2O23 BUILDING BACK A GREENER BANGLADESH Country Environmental Analysis BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 I © 2023 The World Bank 1818 H Street NW, Washington, DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org Some rights reserved. This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank Group does not guarantee the accuracy, reliability, or completeness of the content included in this work, or the conclusions or judgments described herein, and accepts no responsibility or liability for any omissions or errors (including, without limitation, typographical errors, and technical errors) in the content whatsoever or for reliance thereon. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of the World Bank Group concerning the legal status of any territory or the endorsement or acceptance of such boundaries. The findings, interpretations, and conclusions expressed in this volume do not necessarily reflect the views of the organizations of the World Bank Group, their respective Boards of Executive Directors, and the governments they represent. The contents of this work are intended for general informational purposes only and are not intended to constitute legal, securities, or investment advice, an opinion regarding the appropriateness of any investment, or a solicitation of any type. Some of the organizations of the World Bank Group or their affiliates may have an investment in, provide other advice or services to, or otherwise have a financial interest in, certain of the companies and parties named herein. Nothing herein shall constitute or be construed or considered to be a limitation upon or waiver of the priv- ileges and immunities of any of the organizations of The World Bank Group, all of which are specifically reserved. Rights and Permissions The material in this work is subject to copyright. Because The World Bank Group encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for noncommercial purposes as long as full attribution to this work is given and all further permissions that may be required for such use (as noted herein) are acquired. Photographs from other sources excepted. The World Bank Group does not warrant that the content contained in this work will not infringe on the rights of third parties and accepts no responsibility or liability in this regard. Attribution: Please cite the work as follows: World Bank. 2023. “Building Back a Greener Bangladesh: Country Envi- ronmental Analysis.” Washington DC, The World Bank Group. All queries on rights and licenses should be addressed to World Bank Publications, The World Bank Group, 1818 H Street NW, Washington, DC 20433, USA; e-mail: pubrights@worldbank.org. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 II TABLE OF CONTENTS List of Acronyms  V Acknowledgments  VII Executive Summary VIII Chapter 1. Introduction 1 1.1 Country context 1 1.2 Objective 2 1.3 Methodology 2 1.4 Structure of the CEA Report 4 C1 References 5 Chapter 2. Cost of Environmental Degradation – Environmental Health Issues  6 2.1 Introduction  6 2.2 Ambient air pollution  6 2.3 Household air pollution 10 2.4 Lead pollution 13 2.5 Household drinking water, sanitation, and hygiene 22 2.6 Health effects in children 27 2.7 Conclusions and recommendations 28 C2 References / Endnotes 32 Chapter 3. Bangladesh’s Environmental Governance Framework 41 3.1 Introduction 41 3.2 Legal framework for environmental management in Bangladesh 41 3.3 Institutional framework for environmental management 44 3.4 Institutional shortcomings at MoEFCC and DoE 46 3.5 Monitoring and evidence-based planning 51 3.6 Environmental enforcement 52 3.7 Conclusions and recommendations 58 C3 References / Endnotes  62 Chapter 4. Environmental Planning and Environmental Impact Assessment 66 4.1 Introduction 66 4.2 Objectives and nature of environmental clearance 66 4.3 Screening 67 4.4 Scoping and preparation of EIA 68 4.5 Consultation and public participation 69 4.6 EIA review 70 4.7 Follow-up of ECC conditions  70 4.8 Trends in ECC applications and renewals 71 4.9 Conclusions and recommendations 73 C4 References / Endnotes  74 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 III Chapter 5. Cost-Benefit Analysis of Environmental Health-Risk Interventions 76 5.1 Introduction 76 5.2 Benefits and costs of PM2.5 ambient air pollution control interventions 76 5.3 Benefits and costs of interventions to control household air pollution 81 5.4 Benefits and costs of interventions to mitigate and prevent lead (Pb) exposure 89 5.5 Benefits and costs of improved WASH interventions 95 5.6 Benefits and costs of mitigating arsenic in drinking water 104 5.7 Conclusions 107 C5 References / Endnotes  109 Chapter 6. Air Quality Management in the Greater Dhaka Area 113 6.1 Introduction  113 6.2 Air quality in Bangladesh 114 6.3 Sources of PM2.5 Exposure in the Greater Dhaka Area in 2020 116 6.4 Cost-effective emission controls in the Greater Dhaka Area  122 6.5 Priority measures for cost-effective improvement of air quality in GDA 129 6.6 A way forward  131 C6 References / Endnotes 133 Chapter 7. CGE Analysis of Green Policies in Bangladesh  134 7.1 Introduction 134 7.2 Methodology 134 7.3 Model experiments of energy-subsidy removal  135 7.4 Exploring the introduction of carbon-pricing instruments 139 7.5 Water Investment Program 144 7.6 Conclusions 148 C7 References / Endnotes 150 Chapter 8. Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management  153 8.1 Introduction 153 8.2 Plastic waste consumption and disposal in Bangladesh 154 8.3 Plastic pollution through abandoned, lost, or otherwise discarded fishing gear (ALDFG) 156 8.4 Impacts of plastic pollution  157 8.5 Governance of waste management  162 8.6 Bangladesh’s plastic economy  165 8.7 Policy recommendations for integrated plastic-waste management 167 C8 References / Endnotes 169 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 IV Chapter 9. Enabling the Environment for Green Financing in Bangladesh 174 9.1 Introduction 174 9.2 Green finance 174 9.3 Key green finance stakeholders in Bangladesh  174 9.4 Demand for green financing 176 9.5 Barriers to channeling green finance into Bangladesh’s green growth projects  177 9.6 Recommendations 182 C9 References / Endnotes 185 Chapter 10. Expanding the Range of Environmental Management Tools in Bangladesh 187 10.1 Introduction 187 10.2 Types of environmental policy instruments 187 10.3 Market-oriented options 189 10.4. Litigation-oriented options: Liability legislation 191 10.5 Conclusions and recommendations 192 C10 References / Endnote 193 Chapter 11. A Way Forward 195 11.1 Interventions to address Bangladesh’s environmental priorities 195 11.2 Strengthening environmental governance systems 196 Appendixes203 Appendix A. Data and Methodology for Estimating Health Effects 203 Appendix B. Health Effects of Particulate Matter Pollution 207 Appendix C. Blood Lead Levels and Sources of Lead Exposure 211 Appendix D. Estimating IQ Losses from Pb in Children 220 Appendix E. Estimating Health Effects from Pb in Adults 223 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene 225 Appendix G. Valuation of IQ Losses 230 Appendix H. Valuation of Illness  232 Appendix I. Valuation of Mortality 235 Appendix J. Adjusting Mortality Estimates for Multiple Risk Factors 237 Appendix K. Organogram of Bangladesh Department of Environment 238 Appendix L. Need for Regular and Reliable Production of Environmental Data and Statistics 239 Appendix M. Bangladesh Environmental Sustainability and Transformation Project 240 Appendix N. Estimation of Health Benefits of Interventions 241 Appendix O. Plastic Waste in Riparian Land and Waters of Rivers and Canals around Dhaka City 242 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh 243 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 V List of Acronyms 8FYP 8th Five-Year Plan CVD cardiovascular disease AAP ambient air pollution DALY disability-adjusted life year ADB Asian Development Bank DG Director General ADP Annual Development Programme DoE Department of Environment AF attributable fraction DPC Development Policy Credit ALRI acute lower respiratory infections DPHE Department of Public Health Engineering APCR Air Pollution Control Rules EC Environmental Clearance AQG air quality guideline ECA Environment Conservation Act AQM air quality management ECC Environmental Clearance Certificate BAU business as usual E. coli Escherichia coli bacteria BB101 CGE Bangladesh Bioeconomic 101 ECR Environment Conservation Rules BB Bangladesh Bank ECtA Environment Court Act BBS Bangladesh Bureau of Statistics EDTA Ethylenediaminetetraacetic acid BC black carbon EFSA European Food Safety Authority BCIC Bangladesh Chemical Industries Corporation EIA Environmental Impact Assessment BCR benefit-cost ratio EIS electric induction stove BDP Bangladesh Delta Plan 2100 EMF Environmental Management Framework BDT Bangladeshi taka (Tk) EMP Environmental Management Plan BEPZA Bangladesh Export Processing Zones Authority EMR Hazardous (e-waste) Management Rules BEST Bangladesh Environmental Sustainability and EMS Environmental Management System Transformation Project EQS Environmental Quality Standards BEZ Bangladesh Economic Zone ES electric stove BEZA Bangladesh Economic Zone Authority ESCAP UN Economic and Social Commission for Asia BFD Bangladesh Forest Department and the Pacific BFIDC Bangladesh Forest Industries Development ESDO Environment and Social Development Corporation Organization BFRI Bangladesh Forest Research Institute ESP electrostatic precipitator BFSIC Bangladesh Sugar and Food Industries ESRM Environmental and Social Risk Management Corporation ETP effluent treatment plant BIWTA Bangladesh Inland Water Transport Authority FAO Food and Agriculture Organization BLL blood lead level FGD flue gas desulfurization BMBKEA Brick Manufacturing and Brick Kilns FI financial institution Establishment Act FY fiscal year BPDB Bangladesh Power Development Board GAINS Greenhouse Gas and Air Pollution Interactions BSCIC Bangladesh Small and Cottage Industries and Synergies Corporation GBD global burden of disease BSEC Bangladesh Securities and Exchange Commission GDA Greater Dhaka Area BSTI Bangladesh Standards and Testing Institution GDP gross domestic product CASE Clean Air and Sustainable Environment GFVC Green Financial Value Chain CCDR Country Climate and Development Report GHG greenhouse gas CDC US Centers for Disease Control and Prevention gm gram CEA Country Environmental Analysis GoB Government of Bangladesh CETP centralized effluent-treatment plant Ha hectare CGE computable general equilibrium HAP household air pollution CH4 methane HEI Health Effects Institute CLRTAP Convention on Long-Range Transboundary Air Pollution HWF handwashing facility CMSMEs cottage, micro, small, and medium enterprises I&M inspection and maintenance CNG compressed natural gas ICS improved cookstove CO2 carbon dioxide ID iron deficiency CoED cost of environmental degradation IDCOL Infrastructure Development Company Limited COPD chronic obstructive pulmonary disease IEE initial environmental examination CSO civil society organization IER integrated exposure–response BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 VI IEUBK Integrated Exposure Uptake Biokinetic POU point of use IGP Indo-Gangetic Plain POUT point-of-use treatment IHD ischemic heart disease ppb parts per billion IHME Institute for Health Metrics and Evaluation PPM primary PM2.5 IIASA International Institute for Applied Systems ppm parts per million Analysis PPP purchasing power parity IPEN International Pollutants Elimination Network RCT randomized controlled trial IQ intelligence quotient RECP resource-efficient and cleaner production kWh kilowatt-hour RMG ready-made goods LC lung cancer RR relative risk LDPE low-density polyethylene SAM Social Accounting Matrix LFP labor-force participation SAR South Asia Region LGI local government institution SD standard deviation LMI lower-middle income SDG Sustainable Development Goal LMIC low- and middle-income countries SEZ special economic zone LMO Living Modified Organisms SLCP short-lived climate pollutants LPG liquified petroleum gas SO2 sulfur dioxide LSMGO low sulfur marine gas oil SPM secondary PM2.5 m meter SREDA Sustainable and Renewable Energy mg/kg milligram (one-thousandth of a gram) per Development Authority kilogram SWM solid waste management ml milliliter (one-thousandth of a liter) SWMR solid waste management rules MICS Multiple Indicator Cluster Survey tCO2e tons of carbon dioxide equivalent MJ megajoule TCS traditional cookstove MoC Ministry of Commerce Tk Bangladeshi taka MoEFCC Ministry of Environment, Forest and Climate TREL theoretical minimum-risk exposure level Change ToR terms of reference MoF Ministry of Finance TSIP Toxic Sites Identification Program MoI Ministry of Industries µg/dL microgram (one-millionth of a gram) per deciliter MoIB Ministry of Information and Broadcasting μg/m3 micrograms (one-millionth of a gram) per cubic MoLGRDC Ministry of Local Government, Rural meter Development and Co-operatives ULAB used lead-acid battery MoP Ministry of Planning UNICEF United Nations Children’s Fund MtCO2e metric tons of carbon dioxide equivalent US United States NBR National Board of Revenue USEPA US Environmental Protection Agency NCAPC National Committee on Air Pollution Control VOC volatile organic compounds NCD noncommunicable disease VLSFO very low sulfur fuel oil NGO nongovernmental organization VSBK vertical shaft brick kiln technology NH3 ammonia VSL value of statistical life NHANES National Health and Nutrition Examination Surveys WASA Water Supply and Sewerage Authority NIPORT National Institute of Population Research and WASH water, sanitation, and hygiene Training WB World Bank NOX nitrogen oxides WHO World Health Organization O3 ground-level ozone WSS water supply and sanitation O&M operations and maintenance WTP willingness to pay PAF population attributable fraction YLD years lived with disability Pb lead PES Payment for Ecosystem Services Note: All dollar ($) amounts are in US dollars except PFI participating financial institution when specified otherwise. PIF potential impact fraction PMF positive matrix factorization PM2.5 particulate matter with diameter equal to or smaller than 2.5 micrometers (μm) POP persistent organic pollutant BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 VII Acknowledgments This Country Environmental Analysis (CEA) was prepared by a team of the World Bank staff and external experts led by Ana Luisa Gomes Lima and consisting of Markus Amann, Santiago Enriquez, Monika Kumar, Bjorn Larsen, Bushra Nishat, Jostein Nygard, Daniel Payares Montoya, Pasquale Lucio Scandizzo, Nina Tsydenova, and Eun Joo Yi. The authors gratefully acknowledge other contributors to different chapters of the CEA: Iqbal Ahmed, Nathalia Lima Cano, Daniele Cufari, Madhu Shudan Das, Zoie Diana, Muhammad Anwar Iqbal, Mi Hoon Jeong, Provat Kumar Saha, Jihae Kwon, Nathalie Laureano, Ahmad Kamruzzaman Majum- der, Elizabeth Dykstra-McCarthy, Niamul Naser, Pawan Patil, Md. Shafiqur Rahman, Poonam Rohatgi, Jason Russ, Wolfgang Schöpp, Istiak Sobhan, Josefo Tuyor, Nasir Uddin, Nousheen Nower Zoarder, and S. M. Zulkernine. The team would like to express its gratitude to Dr. Farhina Ahmed, Secretary, Ministry of Environment, Forest and Climate Change (MoEFCC), and Dr. Abdul Hamid, Director General, Department of Environment (DoE). The work was done in full collabora- tion with those institutions. The team would also like to thank the valuable inputs from officials of the MoEFCC, the DoE, the Ministry of Planning, the Bangladesh Bureau of Statistics, the Finance Division, the Bangladesh Bank, the Directorate General of Health Services, and other governmental institutions. Representatives from academia, research and development, civil society organizations, and development partners provided very useful feedback during the various discussions and consultations that took place in Dhaka. Critical support throughout various stages of preparation was provided by the following peer reviewers: Concepcion Aisa, Rich- ard Damania, Kamalika Das, Andres F. Garcia, Anthony Granville, Martin Heger, Sachiko Kondo, Thierry Martin, Taisei Matsuki, M Towhid Nawaz Mowla, Vladislava I. Nemova, Thu Thi Le Nguyen, Justice Odoi, Alexander Pankov, Anjali Suneel Parasnis, Ernesto Sánchez-Triana, Hua Tan, Partha Guha Thakurta, Mike Tomin, Margaret Triyana, Baljit Wadhwa, and Yutaka Yoshino. The team acknowledges other colleagues for their suggestions to refine the report: Tanuja Bhattacharjee, Harsh Goyal, Bernard Haven, Christine Heumesser, Md. Khaliquzzaman, Lilian Pena, Wameq Azfar Raza, Ignacio Urrutia, Jari Väyrynen, Samina Yasmin (World Bank), Sadiq Ahmed (Policy Research Institute), Tanvir Ahmed (Bangladesh University of Engineering and Technology), SoEun Ahn (Korea Environment Institute), A.K. Enamul Haque (East West University), and Mahfuzar Rahman (Pure Earth). The team is grateful to Mercy Miyang Tembon (Vice President and Corporate Secretary), Abdoulaye Seck (Country Director), and Christophe Crepin (Practice Manager), who provided overall guidance throughout the completion of this work. The team also acknowledges Mehrin Ahmed Mahbub, Faizul Karim, and Ramim Ahmed, who led outreach and communi- cations, supported by Stan Wanat for editing, Anthony Bagliani for design, layout, and infographics, and Mahajabin Afrin, Ian Richie Paulson, and Hanny for overall administrative support. Any remaining errors or omissions are the authors’ own. The team gratefully acknowledges the financial support provided for the report by the Korea Green Growth Trust Fund, PROBLUE, and the Global Program on Sustainability. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 VIII Executive Summary Executive Summary The 2023 Country Environmental Analysis (CEA) aims to support the Government of Bangladesh (GoB) in informing policies and investments for improving environmental health and pollution management, a critical step towards a green growth pathway. The CEA report focuses on (a) identifying the environmental priorities of the country and assessing how they affect health and productivity; (b) identifying interventions to tackle those priorities; (c) assessing the strengths and shortcomings in the country’s environmental governance framework to address the environmental priorities and implement the proposed interven- tions; and (d) based on that analysis, making recommendations to strengthen governance and agencies’ institutional capacity for environmental management. Over the past two decades, Bangladesh made substantial economic progress as one of the world’s fastest-growing econo- mies, having reached lower-middle-income (LMI) country status in 2015 and being set to move off of the United Nations’ Least Developed Country Index in 2026. However, the COVID-19 pandemic, followed by a sharp rise in global commodity prices and monetary policy tightening in advanced economies, decelerated the Bangladesh’s economic growth and increased the poverty rate for the first time in decades. Bangladesh’s development pathway has occurred at the expense of public goods, with negative externalities that affect the health, productivity, and welfare of the Bangladeshi people, particularly the poor and the most vulnerable groups. Intensive manufacturing and rapid urbanization, coupled with limited institutional capacity for environmental governance, have resulted in severe environmental degradation, natural resources depletion, and increased vulnerability to climate change. In Bangladesh, the exposure to environmental health risk factors is at critically high levels. Four major environmental health risks were associated with over 272,000 premature deaths and 5.2 billion days lived with illness, which has an annual cost equivalent to 17.6 percent of GDP in 2019. The highest impacts are due to ambient air pollution (AAP) and household air pollu- tion (HAP), responsible for nearly 55 percent of the deaths. These two factors should be established as the highest environmen- tal priorities. Unsafe drinking water, poor sanitation, and hygiene; and lead exposure also represent pressing challenges, having caused approximately one-fourth and one-fifth of total deaths, respectively. Despite substantial declines in lead exposure over the last two decades, blood lead levels (BLLs) in children and adults remain at very high levels, and 17 percent of the population relies on drinking water with arsenic concentrations above the WHO guideline of 10 ppb. Lead exposure is estimated to have impaired intelligence among children, amounting to an annual loss of nearly 20 million IQ points. Environmental pollution limits the country’s human capital formation and retention and affects city attractiveness and com- petitiveness by reducing livability and productivity. Environmental impacts pose a disproportional burden on the poorest and most vulnerable groups, such as women, elders, and children under five years old, who suffer long-lasting health effects (includ- ing impacts on their cognitive development and productivity). These groups have limited resources to cope with the impacts of pollution on their livelihoods. Additionally, internal climate and rural-urban migration is adding pressure on cities, with increased traffic, noise and air pollution, and higher demand for essential services such as water supply and sanitation, solid-waste man- agement, energy provision, and health services, which are already constrained, especially for the most disadvantaged groups and during extreme climate events. Bangladesh faces other environmental and natural resource issues, such as river pollution and salinity intrusion, soil deg- radation, biodiversity loss, high exposure to mercury and heavy metals and noise pollution. Plastic-waste management is particularly challenging in the country. Plastic waste is mostly burned or openly dumped together with other solid waste streams, leading to increased flooding and river pollution, damage to ecosystems, and health risks such as vector-borne dis- eases and illnesses from air pollution. Since rivers discharge into the sea, plastic pollution in waterways is directly linked to marine pollution. The CEA assessed potential solutions to prevent and mitigate the impacts of Bangladesh’s major environmental health risks. A benefit-cost analysis helped identify appropriate interventions that promised the greatest control of impacts by presenting benefit-cost ratios (BCRs)1 of alternative policies and investments. Implementation of the following interventions (all with BCRs greater than one) is estimated to prevent over 133,000 premature deaths per year, among other benefits: BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 IX Executive Summary • Ambient and household air pollution control interventions. Comprehensive measures can, if fully implemented, reduce am- bient PM2.5 by as much as 33 percent by 2030. Priorities for such control measures include the following: (a) replace household use of solid fuel for cooking by switching to liquefied petroleum gas (LPG) or electricity; (b) control emissions from industry and the power sector; (c) eliminate the burning of waste; (d) improve management of agricultural fertilizers and livestock ma- nure; and (e) collaborate with neighboring countries to address transnational PM2.5 pollution. The most effective intervention to improve ambient PM2.5 is the reduction or elimination of solid fuel for cooking by households switching to LPG or electricity, which has the added benefit of reducing the health effects of HAP. Other priorities for HAP control measures are to (f) further assess the potential for promoting the use of electric stoves for cooking, and perhaps especially induction stoves, a cheaper option than LPG for small users of electricity that can benefit from lower residential block tariff rates for electricity, and (g) further assess price and non-price obstacles and incentives for adoption of LPG for cooking. In the transition to cleaner fuels for households, continued expansion of improved cookstoves programs (particularly the promotion of dual-burner stoves) will continue to be important for households that cannot afford cooking with LPG or electricity. In parallel, health policies are needed to (a) enhance curative care of health problems brought on by air pollution, and (b) gather community-level data on the health issues in air pollution hotspots, coupled with meteorological and air quality data, to inform policy decision-making. • Lead exposure control interventions. Because of data constraints on the sources of lead, three provisional interventions were considered to mitigate lead exposure and impacts. The following interventions should be prioritized: (a) supplement iron for children ages 6 to 59 months; (b) replace lead-contaminated cookware made from recycled aluminum; and (c) rehabilitate abandoned used lead-acid battery (ULAB) recycling sites. The main benefit of these interventions is increased lifetime in- come from averting IQ losses in early childhood. To address the challenges of lead pollution and population exposure, which will still take time to solve, priority should also be given to (d) undertaking representative BLL measurement studies along with identification of sources of lead exposure, which will inform further policy formulation; (e) building the country’s laboratory ca- pacity for measuring BLL and testing lead in food and other products; and (f) enhancing coordination across environmental, health, food safety and consumer agencies to improve data management and policy formulation and to build awareness of lead poisoning and prevention measures among key stakeholders such as health providers and community leaders. • Water, sanitation, and hygiene (WASH) interventions. The interventions with the highest BCRs for addressing microbio- logical pollution that should be prioritized are (a) household point-of-use treatment of drinking water with ceramic filter; (b) safely managed improved non-shared sanitation for households currently having unimproved sanitation; and (c) promotion of handwashing with soap targeting caregivers of children under five. Further measures that should follow are (d) safely man- aged improved non-shared sanitation for households currently sharing sanitation with other households; and (e) promotion of handwashing with soap to all household members. For mitigating exposure to arsenic in drinking water, three control interventions should be prioritized: provision of deep tube wells, ponds with sand filters, and household filtering, such as the SONO filter that uses iron and sand filtration. Further analysis is needed to assess the impacts of other highly poisonous heavy metals in water, such as lead, mercury, and cadmium. Additionally, the CEA used a computable general equilibrium (CGE) model to analyze the economic, distributional, and en- vironmental effects of policy and investment options for the pursuit of Bangladesh’s green growth objectives, particularly through interventions that could reduce air pollution and inadequate WASH. The model’s results suggest that removing the present energy subsidies may be a first choice for a fiscal policy intervention, with beneficial effects on both efficiency and en- vironmental protection, especially for air quality. The removal’s impact on inclusiveness would also be beneficial if the policy is combined with a redistribution of government savings to the poor. Setting the stage for efficient carbon markets also appears to be a feasible policy for Bangladesh with several beneficial effects, especially if combined with suitable policies for redistribution to poorer households. The model’s exercises also assessed investments in water-resources management, suggesting that such a program could be highly beneficial and mobilize local labor and other unemployed resources. In general, the CGE simulations indicated that those policy options may be reasonably effective in generating benefits (reduction of externalities), increasing GDP, and improving the condition of the poor. However, none of the fiscal and investment policy measures taken individually is likely able to sustainably increase incomes and reduce externalities. A combination of policy measures seems more effective than isolated interventions. In addition, command-and-control policies can be usefully complemented by fiscal and redistribu- tion measures. Furthermore, compared to GDP, net social benefits tend to grow more than proportionally with policy combina- tions—and even more so if these policies include redistributive policies. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 X Executive Summary Since air pollution is the country’s highest environmental priority, the CEA also assessed cost-effective measures to improve air quality in the Greater Dhaka Area (GDA), particularly to reduce human exposure to PM2.5, the most harmful air pollutant for human health, to the WHO’s annual Interim Target 1 of 35 µg/m3. Although this initial analysis could be refined with improved input data, it provides a solid basis to identify priority source sectors and interventions for emissions control, mainly due to their large emission-reduction potential. Priority sectors and interventions are (a) cleaner power generation; (b) universal access to clean cooking fuels; (c) separation of food waste, collection, and centralized composting in urban and rural areas; (d) enhanced PM controls at large industrial sources; (e) reduction of road and construction dust; (f) modern brick kilns, and (g) enforcing the ban on open burning of waste. For some sectors, the government has already issued regulations on emission standards, which will show some effect in the future. However, additional policies are needed to improve air quality in the GDA (and the country as a whole), moving beyond command-and-control interventions. A comprehensive program must include a portfolio of measures that deliver sufficient air quality improvements while being economically, socially, administratively, and politically acceptable. Because of transboundary emissions, cooperation with other districts in Bangladesh and countries of the Indo-Gangetic Plain is also indispensable for achieving substantial air quality improvements in the GDA. At the same time, regionally harmonized strategies could alleviate the need to take the GDA’s most expensive measures. Similarly, a holistic, integrated approach based on a combination of legal, financial, and communication instruments is need- ed to improve plastic-waste management. These measures should include (a) research and development of alternatives to single-use plastics; (b) effective implementation of the ban on plastic bags and extension of its scope to other single-use plastic items; (c) mandatory extended producer responsibility (EPR) guidelines to enable industry co-funding of plastic-waste collection and recycling systems and establish producer responsibility organizations (PROs); (d) an integrated waste-management frame- work to address growing plastic waste and disposal in open places; (e) waste segregation at the household level, development of missing infrastructure needed for such segregation, and implementation of behavior-change campaigns; (f) harmonization of plastic-management policies to promote circular economy; (g) plastic cleanup and recovery schemes to reduce legacy plastic waste and mitigate associated impacts; and (h) development of a monitoring system to implement the Solid Waste Manage- ment Rules 2021 and targets of the Plastic Action Plan. Limitations in environmental policies—mostly of command-and-control and focused on environmental clearance—and weak enforcement have rendered Bangladesh’s environmental management framework ineffective in reducing environmental degradation. Although a reasonably structured institutional framework is in place at the Ministry of Environment, Forest and Climate Change (MoEFCC) and the Department of Environment (DoE), their operation is hampered by (a) gaps in their organi- zational structure and environmental regulations; (b) insufficient budgetary and human resources; (c) large emphasis on envi- ronmental clearance and command-and-control policies; (d) capacity constraints for research, monitoring, and enforcement activities; (e) limited public participation and transparency in monitoring, oversight, and decision-making; (f) limited application of the polluter pays principle, with sanctions that are not able to deter polluting activities; (g) insufficient coordination among public agencies at the national and local levels; and (h) bottlenecks at environmental courts and delays in judicial cases. Those constraints are coupled with insufficient incentives for citizens and businesses, such as access to green financing, research and development of green technologies, and awareness campaigns, to comply with environmental regulations and expand their market opportunities. Despite an explicit commitment to green growth in its 8th Five-Year Plan (2021-25) (8FYP), Bangladesh lags other emerging markets and developing economies in green finance due to structural weaknesses. Key stakeholders—such as borrowers, financial institutions (FIs), financial investors, consumers, and the government—still face several institutional bottlenecks and barriers in adopting and financing green practices. Policy options to improve environmental quality and accelerate Bangladesh’s transition towards green growth include the following: • Setting evidence-based priorities. Bangladesh’s environmental governance system shows a misalignment between the country’s environmental priorities, institutional structure and efforts, and resource allocation. This is largely due to (a) the absence of an integrated system of reliable data and organizational capabilities to provide analytical support to the deci- sion-making process, (b) the lack of representation of vulnerable groups that are mainly affected by environmental degrada- tion, and (c) the absence of a formal planning mechanism for allocating financial and human resources according to clearly defined environmental priorities that are linked to poverty alleviation and social priorities. To address those challenges, the GoB needs to enhance its environmental monitoring and data-management capacity, including systematic evaluation of government interventions, networks for automated air and water-quality monitoring, outcome-oriented indicators to assess institutional performance, and adequate institutional presence in the field with sufficient and well-trained staff. Another key BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 XI Executive Summary measure is to create a research and development unit at the DoE, which would conduct the analytical work in partnership with other government agencies to identify priorities and inform environmental planning—for example, through estimates of the cost of environmental degradation, cost-benefit analyses, and economic and distributional modeling. • Diversifying and strengthening environmental policy instruments. As Bangladesh continues to develop its legal and in- stitutional framework for environmental management, it should consider developing a wider range of environmental in- struments, including (a) economic and market-based instruments, such as pollution charges, deposit-refund schemes, EPR, and final demand interventions; (b)  litigation-based instruments, including liability legislation; and (c) information-based instruments, such as awareness campaigns and regular dissemination of environmental quality data and pollution loads, lists of highly polluting industries, and results of enforcement activities. These instruments could initially focus on identified environmental priorities and gradually expand to cover additional areas. In this process, the GoB should carefully assess the interventions’ potential economic, social, and distributional effects, as well as identify mitigation measures for those impacts. As for command and control, a comprehensive amendment to the Environment Conservation Act (ECA) and its rules is need- ed to (a) modernize and make enforcement activities more efficient, including clear provisions to implement the polluters pay principle and set adequate sanctions and incentives for compliance with the ECA’s provisions; (b) set the mandates and foun- dations for further regulations on EPR and payment for ecosystem services (PES); (c) mobilize green financing by establishing a permanent environmental fund, which could receive resources from the compensation for environmental damage envis- aged in Article 7 of the ECA and eventually from environmental taxes; (d) improve stakeholder engagement in environmental decision-making; and (e) require Strategic Environmental Assessment for policies, plans, and programs, among other themes. As for the Environmental Clearance (EC) system, as a first measure, the DoE should conduct an in-depth, independent eval- uation of Environmental Clearance Certificates (ECCs) approved for red and orange category projects, to extract common challenges and lessons to inform policy formulation—not only for improving the EC process, but also further regulate spe- cific technical requirements. Although the ECR 2023 is expected to improve the EC process, additional amendments and guidelines are required to clarify and strengthen assessment criteria and procedures related to key themes— for example, the screening of projects that are not pre-categorized in the ECR; monitoring and enforcement after ECC issuance; stakeholder consultations and access to information, including through ICT tools. • Strengthening organizational structure and institutional capacity. The GoB should carry out a detailed analysis of the organizational structure of the MoEFCC and affiliated agencies to set clearer mandates and more efficient processes for environmental governance, including interagency coordination. The DoE needs specialized technical units to respond to identified environmental priorities with the necessary human, technical, and financial resources to fulfill their mandates. The establishment of an environmental prosecution agency that is independent of the DoE and shielded from political interference must also be considered to make the environmental courts system more effective. To strengthen the capacity of environmental organizations to execute decisions, key measures include raising the DoE’s budget (especially for monitor- ing and enforcement activities), establishing a cadre of environmental specialists, and increasing the DoE’s headcount. This will allow more qualified professionals to reach senior official positions, attract and retain talented individuals, and ensure that decisions and policies are made by people with adequate backgrounds and experience. Completing the DoE’s decen- tralization process is also essential to expand its physical presence to all districts, with adequate staffing, equipment, and budget, and to expedite actions and better balance the needs and priorities of central government officials and politicians with local stakeholders. For that, a comprehensive information-management system with automated monitoring for com- pliance and enforcement is essential for an effective decentralization process, as well as for gathering critical data to inform decision-making and public participation. • Strengthening citizen-driven accountability. Responding to priority environmental challenges in Bangladesh calls for a more systematic effort to raise awareness of, and social accountability for, environmental issues. Also missing in the current institutional framework are mechanisms to incorporate the concerns of groups most severely affected by environmental degradation into the GoB’s planning processes, as well as to allow citizens to directly litigate in environmental courts as plain- tiffs—which requires amending the Environment Court Act. Ways to improve public information and promote transparency, accountability, and awareness include the publication of data in support of key environmental indicators (including pollution loads and environmental health statistics), wider use of public forums for air development initiatives, and broader and more detailed review and discussion of environmental management tools. Mechanisms to disseminate information in a manner that is easily interpretable can allow communities to serve as informal regulators. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 XII Executive Summary • Building an enabling environment for green financing. To facilitate the flow of resources from green finance suppliers to sectors pursuing these resources, the GoB should create an environmental management ecosystem by (a) adopting a broad- based national green growth strategy and a national action plan backed by a commensurate set of regulatory and institution- al frameworks; (b) constituting a high-level national oversight body to coordinate and monitor the progress of green growth efforts; and (c) creating an ecosystem of ministries and government agencies that collect and analyze point-source data to enforce policies that create a pipeline of verified investment-ready projects. Expanding its range of environmental policy in- struments, the GoB should use a mix of incentives to boost environmental markets by (a) encouraging the adoption of green practices and promoting green businesses and investments with positive environmental externalities; (b) adopting incentives that address the risks faced by FIs; (c) fostering a collaborative institutional system to implement green financial incentives; and (d) reducing the risks perceived by financiers and boost private-sector adoption of green practices and technologies, and thereby boost the offering of green products and services. Strengthening institutional and borrower capabilities is also essential for building skills and expertise in green financing across sectors, from technocrats in government agencies to FIs, and from private businesses to students. Endnote 1 BCR is the ratio of benefits to costs. A BCR greater than one indicates that the benefits are greater than the costs. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 1 Introduction CHAPTER 1. INTRODUCTION 1.1 Country context Bangladesh, the eighth most populous country in the world, is one of the world’s fastest growing economies with substantial economic progress over the past two decades. Since 2000, income per capita has has tripled,, and the poverty rate has more than halved from 48.9 percent to 21.8 percent in 2018 (based on the national poverty line). Bangladesh reached lower-middle-in- come (LMI) status in 2015 and was set to move off of the United Nations’ Least Developed Country Index in 2026. However, the COVID-19 pandemic decelerated the Bangladesh’s economic growth nearly and increased the poverty rate for the first time in decades. GDP growth fell from 7.9 percent in fiscal year 2019 to 3.4 percent in fiscal year (FY) 2020, as exports declined due to supply-chain disruptions and depressed external demand for ready-made goods (RMG) exports. Although Bangladesh seemed to recover rapidly from the COVID-19 pandemic, a sharp rise in global commodity prices and synchronized monetary policy tightening in advanced economies put that recovery at risk. Real GDP growth decelerated from 7.1 percent in FY2022 to an estimated 6.0 percent in FY2023, as high inflation weighed on private consumption and fiscal consolidation measures slowed government consumption and investment growth. Recovery is expected but will be gradual. The GDP growth is expected to decelerate in FY2024 before returning to its long-term trend. Bangladesh’s development pathway has occurred at the expense of public goods, with negative externalities that affect the health, productivity, and welfare of the Bangladeshi people, particularly the poor and the most vulnerable groups. Intensive manufacturing and rapid urbanization, coupled with limited institutional capacity for environmental governance, have resulted in severe environmental degradation, natural resources depletion, and increased vulnerability to climate change. In Bangladesh, 3 in 10 children grow up stunted due to polluted water or lack of nutrition. In 2019, the health effects of ambient and indoor air pollution; lead exposure; and inadequate water, hygiene, and sanitation were responsible for 32 percent of prema- ture deaths nationwide; 5.2 billion days lived with illness; and impaired intelligence among children, amounting to a loss of 20 million IQ points, according to this Country Environmental Analysis (CEA). Soil and water contamination, including from salinity intrusion and heavy metals, degrade natural resources essential for livelihoods and productive activities. The rivers surrounding the Greater Dhaka Area (GDA) receive about 60,000 meters per day of toxic industrial waste from more than 7,000 industries mainly located in nine major industrial cluster areas: Tongi, Hazaribagh, Tejgaon, Tarabo, Narayanganj, Savar, Gazipur, Ghorashal, and the Dhaka Export Processing Zone (Uddin and Jeong 2021). Soil pollution from industries is a major issue that also indirectly affects the rivers through groundwater flows and runoff during rainfall and flood events into the water bodies. Furthermore, chemicals used for agriculture are significantly polluting the soil. Inadequate waste management also contributes to the spread of vector-borne diseases, increased air pollutants and greenhouse gas emissions, and increased vulnerability to flooding. De- pletion of the critical natural areas is also leading to a steady increase in the risk to flooding around the coastal areas, as well as infiltration of salinity into Bangladesh’s surface and groundwater supplies (Sen and Ghorai 2019). Those environmental impacts pose a disproportional burden on the poorest and most vulnerable groups, such as women, elders and children under age five years, who suffer from long-lasting health effects (including impacts on their cognitive development and productivity) and have limited resources to cope with impacts of pollution on their livelihoods. Therefore, environmental pollution limits their ability to overcome poverty and impairs the country’s human capital formation and retention. Pollution can also affect a city’s attractiveness and competitiveness by reducing livability and productivity. Additionally, internal climate and rural-urban migration is adding pressure on cities, with increased traffic, noise and air pollution, and higher demand for essential services such as water supply and sanitation, solid-waste management, energy provision, and health services, which are already constrained, especially for the most disadvantaged groups and during extreme climate events. Without targeted pol- icy action, increasing internal migration will exacerbate environmental degradation, affect climate-sensitive sectors, and further strain infrastructure and social safety-net systems (Rigaud et al. 2018). Environmental degradation in Bangladesh is linked to constraints in environmental governance, such as (a) regulation gaps; (b) large emphasis on environmental clearance and command-and-control policies; (c) poor monitoring and enforcement capacity; (d) limited public participation and transparency in monitoring, oversight, and decision-making; (e) limited application of the polluter pays principle, with sanctions that are not able to deter polluting activities; (f) lack of coordination and clear mandates for environmental and climate-data management among public agencies; and (g) bottlenecks at environmental courts and delays BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 2 Introduction in judicial cases. These constraints also affect business development by delays in environmental clearance processes, arbitrary decisions, lack of legal certainty, and lack of support to improve the environmental performance of local enterprises to access international markets. In this context, a shift in Bangladesh’s growth model is urgently needed to allow greener and more resilient development. The World Bank (2012) defines green growth as a growth pattern that is efficient in its use of natural resources; clean in that it mini- mizes pollution and environmental impacts; resilient in that it accounts for natural hazards and other shocks and the role of en- vironmental management and natural capital in preventing disasters; and inclusive as it maximizes benefits for, and minimizes costs to, the poor and most vulnerable. Following a green growth strategy path for Bangladesh means that economic, social, and environmentally sustainable growth is achieved in a way that pursues poverty eradication and shared prosperity. Such a strategy will (a) ensure that natural resources and environmental services can sustainably fulfill their economic potential, and (b) tackle the increasing risks of shocks in an integrated manner and simultaneously ensure sustainability, resilience, and inclusiveness. Channeling financing and policy shifts into a green growth approach can create a multiplier effect: reviving the economy, in- vesting in projects to help Bangladesh prepare for the impending challenges of climate change while creating jobs, promoting low-carbon infrastructure, and building a more equitable society. Moreover, green growth is pivotal to ensuring that Bangladesh can decouple from its rather high carbon-intensive and relatively highly polluting, unsustainable growth path to one that is resil- ient and inclusive as Bangladesh endeavors to improve the quality of life and opportunities for all its citizens. The Government of Bangladesh (GoB) has initiated such a transition, as envisaged in its major national development strategies. Bangladesh’s 8th Five-Year Plan (2021-25) (8FYP) centers on six core themes, including “a sustainable development pathway that is resilient to disaster and climate change, ensures sustainable use of natural resources, and successfully manages the inevitable urban transition” (GED 2020). Over the medium term, the 8FYP targets comprehensive structural reforms to accelerate sustain- able growth while building climate resilience across the economy, enhancing the provision of public services, especially for peo- ple living in poverty, and promoting a better-managed environment and natural resources to support productivity and growth. Green, resilience, and inclusion elements are also embedded in the Bangladesh Delta Plan 2100 (BDP), a key instrument to ad- dress the sources of long-term climate-change vulnerability at source, thereby reducing the adverse effects of climate change on the population and generating co-benefits for environmental sustainability, job creation, and provision of essential services (GED 2018). The recently adopted National Adaptation Plan 2023–2050 (NAP) aims to build climate resilience while stimulating sus- tainable and inclusive economic growth. To achieve these goals, the GoB needs to further strengthen its regulatory framework and institutional capacity not only to manage negative environmental externalities from its rapid economic growth, but also to create opportunities for green jobs and new growth engines. 1.2 Objective This CEA provides analytical underpinnings to inform policy reforms and investments for improving environmental health and pollution management, a crucial step towards Bangladesh’s green growth pathway. The report focuses on (a) identifying the environmental priorities of the country and assessing how they affect health and productivity; (b) identifying interventions to tackle those priorities; (c) assessing the strengths and shortcomings in the country’s environmental governance framework to address the environmental priorities and implement the proposed interventions; and (d) based on that analysis, making recommendations to strengthen governance and agencies’ institutional capacity for environmental management. 1.3 Methodology An interdisciplinary team prepared a series of background papers whose findings and recommendations are compiled in this CEA. As a first step, the team reviewed the 2018 CEA to identify critical themes to be updated and expanded in the cur- rent report, as well as the GoB’s progress in implementing the recommendations (box 1.1). The 2018 CEA focused on urban areas, identifying challenges related to environmental degradation and analyzing the country’s institutional framework for environmental management and green growth. The report outlined recommendations to improve policies, regulations, and institutional capacity in the areas of pollution management, resource efficiency, and environmental performance. The present CEA covers both urban and rural areas. Although it also focuses on pollution issues, the 2023 CEA expands the environmental governance analysis and, through a variety of economic analyses, the range of potential interventions to overcome environ- mental degradation. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 3 Introduction The team used the Green, Resilient, Inclusive Development (GRID) benchmarking tool to assess Bangladesh’s performance across four pillars (sustainability, efficiency, resilience, and inclusivity) in critical indicators against its development peers, aspira- tional targets, and the world. This exercise uncovered Bangladesh’s deficiencies in all GRID dimensions, with the worst perfor- mance in indicators under the sustainability and resilience pillars: high mortality from air pollution, significant water-pollution challenges, high levels of deforestation, significant land degradation, high proportion of slum population, and high risk to assets, among others. The GRID benchmarking informed the selection of priority themes for developing the CEA. The CEA scoping was also informed by the report Breathing Heavy: New Evidence on Air Pollution and Health in Bangladesh (Raza et al. 2022), and the World Bank (2022b) report Striving for Clean Air: Air Pollution and Public Health in South Asia. Box 1.1 Main developments since the 2018 CEA The GoB incorporated some of the 2018 CEA recommendations in its 8FYP, highlighting its plans to (a) initiate environmental fiscal reforms to reduce pricing distortions that undermine sound environmental management; (b) improve monitoring of air and water quality, pollution emissions, and discharges; (c) expand public participation in environmental management; and (d) decentralize environmental management. The GoB has made progress implementing some of these plans. For ex- ample, the budget allocation to the Ministry of Environment, Forest and Climate Change (MoEFCC) has increased in the past three years after a reduction because of the COVID-19 pandemic. The MoEFCC has strengthened its regulatory framework by adopting, among other instruments, the 2023 Environment Conservation Rules (ECR), 2022 Air Pollution Control Rules (APCR), and 2021 Solid Waste Management Rules. The DoE has added a wing on chemicals and waste management to its organogram and expanded the number of district offices. With support from the World Bank-financed Bangladesh Envi- ronmental and Sustainability Transformation (BEST) Project, the DoE is expected to receive financial resources and technical assistance in the next years to (a) decentralize and increase the technical specialization of its organizational structure, includ- ing new local offices, environmental monitoring systems, and tools for disseminating environmental information; (b) recruit and retain qualified technical staff; (c) develop regulatory and policy reforms; and (d) create an endowment fund to mobilize sustainable financing for environmental conservation actions. Going further in identifying the country’s environmental priorities, the team estimated the costs of environmental degradation in Bangladesh. The analysis determined the focus of the CEA on pollution management, particularly air quality management. After identifying the major environmental challenges, the team conducted a benefit-cost analysis to compare—and assess the eco- nomic feasibility of—alternative interventions that are readily available to reduce the significant costs of environmental degrada- tion, particularly household and outdoor air pollution, inadequate water, sanitation, and hygiene (WASH), and lead (Pb) contami- nation. For air pollution, the team also conducted a cost-effectiveness analysis of key interventions for the GDA. The team developed a computable general equilibrium (CGE) model to provide quantitative estimates on the environmental sustainability, economic contributions, and social implications of alternative policy scenarios that could improve air quality and WASH. Additionally, a review of the GoB’s national development strategies and interviews with key stakeholders led to specific studies on plastic-waste man- agement. Furthermore, an analysis of the country’s environmental governance system aimed at identifying interventions to im- prove Bangladesh’s institutional capacity to address its environmental priorities, including enhancing the environmental clearance system, diversifying policy instruments, and establishing the underlying conditions for green financing. The institutional analysis was informed by an overview of the country’s framework for assessing and managing the environmental and social risks and im- pacts of development projects, taking the World Bank’s Environmental and Social Framework as a benchmark. The CEA also considered findings and recommendations from other World Bank-financed analytics, such as (a) the 2022 Bangla- desh Country Climate and Development Report (CCDR) (World Bank 2022a), (b) the ongoing technical assistance (TA) to develop an Umbrella Investment Program (UIP) for the Dhaka Rivers, and (c) the upcoming Framework for Implementing Green Growth in Bangladesh (FIGGB) Report. The CEA recommendations to improve environmental governance, plastic-waste management, and WASH interventions are well aligned with the findings and recommendations of the UIP TA on industrial pollution in the GDA. Building on the CCDR recommendation of adopting a clean air program with climate co-benefits, the CEA provides key analytical underpinnings for selecting interventions and enhancing the institutional framework needed to design and imple- ment such a program. In addition, the CEA complements the CCDR findings that underpin recommendations on (a) incentives for green financing, (b) energy-focused carbon tax, (c) phasing out fossil fuel subsidies, and (d) circular economy solutions for in- dustries. The CEA also informed the FIGGB Report, as reflected in recommendations for improving environmental management and adopting specific policies for increasing efficiency and sustainability in key economic sectors, as well as setting the enabling environment for green financing. