUK and the DAP team to a common platform.
The flood management strategies expectedly should have a regional approach. However,
there are measures which need to be put in place and actions taken at the local level to
achieve overall reduction in vulnerability to flooding. These include among others,
freeing up encroached canal systems, rehabilitating flood retention ponds, improving
connectivity between water-bodies etc. In order to incorporate such measures in the
DAPs, it will be necessary for RAJUK, LGED and other principal organisations
responsible for management of water resources to work together to assist the DAP team.
Actions in Medium Term
6 Develop strategic planning directives for urban growth
The DAP formulation process will ultimately rely on a strategic planning framework to
provide the directives, tools and guidance. While the local area plans will be important
working tools, change will occur and new plans will have to be formed. This strategic
framework would be a point of reference for local authorities; for DAP consultants; and
for future urban growth for the stated period. It is hoped that the new framework will be
coherent, tight and address the inadequacies of the past and current urban planning
approaches and processes.
7 Funding procedures for local development projects
It has been noted in the report that development projects, which include urban projects,
initiated by local governments and local level sectoral agencies are channelled up to the
relevant ministry for funding, and further up to the Planning Commission if they are
beyond a designated cost level. In either case, the funding provided is based on budgetary
criteria. There is no mechanism to ensure that the project has been environmentally
appraised or the sustainability of such projects has been established. Furthermore, there
could be duplication of effort in two adjoining authorities leading to waste of valuable
resources. For long-term environmental sustainability, it will be important to address this
problem. This requires the mainstreaming environmental issues prior to initiating any
systemic change. The Environmental Assessment regulations already exist in Bangladesh
and linking funding to the EA approvals maybe one of the approaches that maybe
considered.

APPENDIX A
FINAL CONSULTATION WORKSHOP PROCEEDINGS

Final Consultation Workshop

on
Strategic Environmental Assessment of
Dhaka Metropolitan Development Plan
16 August 2007
Venue: Dhaka Sheraton Hotel
WORKSHOP PROCEEDINGS
The Final Consultation Workshop on the SEA was held on 16 August 2007 at Dhaka as the final round of
consultations with key stakeholders to discuss the draft Final Report of Strategic Environmental
Assessment of DMDP and to seek concluding feedback.
Workshop Objectives
The principal objectives of the workshop were as follows:
• Apprise stakeholders of the findings and recommendations of the Strategic EA study;

• Develop broad consensus on the recommendations with the stakeholders of concern;
• Explore potential for assessing whether a consensus existed for setting up a regional (DMDP
wide) strategic planning authority; and
• Discuss ways to kick-start institutional reform and carry out strengthening of key urban planning
agencies responsible for planning and plan implementation in the DMDP region.
Inaugural Session
The workshop commenced with a recitation of the Holy Quran. This was followed by the inaugural
address of Chief Guest, Mr A S M Rashidul Hai, Secretary, Ministry of Housing and Works.
Mr Hai accepted in his speech that urban planning in Dhaka is presently constrained by a number of
systemic shortcomings including lack on planning capacity within the apex planning agency RAJUK;
inadequate coordination between various agencies; absence of land use zoning; and the non-existence of
an overarching planning guidelines and planning document to guide urban development. This has resulted
in fractured, haphazard and environmentally unsustainable urbanisation of Dhaka. He also opined that it
was unlikely for the DAPs planning process alone to solve the present problems of lack of urban
infrastructure and associated environmental degradation until some action is taken at the strategic level to

provide overall direction to urban planning in Dhaka. He said that such strategic planning needs to
consider the entire DMDP area for dispersal of population, setting up of crucial infrastructure like sewage
treatment plants or looking at ways for flood protection and control, keeping in mind long-term scenarios.
He also pointed out current scenario was unacceptable and the proposed changes provided an opportunity
to build improvements that promote environmentally sustainable and socially sensitive planning.
Importantly, he also conveyed that the Government was prepared to consider appropriate reform in the
institutions that play a key role in urban planning for Dhaka and also improve their planning capabilities
through systematic strengthening and capacity building. He noted that the workshop was represented by
members of key stakeholder groups and wanted it to be the platform to discuss the need for such new
approaches and try and arrive at a consensus for taking the recommendations forward.
Chief Guest Mr A S M Rashidul Hai delivering his address in the

