Pollution Abatement Strategies for Rivers and …ext.bd.undp.org/CCED/bgdp/BGDP Materials/Review Documents...Pollution Abatement Strategies for Rivers and Wetlands in and Around Dhaka

Pollution AbatementStrategies for Rivers and Wetlands in and Around

Dhaka City

February 2010

Parliamentary Standing Committee on Ministry of Environment & Forests

February 2010

Pollution AbatementStrategies for Rivers and Wetlands in and Around

Dhaka City

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Executive SummaryE1. Background

The water quality of all the five rivers around Dhaka, including Buriganga, Balu and the Lakhya, is deteriorating rapidly due to pollution from industrial and municipal sources, and the situation turns particularly alarming during the dry season. Due to the deteriorating quality of the raw water coming through its intake structure at Sarulia, the Saidabad water treatment plant is facing serious problems in treating drinking water during the dry season. Apart from pollution, the other serious issue of concern is unabated encroachment of the rivers, inland khals, wetlands and other water bodies. The effects of encroachment and filling up of khals, lakes and wetlands, both by public and private agencies become devastating during floods, and frequent water logging on the streets of the city results from consequent drainage congestion.

E2. Mission Objectives

In the backdrop of such a dismal situation, the newly elected government has decided to address two very serious related issues – pollution and encroachment of rivers, khals, and wetlands in and around Dhaka city. The government has taken the move to vacate the encroached water bodies as well as to address pollution management in an effort to make Dhaka a place for sustainable living. In support of this endeavor by the government, the United Nations Development Programme (UNDP) has fielded a Mission to provide technical support to the Sub-Committees of the Parliamentary Standing Committee on River Pollution and Illegal Land Occupation to come up with a vision and action plan to save and restore the rivers and other wetlands in and around Dhaka city.

The Mission objective is to come up with related policy recommendations and technical interventions for long term sustainability considering the socio-economic, institutional, and environmental and climate change aspects. In order to achieve the Mission objective, this particular report addresses the pollution status of the rivers and associated

wetlands within Dhaka City. Specific pollution abatement strategies in terms of both policy recommendations and technical interventions have been analyzed and listed for the Parliamentary Standing Committee to discuss and consider for implementation.

E3. Status of Dhaka Watershed

The river system in the Dhaka watershed includes Dhaleswari, Turag, Tongi Khal, Buriganga, Balu, Bangshi and Sitalakhya Rivers as shown in Figure 2.1. All the rivers can be classified under two systems – the Balu- Sitalakhya river system and the Turag-Buriganga-Bangshi-Dhaleshwari river system. The surface water quality in the two river systems and other surface water bodies e.g. khals and ponds have very high BOD, COD and E-coli content indicating discharge of untreated industrial effluents and domestic sewage. The organic pollution of the rivers is contributed by the poor state of sewerage and sanitation system of the Dhaka urban area. The Pagla Sewage treatment plant has an installed capacity of 120 MLD and presently operates at 1/3rd of its capacity. There are 19 primary discharge points to the rivers and at least 41 secondary discharge points within the city (IWM, 2007) that drain mixed effluent including untreated wastes from industrial units like tanneries, dying and bleaching units. In addition to sewage, the inefficient solid waste management system with only 50% of the municipal solid waste being collected by the city corporation results in most of the wastes disposed into water bodies, low lying areas and khals.

As a result of the high pollution levels, many sections of the rivers and canals in the city and surrounding areas are biologically dead particularly during the dry season, with most of this water unfit for any human use even for irrigation. Surface water pollution from discharge of untreated sewage and industrial effluents impacts all Dhaka residents either by higher health care cost associated with water borne disease or by lost productivity (World Bank, 2007).

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Turag

Balu

Sitalakhya

Buriganga

Dhaleshwari

Dhaleshwari

Tongi Khal

Figure E1: Image map showing Dhaka watershed and peripheral rivers

E4. Khals, Lakes and Water Bodies within Dhaka City

Once characterized by numerous freshwater natural khals (canals) and wetlands, Dhaka city has, over the decades turned into a city of water logging and drainage congestion. Two extremely unacceptable processes are ongoing at present with the drainage system of Dhaka city – on the one hand the natural drainage khals and wetlands are being encroached and filled up by different vested groups leading to serious drainage congestion, and on the other indiscriminate discharge of untreated domestic sewage and industrial effluent is grossly polluting these water bodies making them totally unusable for any intended purpose. The inland drainage conveyance khals have virtually become wastewater khals discharging into the peripheral rivers

resulting in gross pollution of these rivers. In addition, the practice of indiscriminate disposal of municipal solid wastes into khals and wetlands within the city in absence of an efficient solid waste collection system, further deteriorates the water quality of the inland khals and water bodies that eventually contributes to increase the pollution level of the peripheral rivers.

A large number of khals, lakes and water bodies in different parts of Dhaka are in a dismal state. Many of these khals have been encroached or replaced by box culverts leading to primary drainage congestion. These water bodies, which could serve to refresh the city environment, are in fact polluting the environment by acting as dumping grounds for domestic and industrial wastes, breeding grounds for mosquitoes and by spreading diseases. The effects of the encroachment and filling up of khals, lakes and wetlands,

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both by public and private agencies become devastating during floods. These practices of encroachment and pollution, unless stopped forthwith, will lead to a situation when the city will not be livable anymore.

While the western Dhaka relies on pump drainage, the eastern Dhaka relies on gravity drainage system based on khals and wetlands. In order to protect Dhaka from frequent internal floods, a total of at least 40% of the 166 km2 drainage catchment area (within eastern Dhaka) must be delineated and protected as wetlands and water bodies under the purview of Wetland Conservation Act 2000. Considering the urgency of the matter in the backdrop of rapid filling up of low lands, and to protect the city from frequent flooding and damage of its ecosystem, it is strongly proposed that these 40% wetlands including the reserved ponds/lakes be declared by the Ministry of Environment and Forest as ecologically critical area (ECA) through official gazette notification without much delay. Of 40%, a minimum of 12% of the drainage catchment area equivalent to about 20 km2 can be made available as reserved ponds or lakes and developed as water parks and the rest 28% protected as natural wetlands for the retention of storm water.

E5. Solid Waste Management of Dhaka City

With about 50% of the waste being collected and disposed from the city, the remaining wastes are being dumped in low lying areas, khals, city drainage system, and also directly into rivers. 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 industrial wastes are not categorized as hazardous or non-hazardous and are disposed with ordinary municipal waste.

Land requirement for solid waste disposal is very high. Unless volume of solid waste could be reduced, this is going to be a major problem for the DCC. Both surface and groundwater pollution and pollution of the total

environment (water, air, soil) surrounding landfill sites are also major concerns.

In Dhaka city, with more than 60% organic, our solid wastes are very much suitable for composting. Composting can significantly reduce land requirement for final disposal of solid waste According to some preliminary estimates, with composting land requirement could be reduced by about 75%. Sale of compost could be a good source of income/ revenue for the DCC and in fact it could make the SWM profitable. Composting has great environmental benefits. Composts are excellent soil conditioner and can have a significant positive impact in our agricultural sector. Recent information suggests that there is a good demand/ market for compost in Bangladesh.

While it may take some time to introduce source reduction and separation practice in Dhaka city, implementation of “integrated solid waste management” approach at waste disposal sites would bring significant changes in the present solid waste management scenario. It is therefore, recommended that DCC gives serious consideration to ISWM while designing disposal sites. Employing ISWM in all other cities and in small and medium towns of Bangladesh would lead to sustainable waste management and bring in multidimensional benefits including positive impact in agricultural sector, avoidance of drainage congestion and abatement of pollution..

E6. Pollution Abatement Strategies

As mentioned earlier, pollution of Dhaka watershed is primarily caused by both, domestic sewage in absence of adequate sewerage and sanitation facilities and industrial wastewater discharges from nine major industrial clusters as studied by IWM (2007). Pollution abatement strategies therefore focus on both these sources. However, interventions related to domestic wastewater are limited to improvement of sewerage system including treatment particularly within Dhaka city and improving on-site sanitation facilities in other areas. Interventions in all the existing industrial clusters would have a variety of options depending on sizes, location and type of industries.

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The interventions could be classified in three broad categories: Policy interventions, Management interventions and Technical interventions..

Several important policy interventions have been proposed:

DWASA must urgently act to implement its own policy through rehabilitating and expanding its existing sanitary sewer network so that the Pagla sewage treatment plant runs in its full capacity of 120,000 m3 per day. Disconnection of domestic sewage discharge from storm drainage systems must be initiated immediately. Simultaneously RAJUK must monitor installation of septic tanks of appropriate design where sewer network does not exist.

It is extremely important that the government, as an immediate step towards pollution abatement, institutes an independent EIA review body drawing experts from research organizations, industry associations, media and the civil society, instead of current DoE in-house review process. The outcome of the EIA review and the accepted EIA report must be displayed in a public domain e.g., at a designated website. It is also important that regular post development environmental monitoring undertaken by project proponent is subject to a third party verification and that the information is disclosed to the public.

The government should play the vital role of promoting CP approach through policy revision, establishing model industries with integrated pollution management system and involving media and civil society for awareness building. Further the government in collaboration with donor agencies should facilitate access to funds for initial investments on clean technology adoption by industries particularly by the small and medium enterprises.

Pollution charges in the form of emission and effluent charges are the most common economic instruments used in environmental policy in developing countries. These charges are based on the quantity and the pollution potential of the discharged pollutants. Such an economic instrument needs high level of political

commitment in the form of government support and it is important that the government takes necessary steps to make provisions in the environmental policy and regulations for introducing pollution charges. Consensus among major stakeholders such as DoE, industries on which pollution charges are imposed and communities exposed to pollution, is important in implementing the policy. Well equipped and specially trained units within the DoE would be essential for this pollution charges program to be successful.

It is important that government establishes stringent control in maintaining stream water quality standards rather than focusing on uniform effluent discharge standards. This will require monitoring of the pollution load from different sources in terms of say total BOD load per day. This may further require limiting number of industries along river stretches. Until DoE strengthens its monitoring cell with adequate trained personnel and equipment, the task of monitoring can be outsourced to private sector institutions or research organizations or universities having laboratory facilities of international standard.

The current parliament should promulgate the proposed “Clean Water Act” in order to effectively minimize pollution in the waters of Bangladesh through appropriate instruments within the provision of this Act. Watershed or River wise independent management authorities should be instituted with full functional authorities and financial power to implement the provisions of this Act under the overall guidance of the office of the Prime Minister.

The government should facilitate transformation of Tejgaon industrial area into a commercial zone considering its location within the city through offering incentives for immediate relocation of major polluting industries.

The government can take immediate step to incorporate in the ECR 1997 through Gazette notification, public disclosure of environmental quality information through different public media, mandatory for DoE.

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E7. Specific Interventions

Several specific interventions have been considered in an effort to achieve pollution abatement objectives at some strategic areas. It is therefore extremely important that government and all other stakeholders join together

Policy Interventions:

Intervention Lead Institutions Time of Initiating Intervention

An independent EIA review body drawing experts from research organiza-tions, industry associations, media and the civil society

MoEF/MoL Immediate

Incorporate in the ECR 1997 through Gazette notification, public disclosure of environmental quality information

MoEF/MoL Immediate

Make provisions in the environmental policy and regulations for introducing pollution charges based on discharged loads

MoEF/MoL Immediate

Delineate and declare through Gazette notification, 40% of eastern Dhaka drainage area comprising natural wetlands and reserved ponds/ lakes as ecologically critical area(ECA)

MoEF/MoL Within 3 months

Initiate the process of enactment of the new law “Clean Water Act” MoEF/MoL Immediate

DWASA must urgently act to implement its own policy of having separate sewerage systems; initiate disconnecting of domestic sewers from storm drainage systems.

DWASA/RAJUK Immediate

Facilitate transformation of Tejgaon industrial area into a commercial zone including green industries, considering its location within the city through offering incentives for immediate relocation of major polluting industries.

RAJUK/ MoI/ DCCI/ MoF

Within 6 months

Establish model industries to promote cleaner production, waste minimiza-tion and pollution prevention involving media and civil society for aware-ness building.

Facilitate access to funds for initial investments on clean technology adop-tion by industries particularly by the small and medium enterprises.

MoEF/ MoI/ DCCI/ MoF

Within next one year

Orientation and training programs on cleaner production, waste minimiza-tion and pollution prevention, ISO 1400 and EMS for management staff and trainers of industries

MoEF/ Training Insti-tutes/ Industries

Within 6 months

to abate pollution at these strategic locations with a combination of policy, management and appropriate technical interventions. Some policy and management interventions as listed in the table below are common for all areas. Technical and policy interventions that are different for different areas are discussed below separately.

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Management Interventions:


Using alternative raw materials, pollution prevention program by changing processes within the industry, and recovery of process chemicals

Individual Industry/ MoEF

Immediate

Segregation of organic pollution stream from chemical process water for storage, treatment and disposal separately


Immediate

Storage of wastewater during the dry season, preferably after physico-chemical treatment and chemical recovery


Immediate

Physical Interventions:


Addressing pollution of Balu-Sitalakhya river system:

Off-site biological treatment of organic pollution from both domestic and industrial sources at Dasherkandi near Trimohini- Norai Khal before dis-posal into Balu-Sitalakhya river system.

DWASA Within 3 months; Dura-tion 3 years

Capturing industrial and domestic wastewater from storm water drainage system and diverting these waste loads from Begunbari-Hatirjheel area to the treatment plant at Dasherkandi.