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 4 Introduction 1.4 Structure of the CEA Report This CEA compiles the findings and recommendations of several papers and stakeholder consultations. The report is structured in eleven chapters as follows: Chapter 1 introduces the report with information on the country context and the objectives, scope, and methodology of the CEA. Chapter 2 estimates the health effects and corresponding costs of environmental degradation. The chapter focuses on (a) out- door and household air pollution (PM2.5), (b) lead exposure among children and adults, and (c) inadequate WASH, including arsenic contamination in drinking water and microbiological pollution. Chapter 3 summarizes key institutions and regulations for environmental management in Bangladesh, especially policy instru- ments and agencies that are relevant to the country’s environmental priorities. The chapter assesses the strengths and short- comings of Bangladesh’s environmental governance system, including mechanisms for planning and organizational perfor- mance evaluation, interagency coordination, environmental monitoring and data management, enforcement, accountability, transparency, and public participation. Chapter 4 discusses the main elements of the environmental clearance system in Bangladesh, considering aspects such as the nature of environmental impact assessments, institutional leadership, and interagency coordination, screening and scoping processes, public participation, access to information, and evaluation of alternatives. The chapter assesses the adequacy of the environmental clearance system to address the country’s environmental priorities. Chapter 5 analyzes the costs and benefits of potential interventions to address household and outdoor air pollution; inadequate water, hygiene, and sanitation; arsenic contamination in Bangladesh; and lead exposure. Through this cost-benefit analysis (CBA), the chapter provides information for prioritizing interventions and better allocating the government’s limited resources. Chapter 6 analyzes air quality management in GDA and, through cost-effectiveness and CBA, identifies potential interventions to reduce human exposure to PM2.5 to the WHO’s Annual Interim Target 1 (35 ug/m3) by 2030. Chapter 7 discusses the prospects for green growth policies in Bangladesh that have the potential to tackle major environmental priorities—that is, air pollution and inadequate WASH. Through a CGE model, the chapter assesses potential economic, distribu- tional, and environmental effects of the following policy experiments: (a) phaseout of energy subsidies, (b) carbon pricing (carbon tax and cap and trade system), and (c) investments in a water program (as envisaged in the BDP). Chapter 8 provides an overview of the physical elements of Bangladesh’s plastic-waste management system and outlines the key policy recommendations to support the transition to integrated plastic-waste management. Chapter 9 identifies the barriers to accessing green financing, especially to address environmental priorities, and proposes inter- ventions to facilitate the flow of resources from green finance suppliers to sectors pursuing such resources. Chapter 10 identifies available environmental policy instruments, beyond traditional command-and-control, for improving envi- ronmental management in Bangladesh. Chapter 11 summarizes takeaways from each chapter and recommendations for policy and investment options to strengthen governance and institutional capacity to support the transition towards a green economy. Following the chapters is a set of 16 appendixes that provide greater detail on some of the topics covered in the main body of the CEA. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 5 Introduction C1 References GED (General Economics Division). 2018. Bangladesh Delta Plan 2100: Bangladesh in the 21st Century—Volume 1: Strategy. Dhaka, Bangladesh: General Economics Division, Bangladesh Planning Commission, Ministry of Planning, GoB. GED (General Economics Division). 2020. Eighth Five Year Plan—June 2020 – June 2025. Promoting Prosperity and Foresting Inclusiveness. Dhaka, Bangladesh: General Economics Division, Bangladesh Planning Commission, Ministry of Planning, GoB. Raza, Wameq Azfar, Iffat Mahmud, and Tamer Samah Rabie. 2022. “Breathing Heavy: New Evidence on Air Pollution and Health in Bangladesh.” International Development in Focus. Washington, DC: World Bank. doi:10.1596/978-1-4648-1919-3. License: Creative Commons Attribution CC BY 3.0 IGO. Sen, H. S., and D. Ghorai. 2019. “The Sundarbans: A Flight into the Wilderness.” In The Sundarbans: A Disaster-Prone Eco-Region, edited by H. S. Sen, 3–28. Coastal Research Library book series, volume 30. Springer, Cham. Uddin, Md. J., and Y.-K. Jeong. 2021. “Urban River Pollution in Bangladesh during Last 40 Years: Potential Public Health and Ecological Risk, Present Policy, and Future Prospects toward Smart Water Management.” Heliyon 7 (2): e06107. https://doi.org/10.1016/j.heliyon.2021.e06107 World Bank. 2012. Inclusive Green Growth: The Pathway for Sustainable Development. Washington, DC: World Bank. https://openknowledge.worldbank.org/ handle/10986/6058. World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/585301536851966118/ Enhancing-Opportunities-for-Clean-and-Resilient-Growth-in-Urban- BangladeshCountry-Environmental-Analysis-2018 World Bank. 2022a. Bangladesh Country Climate and Development Report. Washington, DC: World Bank Group. https://openknowledge.worldbank.org/server/ api/core/bitstreams/6d66e133-e49d-5ad9-b056-7b1a6c6206ed/content World Bank. 2022b. Striving for Clean Air: Air Pollution and Public Health in South Asia. Washington, DC: World Bank. https://www.worldbank.org/en/region/sar/ publication/striving-for-clean-air BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 6 Cost of Environmental Degradation – Environmental Health Issues CHAPTER 2. COST OF ENVIRONMENTAL DEGRADATION – ENVIRONMENTAL HEALTH ISSUES 2.1 Introduction Pollution has substantial impacts on humans and the environment. This includes health impacts such as premature mortality, illness, and associated health-care expenditures and burdens on caregivers; children’s nutritional status and cognitive develop- ment and associated learning productivity, school outcomes and lifetime earnings, and overall labor productivity; impacts on ag- ricultural productivity; impacts on ecosystem services such as forest and water quality and associated effects on wildlife, timber and non-timber forest products, fisheries, and recreation and tourism; and effects on urban attractiveness, housing values, and competitiveness of cities. The health impacts of pollution have generally been found to constitute the largest share of the cost of pollution that can be quantified. Consequently, quantitative assessments of such health impacts can serve as an instrument to identify environmental priorities, mobilize support for their implementation, and move forward towards realizing environmental goals and objectives. Based on environmental issues raised by the Government of Bangladesh (GoB) and in literature review, this chapter estimates the main health effects in Bangladesh from key environmental health risks in 2019: outdoor ambient air pol- lution (AAP); household air pollution (HAP) from use of solid fuels; lead (Pb) exposure; and inadequate drinking water, sanitation, and hygiene (WASH) including arsenic in drinking water. Monetized estimates are provided of the social and economic cost of these health effects in taka and as a percentage of Bangladesh’s GDP in 2019, using standard economic valuation techniques. These estimates have required a large amount of data and multiple methodologies that are summarized in appendix A. Although this chapter focuses on those four major environmental health risks, Bangladesh faces other environmental and nat- ural resources degradation issues, such as water pollution including river pollution and salinity intrusion, soil degradation, biodi- versity loss, exposure to mercury and other heavy metals, and noise pollution. Further studies should be conducted to assess the costs and impacts of those environmental problems. 2.2 Ambient air pollution Particulate matter (PM) and especially PM2.5 is the outdoor ambient air pollutant that is globally associated with the greatest health effects.2 Population-weighted ambient PM2.5 in Bangladesh and nearby countries is presented in figure 2.1. Ambient PM2.5 in Bangladesh was 63.4 μg/m3 in 2019. This is more than twelve times as high as WHO’s annual air quality guideline (AQG) for PM2.5 of 5 μg/m3 and nearly twice the WHO’s first interim target and Bangladesh’s standard of 35 μg/m3 for annual air quality (WHO 2021). Figure 2.1 Population-weighted ambient PM2.5 concentrations in Bangladesh and region in 2019 | µg/m3 Source: HEI 2020. Note: Data from Global Burden of Disease Study 2019. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 7 Cost of Environmental Degradation – Environmental Health Issues 2.2.1 Population exposure to ambient air pollution Monthly average ambient PM2.5 is reported in eight divisions in Bangladesh. The annual average PM2.5 calculated from these month- ly averages ranges from 48 to 103 μg/m3 (figure 2.2). This is 10–20 times the WHO AQG for annual PM2.5. Figure 2.2 Annual ambient PM2.5 at monitoring stations in Bangladesh, 2019–2 1 | µg/m3 Source: Produced from data reported in the Monthly Air Quality Monitoring Reports by DoE, Bangladesh. Note: Annual ambient PM2.5 is calculated for the full twelve months of a year. Data from the COVID-19 lockdown periods of April, May, and June 2020 are not included. Ambient PM2.5 during the lockdowns was substantially lower than during a normal year according to estimates by Qui et al. (2021). The measurement data from the urban monitoring stations are used here as an approximation for ambient PM2.5 in urban areas in the eight divisions. This results in population-weighted urban annual ambient PM2.5 of 77 μg/m3. Measurements of ambient PM2.5 in rural areas are practically nonexistent. Major sources of PM2.5 in rural areas include emissions from burning of solid fuels by households for cooking and other domestic purposes; waste burning; and long-range emissions from urban areas within a di- vision, from other divisions within Bangladesh, and from outside Bangladesh. The GBD 2019 reports population-weighted annual ambient PM2.5 of 63.4 µg/m3 in Bangladesh in 2019 based on available urban PM2.5 measurements at monitoring stations, chem- ical transport models, and nationwide urban and rural satellite imagery data (HEI 2020). This implies that population-weighted annual ambient PM2.5 was 57 μg/m3 in rural areas, or 75 percent of annual urban ambient PM2.5. Estimated annual ambient PM2.5 by urban, rural, and total for each division is presented in figure 2.3. The sources of the high ambient PM2.5 concentrations in Bangladesh include typical sectors such as road vehicles, industry, and power plants; sectors that often receive less attention such as emissions from the burning of solid waste and emissions from household use of solid fuels for cooking and other domestic purposes that reach the outdoor ambient air; and PM2.5 precursor emissions from fertilizer and livestock practices. Sources of ambient PM2.5 in Bangladesh also include emissions originating from outside Bangladesh. This is discussed in chapter 5 and for the Greater Dhaka Area (GDA) in chapter 6. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 8 Cost of Environmental Degradation – Environmental Health Issues Figure 2.3 Estimated population-weighted annual ambient PM2.5 by division in Bangladesh, 2019–21 | µg/m3 Source: World Bank based on monitoring data from DoE. Note: Data from the COVID-19 lockdown periods of April, May, and June 2020 are not included. 2.2.2 Health effects of ambient air pollution The health effects of long-term exposure to ambient PM2.5 include ischemic heart disease (IHD), cerebrovascular disease (stroke), chronic obstructive pulmonary disease (COPD), lung cancer, type 2 diabetes, acute lower respiratory infections (ALRI) and neona- tal disorders. These are all major health effects evidenced by the GBD 2019 (GBD 2019 Risk Factors Collaborators 2020). Figure 2.4 shows how the risk of death from the six main health effects increases with increasing levels of PM2.5 exposure. The risks are substantial even at low concentrations of ambient PM2.5 and increase rapidly for exposure levels up to 70–90 μg/m3 for all health outcomes except for type 2 diabetes, which flattens out from 35 μg/m3. The risk continues to rise linearly for COPD and ALRI even beyond PM2.5 of 90 μg/m3. Annual deaths from PM2.5 exposure in each of the eight divisions in Bangladesh are estimated from the population-weighted annual ambient PM2.5 in each division in figure 2.3 and the risks of health effects in figure 2.4 (see methodology in appendix B). Figure 2.4 Relative risk of mortality from long-term exposure to PM2.5 Source: GBD 2019 Risk Factors Collaborators (2020) Supplement. Note: RRs of IHD and stroke are age-weighted. An estimated 87–95 thousand people died from ambient PM2.5 air pollution in Bangladesh in 2019, with a central estimate of 91 thousand (table 2.1). About 63 percent of the deaths were from IHD and stroke; 28 percent from pulmonary diseases (COPD, lung cancer, and ALRI); 5 percent from type 2 diabetes; and 4 percent from neonatal disorders. Ambient PM2.5 also caused an estimat- ed 245–266 thousand disability adjusted years of life lived with illness, corresponding to 1.1–1.2 billion days lived with illness. COPD, BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 9 Cost of Environmental Degradation – Environmental Health Issues diabetes, and heart disease accounted for the largest shares of days lived with illness (table 2.2).3 Health effects from ambient PM2.5 during COVID-19 may have been somewhat less than in 2019 due to a lower amount of pollution-generating activities. Health effects likely increased again after COVID-19 along with economic recovery unless actions were implemented to reduce pollution. Table 2.1 Estimated annual deaths from ambient PM2.5 in Bangladesh, 2019 Low Central High Ischemic heart disease (IHD) 23,458 24,489 25,827 Stroke 31,419 32,824 34,648 COPD 14,808 15,247 15,773 Lung cancer 1,867 1,951 2,057 ALRI 8,153 8,390 8,672 Type 2 diabetes 4,387 4,576 4,822 Neonatal disorders 2,986 3,143 3,301 Total in Bangladesh 87,079 90,620 95,099 Source: World Bank. Table 2.2 Estimated days lived with illness from ambient PM2.5, 2019 | Millions Low Central High IHD 292 305 322 Stroke 112 117 124 COPD 353 363 376 Lung cancer 0.67 0.70 0.74 ALRI 19 20 20 Type 2 diabetes 333 347 366 Neonatal disorders 0.43 0.45 0.47 Total in Bangladesh 1,110 1,153 1,208 Source: World Bank. 2.2.3 Cost of health effects of ambient air pollution The cost of health effects of ambient PM2.5 is estimated at Tk 1,291–1,409 billion in 2019, with a central estimate of Tk 1,343 billion (table 2.3). This cost is equivalent to 4.4–4.8 percent of Bangladesh’s GDP that year, with a central estimate of 4.55 percent. Mortal- ity accounts for 86 percent and morbidity for 14 percent of estimated cost (see methodology in appendixes H and I). Table 2.3 Estimated cost of health effects of ambient PM2.5 in Bangladesh in 2019 | Tk, billions Low Central High Cost of mortality 1,105 1,150 1,207 Cost of morbidity 186 193 202 Total cost of health effects 1,291 1,343 1,409 Percent of 2019 GDP 4.38% 4.55% 4.77% Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 10 Cost of Environmental Degradation – Environmental Health Issues 2.3 Household air pollution Household air pollution from the use of solid fuels for cooking and, in some climates for heating, is a major environmental health risk in low- and middle-income countries (LMICs). Seventy-four percent of the population in Bangladesh used solid fuels as pri- mary cooking fuels in 2022 down from 84 percent in 2011 (figure 2.5). The decline in solid fuel use was particularly rapid from 2016 to 2022 at a rate of -1.6 percentage points per year, implying that 650,000 households have been switching to clean fuel and cooking technologies (LPG, gas, electricity) per year. The rate of decline in urban areas was three times faster than in rural areas. At these rates of decline 62 percent of the population will be using solid fuels as primary cooking fuel in 2030. The main solid fuels in Bangladesh are crop residue and wood. As many as 27–33 percent used crop residue and 38–48 percent used wood as primary cooking fuel as recent as 2019.4 Available national surveys seem, however, to indicate a large decline in the use of crop residue as primary fuel in favor of wood from 2018/19 with the Bangladesh Population and Housing Census 2022 reporting 10 percent of households using crop residue and 59 percent using wood as primary cooking fuel (BBS 2022a). One reason may be that crop residue may have become a secondary instead of primary fuel because more households are adopting improved cookstoves (ICSs) with higher fuel efficiency that reduces household demand for crop residue more than for wood. A second reason may be differences in classification of fuels across surveys. Figure 2.5 Solid fuels used for cooking in Bangladesh, 2011–22 | Percent of population Source: World Bank estimates from (BBS 2015; 2019; 2021; 2022a). 2.3.1 Population exposure to household air pollution Exposure to household air pollution depends, among other factors, on cooking location and ventilation, type of cooking fuel, and type of cookstove. Three percent of households in Bangladesh cook in the main house with no separate room, 22 percent cook in a separate room in the main house, 42 percent cook in a separate building from the main house, and 33 percent cook outdoors (BBS/UNICEF 2019). Among the solid fuels used by households in Bangladesh, wood tend to be somewhat less polluting than animal dung, grass/shrub, and crop residue (Shupler et al. 2020). Large-scale ICS programs have made inroads in Bangladesh over the last decade. Over 8 percent of households, or nearly 3.5 million, had a stove with a chimney in 2020 (BBS 2021). Most of these stoves are the Bondhu Chula, a fixed-chimney stove with one to three plates, of which 5 million have been distributed.5 Also, the Infrastructure Development Company Limited (IDCOL) with its partner organizations have sold 3.8 million ICSs as of February 2023.6 The IDCOL stoves are available in three main types ranging from a portable single-plate stove without chimney to single- and double-plate stoves with chimney. The portable single-plate stove accounts for 88 percent of the number of sold stoves (Berkeley Air Monitoring Group 2022). Combined, the Bondhu Chula and IDCOL programs are distributing about 1 million stoves per year. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 11 Cost of Environmental Degradation – Environmental Health Issues Several studies have measured PM2.5 in household kitchens in Bangladesh, but few have measured personal PM2.5 exposures that are needed to assess health effects of solid-fuel use. One study measured personal PM2.5 exposures averaging 144 µg/m3 among 200 adult women cooking with solid fuels in traditional cookstoves (TCS) in rural areas in Chittagong and Dhaka divisions. Mea- surements were conducted over a 48-hours period once in the dry season and once in the wet season (Shahriar et al. 2021). More recently a study of 300 adult women in five divisions measured personal PM2.5 over a 24-hour period in the dry season (Berkeley Air Monitoring Group 2022). Half of the women cooked with solid fuels in TCSs and half with solid fuels in IDCOL’s ICSs. Personal exposures averaged 236 µg/m3 among the women cooking with TCS and 179 µg/m3 among the women cooking with ICS.7 The personal exposures in those two studies include the exposure to ambient PM2.5 in addition to PM2.5 from household use of solid fuels. Subtracting ambient PM2.5 gives net household air pollution personal exposure among adult women of 77 µg/m3 based the study by Shahriar et al. and 107 µg/m3 based on the study by Berkeley Air Monitoring Group. These estimates are used as low and high personal exposures for the estimation of health effects due to household air pollution from the use of solid fuels. Personal exposures for adult men and children are estimated using women/men and women/children exposure ratios from the Global Burden of Disease (GBD) 2019 that is based on a review of personal exposure studies globally. Thus, average personal exposure for all household members from the use of solid fuels is estimated at 63–88 µg/m3 with a central estimate of 76 µg/ m3 (table 2.4). These estimated personal exposures have been adjusted by the share of households with TCS and ICS, and the difference in personal exposure among women using TCS and ICS as found by the Berkeley Air Monitoring Group.8 The share of households with ICS includes both the Bondhu Chula and IDCOL stoves totaling 8.8 million. Some of these stoves are likely to have been replaced due to old age and damage, or households switching to LPG, gas, or electricity for cooking. The personal exposure estimates are therefore somewhat conservative. While the ICSs provide only a moderate reduction in exposure to PM2.5 household air pollution, the continued expansion of the ICS programs, and the promotion of dual-burner stoves in particular, will continue to be important for households that cannot afford cooking with LPG or electricity and also serve an important role in conserving scarce fuel wood and reduce the use of agricultural residue for cooking. The ICS stoves also reduce PM2.5 ambient air pollution because of their improved fuel efficiency and lower PM2.5 emissions. Table 2.4 Estimated personal PM2.5 exposure from household air pollution for households using solid fuels in Bangladesh | μg/m3 Women Men Children Average Low 77 49 66 63 Central 92 59 78 76 High 107 69 91 88 Source: World Bank. Note: The estimates are net of exposure to ambient PM2.5. 2.3.2 Health effects of household air pollution Health effects of long-term exposure to PM2.5 in the household environment from burning of solid fuels include (a) ischemic heart disease (IHD); (b) cerebrovascular disease (stroke); (c) lung cancer (LC); (d) chronic obstructive pulmonary disease (COPD); (e) type 2 diabetes; and (f) acute lower respiratory infections (ALRI), neonatal disorders, and cataract. These are all major health effects evidenced by the GBD 2019 (GBD 2019 Risk Factors Collaborators 2020). Figure 2.6 shows how the risk of death from the six main health effects increases with increasing levels of PM2.5 exposure. The prevalence rates of solid fuel use of 74 percent, the PM2.5 exposure levels in table 2.4, and the relative risks of health effects in fig- ure 2.6 are combined to estimate the health effects of household PM2.5 air pollution from the use of solid fuels (see methodology in appendix B). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 12 Cost of Environmental Degradation – Environmental Health Issues Figure 2.6 Relative risk of mortality from long term PM2.5 exposure Source: GBD 2019 Risk Factors Collaborators (2020) Supplement. Note: RRs of IHD and stroke are age-weighted. An estimated 62–74 thousand persons, with a central estimate of 69 thousand, died from PM2.5 household air pollution in Bangladesh in 2019. This estimate is based on statistics of baseline deaths in 2019 but population use of solid fuels in 2022 and total distribution of ICSs as of February 2023 by the Bondhu Chula and IDCOL programs to reflect the progress made during the last years on the transition to clean cooking and ICSs. About 59 percent of the deaths from household air pollution were from IHD and stroke; 29 percent from pulmonary diseases (COPD, lung cancer, and ALRI); 5 percent from type 2 diabetes; and 7 percent from neonatal disorders (table 2.5). Table 2.5 Estimated annual deaths by cause in Bangladesh from PM2.5 household air pollution, 2019 Low Central High IHD 15,807 17,368 18,603 Stroke 21,208 23,262 24,878 COPD 10,441 11,956 13,223 Lung cancer 1,275 1,405 1,505 ALRI 5,828 6,687 7,409 Type 2 diabetes 2,858 3,135 3,354 Neonatal disorders 4,800 5,052 5,305 Total in Bangladesh 62,215 68,866 74,278 Source: World Bank. Household air pollution also caused an estimated 287–337 thousand DALYs with disease, corresponding to 1.3–1.6 billion days lived with illness. Cataract accounts for the largest share of days lived with illness (41 percent) followed by COPD (21 percent) (table 2.6).9 Table 2.6 Estimated days lived with illness from PM2.5 household air pollution, 2019 | Millions Low Central High IHD 199 218 234 Stroke 82 90 96 COPD 268 307 339 Lung cancer 0.46 0.51 0.54 ALRI 13 15 17 Type 2 diabetes 214 235 251 Neonatal disorders 0.69 0.72 0.76 Cataract 561 591 621 Total in Bangladesh 1,338 1,457 1,559 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 13 Cost of Environmental Degradation – Environmental Health Issues 2.3.3 Cost of health effects of household air pollution The annual cost of health effects of PM2.5 household air pollution is estimated at Tk 1,007–1,198 billion in 2019, with a central estimate of Tk 1,112 billion (table 2.7). The cost is equivalent to 3.4–4.1 percent of Bangladesh’s GDP that year, with a central es- timate of 3.77 percent. Mortality accounts for 79 percent and morbidity for 21 percent of estimated cost (see methodology in appendixes H and I). Table 2.7 Estimated cost of health effects of PM2.5 household air pollution in Bangladesh in 2019 | Tk, Billions Low Central High Cost of mortality 790 874 943 Cost of morbidity 217 238 255 Total cost of health effects 1,007 1,112 1,198 Percent of 2019 GDP 3.41% 3.77% 4.06% Source: World Bank. 2.4 Lead pollution Lead (Pb) exposure continues to be a major environmental health risk in Bangladesh for both children and adults, but the sources of lead exposure are far from fully understood. The population is exposed to lead originating from used lead-acid bat- tery (ULAB) recycling, abandoned ULAB recycling sites, and lead smelting (Ahmad et al. 2014); chemical fertilizers and tanneries (Majumder et al. 2021); jewelry-making industries (Mazumdar, Goswami, and Ali 2017); and electronic waste. Lead exposure also occurs through the use of or contact with articles containing lead such as cookware made of recycled aluminum (ESDO 2018; Weidenhamer et al. 2017), lead-based paint (ESDO/IPEN 2021), cosmetics, toys, as well as through ingestion of other items con- taining lead. Extremely high concentrations of lead were previously found in turmeric in Bangladesh and a study found evidence of lead additive in turmeric in seven of nine major turmeric producing districts (Forsyth et al. 2019a,b; Gleason et al. 2014). Howev- er, the government of Bangladesh implemented measures against this practice, and lead in turmeric was practically eliminated in 2021 (Forsyth et al. 2023). No location is safe from potential lead contamination. Lead pollution in water contaminates fish and other aquatic species and sources of drinking water; lead in soil contaminates agricultural crops and animal fodder; and irrigation water especially from surface water sources contaminates soil and crops. Lead in chemical fertilizers and feed used at fish farms also contributes to the contamination of soil, water, and the food supply. Numerous studies in Bangladesh have documented lead in food and fish (Majumder 2022). Most recently, Pure Earth conducted a market survey with measurements of lead concentrations in consumer goods and foods in twenty-five countries. The survey found that 44-59 percent of sampled metallic foodware (mostly aluminum), ceramic food- ware, and unclassified paints in Bangladesh contained concentrations of lead above references levels, followed by 17 percent for dry staple foods, 13 percent for toys, 9 percent for plastic foodware, and 6 percent for cosmetics (Pure Earth 2023). 2.4.1 Blood lead levels in children and adults The most common indicator of lead exposure is blood lead level (BLL) measured in units of µg of lead per dL of blood. Estimat- ing health effects of lead exposure in a population requires data on mean BLL in the population and data on the distribution of BLLs around the mean. Current mean BLL in children in Bangladesh is difficult to ascertain in the absence of up-to-date BLL measurement studies representative of the wider population of children in the country. Six studies of children’s BLLs in Dhaka are presented in figure 2.7. These studies are the ones that best reflect the general BLL of the children in the city and metropolitan area since the banning of lead in gasoline in Bangladesh in 1999. Mean BLL declined from 15 μg/dL in 2000 to 7.6 μg/dL in 2022. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 14 Cost of Environmental Degradation – Environmental Health Issues Figure 2.7 Trend in children’s mean blood lead level in Dhaka, 2000–22 | µg/dL Sources: icddr,b 2022; Kaiser et al. 2001; Linderholm et al. 2011; Raihan et al. 2018; Wasserman et al. 2011; 2018. Four additional studies shed light on children’s BLLs in rural and peri-urban Bangladesh. These studies date back to 2007 to 2013 and found mean BLLs from 2.5 to 9.1 μg/dL in the Dhaka, Rajshahi, and Rangpur Divisions (Gleason et al. 2020; Mitra et al. 2009; Mitra et al. 2012; Woo et al. 2018). Average BLL across these four studies was 5.85 μg/dL. A study by IEDCR in 2022 of 980 children under 18 years of age in four districts across Bangladesh found an average BLL of 5.63 µg/dL. Among the children under five years of age, the average BLL was 7.4 µg/dL among those living within the reach of ULAB recycling activities and 4.5 µg/dL among those living in areas without such activities (see appendix C). The studies from Dhaka and rural and peri-urban areas indicate a central estimate of nationwide mean BLL in children of 6.4 μg/ dL within a range from 5.7 to 7.0 μg/dL in 2022 (table 2.8). The range in urban and rural areas is determined by assumptions about the rate of decline in BLLs over the last decade. The “low” case is based on the linear trend of BLLs in urban areas and a moder- ate reduction in BLLs in rural areas. The “high” case is based on the assumption of minimal decline in BLLs over the last decade. Table 2.8 Estimated mean BLLs in children in Bangladesh, 2022 | μg/dL Low Central High Urban 7.0 8.0 9.1 Rural 5.0 5.4 5.9 National 5.7 6.4 7.0 Source: World Bank. Very few recent and relevant studies of BLLs were identified for adults during the preparation of this report. Two studies of preg- nant women with a mean age of 23–24 years in three rural locations indicate an average BLL of 4.9 µg/dL (Forsyth et al. 2018; Gleason et al. 2020). One study in two rural locations found average BLL of 7.7 µg/dL (Bulka et al. 2019). However, the studies are 10–15 years old. Overall, it may be expected that average BLL in adults 25+ years of age may be as high as among children under five, given that older adults have higher BLL than young children, and young adults generally have a lower BLL than young chil- dren. Therefore, the “low”, “central”, and “high” national means for children are applied to adults for the purpose of estimating the health effects of lead exposure. The BLL measurement studies of children and adults discussed above largely reflect populations living in areas with no obvious major source of lead exposure. However, there are many “hot spots” with children and adults having substantially higher BLLs. Informal recycling of ULABs, including abandoned recycling sites, are major lead-exposure “hot spots” in Bangladesh and many other low- and middle-income countries for workers and nearby residents (Ericson et al. 2016; Gottesfeld and Pokhrel 2011). The Toxic Sites Identification Program (TSIP) implemented by Pure Earth has since 2011 in partnership with the Department of BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 15 Cost of Environmental Degradation – Environmental Health Issues Geology of the University of Dhaka and the Department of Environment of Bangladesh assessed 249 contaminated sites. 175 of the sites are ULAB recycling and lead smelting sites located throughout the country (McCartor 2018). The total number of ULAB recycling and recharging facilities are, however, substantially larger, reported in the range of 1,100 (World Bank 2018) to 12,200 (Ahmad et al. 2014). The latter figure is based on a survey dating back to 2003–04 by the Bangladesh Bureau of Statistics (BBS). A study of workers at 15 ULAB recycling and recharging facilities in Dhaka City found a mean BLL of 65 μg/dL (Ahmad et al. 2014). A study at an abandoned ULAB-recycling site in Kathgora, Savar in Dhaka Division measured BLLs of children living within 200 meters of the site. The site had been in operation for six months before it was closed. Children’s median BLLs were 23 μg/dL about two years after the site was abandoned. After an exposure risk reduction intervention median BLLs dropped to 15 μg/dL. The intervention involved community education, soil remediation, and cleaning of households to remove lead-contaminated dust (Chowdhury et al. 2021; McCartor and Nash 2018). A study of jewelry makers of 32–62 years of age in Dhaka in 2015 found an average BLL as high as 69 μg/dL. BLLs among background office staff were also elevated with an average BLL of 16 μg/dL (Mazumdar, Goswami, and Ali 2017). A log-normal distribution of BLL of the population in Bangladesh (Fewtrell, Kaufmann, and Prüss-Üstün 2003) indicates that 57 percent of children under five years of age, 61 percent of adult males, and 51 percent of adult females have a BLL ≥ 5 µg/dL, and over one-third of the population has a BLL > 10 μg/dL (table 2.9). These estimates include the populations in lead exposure “hot spots”. The difference in the adult male and female BLL distributions reflects that adult males generally have substantially higher BLLs than adult females (Bulka et al. 2019). Table 2.9 Estimated population blood lead level (BLL) distribution in Bangladesh, 2022 Percent of male Percent of female Percent of children BLL (µg/dL) adults adults (< 5 years) (25+ years) (25+ years) < 2.0 20 18 25 2.01–5.0 23 21 24 5.01–10.0 20 19 19 > 10 37 42 32 Source: World Bank. Note: Mean BLL = 6.4 µg/dL and standard deviation (SD) = 4.02 for children; mean BLL = 7.5 µg/dL and SD = 4.27 for adult males; and mean BLL = 5.27 µg/dL and SD = 4.04 for adult females.10 2.4.2 Lead exposure from soil, dust, and drinking water The World Bank commissioned a study to review available evidence from research in Bangladesh on major sources of lead pol- lution; lead concentrations in soil/dust, air, drinking water, and foods; and population exposure to the pollution (Majumder 2022). The study drew on nearly one hundred research studies and articles and conducted several focus group discussions with a total of 61 participants from government departments, various institutions and universities, and the media. Twenty-two studies of lead concentrations in soil and dust in Bangladesh are summarized in Majumder et al. (2021). Average lead concentrations in agricultural soils, garden soils and roadside soils and dust were 75 mg/kg (ppm). Lead concentrations are substantially higher in many industrial and mining areas and ULAB sites but affect a relatively minor share of the population in Bangladesh. Lead in air was a major source of lead ingestion during the times of leaded gasoline. Mean lead concentrations in air were 0.36 µg/m3 in the studies reviewed by Majumder et al. (2021) that best reflect the exposure of the general population. Lead exposure also comes from drinking water. Well over 95 percent of the population in Bangladesh rely on groundwater (Sham- sudduha et al. 2019). A review of available studies reports lead concentrations in groundwater of 1 µg/L or less in most locations (Hasan, Shahriar, and Jim 2019; Parvin, Haque, and Tareq 2021). This concentration is well below WHO’s guideline value of 10 µg/L (see appendix C). Table 2.10 presents mean lead concentrations in soil, air, and drinking water to which the general population appear to be ex- posed. These concentrations are estimated to result in a BLL of 1.9 µg/dL in two-year-old children. This magnitude of effect on BLL represents about 30 percent of mean BLLs of children under five years of age in Bangladesh. Soil alone contributes an estimated 1.6 µg/dL.11 The effect on BLL is higher for younger children compared to older children. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 16 Cost of Environmental Degradation – Environmental Health Issues Table 2.10 Mean lead concentrations in soil, air, and drinking water and modeled BLLs in children General population Soil 75 mg/kg Air 0.36 µg/m3 Drinking water 1 µg/L Estimated effect on BLL 1.9 µg/dL Source: World Bank estimates using the IEUBK Model Version 2. Note: Effect on BLL is for children two years of age. 2.4.3 Lead exposure from food Heavy metal contamination of food for human consumption is receiving increased attention. Collado-López et al. (2022) re- viewed 152 studies in 43 countries worldwide. Vegetables, fish, and rice were the most studied food groups and over half of the studies were from Asia. Food may be a major source of lead exposure in Bangladesh possibly for a large share of the population. This section presents lead concentrations in rice, vegetables and fish in Bangladesh as reported by three review studies (Islam et al. 2018a; Kumar et al. 2022; Majumder et al. 2021) and several individual studies (see appendix C). These three food groups constitute nearly 80 percent of the daily quantity of food consumption in Bangladesh with rice alone accounting for nearly half of daily food weight intake. Rice: A wide range of lead concentrations have been detected in rice in Bangladesh in the studies reviewed by Kumar et al. (2022). The studies showed a mean concentration of 2.23 mg/kg of rice, largely driven by very high concentrations in a small subset of the studies. Two other studies found substantially lower lead concentrations: Jahiruddin et al. (2017) found mean con- centrations of 0.20 mg/kg in four subdistricts (upazilas) in the Dhaka and Mymensingh Divisions. Real, Azam, and Majed (2017) sampled ten rice varieties from Kawran Bazar, the largest wholesale market in Dhaka, and found lead concentrations of 0.0–0.08 mg/kg. No study of lead in rice in Bangladesh is nationally representative. The mean nationwide lead concentration is therefore highly uncertain but may be in the range of 0.1–0.2 mg/kg and possibly lower or higher. Vegetables: Vegetables are the second most important source of food in terms of daily intake weight. Several reviews and ad- ditional individual studies indicate that mean lead concentrations are in the range of 0.43–1.03 mg/kg in commonly consumed vegetables (Bushra et al. 2022; Haque et al. 2021; Islam et al. 2018a; Kumar et al. 2022; Majumder et al. 2021; Sultana et al. 2022). Two of the studies are measurements from large wholesale vegetable markets. However, two additional studies from wholesale markets show mean lead concentrations of less than 0.06 mg/kg (Real, Azam, and Majed 2017; Shaheen et al. 2016), indicating that larger samples over longer periods of time covering both the rainy and dry seasons may be required to provide more accu- rate perspectives on lead concentrations in vegetables nationally. One potential source of widespread lead in rice and vegetables may be chemical fertilizers. Mohiuddin et al. (2017) measured lead in 54 fertilizer samples from the markets of four districts of Bangladesh. Mean lead concentrations in various types of fertilizers were 100–400 mg/kg. Fish: Fish is the third most important food group in Bangladesh in terms of per capita quantity of consumption and the most important source of protein. Bangladesh ranked third in the world in inland capture fisheries and fifth in culture fisheries pro- duction in 2019 (GoB 2020) and fishery production has increased nearly six-fold from 1985 to 2019. Inland culture fisheries expe- rienced the highest growth rate at 9.2 percent per year, followed by marine fisheries at 3.8 percent per year and inland capture fisheries at 2.9 percent per year. Islam et al. (2018a) and Majumder et al. (2021) reviewed seven studies of lead concentrations in fish from six rivers. Mean concentrations ranged from 0.04 to 9.97 mg/kg. Majumder (2022) presents studies of lead in cultured fish. Mean lead concentrations were 0.64 mg/kg in the five studies with lowest concentrations and 8.9 mg/kg in the two studies with highest concentrations. Two studies of lead in fish from the Kawran Bazar fish market in Dhaka found very divergent con- centrations. Real, Azam, and Majed (2017) reported concentrations of 0.04–1.04 mg/kg while Shovon et al. (2017) reported a mean of 7.1 mg/kg in three common fish species. Studies have also found high concentrations of lead in commercial feed used at fish farms with mean concentrations ranging from 6 to 10 mg/kg. These lead concentrations in feed were highly correlated with lead concentrations in farmed fish (Kundu et al. 2017; Saha, Mottalib, and Al-Razee 2021). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 17 Cost of Environmental Degradation – Environmental Health Issues The studies with the lower mean lead concentrations in fish may best reflect nationwide population exposure to lead in fish, while the studies with the higher mean concentrations may indicate exposure levels for a relatively small share of the popula- tion. This suggests that nationwide population exposure to lead in fish could be somewhere in the range of 0.04–0.74 mg/kg for captured fish and 0.13–1.6 mg/kg for cultured fish. To calculate daily intake of lead per person from fish consumption, lead concentrations in fish reported in mg/kg dry weight must be converted to fresh weight by multiplying by a factor of 0.208 (Saha, Mottalib, and Al-Razee 2021). Predicted BLL from lead in food: The studies of lead concentrations in food in Bangladesh raise serious concerns about food safety and public health. The Integrated Exposure Uptake Biokinetic (IEUBK) Model Version 2 is applied to predict the effect on BLL of a two-year old child from ingestion of lead in food. Daily dietary intake of lead is determined by daily quantity of food ingested, lead concentrations in food ingested, and potential losses of lead from cooking. A two-year-old child is assumed to consume 300 grams of food per day, compared to about 800 grams for an adult in Bangladesh. BLL is modelled for 0.01–1.0 mg/kg of lead concentrations in food to understand how BLLs of different segments of the population may be affected by lead in food. Losses of lead from cooking is set at 33 percent according to the rate found by Islam et al. (2022) for rice in Bangladesh. Losses may stem from evaporation or from the leaching of lead from solid foods into cooking liquids that are not consumed. A lead concentration of 0.15 mg/kg in food ingested by a two-year-old child is predicted to cause a BLL of 6.6 µg/dL including 1.9 µg/dL from other sources (that is, soil and dust, air, water). This BLL is slightly above the estimated average BLL of children under five years in Bangladesh (figure 2.8). This is a plausible average concentration of lead in food for a large share of the population. In this case, lead in food may be responsible for as much 70 percent of average BLL while lead from soil/dust, air and drinking water contributes the remaining 30 percent. At a lead concentration of 0.05 mg/kg in food, BLL is predicted at 3.6 µg/dL of which 1.7 µg/dL from food and 1.9 µg/dL from soil, air and drinking water. In this case, 45 percent of the average BLL of 6.4 µg/dL in children is due to sources other than food, soil/dust, air, and drinking water, which could be lead in recycled aluminum cookware, toys, paint, and other articles. At a lead concentration of 1.0 mg/kg in food, BLL is predicted at 23 µg/dL of which 21 µg/dL is from food. Figure 2.1 Predicted BLL from Pb in food for a two-year-old child Source: World Bank based on application of the IEUBK Model Version 2. An additional effect of lead in agricultural soils is the absorption of lead in rice straw. Lead concentrations in rice straw has been found to be 5–6 times higher than in rice grain (Kibria 2012). Using rice straw, as well as other agricultural residues with lead accu- mulation, for household energy may therefore cause lead air pollution, an issue that needs investigation. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 18 Cost of Environmental Degradation – Environmental Health Issues 2.4.4 Lead exposure from cookware Aluminum cookware can also be a source of lead exposure as evidenced from multiple studies in Asia and Africa (Mathee and Street 2020). Toxic metals are often released into food during cooking especially from cookware made from recycled aluminum. Metals include lead, arsenic, mercury, cadmium, copper, and aluminum. Most of the studies are from Africa (Jitaru et al. 2019; Street et al. 2020; Weidenhamer et al. 2014; Weidenhamer, Chasant, and Gottesfeld 2022), but studies of cookware have also been undertaken in Bangladesh and several other Asian countries including India, Indonesia, Nepal, the Philippines, and Viet- nam (Weidenhamer et al. 2017). Studies show a very large range of lead released during cooking. Many cookware items were found not to release detectable levels of lead while others released lead up to 260 µg per 250 mL food serving (Weidenhamer, Chasant, and Gottesfeld 2022; Weidenhamer et al. 2014; 2017). The magnitude of lead released from cookware also seems to vary by type of food being cooked (Jitaru et al. 2019). A study evaluated the protection against lead released to food from fluoropolymer coatings of four cookware items. The reduc- tion in the release of lead ranged from 42 to 100 percent, while average reduction in aluminum was 98 percent and the release of cadmium was reduced to nondetectable levels (Weidenhamer et al. 2017). Most of the population in Bangladesh prepares food with aluminum cookware since it is inexpensive, easy to handle because of its light weight, and heats the food faster than many alternative cookware (ESDO 2018). Four recycled aluminum cookware items were tested in Bangladesh in the study reported by Weidenhamer et al. 2017. One of the four items released 2 µg of Pb per 250 mL serving while no detectable lead was released from the other three items. All four items released arsenic and aluminum, and one item released cadmium. The market survey by Pure Earth sampled 27 items of metallic cookware in Bangladesh of which 59 percent had Pb concentrations above the reference level of 100 ppm, with a median and maximum Pb concentration of 186 and 8,186 ppm, respectively (Pure Earth 2023). The items have not been tested for leaching of Pb into food while cooking. The IEUBK Model Version 2 is applied to predict the effect on BLL of a two-year-old child from ingestion of lead in food leached from aluminum cookware. If 2 µg of Pb per 250 mL serving is regularly released from aluminum cookware, as found for one of the four aluminum cookware items in Bangladesh, the effect on the child’s BLL is predicted to be an increase of 0.4 µg/dL.12 This is 6 percent of the estimated average BLL in children under five years of age in Bangladesh. However, some aluminum cookware items may release far more lead, as found in several countries in Africa and Asia. The predicted increase in BLL is as high as 13.8 µg/dL if 100 µg of Pb per 250 mL serving is released (figure 2.9). Most of the cookware is made locally in Bangladesh, but little information is available on the fraction of aluminum cookware made from recycled metal. More studies of the sources of aluminum used for cookware production and the magnitude of leach- ing of lead and other toxic metals during cooking are much needed in Bangladesh. Figure 2.8 Predicted increase in BLL from Pb in aluminum cookware for a two-year-old child Source: World Bank based on application of the IEUBK Model Version 2. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 19 Cost of Environmental Degradation – Environmental Health Issues 2.4.5 Health effects of lead exposure on children Effects of lead exposure in children include cognitive impairment, increased risk of attention deficit or hyperactivity disorder, and increased risk of antisocial and criminal behaviors (Landrigan et al. 2018). One such well-established and quantifiable effect of lead exposure in children is neuropsychological impairment measured as IQ loss.13 A seminal study by Lanphear et al. (2005), based on a pooling of seven international longitudinal cohort studies, specified a log-linear function that best describes the re- lationship between children’s BLL and their IQ. A subsequent study, also using the same pooled data, took the analysis further (Crump et al. 2013) and is used here to estimate annual losses of IQ points among children under five years of age in Bangladesh (figure 2.10).14 Since no safe BLL has been established, a theoretical minimum-risk exposure level (TMREL) of 0 μg/dL is applied here to estimate IQ losses (see appendix D). Figure 2.11 Loss of IQ points from lead exposure in early childhood Source: World Bank, produced from the log-linear function reported in Crump et al. (2013). Total annual losses of IQ points among children under five years of age are estimated at 18.9–20.4 million with a central estimate of 19.7 million based on the average BLLs in children in the range of 5.7–7.0 µg/dL discussed in this section (table 2.11).15 The cen- tral estimate corresponds to an average of nearly 7 IQ points per child over the child’s early years of life. About 58 percent of the annual losses are among children with a BLL greater than 10 µg/dL while less than 7 percent of annual losses are among children with a BLL less than 2 μg/dL.16 Table 2.11 Estimated annual losses of IQ points among children < 5 years in Bangladesh, 2019 | IQ points, millions BLL (µg/dL) Lower Central Upper <2 1.44 1.31 1.20 2.0–5.0 3.23 3.10 3.01 5.01–10.0 3.82 3.84 3.86 > 10 10.41 11.49 12.31 Total in Bangladesh 18.90 19.74 20.39 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 20 Cost of Environmental Degradation – Environmental Health Issues 2.4.6 Health effects of lead exposure in adults The GBD 2019 estimated that there were 30,800 deaths from lead exposure in Bangladesh in 2019, of which 29,900 were car- diovascular disease (CVD) deaths and 900 were chronic kidney disease (CKD) deaths (GBD 2019 Risk Factors Collaborators 2020). The methodology used by the GBD 2019 may, however, only capture a portion of CVD deaths from lead exposure because the GBD estimated CVD mortality only through the effect of lead on blood pressure, and of blood pressure on CVD mortality. Lead exposure has, however, cardiovascular effects beyond effects mediated through blood pressure (Lamas et al. 2023; Larsen and Sánchez-Triana 2023; Shaffer et al. 2019). An alternative approach to estimating global CVD mortality from lead exposure is there- fore to rely on research that directly estimates CVD mortality rather than through blood pressure as suggested by Shaffer et al. Brown et al. (2020) developed a health-impact model that used the concentration-response relationship between BLLs and CVD mortality risk from four studies, thus directly estimating CVD mortality (Aoki et al. 2016; Lanphear et al. 2018; Menke et al. 2006; Ruiz-Hernandez et al. 2017). All four studies analyzed BLLs of the adult population in the United States from one or more of the nationally representative National Health and Nutrition Examination Surveys (NHANES) from 1988 to 2010 (CDC 2023). The studies found a wide range in relative risk (RR) of CVD mortality. At the estimated average BLL of 6.4 μg/dL in Bangladesh the increased risk of CVD mortality is 24–91 percent higher than in absence of lead exposure (figure 2.11). This implies an estimated 61,800 CVD deaths from lead exposure in 2019 based on Aoki et al. and as high as 160,000 deaths based on Menke et al. This is more than 2–5 times higher than the GBD 2019 estimate. Using the midpoint of Lanphear et al. and Ruiz-Hernandez et al., as in Larsen and Sanchez-Triana (2023), estimated CVD deaths from lead exposure were 97,100 deaths in 2019. Figure 2.21 Relative risk of CVD mortality from BLL of 1–20 | μg/dL Source: World Bank, derived from Brown et al. (2020) and the four studies noted in the figure. See appendix E. To conservatively estimate the cost of lead exposure in adults, the estimate of CVD mortality based on Aoki et al. is used as the base case. This implies that CVD deaths were about 59–64 thousand in 2019 with a central estimate of 61,800 based on average adult BLLs in the range of 5.7–7.0 µg/dL. Lead exposure also caused an estimated 403–431 million days lived with cardiovascular illness (table 2.12).17 The estimated CVD deaths from adult lead exposure is based on a TMREL BLL of 0 μg/dL. Applying instead a TMREL of 1 μg/dL, as suggested by the relative risk functions in figure 2.11, reduces estimated annual CVD deaths only marginally from 61,800 to 61,000. Table 2.12 Estimated annual deaths and illness from lead exposure among adults in Bangladesh, 2019 Low Central High Cardiovascular disease deaths 59,452 61,800 63,565 Days lived with cardiovascular illness (millions) 403 419 431 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 21 Cost of Environmental Degradation – Environmental Health Issues 2.4.7 Cost of health effects of lead exposure Cost of IQ losses The cost of IQ losses is estimated by the effect of IQ on lifetime income. The relationship between IQ and lifetime income has long been established (Grosse and Zhou 2021; Johnson and Neal 1998; Lin, Lutter, and Ruhm 2018; Lundborg, Nystedt, and Rooth 2014; Salkever 1995; 2014a,b; Schwartz 1994; USEPA 2020; Zax and Rees 2002). Multiple studies have used this relationship for estimating the cost of IQ losses from lead exposure in France, the United States, and in low- and middle-income countries (Attina and Trasande 2013; Gould 2009; Grosse et al. 2002; Muennig 2009; Pichery et al. 2011). The present value of future lifetime income of a child under five years is estimated at Tk 4.2 million. This is based on an estimated average annual labor income in Bangladesh in 2019 of Tk 219,682.18 The cost of a lost IQ point is estimated at Tk 52.1 thousand, based on the estimate of 2.0 percent lifetime income loss per IQ point (see appendix G). This is estimated as the loss of income per lost IQ point multiplied by the percentage of children that may be expected to participate in the labor force. Expected labor force participation is assumed to be the same as the current rate of participation. With an estimated annual loss of 18.9–20.4 million IQ points among children under five in Bangladesh, the estimated annual cost is Tk 985–1,063 billion in 2019, with a cen- tral estimate of Tk 1,029 billion. This is equivalent to 3.3–3.6 percent of Bangladesh’s GDP that year, with a central estimate of 3.5 percent of GDP (table 2.13). Table 2.13 Estimated annual cost of IQ losses among children under five years of age in Bangladesh, 2019   Low Central High Present value of future lifetime income (18–65 years) (Tk) 4,202,088 4,202,088 4,202,088 Lifetime income loss per IQ point lost (percent of lifetime income) 2.0% 2.0% 2.0% Labor force participation rate (18–65 years) 62% 62% 62% Cost per lost IQ point (Tk) 52,106 52,106 52,106 IQ points lost per year (millions) 18.90 19.74 20.39 Total cost (Tk, billions) 985 1,029 1,063 Percent of 2019 GDP 3.34 3.49 3.60 Source: World Bank. Cost of adult health effects Among adults, an estimated 59–64 thousand individuals died prematurely, and 403–431 million days of illness occurred from nonfatal cardiovascular disease due to lead exposure in 2019. The annual cost of these health effects is estimated at Tk 800–855 billion, with a central estimate of Tk 832 billion (table 2.14). Table 2.14 Estimated annual cost of health effects of adult lead exposure in Bangladesh, 2019 | Tk, billions Low Central High Cost of mortality 755 784 807 Cost of morbidity 45 47 48 Total cost of health effects 800 832 855 Percent of 2019 GDP 2.71 2.82 2.90 Source: World Bank. The cost is equivalent to 2.7–2.9 percent of Bangladesh’s GDP in 2019, with a central estimate of 2.8 percent. Mortality accounts for 95 percent and morbidity for 5 percent of estimated cost (see appendixes H and I). The total estimated cost of lead exposure— that is, the effects of lead on children and adults—is Tk 1,785–1,918 billion in 2019 with a central estimate of Tk 1,860 billion. This is equivalent to 6.0–6.5 percent of GDP that year, with central estimate of 6.3 percent of GDP. