When the facts change

The United Nations Educational, Scientific and Cultural Organization (UNESCO) World Heritage Committee (WHC) was held on 2-12 July 2017 in Krakow, Poland. One of the agendas for this 41st session was "State of conservation of properties inscribed on the World Heritage List."  This includes natural properties from Asia-Pacific region such as Sundarban, for discussion and making decision. After examining the documents entitled "Report on the state of conservation of properties inscribed on the World Heritage List" I come across some important discussion and decisions made by UNESCO WHC, which is relevant for Sundarban and pertinent for this essay.
WHC welcomes "the State Party's decision not to approve the Orion power plant and Phase II of the Rampal power plant, and to carry out a Strategic Environmental Assessment (SEA) for the South-West region of Bangladesh, including the property, and requests the State Party to ensure that any large-scale industrial and/or infrastructure developments (including the Rampal power plant) will not be allowed to proceed before the SEA has been completed, and to submit a copy of the SEA to the World Heritage Centre for review by IUCN".  Implication of this decision is manifold.
In 2016, UNESCO urged the Bangladesh Government to relocate the power station, saying it threatened the unique ecosystem. Above decision suggests that development should not be allowed to proceed until SEA is completed. What is SEA? Why it is necessary?  When this should be carried out and what it should contain? Strategic Environmental Assessment (SEA), a systematic decision support process, whose aim is to ensure that environmental and other sustainability aspects are considered effectively in policy, plan and programme making.
In UK, SEA is applied to plans, programmes, any legislative proposals and political or cabinet decision making. Since July 2004, many of the plans and programmes that shape the future have been going through a Strategic Environmental Assessment (SEA). It is an evidence based instrument and its' aim is to support effective and efficient decision-making for development and improved governance by furnishing information regarding questions, issues and alternatives considered in policy, plan and programme(PPP) making.
In the European Union, SEA is a legally enforced assessment procedure required by Directive known as the SEA Directive. The SEA Directive aims at introducing systematic assessment of the environmental effects of strategic land use related plans and programs.
It typically applies to regional and local development, waste and transport plans, within the European Union. The purpose of the SEA-Directive is to "ensure that environmental consequences of certain plans and programmes are identified and assessed during their preparation and before their adoption..."
Generally SEA is carried out before EIA. One of the important parts of SEA is to address whether there is any alternative to the proposed location, if not why not. SEA also needs to assess the effect of alternative plan. The conclusion of SEA feeds into new management plan.
The SEA report must include, the main objectives of the plan or programme, a description of the state of the environment, the environmental protection objectives (national, regional and international) that are relevant to the plan or programme and how they have been taken into account, the significant effects on the environment, including  biodiversity, population, human health, wildlife, soil, water, air, climate, cultural, heritage, landscape and the measures envisaged to prevent, reduce and as fully as possible offset any significant environmental effects, the reasons for selecting a site and not an alternative one, measures for monitoring how the plan or programme affects the environment in practice.
If the plan or programme only affects 'small areas at local level', or if revisions to it represent only 'minor modifications', then it may be exempt from a SEA.  So, asking for SEA means that there is a realisation within WHC and International Union of Conservation of Nature (IUCN) that the programme that has been chalked out by the Government of Bangladesh will potentially affect the wider environment.
WHC welcomes "the information provided on ecological monitoring but notes with concern that sea level rise, salt intrusion and reductions in fresh water flows are posing a threat to the Sundarbans' ecosystem and that the property is particularly vulnerable to impacts from these threats; also "takes note of the critical importance of transboundary cooperation between the States Parties of Bangladesh and India on the World Heritage properties "The Sundarbans" (Bangladesh) and "Sundarbans National Park" (India), further welcomes the efforts made by both States Parties to enhance collaboration, and urges the State Party of Bangladesh to fully implement, as a matter of utmost urgency, the recommendations made by the 2016 mission in relation to ensuring adequate freshwater inflows to the property."
Above decision clearly indicates that some progress has been made by Bangladesh regarding ecological monitoring and regional cooperation and should get due credit for it.
 WHC also "welcomes furthermore the development of a draft "National Oil Spill and Chemical Contingency Plan" (NOSCOP), and further requests the State Party to ensure adequate provision of funding and human resources for the implementation of the plan once it is adopted, and to provide further information and data on the monitoring of long-term impacts from recent shipping incidents involving spills of hazardous materials in proximity to the property."
I believe that this plan should be considered in proposed SEA. This is a critical issue and skilled manpower is required in order to implement this plan effectively. Such plan in UK is tied up with emergency planning resources.
WHC 41st session "regrets that the State Party did not update the Environmental Impact Assessment (EIA) for dredging of the Passur River to include an assessment of impacts on the Outstanding Universal Value (OUV) of the property, as requested by the Committee, and reiterates its request to the State Party to ensure that no dredging activities are conducted before the current EIA is revised in accordance with IUCN's World Heritage Advice Note on Environmental Assessment."
Decision for not updating EIA is not good news for Bangladesh. EIA is a dynamic document. When new data and information become available, then this document should be updated.
WHC also takes note of the mission's conclusion that "the Rampal coal-fired power plant has a high likelihood for impacts on the property arising from air and water pollution, a substantial increase in shipping and dredging, and additional removal of freshwater from an already increasingly saline environment, and that there is insufficient evidence available to demonstrate that these impacts can be mitigated, and requests furthermore the State Party to ensure that these impacts are comprehensively assessed as part of the SEA, and in accordance with IUCN's World Heritage Advice Note on Environmental Assessment, and also urges it to not proceed further with implementation of the Rampal power plant in its current location."
This suggests that SEA need to extend further about the item that EIA addressed before, because EIA carried out before did not sufficiently address several environmental impacts as mentioned above.
WHC requests the State Party "to submit to the World Heritage Centre, by 1 December 2018, an updated report on the state of conservation of the property and the implementation of the above, for examination by the World Heritage Committee at its 43 session in 2019, with a view to considering, in the absence of substantial progress in the implementation of the above-mentioned recommendations, the possible inscription of the property on the List of World Heritage in Danger."
In a nutshell, decision from the 41st session mentioned above suggests that Bangladesh has made some progress about ecological monitoring, trans-boundary collaboration, oil spill and chemical contingency plan and also received appreciation for not approving Orion power plant and phase II of the Rampal Power Plant but there are some regrets also such as not updating EIA, insufficient information in EIA and also Rampal power plant should not proceed without SEA, which need to be reviewed by IUCN. If the above mentioned recommendations are not properly carried out, then possible inscription of Sundarban on the list of "World Heritage in Danger" cannot be ruled out.
In my essay published in the Daily Observer dated 2 September 2016 I touched upon the issue of EIA and reviewed the Coal-fired power plant installation in Rampal. If we believe that coal-fired power plant effect the environment and after SEA we find that there is no other alternative location and impact on environment will not be what we believe to be, then we might alter our view. British economist John Maynard Keynes, once said, 'when the facts change, I change my mind. What do you do, Sir'. English Statistician Thomas Bayes, in his theorem known as Bayes theorem states that for any views that you hold you should always be willing to use new evidence to update your beliefs. I am happy to do this and wait for Strategic Environmental Assessment, though this should have done before adoption of any programme in the south-west region of Bangladesh.

Dr Kanan Purkayastha is a UK based Environmental Advisor, Writer and Researcher. The views expressed in this article are the author's own and do not reflect the view of the organisation he works.