DWASA Ongoing

On-site ETP at individual industry site primarily for physico-chemical treat-ment and chemical recovery in Tejgaon industrial area.


Within 6 months;

Duration 1 years

Improvement of sewerage system in central Dhaka area through rehabilita-tion and expansion of domestic sewerage facilities with provision of treat-ment facilities for the north-eastern part of Dhaka

DWASA Immediate

A large CETP at the downstream end of DND drainage khal to treat about 500000 m3/day

DWASA Within next one year

5 CETPs of varying sizes at Shyampur, Kashipur, Godnail, Jelepara and Kil-larpool to treat clusters of polluting industries of Narayanganj

MoI/ DCCI/ MoEF Within 6 months;

Duration 2 years

Individual ETP for large polluting industries e.g., Bengal Paper Mill, Narayan-ganj


Within 6 months

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Improve on-site sanitation of Narayanganj with effluent and sludge manage-ment facilities

Narayanganj Munici-pality

Within 3 months

3 CETPs of varying sizes at Kanchpur, Tarabo, and Rupshi to treat clusters of polluting industries of Tarabo

MoI/ DCCI/ MoEF Within 6 months; Dura-tion 2 years

Individual ETP for large polluting industries e.g., Rahman Chemicals, and Sobnom Oil Mill of Tarabo Industrial cluster


Within 3 months; Dura-tion one year

3 CETPs of varying sizes at Tongi BSCIC area, Tongi industrial area, Cherag Ali to treat clusters of polluting industries of Tongi

BSCIC/ MoI/ DCCI/ MoEF

Within 6 months; Dura-tion 2 years

Addressing pollution of Turag-Buriganga-Dhaleshwari river system:

Capturing industrial effluent from Hazaribag (about 20000 m3/day) and domestic wastewater from storm water outlets and diverting these waste loads from Buriganga to the Pagla Sewage Treatment Plant that currently runs at less than a third of its capacity. About 14 km long Diversion Sewer along the bank of the river with three lift stations and 10 diversion struc-tures, would be required.

DWASA Within 6 months; Duration 2 years

On-site chrome recovery plants (common or individual) at Hazaribag. Individual Industry/ MoEF/ UNIDO

Within 3 months; Dura-tion 1 years

Common treatment plants at appropriate locations following the outfalls of DEPZ

BEPZA/ BoI/ MoEF Within 3 months; Dura-tion 1 years

Common treatment plants at appropriate locations one for each major area of industrial concentrations, such as Konabari, Kashimpur of Gazipur

DCCI/MoI/ BSCIC Within 6 months; Dura-tion 2 years

Individual ETP for large polluting industries in all industrial clusters Individual Industry/ MoEF

Within 3 months; Dura-tion 1 year

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E8. Clean-Up of Contaminated River Beds

It can be considered for obvious reasons that the beds of all peripheral rivers and canals within the city are heavily contaminated by pollutants from different sources. Pollution along with other types of degradation including erosion, encroachment, unauthorized and unabated commerce and business on encroached lands, and the continuing spread of unplanned urbanization is posing serious threat to the sustainability of the river systems around Dhaka city.

A wide variety of pollutants including toxic heavy metals, hydrocarbons, persistent organic pollutants (POPs), municipal and industrial organics, sewage sludge, hospital wastes, pathogens are being increasingly discharged into the rivers and canals in and around Dhaka City. As a result, the grossly polluted waters and contaminated river beds have become hazardous to human health when potentially toxic substances move through the food chain or reach groundwater used for drinking water supplies.

The current waste disposal practices within Dhaka watershed area have virtually made the river beds as sinks for a diverse range of pollutants. Clean up of the contaminated river beds have therefore, become a priority action while considering river pollution abatement strategies. To be effective and sustainable this river bed clean-up action, must follow some logical steps and be based on scientific analysis.

The recent government initiative of excavating Buriganga river bed on an experimental basis deserves appreciation in that it reflects the positive move by the government in an effort to restore the dying rivers around Dhaka City. However, the initiative lacks a comprehensive planning that is essential for excavation of contaminated bed materials, contaminant characterization, treatment of various contaminants, identification and preparation of disposal locations for final disposal of the bed materials. The logical steps to be followed for river bed clean-up action:

1. Delineation of alignment and channel width (flood plain width) of each river

2. Identification of point sources of pollution

3. Complete stoppage of pollution discharges from all identified point sources

4. Minimizing non-point source pollution through changing basin management practices

5. Sampling and scientific laboratory analysis of bed sediment volume and contaminant characteristics

6. Establishing procedure for excavation of river beds

7. Based on scientific analysis of bed sludge, separating contaminants e.g., plastics, degradable and non-degradable

8. Identification of disposal methods and sites according to contaminant characteristics

9. Appropriate treatment and disposal of different fraction of contaminants

10. Setting a realistic timeframe for phased remediation of contaminated river beds

Ideally the most suitable and safe option would be to transport the excavated materials to sanitary landfill for disposal. However, the only available Matuail landfill at Demra would not be adequate for disposal of huge volume of dredge spoils from all the peripheral rivers. It is therefore, important that the government look for some vacant lands appropriate for disposal. A comprehensive plan would involve

identification and acquisition of some nearby vacant lands,

erecting appropriate platforms for dewatering,

separating non-degradable plastics and inorganic materials,

preparing the beds with adequate drainage facilities for filling with remaining dredge spoils that would be mostly organic, and

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procuring cover materials.

Non-degradable plastics and polythene could be recycled for making lower grade plastic items of various uses. It is also important to address the issue of groundwater contamination from leaching of excavated soil that might contain dissolved toxic chemicals.

E9. Cost of Interventions

As mentioned earlier, pollution abatement interventions could be classified into three categories – policy, management and physical interventions. Policy and management interventions do have inherent costs involvement but could be far less compared to the costs involved in physical interventions required in the field and therefore not included in the estimates. Estimates of costs for different interventions have been mentioned but they are very indicative.

Actual cost estimates should be prepared based on detailed design of each intervention. The indicative costs for immediate interventions discussed in this report would be around BDT 21000 million (USD 300 million). Costs of clean-up of river beds are not included and should be determined based on analysis mentioned above.

While the physical interventions would require significant government investments, the private sector industries can be motivated to come forward with investments for their own ETPs. Some kind of fiscal incentives, for instance, tax exemption on imported ETP equipments could be an effective motivational factor. The government may also play the role of a facilitator in arranging finances from commercial banks, Industry Bank, Shilpa Rin Shangstha or other sources.

E10. Sequencing Interventions and Timeframe

The scale of the problems related to water pollution in Dhaka watershed is so large and there are so many interventions that need to be implemented simultaneously in order to achieve objectives of pollution management that it becomes difficult to sequence them one after another.

It is therefore, considered to be based on the urgency of addressing pollution of a particular river system. While most of the policy interventions can be initiated without much delay and with significant outcomes, technical interventions have been sequenced considering priority areas.

Given the present pollution status of all the rivers around Dhaka watershed and the khals and water bodies within the city, it is extremely important that the government moves fast in order to save the rivers and water bodies from further deterioration and to make Dhaka city a place for sustainable living. All the specific interventions including policy, management and technical interventions can be initiated immediately. It may be necessary for the government to spend 3 to 6 months for planning, locating sources of funds and for administrative formalities. Policy and management interventions may require further discussions in relevant parliamentary committees but can be initiated without much delay.

All the specific interventions discussed in this report are relevant and can be undertaken within the current year and it is possible that most of the physical interventions can be completed within a time frame of 4 years. It is expected that these interventions if implemented, will bring about significant improvements in the quality of life of the Dhaka city dwellers.

E11. Institution for Sustainable Watershed Management

In absence of a strong institutional arrangement, coordinated efforts and effective governance, the people and the economy are paying high price for the degraded environment in the Dhaka watershed. Many institutions e.g., the Department of Environment, DWASA, Dhaka City Corporation, RAJUK, adjacent Municipalities, BIWTA, BWDB, and the DC of Dhaka are all relevant to the issues of encroachment and pollution of rivers and water bodies in and around Dhaka. The segmented roles and responsibilities of these institutions result in a situation when critical issues like encroachment and filling up of water bodies, discharge of untreated industrial and domestic wastes remain virtually unattended.

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With shared ownership, powers and responsibilities, and due to lack of effective coordination, these institutions are apparently not in a position to protect, develop and manage the Dhaka watershed that includes six peripheral rivers including the floodplains, city lakes, canals, and wetlands. It is therefore important that the government gives a serious consideration to establish a new institution with full ownership, power and responsibilities to protect, restore, develop and manage the entire Dhaka watershed.

The proposed institution may be styled as “Dhaka Watershed Management Authority” and should be headed by a public representative, preferably with the rank and status of a full Minister, and guided by a statutory Board with representatives from relevant stakeholders including local MPs, civil society, experts, university professors, regulatory and administrative agencies, media and eminent personalities. The detailed terms of reference (ToR) of the institution head, and the members of the Board, and the required organogram should be developed through discussions at appropriate forum.

E12. Concluding Remarks

The pollution status of Dhaka watershed is in a grave situation. The water quality indicator, Dissolved Oxygen (DO), demonstrates extremely low value (much less than the standard of 5 mg/L and in most situations less than 1 mg/L) all around the river system and in the khals and lakes

of the city. At some critical points in time water bodies at specific locations demonstrate complete devoid of oxygen representing septic condition when no aquatic life form can survive and the water becomes unusable for any intended purpose. The scale of the problem is so huge that only a handful immediate solution package cannot address all related issues. The above lists of interventions therefore by no means exhaustive and there would be more to improve continually.

However, the interventions recommended in this report will certainly bring positive changes in the water quality status of the water bodies within Dhaka watershed and improve significantly the level of DO. It is expected that the DO level would rise close to 4 mg/L, given all policy, management and physical interventions are implemented, and the water quality would then be suitable for many uses including that for drinking water supply source.

The listed interventions would significantly minimize pollution of rivers and water bodies in and around Dhaka city thereby providing its dwellers a way forward towards sustainable living. It is strongly recommended that the Policy, Management and Technical Specific Interventions are discussed in appropriate forum and necessary actions are taken without much delay. Physical interventions in the field are however, subject to feasibility and all interventions are subject to environmental assessment which can also be done immediately.

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Contents EXECUTIVE SUMMARY II

ACRONYMS & ABBREVIATIONS XIII

CHAPTER 1 1

CONTEXT 1

1.1 Background 1

1.2 Mission Objectives 2

CHAPTER 2 3

POLLUTION SCENARIO OF DHAKA WATERSHED 3

2.1 Status of Dhaka Watershed 3

2.2 Balu-Sitalakhya River System 3

2.2.1 Pollution Sources 3

2.2.2 Water Quality Status 6

2.3 Turag-Buriganga-Dhaleshwari River System 6

2.3.1 Pollution Sources 6

2.3.2 Water Quality Status 6

2.4 Effects of Water Pollution 7

CHAPTER 3 9

PROTECTING KHALS, LAKES AND WATER BODIES OF DHAKA CITY

FROM ENCROACHMENT, FILLING-UP AND POLLUTION 9

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3.1 Present Status 9

3.2 Improvement Proposals 12

3.3 Solid Waste Management 16

CHAPTER 4 18

POLLUTION ABATEMENT STRATEGIES 18

4.1 Intervention Strategies 18

4.2 Policy Interventions 19

4.2.1 Ensuring Existing Policy Implementation 19

4.2.2 Ensuring Effective Environmental Assessment (EIA) of Industries/ Projects 19

4.2.3 Promotion of Cleaner Production 20

4.2.4 Introducing Pollution Charges 20

4.2.5 Enforcing Ambient Stream Water Quality Standards 21

4.2.6 Promulgation of a New Law: “Clean Water Act” 21

4.2.7 Reviewing Land Zoning and Recent Transformation Processes 22

4.2.8 Public Disclosure of Environmental Information 22

4.3 Management Interventions 22

4.3.1 Internalizing environmental management within industries 22

4.3.2 Adopting ISO 14000 in industries 23

4.3.3 Waste minimization in industrial processes 23

4.3.4 Environmental Monitoring Program 23

4.4 Specific Interventions 23

4.4.1 Pollution Abatement of Balu-Sitalakhya River System 24

4.4.2 Pollution Abatement of Turag-Buriganga-Dhaleshwari River System 28

4.4.3 Clean-Up of Contaminated River Beds 30

CHAPTER 5 32

SEQUENCING POLLUTION ABATEMENT INTERVENTIONS 32

5.1 Policy Interventions 32

5.2 Management Interventions 33

5.3 Technical Interventions 33

5.4 Cost of Interventions 34

5.5 Time Frame for Interventions 34

5.6 Institution for Sustainable Watershed Management 35

5.7 Concluding Remarks 36

REFERENCES 36

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ACRONYMS & ABBREVIATIONSBEMP Bangladesh Environmental Management

Project

BEPZA Bangladesh Export Processing Zone Authority

BGMEA Bangladesh Garments Manufacturing and Exporters’ Association

BOD Biochemical Oxygen Demand

BoI Board of Investment

BSCIC Bangladesh Small and Cottage Industries Corporation

BUET Bangladesh University of Engineering and Technology

BWDB Bangladesh Water Development Board

CETP Combined Effluent Treatment Plant

DCCI Dhaka Chamber of Commerce and Industries

DEPZ Dhaka Export Processing Zone

DO Dissolved Oxygen

DoE Department of Environment

DWASA Dhaka Water Supply and Sewerage Authority

ECA Ecologically Critical Area

EIA Environmental Impact Assessment

EMS Environmental Management System

EPZ Export Processing Zone

EQS Environmental Quality Standard

ETP Effluent Treatment Plant

FBCCI Federation of Bangladesh Chamber of Commerce and Industries

GoB Government of Bangladesh

IWM Institute of Water Modelling (erstwhile SWMC)

ISO Organization of International Standards

JICA Japan International Cooperation Agency

MoEF Ministry of Environment and Forests

MoF Ministry of Finance

MoI Ministry of Industries

MoL Ministry of Law

MLD Million Liters per Day

RAJUK Rajdhani Unnayan Kartripakhya (Capital Development Authority)

SWTP Surface Water Treatment Plant

ToR Terms of Reference

UNDP United Nations Development Programme

UNIDO United Nations Industrial Development Organization

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Context1.1 Background

Water pollution is caused primarily by the acts of human that introduce extraneous substances into the water environment thereby causing unfavorable changes. These changes in turn affect human by endangering his health, harming the ecosystem and by interfering with legitimate use of the water resources. The effects of water pollution are of great concern and can cause serious impairment to healthy living. The immediate effects of water pollution could be seen as

health problems by affecting human health and lives;

economic problems by affecting the value of human property and materials;

ecological problems by disturbing eco-balance, interfering with conservation of water resources and threatening the existence of species; and

aesthetic problems by affecting human sense.