Inaugural session
In her welcome address to the workshop by Ms Nayeema Khatun, Project Director SEA, she provided a
brief outline of the planning process within the DMDP area and the presently ongoing DAP plan
preparation process. She stressed on the need for environmentally-sound planning and underlined that this
has prompted RAJUK in initiating this study with support from the World Bank. She explained that the
SEA study was intended to undertake a detailed review of the existing DMDP and sectoral plans,
understand their linkages with priority environmental issues and complement the DAP preparation
process by providing an overall environmental framework for the DAPs. She requested the participants to
come forward with opinions on the findings and recommendations of the study after reviewing the
Executive Summary provided to the participants. She also expressed hope that the deliberations of the
workshop would go a long way in drawing up inclusive and participative Detailed Area Plans in close
collaboration with various other sectoral agencies and administrative authorities and would help the city
to grow and prosper in an environmentally sustainable way.
Dr A K Ghosh, Senior Environmental Specialist of SENES briefly outlined the approach taken by the
study team and explained the key conclusions reached. He explained that the that the priority
environmental issues and constraints in the city of Dhaka were related primarily to the use of land and

water resources and how their management have been factored into the recommendations that have
been proposed by the study. He stressed on the need for drawing up a regional planning perspective
taking the entire DMDP area and the immediate need for mapping of the present landuse and the
establishment of a landuse control system for the city.
In his inaugural speech, special guest to the workshop Mr A H M Rezaul Kabir ndc, Secretary Ministry
of Environment & Forest briefly referred to the magnitude of the environmental problems present in
Dhaka and pointed out that many of these environmental problems being encountered were a direct
result of decades of unplanned and haphazard growth that the city has witnessed with scant regard to
environmental considerations and issues. He noted that though the country had established project level
EIA system, it has not worked to the satisfaction of the Ministry to be an effective mechanism because
of the lack of proper monitoring and enforcement machinery within the government. In this context, he
observed that higher-level (strategic) environmental assessments can play an important role to help
decision makers to take important urban planning decisions that would help in arresting further
environmental degradation in Dhaka and make progress towards building a cleaner and sustainable city
that will provide it residents with a better and healthier quality of life.
In his inaugural speech, the Guest of Honour, Mr Xian Zhu, Country Director, The World Bank
expressed his satisfaction at the way that Bangladesh is making steady progress with regard to a
number of development indicators and said that the World Bank is extremely happy to be a partner in
its advancement. He observed that the SEA study has played a crucial role in highlighting the gaps in
the planning process and the institutional weaknesses that have hindered the planned development of
the city in accordance with DMDP formulated in the early nineties and have brought into focus high
potential risks to the environment and the vulnerable sections of the society. For example, he said that
the study has pointed out the high risk of flooding to certain fringe areas of the DMDP can be further
aggravated by climate change impacts in the medium to long term and has consequently highlighted an
urgency to draw up integrated regional plans accounting for the entire DMDP area. He also noted that
the study has also pointed out a need for institutional reforms and strengthening of key planning
agencies like RAJUK in order to ensure that urban planning in Dhaka is undertaken in a holistic
manner and factoring the requirements of the weaker sections of the society whose interests have been
neglected in the current planning process. The World Bank, he said, would be happy to support the
Government of Bangladesh in this process.
After this, a detailed presentation was made by Mr Debanjan Bandyopadhyay, Deputy Team Leader of
the SEA Team on the findings and recommendations that have emerged from the study. He explained the
specific objectives of the study and the methodology adopted. In doing so, he explained the reasons for
the study to have metamorphosed into an “institution-centric” study from an environmental one. He
elucidated the four priority issues that were short listed based on technical analysis and after receiving
inputs from stakeholders on the environmental issues. Subsequently, the significant risks arising as a
result of the gaps in the existing planning framework, weaknesses in the institutional setup and political
economy considerations were explained. The high risk of progressing with the DAPs without having a
higher level strategic planning guidelines based on current landuse and proposed landuse were also

