Tuesday, 19 October, 2021

NCSS Position Paper on "the Recommendations of the Recent Meeting of UNESCO World Heritage Committee on the Sundarbans"

NCSS Position Paper on

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The National Committee for Saving the Sundarbans (NCSS) is a coalition of over 50 environment and human rights organizations in Bangladesh administered by Bangladesh Poribesh Andolon (BAPA).

NCSS asserts that the 2021 decisions of the UNESCO World Heritage Committee fail to protect the Outstanding Universal Value of the Sundarbans World Heritage site from the threats of on-going industrial and infrastructure projects, and endorses a Strategic Environmental Assessment (SEA) for south-western Bangladesh that lacks scientific integrity and transparency. 

On Friday July 23, UNESCO’s 21-member World Heritage Committee met online to finalize recommendations for the Sundarbans World Heritage site. The decisions are yet to make publicly available in written format.

However, the Committee reviewed a draft decision by the IUCN and UNESCO World Heritage Center that followed findings from a December 2019 Reactive Monitoring Mission.

These findings included:

1. While the property’s [outstanding universal value] (OUV), including its hydrological and ecological processes and its biodiversity, remains present, the property continues to be threatened by possible impacts from large-scale industrial development. It is also a source of great concern that the three power plant projects in Rampal, Taltoli and Kolapara continue to advance, while their construction and operations could potentially impact the property’s OUV. 

2. In the absence of a comprehensive assessment of cumulative impacts from the ongoing and proposed large-scale industrial developments, significant concerns remain regarding their possible negative impacts on the property, and therefore the continuation of these developments before the on-going SEA is completed represents a potential danger to the property’s OUV.

3. “The Strategic Environmental Assessment (SEA) [for southwestern Bangladesh currently underway] should provide an adequate planning instrument, whose implementation would ensure that no large-scale industrial development would be permitted in the vicinity of the property, and that no further intensification of shipping and dredging would occur if either is considered to have potential negative impacts on the OUV of the property.

4. The Committee should review the progress achieved in the development of the SEA at the next session in 2022 with a view to considering the possible inscription of the property on the List of World Heritage in Danger.

5. Ensure that no further decision is made for any new large-scale industrial and/or infrastructural developments, including further development of the Mongla Port and any other development that might further increase traffic on the Pashur River, until the SEA for the South-West region of Bangladesh is completed.

Sadly, due to overwhelming politicization of the Committee to undermine science and conservation in favor of industrial projects, a majority of Committee members intervened to weaken the above recommendations. China, Russian Federation, Egypt, Ethiopia, Saudi Arabia, South Africa, Nigeria, Oman, Thailand repeatedly struck down proposals by Norway, seconded by Australia, to retain aspects of the 2019 monitoring mission recommendations.

Moreover, the committee did not pay attention to the clear statement from the center while they mentioned that the state party did not follow the request of the 41 COM in 2017 and 43 COM in 2019 regarding not to continue development of any large-scale infrastructure till the SEA was complete.  

Though weakened, some aspects of the original recommendations remain. The Committee’s final 2021 decision on the Sundarbans includes:

1. Notes with concern that the development of the large-scale industrial projects which could potentially impact the property’s OUV in the absence of the SEA continues to advance; (para 11)

2. Notes the ongoing expansion and dredging operations near Mongla Port would require additional maintenance dredging and are likely to increase traffic on the Pashur River and urges the State Party to ensure that no further decision is made for any new large-scale industrial and/or infrastructural development, which may influence the OUV of the property; (para 10.)

3. Urges the State Party to ensure that the findings of the SEA form the basis for future decision making on development that may impact the OUV of the property, and further requests the State Party to submit the final SEA, including the strategic environmental management plan, to the World Heritage Centre for review by IUCN and subsequent examination by the Committee at its 45th session;

4. Requests moreover the State Party to submit to the World Heritage Centre, by 1 February 2022, an updated report on the state of conservation of the property for review by the Committee in July 2022;

National Committee for Saving the Sundarbans (NCSS) was allowed to take the floor after the decision was passed.

NCSS reminded the Committee that the 2019 Reactive Monitoring mission concluded that the property’s OUV continues to be threatened by possible impacts from large-scale industrial development, including the power plants at Rampal, Kalapara and Taltoli.

NCSS also reminded the Committee that its 2017 Decision urged Bangladesh to "ensure that any large-scale industrial and/or infrastructure developments will not be allowed to proceed before the SEA has been completed."

Finally, NCSS called for the SEA to be done independently with scientific integrity and full participation, which has not yet occurred.

NCSS concluded with the warning that ecological degradation of the Sundarbans World Heritage site by large scale industries will create a vicious cycle for Bangladesh as it faces climate change that must not be allowed to take hold.

NCSS condemns the 2021 Committee for failing to uphold the mission of the World Heritage Convention, which is to take decisions for conservation of World Heritage sites on the basis of scientific evidence.

Millions of people rely on the Sundarbans for livelihoods and shelter from storms and floods. As climate change increases, the mangrove forests of the delta, and the ecological dynamics of all species living there, must be protected from the impacts of industrialization.

These impacts include toxic air pollution from the coal plants at Rampal, Kalapara and Taltoli, water pollution from coal spills, dust and vast amounts of toxic coal ash and flue sludge dumped on the floodplains, constant ship traffic noise and shore-eroding waves from boat wakes, ship strikes of freshwater dolphins, near constant dredging noise and turbidity, collisions, fuel spills, and air pollution from burning fuel oil. The coal plants will also produce huge amounts of greenhouse gases during these crucial decades when the whole world must somehow transition to clean energy in order to avoid climate catastrophe.

We regret that the 2021 World Heritage Committee failed to help galvanize major international aid and action toward that goal of Bangladesh becoming a leader in the global clean energy transition to address the planetary emergency for the climate vulnerable countries so that the Sundarbans can truly be saved.

We demand a) the SEA should be completed independently while all the public consultation that was promised in the first document must be done.

b) Credible modeling of the cumulative impacts of air and water pollution from all existing and proposed industries in SW Bangladesh that includes Kalapara and Taltoli.

c) Modelling of the cumulative depositions of mercury, arsenic, selenium, dioxin and other toxics from coal.

d) All data must be made public, including all parameters of the models.

e) Complete EIAs must be made available for the plats in Taltoli and Kalapara and all current and proposed industries in Mongla.

f) A draft of the SEA must be made public in all stakeholder languages, and adequate time given for public review and comments.

g) The final SEA must respond adequately to public comments and expert peer reviews.

h) The SEA must meet the IUCN Advice Note for Environmental Assessment, and the World Heritage Operational Guidelines (2019) 118bis.