Overpopulation, unplanned urbanization and unregulated industrialization are among characteristic phenomena that are taking place in many places of Bangladesh including Dhaka. These processes are primarily responsible for generating increasing amount of wastes leading to water pollution. Furthermore, higher water temperatures and changes in extremes, including floods and droughts, due to climate change, are projected to affect water quality and exacerbate many forms of water pollution – from sediments, nutrients, dissolved oxygen, pathogens, pesticides and salt, as well as thermal pollution, with possible negative impacts on ecosystems, human health, and water system reliability and operating costs.

Dhaka city, 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, primarily during the last two decades has led to a shortfall in urban services infrastructure thereby resulting in severe environmental degradation and strain on its environmental resources. The demand for potable water in the city is estimated to be over 1500 Million Liters per day (MLD) of which only about 15% is supplied from the Sitalakhya and Buriganga rivers via two water treatment plants located at Chandighat and Saidabad. Cumulatively more than 80 % of the total water requirement is dependent on ground water. The rampant extraction of ground water throughout the watershed has resulted in depletion of the ground water levels by approximately 3 m/year.

The water quality of all the five rivers around Dhaka, including Buriganga, Balu and the Lakhya, is deteriorating rapidly due to pollution from industrial and municipal sources, and the situation turns particularly alarming during the dry season. Due to the deteriorating quality of the raw water coming through its intake structure at Sarulia, the Saidabad water treatment plant is facing significant problems in treating water during the dry season.

Discharge of untreated industrial effluents in rivers is primarily responsible for such water pollution. Besides, human waste and agricultural runoff containing toxic pesticides is also causing pollution of surface water bodies including rivers, ponds and canals. Discharge of spent fuel, oil and other wastes from water transports and accidental oil spill on the peripheral rivers of Dhaka have caused devastating impact on the aquatic flora and fauna of these rivers.

Apart from pollution, the other serious issue of concern is unabated encroachment of the rivers, inland khals, wetlands and other water bodies. The effects of encroachment and filling up of khals, lakes and wetlands, both by public and private agencies become devastating during floods, and frequent water logging on the streets of the city results from consequent drainage congestion. The satellite image map of Figure 1.1 indicates indiscriminate filling up of low lands and wetlands of Dhaka city.

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Po l l u t i on Aba temen t S t ra t eg i e s fo r R i v e r s and Wet l ands i n and A round Dhaka C i t y2

1.2 Mission Objectives

In the backdrop of such a dismal situation, the newly elected government has decided to address two very serious related issues – pollution and encroachment of rivers, khals, and wetlands in and around Dhaka city. The government has taken the move to vacate the encroached water bodies as well as to address pollution management in an effort to make Dhaka a place for sustainable living.

In support of this endeavor by the government, the United Nations Development Programme (UNDP) has fielded a Mission to provide technical support to the Sub-Committees of the Parliamentary Standing Committee on River Pollution and Illegal Land Occupation to come up with a vision

Turag

Balu

Sitalakhya

Buriganga

Dhaleshwari

Dhaleshwari

Tongi Khal

Figure 2.1 Satellite Image Map showing the Dhaka Watershed

and action plan to save and restore the rivers and other wetlands in and around Dhaka city.

The Mission objective is to come up with related policy recommendations and technical interventions for long term sustainability considering the socio-economic, institutional, environmental and climate change aspects. In order to achieve the Mission objective, this particular report addresses the pollution status of the rivers and associated wetlands. Specific pollution abatement strategies in terms of both policy recommendations and technical interventions have been analyzed and listed for the Parliamentary Standing Committee to discuss and consider for implementation.


Pollution Scenario of Dhaka Watershed2.1 Status of Dhaka Watershed

The watershed of Dhaka covers an area of approximately 1,500 km2 (IWM, 2007) including the Dhaka Metropolitan Area (260 km2), Dhaka-Narayanganj- Demra project area (56 km2), Narayanganj (20 km2) and approximately 1,000 km2 are in Tangail, Gazipur, Manikganj and Narayanganj District. The river system in the Dhaka watershed includes Dhaleswari, Turag, Tongi Khal, Buriganga, Balu, Bangshi and Sitalakhya Rivers as shown in Figure 2.1. All the rivers can be classified under two systems – the Balu- Sitalakhya river system and the Turag-Buriganga-Bangshi-Dhaleshwari river system. Tongi khal connects Turag and Balu and flows to either river depending on their flow conditions.

The surface water quality in the two river systems and other surface water bodies e.g. khals and ponds have very high BOD, COD and E-coli content indicating discharge of untreated industrial effluents and domestic sewage. The organic pollution of the rivers is contributed by the poor state of sewerage and sanitation system of the Dhaka urban area. Presently, the underground sewer network of Dhaka city covers only 30% of the area of the existing urban areas, and 20% of the population residing in it. Sanitation facilities like septic tanks and soak pits are poorly or inadequately designed. The sanitation facilities in slum are even poorer.

The Pagla Sewage treatment plant has an installed capacity of 120 MLD and presently operates at 1/3rd 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 (IWM, 2007). Many of these discharge points drain mixed effluent including untreated wastes from industrial units like tanneries, dying and bleaching units.

In addition to sewage, the inefficient solid waste management system with only 50% of the municipal solid waste being collected by the city corporation results in most of the wastes disposed into water bodies, low lying areas and khals. 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, with most of this water unfit for any human use even for irrigation. Surface water pollution from discharge of untreated sewage and industrial effluents impacts all Dhaka residents either by higher health care cost associated with water borne disease or by lost productivity (World Bank, 2007).

2.2 Balu-Sitalakhya River System

2.2.1 Pollution Sources

The major sources of pollution in the entire Dhaka watershed are as follows.

Municipal / domestic wastewater

Industrial effluent

Urban and rural run off

Agricultural run off

Drainage / leaching from land disposal of liquid and solid wastes

The Balu River originates from north of Dhaka and is about 30 kilometer long and joins Sitalakhya near Demra, and receives discharge from the Tongi khal located north of Dhaka and a number of other inland khals including the Norai khal. Norai khal receives waste load from a number of khals including Mohakhali khal, Gozaria khal and Manda khal. It also receives the industrial waste load from the Tejgaon industrial area through the Begunbari khal. Non-point source pollution is also significant for the Balu river system. In the

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absence of sewerage system and sewage treatment plant, municipal wastes from areas adjacent to the Norai khal and Dholai khal, e.g., Basabo, Madartek, Goran, Nandipara, Trimohoni and Khilgaon, flow into these khals. Municipal wastes from areas such as Rampura, Badda, Maradia, and Merul also flow into the Norai khal through different drains and canals. Besides, these khals and the Balu River itself

Sources Pollution Route

Industrial effluent from Tongi industrial cluster having more than 200 industries including textile dying and chemical pharmaceutical industries

About 3800 kg BOD/day pollution load is discharged through five major outfalls directly into Tongi khal. Part of this load flows towards east into the Balu river and eventually flows to the Sitalakhya near Demra.

Domestic sewage, urban runoff from Tongi area

About 3400 kg BOD/day pollution load follows the same route as industrial pollution.

Industrial effluent from Ghorashal primarily from one fertilizer factory and two paper mills

About 5400 kg BOD/day pollution load discharged through three major outfalls directly into Sitalakhya river that travels past Dhaka and Narayanganj to discharge into Dhaleshwari.

Industrial effluent from Tejgaon industrial cluster having 130 industries including major polluting textile dying, printing, composite, washing; chemical industries, bitumen emulsion and insecticide industries.

About 42000 kg BOD/day pollution load discharged through 3/4 major outfalls into Begunbari-Hatirjheel area to Norai khal that discharges into Balu river that flows into Sitalakhya near Demra, affecting seriously the the Saidabad water treatment plant intake just 500 m downstream of the confluence, eventually flows down to Dhaleshwari to the south of Narayanganj.

Domestic sewage, urban runoff from Tejgaon and adjoining areas

A huge 18000 kg BOD/day pollution load follow the same route as industrial effluent.

Industrial effluent from Tarabo industrial cluster having major polluting industries including chemical and oil mills.

About 27000 kg BOD/day pollution load discharged through five major outfall directly into the Sitalakhya near DND area

Cooling water discharge from power plants at Siddhirganj and Haripur

A significant volume of thermal waste is being discharged directly into the Sitalakhya river raising water temperature and causing rapid depletion of dissolved oxygen

Mixed industrial and domestic sewage from a vast DND area and also scattered industrial clusters in Narayanganj

A total of about 43000 kg BOD/day pollution loads are discharged through identified seven major outfalls directly into Sitalakhya, Buriganga and Dhaleshwari rivers.

receive human waste load from the hanging latrines along their stretches.

The Sitalakhya River originates at the bifurcation of the Old Brahmaputra and is about 113 kilometers long. The river flows east of the Modhupur Tract and approaches Dhaka from the northeast. The Sitalakhya River joins the Dhaleswari

Table 2.1 Pollution Sources and Routes in Balu-Sitalakhya River System


Figure 2.1 Map showing the Dhaka Watershed (Source: IWM, 2007)


River to the south of Dhaka. Untreated industrial waste is the principal polluter of the Sitalakhya River. Industries, including polluting industries like textile-dying, chemical, pulp and paper and oil mill which have been developed along the bank of the river (primarily from Kanchan to Narayangonj) discharge their untreated waste into the river. Besides, municipal and human wastes from Narayanganj area and industrial waste from the DND area also pollute the river. Besides, non-point sources along the river also contribute to its pollution. The polluted water of the Balu River also contributes significantly to the worsening quality of the Sitalakhya River, especially during the dry season. Specific sources of pollution and the pollution route in the Balu-Sitalakhya river system can be observed from Figure 2.1 and is outlined in Table 2.1.

2.2.2 Water Quality Status

A huge pollution load of about 143000 kg BOD per day in addition to pollution from numerous non-point sources has turned the Balu-Sitalakhya river system virtually into a wastewater conveyance system particularly during the dry season of the year. Available data suggest that the Balu-Sitalakhya river system is heavily polluted with organic and human wastes, especially during the dry season, as indicated by the low values of DO and high values of Coliform. Since 1989, the DO concentration in the Balu River have been much below the critical level of 4 mg/l; in the Sitalakhya River, the DO values have been frequently below 4 mg/l since 1997 (DoE/BEMP, 2004). Similar low DO values are also reported by IWM (2007). BUET (2007) reports much lower value of DO of around 3.0 mg/L in Sitalakhya River during February-March and less than 1.0 mg/L in waters of Begunbari khal during the same period.

Relatively high ammonia was detected in both Balu and Sitalakhya Rivers. High concentration of ammonia in water is usually an indication of bacterial, sewage, and animal waste pollution. Measured data suggest that the Norai khal is the most probable source of ammonia in the Balu river system while high ammonia concentration has been reported by BUET (2007) in Sitalakhya near Sarulia intake point. Such low values of DO reflect gross pollution of the river system, a situation where aquatic lives cannot sustain and the water

becomes unsuitable for any intended purpose including potable water supply source.

2.3 Turag-Buriganga-Dhaleshwari River System

2.3.1 Pollution Sources

Turag River originating from Bangshi near Kaliakoir flows along the western side of Gazipur, Tongi and Dhaka before joining Buriganga at Kholamora of Keranigonj that receives a huge waste load of industrial effluent from Gazipur and Tongi industrial area apart from domestic waste loads from numerous sources along its banks. Buriganga flows by the south of Dhaka meets Dhaleshwari at Dharmaganj to the south of Narayanganj and receives tremendous amount of pollution load from Hazaribag industrial cluster, domestic sewage load from a major part of Dhaka, Narayanganj and Keraniganj.

River Bangshi originating from eastern Dhaleshwari off Jamuna flows through Savar and meets again Dhaleshwari at south-western part of Dhaka and flows as Dhaleshwari up to Meghna. Bangshi River receives tremendous amount of pollution load from DEPZ and Savar industries. Sources of pollution and the pollution route in the Turag-Buriganga-Dhaleshwari River System are outlined in Table 2.2.