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 22 Cost of Environmental Degradation – Environmental Health Issues 2.5 Household drinking water, sanitation, and hygiene Water resources are of immense importance to Bangladesh, not only for municipal and household water supply, but also for fisheries, irrigation and agriculture, and industry. However, heavy metals and chemical pollution is affecting these resources as well as agricultural soils and crop production. Uddin and Jeong (2021) found high levels of heavy metal pollution in multiple rivers. Islam et al. (2018c) identified cadmium, arsenic, chromium, copper, lead, and nickel as priority pollutants for control, with high concentrations of many of these pollutants in irrigation water and agricultural soils exceeding FAO guidelines. Islam et al. (2018a) undertook a review of the literature on arsenic, lead, cadmium, and chromium pollution of waters, soils, and foods in Bangladesh and concluded that contamination from geological, industrial waste, and urban sources is a major issue that needs further assessment. Industrial and agrochemical pollution are two major sources of water pollution. This includes heavy metals and chemical pollu- tion of water resources that poses a health threat through the food supply. The pollution impacts both captured and cultured fish. It also impacts agricultural crops through irrigation on top of other sources of agricultural soil pollution. This is assessed in section 2.4 for lead pollution based on published data and research while comprehensive health risk assessments are yet to be undertaken for other heavy metals and chemicals. Heavy metals and chemical pollution may also affect drinking water supplies. Drinking water to date does not seem to suffer from lead pollution (section 2.4.2). Arsenic contamination is discussed below in section 2.5.2. Salinity intrusion is also an environmental health concern especially in coastal districts where it is affecting the qual- ity of drinking water supply, agriculture productivity, and public health. Rising water stress and declining groundwater levels in some of the dense settlements in Bangladesh combined with these pol- lution issues can lead to substantial negative impacts on access to safe and clean drinking water, crop production, and broader public health outcomes. These challenges are compounded by climate change impacts in terms of availability of safe water, floods, and saline intrusion. Inadequate fecal sludge management is another issue that affects water quality and public health. Many of these water-resources issues are discussed in Joseph and Shrestha (2021) while this report focuses exclusively on house- hold drinking water, sanitation, and hygiene. The health effects of inadequate WASH assessed in this report arise from two prin- cipal sources: (a) fecal contamination or microbiological pollution in relation to drinking water, sanitation, and hygiene; and (b) exposure to arsenic in groundwater tubewells used for drinking. 2.5.1 Microbiological pollution The health safety of drinking water is influenced not only by the type of water supply but also by drinking-water accessibility, availability when needed, quality of water at source, household collection, storage, and point-of-use treatment practices before drinking. Therefore, WHO/UNICEF reports an indicator called “safely managed drinking-water services” defined as an improved drinking-water source that is free from microbiological (E. coli) and priority chemical contamination (arsenic and fluoride), is lo- cated on premises, and is available when needed (UNICEF/WHO 2019). An estimated 99 percent of the population in Bangladesh used an improved water source for drinking in 2019 according to the nationally representative Bangladesh Multiple Indicator Cluster Survey (MICS) 2019 (BBS/UNICEF 2019). Not all of these water sources meet the WHO/UNICEF criteria for safely managed drinking water. Over 82 percent of the population of Bangladesh had their drinking-water source on premises in 2019. However, nearly 17 percent of households spent from 30 to 60 minutes per day collecting water, and over 6 percent of households spent more than one hour per day collecting water according to the MICS survey. The MICS survey also included testing for E. coli bacteria—an indicator of fecal contamination—in the source water and in actual drinking water of over 6,000 households throughout Bangladesh. 40 percent of the household population had E. coli in their source water and as many as 82 percent had E. coli in their actual drinking water, suggesting a high incidence of contamination from the point of drinking-water collection to drinking-water storage. The presence of E. coli in source water was substantially higher among households with piped water supply than among households with tubewell/borehole (figure 2.12, left). In the actual drinking water at point of household storage, the presence of E. coli in water from piped sources and tubewell/boreholes was very similar (figure 2.12, right). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 23 Cost of Environmental Degradation – Environmental Health Issues Figure 2.12 Population with E. coli in source water (left) and actual drinking water (right), 2019 Source: World Bank, produced from BBS/UNICEF (2019). Note: Number of E. coli per 100 ml of water. Only 48 percent of the population in Bangladesh had safely managed drinking water in 2019, ranging from 41 percent among households with piped water supply to 50 percent among households with tubewell/borehole (figure 2.13). Safely managed water is based on source water of which 60 percent is free from E. coli. However, as discussed, only 18 percent of actual drinking water was free from E. coli. The difference between the percentage of population with source water free from E. coli and actual drinking water free from E. coli points to the importance of safe handling and storage of drinking water, as well as the need to improve quality of piped water supply. It also highlights the role of household point-of-use treatment of drinking water in ensur- ing drinking water that is free from microbiological pollution. Figure 2.13 Population with safely managed drinking water, 2019 Source: World Bank, produced from BBS/UNICEF (2019). Note: HHs = households. Only about 10 percent of the household population in Bangladesh reported that they treated their water prior to drinking in 2019 by an appropriate method.19 The main method of treatment was boiling (5 percent) and filtering of water (6 percent). The prevalence of drinking-water treatment is particularly low in rural areas. By household living standard, the drinking-water treat- ment rate is 37 percent among the richest quintile of households versus 1 percent among the two poorest quintiles (figure 2.14). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 24 Cost of Environmental Degradation – Environmental Health Issues Figure 2.14 Household treatment of drinking water, 2019 | Percent of population Source: World Bank, produced from BBS/UNICEF (2019). Note: HHs = households. 2.5.1.2 Access to safe household sanitation Nearly 85 percent of the population in Bangladesh had access to improved sanitation facilities in 2019, but 20 percent of the population shared sanitation facilities with other households. Therefore, only 65 percent had basic improved non-shared sani- tation. The most common type of improved sanitation facility was flush or pour-flush toilet connected to a sewer system, septic tank, or pit. The second most common improved facility was dry pit latrine with slab (figure 2.15). Access to improved sanitation facilities varied from 67 percent among the poorest quintile of households to 97 percent among the richest quintile. A little over 15 percent had unimproved sanitation including 1.5 percent practicing open defecation. Far from all households with improved non-shared sanitation had safely managed sanitation. Safely managed sanitation means that excreta are safely treated in situ or transported and treated off-site. According to WHO/UNICEF, there are three practical options for safe management: excreta are removed through sewer lines and treated off-site at wastewater treatment plants; excreta are emptied from septic tanks and pits and treated offsite at facilities designed for fecal sludge; or excreta are treated and disposed of in situ in septic tanks with appropriate leach fields or in latrine pits that are covered and left undisturbed when full (UNICEF/WHO 2019). Figure 2.15 Access to improved sanitation in Bangladesh, 2019 | Percent of population Source: World Bank, produced from BBS/UNICEF (2019). The Bangladesh MICS 2019 also reports on households’ access to handwashing facilities: 75 percent of the population had access to a place of handwashing with soap and water present on household premises while 25 percent did not have a place with such items. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 25 Cost of Environmental Degradation – Environmental Health Issues 2.5.1.2 Health effects of microbiological pollution An estimated 72–95 percent of diarrheal disease morbidity and mortality is due to inadequate drinking water, sanitation, and hand hygiene in Bangladesh (table 2.15). The range reflects uncertainties about the magnitude of risk of disease from various types of drinking water (see appendix F). Individually, inadequate drinking water is associated with the largest attributable frac- tion of diarrheal disease. Table 2.15 Attributable fractions of diarrheal disease from inadequate WASH in Bangladesh, 2019 Low (percent) High (percent) Inadequate drinking water 54.1 88.0 Inadequate sanitation 31.2 53.3 Inadequate handwashing with soap 11.6 11.6 Inadequate drinking water, sanitation, and hand hygiene 72.1 95.0 Source: World Bank. Note: The joint attributable fraction of WASH is less than the sum of the individual attributable fractions. Annual deaths from inadequate WASH are estimated at 34–44 thousand in 2019, with a central estimate of 39 thousand (table 2.16). The main source of death is diarrheal disease including typhoid and paratyphoid. Deaths from ALRI due to inadequate handwashing and infectious disease mortality from underweight caused by repeated diarrheal infections in early childhood are about the same. Table 2.16 Annual deaths from inadequate WASH in Bangladesh, 2019 Low Central High Diarrheal disease 23,741 27,518 31,295 Typhoid/paratyphoid 5,672 6,574 7,476 ALRI from inadequate handwashing 2,792 2,792 2,792 Infectious diseases from underweight 2,401 2,783 3,165 Total a 34,079 39,057 44,034 Source: World Bank. Note: a Adjusted for multiple risk factors. Inadequate drinking water, sanitation, and hygiene also caused an estimated 0.8–1.1 billion days lived with illness in 2019. Diarrhe- al disease accounts for 98 percent of the days (table 2.17). Table 2.17 Estimated days lived with illness from WASH in Bangladesh, 2019 | Millions of days Low Central High Diarrheal diseases 789 915 1,040 Typhoid/paratyphoid 7.6 8.8 10.0 ALRI 6.5 6.5 6.5 Total days of disease from WASH 803 930 1,057 Source: World Bank. 2.5.1.3 Cost of microbiological pollution Microbiological pollution associated with inadequate drinking water, sanitation, and hygiene is estimated to cost in the range of Tk 619–805 billion in 2019, with a central estimate of Tk 712 billion (see appendixes H and I). This is equivalent to 2.0–2.7 percent of GDP in 2019, with a central estimate of 2.4 percent (table 2.18). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 26 Cost of Environmental Degradation – Environmental Health Issues Table 2.18 Cost of health effects of inadequate WASH, 2019 | Tk, billions Low Central High Cost of mortality 433 496 559 Cost of morbidity 187 216 246 Total cost 619 712 805 Percent equivalent of 2019 GDP 2.10 2.41 2.73 Source: World Bank estimates. 2.5.2 Arsenic exposure Arsenic in drinking water from tubewells continues to be a health concern in Bangladesh. The MICS 2019 survey included mea- surements of arsenic concentrations in drinking water in over 12,000 households. The survey found that 17 percent of households had arsenic concentrations in drinking water exceeding the WHO guideline of 10 parts per billion (ppb) (μg/L) and 11 percent of households had concentrations exceeding the Bangladeshi standard of 50 ppb. While the percentage of households with elevated arsenic concentrations in drinking water has declined somewhat since the measurements from MICS 2009 and MICS 2012–13 (BBS/UNICEF 2010; 2014), the arsenic prevalence still poses a significant health risk in several divisions, particularly in Chat- togram and Sylhet. 2.5.2.1 Health effects of arsenic exposure Exposure to arsenic in drinking water has been found to be associated with various health effects including skin lesions (Argos et al. 2011; Karagas et al. 2015); cancer, kidney and liver failure, and ulcer (FAO et al. 2010); and neurological impairments such as poor cognitive performance, reduced intellectual function, learning deficits, mood disorders, visual, speech, attention, and memory disturbances (Brinkel et al. 2009; Tyler and Allan 2014). Increased risks of lung and bladder cancer and arsenic-associated skin lesions have been found from ingestion of drinking water with arsenic concentrations below 50 µg/liter (WHO 2011). Several studies have also documented the effect of arsenic in drinking water on mortality: all-cause and chronic disease mortality (Argos et al. 2010); nonaccidental all-cause mortality, cancers, cardiovascular-disease mortality, and infectious-disease mortality (Sohel et al. 2009); heart-disease mortality (Chen et al. 2011); lung-disease mortality (Argos et al. 2014); mortality in children (Rahman et al. 2013); and stroke mortality (Rahman et al. 2014). Elevated risks of all-cause mortality in relation to arsenic concentrations in drinking water are presented in table 2.19. Table 2.19 Risk of mortality from arsenic in drinking water Arsenic (µg/liter) Hazard ratio (95% CI) Nonaccidental All-cause all-cause mortality mortality in population 15+ years a in population 18+ years b ≤ 10 1.00 1.00 10–50 1.16 (1.06–1.26) 1.34 (0.99–1.82) 50–150 1.26 (1.18–1.36) 1.09 (0.81–1.47) > 150 1.36 (1.27–1.47) 1.68 (1.26–2.23) Sources: Sohel et al. 2009; Argos et al. 2010. a b Note: CI = Confidence Interval. Based on the arsenic measurements from MICS 2019 and the mortality risks presented above, arsenic in drinking water in Bangladesh is estimated to have caused 30,629–50,051 deaths with a central estimate of 40,340 deaths in 2019.20 Nearly two- thirds of the deaths are among the 7 percent of the population with arsenic concentrations exceeding 150 ppb (or μg/L), and one-quarter are among the 6 percent of the population with arsenic concentrations between the WHO guideline (10 ppb) and Bangladeshi standard (50 ppb) (table 2.20). Arsenic in drinking water also caused 1.2–2.4 billion days of illness per year.21 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 27 Cost of Environmental Degradation – Environmental Health Issues Table 2.20 Estimated annual deaths from arsenic in drinking water, 2019 Arsenic Population exposure distribution Estimated deaths from arsenic in household drinking water (μg/liter) (percent) Low Central High ≤ 10 83.2 0 0 0 10–50 6.1 6,691 10,528 14,366 50–150 3.6 6,416 4,330 2,244 > 150 7.1 17,522 25,481 33,441 Total 100.0 30,629 40,340 50,051 Source: World Bank. 2.5.2.2 Cost of arsenic in drinking water The health effects had a cost of Tk 520–917 billion with a central estimate of Tk 712 billion (see appendixes H and I). This was equivalent to 1.8–3.0 percent of GDP in 2019, with a central estimate of 2.4 percent. Cost of mortality and morbidity constituted 72 percent and 28 percent of total cost respectively (table 2.21). Table 2.21 Cost of health effects of arsenic in drinking water in Bangladesh, 2019 | Tk, billions Low Central High Cost of mortality 389 512 635 Cost of morbidity 131 200 282 Total cost 520 712 917 Percent equivalent of 2019 GDP 1.76 2.41 3.11 Source: World Bank. 2.6 Health effects in children Environmental pollution affects children and adults differently. Many health effects are the result of long-term exposure to pollu- tion over many years that are first experienced in adulthood. This includes cardiovascular disease, lung cancer, COPD, and type 2 diabetes from PM2.5 air pollution, cardiovascular disease from lead exposure, and chronic health effects and mortality from arse- nic. The health effects of pollution experienced by children estimated in this report are acute illnesses including lower respiratory infections from PM2.5 air pollution, diarrheal infections from inadequate drinking water, sanitation, and hygiene, and cognitive impairment from lead exposure. Using the same data and methodologies as in the previous sections, it is estimated that environmental pollution caused nearly 20,000 deaths, 345 million days of illness, and the loss of nearly 20 million IQ points among children in Bangladesh in 2019 (table 2.22). Ambient air pollution, household air pollution, and inadequate drinking water, sanitation, and hygiene each caused about one-third of the deaths, while 95 percent of days of illness were caused by inadequate drinking water, sanitation and hygiene. As many as 85 percent of the deaths were among children 0–4 years of age and 80 percent of the days of illness were among children 5–17 years of age. Estimation of IQ loss from lead exposure was restricted to children 0–4 years of age but may to some extent also affect older children. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 28 Cost of Environmental Degradation – Environmental Health Issues Table 2.22 Annual deaths and illness in children from environmental risk factors in Bangladesh, 2019 Deaths, 2019 Days of illness, 2019 (millions) Children Children Children Children Children Children 0–4 years 5–17 years 0–17 years 0–4 years 5–17 years 0–17 years Ambient air pollution 6,543 453 6,996 3.3 3.2 6.6 Household air pollution 6,063 378 6,441 3.4 3.0 6.4 Lead (Pb) exposure – lost IQ points a 19.7 0 19.7 Drinking water, sanitation, and hygiene 3,973 2,173 6,146 64 268 332 Total 16,579 3,004 19,583 91 275 365 Source: World Bank. Note: a IQ points lost, millions. The estimated cost of the health effects in children from environmental pollution was Tk. 1,356 billion in 2019, equivalent to 4.6 percent of Bangladesh’s GDP that year. This is 26 percent of the total cost in all age groups. As much as 76 percent of the cost of health effects in children is from the loss of IQ points from lead exposure, and as much as 92 percent of the cost was among children 0–4 years of age, demonstrating the vulnerability of the youngest children to pollution (table 2.23). The estimated health effects in children are conservative. Due to data constraints the estimates do not include health effects of pre-natal and early childhood exposure to arsenic. Neither do they include health effects of air pollution other than lower respi- ratory infections and neonatal disorders from PM2.5. Studies have, however, found evidence of adverse birth outcomes such as preterm birth and low birthweight and impaired neurodevelopment, IQ loss, and stunting in early childhood from prenatal and childhood exposure to various air pollutants. These health effects impair educational outcomes and lifetime earnings and could be substantial in view of ambient air pollution levels and the high prevalence of household solid fuel use in Bangladesh. Neither do the estimates include health effects in children from exposure to chemicals other than lead. Health effects in children from other chemicals include neurotoxic effects of mercury and endocrine disrupting chemicals such as polybrominated diphe- nyl ether and organophosphates as well as adverse birth outcomes from prenatal exposure to cadmium. Long term exposure to cadmium and several endocrine disruptive chemicals have also been found to have cardiovascular disease effects in adults. Table 2.23 Estimated annual cost of environmental health effects in children in Bangladesh, 2019 Cost (Tk, billions), 2019 Cost (% of GDP), 2019 Children Children Children Children Children Children 0–4 years 5–17 years 0–17 years 0–4 years 5–17 years 0–17 years Ambient air pollution 83 6 90 0.28 0.02 0.30 Household air pollution 77 5 83 0.26 0.02 0.28 Lead (Pb) exposure – lost IQ points 1,029 0 1,029 3.49 0.00 3.49 Drinking water, sanitation, and hygiene 65 90 155 0.22 0.30 0.53 Total 1,255 101 1,356 4.25 0.34 4.59 Source: World Bank. 2.7 Conclusions and recommendations Over 270,000 people are estimated to have died in Bangladesh in 2019 from the environmental health risks assessed in this report.22 This was over 32 percent of all deaths in the country.23 Fifty-three percent of the deaths were from ambient and house- hold PM2.5 air pollution. Adult lead (Pb) exposure and inadequate drinking water, sanitation, and hygiene caused 21 percent and 26 percent of total deaths, respectively. The environmental health risks also caused 5.2 billion days lived with illness in 2019, and, additionally, impaired intelligence among children amounted to a loss of 20 million IQ points (table 2.24). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 29 Cost of Environmental Degradation – Environmental Health Issues Table 2.24 Annual deaths and days of illness from environmental risk factors in Bangladesh, 2019 Deaths Days of illness (millions) Low Central High Low Central High Ambient air pollution 87,079 90,620 95,099 1,110 1,153 1,208 Household air pollution 62,215 68,866 74,278 1,338 1,457 1,559 Lead (Pb) exposure 59,452 61,800 63,565 403 419 431 Lead (Pb) exposure – children 18.9 19.7 20.4 (lost IQ points) a Lead (Pb) exposure – adults 59,452 61,800 63,565 403 419 431 Drinking water, sanitation, and hygiene 64,708 79,397 94,085 1,934 2,656 3,492 Microbiological pollution 34,079 39,057 44,034 803 930 1,057 Arsenic in drinking water 30,629 40,340 50,051 1,131 1,726 2,436 Total 273,454 300,682 327,027 4,785 5,685 6,690 Adjusted total b 249,713 272,422 294,156 4,370 5,151 6,018 Source: World Bank. Note: a IQ points lost, millions. b Adjusted for multiple risk factors using method in appendix J. Annual deaths from environmental risk factors are higher than the total number of deaths caused by natural disasters between 1971 and 2021 (box 2.1). For comparison purposes, road traffic accidents in Bangladesh caused at least 5,227 deaths in 2019 (Kundu, Banna, and Sayeed 2020). Box 2.1 Cost of natural resources degradation and natural disasters The World Bank estimated the costs of natural resources degradation and natural disasters, which have a significant impact on human health and impose substantial costs on the economy of Bangladesh. Because of data constraints, the analysis focused on the costs of forest loss, agricultural soil nutrient depletion, and natural disasters. The analysis of these three fac- tors found an estimated annual cost from Tk. 702–1.510 billion in 2019, equivalent to 2.7–5.9 percent of GDP that year, with a midpoint estimate of Tk. 1.106 billion or 4.4 percent of GDP (table B2.1). Table B2.1 Cost of natural resource degradation and natural disasters, 2019 Annual cost (Tk, billions) Annual cost (% of GDP) Low Midpoint High Low Midpoint High Agricultural land nutrient depletion 310 345 379 1.2 1.4 1.5 Forest losses and degradation 9.3 9.3 9.3 0.0038 0.0327 0.0364 Natural disasters 383 752 1,122 1.5 3.0 4.4 Total cost 702 1,106 1,510 2.7 4.4 5.9 The analysis of impacts of natural resource degradation and natural disasters on the economy and human health found the following: • Agricultural soil depletion is mainly caused by using crop residue as household fuel and the limited transition to modern and clean cooking fuels and technologies. Potassium is the most sever nutrient deficiency, responsible for an estimated loss of 10-13 million tonnes per year or 27-36 percent of current rice grain production. • Forest loss and degradation also pose a significant threat to Bangladesh’s economy and population —for example, through the spread of zoonotic diseases, increased vulnerability to climate change and loss of natural assets that are essential to livehihoods. With only a little over 14 percent forest cover, a high population density and a high share of land allocated to agricultural crop cultivation, forests play a critical role in protecting against cyclones, landslides, and erosion BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 30 Cost of Environmental Degradation – Environmental Health Issues allocated to agricultural crop cultivation, forests play a critical role in protecting against cyclones, landslides, and erosion in the Hill forest area and providing resources such as fuelwood, bamboo, and timber. • Between 1971 and 2021, natural disasters caused a total of 220,181 deaths in Bangladesh (including from floods, cyclones, and other storms, extreme temperature, landslides, earthquakes, and droughts) (World Bank estimates based on EM- DAT 2022). Even mild and moderate droughts can have a significant cost when they affect large areas of the country. The 2021 Global Climate Risk Index ranked Bangladesh as the world’s seventh-most-affected country in 2000–19 (German- watch 2021). In addition, Bangladesh ranks second highest in the natural hazard risk index, which also covers hazards not related to climate (EC DRMKC). To estimate the cost of natural disasters, the Bank reviewed the estimates from four sourc- es for flood and cyclone, drought, and “other” natural disasters: ADB (2016), BBS (2022c), EM-DAT (2022), and ESCAP (2021). However, there was a significant discrepancy between the cost estimates for droughts and “other” between the two avail- able sources (BBS 2022c; ESCAP 2021), and extensive risks and indirect loss were only estimated by ESCAP 2021. Thus, the Bank limited its estimates to the expected average annual costs of flood and cyclone, without including extensive risks and indirect costs. This gives expected average annual cost in the range of Tk. 211–272 billion with a midpoint estimate of Tk. 241 billion. The cost is equivalent to 0.8–1 percent of GDP in 2019, with a midpoint estimate of 0.9 percent. The 2022 Bangladesh Country Climate and Development Report (CCDR) provides additional data on exposure and vulnerability to natural hazards in Bangladesh, which “pose grave risk to communities and their assets, causing disproportional damage and disrupting lives and livelihoods” (World Bank 2022). The World Bank did not conduct a cost-benefit analysis of potential interventions to address those issues because of limited quantitative data. However, the CCDR has identified key interventions to address natural disasters in Bangladesh, which are closely associated with climate change adaptation. Additionally, the World Bank is preparing a policy note on agricultural soil depletion. Source: World Bank The health effects from the environmental risk factors can be monetized by using standard valuation techniques to provide an economic and welfare perspective on the magnitude of these effects. The annual cost of the environmental health effects is estimated in the range of Tk 4.8–5.6 trillion in 2019, with a central estimate of Tk 5.2 trillion. This cost is equivalent to 16.2–19.0 percent of Bangladesh’s GDP in 2019, with a central estimate of 17.6 percent (table 2.25). About 42 percent of the cost is from ambient and household PM2.5 air pollution; 33 percent from lead exposure; and 25 percent from inadequate drinking water, sanitation, and hygiene. Over half of the cost of lead exposure is from loss of IQ points among children. Half of the cost of inadequate drinking water, sanitation, and hygiene is from arsenic in drinking water. A comparison of these estimates of health effects and costs to the estimates in the 2018 Country Environmental Analysis is provided in box 2.2. Box 2.2 Consistency with the 2018 CEA The 2018 Country Environmental Analysis (CEA) reported over 80,000 deaths from environmental risk factors in urban Ban- gladesh at a welfare cost equivalent to 3.7 percent of GDP including cost of morbidity (World Bank 2018). The estimate im- plies a death rate of 146 per 100,000 population in urban areas. The death rate from environmental risk factors estimated in this report for all of Bangladesh is 167 per 100,000 population. The urban death rate from the CEA 2018 are lower than the national estimate due to several factors: (a) the death rate from household air pollution is lower than the national estimate due to lower rates of solid-fuel use for cooking in urban than in rural areas; (b) the death rate from microbiological pollution in WASH is lower than the national estimate due to a lower fatality rate from diarrheal disease in urban than in rural areas; and (c) the CEA 2018 does not estimate urban mortality from lead exposure. Three main factors explain the difference in the welfare cost of pollution—3.7 percent of GDP versus 17.6 percent of GDP for the national estimate. The factors are (a) the national population is 2.7 times the urban population and explains nearly 60 percent of the difference in cost; (b) the cost of IQ losses in children from lead exposure at 3.5 percent of GDP at the national level is not included in the 2018 CEA other than as a minor cost of 0.03 percent of GDP associated with urban used lead-acid battery (ULAB) sites; and (c) the national cost estimate accounts for higher morbidity cost of pollution than the 2018 CEA accounts for. Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 31 Cost of Environmental Degradation – Environmental Health Issues Table 2.25 Estimated annual cost of environmental health effects in Bangladesh, 2019 Cost (Tk, billions), 2019 Cost (percent of GDP), 2019 Low Central High Low Central High Ambient air pollution 1,291 1,343 1,409 4.38 4.55 4.77 Household air pollution 1,007 1,112 1,198 3.41 3.77 4.06 Lead (Pb) exposure 1,785 1,860 1,918 6.05 6.30 6.50 Lead (Pb) exposure - children (lost IQ points) 985 1,029 1,063 3.34 3.49 3.60 Lead (Pb) exposure – adults 800 832 855 2.71 2.82 2.90 Drinking water, sanitation, and hygiene 1,139 1,424 1,722 3.86 4.82 5.83 Microbiological pollution 619 712 805 2.10 2.41 2.73 Arsenic in drinking water 520 712 917 1.76 2.41 3.11 Total 5,221 5,739 6,247 17.7 19.4 21.2 Adjusted total a 4,768 5,199 5,619 16.2 17.6 19.0 Source: World Bank. Note: a Adjusted for multiple risk factors using the method in appendix J. Nationwide population-weighted ambient PM2.5 in Bangladesh is among the highest in the world and as many as 74 percent of the population used solid fuels as their primary cooking fuel in 2019, causing enormous health effects among the population. Despite substantial declines in lead exposure over the last two decades, BLLs in children and adults remain at very high levels, and 17 percent of the population rely on drinking water with arsenic concentrations above the WHO guideline of 10 ppb. In sum, environmental health risk exposure levels in Bangladesh are at critically high levels, and aggregate health effects and their costs are substantial. Controlling and preventing outdoor ambient PM2.5 pollution should be a priority. The focus should be on reducing PM2.5 concentrations from current levels of about 64 μg/m3 to WHO’s Interim Targets I–IV of 35 to 10 μg/m3 and eventually to WHO’s annual AQG of 5 μg/m3. Control of household air pollution is also a high priority. With three-quarters of the population using solid fuels for cooking, health benefits from improving ambient PM2.5 will be rather minimal unless household air pollution is controlled simultaneously. Clean fuels and technologies—such as LPG, natural gas, and electricity—are by far the most effective interventions but continued expansion of the ICS programs, and promotion of dual-burner stoves in particular, will continue to be important for households that cannot afford cooking with LPG or electricity and also serve an important role in conserving scarce fuel wood and reduce the use of agricultural residue for cooking. Considering recent evidence of the severity of impacts of lead on children and adults, representative BLL measurement studies should be undertaken along with identification of sources of lead exposure. Improvements should be continued in the water and sanitation sector, with emphasis on safely managed drinking water and sanitation with safely managed disposal and treat- ment of fecal sludge. Further analysis is needed to assess the impacts of salinity intrusion and other highly poisonous heavy metals in water, such as lead, mercury, and cadmium. Additional studies are also needed to better understand the economic and distributional impacts of the four categories of environmental health risks covered by this chapter. The health effects and costs of environmental pollution estimated in this chapter should be considered conservative. PM2.5 am- bient and household air pollution has additional health effects such as increased incidence of preterm birth, low birth weight and stunting in early childhood. These health effects are associated with impaired cognitive development, IQ, and compromised human capital development and lifetime earnings potential. PM2.5 air pollution has also been found to affect labor productivity in both manufacturing and service sectors in many countries. Moreover, the health effects of air pollution estimated in this chapter do not incorporate health effects of other air pollutants that may be additional to the effects of PM2.5. For lead exposure, addi- tional impacts that may not be fully captured by the effect on IQ and lifetime income include the effects of exposure in early childhood on learning productivity in school and subsequent impairment of labor productivity. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 32 Cost of Environmental Degradation – Environmental Health Issues C2 References / Endnotes ADB (Asian Development Bank). 2016. “Disaster Risk Financing in Bangladesh.” ADB South Asia Working Paper Series No. 46. Manila, Philippines: ADB. Ahmad, J. U., and M. A. Goni. 2010. “Heavy Metal Contamination in Water, Soil, and Vegetables of the Industrial Areas in Dhaka, Bangladesh.” Environ Monit Assess 166 (1): 347–57. https://doi. org/10.1007/s10661-009-1006-6. Ahmad, M. K., S. Islam, S. Rahman, M. Haque, and M. M. Islam. 2010. “Heavy Metals in Water, Sediment and Some Fishes of Buriganga River, Bangladesh.” Int J Environ Rese 4 (2): 321–32. https://doi.org/10.22059/ IJER.2010.24. Ahmad, S. A., M. H. Khan, S. Khandker, A. F. M. Sarwar, N. Yasmin, M. H. Faruquee, and R. Yasmin. 2014. “Blood Lead Levels and Health Problems of Lead Acid Battery Workers in Bangladesh.” Scientific World Journal 1–7. http://dx.doi.org/10.1155/2014/974104. Ahmed, M. K., N. Shaheen, M. S. Islam, M. Habibullah-al-Mamun, S. Islam, M. Mohiduzzaman, and L. Bhattacharjee. 2015. “Dietary Intake of Trace Elements from Highly Consumed Cultured Fish (Labeo rohita, Pangasius pangasius and Oreochromis mossambicus) and Human Health Risk Implications in Bangladesh.” Chemosphere 128: 284–92. Ahmed, M. K., M. A. Baki, G. F. Kundu, M. S. Islam, M. M. Islam, and M. M. Hossain. 2016. “Human Health Risks from Heavy Metals in Fish of Buriganga River, Bangladesh.” Springer Plus 5 (1): 1–2. https://doi.org/10.1186/ s40064-016-3357-0. Alam, M. M., and M. M. Haque. 2021. “Presence of Antibacterial Substances, Nitrofuran Metabolites and Other Chemicals in Farmed Pangasius and Tilapia in Bangladesh: Probabilistic Health Risk Assessment.” Toxicol Rep 8: 248–57. Alberini, A., and A. Krupnick. 2000. “Cost-of-Illness and Willingness-to-Pay Estimates of the Benefits of Improved Air Quality: Evidence from Taiwan.” Land Economics 76: 37–53. Aoki, Y., D. J. Brody, K. M. Flegal, T. H. Fakhouri, D. A. Axelrad, and J. D. Parker. 2016. “Blood Lead and Other Metal Biomarkers as Risk Factors for Cardiovascular Disease Mortality.” Medicine 95 (1): e2223. PMID: 26735529, https://doi.org/10.1097/MD.0000000000002223. Ara, M. H., A. R. Khan, M. Uddin, and P. K. Dhar. 2018a. “Health Risk Assessment of Heavy Metals in the Leafy, Fruit, and Root Vegetables Cultivated near Mongla Industrial Area, Bangladesh.” J Hum Environ Health Promot 4 (4): 144–52. Ara, M. H., U. K. Mondol, P. K. Dhar, and M. N. Uddin. 2018b. “Presence of Heavy Metals in Vegetables Collected from Jashore, Bangladesh: Human Health Risk Assessment.” J Chem Health Risks 8: 277–87. Argos, M., T. Kalra, P. Rathouz, Y. Chen, B. Pierce, F. Parvez, T. Islam, A. Ahmed, M. Rakibuz-Zaman, R. Hasan, G. Sarwar, V. Slavkovich, A. van Geen, J. Graziano, and H. Ahsan. 2010. “Arsenic Exposure from Drinking Water, and All-Cause and Chronic-Disease Mortalities in Bangladesh (HEALS): A Prospective Cohort Study.” Lancet 376: 252–58. Argos, M., T. Kalra, B. Pierce, Y. Chen, F. Parvez, T. Islam, A. Ahmed, R. Hasan, K. Hasan, G. Sarwar, D. Levy, V. Slavkovich, J. H. Graziano, P. J. Rathouz, and H. Ahsan. 2011. “A Prospective Study of Arsenic Exposure from Drinking Water and Incidence of Skin Lesions in Bangladesh.” Am J Epidemiol 174 (2): 185–94. Argos, M., F. Parvez, M. Rahman, M. Rakibuz-Zaman, A. Ahmed, S. K. Hore, T. Islam, Y. Chen, B. L. Pierce, V. Slavkovich, C. Olopade, M. Yunus, J. A. Baron, J. H. Graziano, and H. Ahsan. 2014. “Arsenic and Skin Lesion Status in Relation to Malignant and Non-malignant Lung Disease Mortality in Bangladeshi Adults.” Epidemiology 25 (4): 536–43. Attina, T., and L. Trasande. 2013. “Economic Costs of Childhood Lead Exposure in Low- and Middle-Income Countries.” Environmental Health Perspectives 121 (9): 1097–102. BBS (Bangladesh Bureau of Statistics). 2015. Population and Housing Census 2011: Socioeconomic and Demographic Report. National Report Volume 4. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2019. Report on Bangladesh Sample Vital Statistics 2019. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2021. Report on Bangladesh Sample Vital Statistics 2020. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2022a. Population and Housing Census 2022. Preliminary Report and additional data provided by BBS. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2022b. Statistical Yearbook Bangladesh 2021. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2022c. Bangladesh Disaster-related Statistics (BDRS) 2021: Climate Change and Natural Disaster Perspectives. Key Findings and Detailed Tables. Strengthening Environment, Climate Change and Disaster Statistics (ECDS) Project. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2010. Bangladesh Multiple Indicator Cluster Survey 2009. Final Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2014. Bangladesh Multiple Indicator Cluster Survey 2012–13. Final Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2019. Progotir Pathey: Bangladesh Multiple Indicator Cluster Survey 2019. Survey Findings Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. Berkeley Air Monitoring Group. 2022. Bangladesh’s National Cookstove Program: Comparing Beneficiaries of IDCOL Stoves to Traditional Stoves by Exposure to Household Air Pollution. Prepared in collaboration with the International Centre for Diarrheal Research, Bangladesh (ICDDR,B) for the Infrastructure Development Company Limited (IDCOL). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 33 Cost of Environmental Degradation – Environmental Health Issues Bhuiyan, M. A. H., M. A. Islam, S. B. Dampare, L. Parvez, and S. Suzuki. 2010. “Evaluation of Hazardous Metal Pollution in Irrigation and Drinking Water Systems in the Vicinity of a Coal Mine Area of Northwestern Bangladesh.” J Hazard Mater 179 (1–3): 1065–77. doi:10.1016/j.jhazmat.2010.03.114. Bhuyan, M. S., M. A. Bakar, A. Akhtar, and M. S. Islam. 2016. “Heavy Metals Status in Some Commercially Important Fishes of Meghna River Adjacent to Narsingdi District, Bangladesh: Health Risk Assessment.” Am J Life Sci 4: 60–70. Black, R., L. Allen, Z. Bhutta, L. E. Caulfield, M. de Onis, M. Ezzati, C. Mathers, and J. Rivera. 2008. “Maternal and Child Undernutrition: Global and Regional Exposures and Health Consequences.” Lancet 371: 243–60. Brinkel, J., M. H. Khan, and A. Kraemer. 2009. “A Systematic Review of Arsenic Exposure and Its Social and Mental Health Effects with Special Reference to Bangladesh.” Int J Eviron Res Public Health 6: 1609–19. Brown, L., M. Lynch, A. Belova, R. Klein, and A. Chiger. 2020. “Developing a Health Impact Model for Adult Lead Exposure and Cardiovascular Disease Mortality.” Environmental Health Perspectives 128 (9). https://doi.org/10.1289/EHP6552. Brown, J. S., S. M. Spalinger, S. G. Weppner, K. J. W. Hicks, M. Thorhaug, W. C. Thayer, M. H. Follansbee, and G. L. Diamond. 2023. “Evaluation of the Integrated Exposure Uptake Biokinetic (IEUBK) Model for Lead in Children.” J Expo Sci Environ Epidemiol 33 (2): 187–97. doi:10.1038/s41370-022-00473-2. Bulka, C. M., M. Scannell Bryan, V. W. Persky, M. L. Daviglus, R. A. Durazo-Arvizu, F. Parvez, V. Slavkovich, J. H. Graziano, T. Islam, J. A. Baron, H. Ahsan, and M. Argos. 2019. “Changes in Blood Pressure Associated with Lead, Manganese, and Selenium in a Bangladeshi Cohort.” Environmental Pollution 248: 28–35. doi:10.1016/j. envpol.2019.01.129. Burnett, R. T., C. A. Pope III, M. Ezzati, C. Olives, S. S. Lim, Sumi Mehta, H. H. Shin, G. Singh, B. Hubbell, M. Brauer, H. R. Anderson, K. R. Smith, J. R. Balmes, N. G. Bruce, H. Kan, F. Laden, A. Prüss-Üstün, M. C. Turner, S. M. Gapstur, W. R. Diver, and A. Cohen. 2014. “An Integrated Risk Function for Estimating the Global Burden of Disease Attributable to Ambient Fine Particulate Matter Exposure.” Environmental Health Perspectives 122: 397–403. Bushra, A., H. M. Zakir, S. Sharmin, Q. F. Quadir, M. H. Rashid, M. S. Rahman, and S. Mallick. 2022. “Human Health Implications of Trace Metal Contamination in Topsoils and Brinjal Fruits Harvested from a Famous Brinjal-Producing Area in Bangladesh.” Science Reports 12: 14278. https://doi.org/10.1038/s41598-022-17930-5. Cairncross, S., C. Hunt, S. Boisson, K. Bostoen, V. Curtis, I. C. H. Fung, and W.-P. Schmidt. 2010. “Water, Sanitation and Hygiene for Preventing Diarrhoea.” Int J Epidemiology 39: i193–i205. Canfield, R. L., C. R. Henderson, D. A. Cory-Slechta, C. Cox, T. A. Jusko, and B. P. Lanphear. 2003. “Intellectual Impairment in Children with Blood Lead Concentrations below 10µg per Deciliter.” NEJM 348 (16): 1517–26. Carlisle, J., K. Dowling, D. Siegel, and G. Alexeeff. 2009. “A Blood Lead Benchmark for Assessing Risks from Childhood Lead Exposure.” J of Environmental Science and Health Part A 44: 1200–08. CDC (Centers for Disease Control and Prevention). 2023. National Health and Nutrition Examination Survey. Atlanta, GA: CDC. https://www.cdc.gov/nchs/nhanes/ index.htm. Chen, Y., J. Graziano, F. Parvez, M. Liu, V. Slavkovich, T. Kalra, M. Argos, T. Islam, A. Ahmed, M. Rakibuz-Zaman, R. Hasan, G. Sarwar, D. Levy, A. van Geen, and H. Ahsan. 2011. “Arsenic Exposure from Drinking Water and Mortality from Cardiovascular Disease in Bangladesh: A Prospective Cohort Study.” British Medical Journal 342: d2431. Chowdhury, K. I. A., S. Nurunnahar, M. L. Kabir, M. T. Islam, M. Baker, M. S. Islam, M. Rahman, M. A. Hasan, A. Sikder, L. H. Kwong, G. K. Binkhorst, E. Nash, J. Keith, A. McCartor, S. P. Luby, and J. E. Forsyth. 2021. “Child Lead Exposure near Abandoned Lead Acid Battery Recycling Sites in a Residential Community in Bangladesh: Risk Factors and the Impact of Soil Remediation on Blood Lead Levels.” Environmental Research 194: 110689. Collado-López. S., L. Betanzos-Robledo, M. M. Téllez-Rojo, H. Lamadrid-Figueroa, M. Reyes, C. Ríos, A. Cantoral. 2022. “Heavy Metals in Unprocessed or Minimally Processed Foods Consumed by Humans Worldwide: A Scoping Review.” Int J Environ Res Public Health 19 (14): 8651. doi:10.3390/ijerph19148651. Cropper, M., and W. Oates. 1992. “Environmental Economics: A Survey.” Journal of Economic Literature 30: 675–740. Crump, K., C. Van Landingham, T. Bowers, D. Cahoy, and J. Chandalia. 2013. “A Statistical Reevaluation of the Data Used in the Lanphear et al. (2005) Pooled- Analysis that Related Low Levels of Blood Lead to Intellectual Deficits in Children.” Crit Rev Toxicol 43 (9): 785–99. Das, P. R., M. K. Hossain, B. S. Sarker, A. Parvin, S. S. Das, M. Moniruzzaman, and B. Saha. 2017. “Heavy Metals in Farm Sediments, Feeds and Bioaccumulation of Some Selected Heavy Metals in Various Tissues of Farmed Pangasius hypophthalmus in Bangladesh.” Fisheries and Aquaculture Journal 8: 1–9. Dhar, P. K., N. Uddin, M. H. Ara, and N. T. Tonu. 2019. “Heavy Metals Concentrations in Vegetables, Fruits and Cereals and Associated Health Risk of Human in Khulna, Bangladesh.” J Wat Env Sci 3 (1): 453–59. Dickie, M., and S. Gerking. 2002. “Willingness to Pay for Reduced Morbidity.” Paper presented at “Economic Valuation of Health for Environmental Policy: Assessing Alternative Approaches,” Orlando, FL, March 18–19. DoE (Department of Environment). 2021. Monthly Air Quality Monitoring Report. Reporting Month: March 2021. Dhaka, Bangladesh: Department of Environment. Ministry of Environment, Forest and Climate Change. EC DRMKC (European Commission Disaster Risk Management Knowledge Centre). INFORM Risk – Map Explorer. https://drmkc.jrc.ec.europa.eu/inform-index/ INFORM-Risk/Map EFSA (European Food Safety Authority). 2013. “Scientific Opinion on Lead in Food.” EFSA Panel on Contaminants in the Food Chain. Parma, Italy: EFSA. EM-DAT. 2022. The International Disaster Database. Centre for Research on the Epidemiology of Disasters (CRED). Brussels, Belgium. http://www.emdat.be. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 34 Cost of Environmental Degradation – Environmental Health Issues Ericson, B., P. Landrigan, M. P. Taylor, J. Frostad, J. Caravanos, J. Keith, and R. Fuller. 2016. “The Global Burden of Lead Toxicity Attributable to Informal Used Lead- Acid Battery Sites.” Annals of Global Health 82 (5): 686–99. Ericson, B., H. Hu, E. Nash, G. Ferraro, J. Sinitsky, and M. P. Taylor. 2021. “Blood Lead Levels in Low- and Middle-Income Countries: A Systematic Review.” Lancet Planet Health 5: e145–53. ESCAP (UN Economic and Social Commission for Asia and the Pacific). 2021. The Risk and Resilience Portal. ESCAP. https://rrp.unescap.org/economic-impacts/ economic-impact. ESDO (Environment and Social Development Organization). 2018. “Aluminum Cookware: A Major Source of Lead and other Toxic Metal Contamination in Bangladesh.” Dhaka, Bangladesh: ESDO. ESDO (Environment and Social Development Organization) / IPEN (International Pollutants Elimination Network). 2021. “Lead in Solvent-based Paints for Home Use in Bangladesh.” Dhaka, Bangladesh: ESDO and IPEN Sweden. FAO, UNICEF, WHO, and WSP (Food and Agriculture Organization, United Nations Children’s Fund, World Health Organization, and Water and Sanitation Programme). 2010. Towards an Arsenic Safe Environment in Bangladesh. A joint publication by the FAO, UNICEF, WHO, and WSP. Fewtrell, L., R. Kaufmann, and A. Prüss-Üstün. 2003. “Lead: Assessing the Environmental Burden of Disease at National and Local Levels.” Environmental Burden of Disease Series 2. Geneva, Switzerland: World Health Organization. Fewtrell, L., A. Prüss-Üstün, R. Bos, F. Gore, and J. Bartram. 2007. “Water, Sanitation and Hygiene: Quantifying the Health Impact at National and Local Levels in Countries with Incomplete Water Supply and Sanitation Coverage.” Environmental Burden of Disease 15. Geneva, Switzerland: World Health Organization. Fishman, M. S., L. E. Caulfield, M. De Onis, M. Blossner, A. A. Hyder, L. Mullany, and R. E. Black. 2004. Childhood and Maternal Underweight. In Comparative Quantification of Health Risks—Global and Regional Burden of Disease Attributable to Selected Major Risk Factors – Vol. 1, edited by M. Ezzati, A. D. Lopez, A. Rodgers, and C. J. L. Murray. Geneva, Switzerland: World Health Organization. Forsyth, J. E., M. Saiful Islam, S. M. Parvez, R. Raqib, M. Sajjadur Rahman, E. Marie Muehe, S. Fendorf, and S. P. Luby. 2018. “Prevalence of Elevated Blood Lead Levels among Pregnant Women and Sources of Lead Exposure in Rural Bangladesh: A Case Control Study.” Environmental Research 166: 1–9. doi:10.1016/j. envres.2018.04.019 Forsyth, J. E., S. Nurunnahar, S. S. Islam, M. Baker, D. Yeasmin, M. S. Islam, M. Rahman, S. Fendor, N. M. Ardoin, P. J. Winch, and S. P. Luby. 2019a. “Turmeric Means ‘Yellow’ in Bengali: Lead Chromate Pigments Added to Turmeric Threaten Public Health across Bangladesh.” Environmental Research 179: 108722. Forsyth, J. E., K. L. Weaver, K. Maher, M. S. Islam, R. Raqib, M. Rahman, S. Fendorf, and S. P. Luby. 2019b. “Sources of Blood Lead Exposure in Rural Bangladesh.” Environ Sci Technol 53: 11429−36. Forsyth, J. E., M. Baker, S. Nurunnahar, S. Islam, M. S. Islam, T. Islam, E. Plambeck, P. J. Winch, D. Mistree, S. P. Luby, and M. Rahman. 2023. “Food Safety Policy Enforcement and Associated Actions Reduce Lead Chromate Adulteration in Turmeric across Bangladesh.” Environmental Research 232: 116328. doi:10.1016/j. envres.2023.116328. GBD (Global Burden of Disease) 2013 Risk Factors Collaborators. 2015. “Global, Regional, and National Comparative Risk Assessment of 79 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks in 188 Countries 1990–2013: A Systematic Analysis for the Global Burden of Disease Study 2013.” Lancet 386: 2287–323. GBD (Global Burden of Disease) 2015 Risk Factors Collaborators. 2016. “Global, Regional, and National Comparative Risk Assessment of 79 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks, 1990–2015: A Systematic Analysis for the Global Burden of Disease Study 2015.” Lancet 388: 1659–724. GBD (Global Burden of Disease) 2016 Risk Factors Collaborators. 2017. “Global, Regional, and National Comparative Risk Assessment of 84 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks, 1990–2016: A Systematic Analysis for the Global Burden of Disease Study 2016.” Lancet 390: 1345–422. GBD (Global Burden of Disease) 2017 Risk Factor Collaborators. 2018. “Global, Regional, and National Comparative Risk Assessment of 84 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks for 195 Countries and Territories, 1990–2017: A Systematic Analysis for the Global Burden of Disease Study 2017.” Lancet 392: 1923–94. GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. Germanwatch 2021. Global Climate Risk Index 2021. Bonn, Germany: Germanwatch. https://www.germanwatch.org/en/19777 Gilbert, S. G., and B. Weiss. 2006. “A Rationale for Lowering the Blood Lead Action Level from 10 to 2 µg/dL.” NeuroToxicology 27: 693–701. Gleason, K., J. P. Shine, N. Shobnam, L. B. Rokoff, H. S. Suchanda, M. O. Ibne Hasan, G. Mostofa, C. Amarasiriwardena, Q. Quamruzzaman, M. Rahman, M. L. Kile, D. C. Bellinger, D. C. Christiani, R. O. Wright, and M. Mazumdar. 2014. “Contaminated Turmeric is a Potential Source of Lead Exposure for Children in Rural Bangladesh.” J Environ Public Health 2014: 730636. doi:10.1155/2014/730636. Gleason, K. M., L. Valeri, A. H. Shankar, J. F. Obrycki, O. S. I. Hasan, G. Mostofa, Q. Quamruzzaman, R. O. Wright, D. C. Christiani, D. C. Bellinger, and M. Mazumdar. 2020. “Stunting and Lead: Using Causal Mediation Analysis to Better Understand How Environmental Lead Exposure Affects Cognitive Outcomes in Children.” Journal of Neurodevelopmental Disorders 12: 39 https://doi.org/10.1186/s11689-020-09346-x. GoB (Government of Bangladesh). 2020. “Making Vision 2041 a Reality: Perspective Plan of Bangladesh 2021–2041.” General Economics Division, Bangladesh Planning Commission, Ministry of Planning. Dhaka, Bangladesh: Government of the People’s Republic of Bangladesh. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 35 Cost of Environmental Degradation – Environmental Health Issues Gottesfeld, P., and A. Pokhrel. 2011. “Review: Lead Exposure in Battery Manufacturing and Recycling in Developing Countries and Among Children in Nearby Communities.” Journal of Occupational and Environmental Hygiene 8: 520–32. Gould, E. 2009. “Childhood Lead Poisoning: Conservative Estimates of the Social and Economic Benefits of Lead Hazard Control.” Environmental Health Perspectives 117 (7): 1162–67. Grosse, S. D. 2014. “Response to Salkever: More Information Needed to Estimate the Effect of Childhood IQ on Adult Earnings.” Association of Environmental and Resource Economists (AERE) Newsletter 34 (2): 29–34. Grosse, S. D., and Y. Zhou. 2021. “Monetary Valuation of Children’s Cognitive Outcomes in Economic Evaluations from a Societal Perspective: A Review.” Children 8: 352. https://doi.org/10.3390/children8050352 Grosse, S. D., T. D. Matte, J. Schwartz, and R. J. Jackson. 2002. “Economic Gains Resulting from the Reduction in Children’s Exposure to Lead in the United States.” Environmental Health Perspectives 110 (6): 563–69. Haque, M., N. M. Niloy, A. Khirul, F. Alam, and S. M. Tareq. 2021. “Appraisal of Probabilistic Human Health Risks of Heavy Metals in Vegetables from Industrial, Non- industrial and Arsenic Contaminated Areas of Bangladesh.” Heliyon 7 (2): e06309. ISSN 2405-8440. https://doi.org/10.1016/j.heliyon.2021.e06309. Hasan, M. K., A. Shahriar, and K. U. Jim. 2019. “Water Pollution in Bangladesh and Its Impact on Public Health.” Heliyon 5: e02145. HEI (Health Effects Institute). 2020. State of Global Air 2020. Boston, MA: HEI. https://www.stateofglobalair.org/data/#/air/plot ICCDR,B. Non-communicable diseases. A Brief Guide to Non-Communicable Diseases (NCDs) and their Impact Globally and in Bangladesh. https://www. icddrb.org/news-and-events/press-corner/media-resources/non-communicable-diseases. Islam, M. S., and M. Habibullahalmamun. 2017. “Accumulation of Trace Elements in Sediment and Fish Species of Paira River, Bangladesh.” AIMS Environ Sci 4: 310–22. https://doi.org/10.3934/environsci.2017.2.310. Islam, F., M. Rahman, S. S. Khan, B. Ahmed, A. Bakar, and M. Halder. 2013. “Heavy Metals in Water, Sediment and Some Fishes of Karnofuly River, Bangladesh.” Pollut Res 32: 715–21. http:// www.envirobiotechjournals.com/article_abstract. php?aid=4763&iid=165&jid=4. Islam, M. S., M. K. Ahmed, M. Habibullah-Al-Mamun, and M. Raknuzzaman. 2015. “The Concentration, Source and Potential Human Health Risk of Heavy Metals in the Commonly Consumed Foods in Bangladesh.” Ecotoxicol Environ Saf 122: 462–69. Islam, M. M., M. R. Karim, X. Zheng, and X. Li. 2018a. “Heavy Metal and Metalloid Pollution of Soil, Water and Foods in Bangladesh: A Critical Review.” International J of Environmental Research and Public Health 15 (12): 2825. https://doi.org/10.3390/ijerph15122825. Islam, R., S. Kumar, A. Rahman, J. Karmoker, S. Ali, S. Islam, and M. S. Islam. 2018b. “Trace Metals Concentration in Vegetables of a Sub-urban Industrial Area of Bangladesh and Associated Health Risk Assessment.” AIMS Environ Sci 15 (3): 130–42. https://doi. org/10.3934/environsci.2018.3.130. Islam, A., D. Romic, A. Akber, and M. Romic. 2018c. “Trace Metals Accumulation in Soil Irrigated with Polluted Water and Assessment of Human Health Risk from Vegetable Consumption in Bangladesh.” Environ Geochem Health 40: 59–85. https://doi.org/10.1007/s10653-017-9907-8. Islam, S., A. Islam, K. Phoungthong, F. Ustaoğlu, C. Tokatli, R. Ahmed, K. Ibrahim, and A. Idris. 2022. “Potentially Toxic Elements in Vegetable and Rice Species in Bangladesh and their Exposure Assessment.” Journal of Food Composition and Analysis 106: 104350, ISSN 0889-1575. https://doi.org/10.1016/j.jfca.2021.104350. Jahiruddin, M., Y. Xie, A. Ozaki, M. R. Islam, T. V. Nguyen, and K. Kurosawa. 2017. “Arsenic, Cadmium, Lead and Chromium Concentrations in Irrigated and Rain-fed Rice and their Dietary Intake Implications.” Australian Journal of Crop Science 11 (7): 806–12. https://doi.org/10.21475/ajcs.17.11.07.pne408. Jamal, A. H. M. S. I. M., Md. A. Ahsan, S. Ahmed, S. Akter, R. Sultana, A. Nahar, and Md. R. Uddin. 2020. “Physicochemical and Microbiological Quality of Potable Water Supplied by DWASA in Dhaka City of Bangladesh.” American Journal of Biological and Environmental Statistics 6 (1): 1–6. doi:10.11648/j.ajbes.20200601.11. Jitaru, P., L. Ingenbleek, N. Marchond, C. Laurent, A. Adegboye, S. E. Hossou, A. Z. Koné, A. D. Oyedele, C. S. K. J. Kisito, Y. K. Dembélé, S. Eyangoh, P. Verger, B. Le Bizec, J. C. Leblanc, and T. Guérin. 2019. “Occurrence of 30 Trace Elements in Foods from a Multi-centre Sub-Saharan Africa Total Diet Study: Focus on Al, As, Cd, Hg, and Pb.” Environ Int 133 (Pt B): 105197. doi:10.1016/j.envint.2019.105197. Johnson, W. R., and D. Neal. 1998. “Basic Skills and the Black–White Earnings Gap.” In The Black–White Test Score Gap, edited by C. Jencks and M. Phillips. Washington, DC: Brookings Institution Press. Joseph, G., and A. Shrestha. 2021. “Monsoons, Rivers, and Tides: A Water Sector Diagnostic of Bangladesh.” World Bank, Washington, DC. Jusko, T. A., C. R. Henderson, B. P. Lanphear, D. A. Cory-Slechta, P. J. Parsons, and R. L. Canfield. 2008. “Blood Lead Concentrations < 10 ug/dL and Child Intelligence at 6 Years of Age.” Environmental Health Perspectives 116 (2): 243–48. Kaiser, R., A. K. Henderso, W. R. Daley, M. Naughton, M. H. Khan, M. Rahman, S. Kieszak, and C. H. Rubin. 2001. “Blood Lead Levels of Primary School Children in Dhaka, Bangladesh.” Environ Health Perspect 109 (6): 563–66. doi:10.1289/ehp.01109563. Karagas, M., A. Gossai, B. Pierce, and H. Ahsan. 2015. “Drinking Water Arsenic Contamination, Skin Lesions, and Malignancies: A Systematic Review of the Global Evidence.” Curr Envir Health Rpt 2: 52–68. Kibria, M. G. 2012. “Uptake of Cadmium and Lead by Rice Grown in Four Contaminated Soils of Chittagong, Bangladesh.” Hamdard Medicus 55 (2). Kumar, S., R. Islam, P. B. Akash, Md. H. R. Khan, R. Proshad, J. Karmoker, and G. R. MacFarlane. 2022. “Lead (Pb) Contamination in Agricultural Products and Human Health Risk Assessment in Bangladesh.” Water, Air, & Soil Pollution 233: 257. https://doi.org/10.1007/s11270-022-05711-9. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 36 Cost of Environmental Degradation – Environmental Health Issues Kundu, G. K., M. Alauddin, M. S. Akter, M. S. Khan, M. M. Islam, G. Mondal, D. Islam, L. C. Mohanta, and A. Huque. 2017. “Metal Contamination of Commercial Fish Feed and Quality Aspects of Farmed Tilapia (Oreochromis niloticus) in Bangladesh.” Bioresearch Communications (BRC) 3: 345–53. Kundu, S., M. H. A. Banna, and A. Sayeed. 2020. “Road Traffic Accidents in Bangladesh: A Top Public Health ssue?” Population Medicine 2 (May): 11. doi:10.18332/ popmed/120968. Lamas, G. A., A. Bhatnagar, M. R. Jones, K. K. Mann, K. Nasir, M. Tellez-Plaza, F. Ujueta, and A. Navas-Acien; American Heart Association Council on Epidemiology and Prevention; Council on Cardiovascular and Stroke Nursing; Council on Lifestyle and Cardiometabolic Health; Council on Peripheral Vascular Disease; and Council on the Kidney in Cardiovascular Disease. 2023. “Contaminant Metals as Cardiovascular Risk Factors: A Scientific Statement From the American Heart Association.” J Am Heart Assoc 12 (13): e029852. doi:10.1161/JAHA.123.029852. Landrigan, P. J., R. Fuller, N. J. R. Acosta, O. Adeyi, R. Arnold, N. N. Basu, A. B. Baldé, R. Bertollini, S. Bose-O’Reilly, J. I. Boufford, P. N. Breysse, T. Chiles, C. Mahidol, A. M. Coll-Seck, M. L. Cropper, J. Fobil, V. Fuster, M. Greenstone, A. Haines, D. Hanrahan, D. Hunter, M. Khare, A. Krupnick, B. Lanphear, B. Lohani, K. Martin, K. V. Mathiasen, M. A. McTeer, C. J. L. Murray, J. D. Ndahimananjara, F. Perera, J. Potočnik, A. S. Preker, J. Ramesh, J. Rockström, C. Salinas, L. D. Samson, K. Sandilya, P. D. Sly, K. R. Smith, A. Steiner, R. B. Stewart, W. A. Suk, O. C .P. van Schayck, G. N. Yadama, K. Yumkella, and M. Zhong. 