highlighted. This was followed by a presentation of the recommendations and requested the participants
to freely speak up as the SEA team was open to receiving suggestions and feedback on both the findings
and the recommendations of the study.
Subsequently, Mr M A Qasem, Director General, Local Government and Rural Development said in his
speech that he agreed with the findings of the SEA and many of the key environmental problems are
influenced by political economy factors and little coordination between institutions responsible for plan
implementation and monitoring. He observed that until some interventions were made at high level,
finding solutions through “end-of-the-pipe” methods after the problems have already been created as
result of faulty planning or inadequate coordination between institutions would only be superficial and is
unlikely to solve the issues. He concluded by saying that there is a need to explore ways through which
such coordination between RAJUK and the Dhaka City Corporation, Pourashavas and Sectoral Agencies
like DWASA can be effected and agree on whether the Government should consider setting up of a
higher level body to provide leadership in this regard or strengthen existing institutions appropriately to
improve their planning capabilities and establish better systems for bringing about effective collaboration
between all concerned departments and agencies.
The inaugural session of the workshop was chaired by Mr K A M Haroon, the Chairman of RAJUK. In
his concluding remarks to the inaugural session, he thanked the distinguished speakers for being present
at this important workshop and for expressing their views on the SEA study. He noted that the
deliberations at the inaugural session have confirmed that if proper thought is given at the planning and
decision making level, many of the environmental problems of Dhaka can be solved more effectively. He
also observed that if the strategic assessment had been undertaken earlier, it may have resulted in better
understanding of the weaknesses in the planning system and prevent some of the environmental damages
that have already taken. After taking note of the earlier discussions, he was in broad agreement with the
study’s recommendations and hoped that they can help in making necessary corrections in the DAP
preparation process that are presently underway and also requested considering the establishment of a
regional planning authority to guide the DAP consultants and associated sectoral agencies in carrying out
the planning task effectively and efficiently. Before concluding the session, he also thanked the World
Bank to support such a study.
Technical Session
The participants were divided into two groups to discuss the following two topics. After an hour and half
of discussion the groups came back and presented their consensus on taking this study forward:
Group A: Strategic Environmental Planning Framework for Dhaka
• The need for a higher level urban policy for delineating broad directions of growth, based on
assessment of existing landuse in the DMDP, was felt required to adequately guide the local
level DAP planning process.

• It was discussed that the present DAP consultants would be able to complete the DAP
formulation process with existing capabilities, in spite of certain hurdles being faced. The
participants requested the SEA consultant to bring out the positives of the DAP planning
process.
• Opinion was expressed by the DAP consultants that the Terms of Reference for the DAP
planning studies need to be modified taking into consideration ground level planning
requirements and constraints.
• The planning capabilities of RAJUK should be strengthened and in spite of the apparent
weaknesses, it was agreed that with proper capacity building, it can play an important role in
the urban planning process of Dhaka.
• However, the group also agreed that RAJUK should not be responsible for both planning in the
area as well as in developing projects. This was viewed as being in conflict of interest. It was
pointed out RAJUK was more keen on development as it yielded more revenues.
• A pressing need was felt by the group to improve coordination between RAJUK and the
various sectoral and utility organisations that play a role for the development of Dhaka.
Group Discussions in the Technical Session in progress
Group B: Engagement of Stakeholders in Urban Planning

• Three levels of engagement were proposed by the group:
o National level for developing policies and guidelines in urban planning for the country;
o Regional Level – DMDP for developing regional level plans based on a national
strategy; and
o Lastly, local level engagement through ward-committees and other mechanism;
• There was consensus that Television was the media of choice for creating awareness amongst
the Bangladesh masses and this media was never used to let people know what was being
proposed for DAPs. The recommendation was to make se of this media for awareness building
and seeking feedback.

• Other media like Internet websites should also be effectively utilized for seeking feedback.
• There was a strong need felt for building awareness among all sections of society including
government agencies, NGOs and public on environmental sensitive areas and how the
unplanned infrastructure development was causing problems on several front including water
pollution, floods, poor air quality etc. This was felt necessary for the public to effectively
provide feedback as well as fight the system to ensure this does not go on.
Panel Discussion
Professor Nazrul Islam, the Chair for the panel and a distinguished urban planner, set the tone for the
discussions by briefly relating his appreciation of the progression of urban plans for the city of Dhaka.
Taking part in the discussions, Mr Md. Nasiruddin, RAJUK, Member Planning accepted the
weaknesses in RAJUK that were pointed out in the study and the need to take the opinion of experts
present to bring in necessary reforms in the planning system and within RAJUK. He said that in spite
of the apparent lapses, with appropriate support from other agencies and with proper reinforcement of
planning capacity, RAJUK as the key agency can play an important role to undo some of the
environmental damage that has already been done. Expressing his views, Dr. Ainun Nishat, Director -
IUCN pointed out that the SEA consultations should have been more encompassing and thorough. He
expressed the need for protecting existing environmentally sensitive areas like wetlands and other
natural habitats with the city through proper landuse zoning and implementation of landuse control
plans.
Prof Nazrul Islam expressing his views at the Panel Discussion
Dr A K Ghosh referred to a case study from Kolkata where the east Kolkata wetlands, now a Ramsar
declared protected site, and adjoining agricultural fields, played an important role in the urban ecology
of a large metropolitan city. He expressed the opinion that such approaches need to be considered at the