The Buriganga River which flows near Hazaribag is one of the most polluted rivers in Bangladesh. Besides the tannery industries, many other industrial, chemical, food processing, sanitary sewage, lubricants from launch/marine vessels etc. are polluting this river. There is a surface water intake facility of Chandnighat Water Treatment Plant, just at the downstream of the Hazaribag disposal point. The situation becomes grave especially during dry season when the flow in the river reduces to its minimum. So, the pollution generated by the tannery industries of Hazaribag has created a serious concern.

2.3.2 Water Quality Status

Available data on water quality of Buriganga and Turag suggests that the rivers are seriously polluted particularly


during the dry period. Buriganga DO drops down to less than 1.0 mg/L and a recent BUET study on bio-monitoring of Buriganga indicates no biological life in the river water. The water quality of Bangshi river is of serious concern. The recent monitoring by IWM (2007) shows DO level of 0.96 and 0.52 mg/L at two locations of the river suggesting that this river also following the path of Buriganga. Interestingly, DEPZ that is supposed to strictly maintain effluent quality has been identified as the major polluter of Bangshi.

2.4 Effects of Water Pollution

The Balu-Sitalakhya and the Turag-Bangshi-Buriganga- Dhaleshwari river systems are supposed to provide water for a variety of use including drinking, washing, cooking, bathing, recreation as well as for irrigation and fisheries, and most importantly support the life system of these rivers. Unfortunately, pollution of these natural water courses from industrial discharges and domestic sewage is having the most damaging effects on the environment.

Sources Pollution Route

Industrial effluent from Hazaribag industrial cluster having more than 100 tanneries

About 46300 kg BOD/day pollution load is discharged through three major outfalls directly into the Buriganga river and eventually flows to the Dhaleshwari near Narayanganj.

Domestic sewage, urban runoff from a large part of southern Dhaka including Hazaribag area

About 9400 kg BOD/day pollution load follows the same route as industrial pollution.

Industrial effluent from DEPZ having about 200 industries

Discharges about 31000 kg BOD/day pollution load through five major outfalls directly into Bangshi river that travels through Savar to discharge into Dhaleshwari.

Industrial effluent from Savar industrial cluster

About 2000 kg BOD/day pollution load discharged through 4 major outfalls into Bangshi and Karnatali rivers. Karnatali flows into Turag, while Bangshi flows down to Dhaleshwari.

Mixed industrial and domestic sewage from a vast area of Dhaka and also some scattered industrial clusters in Narayanganj

A significant pollution loads are discharged from numerous non-point sources directly into Buriganga and eventually to Dhaleshwari river.

Pollutants present in industrial effluents can be broadly categorized into:

(i) biodegradable organic compounds (measured in terms of biochemical oxygen demand or BOD5),

(ii) non-biodegradable or persistent organic pollutants (POPs)

(iii) heavy metals (e.g., Hg, Cr, Cd, Pb, Cu), and

(iv) a wide range of other dissolved substances, and suspended solids.

The tanneries, textiles, paper and pulp industries, food and fish industries and distilleries mainly discharge biodegradable organic wastes. These wastes undergo aerobic decomposition in the receiving water body; as a result dissolved oxygen of water goes down endangering fish and other aquatic species.


Non-biodegradable organic wastes are mainly discharged by the pesticide manufacturing, chemical and pharmaceutical industries. Many of the POPs contained in these effluents are toxic and can have a devastating effect on the aquatic environment.

Toxic heavy metals are present in the effluents from textile dying and printing, paper and pulp industry, electroplating industry, paint, pesticide and other chemical industries. Suspended solids and high concentrations of dissolved salts contained in different types of industrial effluent also pollute the receiving water body.

The effects of pollution of water from various sources can be summarized as follows:

Organic wastes

DO depletion affecting aquatic lives and damaging the ecosystem

Nutrients (C, N, P)

Algal bloom leading to eutrification, DO depletion and fish kill

POPs

Genetic disorders (Mutagens)

Birth defects (Teratogens)

Cancer (Carcinogens)

Heavy Metals (Hg, Pb, As, Cd, Cr)

Kidney, lever, and brain damage

Carcinogenic

The effects of pollution of the river systems, khals and other water bodies of Dhaka watershed on human health, productivity, environment and the economy are enormous. However, these have to be confirmed by undertaking a quantitative assessment in terms of environmental and economic losses.


C h a p t e r 3

Protecting Khals, Lakes and Water Bodies of Dhaka City from Encroachment, Filling-Up and Pollution3.1 Present Status

Inland and peripheral water system of Dhaka city serves various important purposes such as storage of flood water, storm and rainwater drainage of Dhaka city, and replenishments of groundwater resources. Apart from these, the water systems also serve as sources of water supply for various purposes and support aquatic ecosystems of Dhaka city. The natural khals, lakes and wetlands perform the primary functions of storm water conveyance and temporary detention in the overall storm water drainage system of Dhaka city. Storm water within the city collected by several networks of drainage pipes is drained through these khals that eventually discharge into the surrounding rivers.

Once characterized by numerous freshwater natural khals (canals) and wetlands, Dhaka city has, over the decades turned into a city of water logging and drainage congestion. Two extremely unacceptable processes are ongoing at present with the drainage system of Dhaka city – on the one hand the natural drainage khals and wetlands are being encroached and filled up by different vested groups leading to serious drainage congestion, and on the other

indiscriminate discharge of untreated domestic sewage and industrial effluent is grossly polluting these water bodies making them totally unusable for any intended purpose. The Gulshan, Banani and Dhanmondi lakes are also not spared from these unscrupulous practices of encroachment and pollution. The recently measured water quality of Gulshan and Banani lakes (Darda and Islam, 2009) indicate severe pollution of these lakes.

The inland drainage conveyance khals have virtually become wastewater khals discharging into the peripheral rivers resulting in gross pollution of these rivers. The situation turns grave during dry seasons. While there is no rainfall during this time, the internal drainage systems including the khals carry only concentrated wastewater from both industrial and domestic sources and discharge them into the surrounding rivers. The river waters thus become completely unsuitable for any intended purpose even for navigation as the water stinks. The intake at Sarulia, Demra located on the river Sitalakhya about 500 m downstream of the confluence between Balu and Sitalakhya draws water for the largest surface water treatment plant at Saidabad and during the dry season the raw water quality deteriorates to such an extent that the Saidabad water treatment plant faces serious operational difficulties.

The situation of Chandnighat Water Treatment Plant that draws raw water from the river Buriganga just downstream of Hazaribagh tannery waste disposal is worst particularly during dry season as the plant cannot produce water of drinking water quality standard. In addition, the practice of indiscriminate disposal of municipal solid wastes into khals and wetlands within the city in absence of an efficient solid waste collection system, further deteriorates the water quality of the inland khals and water bodies that eventually contributes to increase the pollution level of the peripheral rivers.

In Dhaka city both gravity drainage and pump drainage systems are being developed in order to protect the city from internal and external flooding. External floods occur when the water levels of the surrounding rivers is high and there are not enough flood protection works to stop the flood waters from entering the city, while the internal


floods occur due to storm rainfall and are caused by inadequate drainage facilities and their improper operation and maintenance. Although originally natural gravity drainage system worked very well with the existence of numerous khals and wetlands, in the recent past however, the western part of Dhaka has seen the development of pump drainage system with the erection of western embankment in an effort to protect the built up area following the 1988 devastating flood.

A large number of khals, lakes and water bodies in different parts of Dhaka are in a dismal state. Many of these khals have been encroached or replaced by box culverts leading to primary drainage congestion. Most of these khals and water bodies are suffering from severe pollution. These water bodies, which could serve to refresh the city environment, are in fact polluting the environment by acting as dumping grounds for domestic and industrial wastes, breeding grounds for mosquitoes and by spreading diseases.

The effects of the encroachment and filling up of khals, lakes and wetlands, both by public and private agencies become devastating during floods. In Dhaka city the rapid filling up of wetlands earmarked for retention ponds is a major area of concern for the macro-Drainage System. In addition, clogging of storm-water drainage pipes/lines and box culverts in the absence of regular maintenance, connection of domestic and industrial wastewater lines to storm drainage system, inadequate number and inappropriate placement of catch pits/ basins, inadequate drainage network, which would carry storm-water to the receiving khals and inadequate flowing khals that would carry drainage water to the surrounding rivers is making the situation worse.

DWASA has identified 50 khals in Dhaka city (see Figure 3.1) of which eight khals have been transformed into box culverts and brick sewers. About 143 km2 western part of Dhaka have been protected by erecting flood embankments following the devastating 1988 flood of which some 95 km2 catchment area drain out storm water through a number of major khals including Kalyanpur khal system, Baunia Khal, Abdullapur khal, Diabari khal, Degun khal and others measuring about 65 km long, and discharges into Turag-Buriganga river system through 3 pump stations namely,

Goran-Chatbari (22.0 m3/sec), Kalyanpur (20 m3/sec) and Dholai Khal (22.0 m3/sec).

While the total pumping capacity is inadequate compared to the requirement for the western Dhaka, the Dholai Khal pumps suffer from operational difficulties at full capacity due to gross inadequacy of retardation sump. The existing 100 hectare retarding pond area for Kalyanpur pump station is under threat of being encroached. The Goran-Chatbari pump station still has the required retarding pond area but is expected to face serious threat once the adjoining Uttara 3rd phase housing project of RAJUK is completed by filling up of the vast low land in the vicinity.

A total catchment area of about 166 km2 comprising 48 km2 of western Dhaka and 118 km2 of eastern part of Dhaka, together, drain through a system of major khals including Begunbari khal system, Girani, khal, Shegunbagicha khal, Meradia khal, Manda khal, Sutibhola khal, Boalia khal, Dumni khal and other tributaries, measuring about 75 km long discharges gravitationally into the Balu-Sitalakhya river system.

The eastern part of Dhaka is not yet protected against external flood and relies on gravity drainage system through these khals and wetlands that serve to detain storm water in addition to other ecological functions. Many of these large khals however, are subject to encroachments and wetlands are being filled up for housing projects in an unplanned and unregulated way thereby increasing the risk of inundation of the eastern as well as a significant part of western Dhaka.

The feasibility study on greater Dhaka protection project of FAP-8A prepared by JICA (1992) assessed the drainage requirements of eastern Dhaka, DND area and Narayanganj West area. The study specifically estimated storm water retention volume, pumping capacity and associated retention pond areas. For eastern Dhaka a total of about 180 m3/sec pumping at four locations would be required with a provision of about 19.0 km2 retarding pond areas, the study estimates. The estimate assumed that 75% of the eastern Dhaka area will be built up by 2010 from 30% in 1990 and that the eastern embankment will be erected.

This estimate is no longer valid as the pattern of


Figure 3.1 Existing Drainage Khals and Water Bodies of Dhaka City


development has changed over the last decade, with more covered areas in both western and eastern Dhaka that will result more runoff volume to be retained and pumped. It will therefore be extremely expensive for eastern Dhaka to go for pump drainage system.

Apart from a total of 261 km2 area of West and East Dhaka city, a significantly large 57 km2 of the DND area has its drainage system in a complete dismal situation having a total of 11 khals that are subject to encroachment due to unregulated development, receiving domestic and industrial sewage in absence of proper sanitation facilities, eventually draining through DND drainage khal into the Sitalakhya river. The drainage system of DND area is the responsibility of BWDB. The entire area has been protected by the surrounding road cum embankment with concrete flood walls from external flooding from the rivers Buriganga, Balu and the Sitalakhya.

The area originally developed for planned agricultural area is now rapidly changing to an unplanned urban area with unregulated industrial development. The entire area is crisscrossed by irrigation and drainage channels which are in dismal conditions as a result of unplanned filling up for housing and industries. The Demra pump station within the DND area operated by BWDB, having a capacity of 14.5 m3/sec much less than the estimated 64.7 m3/sec assessed by the feasibility study (JICA, 1992) on the basis of rapid urbanization and consequent increased run-off. This requirement will be much higher if the unplanned development of DND area continues.

3.2 Improvement Proposals

While it is recognized by all concerned including the government and the civil society that the practices of encroachment and pollution of the khals and wetlands of the city are not acceptable, the processes are in fact going on unabated. These practices of encroachment and pollution, unless stopped forthwith, will lead to a situation when the city will not be livable anymore. It is therefore imperative on the part of the government that immediate steps are taken in terms of policy intervention, promulgation of new laws where appropriate and physical implementation in

the field, all in association with massive public campaign on the ill effects of such immoral practices. In this section, improvement proposals have been made for the khals and water bodies in order to keep the drainage system of Dhaka city functional. The pollution abatement strategies of these khals, water bodies and peripheral rivers have been discussed in the next chapter.

The western part of Dhaka is protected by embankment and flood walls from external floods and fully relies on pump drainage system. Pumping capacity is inadequate and so are retardation pond areas. While there left no provision for expansion of retardation pond areas at Dholai khal and Kalyanpur pumping stations, it is proposed that the Goran-chatbari retardation pond area be expanded up to 5.5 km2 and that a peripheral water body of about 2.0 km2 is reserved at the periphery of the proposed Uttara 3rd phase development to avoid future water logging as the Uttara 3rd phase housing area is being developed filling up a vast area of low lands. Also the 0.5 km2 water body known as Bounia Beel and a 1.0 km2 water body on khal nos. 44 and 45 off Bounia khal are proposed to be kept reserved to facilitate drainage of the Zia international airport. The pump station on Shegunbagicha khal near Bishwa Road to drain storm water from Secretariat and Motijheel area will not be able to operate at full capacity unless the proposed 0.3 km2 retardation pond area is protected.