2018. “The Lancet Commission on Pollution and Health.” Lancet 391 (10119): 462–512. doi:10.1016/S0140-6736(17)32345-0. Lanphear, B. P., R. Hornung, J. Khoury, K. Yolton, P. Baghurst, D. C. Bellinger, R. L. Canfield, K. N. Dietrich, R. Bornschein, T. Greene, S. J. Rothenberg, H. L. Needleman, L. Schnaas, G. Wasserman, J. Graziano, and R. Roberts. 2005. “Low-level Environmental Lead Exposure and Children’s Intellectual Functions: An International Pooled Analysis.” Environmental Health Perspectives 113 (7): 894–99. Lanphear, B. P., S. Rauch, P. Auinger, R. W. Allen, and R. W. Hornung. 2018. “Low-level Lead Exposure and Mortality in US Adults: A Population-based Cohort Study.” Lancet Public Health 3 (4): e177–84. PMID: 29544878, https://doi.org/10.1016/S2468-2667(18)30025-2. Larsen, B. 2007. Cost of Environmental Health Risk in Children under Five Years of Age: Accounting for Malnutrition in Ghana and Pakistan. Background report prepared for the World Bank. Environment Department. Washington, DC: World Bank. Larsen, B., and E. Sánchez-Triana. 2023. “Global Health Burden and Cost of Lead Exposure in Children and Adults: A Health Impact and Economic Modelling Analysis.” Lancet Planet Health September 12. https://doi.org/10.1016/S2542-5196(23)00166-3. Li, Y., J. Hu, W. Wu, S. Liu, M. Li, N. Yao, J. Chen, L. Ye, Q. Wang, and Y. Zhou. 2016. “Application of IEUBK Model in Lead Risk Assessment of Children Aged 61–84 Months Old in Central China.” Science of the Total Environment 541: 673–82. ISSN 0048-9697. https://doi.org/10.1016/j.scitotenv.2015.09.103. Lim, S. S., T. Vos, A. D. Flaxman, G. Danaei, K. Shibuya, H. Adair-Rohani, M. Amann, H. R. Anderson, K. G. Andrews, M. Aryee, C. Atkinson, L. J. Bacchus, A. N. Bahalim, K. Balakrishnan, J. Balmes, S. Barker-Collo, A. Baxter, M. L. Bell, J. D. Blore, F. Blyth, C. Bonner, G. Borges, R. Bourne, M. Boussinesq, M. Brauer, P. Brooks, N. G. Bruce, B. Brunekreef, C. Bryan-Hancock, C. Bucello, R. Buchbinder, F. Bull, R. T. Burnett, T. E. B., B. Calabria, J. Carapetis, E. Carnahan, Z. Chafe, F. Charlson, H. Chen, J. Shen Chen, A. T.-A. Cheng, J. C. Child, A. Cohen, K. E. Colson, B. C. Cowie, S. Darby, S. Darling, A. Davis, L. Degenhardt, F. Dentener, D. C. Des Jarlais, K. Devries, M. Dherani, E. L. Ding, E. R. Dorsey, T. Driscoll, K. Edmond, S. E. Ali, R. E. Engell, P. J. Erwin, S. Fahimi, G. Falder, F. Farzadfar, A. Ferrari, M. M. Finucane, S. Flaxman, F. G. R. Fowkes, G. Freedman, M. K. Freeman, E. Gakidou, S. Ghosh, E. Giovannucci, G. Gmel, K. Graham, R. Grainger, B. Grant, D. Gunnell, H. R. Gutierrez, W. Hall, H. W. Hoek, A. Hogan, H. D. Hosgood III, D. Hoy, H. Hu, B. J. Hubbell, S. J. Hutchings, S. E. Ibeanusi, G. L. Jacklyn, R. Jasrasaria, J. B. Jonas, H. Kan, J. A. Kanis, N. Kassebaum, N. Kawakami, Y.-H. Khang, S. Khatibzadeh, J.-P. Khoo, C. Kok, F. Laden, R. Lalloo, Q. Lan, T. Lathlean, J. L. Leasher, J. Leigh, Y. Li, J. K. Lin, S. E. Lipshultz, S. London, R. Lozano, Y. Lu, J. Mak, R. Malekzadeh, L. Mallinger, W. Marcenes, L. March, R. Marks, R. Martin, P. McGale, J. McGrath, S. Mehta, Z. A. Memish, G. A. Mensah, T. R. Merriman, R. Micha, C. Michaud, V. Mishra, K. M. Hanafiah, A. A. Mokdad, L. Morawska, D. Mozaffarian, T. Murphy, M. Naghavi, B. Neal, P. K. Nelson, J. M. Nolla, R. Norman, C. Olives, S. B. Omer, J. Orchard, R. Osborne, B. Ostro, A. Page, K. D. Pandey, C. D. H. Parry, E. Passmore, J. Patra, N. Pearce, P. M. Pelizzari, M. Petzold, M. R. Phillips, D. Pope, C. A. Pope III, J. Powles, M. Rao, H. Razavi, E. A. Rehfuess, J. T. Rehm, B. Ritz, F. P. Rivara, T. Roberts, C. Robinson, J. A. Rodriguez-Portales, I. Romieu, R. Room, L. C. Rosenfeld, A. Roy, L. Rushton, J. A. Salomon, U. Sampson, L. Sanchez-Riera, E. Sanman, A. Sapkota, S. Seedat, P. Shi, K. Shield, R. Shivakoti, G. M. Singh, D. A. Sleet, E. Smith, K. R. Smith, N. J. C. Stapelberg, K. Steenland, H. Stöckl, L. J. Stovner, K. Straif, L. Straney, G. D. Thurston, J. H. Tran, R. Van Dingenen, A. van Donkelaar, J. L. Veerman, L. Vijayakumar, R. Weintraub, M. M. Weissman, R. A. White, H. Whiteford, S. T. Wiersma, J. D. Wilkinson, H. C. Williams, W. Williams, N. Wilson, A. D. Woolf, P. Yip, J. M. Zielinski, A. D. Lopez, C. J. L. Murray, and M. Ezzati. 2012. “A Comparative Risk Assessment of Burden of Disease and Injury Attributable to 67 Risk Factors and Risk Factor Clusters in 21 Regions, 1990–2010: A Systematic Analysis for the Global Burden of Disease Study 2010.” Lancet 380: 2224–60. Lin, D., R. Lutter, and C. J. Ruhm. 2018. “Cognitive Performance and Labour Market Outcomes.” Labour Econ 51: 121–35. Linderholm, L., K. Jakobsson, T. Lundh, R. Zamir, M. Shoeb, N. Nahar, and A. Bergman. 2011. “Environmental Exposure to POPs and Heavy Metals in Urban Children from Dhaka, Bangladesh.” Journal of Environmental Monitoring 13: 2728. Lindhjem, H., S. Narvud, N. A. Braathen, and V. Biausque. 2011. “Valuing Mortality Risk Reductions from Environmental, Transport, and Health Policies: A Global Meta-Analysis of Stated Preference Studies.” Risk Analysis 31 (9): 1381–407. Lundborg, P., P. Nystedt, and D. O. Rooth. 2014. “Height and Earnings: The Role of Cognitive and Noncognitive Skills.” J Hum Resour 49: 141–66. Lustberg, M. and E. Silbergeld. 2002. “Blood Lead Levels and Mortality.” Arch Intern Med 162 (21): 2443-9. doi:10.1001/archinte.162.21.2443. Majumder, A. K. 2022. “Support to Cost-Benefit Analysis of Interventions to Address Lead Contamination in Bangladesh.” Prepared for the World Bank. Washington, DC: World Bank. Majumder, A. K., A. al Nayeem, M. Islam, M. M. Akter, and W. S. Carter. 2021. “Critical Review of Lead Pollution in Bangladesh.” Journal of Health Pollution 11: 210902. Mathee, A., and R. Street R. 2020. “Recycled Aluminium Cooking Pots: A Growing Public Health Concern in Poorly Resourced Countries.” BMC Public Health 20: 1411 https://doi.org/10.1186/s12889-020-09485-9. Mazumdar, I., K. Goswami, and S. Ali. 2017. “Status of Serum Calcium, Vitamin D and Parathyroid Hormone and Hematological Indices Among Lead Exposed Jewelry Workers in Dhaka, Bangladesh.” Indian Journal of Clinical Biochemistry 32 (1): 110–16. doi:10.1007/s12291-016-0582-9. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 37 Cost of Environmental Degradation – Environmental Health Issues McCartor, A. 2018. “Toxic Sites Identification Program in Bangladesh.” Prepared for UNIDO. New York, NY: Pure Earth. https://www.pureearth.org/wp-content/ uploads/2018/12/Bangladesh-TSIP-Report-UNIDO.pdf. McCartor, A., and E. Nash. 2018. Project Completion Report: Reducing Lead Poisoning Among Children in Kathgora, Bangladesh. New York, NY: Pure Earth. https://www.pureearth.org/wp-content/uploads/2019/10/PCR-Report_Kathgora.pdf Mehta, S., H. Shin, R. Burnett, T. North, and A. Cohen. 2013. “Ambient Particulate Air Pollution and Acute Lower Respiratory Infections: A Systematic Review and Implications for Estimating the Global Burden of Disease.” Air Qual Atmos Health 6: 69–83. Menke, A., P. Muntner, V. Batuman, E. K. Silbergeld, and E. Guallar. 2006. “Blood Lead below 0.48 μmol/L (10 μg/dL) and Mortality among US Adults.” Circulation 114 (13): 1388–94. PMID: 16982939, https://doi.org/10.1161/CIRCULATIONAHA.106.628321. Mitra, A. K., A. Haque, M. Isla, and S. A. M. K. Bashar. 2009. “Lead Poisoning: An Alarming Public Health Problem in Bangladesh.” Int J Environ Res Public Health 6: 84–95. doi:10.3390/ijerph6010084. Mitra, A. K., E. Ahua, and P. K. Saha. 2012. “Prevalence of and Risk Factors for Lead Poisoning in Young Children in Bangladesh.” Journal of Health, Population and Nutrition 30 (4): 404–09. Mohiuddin, K. M., F. R. Era, M. S. H. Siddiquee, and M. M. Rahman. 2017. “Quality of Commonly Used Fertilizers Collected from Different Areas of Bangladesh.” Journal of Bangladesh Agricultural University 15 (2): 219–26. doi:10.3329/jbau.v15i2.35066. Mortuza, M. G., and F. A. Al-Misned. 2015. “Trace Elements and Heavy Metals in Five Cultured and Captured Fishes from Rajshahi City, Bangladesh.” Biomedical Sciences Today 1: 1–9. Mostafa, M. G., S. M. Uddin, and A. Haque. 2017. “Assessment of Hydro-Geochemistry and Groundwater Quality of Rajshahi City in Bangladesh.” Applied Water Science 7: 4663–71. https://doi.org/10.1007/s13201-017-0629-y. Mottalib, M. A., S. H. Somoal, M. Aftab, A. Shaikh, and M. S. Islam. 2016. “Heavy Metal Concentrations in Contaminated Soil and Vegetables of Tannery Area in Dhaka, Bangladesh.” Int J Cur Res 8 (5): 30369–73. Muennig, P. 2009. “The Social Costs of Childhood Lead Exposure in the Post-Lead Regulation Era.” Arch Pediatr Adolesc Med 163 (9): 844–49. Naser, H. M., S. Sultana, R. Gomes, and S. Noor. 2012. “Heavy Metal Pollution of Soil and Vegetable Grown near Roadside at Gazipur. Bangladesh.” J Agric Res 37 (1): 9–17. https://doi.org/10.3329/bjar.v37i1.11170. Navrud, S., and H. Lindhjem. 2010. “Meta-Analysis of Stated Preference VSL Studies: Further Model Sensitivity and Benefit Transfer Issues.” Prepared for the Environment Directorate. Paris, France: OECD. OECD (Organisation for Economic Co-operation and Development). 2012. “Mortality Risk Valuation in Environment, Health, and Transport Policies.” Paris, France: OECD. Olofin, I., C. M. McDonald, M. Ezzati, S. Flaxman, R. Black, W. Fawzi, L. Caulfield, and G. Danaei. 2013. “Associations of Suboptimal Growth with All-Cause and Cause- Specific Mortality in Children under Five Years: A Pooled Analysis of Ten Prospective Studies.” PLOS ONE 8: e64636. Parvin, F., M. M. Haque, and S. M. Tareq. 2021. “Recent Status of Water Quality in Bangladesh: A Systematic Review, Meta-Analysis and Health Risk Assessment.” Environmental Challenges 6: 100416. doi:10.1016/j.envc.2021.100416. Parvin, R., A. Sultana, and M. A. Zahid. 2014. “Detection of Heavy Metals in Vegetables Cultivated in Different Locations in Chittagong, Bangladesh.” IOSR J Environ Sci Toxicol Food Tech 8 (4): 58–63. https://doi. org/10.9790/2402-08425863. Pichery, C., M. Bellanger, D. Zmirou-Navier, P. Glorennec, P. Hartemann, and P. Grandjean. 2011. “Childhood Lead Exposure in France: Benefit Estimation and Partial Cost-Benefit Analysis of Lead Hazard Control.” Environmental Health 10: 44. Pope, D., B. Nigel, M. Dherani, K. Jagoe, and E. Rehfuess. 2017. “Real-Life Effectiveness of ‘Improved’ Stoves and Clean Fuels in Reducing PM2.5 and CO: Systematic Review and Meta-Analysis.” Environment International 101 (April): 7–18. Proshad, R., Md. Islam, and T. Kormoker. 2018. “Assessment of Heavy Metals with Ecological Risk of Soils in the Industrial Vicinity of Tangail District, Bangladesh.” International Journal of Advanced Geosciences 6: 10.14419/ijag.v6i1.9791. Prüss-Üstün, A., J. Bartram, T. Clasen, J. Colford, O. Cumming, V. Curtis, S. Bonjour, A. Dangour, J. De France, L. Fewtrell, M. Freeman, B. Gordon, P. Hunter, R. Johnston, C. Mathers, D. Mausezahl, K. Medlicott, M. Neira, M. Stocks, J. Wolf, and S. Cairncross. 2014. “Burden of Disease from Inadequate Water, Sanitation and Hygiene in Low- and Middle-Income Settings: A Retrospective Analysis of Data from 145 Countries.” Trop Med Int Health 19: 894–905. Pure Earth. 2023. “Lead in Consumer Goods: A 25-Country Analysis of Lead (Pb) Levels in 5,000+ Products and Foods.” New York, NY: Pure Earth. www.pureearth. org. Qiu, Z., M. A. Ali, J. E. Nichol, M. Bilal, P. Tiwari, B. A. Habtemicheal, M. Almazroui, S. K. Mondal, U. Mazhar, Y. Wang, S. Sarker, F. Mustafa, and M. A. Rahman. 2021. “Spatiotemporal Investigations of Multi-Sensor Air Pollution Data over Bangladesh during COVID-19 Lockdown.” Remote Sens 13: 877. https://doi.org/10.3390/ rs13050877. Rabie, T., and V. Curtis. 2006. “Handwashing and Risk of Respiratory Infections: A Quantitative Systematic Review.” Trop Med Int Health 11 (3): 258–67. Rahman, M., N. Sohel, M. Yunus, M. Chowdhury, S. Hore, K. Zaman, A. Bhuiya, and P. Streatfield. 2013. “Increased Childhood Mortality and Arsenic in Drinking Water in Matlab, Bangladesh: A Population-based Cohort Study.” PLOS ONE 8 (1): e55014. Rahman, M., N. Sohel, M. Yunus, M. Chowdhury, S. Hore, K. Zaman, A. Bhuiya, and P. Streatfield. 2014. “A Prospective Cohort Study of Stroke Mortality and Arsenic in Drinking Water in Bangladeshi Adults.” BMC Public Health 14: 174. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 38 Cost of Environmental Degradation – Environmental Health Issues Raihan, M. J., E. Briskin, M. Mahfuz, M. M. Islam, D. Mondal, M. I. Hossain, A. M. S. Ahmed, R. Haque, and T. Ahmed. 2018. “Examining the Relationship between Blood Lead Level and Stunting, Wasting and Underweight: A Cross-sectional Study of Children under 2 Years-of-Age in a Bangladeshi Slum.” PLOS ONE 13 (5): e0197856. https://doi.org/10.1371/journal.pone.0197856 Real, I. H., H. M. Azam, and N. Majed. 2017. “Consumption of Heavy Metal Contaminated Foods and Associated Risks in Bangladesh.” Environ Monit Assess 189: 651. PMID: 29181620 doi:10.1007/s10661-017-6362-z. Ruiz-Hernandez, A., A. Navas-Acien, R. Pastor-Barriuso, C. M. Crainiceanu, J. Redon, E. Guallar, and M. Tellez-Plaza. 2017. “Declining Exposures to Lead and Cadmium Contribute to Explaining the Reduction of Cardiovascular Mortality in the US Population, 1988–2004.” International Journal of Epidemiology 46 (6): 1903–12. PMID: 29025072. https://doi.org/10.1093/ije/dyx176. Saha, B., M. Mottalib, and A. N. Al-Razee. 2021. “Heavy Metals Accumulation in Different Cultivated Fish Tissues through Commercial Fish Feeds and Health Risk Estimation in Consumers in Bangladesh.” Chemical Review and Letters 4: 10–20. Salkever, D. S. 1995. “Updated Estimates of Earnings Benefits from Reduced Exposure of Children to Environmental Lead.” Environmental Research 70: 1–6. Salkever, D. S. 2014a. “A Tale of Apples and Oranges (and Footnotes): Comments on Grosse’s Review of the IQ-Earnings Literature.” Association of Environmental and Resource Economists (AERE) Newsletter 34 (2): 23–28. Salkever, D. S. 2014b. “Assessing the IQ-earnings Link in Environmental Lead Impacts on Children: Have Hazard Effects Been Overstated?” Environmental Research 131: 219–30. Samad, M. A., Y. Mahmud, R. K. Adhikary, S. B. Rahman, M. S. Haq, and H. Rashid. 2015. “Chemical Profile and Heavy Metal Concentration in Water and Freshwater Species of Rupsha River, Bangladesh.” American J Environ Protect 3 (6): 180–06. https://doi.org/10.12691/ env-3-6-1. Schober, S., L. Mirel, B. Graubard, D. Brody, and K. Flegal. 2006. “Blood Lead Levels and Death from All Causes, Cardiovascular Disease, and Cancer: Results from the NHANES III Mortality Study.” Environmental Health Perspectives 114: 10. CID: https://doi.org/10.1289/ehp.9123. Schwartz, J. 1994. “Societal Benefits of Reducing Lead Exposure.” Environmental Research 66: 105–12. Shaffer, R. M., S. P. Sellers, M. G. Baker, R. de Buen Kalman, J. Frostad, M. K. Suter, S. C. Anenberg, J. Balbus, N. Basu, D. C. Bellinger, L. Birnbaum, M. Brauer, A. Cohen, K. L. Ebi, . Fuller, P. Grandjean, J. J. Hess, M. Kogevinas, P. Kumar, P. J. Landrigan, B. Lanphear, S. J. London, A. A. Rooney, J. D. Stanaway, L. Trasande, K. Walker, and H. Hu 2019. “Improving and Expanding Estimates of the Global Burden of Disease Due to Environmental Health Risk Factors.” Environ Health Perspectives 127 (10): 105001. doi:10.1289/EHP5496. Shaheen, N., N. Irfan, I. N. Khan, S. Islam, Md. S. Islam, and Md. K. Ahmed. 2016. “Presence of Heavy Metals in Fruits and Vegetables: Health Risk Implications in Bangladesh.” Chemosphere 152: 431–38. ISSN 0045-6535. https://doi.org/10.1016/j.chemosphere.2016.02.060. Shahriar, M. H., M. A. H. Chowdhury, S. Ahmed, M. Eunus, S. B. Kader, B. A. Begum, T. Islam, G. Sarwar, R. Al Shams, R. Raqib, D. S. Alam, F. Parvez, H. Ahsan, and Md. Yunus. 2021. “Exposure to Household Air Pollutants and Endothelial Dysfunction in Rural Bangladesh.” Environmental Epidemiology 5: e132. doi:10.1097/ EE9.0000000000000132. Shamsudduha, M., G. Joseph, S. Haque, M. Khan, A. Zahid, and K. Ahmed. 2019. “Multi-Hazard Groundwater Risks to the Drinking Water Supply in Bangladesh: Challenges to Achieving the Sustainable Development Goals.” Policy Research Working Paper 8922. World Bank, Washington DC. Shin, H. H., A. Cohen, C. A. Pope III, M. Ezzati, S. S. Lim, B. Hubbell, and R. T. Burnett. 2013. “Critical Issues in Combining Disparate Sources of Information to Estimate the Global Burden of Disease Attributable to Ambient Fine Particulate Matter Exposure.” Working Paper prepared for “Methods for Research Synthesis: A Cross- Disciplinary Workshop.” Harvard Center for Risk Analysis, Boston, MA, October 3. Shovon, M. N., B. C. Majumdar, and Z. Rahman. 2017. “Heavy Metals (Lead, Cadmium and Nickel) Concentration in Different Organs of Three Commonly Consumed Fishes in Bangladesh.” Fisheries and Aquaculture Journal 8 (3): 1000207. https://doi.org/10.4172/2150- 3508.1000207. Shupler, M., A. Birch, D. Miller-Lionberg, M. Jeronimo, R. E. Arku, Y. L. Chu, M. Mushtaha, L. Heenan, S. Rangarajan, P. Seron, F. Lanas, F. Cazor, P. Lopez-Jaramillo, P. A. Camacho, M. Perez, K. Yeates, N. West, T. Ncube, B. Ncube, J. Chifamba, R.Yusuf, A. Khan, B. H., X. Liu, L. Wei, L. A. Tse, D. Mohan, P. Kumar, R. Gupta, I. Mohan, K. G. Jayachitra, P. K. Mony, K. Rammohan, S. Nair, P. V. M. Lakshmi, V. Sagar, R. Khawaja, R. Iqbal, K. Kazmi, S. Yusuf, and M. Brauer. 2020. “Household and Personal Air Pollution Exposure Measurements from 120 Communities in Eight Countries: Results from the PURE-AIR Study.” Lancet Planet Health 4 (10): e451–62. doi:10.1016/ S2542-5196(20)30197-2. Smith, K. R., N. Bruce, K. Balakrishnan, H. Adair-Rohani, J. Balmes, Z. Chafe, M. Dherani, D. H. Hosgood, S. Mehta, D. Pope, E. Rehfuess, and others in the HAP CRA Risk Expert Group. 2014. Millions Dead: How Do We Know and What Does It Mean? Methods Used in the Comparative Risk Assessment of Household Air Pollution.” Annu Rev Public Health 35: 185–206. Sohel, N., L. A. Persson, M. Rahman, P. K. Streatfield, M. Yunus, E. C. Ekström, and M. Vahter. 2009. “Arsenic in Drinking Water and Adult Mortality: A Population- based Cohort Study in Rural Bangladesh.” Epidemiology 20 (6): 824–30. Street, R. A., A. Mathee, S. Tanda, C. Hauzenberger, S. Naidoo, and W. Goessler. 2020. “Recycling of Scrap Metal into Artisanal Cookware in the Informal Sector: A Public Health Threat from Multi Metal Exposure in South Africa.” Sci Total Environ 699: 134324. doi:10.1016/j.scitotenv.2019.134324. Sultana, R., R. U. Tanvir, K. A. Hussain, A. S. Chamon, and Md. N. Mondol. 2022. “Heavy Metals in Commonly Consumed Root and Leafy Vegetables in Dhaka City, Bangladesh, and Assessment of Associated Public Health Risks.” Environ Syst Res 11: 15. https://doi.org/10.1186/s40068-022-00261-9. Surkan, P. J., A. Zhang, F. Trachtenberg, D. B. Daniel, S. McKinlay, and D. C. Bellinger. 2007. “Neuropsychological Function in Children with Blood Lead Levels < 10 µg/dL.” NeuroToxicology 28 (6): 1170–77. Tasrina, R. C., and A. Rowshon. 2015. “Heavy Metals Contamination in Vegetables and its Growing Soil.” Int J Environ Anal Chem 2 (3). doi:10.4172/2380-2391.1000142. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 39 Cost of Environmental Degradation – Environmental Health Issues Tyler, C., and A. Allan. 2014. “The Effects of Arsenic Exposure on Neurological and Cognitive Dysfunction in Human and Rodent Studies: A Review.” Curr Envir Health Rpt 1: 132–47. Uddin, J., and Y.-K. Jeong. 2021. “Urban River Pollution in Bangladesh during Last 40 Years: Potential Public Health and Ecological Risk, Present Policy, and Future Prospects toward Smart Water Management.” Heliyon 7 e06107. https://doi.org/10.1016/j.heliyon.2021.e06107. Uddin, M., N., M. K. Hasan, and P. K. Dhar. 2019. “Contamination Status of Heavy Metals in Vegetables and Soil in Satkhira, Bangladesh.” J Mater Environ Sci 10 (6): 543–52. https://www.jmaterenvironsci.com/ Document/vol10/vol10_N6/57-JMES-Uddin-2019.pdf . UNICEF/WHO (United Nations Children’s Fund / World Health Organization). 2019. “Progress on Household Drinking Water, Sanitation and Hygiene 2000–2017: Special Focus on Inequalities.” New York, NY: UNICEF and WHO. USEPA (US Environmental Protection Agency). 2020. “Economic Analysis of the Final Rule to Revise the TSCA Dust-Lead Post-Abatement Clearance Levels.” Office of Pollution Prevention and Toxics. Washington, DC: USEPA. Wasserman, G. A., X. Liu, F. Parvez, P. Factor-Litvak, H. Ahsan, D. Levy, J. Kline, A. van Geen, J. Mey, V. Slavkovich, A. B. Siddique, T. Islam, and J. Graziano. 2011. “Arsenic and Manganese Exposure and Children’s Intellectual Function.” Neurotoxicology 32 (4): 450–57. doi:10.1016/j.neuro.2011.03.009. Wasserman, G. A., X. Liu, F. Parvez, Y. Chen, P. Factor-Litvak, N. J. LoIacono, D. Levy, H. Shahriar, M. N. Uddin, T. Islam, A. Lomax, R. Saxena, E. A. Gibson, M. A. Kioumourtzoglou, O. Balac, T. Sanchez, J. K. Kline, D. Santiago, T. Ellis, A. van Geen, and J. H. Graziano. 2018. “A Cross-Sectional Study of Water Arsenic Exposure and Intellectual Function in Adolescence in Araihazar, Bangladesh.” Environment International 118: 304–13. doi:10.1016/ j.envint.2018.05.037 Weidenhamer, J., M. Chasant, and P. Gottesfeld.  2022.  “Metal Exposures from Source Materials for Artisanal Aluminum Cookware.” International Journal of Environmental Health Research doi:10.1080/09603123.2022.2030677. Weidenhamer, J. D., P. A. Kobunski, G. Kuepouo, R. W. Corbin, and P. Gottesfeld. 2014. “Lead Exposure from Aluminum Cookware in Cameroon.” Sci Total Environ 496: 339–47. doi:10.1016/j.scitotenv.2014.07.016. Weidenhamer, J. D., M. P. Fitzpatrick, A. M. Biro, P. A. Kobunski, M. R. Hudson, R. W. Corbin, and P. Gottesfeld. 2017. “Metal Exposures from Aluminum Cookware: An Unrecognized Public Health Risk in Developing Countries.” Sci Total Environ 579: 805–13. doi:10.1016/j.scitotenv.2016.11.023. WHO (World Health Organization). 2011. “Guidelines for Drinking-Water Quality.” Fourth edition. Geneva, Switzerland: WHO. WHO (World Health Organization). 2021. “WHO Global Air Quality Guidelines: Particulate Matter (PM2.5and PM10), Ozone, Nitrogen Dioxide, Sulfur Dioxide and Carbon Monoxide.” Geneva, Switzerland: WHO. License: CC BY-NC-SA 3.0 IGO. Wilson, C. 2003. “Empirical Evidence Showing the Relationships between Three Approaches for Pollution Control.” Environmental and Resource Economics 24: 97–101. Wolf, J., A. Prüss-Üstün, O. Cumming, J. Bartram, S. Bonjour, S. Cairncross, T. Clasen, J. M. Colford Jr, V. Curtis, J. De France, L. Fewtrell, M. C. Freeman, B. Gordon, P. R. Hunter, A. Jeandron, R. B. Johnston, D. Mäusezahl, C. Mathers, M. Neira, and J. P. T. Higgins. 2014. “Assessing the Impact of Drinking Water and Sanitation on Diarrheal Disease in Low- and Middle-Income Settings: Systematic Review and Meta-regression.” Tropical Medicine and International Health 19: 928–42. Wolf, J., P. Hunter, M. Freeman, and O. Cumming. 2018. “Impact of Drinking Water, Sanitation and Handwashing with Soap on Childhood Diarrhoeal Disease: Updated Meta-analysis and Meta-regression.” Tropical Medicine and International Health 23 (5): 508–25. Woo, M. K., E. S. Young, G. Mostofa, S. Afroz, O. S. I. Hasan, Q. Quamruzzaman, D. C. Bellinger, D. C. Christiani, and M. Mazumdar. 2018. “Lead in Air in Bangladesh: Exposure in a Rural Community with Elevated Blood Lead Concentrations among Young Children.” International Journal of Environmental Research and Public Health 15: 1947. doi:10.3390/ijerph15091947 World Bank. 2008. Environmental Health and Child Survival: Epidemiology, Economics, Experiences. Washington DC: World Bank. World Bank. 2016a. Discounting Costs and Benefits in Economic Analysis of World Bank Projects. OPSPQ. May 2016. Washington, DC: World Bank. World Bank. 2016b. Methodology for Valuing the Health Impacts of Air Pollution: Discussion of Challenges and Proposed Solutions. Prepared by N. Urvashi and C. Sall. Washington DC: World Bank. World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh. Country Environmental Analysis 2018. Washington DC: World Bank. World Bank. 2022. Bangladesh Country Climate and Development Report. Washington, DC: World Bank Group. https://openknowledge.worldbank.org/server/ api/core/bitstreams/6d66e133-e49d-5ad9-b056-7b1a6c6206ed/content World Bank. 2023. World Development Indicators. Washington DC: World Bank. World Bank and IHME (Institute for Health Metrics and Evaluation). 2016. The Cost of Air Pollution: Strengthening the Economic Case for Action. Washington, DC: World Bank. Zax, J. S., and D. I. Rees. 2002. “IQ, Academic Performance, Environment, and Earnings.” Rev Econ Stat 84: 600–16. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 40 Cost of Environmental Degradation – Environmental Health Issues Endnotes 2 PM2.5 are particulates with a diameter smaller or equal to 2.5 micrometers (µm). 3 See annex 2G for the methodology for calculations of years of disability and days of illness. 4 World Bank estimates based on BBS/UNICEF (2019) and BBS (2019). 5 https://www.bondhufoundation.org/ongoing-project/bondhu-chula/ 6 https://idcol.org/home/ics 7 Personal exposure was measured for women using each of the three types of IDCOL stoves. The exposure of 179 µg/m3 is the weighted average based on sales of each type. See Berkeley Air Monitoring Group (2022). 8 Ambient PM2.5 deducted from personal exposure was a rural annual average of 57 µg/m3 for the study by Shahriar et al. (2021) because this study included measurements both in the dry and wet seasons. Ambient PM2.5 deducted from personal exposure for the study by Berkeley Air Monitoring Group (2022) was 112 µg/m3. This was average ambient PM2.5 during the dry season measurement period in the five divisions of the study (mainly January–February 2022). 9 See annex 2G for the methodology for calculations of years of disability and days of illness. 10 The standard deviations for the population of Bangladesh were estimated from mean BLLs and standard deviations reported in Ericson et al. (2021) from nearly 300 BLL measurement studies in 30 low- and middle-income countries (LMICs) for children and 355 studies in 36 LMICs for adults. 11 The effects on BLLs were estimated using the Integrated Exposure Uptake Biokinetic (IEUBK) Model Version 2 developed by the USEPA. The model has for instance been applied to predict BLLs from remediation of Pb contaminated soil (Brown et al. 2023) and from dietary and soil/dust intake of Pb in China (Li et al. 2016). Model parameters were adjusted to reflect the situation in Bangladesh with respect to time spent outdoors per day (4.8 hours), daily quantity of drinking water intake (0.82 liters), and soil ingested (0.168 grams per day) by a two-year-old child. 12 This is estimated assuming a two-year-old child’s food consumption of 300 g/day or a little less than half of an adult’s food consumption (800 g/day) in Bangladesh. 13 Intelligence quotient (IQ) is a score on standardized tests designed to assess intelligence. 14 The log-linear function is Δ IQ = β [ln (BLL+1)] with β = 3.246 for childhood lifetime BLLs prior to IQ testing (see annex 2C). 15 Loss of IQ points is calculated for all children, with annual IQ loss calculated as Δ IQ / 5 by assuming that the children’s IQ points are lost in the first five years of life. The GBD 2019 limits the estimate of health effects in children to children for whom Pb exposure causes idiopathic developmental intellectual disability (IQ score below 70). 16 IQ losses are 17.5–19.2 million points with a TMREL of 2 μg/dL. 17 See annex 2G for the methodology used to calculate days of illness. 18 The present value is estimated based on a discount rate of 5 percent and a long-term real annual future income growth of 2.5 percent. The discount rate is twice the income growth rate as proposed by World Bank (2016a). 19 Appropriate methods include boiling, bleaching/chlorination, filtering, and solar disinfection. 20 Deaths from arsenic in drinking water is baseline all-cause deaths (or nonaccidental all-cause deaths) in 2019 from the GBD 2019 for Bangladesh multiplied by the attributable fraction (AF) of these deaths due to arsenic. The AF is calculated using the attributable fraction formula in annex 2E. 21 Days of illness (D), for each type of illness, are calculated as follows: D = M * YLDs per death * 365 / w where M is deaths from arsenic exposure, YLDs per death is from the Global Burden of Disease 2019 (GBD 2019) for Bangladesh, and w is the disability weight of illness from the GBD 2019. 22 This annual rate is higher than the total number of deaths caused by natural disasters between 1971 and 2021. In that period, natural disasters caused a total of 220,181 deaths in Bangladesh (including from floods, storms, temperature extremes, landslides, earthquakes, and droughts). The World Bank estimates were produced from EM-DAT (2022). 23 For comparison purposes, road traffic accidents in Bangladesh caused at least 5,227 deaths in 2019, and an estimated 75,617 deaths were attributed to diabetes in 2021 (ICCDR,B; Satyajit, Banna, and Abu Sayeed 2020). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 41 Bangladesh’s Environmental Governance Framework CHAPTER 3. BANGLADESH’S ENVIRONMENTAL GOVERNANCE FRAMEWORK 3.1 Introduction Tackling pollution and reducing its severe health effects are fundamental to achieving Bangladesh’s broader development goals. This chapter analyzes the design and effectiveness of environmental regulations and institutions in Bangladesh, particularly for addressing priority challenges in environmental health and pollution management. It builds on and complements the institu- tional analysis from the 2018 Country Environmental Analysis (CEA) (World Bank 2018). The methodology used to develop this chapter consisted of (a) a desktop review of official documents, including existing laws and regulations, policies, guidelines, plans and annual reports of government agencies; (b) a review of results and lessons learned from recently completed analytics and operations financed by Development Partners (DPs); and (c) discussions with Govern- ment of Bangladesh (GoB) officials and other stakeholders as part of the CEA consultations. Among those stakeholders, the Bank team conducted semi-structured interviews with representatives from industry associations, academia, Civil Society Organiza- tions (CSOs), and DPs. These interviews provided diverse perspectives on opportunities to strengthen Bangladesh’s institutional framework for environmental management. 3.2 Legal framework for environmental management in Bangladesh Bangladesh’s environmental legal framework is shaped by more than 100 acts, rules, policies, and plans. Article 18A of Bangla- desh’s Constitution, introduced in 2011 through the 15th Amendment, recognizes environmental protection as a fundamental right and establishes that the state must “endeavor to protect and improve the environment and to preserve and safeguard the natural resources, biodiversity, wetlands, forests and wildlife for the present and future citizens.” The country’s legislation covers a wide range of environmental and natural resource issues, including air, noise, and water pollution, forests, biodiversity conserva- tion, and wetland management. Additional instruments focus, among others, on agriculture and livestock, fisheries, land degra- dation, water resource management, disaster risk management, labor and occupational risks, pesticides, renewable energy and energy efficiency, industry, and trade. Figure 3.1 summarizes the chronological development of major environmental policies and regulations since the adoption of Bangladesh’s first environmental policy in 1992. The list is not exhaustive and focuses on the environmental priorities covered by the CEA. Complementing the 2018 CEA, except for the Environment Conservation Act (ECA) 1995, this chapter emphasizes regulations approved from 2018 to 2023, especially those instruments related to the country’s environmental priorities identified in Chapters 2 and 7 (air pollution, water supply and sanitation, lead and other chemicals, and plastic waste). Environment Conservation Act. The ECA 1995 (amended in 2000, 2002, and 2010) remains the backbone of the legal frame- work for environmental protection in Bangladesh. The law aims at (a) promoting environmental conservation, (b) improving the country’s environmental quality standards, and (c) controlling and mitigating environmental pollution. The ECA includes pro- visions on (a) environmental standards, including limits on noise, air pollution emissions, and discharges into water and soil; (b) environmental clearance of industries, infrastructure, and development projects; and (c) remedial measures and compensation from those responsible for ecosystem damages or emitting and discharging pollutants above permissible levels. The act also set forth sanctions for noncompliance with its provisions. Despite its previous amendments, the ECA omits critical issues in environmental management. A comprehensive reform to the ECA is needed to ensure a transformative change towards greening the economy and ensuring sustainable development. A new amendment and corresponding rules should include provisions to: (a) expand the DoE services and incorporate a new Environment cadre in the Bangladesh Civil Service (BCS); (b) promote circular economy, eco-design, and market-based policy instruments; (c) modernize and make enforcement activities more efficient, including clear provisions to implement the pollut- ers pay principle and set adequate sanctions and incentives for compliance with the ECA provisions, based on the magnitude of the risk or actual damage, recidivism, and polluter’s payment capacity; (d) mobilize green financing by establishing a permanent Environment Fund, which could receive resources from the compensation for environmental damage envisaged in Article 7 of ECA and eventually from environmental taxes and imposed fines; (e) improve stakeholder engagement in environmental de- BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 42 Bangladesh’s Environmental Governance Framework cision-making; (f) require Strategic Environmental Assessment (SEA) for policies, plans and programs; (g) set the mandates and foundations for further regulations on Extended Producer Responsibility (EPR), Payment for Ecosystem Services (PES), and Living Modified Organisms (LMO), among other themes. Figure 3.1 Development of environmental policies and regulations in Bangladesh National Environmental Shipbreaking and Recycling Rules 2011 NDC 2021 Policy 1992 Hazardous Waste Management and Ship-Breaking Waste EIA Guidelines for Industries 2021 National Energy Policy 1995 Management Rules 2011 E-Waste Management Rules 2021 Environment Conservation Sustainable and Renewable Energy Development Authority Solid Waste Management Rules Act 1995 (SREDA) Act 2012 2021 National Environment Brick Manufacturing and Brick Kilns Establishment Act (BMBKEA) Air Pollution Control Rules 2022 Management 2013 Environment Conservation Rules Action Plan (1995–2005) Bangladesh Water Act 2013 2023 Water Supply and Sanitation National River Conservation Act 2013 Energy Efficiency and Act 1996 Bangladesh Country Action Plan for Clean Cookstoves 2013 Conservation Rules 2016 Environment Conservation Energy Efficiency & Conservation Rule 2014 (Amended 2023) Rules 1997 Environment and Biodiversity Energy Efficiency & Conservation Master Plan Up to 2030 (2014) Conservation of Saint Martin’s Bangladesh Electricity & Energy Research Council Act 2015 Island and Eco-Friendly Tourism Bangladesh Standards and Guidelines for Sludge Management Guidelines 2023 2015 Bangladesh Country Investment Plan for Environment, Forestry, and Climate Change (2016–2021) 1990 2000 2010 2015 2020 ECR 1997 (Amended Feb, Aug 2002) Ecologically Critical Area Rules 2016 National Industrial Policy 2005 National Industrial Policy 2016 Environment Court Act 2000 Energy Efficiency and Conservation Rules 2016 ECA (Amended 2000 and 2002) Energy Audit Rules 2016 ECR 1997 (Amended 2005) Petroleum Act 2016 Renewable Energy Policy 2008 Bangladesh Biodiversity Act 2017 Medical Waste Management Rules 2008 ECR 1997 (Amended Feb 2017) Ecologically Critical Areas Gazette 2009 Pesticide Act 2018 Mobile Court Act 2009 Bangladesh Water Rules 2018 BEZA Act 2010 Bangladesh Ship Recycling Act 2018 (ratifying Bangladesh Climate Change Trust Act 2010 Hong Kong International Convention for safe and Balumahal and Soil Management Act 2010 environmentally sound recycling of ships 2009) Speedy Increase of Electricity & Fuel (Special Provision) National Environment Policy 2018 2010 Roadmap and Action Plan for Implementing National 3R Strategy 2010 Bangladesh’s Nationally Determined Contribution (NDC) Environment Court Act 2010 2018 ECR 1997 (Amended 2010) BMBKEA 2013 (Amended 2019) ECA 1995 (Amended 2010) Air Pollution Control Guideline 2019 (For Dhaka) Sources: Faroque and Hasan 2014; MoEFCC; World Bank 2018. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 43 Bangladesh’s Environmental Governance Framework Environment Conservation Rules (ECR). In 2023, the MoEFCC approved the new ECR (ECR 2023), which strengthened require- ments and clarified procedures for industries and project units to assess and manage environmental and social impacts asso- ciated with their activities. The new ECR updated the water quality and sewerage standards, as well as waste emissions and liquid waste standards for industries and projects. Standards for ambient air were moved to the Air Pollution Control Rules (APCR), 2022. The new ECR, as in the 1997 version, kept limited provisions on the DoE’s responsibilities of policy formulation, data collection, environmental quality monitoring and enforcement (including, for example, the use of new technologies for over- sight activities). The ECR 2023 detailed provisions for project scoping, categorization, site clearance, environmental assessment (including social issues), cross-sector and stakeholder consultations, among others. Additionally, the ECR 2023 regulated access to information and stakeholder participation throughout the environmental clearance process, particularly for those activities that require a full Environmental Impact Assessment (EIA). Although the ECR 2023 is expected to improve the environmental clearance (EC) process, additional guidelines are required to clarify assessment criteria and procedures related to key themes as described in Chapter 4 of the CEA. Air Pollution Control Rules (APCR). The APCR 2022 sets national air quality standards based on WHO Air Quality Guidelines (Interim Goals), emissions limits and technical specifications for key sectors, mandates and coordination mechanisms among relevant line ministries to control both household and outdoor air pollution. The rules elevated the air quality management (AQM) leadership beyond the environment sector by establishing the National Committee on Air Pollution Control (NCAPC), a multi-sector decision-making body presided over by the Cabinet Secretary to coordinate the APCR implementation and instructing relevant agencies on specific interventions to comply with the new rules. The NCAPC is mandated, for example, to impose emergency measures in case of heavy air pollution, such as restricting activities of industries or projects, vehicles, or any source of air pollution in a certain area and closure of educational institutions. The APCR also envisages the objectives and min- imum requirements of its implementation management tools, such as a National Air Quality Management Plan (also covering interventions and targets for household air pollution), a degraded airsheds declaration and management plan, the publication of a list of high air polluting industries and activities, prevention plans, and monitoring and control systems. Although APCR 2022 represents an important achievement of AQM in Bangladesh, the rules lack specific provisions on mar- ket-based policy instruments, the use of ICT and remote monitoring of emissions in highly polluting industries, and the need to develop evidence to inform policy making (for example, through emissions inventories, chemical composition and source appor- tionment studies, emission projections). Additional guidelines should be approved to (a) guide enforcement activities related to AQM, particularly on-site inspection by the DoE and mobile courts, (b) gather and disseminate air quality monitoring data, and (c) identify prioritized activities, industries, and projects for monitoring, enforcement and disclosure of emissions-related information. Other relevant regulatory development for AQM refers to the 2019 Amendment of the Brick Manufacturing and Brick Kilns Establishment Act (BMBKEA) 2013. The amendment set phased targets to reduce the use of clay-fired bricks in public works from 2019 to 2025, except for the construction of the base/sub-base of the highways. However, implementation of this phased reform is delayed. In other sectors, the GoB approved a framework for adopting a market-linked price adjustment system for high-speed diesel (HSD), heavy fuel oil (high-sulfur fuel oil, HSFO) and octane prices in 2024—although similar measures are rec- ommended for other types of fuels. The Power Division amended the 2016 Energy Efficiency and Conservation Rules in 2023 to systematically assess energy-saving potential and improve the energy efficiency of the largest consumers. These energy policies may generate emissions reductions and positively impact air quality. Regulations on heavy metals and other toxic chemicals. The ECR 2023 sets parameters on lead, mercury, arsenic, cadmium and other chemicals in the waste emissions and water quality standards. The rules also envisage maximum permissible levels of chemicals for key industries, including crude oil, pesticides, textile, fertilizer, paint, and battery manufacturing. Through Statutory Regulatory Orders (SROs), the Bangladesh Standards and Testing Institution (BSTI) sets testing methods and permissible limits for heavy metals in multiple products (for example, fertilizers, pesticides, starch and derived products, refined sugar and other food, solid biofuels, cosmetics, toys, paint, batteries, ceramic and glass dinnerware, and ceramic tiles) (BSTI 2021). Regarding lead, BSTI issued SRO No. 221-Law/2018 with three standards on household and home decoration paints, setting a total lead limit of 90 ppm (parts per million) in paint manufacturing and requiring manufacturers to obtain a license at BSTI.24 Since 1996, Bangladesh has gradually banned highly toxic pesticides (partially or completely), including the removal of class 1a and 1b pes- ticides from agriculture use, p,p-dichlorodiphenyltrichloroethane (DDT) and other persistent organic pollutants (POPs). In 2018, the GoB adopted the Pesticide Act, replacing the Pesticides Ordinance 1971 and the Pesticide Rules 1985. The Import Policy Order (2021–2024) issued by the Ministry of Commerce (MoC) bans the importation of industrial sludge and fertilizer, any kind of waste material, and chemicals controlled under the Stockholm Convention on POPs and requires DoE authorization to import ozone-depleting substances.25 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 44 Bangladesh’s Environmental Governance Framework In 1993, Bangladesh acceded to the Basel Convention on the control of transboundary movements of hazardous wastes and their disposal. However, there was no specific regulation for hazardous waste management within the country, which was par- tially covered by Hazardous Wastes and Shipbreaking Waste Management Rules, 2011. In 2021, in addition to the overarching Solid Waste Management Rules (SWMR), the MoEFCC adopted the Hazardous (E-Waste) Management Rules (EMR) and SRO No. 45-Act/2021 on battery recycling, which complemented SROs No. 175-Act/2006 and No. 29-Act/2008, covering clearance obli- gations, disposal of batteries, approved labs, restrictions on financial transactions for used/nonfunctional batteries, among other provisions. The EMR envisage a registration process before the DoE, in addition to the regular EC process, for manufacturing, trading, recycling, and operating other businesses related to electric and electronic equipment; maximum limits for the use of heavy metals and toxic substance in certain electronic products; EPR for collecting and management wastes from electric and electronic equipment; and sanctions for not complying with these regulations. The DoE is also working on new regulations and amendments, such as the amendment of the Medical Waste Management and Processing Rules, the Chemical Waste Management Rules, the Amendment of the Environment Court Act (ECtA); and the ratification of key international instruments, such as the Minamata Convention on Mercury, the amendment to the Stock- holm Convention on Persistent Organic Pollutants. Water and Sanitation regulations. The Water Supply and Sewerage Authority Act (WSSAA) 1996 regulated the country’s WSS framework, envisaging autonomous corporate management structures of Water Supply and Sewerage Authority (WASA). How- ever, industrial effluents are not covered by the WSSAA, and there was no reference for evidence-based, long-term planning for sustainable use and management of water resources. The Bangladesh Water Act 2013 and its subsequent Water Rules 2018 regulate the integrated development, management, abstraction, distribution, use, protection, and conservation of water resourc- es. This legislation provides for the right to water when it is used for the purposes of drinking, sanitation, and sewage disposal, regulates land ownership requirements, surface water, among other themes. In 2023, the Local Government Division adopted national Water Supply and Sanitation (WSS) Guidelines, which must be incorporated in legal framework of urban local govern- ment institutions (LGIs) by September 2023 for regulating WSS services at secondary cities (Pourashavas), including criteria and procedures for setting tariffs and service fees. Additionally, the ECA mandates the Director General (DG) of the Department of Environment (DoE) to conduct a drinking water quality surveillance program. 3.3 Institutional framework for environmental management Several government organizations have an important role in environmental management in Bangladesh, but the MoEFCC and the DoE hold the primary responsibility for environmental protection. Ministry of Environment, Forest and Climate Change (MoEFCC). The Ministry is the primary agency responsible for environmen- tal management, and it carries out its mandate through the operation of seven specialized agencies: the DoE, Bangladesh Forest Department (BFD), Bangladesh Forest Industries Development Corporation (BFIDC), Bangladesh Forest Research Institute, Ban- gladesh National Herbarium, Bangladesh Climate Change Trust (BCCT), and Bangladesh Rubber Board (BRB). The Parliament’s Standing Committee on Environment, Forest and Climate Change has the authority to oversee the functions of the MoEFCC. Parliamentary committees can directly question the minister to elicit information or organize parliamentary commissions to conduct investigations, raise the visibility of policy issues and make recommendations on how to improve the ministry’s perfor- mance (Ohiduzzaman 2010). According to the ECA, the Department of Environment is the primary agency entrusted with implementing the act. It carries out six key responsibilities: (a) monitoring environmental quality; (b) controlling and monitoring industrial pollution; (c) establish- ing regulations and guidelines for activities impacting the environment; (d) reviewing environmental impact assessments and managing the environmental clearance process; (e) promoting environmental awareness through public information programs; and (f) coordinating the implementation of a number of international protocols and conventions that Bangladesh has signed (ECA; Ferdous 2017; World Bank 2018). With a broad mandate, the DG of the DoE has the authority to take any necessary mea- sures to meet the objectives of the ECA, including the power to issue written notices to anybody, enlisting their assistance in discharging the DoE’s duties. The DG can adopt environmental standards to control and mitigate pollution, issue environmental clearances, and penalize a company or person for not complying with environmental standards or for damaging ecosystems. For example, based on such broad mandate, the DG has ordered industries and projects operating without an Environmental Clear- ance Certificate (ECC) to suspend their activities or has disconnected those facilities from water, gas, or electricity services. The DG also has legal authority to identify contaminated sites that pose risks to public health, conduct research, and collect, publish, and disseminate information to contribute to environmental awareness and education. Building on the ECA and the ECR, the BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 45 Bangladesh’s Environmental Governance Framework DoE must also work on guidelines for the DG mandate to avoid arbitrary decisions and ensure legal certainty for citizens. Those guidelines are also needed for other DoE’s enforcement activities (Section 3.5). The Ministry of Planning (MoP), especially through the Planning Commission, is responsible for fostering intersectoral coordina- tion among ministries and setting short-, medium-, and long-term strategic government goals. The MoP plays a powerful role in defining policies and resource allocation to accomplish these objectives, as well as in selecting public investment projects. As part of the MoP, the Bangladesh Bureau of Statistics (BBS) is responsible for providing statistical information to guide deci- sion-making and the development process. Under the Bangladesh Environmental Statistics Framework (BESF) 2016–2030, the GoB plans to implement an integrated approach to collecting, analyzing, and disseminating environmental data and informa- tion on the basis of national priorities and future plans. The Finance Division of the Ministry of Finance (MoF) is fundamental to develop an Environmental Fiscal Reform and to define fiscal instruments to operationalize the polluter pays and user pays principles. The National Board of Revenue (NBR), also under the MoF, collects tax revenues and, therefore, can advise on the use of different market-based instruments to control pollution, including environmental taxes or deposit and refund schemes. NBR is also responsible for the inspection of all chemical imports, keeping records of volumes and quantities of imported products into Bangladesh, including legally imported lead and lead compounds. Such information can be used to identify trends in lead use that should prompt additional government responses. The country’s central bank, the Bangladesh Bank (BB), has developed green financing policy and guidelines, established mini- mum targets of direct green financing for all banks and non-bank financial institutions, and created green concessional lending schemes to promote eligible green investments. Chapter 9 assesses the barriers to accessing these green financing schemes. The Ministry of Water Resources is primarily responsible for the development and management of Bangladesh’s water resourc- es, including surface and groundwater. However, there is no central institution governing the entire WSS sector in the country, and there is no formal regulator to approve water and sanitation tariffs—which are low and vary across consumer groups—and monitor service standards and performance of service providers. LGIs have conducted WSS functions through multiple agen- cies—such as WASAs in the case of City Corporations—in a disconnected and uncoordinated manner based on their own local regulations. LGIs are also tasked with providing services of public health, waste management, road networks, disaster manage- ment and urban planning. For this reason, the Ministry of Local Government, Rural Development and Co-operatives (MoLGRDC), which oversees all matters related to LGIs, play a key role in implementing environmental policies issued by MoEFCC. The core function of the Ministry of Industries (MoI) is to issue and oversee industrial policy, including methods and standards through BSTI. The ministry is also a member of various national committees with linkages with environmental management, such as the Climate Change, Climate Finance, and National Rivers Commissions and the recently created NCAPC. The Ministry of Commerce (MoC) has a mandate to promote better environmental management of import and export-oriented industries. The Import and Export Control Department, under the MoC, must ensure that imports and exports meet minimum environ- mental, health, and safety standards, including for harmful substances. The Ministry of Agriculture plays a key role in (a) supporting the development of new technologies to enhance agricultural productivity and distributing agricultural inputs (for example, urea and non-urea fertilizers); and (b) monitoring the content of pollutants and hazardous substances (for example, excessive amounts of lead) in food, including spices, fish and vegetables that have been identified by previous studies as containing high lead levels. The Bangladesh Road Transport Authority (BRTA), under the Ministry of Road Transport and Bridges, issues fitness certificates and conducts vehicle emission inspections, as delegated by the DoE based on ECA. The BRTA is also part of the NCAPC. The Ministry of Power, Energy and Mineral Resources is also crucial for improving air quality in Bangladesh because of its man- date over power generation and fuel quality. The Ministry of Labour and Employment, especially through the Department of Inspection for Factories and Establishments (DIFE), is responsible for ensuring the welfare, safety and health of valuable human resources working in various sectors contrib- uting to national development. The Directorate General of Health Services (DGHS), under the Ministry of Health and Family Wel- fare, leads efforts to develop and implement strategies to identify and protect populations at risk, including occupational health hazards such as battery recycling. DGHS can also collect routing health information, which could be expanded to monitor the health effects of environmental risks, such as blood lead levels or hospital admissions associated with air pollution and exposure to hazardous chemicals. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 46 Bangladesh’s Environmental Governance Framework 3.4 Institutional shortcomings at MoEFCC and DoE Even though a reasonably structured institutional framework for environmental governance is in place at the MoEFCC and the DoE, the framework’s actual operation is hampered by gaps and shortcomings in its organizational structure, insufficient bud- getary and human resources, challenges with coordination across agencies and with local governments, and limited environ- mental data management and evidence-based decision-making. 3.4.1 Organizational structure As for the DoE’s organizational design perspective, there was an increase in its specialized technical units in the past years, which are comprised of directorates on (a) environmental clearance, (b) monitoring and enforcement, (c) air quality, (d) climate change, (e) natural resource management (NRM), and (f) chemical and waste management. Other units cover administration, planning, information technology and legal matters (appendix K). Outside the Dhaka headquarters, the DoE operates through eight divi- sional offices (Dhaka, Chattogram, Rajshahi, Khulna, Barisal, Sylhet, Rangpur, and Mymensigh), two metropolitan offices (Dhaka and Chattogram) and 50 district offices. There is no DoE office in the remaining fourteen districts and at the Upazila (subdistrict) level (DoE 2023). Certain gaps in the DoE’s structure might compromise the fulfillment of the DoE’s mandate. By merging two key areas of re- sponsibility—environmental quality monitoring and environmental enforcement—under a single directorate, the DoE performs a broad range of activities with limited staff and technical capacity (sections 3.5 and 3.6). Although water pollution is a serious problem in Bangladesh, especially from industrial waste and inadequate WASH, the DoE does not have a specialized unit direct- ly focusing on water quality, and this function is partially covered by the NRM directorate because of its mandate over wetlands. Understaffing and lack of clear strategy for the new chemicals and waste management unit also hamper the control of lead and other heavy metals contamination. Although approved by the 4th meeting of the National Environment Committee in 2017, the establishment of a training and research center for environment and climate issues at the DoE is still under process (MoEFCC 2023).26 A potential overlap results from the NRM directorate’s oversight of ecologically critical areas management and biodiver- sity matters, while BFD also performs activities to “manage and conserve forest resources along with biodiversity and watershed management and development [… and] enforce laws and regulations for the protection and management of forest resources and wildlife as the custodian of the government forests.” (BFD 2018). Because of those shortcomings, before amending the ECA 1995 and setting clearer mandates for environmental governance, the GoB should proceed with a detailed analysis of the organizational structure under the MoEFCC and affiliated agencies. The analysis should identify gaps and overlaps in the institutional framework and recommend a restructuring process to address those deficiencies – either creating, removing or expanding units to increase efficiency across environmental agencies. For exam- ple, merging the NRM agenda and BFD’s mandate under a single department could be an option. This new specialized agency would cover all matters of NRM, including (a) ECA management, (b) forests, (c) biodiversity and biosafety, (d) water ecosystem management, and (e) land degradation management. In parallel, the DoE would focus on pollution management and environ- mental health issues. The DoE would keep some NRM specialists for enforcement and environmental clearance activities. In any case, for the greater interest of the country’s natural resources conservation and for its sustainable use, DoE and BFD must work together in their jurisdiction under the supervision of the MoEFCC. 