highest strategic level before deciding upon the development and landuse of about 1000 km2 of fringe
areas of Dhaka which comprise primarily of agricultural areas, flood flow zones and wetlands.
Mr K M Minnatullah from the World Bank noted that the World Bank is planning to take an integrated
program for improvement of water quality in the entire Dhaka watershed through the DWINRP project
and the overall urban plans of the city has to be drawn up in a manner that it complements the project.
As a result, he felt that the RAJUK would have to play the role of an important stakeholder in the
project and the World Bank is ready to extend support to RAJUK and build necessary capacity within
the organisation.
Mr Murali Ganapathy from SENES clarified requests of various stakeholders on why only four
priorities were presented in the Executive Summary and that air quality, noise, transportation and
industrial pollution were all discussed in the detailed report. He further highlighted that implementing a
strong environmental impact assessment system and procedure for infrastructure projects can address
key environmental impacts of key urban infrastructure projects and at the same time result in increasing
public awareness and participation in the development process.
The panel discussion concluded with Prof Nazrul Islam summarizing the individual speakers and
stressed on the following key issues:
• Developing a regional urban planning guidelines to ensure uniformity all across the region;
• The need to draw up a landuse plan for DMDP region highlighting all key sensitive areas;
• Removing the current conflict of planning and development by the same agency; and
• Carry out adequate reform of RAJUK and reinforce its capacity to undertake planning and
monitoring effectively.
The Workshop was concluded with a Vote of Thanks by Mr Neaz Rahman, SEA Team Leader. He
thanked all the distinguished guests and the stakeholders for providing the SEA team with the benefit of
their views and felt that this feedback will immensely help in further refining the final report of the study.

News Coverage of Workshop:
The Daily Star
Incorporate environmental issues into city’s dev process
Speakers tell workshop

Staff Correspondent
Speakers at a workshop have underscored the need for incorporating environmental issues into the city’s
overall development process to enhance the quality of life of its dwellers.
The workshop titled ’Strategic Environmental Assessment of Dhaka Metropolitan Development Plan’ was
held at a city hotel on Thursday to disseminate the objectives of Strategic Environmental Assessment
(SEA).
The government has proposed the SEA for Dhaka Metropolitan area to shed light to complex interactions
between environmental, social, economic and institutional factors linked to urban planning and
development.
World Bank is supporting the government in framing the draft SEA, and Rajuk would be the
implementing agencies.
Terming the urban planning of Dhaka a ’quagmire’ of poor planning process and plans, Dr AK Ghosh,
senior environmental specialist, said low level of environmental awareness among sectoral and local
planners and very limited efforts to achieve real public good were evident in the urbanisation process.
Stressing on bringing other actors like the utility service providers on board, he further said as Rajuk is
active in the development of commercial areas like shopping centres and malls, it very often overlooks
the planning guidelines and encroaches on environmentally sensitive areas.
AHM Rezaul Kabir, secretary to environment and forest ministry, laid emphasis on regional consensus on
environmental issues and said a strategic plan to this end may act as baseline policy for future planning of
the city.
Lauding the timely approach of the government, Zhu Xian, country director of the World Bank, said as
urban plans are being formulated for six regions of Dhaka Metropolitan area, it is considered to be an
ideal time to undertake an independent assessment about the possible environmental consequences of the
implementation of such plans and build corrective measures wherever required.
MA Qasem, director general of LGRD, laid emphasis on coordinated and concerted efforts by all the
concerned institutions.
ASM Rashidul Hai, secretary to housing and public works ministry, KAM Haroon, chairman of Rajuk
and Nayeema Khatun, project director of SEA also spoke on the occasion.
Debanjan Bandyopadhyay, team leader, made a presentation on draft SEA report.