While the western Dhaka relies on pump drainage, the eastern Dhaka relies on gravity drainage system based on khals and wetlands. Pump drainage system is not available in the eastern Dhaka and is also not desirable as it is energy dependent and exorbitantly expensive and also has adverse environmental impacts on the adjoining areas. Given this situation, unless the existing wetlands and water bodies are protected the drainage system of eastern Dhaka will collapse and its built up areas will be subject to regular inundation.

In order to protect eastern Dhaka from frequent internal floods, a total of at least 40% of the 166 km2 drainage catchment area must be delineated and protected as wetlands and water bodies under the purview of Wetland Conservation Act 2000. Wetland areas of approximately 60 km2 (marginally less than 40%), within eastern Dhaka


have been indicated in Figure 3.2. Considering the urgency of the matter in the backdrop of rapid filling up of low lands, and to protect the city from frequent flooding and damage of its ecosystem, it is strongly proposed that these 40% wetlands including the reserved ponds/lakes be declared by the Ministry of Environment and Forest as ecologically critical area (ECA) through official gazette notification without much delay.

Section 5(1) of the Environment Conservation Act 1995 (ECA, 1995) clearly states that “if the Government is satisfied that an area is in an environmentally critical situation or is threatened to be in such situation, the Government may, by notification in the official Gazette, declare such area as an ecologically critical area.” Section 5(2) of the same act further states that “the Government shall, in the notification published under section 5(1) or in a separate notification,

specify the activities or processes that cannot be initiated or continued in an ecologically critical area.” Rule 3(1) (h) of the Environment Conservation Rules, 1997 (ECR, 1997) specifically mentions “wetland” as one of the factors for consideration while declaring any area as Ecologically Critical Area. Rule 3(2) further mentions that the Government shall, in accordance with the standards referred to in Rules 12 and 13, specify activities or processes that cannot be continued or initiated in an ecologically critical area.

The concerned Ministry of Environment and Forest of the government is clearly mandated to strictly enforce these rules for the protection of the wetlands from encroachment, filling up and pollution. Discharge of industrial and municipal liquid and solid wastes can be restricted in accordance with the Rules 3, 12 and 13 of the ECR 1997.

Figure 3.2 Wetlands of eastern Dhaka City proposed to be conserved by declaring as Ecologically Critical Area


Of 40%, a minimum of 12% of the drainage catchment area equivalent to about 20 km2 can be made available as reserved ponds or lakes and developed as water parks and the rest 28% protected as natural wetlands for the retention of storm water. Since the practice of encroachment and filling up of khals and wetlands is going on at a rapid pace defying the Wetland Conservation Act 2000, it is extremely important that the areas earmarked for reserved ponds/ lakes are acquired, protected from being filled up and made available as water parks. The identified locations and estimated areas for five ponds/lakes in the eastern fringe of Dhaka have been tentatively presented in Figure 3.3. These are located near Manda-Dakshingaon khal (2.5 km2), Nandipara-Trimohini khal (2.5 km2), Norai-Sutibhola khal (5.0 km2), Dumni-Beraid khal (6.0 km2), and Boalia-

Figure 3.3 Image maps of Dhaka City indicating locations of reserved ponds/ water bodies, proposed to be developed as Water Parks

Gobindapur khal (4.0km2).

In addition, some khals have also been identified that needs to restored, expanded and protected for smooth conveyance of storm water in the city. The proposed extensions of the identified khals have been listed below and are shown in Figure 3.4:

Kashaibari-Boalia khal extension of about 2.5 km to connect Kashaibari-Uttara Railway borrowpit

Kashaibari-Boalia khal extension of about 1.5 km to connect regulator near Nikunja 2

Khilkhet-Boalia khal extension of about 2.0 km to connect regulator near Nikunja 2


Figure 3.4 Proposed Drainage Khals and Water Retention Ponds in Dhaka City


Khilkhet-Boalia khal extension of about 1.7 km to connect regulator near Nikunja 1

Kuril-Boalia khal extension of about 2.1 km to connect regulator south of Nikunja 1

All extensions are proposed to be 50 m wide, while the downstream end of the Boalia-Bowfar khal should be maintained at least 100 m wide.

3.3 Solid Waste Management

Solid waste management of Dhaka city has remained a critical issue in the delivery of services to the city dwellers as well as in the management of city drainage system as it relates to primary and secondary drainage congestions with consequent water logging and pollution of khals, lakes, water bodies and peripheral rivers. The Dhaka city area generates approximately 3500 to 4000 tonnes/day of residential, commercial and institutional Municipal Solid Waste (MSW), while the DMDP area generates approximately 7000 tonnes/day (World Bank, 2007). However, with rapid urbanization, increasing per capita incomes and changing lifestyles, the rate of increase of MSW generation is also likely to increase as also the percentage of recyclables and non-degradable materials. At present, biodegradable organic matter constitute more than 60% of the waste.

With about 50% of the waste being collected and disposed from the city, the remaining wastes are being dumped in low lying areas, khals, city drainage system, and also directly into rivers. 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 industrial wastes are not categorized as hazardous or non-hazardous and are disposed with ordinary municipal waste.

Land requirement for solid waste disposal is very high. Unless volume of solid waste could be reduced, this is going to be a major problem for the DCC. Both surface and groundwater pollution and pollution of the total environment (water, air, soil) surrounding landfill sites are also major concerns.

Integrated Solid Waste Management

The Clean Dhaka Master Plan 2005 that has been adopted by DCC encourages collection of solid waste from households but does not place any emphasis on segregation of waste and treatment or resource recovery from waste. Composting as a method of disposal is well recognized and has been successfully implemented by “Waste Concern” an environmental NGO. However, no such initiatives have been taken or have been encouraged by the Clean Dhaka Master Plan.

In recent years, there has been an increasing recognition of the impact of waste on the environment and the need to reduce it and of the fact that it is often not waste at all, but a valuable resource. This has led to a change which turns the traditional approach on its head. Instead of dumping waste, the new focus is on reducing it. If we don’t produce waste in the first place, we don’t have anything to get rid of. And where waste is produced, the next steps are to reuse or recycle it. The best approach to managing solid waste is to avoid creating it in the first place. Once waste is created, recycling, which includes composting, is one of the most effective methods of reducing the amount of material in the waste stream. Sanitary land-filling is required for residual waste but incineration should be least preferred option.

This 3-R (reduce, reuse and recycle) principle has changed the waste management hierarchy and is now being increasingly employed worldwide. It is on this principle that the integrated solid waste management (ISWM) approach is based on. While source reduction and separation are considered important elements, ISWM approach can also be applied at the ultimate disposal point as outlined in the Figure below.

Practices that decrease, avoid, or eliminate the generation of waste are considered source reduction and can include the implementation of procedures as simple and economical as good housekeeping. Recycling is the use, reuse, or reclamation of wastes and/or materials. Treatment involves the destruction or detoxification of wastes into nontoxic or less toxic materials by chemical, biological or physical methods, or any combination of these methods. Disposal


has been included in the hierarchy because it is recognized that residual wastes will exist. The so-called “ultimate disposal” options include landfilling, land farming, ocean dumping, and deep-well injection.

In Dhaka city, with more than 60% organic, our solid wastes are very much suitable for composting. Composting can significantly reduce land requirement for final disposal of solid waste According to some preliminary estimates, with composting land requirement could be reduced by about 75%. Sale of compost could be a good source of income/ revenue for the DCC and in fact it could make the SWM profitable. Composting has great environmental benefits. Composts are excellent soil conditioner and can have a significant positive impact in our agricultural sector. Recent information suggests that there is a good demand/ market for compost in Bangladesh.

While it may take some time to introduce source reduction and separation practice in Dhaka city, implementation of “integrated solid waste management” approach at waste disposal sites would bring significant changes in the

present solid waste management scenario. It is therefore, recommended that DCC gives serious consideration to ISWM while designing disposal sites. Employing ISWM in all other cities and in small and medium towns of Bangladesh would lead to sustainable waste management and bring in multidimensional benefits including positive impact in agricultural sector, avoidance of drainage congestion and abatement of pollution.


Pollution Abatement Strategies4.1 Intervention Strategies

As mentioned in Chapter 2, pollution of Dhaka watershed is primarily caused by both, domestic sewage in absence of adequate sewerage and sanitation facilities and industrial wastewater discharges from nine major industrial clusters as studied by IWM (2007). Pollution abatement strategies therefore focus on both these sources. However, interventions related to domestic wastewater are limited to improvement of sewerage system including treatment particularly within Dhaka city and improving on-site sanitation facilities in other areas. Interventions in all the existing industrial clusters would have a variety of options depending on sizes, location and type of industries. The interventions could be classified in three broad categories:

Policy interventions

Management interventions

Technical interventions

Recognizing the recent paradigm shift from costly pollution control measures to cost effective environmental management, improved environmental performance in the industrial clusters could be achieved through a combination of policy interventions, good management practice and technical control measures.

Policy interventions may include

Ensuring existing policy implementation

Ensuring effective environmental assessment of industries

Promotion of cleaner production

Introducing pollution charges/ permits system

Enforcing ambient stream water quality standards

Reviewing land zoning and transformation processes

Public disclosure of environmental information

Management interventions should include:

Internalizing environmental management within industries

Adopting ISO 14000 series in industries

Waste minimization in industrial processes including avoidance of generation of wastes and productive utilization of generated wastes

Technical interventions will depend on specific pollution/ wastewater characteristics of a particular industry or a particular outlet or an industrial cluster as a whole. Treatment processes may include:

Treatment in individual industries employing: (a) Physico-chemical processes, or (b) Biological processes, or (c) Physico-chemical processes followed by biological treatment.

Individual pre-treatment followed by common effluent treatment for a group of industries.

Segregation of stronger effluent streams (e.g., from scouring, bleaching and dying) from weaker streams and employing appropriate treatment for each stream (in individual or common treatment plant).

Segregation of process wastewater containing recoverable chemicals from storm-water and domestic sewage and treating them separately.

Changing raw materials and processes within the industry to eliminate specific pollutants.

C h a p t e r 4


4.2 Policy Interventions

4.2.1 Ensuring Existing Policy Implementation

The Dhaka Water Supply and Sewerage Authority has the policy of developing separate sewerage system in the city. This requires that two completely separate systems are developed – the sanitary sewerage system for collection, treatment and disposal of domestic sewage from households and institutions, and the storm water drainage system for collection and disposal of untreated storm water. In practice however, DWASA is not moving in the direction that corroborates its own policy.

While over the last two decades DWASA has installed hundreds of kilometers of storm drains in an effort to address the ever increasing water logging problems, it has done virtually nothing in respect of improving the sanitary sewerage system to address the needs of the rapidly growing population of the city. The age old sanitary sewerage system which DWASA claims to have been serving about 20% of the city population is in true sense not functioning in absence of proper maintenance as evidenced by the Pagla sewage treatment plant receiving less than a third of its capacity.

Instead, by not developing the sanitary sewerage system, DWASA has virtually encouraged illegal connections of domestic sewers, directly or via septic tanks, to storm drainage system that discharges through numerous outlets into open water bodies, canals, lakes and rivers in and around Dhaka City resulting in severe sewage pollution of these water bodies. This backfires to DWASA when it considers treating surface water for water supply for the city dwellers.

DWASA must urgently act to implement its own policy through rehabilitating and expanding its existing sanitary sewer network so that the Pagla sewage treatment plant runs in its full capacity of 120,000 m3 per day. Disconnection of domestic sewers from storm drainage systems must be initiated immediately. Simultaneously RAJUK must monitor installation of septic tanks of appropriate design where

sewer network does not exist.

4.2.2 Ensuring Effective Environmental Assessment (EIA) of Industries/ Projects

Section 12 of the Bangladesh Environment Conservation Act 1995 and Rule 7 of the Environment Conservation Rules 1997 together form the basic framework for undertaking environmental impact assessment (EIA) for new or existing industries and projects in Bangladesh. The purpose of EIA is to enhance industries and projects by helping prevent, minimize, mitigate or compensate for any adverse environmental and social impacts. Since its establishment in 1989, the Department of Environment (DoE), which is mandated for the overall improvement in environmental governance, have not been able to adequately enforce regulations nor monitor non-compliance.

The EIA review process is open to manipulation and negotiation and is of particular concern. The government must recognize that EIA is an important tool for environmental management and that environmental degradation can be minimized through effective implementation of adequately designed mitigation and monitoring plans that form major parts of EIA.

It is therefore extremely important that the government, as an immediate step towards pollution abatement, institutes an independent EIA review body drawing experts from research organizations, industry associations, media and the civil society, instead of current DoE in-house review process. The outcome of the EIA review and the accepted EIA report must be displayed in a public domain e.g., at a designated website. It is also important that regular post development environmental monitoring undertaken by project proponent is subject to a third party verification and that the information is disclosed to the public.

4.2.3 Promotion of Cleaner Production

The cost of end-of-pipe treatment of industrial effluent


is becoming prohibitively high and cleaner production approach is being increasingly employed in industries globally including many countries in Asia. Cleaner production minimizes the use of resources and reduces the wastes discharged to the environment. Cleaner production can reduce pollution loads significantly thereby reducing the need for end-of-pipe investments resulting in both financial and economic gains.