3.4.2 Budget and human resources Despite some improvements, the MoEFCC is still underfunded. The ministry’s budget allocation was BDT 10.3 billion in fiscal year (FY) 2017, approximately $124 million and about 0.2 percent of the national budget. Since FY2020, when the country’s revised budget prioritized interventions to address the impacts of the COVID-19 pandemic, the MoEFCC annual budget has increased gradually, reaching BDT 15 billion in FY2023, approximately $142 million and equivalent to 1.5 percent of the national budget (table 3.1). However, a significant portion of that increase came with development projects, and because of some delays in their implementation, the percentage of unspent budget reached 11 percent in FY2021. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 47 Bangladesh’s Environmental Governance Framework Table 3.1 MoEFCC annual budget (per fiscal year) | BDT, thousands Unspent Allocated Budget Total Expenditure Fiscal Year Budget Management Development Total Management Development Total % 2018/19 82,034 52,008 13,4042 79,788 51,858 131,603 1.81 2019/20 54,841 34,334 89,175 50,455 33,906 84,362 5.39 2020/21 62,351 41,356 103,707 56,204 35,907 92,111 11.18 2021/22 67,109 55,269 122,378 63,910 47,101 111,011 9.23 2022/23 76,257 73,869 150,126 — Sources: MoEFCC 2023; MoF 2022. Note: — = Not available. Another challenge is ensuring the efficient use of resources and a more equitable distribution across the MoEFCC’s departments and associated agencies. Within the MoEFCC, the current institutional setup, budget allocation and staff distribution indicate a strong focus on forest-related issues. BCS has a specific Forest cadre, providing more stability, specialization, and promotion op- portunities for staff of forest-related agencies. There is no doubt that forests are extremely relevant to the country’s sustainability, resilience and livelihoods. In 2015, the forest cover in Bangladesh was 1.88 million hectares or 14.1 percent of the country’s land area, including approximately 1.2 million hectares owned by BFD (GoB 2020). However, the discrepancy in staff and budget allo- cation among the MoEFCC’s departments is not consistent with Bangladesh’s environmental priorities, as shown by the costs of environmental degradation (Chapter 2). The DoE’s annual budget accounts for 9.16 percent of the MoEFCC’s budget, compared to 69.39 percent of BFD’s budget. Although the DoE’s annual budget has also increased in the past years, reaching BDT 1.37 billion in FY2023 (approximately $12.9 million), it is still insufficient to fulfill its multiple functions (table 3.2). While Bangladesh aspires to become a middle-income country, the DoE’s approved headcount and budget are notably lower than that of environmental agencies of comparatively sized middle-income countries, where staffing data was available (table 3.3).27 The BFD should provide the benchmark, and the DoE’s budget and staff should be leveled up to those standards. Table 3.2 Human resources and general budget allocation (FY2023) of MoEFCC’s agencies Share of MoEFCC Approved Workforce in Vacant Annual budget Department annual budget Posts Service posts (BDT in thousand) (%) Secretariat, MoEFCC 184 125 59 26,684.00 17.77 Department of Environment 1,133 580 553 13,755.52 9.16 Forest Department 10,492 6,989 3,503 104,178.00 69.39 Forest Research Institute 769 389 380 4,846.00 3.22 Bangladesh National Herbarium 52 40 12 662.48 0.44 Bangladesh Forest Industries Development 6,563 5,029 1,534 0 0 Corporation (BFDC) Bangladesh Climate Change Trust (BCCT) 82 58 24 0 0 Bangladesh Rubber Board (BRB) 70 17 53 0 0 Sources: MoEFCC 2023; MoF 2022. Note: BFDC has its own budget as a state-owned enterprise. Since BCCT and BRB are included in the support budget category, they are not reflected in MoEFCC’s general budget. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 48 Bangladesh’s Environmental Governance Framework Table 3.3 Annual budget allocation and approved headcount in environmental agencies of selected countries Philippines Mexico (SEMARNAT,   Bangladesh (DoE) (Environmental PROFEPA, ASEA) Management Bureau) Country population (2022) 171,186,372 115,559,009 127,504,125 Country GDP ($) (2022) 460,200,000,000 404,280,000,000 1,410,000,000,000 Total approved agency (headcount) 1133 1772 9985 National population by employee, based on headcount 151,091 65,214 12,770 Environmental agency budget (FY2022) ($) 16,823,300 69,679,487 2,399,756,210 Environmental agency budget per capita 0.10 0.60 18.82 Environmental agency budget as share of national budget (per- 0.03 0.07 0.21 centage) Sources: GoM 2023; GoPh 2023; Secretaria de Hacienda y Credito Publico 2022; Note: In Mexico, data include aggregate budget for (i) the Ministry of Environment (SEMARNAT) for policy making; (ii) the Agency for Safety, Energy and Environment (ASEA), which approves environmental clearances and conducts environmental enforcement for the energy sector; and (iii) the Federal Attorney Office for Environmental Protection (PROFEPA), which oversees enforcement of environmental regulations.   Additionally, the sharp increase in the DoE’s budget in fiscal 2019 and fiscal 2022 is associated with development expenditures (for example, public investment projects, which are one-time budget for specific purposes) rather than management expen- ditures (for example, recurrent expenditures for carrying out core functions, such as public officials’ salaries, goods needed to provide services, social or economic interventions, and interest payments, among others) (table 3.4). In this context, the DoE must advocate for additional sources of revenue and identify ways to maximize resources allocated for environmental management. This could be done through market-based instruments (environmental taxes, pollution charges, service fees, green bonds, and so forth), earmarking of a portion of collected fines to environmental activities, partnerships with donors and the private sector, and the creation of a permanent Environment Fund. The latter could help the DoE mobilize sustainable financing for environ- mental conservation actions such as policy studies, research and development, technology pilots, and citizen engagement. Chapters 9 and 10 analyze policy options to maximize financing for environmental management. Table 3.4 DoE annual budget (per fiscal year) | BDT, thousands Allocated budget Total expenditure Revenue Fiscal year Management Development Total Management Development Total collection 2018/19 420,000 1,049,200 1,469,200 352,213 988,260 1,340,473 700,592 2019/20 500,000 123,300 623,300 360,680 67,231 427,911 676,732 2020/21 523,330 261,400 784,730 412,569 191,190 603,759 769,401 2021/22 614,190 955,900 1,570,090 481,869 669,312 1,151,181 972,078 2022/23 692,552 683,000 1,375,552 — Sources: DoE 2023; MoF 2022. Note: — = Not available. The rationale for budget allocation within the DoE is not clear either. Most financial and human resources seem to target the EC process, leaving even fewer funds for other key functions such as monitoring, enforcement, research, and policy making. Even though the DoE has an approved headcount of 1,133 posts, it operated with 580 staff in FY2022, as bureaucratic delays have stymied hiring the rest of the staff. According to the DoE, in addition to the currently approved posts, the DoE needs an addi- tional workforce of 3,259 staff to duly implement its mandate across the country (table 3.5). Staff shortage is particularly acute in the DoE’s divisional and district offices, which typically have five to six staff and three staff, respectively. Instead of performing specialized activities and reporting to a thematic directorate, local staff are responsible for multiple functions, from processing BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 49 Bangladesh’s Environmental Governance Framework environmental clearance files to carrying out remediation and enforcement actions. They are responsible for overseeing all in- dustries and development activities that require compliance within their jurisdiction and nearby districts where the DoE does not have an office. Table 3.5 Approved and hired staff in the Department of Environment (number) Additional posts Category Approved staff Employed staff Vacant posts required Officer Class 1 274 823 Director General 1 0 Additional Director General 1 0 Deputy Director General 0 2 Director 23 31 Deputy Director 58 198 Senior System Analyst 1 0 223 51 Environmental Magistrate 8 12 (Executive Magistrate) Assistant Director 120 372 Senior Chemist 39 183 Research Officer 7 4 Accounts Officer 7 14 Librarian, Scientific Officer, Assistant Programmer, others 9 7 Officer Class 2 201 64 137 743 Inspectors, junior chemists, others Supporting staff Class 3 428 204 224 1,215 Supporting staff Class 4 230 89 141 478 Total 1,133 580 553 3,259 Source: DoE 2023. However, having a larger number of approved staff might not result in improvements in the DoE’s performance if those positions remain vacant or are not filled by professionals with relevant technical backgrounds. The DoE’s staff is mostly comprised of gen- eralists from other cadres of the BCS, as there is currently no dedicated environment cadre. This lack of a specialized professional development path within the DoE serves as a disincentive for professional staff with relevant technical qualifications and exper- tise, leading to frequent turnover as they pursue opportunities in the private sector or other government agencies after hitting the internal “glass ceiling” (World Bank 2018). In this context, despite regularly recruiting staff, the DoE faces difficulty in retaining its experts and filling vacant positions. The absence of an environmental cadre also has implications at the leadership level. In some cases, senior officials who are well-intentioned may lack the technical expertise to fully assess the implications of important decisions they make. In addition, members of the civil service cadre often reach these leadership positions when nearing retirement, which can also contribute to frequent turnover. This constant rotation of senior officials without a background in the field results in a continuous need for learning and adaptation, which also affects the DoE’s performance. Staff shortage, coupled with weak technical capacity, has implications for the quality of the DoE’s services and its capacity to monitor environmental quality and compliance with environ- mental standards. These limitations are particularly evident in the districts where the DoE lacks a physical presence, resulting in challenges in verifying all regulated entities (Iftekharuzzaman 2022). 3.4.3 Coordination across agencies and with local governments Strengthening the MoEFCC’s capacity to coordinate with and provide guidance to other ministries and agencies, such as the MoI and the MoC, in addressing environmental priorities is a pressing need. While most private industries are not under the direct BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 50 Bangladesh’s Environmental Governance Framework control of the MoI, this ministry could contribute more to (a) improve the environmental performance of industries by promot- ing resource-efficient and cleaner production (RECP), (b) strengthen testing and standards on chemicals and other pollutants through BSTI; and (c) foster stronger environmental management systems in the public corporations it oversees in the chemical, sugar and food, steel, and vehicle sectors, as well as in the industrial estates for cottage industries that it manages (World Bank 2018). In addition, the MoEFCC and the MoC could enhance coordination to attract sustainable investment in export-oriented industries. The MoC’s Export Policy (2021–2024) aims to improve the quality of export products, enhance quality control and certification systems to meet global standards, encourage the use of advanced, sustainable, and environmentally friendly tech- nologies to ensure standards and compliance, foster the production of high-value export products, and promote excellence in fashion and design. The DoE, DGHS, and DIFE should better coordinate their efforts for policy formulation, on-site inspections, training, awareness campaigns and other activities related to environmental health, work conditions, and OHS. Although the activities of other sector agencies can have significant impacts on environmental management, these agencies do not always prioritize environmental compliance and research and innovation in green technology. The MoEFCC also faces chal- lenges in influencing the work of other line ministries that make decisions with profound environmental implications, such as setting fuel prices or environmental taxes (Ahmed 2017). Such limited capacity is associated both with political power asymmetries between government agencies and staff constraints at the MoEFCC and the DoE to provide technical support during such interac- tions. There have been instances when government institutions have requested the MoEFCC’s and the DoE’s support and have not received it because of technical capacity constraints. The recently established NCAPC is expected to address coordination short- comings in AQM. Similar initiatives should be considered to enhance institutional coordination for other environmental priorities. Coordination with key stakeholders is crucial for learning and improving environmental decision-making. Formally, progress in implementing environmental policies and programs is assessed by the establishment of steering committees with members from relevant ministries and line agencies. The routine review mechanisms of these committees comprise monthly coordina- tion meetings, monthly Annual Development Program (ADP) progress review meetings (physical and financial), Implemen- tation, Monitoring and Evaluation Division reviews, and development partners’ mission reviews (for donor-funded programs). Independent reviews are also undertaken occasionally. However, review mechanisms lack a quantitative monitoring and eval- uation framework, are not underpinned by comprehensive data on environmental conditions, have no participation of stake- holders other than government officials, and can be subject to political bias and influence (Ahmed 2017). Vertical coordination is also critical for the successful decentralization of DoE’s functions. Local interests tend to motivate faster environmental degradation and natural resource depletion. Thus, there are good reasons to advance the decentralization of environmental management responsibilities, including the capacity to respond more effectively to local challenges. Since envi- ronmental problems are typically felt locally, district offices are often in a better position to address environmental problems in a more efficient way. However, without proper supervision from the Head Office, coordination and relatively similar institutional capacities across the local offices, decentralization may lead to significant differences in environmental quality across regions. In this context, the 8th Five-Year Plan (2021-25) (8FYP) mentions that the GoB will promote decentralization of environmental management based on international best practices (GED 2020). In this process, the DoE’s Head Office has kept functions that cannot be successfully decentralized as failure to fulfill them would potentially harm the environment and the population, such as (a) mandate over transboundary issues; (b) coordination of regional, divisional, and district offices, including collaboration and sharing of good practices, and monitoring and evaluation of environmental programs that impact multiple regions; (c) processing environmental clearance applications for industries and projects that extend to two or more departments; and (d) research relat- ed to climate change, air pollution, biodiversity, or water issues that affect multiple subnational areas, as well as multiple countries. In parallel, the DoE has empowered subnational offices with responsibilities in environmental clearance, monitoring, and en- forcement. In the medium term, more responsibilities could be delegated to local offices. This would help promote and facilitate public participation to foster greater political and cultural representation and transparency in the environmental decision-mak- ing process. These efforts would also contribute to following up on local environmental concerns and disseminating relevant information to constituents and stakeholders. In that process, the DoE must also consider political economy dynamics, the nature of the most serious environmental problems, and the actual strengths and weaknesses of both public and private sector organizations at different geographic levels. Decentralization should also involve local governments, as they hold a major responsibility in implementing environmental regu- lations approved by the MoEFCC. However, the absence of a clear role for and limited capacity of LGIs in environmental manage- ment is another major institutional weakness in responding to priority environmental challenges. Although the MoEFCC and its departments, especially the DoE, are mandated with policy formulation, environmental clearance, monitoring and enforcement, BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 51 Bangladesh’s Environmental Governance Framework other important roles and responsibilities that contribute to urban sustainability and climate resilience have been decentralized to city-level institutions. Some of those roles are related to NRM, industrial planning, land use, zoning, and management, as well as the provision of municipal services like WSS and solid waste management (SWM). However, Bangladesh remains among the most fiscally centralized countries in the world. LGIs account for only 7 percent of the country’s expenditures and 1.6 percent of total government taxes in Bangladesh (GED 2020).28 Transfers of resources from the central government to LGIs for the latter’s discretionary use, in the form of block grants, are even more limited—about 12 percent of total expenditures by LGIs in Bangladesh.29 In addition, until recently, transfers from the central to local govern- ments had no clear criteria, frequently determined by the political affiliation of locally elected managers, rather than the actual needs of the local population or a clear prioritization process (GED 2020). For example, an analysis of climate change transfers found that, even though poorer populations in rural areas faced higher climate change risks, they had received a mi- nor portion of funds allocated for climate change adaptation. About 82 percent of such funds had been allocated to City Cor- porations and Paurashavas, while Zilla Parishads had only received 18 percent of the allocated resources (Sharmin et al. 2017). With the amount of transferred funds being unpredictable, particularly to cover discretionary expenditures of LGIs, adequate planning at the local level has been virtually impossible (GED 2020). Constraints in technical capacity for designing priority inter- ventions, financial reporting, and public participation in decision-making also affect local planning systems. Consequently, those weak financing and planning systems have affected the delivery of basic services in Bangladesh and led to poor accountability of LGIs, especially City Corporations and Pourashavas (urban LGIs). To start addressing that, in February 2023, the MoLGRDC intro- duced a new requirement for block grant allocations to urban LGIs—that is, at least 10 percent of those transfers from the central government must be used for green and climate resilient (GCR) priority activities. Urban LGIs will have the discretion to select the specific GCR actions based on the list of GCR goals and priority interventions extracted from the 8FYP and as specified in the corresponding circular.30 As the next steps, the MoLGRDC is developing technical standards and procedures for local planning, including channels for monitoring and evaluation and ongoing stakeholder engagement. By 2025, the MoLGRDC plans to ex- pand the block grant system reform to further incentivize urban LGIs to invest in GCR interventions by introducing performance criteria linked to GCR spending for allocating overall block grants. 3.5 Monitoring and evidence-based planning Despite evidence on the major categories of environmental degradation in Bangladesh (Chapter 2), those key environmental health and pollution issues have received insufficient attention in the high-level policies, instruments, and budget allocations of recent years. In the case of lead exposure and indoor air pollution, the GoB has yet to define clear policies and an institutional framework to tackle these issues, including clear responsibilities and timelines to tackle these risks. This misalignment between environmental priorities, institutional efforts, and resource allocation is largely due to (a) the absence of an integrated system of reliable data and organizational capabilities to provide analytical support to the decision-making process, (b) the lack of repre- sentation of vulnerable groups that are mainly affected by environmental degradation, and (c) the absence of a formal planning mechanism for allocating financial and human resources according to clearly defined environmental priorities that are linked to poverty alleviation and social priorities. The DoE has limited capacity to conduct research, to properly monitor environmental quality and pollution discharges and, based on those findings, to inform policy formulation and environmental decision-making—for example to identify pollution hotspots and priority actions. Environmental monitoring capacity is constrained by various factors, including the absence of reliable time series data on the state of the environment and natural resources, the lack of a system of outcome-focused in- dicators of environmental quality, and insufficient resources to ensure an adequate institutional presence in the field—such as human resources, monitoring devices, laboratory facilities, and information systems. Ambient air quality data collection has improved over time. The first full-fledged Continuous Air Monitoring Station (CAMS) un- der the DoE was set up in 2001. There are now 16 continuous air monitoring stations, complemented by 15 compact monitoring stations (DoE 2018; GED 2021). These monitoring stations measure concentrations of five criteria pollutants (particulate matter— PM2.5 and PM10, O3, SO2, NOX, and CO)31 every minute and transfer this data every 15 minutes to the DoE’s central office, where they are stored. While the World Bank-funded “Clean Air and Sustainable Environment” (CASE) Project was operational (2009-19), it generated monthly air quality reports summarizing collected air quality data. After that, the DoE had not published air quality reports periodically. In November 2023, the DoE started disclosing the Air Quality Index in its website, to inform a wide audience about air quality and the recommended actions under different levels of air pollution. While recognizing the DoE’s progress in establishing a network of reliable air quality monitoring stations, further strengthening is necessary to address the following chal- lenges: (a) current number of existing stations is insufficient for the entire country, and difficulties persist in identifying suitable BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 52 Bangladesh’s Environmental Governance Framework sites for additional stations within populated cities; (b) temporary shutdowns or defects in monitoring devices due to the lack of direct business presence of equipment manufacturers combined with inadequate procurement planning for spare parts; (c) ab- sence of qualified local staff, complicating operation and maintenance of imported equipment; (d) power disruptions, affecting instrument stability and data integrity; (e) limited capacity to monitor emissions from stationary and mobile sources; and (f) need to enhance the AQI system for a more agile calculation and dissemination, using an user-friendly approach. Regarding water quality, the GoB has no continuous surface water quality monitoring stations to assess real-time water quality in Bangladesh rivers, targeted international rivers, and effluent treatment plants. Challenges in the use of statistical methods used for sampling (for example, the uncertainty level associated with the sampling results) have also affected the validity and representativeness of the environmental data. As a result, the aggregate results of envi- ronmental quality data in air and watersheds are not always reliable and, therefore, of limited usefulness for environmental policy formulation. Poor analysis also hampers monitoring efforts, as third-party laboratories undertake most of the analysis of samples for industries and projects, and the authorities do not maintain rigorous quality control amongst the labs. Additionally, even when information exists, it cannot easily be shared across agencies involved in different aspects of environmental quality control, as the country lacks established norms for inter-operational processes to facilitate information exchange among the agencies. The lack of outcome-focused monitoring and evaluation processes poses additional challenges in environmental planning. Although the MoEFCC must achieve annual targets under the 8FYP and, like the DoE, implement its commitments under the ADP, these planning instruments are not sufficient to fully assess institutional performance and improvements in environmen- tal quality. ADPs are budget and output-oriented and do not set specific outcomes and results indicators. Although part of the 8FYP targets could measure outcomes, those indicators lack precision and focus mostly on outputs—such as approval of new regulations or broad activities that are not linked to specific targets (for example, “Develop more bilateral and multilateral en- gagements”) (GED 2022). The DoE also lacks a comprehensive information system to effectively manage monitoring and enforcement information, as well as handle environmental complaints from citizens. Regarding transparency, the DoE publishes an annual report of its activities and thematic studies and has used an information system to process ECCs. However, there are no systematic publications on environmental quality data in a user-friendly format to citizens or detailed information about its enforcement activities, such as industry names, types of violations and fines imposed during inspections. BBS also faces constraints to gather, process and disseminate timely environmental data (appendix L). Specific challenges to implement the BESF include (a) lack of inter-ministerial and inter-agency coordination; (b) lack of a common format and plat- form for collecting, organizing and sharing environmental data; (c) absence of proper mechanisms to ensure the quality of data provided by respective responsible government agencies; (d) insufficient financial resources and inefficient methods for data collection, compilation, processing, and dissemination of environmental data; (e) absence of designated focal point officers in respective data providing government agencies; (f) shortage of skilled human resource capacity; (g) overly ambitious goals for data production that lack prioritization, among others. 3.6 Environmental enforcement 3.6.1 Mandates and regulations Department of Environment. The ECA mandates the DoE to enforce environmental law in Bangladesh, especially the Act and its associated rules. Those enforcement powers include, among others, (a) searching any place, examining any equipment, man- ufacturing or other processes, ingredients, or substance for the purpose of improvement of the environment, and control and mitigation of pollution; (b) take samples of air, water, soil or other substance for analysis.; (c) collect, publicize and disseminate in- formation regarding pollution; (d) order the closure, prohibition or regulation of any industry, undertakings, or processes; (e) seize any equipment, industrial plant, record, register, document, or other material that may be used as evidence of the commission of any offense punishable under the ECA or associated rules. The DoE can also confiscate materials and equipment involved in the offense, as well as cut off water, electricity, and other services from the offenders’ facilities. Mobile and Environmental courts. The Bangladesh Supreme Court, particularly the High Court Division, enforces environmen- tal rights by exercising its constitutional power of judicial review, especially through writ petitions in public interest litigation. In addition, as per the ECtA 2010, specialized environmental courts receive and decide on judicial cases for violation of statutory environmental laws. These specialized courts can also intervene to protect people’s constitutional right to a safe environment BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 53 Bangladesh’s Environmental Governance Framework and balance the interests of multiple stakeholders, including future generations. The ECtA contemplates three types of environ- mental courts: (a) the Special Magistrate Court to adjudicate petty offenses, (b) the (Divisional) Environment Courts to decide on major violations, and (c) the Environment Appellate Court to hear appeals and review petitions in relation to decisions of the other two courts (Mulqueeny, Bonifacio, and Esperilla 2010, 288). Most special magistrates perform their duty in mobile courts, which are special courts that can move from one place to another, as needed to maintain law and order and to prevent offence immediately, by taking cognizance of offences immediately and giving prompt sanction (Mobile Court Act 2009). Expertise in environmental law is not a prerequisite, and any judge can be a member of environmental courts. In the case of mobile courts, the role of special magistrates can be performed by members of the executive branch. Although the ECtA aims to ensure the presence of at least one environment court in each district, it does not mandate their establishment as a separate or inde- pendent court. As a result, the GoB has established only four environmental courts to date, three district-level courts in Dhaka, Chittagong, and Sylhet, and an appellate court in Dhaka. Special magistrates can also conduct their judicial mandate at the DoE rather than in courts. In May 2023, there were five special magistrates performing their functions at the DoE (out of eight envisaged in the headcount), including the Director of the DoE’s Monitoring and Enforcement Wing (MEW), who has also been appointed as a special magistrate. The environmental courts’ jurisdiction covers issues regulated by the ECA, other laws published in the government’s gazette with explicit reference to such jurisdiction, and the rules made under these laws. Thus far, in addition to the ECA and ECR, environmen- tal courts have considered only the BMBKEA as “other law published in the official gazette.” The Act also bars individuals from directly filing suits to the court, thereby further limiting the courts’ capacity to uphold environmental justice. Affected individuals must first file a complaint with the DoE. The DG will assign a DoE inspector to investigate such a claim and prepare a written re- port for the DG’s review and decision on whether to take judicial action. However, the court may consider a direct claim from an individual if they had submitted a written report to the DoE, and after 60 days have elapsed since the submission, the DoE has not taken any investigative action. Even then, the court must offer the DoE adequate opportunity to rationalize its inaction. Inspections. The DoE performs enforcement inspections through its MEW alone or in coordination with mobile courts. The wing has a mandate over the entire country and all matters under environmental law, such as effluent treatment and emissions limits from industries. In addition to regular inspections, the MEW acts when (a) district offices and laboratory offices find irregularities in environmental quality standards or in emissions and effluents limits in certain areas or specific industries or projects and (b) cit- izens complaint to the DoE about environmental noncompliance and damages. To conduct activities outside Dhaka, the MEW requires support from inspectors at district or divisional offices. In parallel, mobile courts have a mandate to inspect industries, projects, and individuals for compliance with environmental regulations on (a) polythene ban, (b) vehicle emissions standards, (c) brick kilns, and (d) construction materials. At mobile courts, the special magistrate may acknowledge an offense directly upon complaint by the DoE inspector or authorized officer without following further formalities. If the applicable penalty exceeds 5 (five) years of imprisonment or 5 (five) lac taka in fines, the special magistrate must refer the case to the Environment Court. Penalties. Section 15 of the ECA sets forth penalties for violations of its provisions or for noncompliance with DG’s directions (ta- ble 3.6). Only a Special Magistrate or Environmental Court can impose those penalties. In addition, ECA Section 15(2) states that rules under that Act can specify certain offenses and their corresponding penalties, although the sanctions so specified shall not exceed imprisonment for two years or a fine of Tk 2 lac or both, and there is no reference of increased fines in case of subsequent offenses. The ECR, EMR, SWMR, APCR, and BMBKEA set forth penalties based on those parameters. The DoE does not receive a portion of the collected proceeds from environmental penalties, which are not earmarked to finance environmental management initiatives. Additionally, setting specific fine ranges through an act (law) has impeded the Govern- ment from regularly updating their value, as an amendment to a law requires years of drafting, consultations, and discussion at the Parliament. As per ECA Section 15 (last updated in 2010), the maximum fine amount is BDT 1,000,000 (equivalent to ap- proximately $9,400), applicable in cases of subsequent offenses. Considering a depreciation of 56.76 percent in the BDT value between 2010–2023, the maximum fine should be updated to at least BDT 2,167,178 to keep its value.32 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 54 Bangladesh’s Environmental Governance Framework Table 3.6 Summary of applicable penalties per ECA Section 15 TYPE OF OFFENSE APPLICABLE PENALTY Noncompliance or violation of direction(s) ECA section First offense Each subsequent offense regarding the following: Subsection (2) Measures ordered by DG for the conserva- Imprisonment minimum 1 Imprisonment 2 years, not exceeding or (3) of tion of the environment, improvement of year, not exceeding 2 years, or a 10 years, or a fine of 2 lac taka, not section 4 environmental standards, and the control fine minimum of 50 thousand exceeding 10 lac taka, or both. and mitigation of environmental pollution. taka, not exceeding 2 lac taka Directions may include closure, prohibition or both. or regulation of any industry, undertakings, or processes. Section 5, Continuing activities or processes or initiat- Imprisonment, not exceeding 2 Imprisonment 2 years, not exceed- sub-sections (1) ing activities or processes are prohibited in years or a fine not exceeding 2 ing 10 years or a fine 2 lac taka, not and (4) ECA. lac taka or both. exceeding 10 lac taka or both. Section 6, Restrictions regarding vehicles emitting Fine not exceeding taka 5 Second offense: fine not exceeding sub-section (1) smoke injurious to the environment. thousand. taka 10 (ten) thousand. Each subsequent offense: imprison- ment not exceeding 1 year or a fine not exceeding taka 10 (ten) thousand or both. Section 6A (a) Manufacture, import, and marketing of (a) Imprisonment not exceed- (a) Imprisonment for 2 years, not ex- polythene products. ing 2 years or a fine not exceed- ceeding 10 years or a fine of 2 lac taka, (b) Sell, exhibit for sell, storage, distribution, ing 2 lac taka or both. not exceeding 10 lac taka or both. transport, or use for sale of polythene prod- (b) Imprisonment 1 year or a (b) N/A ucts. fine not exceeding 50 thou- sand taka or both. Section 6B Restriction on cutting hill. Imprisonment not exceeding 2 Imprisonment 2 years, not exceed- years or a fine not exceeding 2 ing 10 years or a fine 2 lac taka, not Section 6C Restriction on production, import, storage, lac taka or both. exceeding 10 lac taka or both. loading, transportation, and so forth of haz- ardous waste. Section 6D Restriction on pollution due to ship breaking. Section 6E Restriction on water reservoir. Section 7, Compensation and remediation of any act Imprisonment minimum 1 Imprisonment 2 years, not exceeding Sub-section (1) or omission of a person that is causing or year, not exceeding 2 years or a 10 years or a fine of 2 lac taka, not has caused, directly or indirectly, injury to fine minimum of 50 thousand exceeding 10 lac taka or both. the ecosystem or to a person or group of taka, not exceeding 2 lac taka persons. or both. Section 9, Control, mitigate, and immediately report Sub-sections (1), to DoE the discharge of environmental (2), and (3) pollutants above the prescribed limits due to accidents or other incidents. Failure to adopt remediation measures as per DG direction. Section 10, Failure to render, without reasonable excuse, Imprisonment minimum 1 N/A sub-section (2) assistance, or cooperation to the DG or au- year, not exceeding 3 years or thorized person. a fine of 50 thousand taka, not exceeding 3 lac taka or both. Section 12 Environmental Clearance Imprisonment minimum 2 N/A Certificate. years, not exceeding 5 years or a fine of 1 lac taka, not exceed- ing 5 lac taka or both. Any other provision of the ECA, a direction Imprisonment not exceeding 3 N/A issued under the rules, or obstructing the years or a fine not exceeding 5 DG or authorized person in discharging his lac taka or both. duties or intentionally delaying the discharge of such duty. Source: ECA 1995, as amended in 2000, 2002, and 2010. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 55 Bangladesh’s Environmental Governance Framework 3.6.2 Trends in enforcement activities After the EC system, Bangladesh uses Command and Control (CAC) as its major environmental policy instrument. Although it is technically simple to impose regulations with specific fines for noncompliance, data from Bangladesh show significant problems in implementing those regulations, especially when enforcement authorities have limited capacity, and polluters do not have incentives to comply with the law. CAC policies are not feasible for all types of pollution sources—for example, it would be impos- sible to enforce a regulation banning the use of solid fuels for cooking, which is the major source of air pollution in Bangladesh (chapters 2 and 6). Factors affecting low compliance with existing CAC instruments include the ad hoc application of the polluter pays principle, with low and/or arbitrary fines and sanctions that are not able to deter polluting activities. From 2010 to 2018, the DoE imposed 2,800 counts of fines on industries and projects. Textile and fabric industries accounted for 47 percent of noncompliance counts (followed by 17 percent in brick kilns) and 67 percent of collected fines among all types of industries. Most enforcement activities focused on violations that contributed to water pollution (54 percent of noncompliance instances) (Ahmed, Hasan, and Sarwar 2021). The same study found no difference in mean fines among the first, second and third instances of violations, revealing that the DoE did not impose higher fines in case of recidivism. The number of DoE staff continues to be inconsistent with the increasing number of industries over the years, which limited en- forcement activities. The MEW has only 14 officers in service at headquarters (out of 17 posts envisaged in headcount) dedicated to monitoring 40,000 industries across the country and receives limited support from local offices, which makes enforcement activities beyond city centers even more difficult. Divisional and district offices have 37 staff (out of 61 posts of headcount) to support monitoring and enforcement activities. From July 2021 to June 2022, the DoE imposed sanctions on 2,157 individuals, institutions, industries, and projects (hereinafter “entities”) involved in environmental pollution, illegal hill-cutting and filling of reservoirs, including damage to the environment and surroundings throughout Bangladesh. Still, considering the country’s pollution rates, those enforcement activities are modest. In those operations, under ECA Section 7, the DoE imposed compensations for the environmental damages to a few entities, in the total amount of BDT 510 million, out of which it collected BDT 247.7 million, the highest collected amount since FY 2012/13 (table 3.7). Table 3.7 Levy and recovery of compensation for environmental damage as per Section 7 of ECA Number of Imposed compensation Collected compensation Collected vs. imposed Fiscal year sanctioned entities (BDT) (BDT) compensation (%) 2010/11 343 312,700,000 150,500,000 48.13 2011/12 503 499,000,000 363,900,000 72.93 2012/13 510 384,700,000 336,200,000 87.39 2013/14 395 438,500,000 212,200,000 48.39 2014/15 422 397,200,000 227,800,000 57.35 2015/16 398 286,600,000 112,300,000 39.18 2016/17 1,049 189,300,000 142,100,000 75.07 2017/18 571 192,300,000 114,700,000 59.65 2018/19 875 196,700,000 113,800,000 57.85 2019/20 1,313 584,900,000 141,300,000 24.16 2020/21 1,313 688,700,000 109,000,000 15.83 2021/22 2,157 510,700,000 247,700,000 48.50 Total 9,859 4,681,300,000 2,271,500,000 48.52 Source: DoE 2022 The low collection rates are also associated with loopholes in the system, such as polluters’ appeals to courts. There are no re- quirements for alleged offenders to pre-deposit in a judicial account at least part of the imposed fine as a condition to file ap- peals.33 The latter is also motivated by imprecise regulations and excessive discretion of environmental officers, which may lead to errors and arbitrary decisions. For example, there is no specific guideline for the installation and operation of effluent treat- BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 56 Bangladesh’s Environmental Governance Framework ment plants, for vehicle emissions control, chemicals and hazardous waste management, among other relevant topics. The lack of information on the DoE’s website on specific violations constitutes an additional driver for noncompliance with environmental law by impeding citizen-driven accountability. In the calendar years 2021 and 2022, special magistrates conducted 1,979 mobile courts in collaboration with the DoE (tables 3.8 and 3.7). Although mobile courts are more effective than regular MEW inspections, they can only act on pollution cases related to the polythene ban, vehicle emissions, brick kilns and construction materials. Therefore, the number of enforcement actions is modest, considering approximately 40,000 industries and 578,151 vehicles in the country in 2022 (BRTA 2022). Industries and projects are typically inspected as part of the EC process when developers expect an on-site visit from the DoE and in some cases are previously informed about the date of such visit. As for vehicles, there is only one BRTA center conducting vehicle in- spections using advanced equipment, and road inspections by mobile courts and police are limited to visual inspections to spot gross polluter vehicles. Table 3.8 Enforcement activities by mobile courts in calendar years 2021 and 2022 Number of Penalties Number of Year mobile courts Monetary penalty cases filed a Imprisonment Other operated imposed (and collected) 123 brick kilns halted operations. 2021 923 2,567 BDT 89,722,526 33 individuals 125 tonnes of polyethene seized. 2022 1,056 3,109 BDT 97,028,227 2 individuals 56.2 tonnes polyethene seized. Source: DoE. Note: a Multiple cases can be filed in a single operation. Table 3.9 Enforcement activities by mobile courts in fiscal 2022 (July 2021 – June 2022) Mobile Penalties Pollution source / natural courts Cases filed a resource depletion Fines (BDT) Imprisonment Other operated 119 tonnes of polythene granules and Polythene 148 377 3,481,200 raw materials seized Black smoke from vehicles 19 138 200,700 Brick kilns 278 681 182,848,500 129 brick kilns closed Cutting hills 15 21 1,035,000 Filling water bodies 11 20 395,000 Stone crusher 11 214 4,934,002 2,000 kg of lead (Pb) seized One month Three power generators seized Additional pollutants 91 207 6,375,104 imprisonment Utility connection discontinued in 22 to 13 persons factories Air pollution by construction 52 173 1,756,000 materials Noise pollution 96 483 616,500 29 vehicle horns Saint Martin Island (ECA) 25 27 462,000 Total 746 2,341 202,104,006 Source: DoE 2023. Note: a Multiple filed cases can be filed in a single operation. Other challenges for enforcing CAC instruments refer to (a) the DoE’s limited coordination with other public agencies and local governments, for example, for targeting enforcement to pollution hotspots and sharing information, facilities, and equipment; (b) limited staff at the DoE to prepare the documentation needed to file and participate in judicial cases; (c) bottlenecks at en- vironmental courts and delays in judicial cases, especially appeals from project developers against sanctions, which hampers fine collection by the DoE. Political interests also interfere with stricter environmental enforcement in Bangladesh (Ferdous 2017; Iftekharuzzaman 2022). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 57 Bangladesh’s Environmental Governance Framework Since ECtA’s enactment, the DoE has filed very few cases in the existing environmental courts. From July 2018 to June 2022, the DoE filed 465 and 358 cases before the special magistrate courts and environmental courts, respectively (table 3.10). As a court order is a condition for imposing penalties under ECA Section 15, the number of individuals and industries being sanctioned for their environmental offenses is minimal. Additionally, since the DoE does not have enough staff to follow up on those cases after filing them, the Department does not know the results of judicial orders, such as the value of fines imposed by the court and their enforcement. With limited staff, the DoE’s Law Wing focuses on cases at the high court, mostly related to appeals from brick kilns to rejected ECC applications. As of September 2022, there were 590 and 934 pending cases in the special magistrate court and environmental courts, respec- tively. To overcome such backlog, environmental interest groups, including NGOs, have filed public interest litigations before the Supreme Court on environmental matters. As a result, as of September 2022, there were 1,325 pending cases of environmental na- ture in the High Court Division out of 2,028 writ petitions. The DoE has provided 1,033 compliance reports in those cases (DoE 2023). Table 3.10 Cases filed by DoE, charge sheets or investigation reports issued in the environmental courts Special Magistrate Court Environment Court Fiscal year Investigation reports / Investigation reports / Filed cases Filed cases charge sheets filed charge sheet filed 2018/19 86 48 34 35 2019/20 75 48 126 42 2020/21 71 50 150 145 2021/22 233 177 48 125 Total 465 323 358 347 Source: DoE. A key driver to the limited number of cases filed in Bangladesh’s environmental courts is the legal requirement for the DoE to for- mally support any claim presented to a court. Most individuals, but particularly those with limited resources, are unable to follow the lengthy procedure before the DoE and later at environmental courts. Coupled with the small sanctions that the court can impose even to those who have committed grave environmental offenses, the current institutional framework has contributed to cultivating a culture of impunity for polluters. Under these conditions, the courts are unable to perform their duty as indepen- dent and appropriate forums for resolving environmental disputes (Preston 2014, 368). Under its current design, the ECtA can also give rise to a conflict of interest. For instance, the DoE itself may be allegedly respon- sible for violating provisions of the ECA. Even under such a scenario, the court requires a written report from a DoE official to formally consider the case. The current system is also inadequate to respond to situations where a powerful government agency or influential corporation is responsible for violations of ECA provisions. The DoE has never filed a civil or criminal case against another government department, even though there have been high-profile cases documenting such violations. These circum- stances undermine trust in the courts and their legitimacy (Hasanat 2021). The lack of specialized judges also undermines the courts’ performance. The GoB can appoint nonspecialized judges and mag- istrates to environmental courts in addition to their general role in non-environmental cases. However, Bangladesh’s courts already face constraints by a limited number of judges and magistrates, and increasing the requirements needed to serve in an environmental court may have the unintended consequence of leaving environmental courts without a judge (Rahman 2020). Although this analysis recommends extending the legal standing before environmental courts to all citizens, the GoB shall ac- company this reform with adequate resources to avoid an additional backlog of judicial cases. An alternative could be to ensure, by amending the ECtA, that judges have access to external experts who can contribute knowledge and evidence on highly technical and scientific issues. The ECtA does not contemplate the appointment of independent environmental experts to advise the courts, which rely only on the testimony of government staff as experts, despite the potential conflicts of interest mentioned above (Mia 2015). It is a good practice for environmental courts and tribunals around the world to allow for the participation of independent experts to help judges and other stakeholders understand complex scientific and technical issues. Environmental courts comprising a judge, an environmental expert, and experts in other fields (for example, economics) have been effective in crafting judicial rulings that balance the economic interests of enterprises and the environmental damages caused by them (Bjällås 2010, 180–83). In coordi- BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 58 Bangladesh’s Environmental Governance Framework nation with other agencies, the DoE could also issue manuals and support the training of magistrates on relevant environmental issues, such as impacts of pollution, parameters to determine a penalty based on the damage, capacity payment of the offender, and recidivism, among other topics. The High Court has developed more confidence in the DoE’s compensation calculation methodology and has increasingly ap- proved the DoE’s method of collecting compensation, even instructing it to calculate compensation on the court’s behalf (World Bank 2018). However, the DoE still faces challenges to collect fines and compensation. Bangladesh lacks a modern, transparent, rule-based system for applying the polluter pays principle and increasing the effectiveness of oversight activities. Such a system, coupled with reforms in ECA and ECtA, automated monitoring and disclosure of enforcement data, could reduce errors and arbitrary decisions, providing legal certainty to business developers, incentives for complying with the legislation and decreasing appeals of such sanctions. Additionally, the GoB should explore other types of environmental policy instruments to ensure com- pliance with regulations, including through financial incentives to deter harmful practices such as pollution charges and green financing to businesses for adopting RECP (chapters 9 and 10). 3.7 Conclusions and recommendations Bangladesh’s legal and institutional framework for environmental management is evolving, as discussed throughout this chap- ter. There are, however, opportunities to further strengthen the country’s environmental systems and ensure it performs funda- mental functions and coordinated actions to address environmental degradation. The GoB is already working in those interven- tions. The Bangladesh Environmental Sustainability and Transformation (BEST) Project (2023-28) will finance activities to improve environmental governance and infrastructure, enable green financing for air pollution control, and pilot initiatives for vehicle emission control and e-waste management (appendix M). 3.7.1 Strengthening the legal framework A comprehensive amendment to the ECA and ECtA is needed to address some of the present recommendations and ensure a transformative change towards greening the economy and ensuring sustainable development. The ECA amendment should (a) envisage other types of policy instruments (beyond command-and-control); (b) expand the DoE’s enforcement mandate, partic- ularly to impose sanctions without judicial cases and ensure an automatic formula for regularly increasing the maximum amount of fines; (c) envisage other sources of revenues for environmental management such as a permanent environment fund that can receive resources from the DoE’s service fees and damage compensation and provide grants to environmental initiatives such as piloting of green technology; (d) set the foundations for further regulation of EPR, PES, LMO, among other environmental themes; (e) require SEA for policies, programs and plans; (f) improve mechanism for meaningful stakeholder engagement in environmen- tal decision-making. Through the MoF, it is also essential to adopt market-based policies for pollution management (chapter 9). To make the environment courts system more effective for holding polluters accountable, the ECtA amendment should (a) allow affected parties to file lawsuits directly in the court instead of having to go through the DoE, (b) facilitate the use of scientific and expert evidence to inform judicial rulings in environmental cases, (c) give courts a broader mandate covering all environmental policies and acts, and ultimately holding government agencies accountable for their constitutional responsibility for environmental protection and the preservation of natural resources, (d) requirement of a guarantee deposit from the alleged offender as a condi- tion for appeals, and (e) imposition of daily fines for delay in implementing a judicial order—for example, when an industry refuses to comply with a court’s decision that orders it halt polluting activities. To design this reform, it is essential to conduct an in-depth assessment of Bangladesh’s legal and institutional framework, including a benchmarking exercise with international good practic- es on environmental justice. Additionally, such policy reforms should be accompanied by adequate resources to avoid additional backlog of judicial cases, including budget increase and infrastructure development. 3.7.2 Strengthening environmental institutions The GoB should carry out a detailed analysis of the organizational structure under the MoEFCC and affiliated agencies to set clearer mandates and more efficient processes for environmental governance The DoE still needs specialized technical units to respond to identified environmental priorities, with the necessary human, technical and financial resources to fulfill their man- dates. In this regard, key measures include establishing a cadre of environmental specialists and increasing the headcount at the DoE to ensure that qualified professionals can reach senior official positions, attract, and retain talented individuals, and ensure that decisions and policies are made by people with adequate background and experience. For the environmental court system, BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 59 Bangladesh’s Environmental Governance Framework the establishment of an environmental prosecution agency (or specialized unit) that is independent of the DoE and shielded from political interference must also be considered to make environmental justice more effective. This new agency or special- ized unit requires legal and environmental experts with the capacity to develop solid cases before the courts. The GoB should allocate more resources to the MoEFCC and the DoE, including by setting additional sources of revenues and strat- egies to maximize resources allocated for environmental management, such as environmental fiscal instruments (taxes, charges, bonds, and so forth), partnerships with donors and the private sector, and the creation of a permanent Environment Fund. The GoB should consider additional mechanisms to foster inter-agency coordination, including for data exchange and joint monitoring and enforcement actions. Major environmental health and pollution issues still lack the minimum coordination structure for defining priorities and action plans across relevant sectors, such as health, energy, transport, and water. Similar initia- tives to the NCAPC should be considered to enhance institutional coordination for environmental priorities. Efforts to foster clos- er inter-agency coordination could also be based on quantifiable goals. The process of developing environmental performance could be closely tied to efforts requiring units from different organizations to set specific quantifiable goals in their action plans and to systematically monitor their progress toward those goals. Ideally, this performance evaluation system would measure direct impacts on environmental quality, such as reduction in waterborne diseases or in outdoor and indoor concentrations of PM2.5. Disseminating such data and publicly disclosing them can create strong incentives for compliance with coordinated plans and for improved institutional performance. Decentralization of environmental management is key to better balancing the needs and priorities of central government of- ficials and politicians with local stakeholders. Completing the DoE’s decentralization process is essential to expand its physical presence to all districts and ensure that each of them is adequately staffed to perform all the DoE’s functions efficiently and effectively and avoid conflicts of interest between ECC approval and enforcement. International experience shows that decen- tralization is particularly convenient when participation in decision-making and implementation and monitoring by local stake- holders play a central role in ensuring quality outputs and effective results. However, given that Bangladesh is among the most centralized countries in the world, any efforts to transfer more powers and responsibilities to local governments would need to be carefully assessed. Such transfer of responsibilities would need to be complemented with the corresponding transfer of resources and technical support to build the capacity of local governments. Initially, local governments could be increasingly en- gaged in monitoring of environmental data, dissemination of information and awareness campaigns, stakeholder engagement, and identification and interventions to reduce pollution from local sources. 