The Daily Independent, Bangladesh
Unplanned urbanisation responsible for water crisis in city
STAFF REPORTER
Speakers at a workshop yesterday said that unplanned urbanisation and in discriminate use of
underground water are responsible for the recent natural disaster like water logging and water crisis in the
city.
"The capital city expanded without planning and eighty per cent of the people of Dhaka city lifted their
usable water from underground. So, the excessive use of underground water has brought down water level
day by day", experts at the workshop said.
"Violating laws and the lack of coordination between RAJUK and Dhaka City corporation (DCC) for
development activities in city are the main reasons for environmental disaster, the environmental
specialists also said.
They made their remarks at a workshop on "Strategic environmental assessment of the detailed area
plan," held at Sheraton Hotel in the city. The RAJUK and World Bank jointly organised the daylong
workshop before publishing its final report.
ASM Rashidul Hai, secretary of housing and public works was present as chief guest while AHM Rezaul
Kabir, secretary of ministry of environment and forest, Muhammed Abul Quasem, director general of
local government division also addressed the inaugural session. KAM Haroon, chairman of RAJUK
chaired in the inaugural session.
Housing and public works secretary Rashidul Hai said that the political economy of the then governments
has created this manmade natural disaster like water logging in the city.
"We have taken necessary steps to stop artificial natural disaster like water logging in the city", he added.
World Bank country director Xian Zhu presented the keynote paper at the workshop on the draft report of
the Strategic Environmental Assessment (SAE) and said that all the residents of Dhaka are to some extent
impacted by the deteriorating water level.
"The poor people have few options for accessing clean water are the most vulnerable", Xian Zhu said.
The overall urban planning process should take strategic planning to prevent the high risk of the flooding
in certain areas of the Dhaka", Xian Zhu told the workshop.
Dhaka is undergoing massive expansion and its current population of 12 million will increase to 20
million by 2020, making it the world’s third largest city, Khawaja Minnatullah, senior environmental
specialist of the World Bank said.
Speakers at the workshop suggested introduction of strategic urban planning for Dhaka to promote
environmentally sustainable growth of the capital.
"Unplanned growth, uncoordinated activities and also unabated environmental pollution-the economic
cost associated with environmental degradation may amount to more than four per cent of the total GDP",
he added.
He pointed out that institutional reforms and strengthening of the key planning agencies like RAJUK is
urgent for sustainable urban planning in Dhaka.

The Financial Express, Dhaka
Strategic urban planning must for sustainable growth
FE Report
Strategic urban planning is urgently needed for Dhaka to promote environmentally sustainable
growth of the country as well as of the capital city, according to the World Bank (WB).
"Greater Dhaka currently represents more than 40 per cent of Bangladesh’s national gross domestic
product (GDP). The overall urban planning process should take strategic planning principles into
account to prevent the high risk of flooding to certain fringe areas of the Dhaka Metropolitan
Development Plan. Such floodings are likely to be further aggravated by climate change impacts in
the medium to long term", said World Bank (WB) Country Director Xian Zhu during a workshop
Thursday.
A S M Rashidul Hai, Secretary, Ministry of Housing and Public Works, was present as Chief Guest
of the workshop on "Strategic Environment Assessment of Dhaka Metropolitan Development Plan,"
jointly organised by RAJUK and the WB. A H M Rezaul Kabir, Secretary, Ministry of Environment
and Forest and Muhammad Abul Quasem, Director General, Local Government Division, also spoke
in the inaugural session, chaired by K A M Haroon, Chairman, RAJUK.
Dhaka is also undergoing a massive expansion and its current population of 12 million will reach 20
million by 2020, making it the world’s third largest city with unplanned growth, uncoordinated
activities and unabated environmental pollution. The economic costs associated with environmental
degradation may amount to more than 4 per cent of GDP, said WB’s senior environmental specialist.
The unplanned urbanisation has raised two sets of environmental challenges in Dhaka city. The first
arises from urban development projects in different sectors and industries which treat potential
environmental effects as externalities and only try to mitigate these effects as an afterthought and do
not include it as an integral part of their project.
The second set of environmental issues stem from the acute pressure on natural resources resulting
from the indiscriminate use/misuse of these resources.
The government undertook the Strategic Environmental Assessment (SEA), supported by the WB
and implemented by RAJUK, to underpin the complex interactions between environmental, social,
economic and institutional factors linked to the urban planning and development of Dhaka city.
The study found the urgent need for institutional reforms and strengthening of key planning agencies
like RAJUK, to ensure that urban planning in Dhaka is undertaken in a holistic manner.