A recent Dhaka watershed pollution study (IWM, 2007) estimates that the effluent flow from industries can be reduced by 50%, BOD load by 30% and the cost of end-of-pipe effluent treatment can be reduced by about 45% if source control and cleaner production approach could be introduced. It further reveals that the pollution situation of Dhaka watershed has reached to such an extent in terms of volume and strength that traditional pollution control approach employing end-of-pipe treatment only would not be feasible.

A comprehensive, integrated pollution management approach appears to be the answer for Bangladesh particularly the Dhaka watershed that essentially builds on cleaner production approach encompassing waste minimization and pollution prevention and closely linked with environmental management system (EMS) thereby reducing reliance on expensive regulatory approach of end-of-pipe treatment. The main constraints to shift from traditional command and control approach are the lack of information, scientific knowledge on clean technologies and low appreciation of the financial and economic gains by the industries, policy makers, and the civil society in general.

The government should play the vital role of promoting CP approach through policy revision, establishing model industries with integrated pollution management system and involving media and civil society for awareness building. Further the government in collaboration with donor agencies should facilitate access to funds for initial investments on clean technology adoption by industries particularly by the small and medium enterprises.

4.2.4 Introducing Pollution Charges

Pollution charges in the form of emission and effluent charges are the most common economic instruments used in environmental policy in developing countries. These charges are based on the quantity and the pollution potential of the discharged pollutants. These charges can be levied on the actual source emissions that can be directly measured or estimated discharges or in the form of a flat rate in cases of small discharges.

To be effective the pollution charges are to be set at a high level for a limited number of pollutants (World Bank, 1999), for instance, for water pollution BOD and phosphate, and for air emissions SPM, SOx and NOx. Charges should be increased gradually, with rate of increases scheduled in advance to allow industries to make timely adjustments. The ultimate level of charges should be sufficient to provide an incentive for a targeted level of pollution abatement in the watershed over a designated period of time.

Such an economic instrument needs high level of political commitment in the form of government support and it is important that the government takes necessary steps to make provisions in the environmental policy and regulations for introducing pollution charges. Consensus among major stakeholders such as DoE, industries on which pollution charges are imposed and communities exposed to pollution, is important in implementing the policy. Well equipped and specially trained units within the DoE would be essential for this pollution charges program to be successful.

4.2.5 Enforcing Ambient Stream Water Quality Standards

The effluent discharge standard controls the quality of discharges into receiving water, while the ambient stream standard controls the quality of stream water that must be maintained. The common objective of effluent discharge and stream water quality standards is to preserve the receiving natural water bodies so that they do not deplete the DO content of the receiving waters that is required for the survival of aquatic lives nor produce offensive odors or contain toxic substances.


An inherent criticism of uniform effluent standards however, has been that it can cause overburden on the stream water quality due to cumulative effects of many discharges or it can even be uneconomic because of the great variations in flow characteristics and assimilative capacities of rivers and streams. In recent years, there has been a tendency to set standards for receiving waters rather than to specify the exact degree of treatment required to attain stringent effluent discharge standards.

The recent Dhaka watershed pollution study (IWM, 2007) suggests that the pollution level has gone to such an extent that the water quality of peripheral rivers could not be restored to levels specified by ECR standards even if the polluting industries opted for costly sophisticated treatment to attain effluent discharge standards of international level.

It is therefore important that government establishes stringent control in maintaining stream water quality standards rather than focusing on uniform effluent discharge standards. This will require monitoring of the pollution load from different sources in terms of say total BOD load per day. This may further require limiting number of industries along river stretches. Until DoE strengthens its monitoring cell with adequate trained personnel and equipment, the task of monitoring can be outsourced to private sector institutions or research organizations or universities having laboratory facilities of international standard.

4.2.6 Promulgation of a New Law: “Clean Water Act”

Promulgation of this new law could be central to resolve water pollution problems caused by untreated municipal wastewater and industrial effluents and to mitigate the pollution caused by runoff from agricultural lands, city streets and other non-point sources. The provisions of this proposed act would ensure that the discharge of pollutants into water courses is a privilege and not a right and must be authorized by a mandated agency/ authority indicating type and concentration of pollutants, and any violation of the provision of this act will be subject to financial penalties and imprisonment.

The preceding two policy recommendations on pollution charges/ permits, and regulating ambient stream water quality can be mandated under this new act. To facilitate the provision of this Act it is further strongly recommended that independent “River/ Watershed Management Authorities” be instituted with full financial and administrative power under the overall supervision of the Prime Minister’s Office. The organizational structure and the terms of reference must be worked out in such a manner that the authorities can exercise their power and capacity in order to achieve the very objective of “Clean Water Act”.

The current parliament should promulgate the proposed “Clean Water Act” in order to effectively minimize pollution in the waters of Bangladesh through appropriate instruments within the provision of this Act. Watershed or River wise independent management authorities should be instituted with full functional authorities and financial power to implement the provisions of this Act under the overall guidance of the office of the Prime Minister.

4.2.7 Reviewing Land Zoning and Recent Transformation Processes

Interestingly major industries are located in clusters in and around Dhaka city although there is no formal use of industrial land zoning except Tejgaon, Tongi and Hazaribagh which has been declared as industrial zones long ago. Land zoning has the inherent advantage of addressing industrial pollution in terms of effluent treatment and regulatory measures. Given the current urbanization process however, the government needs to review its earlier land use zoning particularly Tejgaon and Hazaribagh.

These two industrial clusters are the major contributors of industrial pollution in the entire Dhaka watershed followed by Narayanganj, DEPZ and Tarabo. Pollution load from Tejgaon is considered to be the major source of Balu-Sitalakhya pollution while Hazaribagh along with domestic sewage causes serious pollution of Buriganga.

The decision of relocating Hazaribagh Tanneries cluster has already been taken by the government which needs to be expedited. Government should seriously consider


transformation of Tejgaon industrial area into a commercial zone as the area is now in the center of the city.

The government should facilitate transformation of Tejgaon industrial area into a commercial zone considering its location within the city through offering incentives for immediate relocation of major polluting industries.

4.2.8 Public Disclosure of Environmental Information

The Environment Conservation Rules 1997 incorporated Environmental Quality Standards for air, water and soil, and mandated the Department of Environment to monitor air, water and soil quality on a regular basis in order to ensure environmental protection. The Department of Environment has been monitoring the air, water and soil quality at selected locations, however, not in a regular fashion. To ensure that DoE fulfils its mandate and keep the ambient quality within the recognized limits given in the Environmental Regulation of 1997, DoE needs to disclose its findings to the public regularly. This would generate indirect pressure from the public and from the civil society on DoE to monitor the environmental quality on a regular basis. Such a disclosure policy can also educate others in the community to demand products that are cleaner than others.

The government can take immediate step to incorporate in the ECR 1997 through Gazette notification, public disclosure of environmental quality information through different public media, mandatory for DoE.

4.3 Management Interventions

4.3.1 Internalizing environmental management within industries

Sustainable environmental improvements can only be achieved when the objectives and requirement of environmental protection are internalized in the management of industries. For this to work, a better understanding is needed of what motivates those responsible for pollution and their responses to different regulations, incentives or other pressure. Industrial

associations like FBCCI, DCCI, BGMEA, Ministry of Industries, MoEF, Ministry of Water Resources, Local Authorities, together can plan pollution prevention and management programs to orient industry management towards improving environmental performance.

4.3.2 Adopting ISO 14000 in industries

Environmental management system (EMS) is a program of continuous environmental improvement that follows a defined sequence of steps drawn from established project management practice and routinely applied for business management. The common framework for EMS is the ISO 14000 series that consists of standards covering ecolabeling and life cycle assessment as well as EMS. The ISO 14000 standard requires that there be a environmental policy that includes commitment to continual improvement and pollution prevention, and a commitment to comply with relevant environmental legislation and regulation. ISO 14000 standards are voluntary but more and more industries are adopting them. MoEF should take initiatives of orienting industries to adopt ISO 14000 standards and introducing EMS.

4.3.3 Waste minimization in industrial processes

The minimization of wastes requiring disposal is becoming increasingly important as available disposal options are becoming constrained both technically and economically. Waste minimization approach often comprises avoidance that refers to actions that avoid generating wastes and utilization that make the wastes a useful input to other processes. This concept needs to be introduced in industries by demonstration projects that could be facilitated by MoEF. Pollution prevention programs are virtually based on this approach of waste minimization.

4.3.4 Environmental Monitoring Program

Systematic observation, measurement, collection and


evaluation of pollutant levels in air, water, soil and food have so far remained extremely weak in absence of a strong institutional support. While the DoE under the MoEF is mandated to carry out regular monitoring of environmental parameters in different media, this very important function could not be performed with any degree of satisfaction because of its lack of capacity that could not be strengthened since its establishment in 1989 due to a variety of reasons including lack of government commitment.

Routine monitoring is important in identifying the possible risks associated with the levels of pollutants. Detection of high levels of toxic pollutants exceeding baseline exposure level in any media through monitoring might emphasize the need for effective control measures. It is therefore extremely important that an environmental monitoring program be developed with the objective of monitoring priority pollutants (need to be identified) within the Dhaka watershed which could eventually be expanded to national level. Until DoE is strong enough to take up the sole responsibility of managing environmental monitoring system, a joint initiative may be undertaken with participation of DoE, universities (e.g., BUET, DU), research NGO and with possible support from multinational institutions.

4.4 Specific Interventions

Several specific interventions have been considered in an effort to achieve pollution abatement objectives at some strategic areas. One important objective of pollution abatement is to improve the water quality of the peripheral rivers that constitute major sources of potable water supply for the Dhaka city dwellers. The river Sitalakhya is currently providing 225 Million Liters per Day (MLD) of raw water to Saidabad Water Treatment Plant (SWTP) and has initiated expansion for another 225 MLD in the second phase and a further 450 MLD is planned for the third phase of the SWTP. Together 900 MLD from Sitalakhya could serve about 50% of the total water supply demand for Dhaka city. However, faced by operational difficulties of the SWTP due to heavily polluted raw water of Sitalakhya, the Dhaka water supply authority is considering exorbitantly expensive option of bringing raw water from distant rivers like the Meghna or the Padma, which is unlikely to be a sustainable option.

Strategically therefore, abating pollution of the Balu-Sitalakhya river system including the internal conveyance canals through a combination of pollution prevention and control measures at different sources would be much more cost effective and sustainable solution. Similar approach is also to be considered for the Turag-Buriganga-Dhaleswari river system.

4.4.1 Pollution Abatement of Balu-Sitalakhya River System

As mentioned earlier, the major sources of pollution to the Balu-Sitalakhya system include Tejgaon industrial cluster and adjoining areas, domestic and industrial pollution loads from DND and Narayanganj area discharging directly into Sitalakhya primarily through DND drainage khal, Tongi industrial and domestic discharges through Tongi khal, industrial effluent from Tarabo industrial cluster and thermal wastes from power plants discharging directly into Sitalakhya.

The largest contributor of organic pollution measured in terms of BOD loading from both industrial and domestic sources is the Tejgaon industrial cluster and its adjoining areas within central Dhaka city. The pollution load from the Tejgaon and its adjoining areas is primarily discharged into the Hatirjheel/Begunbari khal and finally falls into the Balu River through the Norai khal. The Balu river eventually discharges into the Lakhya and influences the raw water quality of the SWTP the intake of which is located about 500 m downstream of the Balu-Sitalakhya confluence.

Among 130 different types of industries the most polluting textile industries, e.g., dying, printing, composite, or washing, constitute the largest number followed by steel mills. There are 5 chemical industries, 5 bakeries, 3 bitumen emulsion factories, 1 insecticide, 2 leather, 5 plastics, 1 oil mill, and 3 soap factories generating considerable pollution loads. It can however be observed that being centrally located in Dhaka city, and given the price of land shooting very high in recent years, the land use pattern of the Tejgaon area is gradually changing, from industrial to more commercial establishment.

A recent study (IWM, 2007) estimates the pollution load from Tejgaon industrial cluster and adjoining areas in terms


of daily BOD load of about 59611 kg/day which has been confirmed by the recent Begunbari-Hatirjheel Project study (BUET, 2008) that estimated about 60480 kg BOD per day.

Both estimates measured combined domestic sewage and industrial wastewater from the area. The organic pollution load from Tejgaon, Narayanganj (including DND, 43025 kg BOD per day), Tarabo (26962 kg/day) and Tongi (7159 kg/day) all discharging into the Balu-Sitalakhya river system as estimated by IWM (2007) is 55% of the total pollution load that is discharged in the entire Dhaka watershed area.

t is therefore extremely important that government and all other stakeholders join together to abate pollution at these strategic locations with a combination of policy, management and appropriate technical interventions. Some policy and management interventions as listed below in Table 4.1 are common for all areas. Technical and policy interventions

that are different for different areas are discussed below separately.

Pollution Abatement Strategies for Tejgaon Area

Considering gradual transformation of land use in Tejgaon, government should facilitate expedite the process by providing attractive incentives for relocating polluting industries. Further the government should enforce DWASA’s existing policy of separate sewerage system and initiate disconnecting domestic sewer connections from storm drainage network. RAJUK must enforce septic tank installations as per its approved design in buildings in areas where sewerage system does not exist. DWASA should include a policy of decentralized wastewater management approach employing medium cost small bore sewerage or

Intervention Type

Description Lead Institutions Costs of Intervention and funding sources

Incentives for relocating polluting industries where appropriate as most of the industrial clusters are overloaded with polluting industries

RAJUK/ MoI/ MoF As required; Tax holiday, ensuring land availability at appropriate locations.