3.7.3 Using evidence for planning and decision-making To increase its monitoring capacity with reliable time series data, the DoE needs to urgently expand its data collection and pro- cessing on environmental pollution, including ambient air and water quality, solid and water-related waste, hazardous waste, and emissions from industries. These improvements must include establishing more automated stations for a granular picture of environmental quality across the country and ensuring that existing stations operate reliably and interruptedly. The monitoring systems must be accompanied by a system of outcome-oriented indicators of environmental quality and an adequate institu- tional presence in the field, with sufficient and well-trained staff. The GoB should also address constraints in implementing the Bangladesh Environmental Statistics Framework by improving the capacity of BBS and relevant data-producing government departments so they can properly gather, process, and disseminate timely and quality environmental data (appendix L). Addi- tionally, health policies are needed to gather and process community-level data on the health issues and prevention measures in pollution hotspots, such as on blood lead levels, and incidence of diseases associated with inadequate WASH and air pollution. Another important step to strengthen environmental planning is to ensure that data collected through monitoring is used to identify environmental priorities, assess alternatives to address them and evaluate progress in achieving environmental goals. The cost of environmental degradation (Chapter 2) is an example of a methodological approach to identifying environmental priorities, while cost-benefit analyses (Chapter 5) and economic and distributional modeling (Chapter 7) could be an approach to prioritize interventions that are likely to benefit individuals and society the most. In coordination with other agencies (for example, BIDS, BBS and DGHS), the DoE’s upcoming research and training center should conduct analytical work to provide robust foundations for (a) setting environmental priorities across sectors, (b) allocating budget in response to those priorities, and (c) designing adequate interventions to address those priorities through diversified policy instruments and investments (Chapter 9). For example, including criteria linked to environmental and climate change challenges, poverty reduction and shared prosperity in the GoB’s budget allo- cation procedures would contribute to reducing discretionary, unpredictable, and politically motivated transfers, which, in turn, is a necessary condition to strengthen the role of local authorities in environmental management. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 60 Bangladesh’s Environmental Governance Framework By establishing systematic baselines and the evaluation of its interventions, the GoB could (a) gauge progress in responding to environmental priorities (such as the ban of two-wheelers to control air pollution) or identify reasons for unsuccessful inter- ventions (such as vehicle inspections); (b) incorporate the lessons from previous initiatives; and (c) adjust policies based on new developments in science and technology (for example, recent evidence showing that PM2.5 and lead cause significant health effects even at low levels that were previously considered safe). For setting a baseline, Bangladesh’s environmental management system would benefit from a comprehensive evaluation, covering the adequacy of the current organizational structure and the efficiency and efficacy of the EC system as the main environmental policy instrument, among other aspects. Formal evaluation and learning mechanisms should be incorporated in the short run into the management routines of the DoE. The information collected with these tools is crucial for building performance-based indicators, which allow organizations to set measurable goals, evaluate their achievements, and engage in the process of reforming and improving their practices. Performance-based indicators also have the potential to strengthen the environmental sector by enhancing transparency and accountability, as well as by demonstrating the social benefits of investing public resources in environmental protection. In addition to allocating more resources and capacity-building to the MoEFCC, the GoB might consider adopting results-based agreements to improve effectiveness and efficiency in the use of public resources in all sectors, including the environment. This approach consists of the signing of results-based agreements between the MoF and the MoEFCC and its agencies, including the DoE. The MoF and the leading sectoral agencies monitor compliance with the agreement based on a small, clear set of critical standards, indicators and milestones. Budgetary disbursements are subject to a given degree of compliance, and allocations in the following budget cycle are decided according to the previous cycle’s results. 3.7.4 Strengthening environmental enforcement Gaps in environmental policies, weak enforcement, and deficient technical capacity have rendered Bangladesh’s environmental management framework ineffective in reducing environmental degradation. Enforcement is selective and sporadic, neglecting some of the most polluting activities, such as lead exposure. As for command-and-control, a comprehensive amendment to the ECA, ECtA, rules and guidelines are needed to make en- forcement activities more efficient, including clear provisions to implement the polluters pay principles, such as more specific parameters for assessing damage and determining penalties and the expansion of the DoE’s mandate for imposing sanctions without a judicial process. The GoB needs to ensure that the adoption of laws and rules is coupled with more specific regulatory instruments—for example, guidelines, manuals, and technical standards. The absence of such instruments opens doors to legal uncertainty, discretionary decisions, appeals for imposed sanctions, and potential acts of corruption. In parallel, the GoB should modernize and expand the range of policy instruments beyond command-and-control and, more specifically, the EC system. The Government could use several policy options: (a) economic and market-based instruments, such as pollution charges, deposit-refund schemes, EPR, and final demand interventions; (b) litigation-based instruments, including liability legislation, and (c) information-based instruments, such as awareness campaigns and regular dissemination of environ- mental quality data and pollution loads, lists of highly polluting industries, and results of enforcement activities. Other key inter- ventions refer to enabling access to green financing and awareness campaigns targeting polluting industries, as in many cases, developers do not improve their practices because of limited resources and knowledge. Enforcement also requires ensuring that authorities have the resources, equipment, and expertise to comply with these standards or, alternatively, establishing a system of certified third parties that can perform these functions. In addition, to increase the DoE’s staff and improve its infrastructure, the GoB should use information technology to improve enforcement. For example, the demand for on-site inspection centers could be reduced if the Government requires highly polluting industries to install automated monitor- ing devices on premises, such as in stacks and CETPs, to transfer data on a regular basis to a DoE-managed information system. The latter would allow remote oversight and facilitate data analysis and dissemination. Additionally, the management of air and water quality monitoring stations could be outsourced to academic institutions or private entities. The demand for vehicle inspection centers could also be supplied through public-private partnerships. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 61 Bangladesh’s Environmental Governance Framework 3.7.5 Improving stakeholder engagement Responding to priority environmental challenges in Bangladesh calls for a more systematic effort to raise awareness of environ- mental issues. Ways to improve public information and promote transparency, accountability, and awareness include the pub- lication of data in support of key environmental indicators (including pollution loads and environmental health statistics); wider use of public forums for air development initiatives, and broader and more detailed review and discussion of environmental management tools.34 Mechanisms to disseminate information in a manner that is easily interpretable can allow communities to serve as informal regulators; such mechanisms also promote accountability on the part of those being regulated and help prevent and mitigate the health effects of pollution. In this context, the DoE should expand dissemination mechanisms, such as the Air Quality Index, to cover other environmental topics and make use of social media and smartphones as dissemination tools. The DoE should also publish progress reports and evaluations with quantitative information to provide a more systematic and evidence-based approach to complement citizens’ observations. Stakeholder engagement, especially those who are most severely affected by environmental degradation, is a key aspect to be improved in the EC process and, in the future, in SEAs (chapter 4). These stakeholder consultations are important to open environmental decision-making to public scrutiny and create opportunities for learning and evaluation, at both project and policy formulation levels. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 62 Bangladesh’s Environmental Governance Framework C3 References / Endnotes Adhikary, T. S. 2019. “From Digital to Manual: BRT’s Lone Automated Set-up to Check Vehicle Fitness Out of Order for 3 Months; Manipulation Risk Goes Up.” Daily Star. Front Page. https://www.thedailystar.net/frontpage/news/digital-manual-1724692 Ahmed, S. 2017. “Background Paper on Determinants of a Green Growth Strategy for Bangladesh.” Policy Research Institute of Bangladesh. UKaid, Economic Dialogue on Green Growth. Ahmed, Tanvir, Md. Quamrul Hasan, and Mohammad Osman Sarwar. 2021. “Trends in Punitive Actions against Environmental Pollution in Bangladesh.” IAIA Conference. https://conferences.iaia.org/2021/edited-papers/1246_AHMED_Trends%20in%20Punitive%20Actions.pdf Akhter, S. 2021. “Lone Automated BRTA Vehicle Inspection Centre Check Few Vehicles.” New Age. Bangladesh. https://www.newagebd.net/article/126027/lone- automated-brta-vehicle-inspection-centre-check-few-vehicles Alvarado, M. J., A. E. McVey, J. D. Hegarty, E. S. Cross, C. A. Hasenkopf, R. Lynch, E. J. Kennelly, T. B. Onasch, Y. Awe, E. Sánchez-Triana, and G. Kleiman. 2019. “Evaluating the Use of Satellite Observations to Supplement Ground-Level Air Quality Data in Selected Cities in Low- and Middle-Income Countries.” Atmospheric Environment 218. Basel Convention. 2004. Training Manual for the Preparation of National Used Lead Acid Batteries Environmentally Sound Management Plans in the Context of the Implementation of the Basel Convention. Basel Convention Series/SBC No. 2004/5. http://archive.basel.int/meetings/sbc/workdoc/tm-ulab/tm_ulab.pdf Begum, B. A. 2017. “Study of Indoor Air Pollution (IAP) Levels in Households with Improved and Traditional Cookstoves.” Study conducted under contract from the Infrastructure Development Company Limited (IDCOL). Begum, B. A., and S. K. Biswas. 2009. “Trends in Particulate Matter (PM) and Lead Pollution in Ambient Air of Dhaka City in Bangladesh.” Journal of Bangladesh Academy of Sciences 32 (2). https://doi.org/10.3329/jbas.v32i2.2427 BSTI (Bangladesh Standards and Testing Institution). 2021. BSTI Standards Catalog 2021. Dhaka: BSTI, Ministry of Industries. http://bsti.portal.gov.bd/sites/default/ files/files/bsti.portal.gov.bd/page/c82bd863_c051_46ce_af11_eb5bec479d5b/2021-08-31-11-36-54b7b1099157fbe275580fb4511a00bf.pdf Damania, R., S. Desbureaux, A.-S. Rodella, J. Russ, and E. Zaveri. 2019.  “Quality Unknown: The Invisible Water Crisis.” Washington, DC: World Bank. https:// openknowledge.worldbank.org/handle/10986/32245 Dhaka Tribune. 2022. “TIB: 66% of Industries Gained Certificates with Bribes.” Tribune Report (January 5, 2022). https://www.dhakatribune.com/nation/2022/01/05/ tib-66-of-industries-gained-eia-certificates-with-bribes DoE (Department of Environment). 2018. “Ambient Air Quality in Bangladesh.” Clean Air and Sustainable Environment Project. Dhaka, Bangladesh: Department of Environment, Ministry of Environment, Forest and Climate Change. DoE (Department of Environment). 2019. “Ecologically Critical Areas of Bangladesh.” http://www.DoE.gov.bd/site/page/9481fd1b-7ca6-4087-890a-886cd226df0e/- DoE (Department of Environment). 2021. “EIA Guidelines for Industries.” Dhaka. Department of Environment, Ministry of Environment, Forest and Climate Change. http://file.portal.gov.bd/uploads/8ef2a505-c131-4a8f-b6d0-2ac4760cc936//635/f6b/1e6/635f6b1e69cb8822258025.pdf DoE (Department of Environment). 2023. Annual Report 2021–2022. http://www.DoE.gov.bd/sites/default/files/files/DoE.portal.gov.bd/annual_reports/7b7587fa_ cfe1_4b2a_aa5c_f6b27202b8fa/2023-03-24-09-12-551f98f0ffba744894abfb8100b3b2af.pdf Enriquez, S., E. Sánchez-Triana, and M. G. Guerra Lopez. 2021. “Economic Instruments and Financial Mechanisms for the Adoption of a Circular Economy.” In An Introduction to Circular Economy, edited by L. Lerwen and S. Ramakrishna. Springer. Environmental Law Institute. 2010. India 2030: Vision for an Environmentally Sustainable Future. Best Practices Analysis of Environmental Protection Authorities in Federal States. Washington, DC: World Bank. http://www.eli.org/pdf /india2030.pdf. Ericson, B., T. T. Duong, J. Keith, T. C. Nguyen, D. Havens, W. Daniell, C. J. Karr, D. N. Hai, L. V. Tung, T. T. N. Ha, B. Wilson, D. Hanrahan, G. Croteau, and M. P. Taylor. 2018. “Improving Human Health Outcomes with a Low-Cost Intervention to Reduce Exposures from Lead Acid Battery Recycling: Dong Mai, Vietnam.” Environmental Research 161: 181–87. https://doi.org/10.1016/j.envres.2017.10.042. ESDO and UNEP (Environment and Social Development Organization and United Nations Environment Programme). 2021. National Strategy for Used Lead Acid Battery (ULAB) Recycling in Bangladesh: A Sustainable Strategy for ULAB Waste Management. Dhaka, Bangladesh: ESDO. https://wedocs.unep.org/bitstream/ handle/20.500.11822/36344/ULABSB.pdf?sequence=3&isAllowed=y ESDO, UNEP, and Pure Earth (Environment and Social Development Organization, United Nations Environment Programme, and Pure Earth). 2020. Comparative Review: Assessment of Regulations on ULAB in Bangladesh and Recommendations for Legislation. https://wedocs.unep.org/bitstream/ handle/20.500.11822/36330/CRRV.pdf?sequence=3&isAllowed=y European Commission. 2008. Directive 2008/50/EC of the European Parliament and of the Council. Ferdous, B. F. 2017. Governance for Green Growth in Bangladesh: Policies, Institutions and Political Economy. United Kingdom Agency for International Development. https://www.greengrowthknowledge.org/research/governance-green-growth-bangladesh-policies-institutions-and-political-economy Forsyth, J. E., K. L. Weaver, K. Maher, M. S. Islam, R. Raqib, M. Rahman, S. Fendorf, and S. P. Luby. 2019. “Sources of Blood Lead Exposure in Rural Bangladesh” Environ Sci Technol 53 (19): 11429–36. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 63 Bangladesh’s Environmental Governance Framework GAHP (Global Alliance on Health and Pollution). 2021. Used Lead Acid Battery Industry in Bangladesh. Draft Final Report. https://southsouthnorth.org/wp- content/uploads/2021/10/210901-GAHP-Final-Report-Bangladesh-ULAB.pdf GED (General Economics Division). 2020a. 8th Five Year Plan, July 2020 – June 2025: Promoting Prosperity and Fostering Inclusiveness. Bangladesh Planning Commission, Government of the People’s Republic of Bangladesh. GED (General Economics Division). 2020b. Making Vision 2041 a Reality: Prospective Plan of Bangladesh 2021–2041. Bangladesh Planning Commission, Government of the People’s Republic of Bangladesh. GED (General Economics Division) 2022. A Training Book on Implementation of the 8th Five Year Plan. https://gedkp.gov.bd/wp-content/uploads/2022/08/A%20 Training%20Handbook%20on%20implementation%20of%20the%208FYP.pdf Global Battery Alliance. 2020. Consequences of a Mobile Future: Creating an Environmentally Conscious Life Cycle for Lead-Acid Batteries. White Paper. In collaboration with Pure Earth, the International Lead Association and Responsible Battery Coalition. https://www3.weforum.org/docs/WEF_LAB_Recycling_ Guidelines_2020.pdf GoB (Government of Bangladesh). 2020. Tree and Forest Resources of Bangladesh: Report on the Bangladesh Forest Inventory. Forest Department, Ministry of Environment, Forest and Climate Change, Government of the People’s Republic of Bangladesh, Dhaka, Bangladesh. http://bfis.bforest.gov.bd/bfi/wp-content/ uploads/2021/02/BFI-Report_final_08_02_2021.pdf GoM (Government of Mexico). Plataforma Nacional de Transparencia. Query conducted on September 23, 2023. https://consultapublicamx. plataformadetransparencia.org.mx/vut-web/faces/view/consultaPublica.xhtml#inicio GoPh (Government of The Philippines). 2023. National Expenditure Program Volume II FY 2023. https://www.dbm.gov.ph/wp-content/uploads/NEP2023/NEP- 2023-VOLUME-2.pdf Hu H., R. Shih, S. Rothenberg, and B. Schwartz. 2007. “The Epidemiology of Lead Toxicity in Adults: Measuring Dose and Consideration of Other Methodologic Issues.” Environmental Health Perspectives 115 (3): 455–62. doi:10.1289/ehp.9783 Iftekharuzzaman. 2022. “The Department of Environment Needs a Complete Overhaul.” Interview by Readus Salehen Jawad. Business Standard. https://www. tbsnews.net/features/panorama/department-environment-needs-complete-overhaul-355870 International Pollutants Elimination Network. 2021. Lead in Solvent-Based Paint for Home Use in Bangladesh https://ipen.org/sites/default/files/documents/ ipen-2021-lead-paint-esdo_v1_2aq-en.pdf Khan, Md. N., C. Z. B. Nurs, M. M. Islam, Md. R. Islam, and Md. M. Rahman. 2017. “Household Air Pollution from Cooking and Risk of Adverse Health and Birth Outcomes in Bangladesh: A Nationwide Population-based Study.” Environ Health 16: 57. https://doi.org/10.1186/s12940-017-0272-y Larsen, B. 2016. Benefits and Costs of Household Cooking Options for Air Pollution Control: Benefits and Costs of Addressing Indoor Air Pollution Challenges in Bangladesh. Copenhagen Consensus Center, Smarter Solutions for Bangladesh, and BRAC. https://www.copenhagenconsensus.com/sites/default/files/larsen_ indoorairpollution.pdf Larsen, B., and J. M. Skjelvik. 2021. “Mexico Environmental Health Effects and Their Costs in 2019.” Washington, DC: World Bank. Maitrot, M. 2017. Unpacking the ‘Bangladesh Paradox’: The Politics of Inclusive Economic and Social Development. Blog. Effective States and Inclusive Development. http://www.effective-states.org/unpacking-the-bangladesh-paradox-the-politics-of-inclusive-economic-and-social-development/ Majumder, A. H., A. A. Nayeem, M. Islam, M. M. Akter, and W. S. Carter. 2021. “Critical Review of Lead Pollution in Bangladesh.” Journal of Health and Pollution  11 (31): 210902. doi:https://doi.org/10.5696/2156-9614-11.31.210902 Margulis, S., and T. Vetleseter. 1999. “Environmental Capacity Building: A Review of the World Bank’s Portfolio.” Environment Department Paper 68, Pollution Management Series, Washington, DC: World Bank. MoEFCC (Ministry of Environment, Forest and Climate Change). 2022. Air Pollution Control Rules 2022. Ministry of Environment, Forest and Climate Change. MoEFCC (Ministry of Environment, Forest and Climate Change). 2023a. Annual Report 2021–2022. https://moef.portal.gov.bd/sites/default/files/files/moef.portal. gov.bd/page/9e7634a4_c7d4_49aa_b2e2_29005bf1e107/MoEFCC_Annual_Report_2021_22.pdf MoEFCC (Ministry of Environment, Forest and Climate Change). 2023b. Environment Conservation Rules 2023. MoEFCC. Nabi, S. 2019. “Draft Clean Air Act Presented for Immediate Approval.” Environment, Dhaka Tribune. https://archive.dhakatribune.com/bangladesh/ environment/2019/02/14/clean-air-act-in-the-offing Nahar, N., S. Mahiuddin, and Z. Hossain. 2021. “The Severity of Environmental Pollution in the Developing Countries and Its Remedial Measures.” Earth 2021 (2): 124–39. https://doi.org/10.3390/earth2010008 North, D. C. 1990. Institutions, Institutional Change, and Economic Performance. Cambridge, UK: Cambridge University Press. North, D. C. 1991. “Institutions.” Journal of Economic Perspectives 5 (1): 97–112. Ohiduzzaman, Md. 2010. Parliamentary Control and Oversight: A Study on the Performance of Parliamentary Standing Committee on Ministry of Environment & Forests on Environment Related Issues. (July 18, 2010). SSRN: https://ssrn.com/abstract=1645045 or http://dx.doi.org/10.2139/ssrn.1645045 Power Division. 2013. Country Action Plan for Clean Cookstoves. Power Division, Ministry of Power, Energy, and Mineral Resources, Government of the People’s Republic of Bangladesh. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 64 Bangladesh’s Environmental Governance Framework Pure Earth. 2020. Assessment of Informal Used Lead Acid Battery Recycling and Associated Impacts in Bangladesh. Produced for UNEP. https://wedocs.unep. org/bitstream/handle/20.500.11822/36331/AIUL.pdf?sequence=3&isAllowed=y Rahman, T., A. R. Faisal, T. Kaham, and U. U. Shekhar. 2020. “Recurrent Indoor Environmental Pollution and Its Impacts on Health and Oxidative Stress of the Textile Workers in Bangladesh.” Environmental Health Insights 14. Rana, M. 2021. “Law to Curb Air Pollution: Where Does Bangladesh Stand?” The Opinion Pages, bdnews24.com. https://opinion.bdnews24.com/2021/06/06/law- to-curb-air-pollution-where-does-bangladesh-stand/ Rehfuess, Eva, Elisa Puzzolo, Debbi Stanistreet, Daniel Pope, and Nigel Bruce. 2014. “Enablers and Barriers to Large-Scale Uptake of Improved Solid Fuel Stoves: A Systematic Review.” Environmental Health Perspectives 122 (2): 120–30. http://dx.doi.org/10.1289/ehp.1306639 Sánchez-Triana, E. 2021. Environmental Challenges for Green Growth and Poverty Reduction: A Country Environmental Analysis for The Lao People’s Democratic Republic. Washington, DC: World Bank Group. http://hdl.handle.net/10986/36266 Sánchez-Triana, E., and L. Ortolano. 2005. “Influence of Organizational Learning on Water Pollution Control in Colombia’s Cauca Valley.” Water Resources Development, 21: 493–508. https:// doi.org/10.1080/07900620500139168 Sánchez-Triana, E., S. Enriquez, J. Afzal, A. Nakagawa, and A. K. Shuja. 2014. Cleaning Pakistan’s Air: Policy Options to Address the Cost of Outdoor Air Pollution. Washington, DC: World Bank. doi:10.1596/978-1-4648-0235-5. Sánchez-Triana, E., S. Enriquez, B. Larsen, P. Webster, and J. Afzal. 2015. Sustainability and Poverty Alleviation: Confronting Environmental Threats in Sindh, Pakistan. Directions in Development. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/22149 Sharmin, N., F. Rahman, G. Mohiuddin, and A. S. Juel Miah. 2017. Climate Finance and Local Government Institutions: Governance in Project Implementation. Transparency International Bangladesh. https://www.researchgate.net/publication/353105019_Climate_Finance_and_Local_Government_Institutions_ Governance_in_Project_Implementation/link/60e7695b30e8e50c01f0360f/download Secretaria de Hacienda y Credito Publico, Presupuesto de Egresos de la Federación para el Ejercicio Fiscal 2022. https://www.gob.mx/cms/uploads/attachment/ file/691406/SHCP_291121_EV.pdf Thurston, G., Y. Awe, B. Ostro, E. Sánchez-Triana. 2021. “Are All Air Pollution Particles Equal? How Constituents and Sources of Fine Air Pollution Particles (PM2.5) Affect Health.” World Bank, Washington, DC. https://openknowledge.worldbank.org/handle/10986/36269 Tribune Desk. 2022. “High Court Seeks Plan to Curb Air Pollution.” Dhaka Tribune. https://www.dhakatribune.com/court/2022/02/15/high-court-seeks-plan-to- curb-air-pollution UNEP (United Nations Environment Programme). 2021. 2020 Update on the Global Status of Legal Limits on Lead in Paint. UNEP in partnership with WHO and US EPA. https://www.unep.org/resources/report/2020-update-global-status-legal-limits-lead-paint UNICEF (United Nations Children’s Fund) and Pure Earth. 2020. “The Toxic Truth: Children’s Exposure to Lead Pollution Undermines a Generation of Future Potential.” UNICEF and Pure Earth. https://www.unicef.org/reports/toxic-truth-childrens-exposure-to-lead-pollution-2020 von Stackelberg, K; P. Williams, E. Sánchez-Triana, and S. Enriquez. 2022. Recycling of Used Lead-Acid Batteries : Guidelines for Appraisal of Environmental Health Impacts. International Development in Focus. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/36593 Webster, A., N. Hossain, S. Mahmud, S. Nazneen, and K. Sen. 2017. The Bangladesh Paradox: Why Has Politics Performed So Well for Development in Bangladesh? ESID Briefing No. 27. Effective States and Inclusive Development. https://www.effective-states.org/wp-content/uploads/2017/02/ESID-Briefing-Paper-27- Bangladesh-Paradox.pdf WHO (World Health Organization). 2021. WHO Global Air Quality Guidelines. Particulate Matter (PM2.5 and PM10), Ozone, Nitrogen Dioxide, Sulfur Dioxide and Carbon Monoxide. Geneva, Switzerland: WHO. https://apps.who.int/iris/bitstream/handle/10665/345329/9789240034228-eng.pdf?sequence=1&isAllowed=y World Bank. 2003.  World Development Report 2003: Sustainable Development — a Dynamic World--Transforming Institutions, Growth, and Quality of Life. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/5985 World Bank. 2007. Republic of Peru Environmental Sustainability: A Key to Poverty Reduction in Peru (English). Washington, DC: World Bank Group. http:// documents.worldbank.org/curated/en/896441468296943537/Republic-of-Peru-environmental-sustainability-a-key-to-poverty-reduction-in-Peru World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank Group. http://hdl.handle.net/10986/30558 World Bank. 2019. Pollution Management in Kosovo. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/33041 World Bank. 2020. Clearing the Air: A Tale of Three Cities. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/34757 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 65 Bangladesh’s Environmental Governance Framework Endnotes 24 These standards are (a) BDS 1423:2018 on enamel, synthetic, and exterior paints for undercoating and finishing applications; (b) BDS 1827:2018 on emulsion paints; and (c) BDS 1833:2018 on economy emulsion paints or distempers. These paints are commonly used in household and home decorations. 25 The policy also bans the import of horns above 100 decibels to prevent noise pollution. 26 The BEST Project will finance the establishment of the training and research center. 27 Data constraints on the budget of environmental agencies, different methodologies or categories used by different countries in their public reporting, as well as specific country contexts and institutional structures for environmental agencies limited direct international comparisons. However, some comparisons were possible with Mexico and the Philippines, two middle-size countries where budget and staffing data were available. 28 Analysis by the General Economics Division (GED) considered data from 16 developing countries and 26 developed countries. Spending by local government institutions represents 19 percent of total government spending in developing countries and 28 percent in industrial countries. Subnational government taxes account for 11.4 percent of total taxes in a sample of 16 developing countries and 22.7 percent in a sample of 24 industrial countries, compared with 1.6 percent of total government taxes in Bangladesh (GED 2020). 29 About two-thirds of funding of LGIs comes from transfers from the central government, which are not for LGIs’ discretionary use, such as special grants and project grants that are earmarked for the spending priorities of the central ministries that provide the funding. 30 GCR priorities listed in the block grants circulars cover, among other, policies for green affordable housing, water, and waste management. Other examples of GCR priorities are (a) development of climate-resilient and flood-resistant infrastructure; (b) reduction of pollution; (c) proper drainage and sewerage systems; (d) increasing access to safe water, sanitation, and hygiene; (e) enhanced use of energy-efficient appliances in the official, residential, and commercial buildings; (f) solid waste management; and (g) environmental and ecological restoration and protection of forest and water bodies. MoLGRDC, Government Circulars dated February 9, 2023. 31 Lead is also considered a criteria pollutant by the ECR, but it is not measured. 32 The inflation calculation for Bangladesh is available at https://www.worlddata.info/asia/bangladesh/inflation-rates.php. Since inflation rates after 2022 are not yet available; consequently, for the following years, the last available rate of 7.70 percent was used in the calculator. 33 This deposit would be kept in a special account and, after the court’s decision, (a) returned to the appellant if he wins the case or (b) used to pay the fine and compensation, as applicable. 34 In Colombia and Indonesia, among other countries, the publication of key environmental performance indicators has been instrumental in raising environmental awareness and placing environmental issues on the national agenda (World Bank 2005). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 66 Environmental Planning and Environmental Impact Assessment CHAPTER 4. ENVIRONMENTAL PLANNING AND ENVIRONMENTAL IMPACT ASSESSMENT 4.1 Introduction Bangladesh has adopted the environmental clearance certificate (ECC) as the most common environmental management instrument to control environmental degradation from industrial units and projects (hereinafter “projects”). The environmental clearance (EC) process is centered on environmental impact assessment (EIA), covering both site and environmental clearance stages. Because of its nature, EC instruments in Bangladesh aim to manage the environmental impacts of specific projects rather than serving as a planning tool—based on participatory efforts to discuss the environmental and social concerns of dif- ferent stakeholders—for governmental agencies’ decision-making. As discussed in chapter 3, because of gaps in environmental regulations and prioritization of command-and-control policies, Bangladesh has used the ECC as a de facto substitute for more detailed environmental regulations and effective enforcement. Despite recent improvements with Environment Conservation Rules (ECR) 2023, the Government of Bangladesh (GoB) is yet to enhance the effectiveness of its EC system, taking advantage of this process to open environmental decision-making to public scrutiny and focus on concrete actions to improve the project’s environmental performance—rather than just meeting pro forma legal requirements. 4.2 Objectives and nature of environmental clearance The ECR defines the environmental impact assessment (EIA) as a well-organized process of identifying, predicting, and eval- uating the potential environmental impacts of a proposed project or activity. As in other South Asian countries, the EIA tool (or the ECC in general) has two main objectives: (a) to avoid, minimize, or compensate for the adverse significant biophysical, social, and other relevant effects of development proposals; and (b) to protect the capacity of natural systems and the ecolog- ical processes to maintain their functions (Lima et al. 2015). For the EC, Bangladesh’s legislation recognizes only two types of environmental assessments: Initial Environmental Examination (IEE) and EIA. With no provision for Strategic Environmental Assessments (SEAs), the Bangladeshi EIA system does not extend to legislative processes, policies, plans, and programs, highlighting the fact that the EIA system is designed to address the impacts of actual physical activities on the ground. Projects with a minor impact on the environment, including on potentially affected people, are not required to obtain a site clearance but must apply to the DoE for an ECC. All projects with the potential to cause moderate to substantial environmental or social impacts must obtain both a site clearance and an ECC from the DoE to start operating. In those cases, land development, construction of any kind of infrastructure, and provision of basic utilities cannot be started without a site clearance. The site clearance aims to ensure that projects (a) are not developed in sensitive areas (for example, protected areas, heritage sites, ecologically critical areas, habitats of threatened species, and declared forestland, among others); and (b) will be sited in an area with adequate environmental infrastructure to manage their effluents and waste.35 The new ECR requires that DoE staff visit the project site before approving the site clearance and again before issuing the environmental clearance. With this new require- ment, the DoE will need even more resources to fulfill its mandates and ensure quality and efficiency in the clearance process. The DoE is responsible for implementing the EIA system, performing functions such as (a) issuing guidelines on how to conduct EIAs for specific projects or sectors; (b) administering the site-clearance processes and ECC processes; (c) reviewing the site-clear- ance applications and ECC applications, including the project’s potential environmental and social impacts and the proposed mitigation measures to avoid, prevent, or mitigate those effects; (d) deciding on the site clearance and ECC application consid- ering the project’s expected residual impacts (that is, those likely to occur after the implementation of mitigation measures); and (e) when applicable, renewing ECCs. The DoE also coordinates with other public agencies (such as the Bangladesh Forest Department and the Ministry of Industries) that may oversee other aspects of the project’s development and operations. In line with the DoE’s decentralization process, the ECR 2023 gives more responsibility to local offices—which were not men- tioned in the ECR 1997—and establishes the designated office (district, divisional, metropolitan, regional, or head offices) respon- sible for receiving the ECC applications, which must be submitted online by default. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 67 Environmental Planning and Environmental Impact Assessment 4.3 Screening The requirements and procedures of the ECC will depend on the project category: projects that may cause significant impacts require an environmental impact assessment (EIA), and projects with moderate or minor impacts are subject to simpler require- ments. Through a screening process, the DoE determines the categorization of projects based on their potential environmental impacts: Green (minor), Yellow (moderate), Orange (considerable), and Red (severe). The categorization will define whether the project proposal should be subject to an environmental assessment and other requirements, the level of detail of such assess- ment, who will be responsible for reviewing the site and environmental clearance application, and the certificate validity, as detailed in table 4.1. The new rules also refer to social issues as part of the site and environmental clearance processes, an aspect that was not explicitly covered in the previous ECR. The ECR 2023 has improved the screening process by updating and detailing the list of pre-categorized projects. For example, in the ECR 1997, all types of power plants were considered under the Red category, requiring a full EIA and yearly renewal. The ECR 2023 categorizes power plants by source of energy (coal, solar, waste, hydro, and so forth) and generation capacity. The new ECR also mandated the DG to decide on the categorization of non-listed projects, as well as to change the category for a project that is likely to cause more severe environmental impacts than those corresponding to its category. Table 4.1 Summary of project categories Potential Competent authority environmental and Requirements to apply for an ECC for deciding on ECC ECC validity social impacts application Category: Green Minor. Some mitiga- Submission of Form 3 of the ECR, with general information and descrip- Relevant DoE office 5 years tion measures may tion of raw materials and finished products. (district, metropolitan, still be needed. divisional, or regional). No application processing fee. The developer pays only the ECC fee based on the project investment amount. Category: Yellow (formerly Orange A) Moderate. Mitigation Must obtain both site and environmental clearances. Relevant DoE office 2 years measures can help (district, metropolitan, Submission of Form 3 of the ECR, with general information and de- to avoid environ- divisional, or regional). scription of raw materials and finished products. Process flow diagram, mental and social layout plan, and effluent-disposal system (as applicable). impacts. Payment of a clearance application processing fee of BDT 2,000 and ECC fee based on the project investment amount. Category: Orange (formerly Orange B) Considerable. Ap- Must obtain both site and environmental clearances. EC Committee of Region- 1 year propriate mitiga- al, Divisional or Metropol- Submission of Form 3 of the ECR, with general information and de- tion measures are itan Office for industrial scription of raw materials and finished products. process flow diagram, required to reduce units or projects listed layout plan, and effluent-disposal system (as applicable). environmental and in Serial No. 1-62 of the social impacts. Feasibility report and IEE. Orange Category. Environmental Management Plan (EMP), and additional plans on pol- EC Committee of the lution minimization, occupation health and safety (OHS), solid-waste Head Office for industrial management, management of hazardous medical waste (as applica- units or projects listed ble), and relocation plan (if required). in Serial No. 63-113 of the For industrial units or projects listed in Serial No. 63-113 of the Orange Orange Category that do Category, the Environmental Clearance Committee (EC Committee) of not require a full EIA. the Head Office may require, based on the IEE and after endorsement DG, based on recommen- by the DG, the proponent to conduct a full EIA if the potential impacts dation of the EC Commit- of the proposed industrial unit or project may cause severe impacts on tee of the Head Office for the environment and human health. industrial units or projects Payment of a clearance application processing fee of BDT 5,000 and listed in Serial No. 63-113 ECC fee based on the project investment amount. of the Orange Category that require a full EIA. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 68 Environmental Planning and Environmental Impact Assessment Potential Competent authority environmental and Requirements to apply for an ECC for deciding on ECC ECC validity social impacts application Category: Red Severe. Significant Must obtain both site and environmental clearances. DG, based on the rec- 1 year mitigation mea- ommendation of the EC Submission of Form 3 of the ECR, with general information and de- sures are required to Committee of the Head scription of raw materials and finished products. Process flow diagram, reduce the environ- Office. layout plan, and effluent-disposal system (as applicable). mental and social impact. ToR for EIA to be approved by the DoE. Full EIA to be completed before site clearance including EMP, and additional plans on pollution minimization, OHS, solid-waste manage- ment, management of hazardous medical waste (as applicable), and relocation plan (if required). EIA to be finalized after public consultation and the final version to be publicly disclosed. After site clearance and compliance with recommendations of the EIA, the ECC would be issued. Payment of a clearance application processing fee of BDT 10,000 and ECC fee based on the project investment amount. Source: ECR 2023. Note: Three different versions of Form 3 are used to apply for an EC: (a) for industrial establishments, (b) for infrastructure projects, and (c) for healthcare institutions. In addition to the application processing fee, the developer must pay an additional fee for obtaining the site or environmental clearance (or its renewal) ranging from BDT 3,000 to 1,500,000, depending on the amount invested in the project. For all projects, the renewal fee is one fourth of the clearance fee. Brickyards have a different fee structure. Although the ECR 2023 improved the screening process, the use of category lists as screening devices still presents challenges and may lead to ineffective and inefficient screening processes. By using rigid lists, a wide range of actions must be completed such as on-site inspections for all project categories, and the DoE does not have the ability to filter out those that would not gen- erate significant environmental effects in particular projects. Schedule 14 lists screening criteria for projects that are not on the list. This appears to be a more rational approach and should be used instead of a list-based approach for all projects. However, the criteria currently proposed in ECR 2023 are very limited—focusing on pollution issues only—and should cover other important environmental and social parameters. The value of issuing and renewing ECC for green and even some yellow projects is questionable. Those projects are not expect- ed to cause significant environmental impacts, yet they require the DoE to devote its limited resources to conduct on-site visits (which has limited enforcement efficacy, since project proponents are expecting those inspections) and review applications for these projects. In recent years, the DoE received few applications for Green projects. This suggests that most of these projects are developed and operated without an ECC (section 4.8). In the ECA amendment and further ECR revision, the GoB should consider exempting these projects from the ECC process and instead focus on regulating them through other instruments such as tech- nical standards for specific activities or land-use zoning. By reducing the number of projects that are subject to an ECC, the DoE would transfer valuable resources to enhance its enforcement capacity, invest in research for green technology, and promote transparency and public participation in decision-making. 4.4 Scoping and preparation of EIA In Bangladesh, the EIA scoping is conducted by the EC Committee based on draft terms of reference (TORs) prepared by the project owner. The ECR set forth a set of information that project proponents must consider when formulating the EIA scope, including project alternatives, description of existing environment, potential impacts, and mitigation measures. The rules do not establish criteria for the EC Committee to distinguish between significant and nonsignificant project impacts and, based on that, decide on the proposed TORs. However, the DoE’s EIA Guidelines for Industries 2021 describe the steps and possible techniques to be adopted by the developer in the scoping process, mentioning stakeholder consultations as a good practice. To ensure that projects with very similar characteristics end up with similar EIA-related requirements, the GoB might consider de- veloping more detailed, mandatory guidelines, but also requiring stakeholder participation in the scoping process—as suggested in the EIA Guidelines for Industres 2021, but not envisaged in the ECR 2023. Such participatory processes give an opportunity to potentially affected groups to express their concerns at an early stage and to ensure that the EIA duly considers the impacts that are the most significant to these groups. This would increase the effectiveness and efficiency of the EIA process by enabling BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 69 Environmental Planning and Environmental Impact Assessment the DoE, the project developer, and the rest of the stakeholders to focus on the most significant issues associated with the proposed project. Regarding the EIA preparation, project owners are responsible for hiring consultants registered with the DoE to conduct the necessary assessments. Environmental consultants and thematic experts must have a postgraduate degree in a relevant field and at least five years of experience preparing EIAs. As per the ECR 2023, consultants shall act independently and impartially in the EIA preparation, in consultation with all concerned parties and following the guidelines under its Schedule 11 for the EIA Report and Environmental Management Plan (EMP). Consultants shall agree with the project owner for formulating the EMP and the monitoring program. However, there is a clear conflict of interests that may affect consultants’ independence. Some developers, who will ultimately pay the consultants, are mainly concerned with obtaining the ECC as quickly as possible and not in conducting a rigorous evalua- tion or meaningfully engaging stakeholders. Therefore, the project developer has incentives to hire a consultant that only focuses on meeting the minimum legal requirements set by the authority and overcoming any potential objections to the project. Since consultants are selected and referenced by developers, they lack incentives to include in their documents information that may be relevant for the authority, if such information may result in denial of the ECC or the setting of additional conditions for the approval of the proposed project. The effects on the EIA’s quality may also be exacerbated by the new deadlines for the DoE to approve the ToRs and the ECCs. With a massive workload and the pressure to comply with deadlines, DoE staff may limit the EIA review to the documentation prepared by the consultants, without asking for additional information to complement the EIA. In addition, the EIA should be prepared following the sector-specific guidelines approved by the DoE and, in their absence, those developed by international organizations. The EIA Guidelines for Industries 2021 remain the only available document is- sued by the DoE with detailed information on how to conduct an EIA. The DoE revised these guidelines in 2021 to incorporate aspects of OHS and cultural heritage sites, though a new revision is required to incorporate provisions from the ECR 2023. The lack of guidelines for non-industry projects has resulted in confusion and ad hoc application of environmental requirements for developers requesting an ECC (Ahammed and Harvey 2004). In the short term, the DoE needs to (a) revise the EIA Guidelines for Industries, updating and expanding their contents as per the ECR 2023 as applicable; and (b) in collaboration with relevant agencies, develop guidelines for non-industry projects, preferably by sector, which could be based on guidance instruments issued by international organizations. Those guidelines should be legally binding. 4.5 Consultation and public participation The involvement of different stakeholders in the preparation of the EIA, particularly the groups likely to be affected by the de- velopment of a project, is crucial to ensure the legitimacy and credibility of the EIA and the associated decision-making process. Public participation within the EIA process has multiple objectives, ranging from gathering data and information from the public about their human and biophysical environment, to seeking public input to identify potential impacts and mitigation or com- pensation mechanisms, to enhancing the quality of the decision-making process and increasing public acceptance and support for the proposed action (André et al. 2006). The ECR 2023 has introduced general provisions on public participation, such as requiring the developer to consult the pub- lic in the project area by both organizing public hearings and providing opportunities to stakeholders to submit their written comments. While this change represents important progress compared to the ECR 1997, stakeholder consultations in the en- vironmental clearance process are still limited, since they are required “in applicable cases,” only for Red category projects, and after the scoping stage. There is no definition of “applicable cases” in the ECR. The scope of consultations will be local, regional, or national, depending on the geographic extent of the project. The developer is responsible for making a draft EIA and its Bangla summary available to the public on its website and at the concerned DoE office and website. The developer must also publish a notice with the date and time of the public hearing in a widely circulated local and national newspaper, and the same information must be posted on the websites of the DoE and the project proponent. The public can comment on the draft EIA online within 30 days of its publication. The minutes of the public hearing must be approved by the concerned DoE office and attached to the EIA report. The proponent must incorporate the necessary changes to the EIA report and EMP in the light of public consultations. Notwithstanding, the ECR does not require the developer to justify when comments are not incorporated in those instruments. The approved EIA report must be uploaded on the DoE website for public information. The ECR does not mention public disclosure of other relevant documents such as the IEE for Orange projects, the minutes of the EC Committee, the EMP, or even a list of projects that have received an ECC. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 70 Environmental Planning and Environmental Impact Assessment Without further regulations, public consultations can end up being geared more towards dissemination of project information rather than providing a mechanism whereby public comment and input can enter the decision-making process and affect the outcome of approval decisions (Acerbi et al. 2014; Lima et al. 2015). In addition, public hearings are often resource intensive and, if not properly organized, can easily turn into a community’s opportunity to voice demands for issues with little or no relationship to the project. Limited provisions for disclosure of information beyond the EIA report also affect transparency and accountability. Based on that, when revising ECA in the next years and then amending the ECR as the new act, the DoE should consider the following steps: (a) expanding the requirements of stakeholder consultations and access to information to other project cate- gories and pertinent documents, and (b) detailing those procedures through guidelines. These new requirements should be accompanied by adequate resources for the DoE and increased awareness of relevant stakeholders. 4.6 EIA review For projects requiring a full EIA, the project proponent shall attach the necessary documents to the application, including a draft ToR for the EIA. A DoE official is responsible for conducting an on-site inspection and then forwarding the application to the headquarters with recommendations for granting a site clearance or rejecting the application. Although the ECR describes the information needed from the project proponent, it does not describe the criteria to support the decision on the ECC appli- cation. The official’s opinion is submitted to the EC Committee, which is responsible for evaluating the EIA report. To receive the committee’s approval, the EIA must adequately measure the project’s environmental and social impacts; include an EMP and a monitoring program that are reasonable, effective, realistic, and adequate; and ensure that the project is not contrary to gov- ernment policies and plans. The committee must consider the comments received during public consultations. Based on this information, the committee will recommend to the DG if the site clearance should be issued and if additional conditions should be included in the approval. The proponent may be invited to the meeting of the EC Committee to clarify information on the EIA report. The EC Committee may also seek the opinion of other relevant agencies. Subsequently, upon compliance with the recommendations of the EIA, the ECC would be issued in favor of the project for one year subject to renewal after expiry. The ECR 2023 also indicates that the EC committee must consider project alternatives when reviewing EIAs. As per the guide- lines for scoping and preparing the EIA report, the proponent must provide an “overview of alternatives, selection of acceptable options and rationale for discarding other options.” It is not clear in the ECR whether the EC Committee can evaluate the “no project” option—although it could simply reject the ECC application—or consider an alternative that is different from the one selected by the developer, if there is a strong evidence base for promoting it. As in many other countries, the Bangladesh regulations give significant discretion to environmental authorities to evaluate EIAs and decide on the ECC application. Although the ECR detailed the required information for each step of the ECC process, the regulations do not provide many criteria to substantiate review and decision-making. Thus, the DoE should adopt detailed guidelines on the issues that need to be highlighted in the minutes of the EC Committee and other relevant decisions. Those issues include what specific decision was made (for example, allowing a project to start land development and construction right after the site clearance and in parallel of EIA); what alternatives were considered by the committee and the environmental, technical, and economic considerations of each alternative and the way in which these were balanced in the decision-making process; and whether all practicable means to avoid or minimize environmental harm from the selected alternative have been adopted or the reasons for not adopting them. The DoE should also require the public disclosure of those minutes. 4.7 Follow-up of ECC conditions Most EIA systems worldwide include a follow-up mechanism that helps authorities to ensure that the conditions included in the ECC are fulfilled, to monitor whether the environmental impacts are consistent with those predicted by the EIA, to assess whether the selected mitigation measures are effective, and to generate information to improve other EIAs. According to the ECR 2023, the developer must include in the EIA a program to monitor the implementation of the mitigation measures, other indicators such as compliance with applicable environmental standards, and information on the team and budget dedicated to the program. As in other countries, EMPs are often used as remedies for the lack of legally established en- vironmental standards or formal government programs. For example, some mitigation measures and other conditions included in the EMPs often include actions that are not necessarily related to the impacts that the project is expected to generate. Instead, some measures and conditions relate to activities (such as reforestation or education) that are socially desirable but that the au- thority is unable to carry out because of its constrained resources. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 71 Environmental Planning and Environmental Impact Assessment The ECR does not specify requirements on periodicity of monitoring reports from the proponent to the DoE. The most important follow-up mechanism remains the ECC renewal, for which the relevant DoE office must pay a site visit. At this stage, DoE officials are required to assess whether the project developer has met all the conditions included in the site and environmental clearances. The efficiency of this follow-up system is questionable. On-site inspection for ECC renewal has limited efficacy in environmental compliance because they are expected by the proponent, are unmanageable by the DoE limited workforce, and increase oppor- tunities for rent-seeking behavior.36 For example, as part of their EMPs, 172 industrial units have installed effluent-treatment plants (ETPs) in fiscal 2021/22, and the DoE has also approved Zero Discharge Plans proposed by 160 institutions. As of June 2022, the total number of industrial units with ETP was at 2,312 (MoEFCC 2023). However, the share of industries that operate the ETP on a regular basis is not clear since the DoE inspects most of them only through the site visits during the ECC process. There is also a significant discrepancy between the number of projects expected to apply for an ECC annual renewal and those that applied for it (Section 4.8). This may occur because of the DoE’s limited capacity to track, monitor, and follow up on ECC renewals, as well as limited understanding by ECC holders about their obligation to renew their clearances. All these factors point to the need to adopt automated systems that can help the DoE to manage the ECC process. To address that, the DoE has introduced automation software (ecc.DoE.gov.bd) to process and track the ECC and renewal applications of any industrial factories or projects. This software has enabled the DoE to track the expiration of ECCs and which industries and projects must apply for an ECC renewal. However, this website should be made easily accessible to the public and expanded to cover the ECC’s monitoring activities. In its current design, the website requires specific information in the search tool, such as the project or industry name or file number, to allow the public to search the status and relevant documents of an ECC application. To fulfill the disclosure requirements of the ECR 2023, the DoE must update the website design to make it more accessible to any citizen interested in various information, such as the ongoing projects in particular districts or thana and the totality of projects of a particular company in Bangladesh, as well as downloading relevant documents of specific ECCs. Additionally, the DoE should re- place field visits for the renewal of environmental clearances with more efficient oversight instruments, particularly for green and yellow projects, and redirect the human and financial resources used in those activities towards enhanced enforcement activities. To strengthen the ECC system, especially in the context of amending the ECA, the GoB should conduct an in-depth analysis of the conditions that have been included in ECCs for a wide variety of Red and Orange category projects and assess their effective- ness and efficiency in mitigating the project’s impacts. Results of this analysis would be crucial to inform the ECA amendment and next ECR revision. Another alternative that the GoB might consider consists of using a third-party system to conduct the monitoring of environ- mental and social indicators for high-risk projects. Under this system, the project developer or operators must cover the costs of such activities, but the funds are deposited in a government account. The DoE must then select the individuals or organizations that will conduct the monitoring from its registry and finance their services partially with fees collected from proponents during the ECC process. Additional mechanisms can help to reduce incentives for rent-seeking behavior. Such mechanisms include using software to randomly select the consultants that will carry out the work or restricting the number of years during which the same individuals can provide this service for the company 4.8 Trends in ECC applications and renewals The annual average of ECCs issued for projects with moderate to significant impacts (Orange and Red category projects) was more than 5,400 between 2015–2022 (as per 1997 ECR). The lower number of ECCs in 2020 and 2021 may be attributed to the economic slowdown associated with the COVID-19 pandemic. In 2022, the number of granted ECCs increased to 5,566. Even though under the ECR 1997 the ECCs of those project categories needed to be renewed annually, historical data show large variation in the number of ECCs that were renewed in that same period, ranging from 9,992 in 2015 to 14,759 in 2022 (table 4.2). For example, the DoE issued 38,242 ECCs for projects of Orange A, Orange B, and Red categories between 2015 and 2021, which required the entrepreneur to renew the certificates within one year. However, the DoE renewed only 14,759 ECCs in 2022. Even if part of those industry units and projects went out of business, the proportion is still low considering ongoing projects with their first ECC approved in or after 2015, as well as the ECC renewal of Green category projects that were required every three years under the ECR 1997. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 72 Environmental Planning and Environmental Impact Assessment Table 4.2 Approved and Renewed ECCs in Bangladesh, 2015–22 New ECCs Year Renewed ECCs Red Orange-B Orange-A Green Total 2015 399 3,123 2,726 16 6,264 9,992 2016 538 3,568 2,961 16 7,083 9,577 2017 681 3,731 2,450 25 6,887 10,451 2018 526 3,319 2,259 142 6,246 11,007 2019 613 3,322 1,263 117 5,315 11,778 2020 485 2,229 779 286 3,779 12,975 2021 564 1,969 737 263 3,533 12,076 2022 643 2,643 2,048 216 5,566 14,759 Source: http://DoE.portal.gov.bd/sites/default/files/files/DoE.portal.gov.bd/page/00bebf37_3b1e_4cde_b2d9_0eb26b5c33b1/2023-03-30-09-00-c8bc821f40d12ae27704adfb23f74547. pdf Note: Project categories are based on ECR 1997. In a study conducted between April 2019 and December 2021, Transparency International Bangladesh surveyed 353 industries in the Dhaka and Chattogram metropolitan areas, finding that 51 percent of those industries operated with an expired ECC and about 30 percent of them had applied for an ECC renewal. Based on the previous ECR, 22 percent of Red category projects re- portedly received an ECC even without submitting an EIA (Transparency International Bangladesh 2022) (figure 4.1). Figure 4.1. Renewal of ECCs in select industries Industries operating with expired ECC (%) Share of industries that applied for ECC renewal 62% 70% 72% 76% 38% 30% 28% 24% Source: Transparency International Bangladesh 2022. These shortcomings raise questions about the effectiveness of the ECC system. Approving and renewing so many ECCs are clearly beyond DoE’s capacity. As a point of comparison, an average of 269 EIAs were filed in the United States annually be- tween 2017 and 2021.37 Based on the previous ECR, the DoE was required to review an IEE for Orange B projects and EIA for Red projects. Given that most projects approved during 2015–2022 fell in the Orange B category and the high number of Red projects during this period, the ECC system created a growing workload for the DoE that was not matched with corresponding increases in budget and staff. In addition, most of the Red projects are related to power, water resources, land resources, and infrastructure-development projects. Reviewing these reports requires very specific expertise, but only DoE staff participated in this process under the ECR 1997. Therefore, there is a high risk that lack of relevant expertise in the EC Committee and public consultations resulted in poor-quality EIA reports. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 73 Environmental Planning and Environmental Impact Assessment Despite strengthening the ECC process, the ECR 2023 will generate additional workload for the DoE, such as public consultations for EIAs and on-site inspections for all project categories, and pressure on its officers to comply with deadlines. Without adequate resources, the DoE will not be able to fully implement the new ECR, with a risk of generating a backlog of applications and approv- ing substandard clearances. 4.9 Conclusions and recommendations Although EIAs by themselves do not lead to significant environmental improvements, they can work as powerful informational tools and lead to increased public participation and environmental awareness (Hironaka and Schofer 2002; Meyer et al. 1997; Rea and Frickel 2000). In Bangladesh, as in many other countries, the EC process tends to focus on meeting pro forma legal re- quirements, rather than concrete actions to improve the project’s environmental performance beyond minimum requirements for managing negative environmental effects. Thus far, these assessments have (a) lacked effective public participation to inform project development, and (b) have resulted in recommendations that are seldom monitored and enforced. By making the EC its predominant environmental management tool (chapter 3), Bangladesh has not taken sufficient advantage of EC’s potential role in opening decision-making to public scrutiny. A major challenge in increasing the effectiveness of EIA to improve decision-making is to develop an economically efficient environmental policy and regulatory framework in which dif- ferent command-and-control regulations, market-based instruments, and information and disclosure tools complement one another (chapter 9). As a first measure, the DoE should conduct an in-depth, independent evaluation of the conditions that have been included in ECCs for Red and Orange category projects and assess their effectiveness and efficiency in mitigating the project’s impacts, including a mitigation-hierarchy approach. This analysis would allow the DoE to extract common challenges and lessons to inform policy formulation—not only for improving the EC process, but also for further regulations dealing with specific tech- nical requirements. As mentioned in the National Environmental Policy 2018 and the 8th FYP, the GoB should amend the ECA or adopt a specific act to require SEAs for policies, programs, and plans, and establish the mandates and procedures for those assessments. For example, the GoB should evaluate whether the DoE or the Planning Commission would oversee SEAs. Although the ECR 2023 is expected to improve the EC process, additional amendments and guidelines are required to clarify and strengthen assessment criteria and procedures related to key themes. In this revision, the GoB should consider exempting projects that are not expected to cause significant environmental impacts (Green and some Yellow projects) from the ECC process and instead focus on regulating them through other instruments, such as technical standards for specific activities or land-use zoning. This exemption should be accompanied by other reforms and investments to ensure that enforcement can be effectively done through other policy instruments (chapter 9). In addition, the MoEFCC and the DoE should consider in those new regulations and guidelines (a) clarifying the screening of proj- ects that are not pre-categorized in the ECR, beyond the pollution criteria envisaged in Schedule 14 of the ECR 2023; (b) requiring an analysis of project alternatives (including the “no-go” option); (c) strengthening the monitoring program after ECC issuance; (d) addi- tional themes such as resource efficiency, impact to and from climate change, OHS, CHS, labor and workers’ rights in collaboration with relevant government agencies and referring to applicable legislation in other sectors; (e) differentiated treatment of vulnerable groups in the assessment and management measures; (f) specific regulations for framework projects or programs, which should follow an environmental and social management framework; and (g) expanding the requirements of stakeholder consultations and access to information to other project categories. In the short-term, the DoE also needs to (a) revise the EIA Guidelines for Industres 2021, updating and expanding their contents as per the ECR 2023; and (b) develop guidelines for non-industry projects, preferably by sector, which could be based on guidance instruments issued by international organizations. These guidelines should be gazetted and made legally binding. These reforms must be accompanied by adequate resources at the DoE, including increased and more stable headcount, increased budget, and equipment. To strengthen enforcement as a follow-up of the ECC process, the DoE should consider (a) making its ECC processing and tracking software easily accessible to the public and expand its coverage to ECC monitoring activities; (b) enhancing other en- forcement activities instead of conducting on-site inspections for ECC renewals of Green and Yellow projects, which have limited efficacy; (c) using a third-party system to conduct the monitoring of environmental and social indicators for high-risk projects; and (d) other mechanisms that can help reduce incentives for rent-seeking behavior. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 74 Environmental Planning and Environmental Impact Assessment C4 References / Endnotes Abracosa, R., and L. Ortolano 1986. “Evaluation of the Philippine Environmental Impact Statement System: 1977–1985.” Philippine Planning Journal 18 (1): 1–29. Abracosa, R., and L. Ortolano. 1987. “Environmental Impact Assessment in the Philippines: 1977–1985.” Environmental Impact Assessment Review 7 (4): 293–310. Acerbi, M., E. Sánchez-Triana, S. Enríquez, R. Tiffer-Sotomayor, A. Gomes Lima, K. Siegmann, P. Clemente-Fernandez, and N. Nkrumah. 2014. “Environmental Impact Assessment Systems in Latin America and the Caribbean.” IAIA Conference, 2014. http://www.iaia.org/conferences/iaia14/IAIA14-finalpapers/Acerbi,%20 Marcelo.%20%20EIA%20systems%20in%20Latin%20America%20and%20the%20Caribbean.pdf Ahmed, Tanvir, Md. Quamrul Hasan, and Mohammad Osman Sarwar. 2021. “Trends in Punitive Actions against Environmental Pollution in Bangladesh.” IAIA Conference. https://conferences.iaia.org/2021/edited-papers/1246_AHMED_Trends%20in%20Punitive%20Actions.pdf Al Farhad, M. M., N. K. Yadev, D. D. Basu, and I. Garg. 2022. “Environmental Impact Assessment: Evaluation of Legislations in Countries of Africa and South Asia.” Centre for Science and Environment, New Delhi. file:///C:/Users/16507/Desktop/Downloads/http___cdn.cseindia.org_attachments_0.35395300_1657777136_ environmental-impact-assessment-report.pdf Chanchitpricha, C., and A. Bond. 2013. “Conceptualising the Effectiveness of Impact Assessment Processes.” Environmental Impact Assessment Review 43: 65–72. ISSN 0195-9255, https://doi.org/10.1016/j.eiar.2013.05.006. DoE (Department of Environment). 2023. Annual Report 2021–2022. http://www.DoE.gov.bd/sites/default/files/files/DoE.portal.gov.bd/annual_reports/7b7587fa_ cfe1_4b2a_aa5c_f6b27202b8fa/2023-03-24-09-12-551f98f0ffba744894abfb8100b3b2af.pdf Dhaka Tribune. 2022. “TIB: 66% of Industries Gained Certificates with Bribes.” Tribune Report (January 5, 2022). https://www.dhakatribune.com/nation/2022/01/05/ tib-66-of-industries-gained-eia-certificates-with-bribes 66% Environmental Law Institute. 2010. India 2030: Vision for an Environmentally Sustainable Future. Best Practices Analysis of Environmental Protection Authorities in Federal States. Study commissioned by the World Bank, Washington, DC. http://www.eli.org/pdf /india2030.pdf. Ferdous, B. F. 2017. Governance for Green Growth in Bangladesh: Policies, Institutions and Political Economy. United Kingdom Agency for International Development. https://www.greengrowthknowledge.org/research/governance-green-growth-bangladesh-policies-institutions-and-political-economy Hironaka, A., and E. Schofer. 2002. “Decoupling in the Environmental Arena: The Case of Environmental Impact Assessment.” In Organizations, Policy and Natural Environment: Institutional and Strategic Perspectives, edited by Andrew J. Hoffman and Marc J. Ventresca, 214–31. Stanford, CA: Stanford University Press. Iftekharuzzaman. 2022. “The Department of Environment Needs a Complete Overhaul.” Interview by Readus Salehen Jawad. Business Standard. https://www. tbsnews.net/features/panorama/department-environment-needs-complete-overhaul-355870 Lima, Ana Luisa, Darshani De Silva, Tapas Paul, Javaid Afzal, Shakil Ahmed Ferdausi, Santiago Enriquez, Mohammed Arif Rasuli, Drona Raj Ghimire, Bilal H. Rahill, and Ernesto Sánchez-Triana. 2015. “Environmental Impact Assessment Systems in South Asia.” April 2015. Paper presented at the Annual Conference of the International Association for Impact Assessment, Florence, Italy. Lima, A. L., A. Takura, A. Rajbhandari, D. Balakrishnan, D. R. Ghimire, E. Mishra, M. Wijeyeratne, M. A. Rasuli, Rajapakse, N. Laureano, S. Ahmed, S. Shobair, and S. M. Zulkernine. 2023. “Environmental Impact Assessment Systems in South Asia.” April 2023. Poster presented at the Annual Conference of the International Association for Impact Assessment, Kuching, Malaysia. Maitrot, M. 2017. Unpacking the ‘Bangladesh Paradox’: The Politics of Inclusive Economic and Social Development. Blog. Effective States and Inclusive Development. http://www.effective-states.org/unpacking-the-bangladesh-paradox-the-politics-of-inclusive-economic-and-social-development/ Margulis, S., and T. Vetleseter. 1999. “Environmental Capacity Building: A Review of the World Bank’s Portfolio.” Environment Department Paper 68, Pollution Management Series, Washington, DC: World Bank. Meyer, John W., David John Frank, Ann Hironaka, Evan Schofer, and Nancy Brandon Tuma. 1997. “The Structuring of a World Environmental Regime, 1870–1990.” International Organization 51 (4): 623–51. MoEFCC (Ministry of Environment, Forest and Climate Change). 2023. Annual Report 2021–2022. https://moef.portal.gov.bd/sites/default/files/files/moef.portal. gov.bd/page/9e7634a4_c7d4_49aa_b2e2_29005bf1e107/MoEFCC_Annual_Report_2021_22.pdf MoEFCC (Ministry of Environment, Forest and Climate Change). 2023. Environment Conservation Rules 2023. Ministry of Environment, Forest, and Climate Change. Nahar, N., S. Mahiuddin, and Z. Hossain. 2021. “The Severity of Environmental Pollution in the Developing Countries and Its Remedial Measures.” Earth 2: 124–39. https://doi.org/10.3390/earth2010008 North, D. C. 1990. Institutions, Institutional Change, and Economic Performance. Cambridge, UK: Cambridge University Press. North, D. C. 1991. “Institutions.” Journal of Economic Perspectives 5 (1): 97–112. Ortolano, L., B. Jenkins, and R. Abracosa. 1987. “Speculations on When and Why EIA is Effective.” Environmental Impact Assessment Review 7 (4): 285–92. Rea, Christopher M., and Scott Frickel. 2000. “The Nation-State and the Natural Environment Over the Twentieth Century.” American Sociological Review 65: 96–116. https://journals.sagepub.com/doi/full/10.1177/07352751231184462 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 75 Environmental Planning and Environmental Impact Assessment Sánchez-Triana, E. 2021. Environmental Challenges for Green Growth and Poverty Reduction: A Country Environmental Analysis for The Lao People’s Democratic Republic. Washington, DC: World Bank Group. http://hdl.handle.net/10986/36266 Sánchez-Triana, E., and L. Ortolano. 2001. “Organizational Learning and Environmental Impact Assessment at Colombia’s Cauca Valley Corporation.” Environmental Impact Assessment Review 21 (1): 223–39. Sánchez-Triana, E., J. Afzal, and S. Enriquez. 2014. “The Role of International Organisations and Development Banks in Pakistan’s Environmental Impact Assessment Practices.” Environmental Impact Assessment Handbook for Pakistan. Islamabad: IUCN Pakistan. Sánchez-Triana, E., S. Enriquez, J. Afzal, A. Nakagawa, and A. K. Shuja. 2014. Cleaning Pakistan’s Air: Policy Options to Address the Cost of Outdoor Air Pollution. Washington, DC: World Bank. doi:10.1596/978-1-4648-0235-5. Sánchez-Triana, E., E. Enriquez, B. Larsen, P. Webster, and J. Afzal. 2015. Sustainability and Poverty Alleviation: Confronting Environmental Threats in Sindh, Pakistan. Directions in Development. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/22149 Transparency International Bangladesh. 2022. Governance Challenges of the Department of Environment and Way Forward. https://www.academia. edu/78900482/Governance_Challenges_of_the_Department_of_Environment_and_Way_Forward Webster, A., N. Hossain, S. Mahmud, S. Nazneen, and K. Sen. 2017. The Bangladesh Paradox: Why Has Politics Performed So Well for Development in Bangladesh? ESID Briefing No. 27. Effective States and Inclusive Development. https://www.effective-states.org/wp-content/uploads/2017/02/ESID-Briefing-Paper-27- Bangladesh-Paradox.pdf World Bank. 2003.  World Development Report 2003: Sustainable Development in a Dynamic World--Transforming Institutions, Growth, and Quality of Life. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/5985 World Bank. 2007. Republic of Peru Environmental Sustainability: A Key to Poverty Reduction in Peru (English). Washington, DC: World Bank Group. http:// documents.worldbank.org/curated/en/896441468296943537/Republic-of-Peru-environmental-sustainability-a-key-to-poverty-reduction-in-Peru World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank Group. http://hdl.handle.net/10986/30558 Endnotes 35 Schedule 9 of the ECR 2023 includes the guidelines applicable to project location and provides additional details, such as the buffer distances that should be considered between different types of projects and sensitive areas. Projects that will be developed in export-processing zones, economic zones, and in the Bangladesh Small and Cottage Industries Corporation’s industrial cities are exempted from the site-clearance requirement. 36 Jagonewy24.com. 2023. “ACC Investigation: Department of Environment Is Drowning in Corruption-Irregularity-Inefficiency” (March 21, 2023) (Translated from Bengali). https://www.jagonews24.com/national/news/841445. Dhaka Post. 2023. “5 Reasons for Corruption in the Department of Environment, ACC Wants Measures” (March 21, 2023) (Translated from Bengali). https://www.dhakapost.com/exclusive/181348. Jugantor. 2022. “Corruption in Environment Department: Take note of TIB’s recommendations” (January 7, 2022) (Translated from Bengali). Daily Star. 2022. “Corruption institutionalized in Environment Department: TIB” (January 5, 2022) (Translated from Bengali). Daily Star. 2022. “Is the Department of Environment Tainted by Corruption? ” (January 7, 2022) (Translated from Bengali). 37 Based on query conducted in the Environmental Impact Statement database. https://cdxapps.epa.gov/cdx-enepa-II/public/action/eis/search BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 76 Cost-Benefit Analysis of Environmental Health-Risk Interventions CHAPTER 5. COST-BENEFIT ANALYSIS OF ENVIRONMENTAL HEALTH-RISK INTERVENTIONS 5.1 Introduction In Bangladesh, the annual cost of environmental pollution associated with the five major environmental health-risk factors is estimated at the equivalent of 17.6 percent of GDP in 2019, as elaborated in chapter 2. Numerous interventions are available to mitigate, control, and prevent many of these health effects at a wide range of costs with varying levels of effectiveness. This chapter aims to identify interventions that promise the greatest environmental health improvements or benefits per taka spent on the interventions. It analyzes the benefits and costs of potential interventions to mitigate health effects for all five major risk factors (table 5.1). The analysis presents benefit-cost ratios (BCRs) of interventions—with BCR being the ratio of benefits to costs. A BCR greater than one indicates that the benefits are greater than costs, with benefits and costs discounted at an annual rate of 5 percent. Table 5.1 Scope of the cost-benefit analysis of environmental health interventions in Bangladesh Environmental health-risk factor Interventions (I’s) # I’s PM2.5 ambient air pollution Interventions in various sectors 21 PM2.5 household air pollution from the use of solid Cleaner cooking (improved biomass cookstoves, liquified petroleum gas 4 fuels for cooking (LPG), electric stoves) Lead exposure Iron supplementation for young children, mitigation of lead exposure from 3 recycled aluminum cookware, and rehabilitation of abandoned used lead acid battery (ULAB) recycling site Microbiological pollution from Household point-of-use treatment (POUT) of drinking water 6 Inadequate drinking-water quality Pour-flush/flush toilets with septic tank 2 Inadequate household sanitation Adequate handwashing with soap 4 Inadequate hygiene Arsenic in drinking water Deep tube wells, pond sand filtering, and household filtering 3 of drinking water Source: World Bank. 5.2 Benefits and costs of PM2.5 ambient air pollution control interventions Annual deaths from population exposure to ambient PM2.5 and household PM2.5 air pollution from the use of solid fuels is es- timated at nearly 160,000 in 2019, along with 2.6 billion days lived with illness. Therefore, improvements in ambient PM2.5 air quality and the use of clean fuels and technologies for cooking can provide substantial health benefits such as reduced cardio- vascular, respiratory and type 2 diabetes illness and mortality. The World Bank employed the GAINS38 model of the International Institute for Applied Systems Analysis (IIASA) to identify cost-effective or least-cost PM2.5 control measures for reaching potential ambient PM2.5 targets for 2030 (World Bank 2022). The model was also employed to study air quality improvements and associated pollution abatement costs including marginal costs of PM2.5 control measures and their effect on ambient PM2.5 in Bangladesh in 2030 (Wagner et al. 2020).39 Applying the results from the two studies, estimated ambient PM2.5 in Bangladesh is reduced from 61 µg/m3 to 41 μg/m3 in 2030 by implementing least-cost control measures (figure 5.1). These measures include eliminating household use of solid fuels by 2030 by switching to LPG or electricity for cooking. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 77 Cost-Benefit Analysis of Environmental Health-Risk Interventions Figure 5.1 Ambient PM2.5 in Bangladesh, 2019–30 | μg/m3 Source: World Bank. 5.2.1 Costs of interventions to control PM2.5 ambient air pollution The GAINS cost-effectiveness analysis for Bangladesh presents 165 measures to control PM2.5 and its precursors that are grouped into 21 categories. Control measures from 13 categories for which benefits are larger than the costs of the measures are presented in table 5.2 and figure 5.2.40 Costs are expressed in constant prices to 2030.41 Cost ranges from less than zero to $161 million (Tk 13,524 million) per year per μg/m3 improvement in ambient PM2.5. These interventions are estimated to reduce ambient PM2.5 from 61 to 41 μg/m3 in 2030, providing a 20 μg/m3 improvement in ambient PM2.5 . Control measures include reducing household use of solid fuels. Solid-fuel use affects both indoor PM2.5 air pollution and outdoor ambient PM2.5 concentrations since smoke from solid-fuel combustion escapes through chimneys, doors, windows, and other openings. Households switching to LPG for cooking provide the greatest reduction in ambient PM2.5 followed by nitrogen oxides (NOx) and sulfur dioxide (SO2) (PM2.5 precursors) control in power plants, eliminating solid waste burning by recycling and organic waste management. Other measures for which the benefits exceed the costs include Stage 2 standards for buses, SO2 control in industry, Stage 24 standards for trucks, and Stage 4 standards for cars. The cumulative reduction in ambient PM2.5 from these measures is minimal (0.06 μg/m3) and not reflected in table 5.2 and figure 5.2. Table 5.2 Cost of PM2.5 control measures | Million $ per year per μg/m3 of ambient PM2.5 improvement Control measures Cost Agricultural fertilizer – improved management 161 Agricultural livestock – manure management 138 Power plants – NOX control 92 Power plants – SO2 control (FGD) 83 Cooking with LPG 72 Power plants – PM control 60 Off-road – stage 3 to 6 standards 52 Industry – NOX control 43 Engines – NOX control 32 Agricultural residue – ban burning 5 Industry – PM control 3 Solid waste recycling and rural organic waste management ≤0 Cleaner small combustion devices ≤0 Source: World Bank, based on data in Wagner et al. (2020) and World Bank (2022). Note: Cost less than or equal to zero (≤0) means that the intervention yields monetary benefits that off-set or more than off-set the cost. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 78 Cost-Benefit Analysis of Environmental Health-Risk Interventions Figure 5.2 Cost of PM2.5 control measures | Million $ per year per μg/m3 of ambient PM2.5 improvement Source: World Bank, based on data in Wagner et al. (2020) and World Bank (2022). Note: Cost less than or equal to zero (≤0) means that the intervention yields monetary benefits that offset or more than offset the cost. 5.2.2 Benefits of interventions for controlling PM2.5 ambient air pollution The benefits estimated here of the PM2.5 control measures are limited to health improvements and, as a result, are conservative. The health benefits of comprehensive PM2.5 control measures are estimated for three scenarios in 2030: (a) PM2.5 control mea- sures without changes in household use of solid fuels; (b) control measures eliminating household use of solid fuels without other PM2.5 control measures; and (c) PM2.5 control measures including elimination of household use of solid fuels. The first and second scenarios are estimated to reduce population-weighted ambient PM2.5 by about an equal magnitude of 10 μg/m3. The third scenario results in an improvement equal to the sum of the first two scenarios. However, the estimated health benefits in each scenario are very different (table 5.3): • Annual deaths avoided (42,000) in the second scenario are four times as high as in the first scenario (10,800); • Annual deaths avoided in the third scenario are nearly 61,300. This is 36 percent of the baseline deaths from PM2.5 that would prevail in 2030 in the absence of PM2.5 control measures; and • Annual deaths avoided in the third scenario are nearly 8,500 more than the sum of the first two scenarios. In the first scenario, the benefit is limited to improvement in ambient PM2.5. The second scenario brings two benefits: ambient PM2.5 improvement and elimination of PM2.5 household air pollution from the use of solid fuels. The third scenario achieves substantial health benefits beyond the sum of benefits in the first two scenarios. This is because incremental health benefits increase at lower ambient PM2.5 concentrations.42 Thus incremental health benefits are increasing the more PM2.5 exposure is reduced. This is the case in the third scenario at ambient PM2.5 of 41 μg/m3 versus 51 μg/m3 in the first and second scenario.43 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 79 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.3 Annual deaths avoided in Bangladesh from comprehensive PM2.5 control measures, 2030 Reduction in population Annual Annual deaths weighted ambient PM2.5 deaths avoided (% of (μg/m3) avoided baseline deaths) Comprehensive PM2.5 control measures (with no reduction in 1 10 10,783 6 household use of solid fuels) Elimination of household use of solid fuels (without other PM2.5 2 10 42,021 24 control measures) Comprehensive PM2.5 control measures including elimination of 3 20 61,290 36 household use of solid fuels Source: World Bank estimates. The estimated health benefits from the three scenarios can be expressed in terms of annual deaths avoided per μg/m3 of im- provement in population-weighted ambient PM2.5 (table 5.4), which shows the following: • Eliminating household use of solid fuels results in 4,202 avoided deaths per year for each μg/m3 improvement in ambient PM2.5. This is four times as effective as other PM2.5 control measures that provide the same ambient PM2.5 improvement but no change in household use of solid fuels; and • PM2.5 control measures are 80 percent more effective in avoiding deaths if household use of solid fuels is eliminated. Table 5.4 Annual deaths avoided per μg/m3 improvement in ambient PM2.5 in Bangladesh, 2030 Annual deaths avoided per μg/m3 improvement Elimination of household use of solid fuels (for example, switching to LPG or electricity), 4,202 and no other PM2.5 control measures Comprehensive PM2.5 control measures for ambient PM2.5 improvements 1,927 (with elimination of household use of solid fuels) Comprehensive PM2.5 control measures for ambient PM2.5 improvements 1,078 (with no reduction in household use of solid fuels) Source: World Bank estimates. Avoided deaths and illness are valued by applying the methodologies in appendixes H and I. The annual benefits of switching from biomass to LPG or electricity for cooking are Tk 68,665 million per μg/m3 improvement in ambient PM2.5, and Tk 31,488 for other least-cost comprehensive PM2.5 control measures (table 5.5). Table 5.5 Benefits of PM2.5 control interventions per year per μg/m3 improvement in ambient PM2.5 Tk, millions $, millions Benefits of LPG and electricity for cooking 68,665 817 Benefits of other comprehensive PM2.5 control measures 31,488 375 Source: World Bank estimates. Note: Benefits are in 2019 constant Tk. 5.2.3 Benefit-cost ratios of interventions to control PM2.5 ambient air pollution BCRs of the PM2.5 control measures range from 2.3 to 134, indicating that health benefits are Tk 2 to Tk 134 for each Tk spent on these measures (figure 5.3). Only three measures have a BCR larger than for LPG for cooking because LPG per μg/m3 also brings the benefits of household air pollution control (see table 5.10).44 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 80 Cost-Benefit Analysis of Environmental Health-Risk Interventions Figure 5.3 Benefit-cost ratios of PM2.5 control measures Industry – PM control 134 Agr. ewsidue – ban burning 84 Engines – NOx control 11.8 LPG stoves 11.3 Industry – NOx control 8.8 Off-road – stage 6 standards 7.3 Powerplants – PM controls: dedusters 6.2 Powerplants – SO2 control: flue gas desul. 4.6 Powerplants – NOx control 4.1 Agr. livestock – manure management 2.7 Agr. fertilizer – improved management 2.3 0 20 40 60 80 100 120 140 160 Source: World Bank estimates. The cost of the comprehensive PM2.5 control measures for which benefits exceed costs is $1.3 billion (Tk 109 billion) per year while the benefit of these measures is $11.4 billion (Tk 954 billion). This gives a BCR of 8.8. Switching to cooking with LPG represents 57 percent of the cost and 73 percent of the benefit (table 5.6). Table 5.6 Cost and benefits of comprehensive ambient PM2.5 control measures | $, millions, per year Costs Benefits BCR Lowest cost measures for first 5 μg/m improvement in ambient PM2.5 (not LPG) 3 79 1,250 15.9 Lowest cost measures for next 5 μg/m improvement in ambient PM2.5 (not LPG) 3 481 1,861 3.9 LPG for cooking for next 10 μg/m improvement in ambient PM2.5 3 732 8,252 11.3 For cumulative 20 μg/m improvement in ambient PM2.5 3 1,292 11,362 8.8 Source: World Bank estimates. Note: Costs and benefits are in constant 2019 values. Further ambient PM2.5 air quality improvements can be achieved but only at increasingly higher costs. Such control measures were assessed by GAINS. Cumulative reductions in ambient PM2.5 from these measures are 3.5 μg/m3, or less than 15 percent of reductions from lower cost PM2.5 control measures that have BCR greater than one. The total cost of high-cost measures is nearly $4 billion per year per μg/m3 while total benefit is $1.25 billion, with a BCR of 0.3. The measures include further control of vehicle emissions, primary PM2.5 and PM2.5 precursors from industry and power plants, emissions from engines and small combustion devices, urban organic waste management (instead of burning), and measures in the agricultural sector. The remaining ambient PM2.5 concentrations estimated to prevail after implementation of the comprehensive measures discussed above are largely due to transnational PM2.5 pollution from neighboring countries, and secondly due to natural sources and PM2.5 and precursor emissions for which abatement cost is likely to exceed benefits. 5.2.4 Conclusions regarding interventions to control PM2.5 ambient air pollution The health effects of population exposure to ambient PM2.5 and PM2.5 household air pollution will continue to be enormous un- less comprehensive PM2.5 control measures are undertaken. Comprehensive PM2.5 control measures may reduce ambient PM2.5 by as much as 33 percent by 2030 which include interventions to eliminate burning of solid waste and improved management of agricultural fertilizers and livestock manure in addition to traditional sectors of pollution such as power plants, industry, and road vehicles. It will also require a full substitution from household use of solid fuels to LPG or electricity as household use of solid BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 81 Cost-Benefit Analysis of Environmental Health-Risk Interventions fuels is the largest single contributor to elevated ambient PM2.5. BCRs of comprehensive PM2.5 control measures that provide one- third improvement in ambient PM2.5 range from 2 to 134, rather 127 indicating health benefits are Tk 2 to 134 for each Tk spent on these measures. Additional PM2.5 control measures were also assessed which may further improve ambient PM2.5 by 5 percent, but at a cost that is substantially higher than the value of expected health benefits. Further ambient PM2.5 improvements can be achieved by collaborating with neighboring countries (especially with India) to address transnational PM2.5 pollution and benefit all countries involved. 5.3 Benefits and costs of interventions to control household air pollution About 74 percent of Bangladesh’s population used solid fuels as the primary cooking fuel in 2022 according to the Population and Housing Census 2022 (BBS 2022). Cooking with clean energies (for example, electricity, LPG, natural gas, biogas) was prac- ticed by 26 percent of the population. About 8.8 million improved biomass cookstoves (ICSs) have been distributed. These are 5 million Bondhu Chula chimney stoves and 3.8 million IDCOL stoves most of which are a single burner portable stove without chimney (see chapter 2). This means that up to 21 percent of households in Bangladesh have an ICS if all stoves are still in use, and at least 53 percent still use traditional cookstoves (TCS). Among those using solid fuels, 25 percent cook in the main house, 42 percent in a separate building, and 33 percent cook outdoors (BBS/UNICEF 2019). This report assesses the benefits and costs of cookstove interventions for households that still use TCS. The interventions reduce household PM2.5 air pollution from the use of solid fuels. The interventions are programs for household adoption of ICSs, LPG, and electric cooking devices. Some ICSs are portable single-burners with no venting of smoke, others are single-, double-, or even triple-burner stoves with chimney. LPG stoves have one to four burners. Electric cooking devices include conventional electric stove (ES), electric induction stove (EIS), electric rice cooker and electric pressure cooker (Saha, Razzak, and Khan 2021; World Bank 2021). As rice cookers and pressure cookers are becoming increasingly popular, they are used in combination with ICS, LPG, or other electric cooking devices. The intervention stoves and devices assessed are (a) single-burner ICS without chimney; (b) ICS with chimney and two burners; (c) LPG stove with two burners; (c) conventional ES with two plates plus rice cooker or pressure cooker; and (d) EIS with two plates plus rice cooker or pressure cooker. Household use of solid fuels has community effects and wider regional effects. An ICS with chimney is more effective for the household than a single-burner chimneyless stove but contributes more to increased outdoor ambient pollution and household pollution in nearby dwellings. Only clean energies and technologies prevent these externalities. To achieve the maximum ben- efits per unit of expenditure on household energy and stove interventions, all households in a community need to participate, and thus achieve a “clean cooking” or an “improved cookstove” community. This concept is especially applicable to clustered household communities. Two burner stoves make households less likely to continue using their TCS(s) to meet their cooking needsThe intervention distinction between conventional electric stove and electric induction stove is made due to the significantly higher energy efficiency of the induction stove. Benefits of the interventions are assessed in three household cooking environments with different air pollution exposure levels: (a) cooking in the house; (b) cooking in a separate building; and (c) cooking outdoors to reflect the main cooking practices in Bangladesh. Pre- and post-intervention assessment is undertaken with respect to (a) household members’ reduction in PM2.5 exposure result- ing from the intervention; (b) health benefits of household members’ reduced PM2.5 exposure; (c) household non-health benefits (that is, fuel and cooking-time savings); and (d) stove and energy costs of interventions. 5.3.1 Pre-intervention PM2.5 exposures in households Pre-intervention PM2.5 exposures refer to exposures in households that still use TCSs. One study measured personal PM2.5 ex- posures averaging 144 µg/m3 among 200 adult women cooking with solid fuels in TCS in rural areas in Chittagong and Dhaka divisions. Measurements were conducted over a 48-hours period once in the dry season and once in the wet season (Shahriar et al. 2021). More recently, a study of 300 adult women in five divisions measured personal PM2.5 over a 24-hour period in the dry season (Berkeley Air Monitoring Group 2022). Personal exposures averaged 236 µg/m3 among the women cooking with TCS. The personal exposures in these two studies include the exposure to ambient PM2.5 in addition to PM2.5 from household use of solid fuels. Subtracting ambient PM2.5 gives net household air pollution personal exposure among adult women of 87 µg/m3 based BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 82 Cost-Benefit Analysis of Environmental Health-Risk Interventions the study by Shahriar et al. and 124 µg/m3 based on the study by Berkeley Air Monitoring Group.45 The average exposure from the two studies is 106 µg/m3 and is used here as the pre-intervention PM2.5 exposure for adult women. Personal exposures for adult men and children are estimated using men/women and children/women exposure ratios of 64 and 85 percent, respectively, from the Global Burden of Disease (GBD) 2019 that is based on a review of personal exposure studies globally. These ratios reflect that men and young children generally spend less time in the household environment and the kitchen than adult women. Av- erage pre-intervention exposure from the use of solid fuels for all household members is therefore 87 µg/m3. This is an average across all household cooking locations (table 5.7). Personal exposures from cooking outdoors or in a separate building are set at 60 and 80 percent, respectively, of exposure from cooking in the house. Table 5.7 Long-term personal PM2.5 exposure from solid fuels by cooking location in households using traditional cookstoves | µg/m3 Adult Adult Children Average women men < 5 years Average across all cooking locations 106 68 90 87 Cooking in house 135 86 115 111 Cooking in separate building 108 69 92 89 Cooking outdoors 81 52 69 66 Source: World Bank estimates. Note: The estimates are net of exposure to ambient PM2.5. 5.3.2 Post-intervention PM2.5 exposures in households The use of ICSs, LPG, and electric stoves is expected to reduce household members’ exposure to PM2.5 from cooking. Review of personal exposure studies before and after installation of an ICS indicates a reduction in exposure of 50 – 60 percent (Larsen 2017; Pope et al. 2017; Shupler et al. 2018). In Bangladesh, the study by Berkeley Air Monitoring Group (2022) found that PM2.5 gross and net personal exposures among households using the ICSs by IDCOL were, respectively, 23–39 and 44–75 percent lower than exposures in households using TCSs. Net personal exposure is the exposure from the use of solid fuels—that is, gross personal exposure less ambient PM2.5. Personal exposures were lowest in the households using double-burner chimney stoves as this stove allows most households to not having to also use the TCS for their cooking needs. Among the households that used ICSs personal exposures were highest among those using the single-burner portable stove without chimney (table 5.8). Table 5.8 Personal PM2.5 exposure reduction from ICS TCS ICS ICS ICS single-burner single-burner double-burner portable stove chimney stove chimney stove PM2.5 gross personal exposure (µg/m3) 236 181 167 143 Reduction in gross personal exposure (%) -23 -29 -39 Ambient PM2.5 exposure (µg/m ) 3 112 112 112 112 PM2.5 net personal exposure (µg/m ) 3 124 69 55 31 Reduction in net personal exposure (%) -44 -56 -75 Source: Based on Berkeley Air Monitoring Group (2022) and ambient PM2.5 data from DoE (2023). Note: TCS = Traditional cookstove; ICS = Improved biomass cookstove. Exposure reductions over the life of the ICS are likely to be less than observed at any point during its useful life since the quality of the ICS deteriorates over time. Consequently, 40 and 65 percent reductions in net personal exposure are applied here for the ICS single-burner stove without chimney and the ICS double-burner stove with chimney, respectively. This reduction is applied to households cooking in the house. Exposure reductions from an ICS for households cooking in a separate building or outdoors may be less than for households cooking in the house, because an ICS would provide less exposure reduction to household mem- bers who tend to spend less time in these locations than in the house. Thus, lesser exposure reductions are applied to households cooking in a separate building and outdoors (table 5.9). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 83 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.9 Personal PM2.5 exposure reduction from ICS by cooking location | Percent reduction Exposure reduction from single-burner ICS Exposure reduction from double-burn- without chimney er ICS with chimney In house 40 65 Separate building 35 55 Outdoors 25 40 Source: World Bank estimates. Note: ICS = Improved biomass cookstove. LPG combustion results in very little PM2.5 emissions and is considered a relatively clean cooking fuel. The total personal ex- posure to PM2.5 among households exclusively using LPG is thus determined by ambient air pollution including PM2.5 from neighboring households using solid fuels. It is therefore stipulated that personal exposure levels in households exclusively us- ing LPG are zero from cooking and total exposure is ambient PM2.5 concentration level. These exposure levels are also applied to households using electric stoves. 5.3.3 Costs of interventions to control household air pollution Many ICS programs have suffered from low adoption and user rates, poor maintenance, and outright abandonment of the ICS in favor of the old TCS (Hanna, Duflo, and Greenstone 2016; Miller and Mobarak 2015; Mobarak et al. 2012). This is particularly the case with programs that are not demand driven—that is, when stoves are distributed for free or at a highly subsidized rate whether or not households want the stoves (Hanna, Duflo, and Greenstone 2016). Thus, for large-scale adoption of cleaner cookstoves and cooking energies to occur several factors influencing adoption rates must be addressed, such as: (a) high initial cost of ICSs; (b) high annual fuel cost of LPG fuel and electricity; (c) tailoring to consumers’ preferences for stove characteristics; (d) installment financing of stoves and LPG auxiliary equipment (gas cylinder, hose, connection); (e) well-targeted information campaigns; and (f) community focus similar to total sanitation and “open defecation free” community programs. Kar and Zerriffi (2015) present a theoretical framework for achieving successful stove-promotion programs. The framework stip- ulates that behavior change for stove adoption and proper use is a process that unfolds over time through a series of six distinct stages. The stages are (1) precontemplation, (2) contemplation, (3) preparation, (4) action, (5) maintenance, and (6) termination. For stove-promotion programs to be successful, they must consider each stage. This includes well-designed behavioral change communication (BCC) strategies, overcoming obstacles to stove adoption (for example, identify desirable stove technology and design, stove financing, warranty, stove satisfaction guarantees), stove servicing and maintenance follow-up. 5.3.4.1 Cost of stoves and equipment The costs of interventions are (a) stove and equipment cost; (b) stove maintenance and repair cost; (c) cost of program to pro- mote the intervention; and (d) energy cost. The cost of ICSs varies depending on fuel and emission efficiency, number of burners, durability, materials, and technology. The cost of three main types of the ICS from IDCOL range from Tk 375 for a portable sin- gle-burner stove without chimney to Tk 1,350 –1,450 for single- and double-burner stoves with chimney (World Bank 2021). Most sales are portable single-burner stoves without any chimney. A popular alternative ICS is the Bondhu Chula stove with one to three burners and chimney for Tk 800 –1,200 (Ahmed and Iqbal 2018). The cost of an LPG stove with two burners ranges from Tk 2,500 to Tk 7,000. The additional costs of a gas cylinder, hose, and gas regulator total about Tk 2,000. The cost of a conventional ES with two plates is similar to the cost of LPG stove. The cost of EIS is often higher. Table 5.10 presents stove and device costs and their useful life. Costs are annualized at a 5 percent discount rate and the useful life of the stoves and devices ranges from 5 to 10 years. Annual maintenance and repair cost is 5 percent of the initial cost. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 84 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.10 Cost of stoves and devices per household ICS single ICS double burner without burner with LPG ES EIS chimney chimney Cost of stove (Tk) 375 1,200 4,000 4,000 5,000 Cost of cylinder, hose, regulator) (Tk) n.a. n.a. 2,000 n.a. n.a. Rice cooker or pressure cooker (Tk) n.a. n.a. n.a. 3,000 3,000 Useful life of stoves and devices (years) 5 5 10 10 10 Annualized cost per household (Tk) 82 264 740 863 987 Annual stove maintenance and repair 19 60 300 350 400 (5% of stove and device cost) Total annualized cost per household (Tk) 101 324 1,040 1,213 1,387 Source: World Bank estimates. Note: Discount rate is 5 percent. n.a. = Not applicable; ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. 5.3.4.2 Cost of promotion program The promotion cost applied for achieving high adoption rates of ICSs and clean technologies is Tk 1,000 per targeted household. The program also monitors and follows up to maximize long-term user rates and proper stove maintenance and repair. Annual- ized cost is Tk 123–220 per household (table 5.11). Table 5.11 Cost of promotion program per household ICS LPG ES EIS Cost of program per household (Tk) 1,000 1,000 1,000 1,000 Annualized over life of stove (years) 5 10 10 10 Annualized program cost per household (Tk) 220 123 123 123 Source: World Bank estimates. Note: Discount rate is 5 percent; ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. 5.3.4.3 Cost of energy Biomass fuel: As many as 80 percent of the population in Bangladesh that use biomass for cooking live in rural areas. Most of these households collect fuelwood or agricultural residues. Many households in small urban areas also collect fuelwood. A value of self-collected biomass fuels is commonly imputed based on time spent to collect biomass fuel. A collection time of 30 minutes per household per day is applied for households cooking with biomass using TCSs.46 The value of this collection time is estimated with average rural female wages and a value of time equal to 50 percent of the wage rate. Rural female wage rate is applied as most fuel collection is carried out by women and takes place in rural areas. The estimated value of biomass collection is Tk 7,025 per household per year.47 This is the pre-intervention energy cost for households using TCS. With ICS, energy savings are 30 –50 percent (Ahmed and Iqbal 2018; World Bank 2021). Savings of 40 percent are applied for both the ICS single-burner portable stove and the ICS double-burner chimney stove because of their fairly similar thermal efficiency (Berkeley Air Monitoring Group 2022). The energy cost using the two ICSs is thus Tk 4,215 per household per year (table 5.13). LPG and electricity: The average annual LPG consumption is 186 kg per household for households using only LPG for cooking (World Bank 2021).48 Based on the energy content of LPG and electricity, and stove efficiencies, cooking exclusively with an ES or EIS would require 2,054 kWh or 1,643 kWh per household per year, respectively, yielding an annual effective energy of 4,436 MJ. The lesser electricity consumption of the EIS arises from its higher energy efficiency (table 5.12).49 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 85 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.12 Estimated household energy consumption for cooking LPG ES EIS Energy content (MJ) 47.7 per kg 3.6 per kWh 3.6 per kWh Stove efficiency 50% 60% 75% Effective energy (MJ) 23.9 per kg 2.2 per kWh 2.7 per kWh Consumption per household per year 186 kg 2,054 kWh 1,646 kWh Total effective energy per household per year 4,436 MJ 4,436 MJ 4,436 MJ Source: World Bank estimates. Note: LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove; MJ = megajoule; kWh = kilowatt-hour. The energy cost of using each of the interventions ranges from Tk 4,215 per household per year for the two ICSs to Tk 15,624 for LPG. The cost of using an EIS is Tk 10,417 (table 5.13). The economic price of LPG is assumed to be Tk 84 per kg. This is based on the long-term LPG export prices from producing countries, including transportation and distribution cost. The cost of using electric stoves is based on a residential electricity price of Tk 6.34 per kWh which recently was the tariff rate for consumers of 300 – 400 kWh of electricity per month. Cooking exclusively with electricity implies electricity consumption of 137–171 kWh per month, which would indicate a monthly household total consumption of 300 – 400 kWh. For households that use very little electricity, cooking exclusively with electricity could cost less. Table 5.13 Cost of energy per household per year ICS LPG ES EIS Energy consumption n.a. 186 kg 2,054 kWh 1,643 kWh Cost per unit (Tk) n.a. 84 per kg 6.34 per kWh 6.34 per kWh Cost per household per year (Tk) 4,215 15,624 13,021 10,417 Source: World Bank estimates. Note: Economic costs are exclusive of taxes and other levies; n.a. = Not applicable; ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. 5.3.4.4 Total costs The total cost of interventions amounts to Tk 4,536–16,787 per household per year (table 5.14). The cost is lowest for cooking with the two ICSs followed by EIS. The cost is highest for LPG. The largest cost for all interventions is energy-consumption cost, ac- counting for 87–93 percent of the total annual cost. Table 5.14 Cost of interventions | Tk per household per year ICS ICS single burner double burner LPG ES EIS without chimney with chimney Stove and devices 82 264 740 863 987 Stove and device maintenance and repair 19 60 300 350 400 Promotion program 220 220 123 123 123 Energy consumption 4,215 4,215 15,624 13,021 10,417 Total cost 4,536 4,759 16,787 14,357 11,927 Source: World Bank estimates. Note: ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 86 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.3.5 Benefits of interventions to control household air pollution Health benefits: An estimated 10,500 to 13,800 deaths could be avoided annually by 2030 if another 45 percent of the population switches from TCS to an ICS single-burner portable stove or to an ICS double-burner stove with chimney. If the same population switches from TCS to LPG or electricity for cooking instead, annual avoided deaths could be 41,700. These estimates incorporate the effect on population-weighted ambient PM2.5 of reducing PM2.5 emissions from household use of solid fuels.50 Reduction in ambient PM2.5 by 45 percent of the population switching from TCS to LPG or electricity for cooking is estimated at 10 μg/m3 while the effect of switching to ICSs is about 5 μg/m3. Avoided deaths and illness are valued by applying the methodologies in appendixes H and I. This gives health benefits of inter- ventions of Tk 9,166–36,344 per household per year (table 5.15). Benefits are higher for households cooking in the house than for households cooking in a separate building or outdoors, due to differences in pre-intervention and post-intervention exposure levels of PM2.5. Health benefits of switching from TCS to clean cooking solutions (LPG, electricity) are 3–4 times higher than adopt- ing one of the ICSs. Switching to ICS double-burner stove with chimney provides 25–40 percent higher health benefits that switching to ICS single-burner stove without chimney. Table 5.15 Health benefits of interventions by cooking location | Tk per household per year ICS ICS Cooking location single burner double burner LPG ES EIS without chimney with chimney In the house 11,152 15,613 39,247 39,247 39,247 In separate building 9,452 12,522 36,598 36,598 36,598 Outdoors 7,375 9,160 33,538 33,538 33,538 Average across all locations 9,166 12,055 36,344 36,344 36,344 Source: World Bank estimates. Note: Average across all locations is weighted by the percentage of households cooking in each location. ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. Fuel and cooking-time savings: Switching from a TCS to an ICS, LPG, or electric stove also has non-health benefits. The main benefits are reduced biomass consumption and reduced cooking time. A collection time of 30 minutes per household per day is applied for households cooking with biomass fuel using TCS. The value of this collection time is estimated using average rural female wages and value of time equal to 50 percent of the female wage. Estimated value of biomass collection is Tk 7,025 per household per year.51 Households using TCSs spend on average 3.5 hours per day on cooking. The use of either of the two ICSs saves 10 minutes per day, and the use of clean cooking technologies such as LPG, gas, and electricity saves 40 minutes per day (World Bank 2019). As for biomass collection time savings, a value of time equal to 50 percent of female rural wage rates are applied to estimate value of cooking-time savings. Annual value of cooking-time savings per household per year are Tk 2,342 for the two ICSs and Tk 9,367 for cooking with LPG and electricity. Total benefits: The total benefits of the cookstove interventions amount to Tk 18,533–52,736 per household per year (table 5.16). Benefits (Tk 52,736 per household per year) are the same for LPG, conventional ES, and EIS. Benefits of these three latter stoves are 2.5–2.8 times the benefits for the two ICSs due to the ICSs’ lesser health benefits and smaller benefits in cooking-time sav- ings benefits. The health benefits per household presented in table 5.16 are averages across cooking locations. Health benefits are somewhat larger for households cooking in the house and somewhat lower for households cooking in a separate building or outdoors as previously discussed. Table 5.16 Benefits of interventions | Tk per household per year ICS ICS Single burner Double burner LPG ES EIS without chimney with chimney Health benefits a 9,166 12,055 36,344 36,344 36,344 Fuel savings 7,025 7,025 7,025 7,025 7,025 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 87 Cost-Benefit Analysis of Environmental Health-Risk Interventions ICS ICS Single burner Double burner LPG ES EIS without chimney with chimney Cooking-time savings 2,342 2,342 9,367 9,367 9,367 Total benefits 18,533 21,422 52,736 52,736 52,736 Source: World Bank estimates. Note: a Average across all cooking locations; ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. 