Dhaka Metropolitan Development Plan Strategic Environmental Assessment

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DHAKA METROPOLITAN DEVELOPMENT PLAN

The World Bank

SENES Consultants Limited

Techno Consult International Limited

Printed on Recycled Paper Containing Post-Consumer Fibre

2.0 SITUATION ANALYSIS OF DHAKA’S ENVIRONMENT.................... 2-1

3.0 URBAN PLANNING IN DHAKA ............................................................. 3-1

34445 –Final – Aug 2007 i SENES Consultants Limited

3.4 Institutional Set up for Governance & Urban Planning .....................................3-14

4.0 RISKS AND OPPORTUNITIES OF PLANNING FRAMEWORK.......... 4-1

5.0 SEA FINDINGS AND RECOMMENDATIONS ...................................... 5-1

APPENDIX A: Final Consultation Workshop Proceedings

34445 –Final – Aug 2007 ii SENES Consultants Limited

2.1 Environmental Priorities in Dhaka.................................................................................2-24

2.1 Spatial Growth of Dhaka..................................................................................................2-2

3.1 DMDP and DAP Planning Areas .....................................................................................3-4

34445 –Final – Aug 2007 iii SENES Consultants Limited

34445 –Final – Aug 2007 iv SENES Consultants Limited

SMPA Strategic Metropolitan Planning Authority

34445 –Final – Aug 2007 v SENES Consultants Limited

1 RATIONALE FOR SEA STUDY

♦ understanding the complex interactions between environmental, social, economic and

34445 –Final – Aug 2007 1 SENES Consultants Limited

2 OBJECTIVES OF THE STUDY

The specific objectives of this SEA are to:

♦ recommend policies, institutional arrangements and governance conditions needed for

34445 –Final – Aug 2007 2 SENES Consultants Limited

4.1 Shortcomings and Gaps at the Strategic Level

34445 –Final – Aug 2007 3 SENES Consultants Limited

4.2 Plan Development and Implementation Problems

The problems at the implementation level relate to:

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4.3 Environmental Priorities that Need to be Addressed by DAP

4.3.1 Land and Land use Management

34445 –Final – Aug 2007 5 SENES Consultants Limited

4.3.2 Water Resources and Quality

4.3.3 Inadequate Sanitation and Sewage Network

4.3.4 Increasing Vulnerability to Floods

34445 –Final – Aug 2007 6 SENES Consultants Limited

5.1 Immediate Action

5.1.2 Resolve Conflict Arising From Multiple Functions of RAJUK

34445 –Final – Aug 2007 7 SENES Consultants Limited

5.1.4 Engaging Stakeholders in Urban Planning

34445 –Final – Aug 2007 8 SENES Consultants Limited

5.1.5 Bring Other Actors on Board

5.2 Actions in Short/medium term

5.2.1 Develop Strategic Planning Directives for Urban Growth

5.2.2 Funding Procedures for Local Development Projects

34445 –Final – Aug 2007 9 SENES Consultants Limited

address this problem. However, mainstreaming environmental issues will be a pre-requisite to

34445 –Final – Aug 2007 10 SENES Consultants Limited

1.1 RATIONALE FOR THE STRATEGIC ASSESSMENT STUDY

34445 –Final – Aug 2007 1-1 SENES Consultants Limited

BOX 1.1 : INSTITUTION-CENTRED SEA

34445 –Final – Aug 2007 1-2 SENES Consultants Limited

1.2 OBJECTIVES OF THE STUDY

The specific objectives of the SEA are to:

• recommend policies, institutional arrangements and governance conditions needed for

1.3 APPROACH AND METHODOLOGY OF SEA

34445 –Final – Aug 2007 1-3 SENES Consultants Limited

To undertake systematic technical analysis of environmental, planning concerns and political-