Introducing pollution charges on the basis of monitoring of daily pollution load discharge

Proposed Dhaka Watershed Authority/ MoEF

To be estimated

Developing EMPs for all existing industries Awareness campaign for developing EMS within industries

MoEF Institution’s own budget

Policy Intervention

Improvement of sewerage (within Dhaka city) and sanitation facilities

DWASA/ Local Municipality

Institution’s own budget



As required; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.



As above

Management Intervention

Storage of wastewater during the dry season, preferably after physicochemical treatment


As above

Table 4.1 Common policy and management interventions


Table 4.2 Proposed technical interventions for pollution abatement from Tejgaon area

simplified sewerage systems and emphasizing wastewater segregation and recycling as appropriate.

A key challenge of pollution abatement in this central part of Dhaka is to separate out domestic sewage and industrial wastewater mix from storm runoff that flows through the khals and into the river system. Then the industrial effluent that contains heavy process chemicals needs to be isolated from domestic sewage for cost effective treatment and disposal. Considering this approach as far as practicable, the following technical interventions listed in Table 4.2 are proposed for immediate implementation.

Pollution Abatement Strategies for Narayanganj and DND Area

As identified by IWM (2007) study Narayanganj and DND area together have seven major effluent outfalls from about 50 major polluting industries discharging into Sitalakhya, Buriganga and Dhaleshwari rivers. The DND drainage khal draining the entire DND area conveys a mix of storm water, domestic sewage and industrial wastewater directly discharging into the Sitalakhya river. The Narayanganj area including DND comprises industrial concentrations at different areas. The characteristics of these areas and

Intervention Type

Description Lead Institutions

Costs of Intervention and funding sources

On-site ETP at individual industry site or CETP for group of industries subject to availability of space, primarily for physico-chemical treatment.


Costs variable depending wastewater volume and pollution load; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.

Off-site biological treatment of organic pollution from both domestic and industrial sources at Dasherkandi near Trimohini- Norai Khal before disposal into Balu-Sitalakhya river system.

DWASA BDT 5000.0 Million; Government of Bangladesh; Waiting for ECNEC approval

Technical Intervention


DWASA BDT 1000.0 Million, (part of Hatirjheel integrated development project); GoB; Project ongoing.

the types of industries in these areas are quite different in nature.

There is no sewerage system or storm sewer system in the DND area, and the area is dominated by small-scale industries. Apart from policy interventions proposed in Table 4.1, the government should initiate a comprehensive planning for regulated development of the DND area with appropriate sanitation, drainage and industrial wastewater management giving due consideration to existing development pattern. The technical interventions required for this area are given in Table 4.3 below.

Pollution Abatement Strategies for Tarabo Industrial Area

The Tarabo industrial cluster is located on the bank of the Sitalakhya River stretching from the Kanchpur Bridge to Rupganj ferry ghat. Major industries in this cluster are located in the Kanchpur, Tarabo, Rupshi and Jatramura areas. Industrial effluents from this cluster are primarily discharged into the Sitalakhya River. Industrial effluent discharged into the Sitalakhya River is of particular concern because the pollution influences the raw water quality of the Saidabad water treatment plant. IWM (2007) identified about 21


major industries including 9 dyeing industries, 7 textile mills, 2 paper mills and 1 oil mill.

Policy intervention must include strict prohibition of new industrial installation along this stretch of Sitalakhya river, as this is clearly within the specified pollution control zone shown in the DMDP. The management interventions are similar to those listed for Tejgaon industrial cluster. Technical interventions required are given in Table 4.4 below.

Table 4.3 Proposed technical interventions for pollution abatement from Narayanganj and DND area

Table 4.4 Proposed interventions for pollution abatement from Tarabo area

Intervention Type



A large CETP at the downstream end of DND drainage khal to treat about 500000 m3/day

DWASA BDT 1500 Million; GoB

5 CETPs of varying sizes at Shyampur, Kashipur, Godnail, Jelepara and Killarpool to treat clusters of polluting industries

MoI/ DCCI/ MoEF

May vary from BDT 35.0 to 210.0 Million depending on size; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.

Individual ETP for large polluting industries e.g., Bengal Paper Mill

Individual Industry

BDT 100 to 300 Million

Technical Field Intervention

Improve on-site sanitation of Narayanganj with effluent and sludge management facilities

Narayanganj Municipality

To be estimated by Municipality; GoB

Intervention Type



3 CETPs of varying sizes at Kanchpur, Tarabo, and Rupshi to treat clusters of polluting industries

MoI/ DCCI/ MoEF

May vary from BDT 35.0 to 210.0 Million depending on size; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.


Individual ETP for large polluting industries e.g., Rahman Chemicals, and Sobnom Oil Mill

Individual Industry

BDT 200 to 300 Million; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha

Pollution Abatement Strategies for Tongi Area

Tongi industrial cluster is located to the east of the Dhaka city and industries in this cluster are located in the Tongi BSCIC area, Tongi industrial area, Cherag Ali, Ershad Nagar, Vhadam, Gazipura, Sataish and Nimtoli areas. Polluting industries include textile-dyeing, chemical-pharmaceutical, printing-packaging, glass-ceramic factories, foods, and other miscellaneous industries. Interventions listed in Table 4.5 are to be undertaken.


Table 4.5 Proposed interventions for pollution abatement from Tongi area

4.4.2 Pollution Abatement of Turag-Buriganga-Dhaleshwari River System

Industrial effluent discharges from Hazaribag, DEPZ, Gazipur and Savar, and domestic sewage discharge from a large part of Dhaka city through storm drain outlets are responsible the pollution of Turag-Buriganga-Bangshi-Dhaleshwari river system in the Dhaka watershed area. According to IWM (2007) study, the river Buriganga is severely affected receiving the largest pollution load (55773 kg BOD per day) from Hazaribag industrial cluster and most of the Dhaka city domestic sewage.

The whole Turag-Buriganga-Bangshi-Dhaleshwari river system further receives 31042 kg BOD/ day from DEPZ, 18922 kg BOD/day from Gazipur industrial cluster and 1757 kg BOD/day from Savar industries. Pollution abatement objective of this river system is to restore back the water quality of these rivers that may be considered as potential sources of surface water supply for Dhaka city including the small Chandnighat water treatment plant and other watershed areas including Keraniganj, Kamrangirchar, Ashulia, and Savar.

As indicated earlier, Turag receives pollutants mostly from Gazipur and Tongi industries while tremendous pollution

Intervention Type



3 CETPs of varying sizes at Tongi BSCIC area, Tongi industrial area, Cherag Ali to treat clusters of polluting industries

MoI/ DCCI/ MoEF

Variable ( BDT 35.0 to 210.0 Million) depending on size; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.


Individual ETP for large polluting industries Individual Industry

BDT 10 to 100 Million; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha

load is discharged into Bangshi river from DEPZ and Savar industries that eventually flows into Dhaleshwari. While Turag feeds into Buriganga, but the Buriganga disaster results primarily from the heaviest pollution load from the Hazaribag industrial cluster that eventually discharges into the Dhaleshwari.

To save Buriganga therefore, the first step is to stop discharging pollution loads from Hazaribag as well to divert domestic sewage disposal from numerous storm water outlets into the river. Like the Balu-Sitalakhya river system, pollution abatement requires a combination of policy, management and capital intensive technical interventions. The management interventions in industries as mentioned earlier, will significantly improve the situation thereby reducing the investment requirements for technical interventions.

Pollution Abatement Strategies for Hazaribag Industrial Area

The Hazaribag tannery cluster is the biggest tannery cluster in Bangladesh and about 85% of the country’s total production of hides/skin is processed here. On an average, about 74,000 tons of raw hides/skins are processed and a combined maximum wastewater flow from the tanneries amount to 21,600 m3/day. The tanneries are discharging


untreated wastewater, which through open drains, reach the river Buriganga, flowing closely.

The main tanning system followed in Hazaribag tannery cluster is chrome tanning. Due to insufficient control of process parameters, a good proportion of tanning salt is discharged with effluent. No organized system of chrome recovery and reuse of direct recycling of liquor is practiced. Besides wastewater, huge quantity of solid waste is also generated in various processes involved.

Intervention Type



On-site chrome recovery plants (common or individual).


GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.


Capturing industrial effluent from Hazaribag (about 20000 m3/day) and domestic wastewater from storm water outlets and diverting these waste loads from Buriganga to the Pagla Sewage Treatment Plant that currently runs at less than a third of its capacity. About 14 km long Diversion Sewer along the bank of the river with three lift stations and 10 diversion structures, would be required.

DWASA

BDT 1300.0 Million; Field survey and design would require additional BDT 100.0 Million; Government of Bangladesh;

Intervention Type

Description Lead Institutions Costs of Intervention and funding sources

Individual ETPs for large and isolated polluting industries

Individual Industry/ BEPZA

Costs variable; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.


Common treatment plants at appropriate locations following the outfalls

BEPZA/ MoI


Table 4.6 Proposed technical interventions for pollution abatement from Hazaribag area

Table 4.7 Proposed technical interventions for pollution abatement from DEPZ

While it has been decided, about 10 years back, that the Hazaribag tanneries will be relocated at Savar with provision of CETP, on the bank of river Dhaleshwari some 15 km upstream of Hazaribag, international experience suggests that it takes quite a long time to relocate such a huge number of industries even after complete preparation of the new site.

Now that the development of the new location has stalled due to legal complicacy, it appears that the relocation might take another 10 years or so and it is not logical that the


Table 4.8 Proposed technical interventions for pollution abatement from Gazipur

discharge of such a huge pollution load from Hazaribag continues.

A policy decision is therefore needed here to consider of an alternative intervention for this substantially long period of time. Table 4.6 includes proposed technical interventions for Hazaribag industrial area.

After about 10 years time when the tanneries will be relocated, the diversion sewer system will collect domestic sewage from a larger part of the city and convey to the Pagla sewage treatment plant.

Pollution Abatement Strategies for Dhaka Export Processing Zone (DEPZ)

The DEPZ cluster comprises the DEPZ, DEPZ (extended), Ashulia and Jirabo areas, covering an area of about 36 km2. The industrial effluents of this cluster are eventually discharged into the Bangshi River through two major khals, namely the Nolam Kunda khal and the Sokundi khal.

There are about 200 industries including polluting textile-dyeing, chemical-soap industries, printing paper- packaging, foods-beverages, steel and miscellaneous industries discharge through seven major outfalls. The policy and management interventions as mentioned earlier will apply and technical interventions are mentioned in Table 4.7 below.

Intervention Type



Individual ETPs for large and isolated polluting industries

Individual Industry/ BSCIC/ MoEF

Costs variable; GoB facilitated credit windows at commercial banks, Industry Bank, Shilpa Rin Shangstha.


Common treatment plants at appropriate locations one for each major area of industrial concentrations, such as Konabari, Kashimpur

/MoI/ BSCIC


Pollution Abatement Strategies for Gazipur Area

The major industries are located at Board Bazar, Rajendrapur, Vhawal, Konabari BSCIC and Kashimpur industrial area. Over 500 industries including textile-dyeing-cotton-washing, glass-ceramic factories, food and beverage, re-rolling, chemicals, milk and miscellaneous industries discharge their effluent into the Turag River through Konabari BSCIC khal, Kashimpur khal and Labanga khal; into the Balu River through Chilai khal; and into the Tongi khal through Ardobazar khal. Pollution control interventions in this cluster should also involve a combination of policy, management and technical interventions. Table 4.8 lists the possible, immediate technical interventions.

Pollution Abatement Strategies for Savar Area

Savar industrial cluster discharges much lower pollution load compared to other clusters. However, pollution abatement interventions, particularly the policy and management interventions for industries in Savar area would be similar to those of Gazipur. Technical interventions would include individual ETPs for large isolated polluting industries and CETPs at major concentrations following the outfalls.


4.4.3 Clean-Up of Contaminated River Beds

It can be considered for obvious reasons that the beds of all peripheral rivers and canals within the city are heavily contaminated by pollutants from different sources. Pollution along with other types of degradation including erosion, encroachment, unauthorized and unabated commerce and business on encroached lands, and the continuing spread of unplanned urbanization is posing serious threat to the sustainability of the river systems around Dhaka city.

A wide variety of pollutants including toxic heavy metals, hydrocarbons, persistent organic pollutants (POPs), municipal and industrial organics, sewage sludge, hospital wastes, pathogens are being increasingly discharged into the rivers and canals in and around Dhaka City. As a result, the grossly polluted waters and contaminated river beds have become hazardous to human health when potentially toxic substances move through the food chain or reach groundwater used for drinking water supplies.

The current waste disposal practices within Dhaka watershed area have virtually made the river beds as sinks for a diverse range of pollutants. Clean up of the contaminated river beds have therefore, become a priority action while considering river pollution abatement strategies. To be effective and sustainable this river bed clean-up action, must follow some logical steps and be based on scientific analysis.

The recent government initiative of excavating Buriganga river bed on an experimental basis deserves appreciation in that it reflects the positive move by the government in an effort to restore the dying rivers around Dhaka City. However, the initiative lacks a comprehensive planning that is essential for excavation of contaminated bed materials, contaminant characterization, treatment of various contaminants, identification and preparation of disposal locations for final disposal of the bed materials. The logical steps to be followed for river bed clean-up action:

11. Delineation of alignment and channel width (flood plain width) of each river

12. Identification of point sources of pollution

13. Complete stoppage of pollution discharges from all identified point sources

14. Minimizing non-point source pollution through changing basin management practices

15. Sampling and scientific laboratory analysis of bed sediment volume and contaminant characteristics

16. Establishing procedure for excavation of river beds

17. Based on scientific analysis of bed sludge, separating contaminants e.g., plastics, degradable and non-degradable

18. Identification of disposal methods and sites according to contaminant characteristics

19. Appropriate treatment and disposal of different fraction of contaminants

20. Setting a realistic timeframe for phased remediation of contaminated river beds

Ideally the most suitable and safe option would be to transport the excavated materials to sanitary landfill for disposal. However, the only available Matuail landfill at Demra would not be adequate for disposal of huge volume of dredge spoils from all the peripheral rivers. It is therefore, important that the government look for some vacant lands appropriate for disposal. A comprehensive plan would involve

identification and acquisition of some nearby vacant lands,

erecting appropriate platforms for dewatering,

separating non-degradable plastics and inorganic materials,

preparing the beds with adequate drainage facilities for filling with remaining dredge spoils that would be mostly organic, and


procuring cover materials.

Non-degradable plastics and polythene could be recycled for making lower grade plastic items of various uses. It is also important to address the issue of groundwater contamination from leaching of excavated soil that might contain dissolved toxic chemicals.


Sequencing Pollution Abatement InterventionsAs discussed earlier, interventions are required in terms of policy decisions, management advancing and technology application in the field. However, sequencing them is

C h a p t e r 5

challenging in that there are a number of interventions that require immediate attention, particularly the policy interventions. Furthermore, the scale of the problems related to water pollution in Dhaka watershed is so large and there are so many interventions that need to be implemented simultaneously in order to achieve objectives of pollution management that it becomes difficult to sequence them one after another. It is therefore, considered to be based on the urgency of addressing pollution of a particular river system. While most of the policy interventions can be initiated without much delay and with significant outcomes, technical interventions have been sequenced considering priority areas.




An independent EIA review body drawing experts from research organizations, industry associations, media and the civil society

MoEF/DoE Immediate

Incorporate in the ECR 1997 through Gazette notification, public disclosure of environmental quality information through different public media

MoEF/DoE Immediate

Make provisions in the environmental policy and regulations for introducing pollution charges based on discharged loads

MoEF/DoE Immediate

Delineate and declare through Gazette notification, 40% of eastern Dhaka drainage area comprising natural wetlands and reserved ponds/ lakes as ecologically critical area(ECA)

MoEF/DoE Within 3 months

Initiate the process of enactment of the new law “Clean W ater Act” MoEF/MoL Immediate DWASA must urgently act to implement its own policy of having separate sewerage systems; initiate disconnecting of domestic sewers from storm drainage systems, and monitor installation of septic tanks of appropriate design where sewer network does not exist.

DWASA/RAJUK Immediate

Facilitate transformation of Tejgaon industrial area into a commercial zone considering its location within the city through o�ering incentives for immediate relocation of major polluting industries.

RAJUK/ MoI/ DCCI/ MoF

Within 6 months

Establish model industries to promote cleaner production, waste minimization and pollution prevention involving media and civil society for awareness building. Facilitate access to funds for initial investments on clean technology adoption by industries particularly by the small and medium enterprises.

MoEF/ MoI/ DCCI/ MoF


O rientation and training programs on cleaner production, waste minimization and pollution prevention, ISO 1400 and EMS for management staff and trainers of industries

MoEF/ Training Institutes/ Industries

Within 6 months


5.2 Technical Interventions


Addressing pollution of Balu-Sitalakhya river system: Off-site biological treatment of organic pollution from both domestic and industrial sources at Dasherkandi near Trimohini- Norai Khal before disposal into Balu-Sitalakhya river system.



DWASA Ongoing

On-site ETP at individual industry site primarily for physico-chemical treatment and chemical recovery in Tejgaon industrial area.


Within 6 months; Duration 1 years

Improvement of sewerage system in central Dhaka area through rehabilitation and expansion of domestic sewerage facilities with provision of treatment facilities for the north-eastern part of Dhaka

DWASA Immediate

A large CETP at the downstream end of DN D drainage khal to treat about 500000 m3/day

DWASA Within next one year

5 CETPs of varying sizes at Shyampur, Kashipur, Godnail, Jelepara and Killarpool to treat clusters of polluting industries of Narayanganj

MoI/ DCCI/ MoEF Within 6 months; Duration 2 years

Individual ETP for large polluting industries e.g., Bengal Paper Mill, Narayanganj


Within 6 months

Improve on-site sanitation of Narayanganj with effluent and sludge management facilities

Narayanganj Municipality

Within 3 months

3 CETPs of varying sizes at Kanchpur, Tarabo, and Rupshi to treat clusters of polluting industries of Tarabo

MoI/ DCCI/ MoEF Within 6 months; Duration 2 years

Individual ETP for large polluting industries e.g., Rahman Chemicals, and Sobnom Oil Mill of Tarabo Industrial cluster


Within 3 months; Duration one year

3 CETPs of varying sizes at Tongi BSCIC area, Tongi industrial area, Cherag Ali to treat clusters of polluting industries of Tongi

BSCIC/ MoI/ DCCI/ MoEF


Addressing pollution of Turag-Buriganga-Dhaleshwari river system: Capturing industrial effluent from Hazaribag (about 20000 m3/day) and domestic wastewater from storm water outlets and diverting these waste loads from Buriganga to the Pagla Sewage Treatment Plant that currently runs at less than a third of its capacity. About 14 km long Diversion Sewer along the bank of the river with three lift stations and 10 diversion structures, would be required.


On-site chrome recovery plants (common or individual) at Hazaribag.

Individual Industry/ MoEF/ UNIDO


Common treatment plants at appropriate locations following the outfalls of DEPZ

BEPZA/ BoI/ MoEF Within 3 months; Duration 1 years

Common treatment plants at appropriate locations one for each major area of industrial concentrations, such as Konabari,

DCCI/MoI/ BSCIC



5.3 Management Interventions







Within 6 months

Storage of wastewater during the dry season, preferably after physico-chemical treatment and chemical recovery


From next dry season

5.4 Cost of Interventions

As mentioned earlier, pollution abatement interventions could be classified into three categories – policy, management and physical interventions. Policy and management interventions do have inherent costs involvement but could be far less compared to the costs involved in physical interventions required in the field and therefore not included in the estimates. Estimates of costs for different interventions have been mentioned but they are very indicative.

Actual cost estimates should be prepared based on detailed design of each intervention. The indicative costs for immediate interventions discussed in this report would be around BDT 21000 million (USD 300 million). Costs of clean-up of river beds are not included and should be determined based on analysis mentioned earlier.

While the physical interventions would require significant government investments, the private sector industries can be motivated to come forward with investments for their own ETPs. Some kind of fiscal incentives, for instance, tax exemption on imported ETP equipments could be an effective motivational factor. The government may also play the role of a facilitator in arranging finances from commercial banks, Industry Bank, Shilpa Rin Shangstha or other sources.

5.5 Time Frame for Interventions

Given the present pollution status of all the rivers around

Dhaka watershed and the khals and water bodies within the city, it is extremely important that the government moves fast in order to save the rivers and water bodies from further deterioration and to make Dhaka city a place for sustainable living.

All the specific interventions including policy, management and technical interventions can be initiated immediately. It may be necessary for the government to spend 3 to 6 months for planning, locating sources of funds and for administrative formalities. Policy and management interventions may require further discussions in relevant parliamentary committees but can be initiated without much delay.

All the specific interventions discussed in this report are relevant and can be undertaken within the current year and it is possible that most of the physical interventions can be completed within a time frame of 4 years. It is expected that these interventions if implemented, will bring about significant improvements in the quality of life of the Dhaka city dwellers.

5.6 Institution for Sustainable Watershed Management

In absence of a strong institutional arrangement, coordinated efforts and effective governance, the people and the economy are paying high price for the degraded environment in the Dhaka watershed. Many institutions e.g., the Department of Environment, DWASA, Dhaka


City Corporation, RAJUK, adjacent Municipalities, BIWTA, BWDB, and the DC of Dhaka are all relevant to the issues of encroachment and pollution of rivers and water bodies in and around Dhaka. The segmented roles and responsibilities of these institutions result in a situation when critical issues like encroachment and filling up of water bodies, discharge of untreated industrial and domestic wastes remain virtually unattended.

The Department of Environment lacks capacity to monitor emissions and regulate environmental standards of rivers, canals, lakes and other water bodies thereby making it largely an ineffective regulatory agency. DWASA plays a conflicting role. On the one hand, it suffers from the consequences of high degree of surface water pollution thereby not being able to maintain raw water quality for its water treatment plants, and on the other DWASA itself to be blamed for polluting the surface water bodies that result due to gross inadequacy in sanitary sewerage system in the rapidly growing city. DWASA is mandated to develop and maintain the city drainage system and the drainage canals yet the ownership of the canals lies with the Ministry of Land through the District Commissioners.

Similarly the rivers are owned by the Ministry of Land while the flow of waters are owned by the Ministry of Water Resources through BWDB, and again the BIWTA under the Ministry of Shipping owns the river banks and is responsible to maintain the depth of flow to facilitate riverine transport. RAJUK, the planning authority of greater Dhaka area mandated to protect the wetlands and demarcated flood flow and sub-flood flow zones, utterly fails to enforce the Wetland Conservation Act 2000. Dhaka City Corporation (DCC), the local government institution, is the only institution administered by public representatives and its Mayor and ward Councilors are directly elected by the city dwellers meaning DCC is directly accountable to the people of this city. Yet DCC is not fully mandated to provide important urban services.

With shared ownership, powers and responsibilities, and due to lack of effective coordination, these institutions are apparently not in a position to protect, develop and manage the Dhaka watershed that includes six peripheral rivers

including the floodplains, city lakes, canals, and wetlands. It is therefore important that the government gives a serious consideration to establish a new institution with full ownership, power and responsibilities to protect, restore, develop and manage the entire Dhaka watershed.

The proposed institution may be styled as “Dhaka Watershed Management Authority” and should be headed by a public representative, preferably with the rank and status of a full Minister, and guided by a statutory Board with representatives from relevant stakeholders including local MPs, civil society, experts, university professors, regulatory and administrative agencies, media and eminent personalities. The detailed terms of reference (ToR) of the institution head, and the members of the Board, and the required organogram should be developed through discussions at appropriate forum.

5.7 Concluding Remarks

Environmental degradation from untreated domestic and industrial wastes has reached a level that poses threats to public health, ecosystem services, and economic growth. The pollution status of Dhaka watershed is in a grave situation. The water quality indicator, Dissolved Oxygen (DO), demonstrates extremely low value (much less than the standard of 5 mg/L and in most situations less than 1 mg/L) all around the river system and in the khals and lakes of the city. At some critical points in time water bodies at specific locations demonstrate complete devoid of oxygen representing septic condition when no aquatic life form can survive and the water becomes unusable for any intended purpose. The scale of the problem is so huge that only a handful immediate solution package cannot address all related issues. The above lists of interventions therefore by no means exhaustive and there would be more to improve continually.

However, the interventions recommended in this report will certainly bring positive changes in the water quality status of the water bodies within Dhaka watershed and improve significantly the level of DO. It is expected that the DO level would rise close to 4 mg/L, given all policy, management and physical interventions are implemented, and the water


quality would then be suitable for many uses including that for drinking water supply source.

The listed interventions would significantly minimize pollution of rivers and water bodies in and around Dhaka city thereby providing its dwellers a way forward towards sustainable living. It is strongly recommended that the Policy, Management and Technical Specific Interventions are discussed in appropriate forum and necessary actions are taken without much delay. Physical interventions in the field are however, subject to feasibility and all interventions are subject to environmental assessment which can also be done immediately.

ReferencesBUET (2008) Integrated Development of Hatirjheel including

Begunbari Khal, Mid-Term Report, RAJUK, Dhaka Bangladesh

BUET (2007) Water Quality Analyses Related to Saidabad Water Treatment Plant, Lakhya River and DND Canal, Final Report, DWASA, Dhaka, Bangladesh

Darda and Islam (2009) A study on Water Quality of Lakes of Dhaka City, Study Report, Department of Civil Engineering, BUET, Dhaka, Bangladesh

DoE/BEMP (2004) Developing an Approach and Investment Strategy for Rehabilitating the Buriganga-Turag-Sitalakhya-Balu River System, Department of Environment, Dhaka, Bangladesh

IWM (2007) Industrial Environmental Compliance and Pollution Control in Greater Dhaka – Phase I, World Bank, Dhaka

JICA (1992) Feasibility Study on Greater Dhaka Protection Project of Bangladesh Flood Action Plan No. 8A, Main Report, FPCO, Government of Bangladesh

World Bank (2007) Dhaka Metropolitan Development Plan: Strategic Environmental Assessment, Draft Final Report, Dhaka, Bangladesh

World Bank (1999) Pollution Prevention and Abatement Handbook 1998, Toward Cleaner Production, World Bank, Washington D.C., USA

Government of the People’s Republic of BangladeshUnited Nations Development Programme