5.3.6 Benefit-cost ratios of household air pollution control interventions The BCRs of the interventions are in the range of 3.1 to 4.5, indicating that benefits are Tk 3.1– 4.5 for every Tk spent on cleaner cooking (figure 5.4).52 The BCR for the ICSs is higher than for LPG and conventional electric stove, but lower than or like the BCR for EIS. Moreover, total benefits of EIS are 2.5–2.8 times the benefits of the ICSs, as previously discussed. While the BCRs for the two ICSs are comparable to the BCRs for LPG and electric stoves, LPG and electricity are the options to effectively combat the health effects of solid fuels. As such, ICSs may be reasonably efficient but not an effective solution for im- proving the health of the population. Health benefits will be especially large when clean cooking is achieved community-wide. However, the health benefits of cooking with electricity are influenced by the fuels and technologies used by power plants for electricity production. Therefore, the magnitude of health effects from incremental production of electricity by power plants for cooking with electricity needs to be assessed. Figure 5.4 Benefit-cost ratios (BCRs) of interventions to control household air pollution Source: World Bank estimates. Note: ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. The BCRs vary with the household’s cooking location. They are highest for households cooking in the house while only some- what lower for households cooking outdoors (table 5.17). Table 5.17 Benefit-cost ratios (BCRs) of interventions to control household air pollution by cooking location ICS ICS single burner Cooking location double burner LPG ES EIS without with chimney chimney In the house 4.5 5.2 3.3 3.9 4.7 In separate building 4.1 4.6 3.2 3.7 4.4 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 88 Cost-Benefit Analysis of Environmental Health-Risk Interventions ICS ICS single burner Cooking location double burner LPG ES EIS without with chimney chimney Outdoors 3.7 3.9 3.0 3.5 4.2 Average across all locations 4.1 4.5 3.1 3.7 4.4 Source: World Bank estimates. Note: ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. The estimation of benefits and costs of the cookstove interventions assumes all households will adopt and sustain the use of the intervention stoves and properly maintain, repair, and replace them when appropriate. This assumption is unrealistic. Some households will continue using TCSs, some will purchase a new stove but return to also using their TCSs after some time, and some households will not adequately keep up their stoves for maximum benefits (Lewis et al. 2015; Pillarisetti et al. 2014; Ruiz-Mercado et al. 2013). If only one-third of households switch to ICS, LPG, or electric stoves, and only two-thirds of those households sustain the use of the stoves through the stoves’ useful life, then BCRs decline from 3.1–4.5 to 3.0–4.1 (table 5.18). This indicates that the BCRs are quite insensitive to household rates of cookstove adoption and sustained use. The influences of these factors on the BCRs are the cost of stoves, the cost of maintenance and repair, and the cost of promotion program per household that respond to the program.53 These cost components are relatively small compared to the cost of energy, except for the ICSs. Therefore, the effect on the BCRs is somewhat larger for ICSs. Table 5.18 Benefit-cost ratios (BCRs) of interventions to control household air pollution ICS ICS Household response to single burner double burner LPG ES EIS promotion program without chimney with chimney Full response 4.1 4.5 3.1 3.7 4.4 Partial response a 3.5 3.8 3.0 3.5 4.1 Source: World Bank estimates. Note: a33 percent of households adopt ICS, LPG, or electric stove, and 66 percent of these households sustain the use of the stoves through the stoves’ useful life; ICS = Improved biomass cookstove; LPG = Liquified petroleum gas; ES = Electric stove; EIS = Electric induction stove. 5.3.6 Conclusions regarding interventions to control household air pollution Noteworthy from the analysis of the interventions is that the BCRs for EIS are considerably higher than for LPG despite higher initial EIS stove cost. The higher BCRs are due to lower cost of cooking with EIS arising from the higher energy efficiency of EIS stoves than LPG stoves. However, the BCRs for EIS and ES depend on the electricity tariff rate paid by the household. For households paying above Tk 7.5 and Tk 9.2 per kWh, the BCRs for ES and EIS, respectively, are below the BCR for LPG. This is the case for households using more than 400 kWh per month. Promotion of electric cooking will also need to be assessed in relation to developments of supply and demand in the electricity sector. While the BCRs for the ICSs may be higher than for LPG and conventional electric stoves, clean cooking technologies such as LPG and electricity are the options for effectively combatting the health effects of solid fuels. In other words, ICSs may be a reasonably efficient but not effective solution for improving the health of the population. Health benefits will be especially large when clean cooking is achieved community wide. Nevertheless, continued expansion of the ICS programs, and promotion of dual-burner stoves in particular, will continue to be important for households that cannot afford cooking with LPG or electricity. ICSs will also serve an important role in conserving scarce fuel wood and reduce the use of agricultural residue for cooking because of the higher energy efficiency of ICSs compared to TCSs. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 89 Cost-Benefit Analysis of Environmental Health-Risk Interventions One priority that emerges from the analysis is to further assess the potential for promoting the use of electric stoves—and per- haps especially induction stoves—for cooking. This is a cheaper option than LPG for small users of electricity that can benefit from lower residential block tariff rates for electricity. With residential block tariffs for electricity pricing, cooking with electricity provides an opportunity for less-well-off households to have this option as well. Further assessment is also warranted regarding the removal of any price and non-price obstacles and regarding the provision of incentives for adoption of LPG for cooking. 5.4 Benefits and costs of interventions to mitigate and prevent lead (Pb) exposure This section assesses the benefits and costs of three interventions to mitigate Pb exposure: (a) a nutrition intervention found to have moderately positive effects on children’s blood lead levels (BLLs); (b) switching from Pb contaminated cookware made of recycled aluminum to stainless steel; and (c) rehabilitation of abandoned used lead-acid battery (ULAB) recycling sites. Assessment of ben- efits and costs of other interventions are constrained by incomplete understanding of how much each source of lead exposure contributes to BLLs. Assessment of costs of various short- and long-term mitigation options are also much needed. 5.4.1 Nutrition intervention One potential avenue to address elevated BLLs in children is nutrition interventions targeted at young children between six months and five years of age as well as for pregnant women. WHO (2021) reports that randomized controlled trials (RCTs) have found that iron and/or calcium supplementation provide a small reduction in children’s BLLs but with low certainty of evidence. However, for zinc, one RCT found no evidence of effect on BLLs (table 5.19). Despite this low certainty, WHO recommends iron and/or calcium supplementation for children up to ten years of age that have a BLL equal to or greater than 5 µg/dL if the child has, or is likely to have, iron deficiency and/or inadequate calcium intake (WHO 2021). Table 5.19 Effect of nutrition interventions on children’s BLLs Nutrient Number of RCTs in Intervention effect on BLL Strength of evidence supplementation children Small reduction in iron-deficient children Very low certainty Iron 3 RCTs No effect in children who are not iron deficient Moderate certainty Calcium 4 RCTs Small reduction Very low certainty Zinc 1 RCT No effect Moderate certainty Source: World Bank based on WHO (2021). Note: RCT = Randomized controlled trial. Well over half of young children in Bangladesh have BLLs greater than 5 µg/dL, since the mean BLL in children under five years of age is estimated at 6.4 µg/dL. Furthermore, around 40 – 45 percent of children under five years of age are anemic (Ahmed et al. 2021; Akpan et al. 2022; Pasricha et al. 2021) while iron deficiency (ID) stands at about 27 percent (Akpan et al. 2022; Pasricha et al. 2021). However, only six percent of children under five years of age are given iron supplements (NIPORT and ICF 2020). But iron fortification of food is on the rise (Ahmed et al. 2021). This section presents estimates of the benefits and costs of iron sup- plementation for children starting at the age of 6 months to the age of 59 months in terms of effects on BLLs as well as anemia. 5.4.1.2 Iron supplementation on children’s BLLs Three RCTs have assessed the effect of iron supplementation on BLLs in children (Kordas 2017). Two studies found a statistical- ly significant effect on BLLs while one study found no effect (table 5.20). A study in Morocco found a 20 percent or 0.8 µg/dL reduction in mean BLLs as a result of iron-fortified biscuits with 8 mg of iron per day for 28 weeks. The reduction in mean BLLs increased to 35 percent from a combination of 8 mg of iron and 41 mg of EDTA (ethylenediaminetetraacetic acid).54 The study in India did not report the effect of iron on mean BLLs but found that 15 mg of iron per day for 16 weeks reduced the number of children with BLLs above 10 µg/dL from 65 to 29 percent, a reduction of 55 percent. This is similar to the study in Morocco for children with BLLs greater than 5 µg/dL. The effect of iron on ID in the studies in India and Morocco was even more pronounced. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 90 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.20 Effects of iron supplementation on blood lead levels of children – three RCTs Mexico India Morocco Morocco Iron tablets (30 mg iron Iron-fortified rice Iron-fortified biscuits Iron- and EDTA-fortified Intervention per day) for 6 months meal (15 mg of iron (8 mg iron per day) biscuits (8 mg iron and 41 mg per day) for 16 weeks for 28 weeks EDTA per day) for 28 weeks School children near a School children School children School children Participants metal smelter complex Age (years) 6–7 5–9 7 (average) 7 (average) Reduction not reported. Children with ID Children with ID Children with ID reduced Iron deficiency (ID) 12% of children had ID at reduced from 70% to reduced from 35% to from 36% to 5% of children baseline 28% of children 5% of children From 12.5 µg/dL to 10.9 From 4.1 µg/dL to 3.3 From 4.41 µg/dL to 2.87 µg/dL Reduction in mean BLL µg/dL (not statistically – µg/dL (35% reduction) significant) (20% reduction) Reduction not reported. 55% reduction in 52% reduction in 66% reduction in children 57% of children had BLL ≥ children with BLLs ≥ children with BLLs > with BLLs > 5 µg/dL (from Reduction in elevated BLLs 10 µg/dL at baseline 10 µg/dL (from 65% to 5 µg/dL (from 27% to 32% to 11% prevalence) 29% prevalence) 13% prevalence) Rosado et al. (2006) Zimmermann et al. Bouhouch et al. (2016) Bouhouch et al. (2016) Reference (2006) Source: World Bank. Note: – = Not available. RCT = Randomized controlled trial. One possible reason for not observing a significant effect on BLL in the study in Mexico may be the low prevalence of ID of 12 percent compared to the prevalence of 70 and 35 percent in the India and Morocco studies, respectively, since the effectiveness of iron supplementation on BLL may be mainly for children with low iron. A second reason may be that the Pb exposure route may largely have been through inhalation of airborne Pb from the smelter complex in Mexico while iron supplementation may be most effective against Pb ingested through the gastrointestinal tract. A third reason may be the persistently high exposure to Pb from the metal smelter complex before and during iron-supplementation intervention. 5.4.1.3 Cost of nutrition intervention The cost of iron supplementation has two components: The first component is the cost of iron supplements in the form of tab- lets, syrups, or fortification of food. Iron syrup with a dose of 12.5 mg of iron per day costs $0.63 per child for a three-month supply (Apkan et al. 2022). The second component is the cost of promoting and delivering the iron supplement to the targeted children. This cost is reported at $4.5–5.8 per child (Apkan et al. 2022; Pasricha et al. 2020). Thus, the total cost is $5.13–6.43 per child. Therefore, the total cost of iron supplementation from the age of six to 59 months is about $46–58 per child if the supplemen- tation program is repeated every six months for a total of nine times (three consecutive supplementation months followed by three months of intermission). This assumes that the full cost of promotion program and delivery is incurred all nine times, while in reality the cost may be less. The benefit of iron supplementation is likely to be largest if the intervention is administered from the age of six months to mitigate potentially irreversible damage to the child’s neuropsychological development during the first years of life. WHO rec- ommends a supplemental dose of 10–12.5 mg and 30 mg of iron per day for children 6–23 months and 24–59 months of age respectively and administered daily for three consecutive months in a year (WHO 2016). Iron supplementation likely needs to be repeated multiple periods of times until the child reaches at least five years of age, as children of are most susceptible to neuro- psychological developmental impairment from Pb in their early years of life. 5.4.1.4 Benefits of nutrition intervention Iron supplementation is estimated to reduce mean BLLs in young children in Bangladesh by 0.8–1.2 µg/dL, and possibly by 2–3 µg/dL among children currently with BLLs of 10–15 µg/dL. This is estimated by applying the effect size of iron supplementation on BLL from the study in Morocco. The benefit of this reduction in mean BLL is an estimated gain of 0.4–0.6 IQ points. This gain BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 91 Cost-Benefit Analysis of Environmental Health-Risk Interventions is valued at 2 percent of lifetime income per IQ point for the percent of children expected to be in the labor force (see appendix G) resulting in an increase in lifetime income of Tk 21–32 thousand ($254–382) per child (table 5.21). Children with BLLs above the mean may experience larger benefits while children with BLLs below the mean may experience smaller benefits. Table 5.21 Benefit of BLL reduction from iron supplementation Low High Remark Mean BLL of children < 5 years estimated and projected Mean BLL pre-intervention (µg/dL) 6.4 6.4 from studies in Bangladesh Change in mean BLL from iron supplementation -0.80 20% Effect size from Bouhouch et al. (2016) Mean BLL post-intervention (µg/dL) 5.6 5.2 Calculated IQ benefit (IQ points per child) +0.4 +0.6 Based on Crump et al. (2013) Benefit per IQ point (Tk, 2019) 86,143 86,143 Based on 2% lifetime income effect per IQ point Rate of labor-force participation (15–64 years) 62% 62% World Bank (2021) Benefit per child (Tk, 2019) 21,363 32,045 Calculated Benefit per child, $ 254 382 Calculated Source: World Bank. Iron supplementation also provides a reduction in the prevalence of anemia. In an RCT in Bangladesh, the prevalence of anemia declined by nearly 50 percent from three months of 12.5 mg of iron supplementation given to eight-month-old infants (Pasricha et al. 2021). Also in Bangladesh, in a home fortification program with micronutrient powder for children 6–59 months of age in one-third of all upazilas, anemia declined by 38 percent (Ahmed et al. 2021). Likewise, a global systematic review and meta-anal- ysis of RCTs found a 39 percent reduction in anemia among 4–23 months old children (Pasricha, Kalumba, and Biggs 2013). Several studies have quantified the benefits of reduction in anemia in terms of disability-adjusted life years (DALYs) in low- and middle-income countries (Pasricha et al. 2020) including in Bangladesh (Ahmed et al. 2021; Apkan et al. 2022). DALYs are calcu- lated using the disability weights from the GBD. This gives 0.025 DALYs per case of anemia averted for a one-year period using weighted average disability weights for mild, moderate, and severe anemia in Bangladesh.55 Valuing a DALY at 1–3 times GDP per capita gives a benefit of Tk 900–2,700 ($11–32) in 2019 per child for anemia averted for one year, based on and the rate of anemia reduction in the study in Bangladesh by Pasricha et al. (2021). For an extended iron supplementation program for children from the age of 6 to 59 months, the benefit of reduction in anemia would be Tk 4,045–12,135 ($48–145) per child. This is substantially less than the benefit of the effect of iron supplementation on children’s BLLs. 5.4.1.5 Benefit-cost ratio of nutrition intervention The total benefits and costs of iron supplementation for children starting from the age of 6 months to the age of 59 months are presented in table 5.22. These benefits and costs give a benefit-cost ratio of 5.5–6.6 when counting only BLL reductions, and 6.6–9.1 when including the benefit of anemia reduction. Therefore, even though the effect of iron supplementation on children’s BLLs is relatively modest, the benefit per taka spent is high. Table 5.22 Benefits and costs of iron supplementation for children 6–59 months in Bangladesh Low end of range High end of range Benefit of BLL reduction (Tk) 21,363 32,045 Benefit of anemia reduction (Tk) 4,045 12,135 Cost of iron supplementation (Tk) 3,878 4,861 BCR (BLL reduction benefit) 5.5 6.6 BCR (anemia-reduction benefit) 1.0 2.5 BCR (BLL + anemia-reduction benefit) 6.6 9.1 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 92 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.4.2 Cookware intervention Studies of cookware made of recycled aluminum in Africa and Asia have found Pb released into food up to 260 µg per 250 mL serving (see chapter 2). A small study in Bangladesh found that one of four items tested released 2 µg of Pb per 250 mL serving while any Pb released from the other three was undetectable. Most recently the market survey by Pure Earth found that 59 percent of 27 sampled items of metallic cookware contained Pb concentrations above the reference level of 100 ppm, with a median and maximum Pb concentration of 186 and 8,186 ppm, respectively (Pure Earth 2023). The items have not been tested for leaching of Pb into food while cooking. Thus, studies are needed to assess the magnitude of lead contamination in food from recycled aluminum in Bangladesh. To illustrate the magnitude of benefits and costs of addressing potential lead-contaminated cookware, the intervention as- sessed here is replacement of cookware made of lead-contaminated recycled aluminum with cookware made of a substitute material not contaminated with lead such as stainless steel. This intervention is targeted at households with young children and pregnant women to help prevent detrimental effects of Pb during the first years of life. The intervention also benefits older chil- dren as well as adults in the household. 5.4.2.1 Benefits of cookware intervention The benefits of avoiding Pb exposure from aluminum cookware are largest for young children and if avoided from the point of pregnancy through the age of five years of the child to avoid potentially irreversible damage to the child’s neuropsychological development during the first years of life. The benefits to young children from avoiding Pb exposure from aluminum cookware for the first five years of life are presented in table 5.23 for 1–25 µg of Pb released per 250 mL food serving. Benefits are estimated based on the effect of Pb on BLLs and of BLLs on IQ and lifetime income. The effect of avoiding this exposure is a reduction in BLLs of 0.2–4.3 µg/dL. This is estimated using the Integrated Exposure Uptake Biokinetic (IEUBK) Model Version 2 developed by the USEPA. A reduction of this magnitude in BLLs is in turn expected to result in an increase in the children’s IQ of 0.1–1.6 points. This gain in IQ is valued at 2 percent of lifetime income per IQ point for the percent of children expected to be in the labor force (see appendix G) resulting in an increase in lifetime income of Tk 5–88 thousand per child. 5.4.2.2 Benefit-cost ratio of cookware intervention An alternative to aluminum cookware is stainless steel. A set of three pots made of stainless steel of sizes 2–5 liters costs around Tk 4,000.56 This implies that the cost of switching to stainless steel is less than the benefit for a household expecting a child even if the household’s current aluminum cookware only releases 1 µg of Pb per 250 mL food serving. For cookware that releases 2–25 µg of Pb the benefit-cost ratio (BCR) is 2.3–21.9. The BCRs would be even larger for households with two young children. Table 5.23 Benefits to young children of avoiding Pb exposure from aluminum cookware Pb from Cookware µg/250 mL 1 2 5 10 25 BLL effect from cookware µg/dL 0.19 0.37 0.92 1.80 4.29 IQ effect IQ points 0.09 0.17 0.41 0.77 1.64 Benefit per IQ point Tk 86,143 86,143 86,143 86,143 86,143 LFP rate (15–64 years) a % 62% 62% 62% 62% 62% Total benefit per child Tk 4,667 9,142 21,927 41,120 87,602 Cost of stainless-steel cookware set Tk 4,000 4,000 4,000 4,000 4,000 BCR 1.2 2.3 5.5 10.3 21.9 Source: World Bank estimates. Note: a LFP = Labor-force participation. The estimated benefits of avoiding exposure to Pb from aluminum cookware are conservative, since adults would also benefit from avoiding such exposure. However, estimating the benefits for adults requires a different model than the IEUBK Model as well as modeling the possibility of the lagged effects of lower BLLs on cardiovascular health improvements. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 93 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.4.3 Interventions targeting used lead-acid battery (ULAB) recycling sites Informal recycling of used lead-acid batteries (ULABs), including abandoned recycling sites, are major lead exposure “hot spots” in Bangladesh and many other low- and middle-income countries for workers and nearby residents (Ericson et al. 2016; Gottes- feld and Pokhrel 2011). Since 2011, the Toxic Sites Identification Program (TSIP) implemented by Pure Earth has collaborated with the Department of Geology of the University of Dhaka and the Department of Environment of Bangladesh in assessing 249 con- taminated sites. As many as 175 of the sites are ULAB recycling and lead smelting sites located throughout the country (McCartor 2018). However, the total number of ULAB recycling and recharging facilities is substantially larger, reported in the range of 1,100 (World Bank 2018) to 12,200 (Ahmad et al. 2014). The latter figure is based a survey dating back to 2003–04 by the Bangladesh Bureau of Statistics (BBS). Two abandoned adjacent ULAB recycling sites in Kathgora, Savar, in Dhaka Division, were rehabilitated in 2018. The sites had been in operation for six months before they were closed in 2016. Operations at the site had included battery case separation, washing and open-pit lead smelting. Rehabilitation included soil remediation (removal of topsoil) as well as removal of lead contaminated dust in nearby households, and community education. Lead concentrations in the soil were measured at 251 points around the sites. Pb concentrations reached over 100,000 mg/kg (ppm) with a mean of 1,400 mg/kg. Concentrations declined with distance from the abandoned recycling and smelting locations. The mean concentration declined to 50 mg/kg after soil remediation (Chowdhury et al. 2021; McCartor and Nash 2018). The cost of the rehabilitation of the sites was $40,300. This included community education ($1,200), soil remediation ($37,500), and household lead dust removal and cleaning ($1,600) (Chowdhury et al. 2021). 5.4.3.1 Benefits of interventions targeting ULAB recycling sites Rehabilitating ULAB recycling sites is likely to benefit children more than adults, since children are often more exposed to Pb in soil and dust through play activities. The lead-contaminated soil and dust at the two abandoned sites and in adjacent homes is likely to have caused irreversible damage to the neuropsychological development of many of the children living near the site. Rehabilitation of the site allows future generations of children to grow up in a cleaner environment. Benefits are estimated ac- cordingly for an annual birth cohort of six children per year for the next twenty years. Children’s mean BLL changed from 22.6 to 14.8 µg/dL from the rehabilitation project (Chowdhury et al. 2021). Future children are on average expected to gain 1.33 IQ points from this improvement in BLL. This gain is valued at 2 percent of lifetime income per IQ point for the percent of children expect- ed to be in the labor force (see appendix G) with the annual birth cohort of six children gaining Tk 435,000 ($5,173) in lifetime income (table 5.24). This annual gain in lifetime income is projected to grow at a rate of 2.5 percent per year for each subsequent birth cohort over the twenty-year assessment period, discounted at 5 percent. Table 5.24 Benefits of the rehabilitation of an abandoned ULAB recycling site in Kathgora, Bangladesh Pre-intervention BLL (µg/dL) 22.6 Chowdhury et al. (2021) Post-intervention BLL (µg/dL) 14.8 IQ points gained per child 1.33 Based on Crump et al. (2013) Annual birth cohort 6.1 Calculated based on children population Benefit per IQ point, Tk 86,143 Based on 2% lifetime income effect per IQ point a Rate of labor-force participation (15–64 years) 62% World Bank (2023) Total annual benefit, Tk thousands 435 Calculated Total annual benefit, $ 5,173 Calculated Source: World Bank. Note: a Lifetime income is calculated using an annual growth rate of real income of 2.5% from age 18 to 65 years and an annual discount rate of 5 percent. 5.4.3.2 Benefit-cost ratio of intervention targeting ULAB recycling site Over a period of twenty years from the rehabilitation project’s completion, the discounted present value of income benefit totals Tk 6.65 million ($79,129). The benefit-cost ratio (BCR) for the site rehabilitation is 1.96, indicating that benefits are nearly twice the cost). This may be considered conservative in so far that other benefits to children, as well as to some extent to adults, are not quantified (table 5.25. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 94 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.25 Present value of total benefits and costs of site rehabilitation Tk, millions (2019) $ (2019) Total benefits 6.65 79,129 Total costs 3.39 40,300 BCR 1.96 1.96 Source: World Bank. Note: Benefits over 20 years discounted at a rate of 5 percent per year. A systematic review of the evidence on the effectiveness of remediation of lead-contaminated soil at five sites in high-income countries found a much smaller effect on BLLs than the project in Bangladesh (Dobrescu et al. 2022). The sources of soil lead con- tamination were nearby mines and/or smelters and lead-based paint. Soil remediation involved removal of the upper layer of soil and replacing with clean soil. Two studies also included interior dust abatement and/or lead-based paint interventions. However, an assessment of remediation of lead contaminated sites in six middle-income countries found declines in mean BLLs of 33–90 percent while only 6 percent at a site in a seventh country. BCRs ranged from 1.7 to 50 using the same methodology and valua- tion of benefits as for Bangladesh (World Bank, forthcoming). The BCRs very much depend on the effect of remediation on BLLs, the size of exposed population, income level at the time of site remediation, and cost of remediation per exposed population. 5.4.4 Conclusions on interventions to mitigate and prevent lead exposure BLLs in Bangladesh remain at levels that cause serious health effects in children and adults. Tens of studies have documented some of the sources of Pb pollution and population exposures. Well-recognized sources of exposure include ULAB recycling and occupational exposures. Pb in turmeric has also been a major concern but appears to have been addressed. However, concerns have increased over Pb and other heavy metal contamination of the food supply, such as rice, vegetables, and fish. While studies are insufficient to determine Pb concentrations in food consumed by the majority of the population, the analysis in this chapter indicates that Pb in food may be a major cause of elevated BLLs in the general population. An undetermined share of Pb in rice, vegetables and culture fish may be from chemical fertilizers and commercial fish feed, as indicated by some studies. The chapter also highlights that cookware made from recycled aluminum may be a major source of Pb exposure for at least some of the population. While the challenges of Pb pollution and population exposure will take time to solve, there are immediate actions that can be taken for which benefits by far exceed the costs as evidenced by the benefit-cost analysis in this chapter (table 5.26). Table 5.26 Benefit-cost ratio (BCR) of three interventions to mitigate and prevent Pb exposure BCR Iron supplementation for children 6–59 months 6.6–9.1 Replacement of aluminum cookware contaminated with Pb 1.2–21.9 Rehabilitation of an abandoned ULAB recycling site in Kathgora 1.9 Source: World Bank. However, a comprehensive intersectoral and interdisciplinary approach is required for optimal mitigation and prevention of Pb exposure. The priority is the following set of measurement studies: (a) undertake nationally representative BLL measurements in children and adults as well as of populations in hot spots; (b) undertake nationally representative Pb measurements in rice and vegetables in dry and wet seasons in urban and rural wholesale markets and own produce in rural areas; (c) undertake nationally representative Pb measurements of rice and vegetables in agricultural fields in dry and wet season, and of chemical fertilizers and irrigation water used in these fields; (d) undertake pilot Pb measurements of agricultural residues used for household en- ergy, as well as measure household Pb air pollution, to assess Pb air pollution concerns; (e) undertake nationally representative Pb measurements in capture and culture fish at wholesale and local markets; (f) undertake nationally representative Pb mea- surements in culture fish and fish feed at fish farms; (g) undertake a sector study of cookware made from recycled aluminum to verify the extent of recycling, sources of recycled aluminum used for making cookware, and (h) undertake measurements of Pb leached into food while cooking. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 95 Cost-Benefit Analysis of Environmental Health-Risk Interventions Once these measurement studies are implemented or underway for implementation, the next priority actions are the following: (a) identify potential interventions for mitigation and prevention of Pb contamination of the food supply, including phytoremedi- ation of Pb and heavy metals in soil and water; (b) set up a comprehensive Pb monitoring and surveillance system; (c) institution- alize the handling of lead-poisoning cases; (d) develop appropriate regulations for the main sources of Pb pollution; (e) develop Guidelines and Manual for Toxic-Site Remediation as a basis for support to a government Plan for Remediating Toxics; (f) Set up a government-run Toxic-Sites Database; (g) develop and enforce regulations for the ULAB recycling sector; and (h) focus on home- based assessment in determining the risk of Pb exposure. 5.5 Benefits and costs of improved WASH interventions This section assesses the benefits and costs of 12 drinking water, sanitation, and hygiene (WASH) interventions: six drinking-water interventions, two sanitation interventions, and four handwashing-with-soap interventions. Quantified benefits of the interven- tions are health improvements and potential time savings. Both direct health benefits in terms of averted illness and mortality from diarrheal disease, and indirect health benefits in terms of averted child mortality through improved nutritional status from averted diarrheal disease are discussed here. The main literature utilized to assess direct health benefits of interventions is an analysis of worldwide studies by Wolf et al. (2018) who present relative risks (RRs) of diarrheal disease associated with various types of household drinking water, sanitation, and handwashing in low- and middle-income countries. Percentage reduction in diarrheal deaths from WASH interventions is considered the same as the percentage reduction in diarrheal disease, assuming a constant fatality rate per case of diarrheal illness. Olofin et al. (2013) and Fewtrell et al. (2007) are applied to estimate indirect health benefits of interventions. Olofin et al. provide a methodology for estimating child mortality associated with poor nutrition- al status of children, and Fewtrell et al. (2007) provide guidance on the magnitude of effect of diarrheal disease in early childhood on children’s nutritional status (see appendix F). The assessed interventions in this section are household-level interventions. Additional interventions that may be considered are community-level interventions such as high-quality piped water supply and community-level safe management of fecal sludge from household sanitation facilities. 5.5.1 Drinking-water interventions Over 98 percent of the population in Bangladesh used an improved water source for drinking in 2019 according to the nationally representative Bangladesh Multiple Indicator Cluster Survey (MICS) 2019 (BBS/UNICEF 2019). However, 40 percent of the house- hold population had E.coli in their source water and as many as 82 percent had E.coli in their actual drinking water. This points to the importance of safe handling and storage of drinking water, as well as improving quality of piped water supply. It also points to the potential role that household point-of-use treatment (POUT) of drinking water can have in improving the safety of drinking water from microbiological pollution. Only 10 percent of the population currently practice POUT of drinking water in Bangladesh (BBS/UNICEF 2019). The drinking-water interventions assessed here are six household POUTs: (a) solar disinfection of drinking water; (b) ceramic fil- tering of drinking water; (c) boiling of drinking water using agricultural residues as energy for boiling; (d) boiling of drinking water using fuelwood as energy for boiling; (e) boiling of drinking water using LPG as energy for boiling; and (f) boiling of drinking water using electricity as energy for boiling. 5.5.1.1 Cost of drinking-water interventions Solar disinfection of drinking water: Solar disinfection has been demonstrated to be effective for eliminating microbial patho- gens in drinking water (Clasen 2009; Clasen et al. 2015). Disinfection of water is based on the combined effect of thermal heating and UV radiation (McGuigen et al. 2012). A common method of solar disinfection is placing 1–2 liters transparent bottles with water (for example, beverage bottles) in the sun for about six hours in locations with high solar radiation and up to two days under cloudy conditions. The disinfected water should be kept in bottles until consumption to avoid recontamination (Clasen 2009). All that is required for this method of drinking-water treatment is transparent plastic or glass bottles; thus, no significant initial capital cost is incurred. However, the method involves some incremental time for filling bottles with water, placing bottles under sunlight, collecting and cleaning bottles, here assumed to be five minutes per household per day valued at 50 percent of average female rural hourly wage rate. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 96 Cost-Benefit Analysis of Environmental Health-Risk Interventions Ceramic filtering of drinking water: Ceramic filters can be simple and effective for removing pathogens in water. Devices consist of a porous ceramic filter coated with colloidal silver. A ceramic filtering device can fulfill a household’s need for drinking water and produce 20–30 liters of purified water per day. It is easy to clean, light weight, portable, and available at various costs and durability. A simply gravity-based system with water storage container may cost Tk 1,500. A useful life of one year is assumed to be conservative. Boiling of drinking water: Boiling and filtering are the two most prevalent forms of household treatment of drinking water in Bangladesh. Cost of boiling depends largely on the type of fuel used for boiling, ranging from Tk 1,171 per household per year for households using self-collected on-farm agricultural residues as energy for boiling to Tk 2,819 for households using LPG (table 5.27). Cost is estimated based on quantity of drinking water, energy required to boil water, stove efficiency, energy content of fuels, and cost of energy per kg or kWh. Cost of using agricultural residues is the time spent on collection, assumed to be five minutes per household per day valued at 50 percent of average female rural hourly wage rate. Average fuel wood price in Bangladesh is applied for calculating the cost of boiling water with wood. The cost applied for LPG is a multiyear average world price including transportation and distribution. Cost of boiling water with electricity depends on household electricity consumption as elec- tricity tariffs increase with consumption. A tariff rate of Tk 6.00 per kWh is applied reflecting a midrange level of consumption. Table 5.27 Cost of boiling drinking water Residues Wood LPG Electricity Quantity of water for boiling 1.5 1.5 1.5 1.5 (liters per person per day) Energy requirement for heating of water (Joules/liter/1 degree 4,200 4,200 4,200 4,200 Celsius) Energy content of fuel (MJ/kg) a 7.5 15.1 47.7 — Stove efficiency for boiling water (%) 12 15 50 60 Energy requirement for boiling water (per household 879 kg 349 kg 33 kg 366 kWh per year) Cost of energy (Tk) n.a. 5.60 per kg b 85 per kg c 6.00 per kWh Cost of boiling water 1,171 1,956 2,819 2,197 (Tk per household per year) Source: World Bank. Note: a SREDA 2020. b BBS 2021. c Economic cost exclusive of taxes. — = Not available; n.a = Not applicable. Annualized costs of the household POUT of drinking-water interventions are presented in table 5.28. Solar disinfection has the lowest cost followed by boiling drinking water using agricultural residues as energy for boiling. On-farm agricultural residues are free but have a recurrent cost in terms of time spent on residue collection (see below). The cost of boiling drinking water using LPG is most expensive followed by the cost of using electricity. The cost of using ceramic filtering and boiling using fuelwood is similar but depends critically on the cost of the filter and durability. The incremental time spent by the household on practicing any one of these methods for treating drinking water is a significant cost component. An incremental time use of five minutes per household per day for all treatment options is applied. Time is valued at 50 percent of average female rural hourly wage rate for boiling with agricultural residues or fuelwood and average na- tional female wage rate for solar disinfection and boiling with LPG or electricity. A promotion program to encourage households to adopt one of the interventions for treating drinking water is an additional cost. The program is assumed to be effective for five years. The program cost is Tk 1,000 per household, annualized with a five percent discount rate. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 97 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.28 Annualized cost of household POUT of drinking water | Tk per household per year Boiling Boiling Boiling Solar Ceramic of water Boiling of of water of water disinfection filter (agricultural water (LPG) (wood) (electricity) residues) Annualized capital cost n.a. 1,500 n.a. n.a. n.a. n.a. Annual cost of boiling water n.a. n.a. 1,171 1,956 2,819 2,197 Annual cost of incremental time used for 1,672 1,672 1,171 1,171 1,672 1,672 water treatment Annualized cost of promotion program 231 231 231 231 231 231 Total annualized cost 1,903 3,403 2,573 3,358 4,722 4,100 Source: World Bank. Note: n.a. = Not applicable. 5.5.1.2 Benefits of drinking-water interventions The health benefits of interventions assessed here pertain to morbidity and mortality from diarrheal disease, intestinal infections (typhoid/paratyphoid), and infectious-disease mortality associated with child underweight in part caused by repeated diarrheal disease in early childhood. Estimating the reduction in these disease burdens from interventions requires knowledge of the risk of disease after receiving an intervention relative to the risk before receiving the intervention. The relative risks from a meta-anal- ysis of studies of POUT are reported in table 5.29 for households with improved drinking-water source, which over 98 of the population in Bangladesh has. These relative risks indicate that POUT provides 24–56 percent disease reduction. A disease reduction of 24 percent is applied for solar disinfection of drinking water and 52 percent for ceramic filtering. The latter is the midpoint of disease reduction for filtering with and without safe water storage after treatment. This rate of disease reduc- tion is also applied to boiling of drinking water (Prüss-Üstün et al. 2019). Table 5.29 Relative risk (RR) of diarrheal disease and mortality for household point-of-use treatment (POUT) of drinking water Filtering and Solar disinfection Filtering safe storage 0.76 0.55 0.44 Source: Wolf et al. 2018. An estimated 22,000 deaths and 500 million days with diarrheal disease can be avoided each year if all households adopt reg- ular POUT of drinking water using ceramic filtering or boiling. A little less than half of these health effects can be avoided if solar disinfection of drinking water is adopted. The value of health benefits per beneficiary household per year is presented in table 5.30 using the methodology in appendixes H and I. Benefits in terms of reduction in infectious diseases are the same for ceramic filtering and boiling of drinking water because the same relative risk reduction in infectious disease is applied. However, using agricultural residues and fuelwood for boiling drinking water causes household air pollution. The marginal health damage cost from the use of solid fuels for cooking in Bangladesh is estimated at Tk 52,476 per household per year in 2026—the midpoint of the intervention time horizon until 2030. Agricultural residue and fuelwood requirement for boiling drinking water is estimated at about 25 percent of fuel used for cooking based on estimated energy requirement for boiling in table 5.27. Thus, the health damage cost or negative health benefit is Tk 10,102 per household per year.57 Therefore, net health benefits are largest for ceramic filtering and boiling of drinking water using LPG and electricity. Net health benefits are smallest for boiling water with agricultural residues or wood due to health effects of household air pollution and for solar disinfection due to smaller percent reduction in infectious disease. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 98 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.30 Benefits of drinking-water interventions Tk per household per year Boiling of water Boiling Boiling of Boiling Solar Ceramic (agricultural of water water (LPG) of water disinfection filter residues) (wood) (electricity) Annual infectious-disease benefits 7,178 16,011 16,011 16,011 16,011 16,011 Annual health damage from house- n.a. n.a. -10,102 -10,102 n.a. n.a. hold air pollution Annual net health benefits 7,178 16,011 5,909 5,909 16,011 16,011 Source: World Bank. Note: n.a. = Not applicable. 5.5.1.3 Benefit-cost ratios of drinking-water interventions The BCRs of the interventions range from 1.8 to 4.7 in the base-case (figure 5.5). The base case reflects that five minutes are spent on water treatment per household per day. The cost of this time use accounts for 35 to 88 percent of total cost of treatment. The BCRs are therefore sensitive to the amount of time spent on treatment. BCRs are 1.3 to 2.8 if ten minutes are spent per day (low-case) and 2.2 to 8.0 if only two minutes are spent per day (high-case). The BCR is smallest for boiling drinking water with fuelwood or agricultural residues because of the damage to health from the household air pollution that is caused by these fuels. BCRs are largest for ceramic filter, boiling drinking water with electricity, and solar disinfection. The advantage of ceramic filtering is larger health benefits than for solar disinfection while the disadvantage is the cost of the filter. The BCR for boiling water using LPG is smaller than for boiling with electricity. Figure 5.5 Benefit-cost ratios (BCRs) of household POUT drinking-water interventions High Base case Low Source: World Bank estimates. 5.5.2 Sanitation interventions About 15 percent of the population in Bangladesh relied on unimproved sanitation in 2019, and 20 percent of the population shared otherwise improved sanitation facilities with other households according to the Bangladesh MICS 2019 household survey (BBS/UNICEF 2019). The most common type of improved sanitation facility is flush or pour-flush toilet connected to a septic tank or pit. Therefore, the household sanitation interventions assessed here are the following: (a) Installation of non-shared pour-flush/flush toilet facility with septic tank to households currently relying on unimproved sanitation facilities; and (b) Installation of non-shared pour-flush/flush toilet facility with septic tank to households currently sharing improved sanitation facilities with other households. Interventions should fulfill the “safely managed sanitation” criteria defined as the use of an improved sanitation facility not shared with other households and where excreta are “safely disposed on-site” or are transported and “treated off-site.” Safely disposed on-site means excreta are disposed in septic tanks with appropriate leach fields or in latrine pits that are left undisturbed when BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 99 Cost-Benefit Analysis of Environmental Health-Risk Interventions full. Safely treated off-site means either excreta are transported by sewer lines to wastewater treatment plants or emptied from septic tanks/pits and treated off-site at facilities designed for fecal sludge (UNICEF/WHO 2019). 5.5.2.1 Cost of sanitation interventions The cost of the household sanitation interventions includes the initial capital cost of the sanitation facility, annual operation and maintenance (O&M), and regular cleaning of the facility. The government of Bangladesh recommends toilets with sanitary offset pit(s) (UNICEF 2020) to facilitate safe sanitation man- agement in line with the Sustainable Development Goals. The cost of a pour-flush toilet with a single sanitary offset pit made of concrete rings and slab and a durable superstructure is estimated at Tk 8,000–14,000 (UNICEF 2020). A midpoint of Tk 11,000 is applied in this benefit-cost assessment. The assumed useful life is 15 years. The annual discount rate is 5 percent. Cleaning of the sanitation facility is assumed to take 30 minutes per week more than the time spent on cleaning the household’s pre-intervention unimproved sanitation facility. Time is valued at 50 percent of average wage rates. Annual operations and maintenance (O&M) cost is 5 percent of initial capital cost. A promotion program to encourage households to adopt the interventions is an additional cost. The program cost is Tk 1,000 per household, annualized over the useful life of the sanitation facility. Cost of cleaning consti- tutes 51 percent, capital cost 30 percent, O&M 16 percent, and promotion program 3 percent of total annualized cost (table 5.31). Table 5.31 Cost of household sanitation | Tk per household per year Annualized capital cost 1,060 Initial capital cost is Tk 11,000 Annual O&M cost 550 5% of capital cost Annual cost of cleaning 1,787 30 minutes per household per week Annualized cost of promotion program 96 Annualization of Tk 1,000 per household Total annualized cost 3,493 Per household Source: World Bank. For households that share a sanitation facility with other households, the cost per beneficiary household of the sanitation inter- vention is less than reported in table 5.31. Nearly 90 percent of the households that share an improved sanitation facility with other households share the facility with five or less households (BBS/UNICEF 2019). Assuming an average of three households per shared facility implies that two new facilities need to be constructed per three households. Since all three households benefit from the construction, the average cost per beneficiary household is Tk 2,361.58 5.5.2.1 Benefits of sanitation interventions The benefits of improved and safely managed sanitation include health improvements, environmental benefits, intangible ben- efits such as status and comfort, and potential time savings benefits. There are both direct household benefits and wider com- munity benefits such as reduced fecal contamination of land and water bodies, with reduced risk of contamination of drink- ing-water sources and other pathways of human exposure. The benefits quantified in this assessment are limited to health and potential time savings benefits, because environmental and intangible benefits are difficult to quantify. The health benefits of the interventions pertain to diarrheal disease and intes- tinal infections (typhoid/paratyphoid), and infectious disease mortality associated with child underweight in part caused by repeated diarrheal disease in early childhood. Estimating the reductions in these disease burdens from interventions requires knowledge of the risk of disease before and after receiving an intervention. The relative risks from a meta-analysis of studies by Wolf et al. (2018) of improved non-shared household sanitation relative to unimproved sanitation is reported in table 5.32. The analysis found a larger reduction in risk of diarrheal disease from improved non-shared sanitation if improved sanitation included sewage connection—that is, 40 percent versus 16 percent. The analysis also found a larger reduction in disease risk for improved sanitation provided in com- munities with high sanitation coverage—that is, 45 percent versus 24 percent. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 100 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.32 Relative risk (RR) of diarrheal disease and mortality for improved sanitation RR Unimproved sanitation 1.00 Improved (non-shared) sanitation without sewage connection 0.84 Improved (non-shared) sanitation with sewage connection 0.60 Improved (non-shared) sanitation (< 75% community sanitation coverage) 0.76 Improved (non-shared) sanitation (> 75% community sanitation coverage) 0.55 Source: Wolf et al. 2018. A relative risk of 0.55, with 45 percent disease reduction, is applied here for households that benefit from the intervention “in- stallation of non-shared pour-flush/flush toilet facility with septic tank to households currently relying on unimproved sanitation facilities.” The relative risk of 0.55 reflects the comparatively high community-sanitation coverage in Bangladesh. For households with improved sanitation but sharing the facility with other households, a lower disease reduction of 16 percent is applied for receiving non-shared facility with septic tank (table 5.33). Table 5.33 Relative risk (RR) of diarrheal disease and mortality for sanitation interventions Disease reduction (%) Improved non-shared safely managed sanitation for households currently with 45 unimproved sanitation Improved non-shared safely managed sanitation for households currently shar- 16 ing improved sanitation with other households Source: World Bank. An estimated 6,230 deaths and 155 million days with diarrheal disease can be avoided each year if all households adopt the sanitation interventions—that is, by the 15 percent of the population currently with unimproved sanitation and the 20 percent currently sharing sanitation facilities with other households. The valuation of the health benefits of interventions per household per year is estimated using the methodology in appen- dixes H and I. The health benefits for households currently having unimproved sanitation are over four times larger than for households sharing sanitation facilities with other households (table 5.34). Times savings benefits may be expected for the households that adopt the intervention “installation of non-shared pour-flush/ flush toilet facility with septic tank to households currently sharing improved sanitation facilities with other households.” These households will have shorter access time to their new facility both in terms of distance and waiting time. It is here assumed that the time saving is 5 minutes per person. Time savings are valued at 50 percent of average wage rates for individuals 15+ years of age and are on average almost as large as the health benefits (table 5.34). Table 5.34 Benefits of household sanitation interventions | Tk per beneficiary household per year Improved non-shared from unim- Improved non-shared from proved sanitation improved shared sanitation Annual health benefits 20,509 4,774 Time savings benefits 0 4,254 Total benefits 20,509 9,028 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 101 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.5.2.3 Benefit-cost ratios of sanitation interventions The BCRs of sanitation interventions range from 3.8 to 5.9 in the base-case (figure 5.6). The base case reflects that an additional 30 minutes are spent on toilet cleaning per household per week to keep it in a sanitary and safe condition. The cost of this time use accounts for 51 percent of total cost. The BCRs are therefore sensitive to the amount of time spent on cleaning. BCRs are 3.1 to 4.7 if 45 minutes are needed per week to keep it in a sanitary condition (low-case) and 5.1 to 7.9 if only 15 minutes are needed (high-case). The BCR is largest for the adoption of improved non-shared and safely managed sanitation facilities by households with unimproved sanitation. The BCR for households sharing sanitation facilities with others is smaller due to smaller benefits per household but indicates that benefits are 3.1 to 5.1 times larger than cost. The BCR for improved non-shared sanitation for households currently sharing facilities with other households is also sensitive to the time benefits of easier access to facility. If time savings are 2 instead of 5 minutes per person per day, the BCR is 2.7 instead of 3.8. Figure 5.6 Benefit-cost ratios (BCRs) of improved non-shared sanitation High Base case Low Source: World Bank estimates. 5.5.3 Hygiene interventions Handwashing with soap and water is found to be the most effective hygiene intervention in reducing diarrheal disease (Cairn- cross et al. 2010; Ejemot-Nwadiaro et al. 2021; Wolf et al. 2018) and acute respiratory infections (Rabie and Curtis 2006). The Bangladesh MICS 2019 (BBS/UNICEF 2019) reports that 75 percent of the population had access to handwashing with soap and water on household premises while 25 percent did not have a place with such items. However, this does not mean that everyone with a handwashing facility washes hands adequately at critical junctures. Having a handwashing facility is hence converted to an estimate of actual handwashing with soap based on an analysis of the association between having a facility and observed handwashing with soap. This conversion indicates that 47 percent of the population practices regular handwashing at critical junctures in Bangladesh (Prüss-Üstün et al. 2019). The benefits and costs are assessed for an intervention that is delivered by implementing a promotion program for handwash- ing with soap at critical junctures. Benefits and costs are assessed for four groups of households: (a) all households; (b) households with children under five years of age; (c) households without children under five; and (d) only the caretakers of children under five and the children under five in the household. Children under five and the population five years and older are differentiated, since these two population groups have very different disease and mortality rates. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 102 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.5.3.1 Cost of hygiene interventions Handwashing with soap has multiple recurrent costs. These are the use of water for handwashing, soap, and the value of time spent on handwashing. For individuals five years and older, resource use is 3 liters of water per person per day, 12 bars of soap (100 gm each) per person per year, and three minutes spent on handwashing per person per day. Resource use is double for caretakers of children under five, as caretakers perform handwashing for themselves and at least one child (table 5.35). Table 5.35 Recurrent resources spent on handwashing with soap Persons five years Caretaker of child or older under five years Water for handwashing (liters per person per day) 3 6 Soap consumption (bars per person per year) 12 24 Time spent on handwashing (minutes per person per day) 3 6 Source: World Bank estimates. The annualized costs of handwashing with soap are presented in table 5.36. The applied cost of water is Tk 25 per m3 for house- holds with piped water into the dwelling and Tk 248 per m3 for households with water in the yard or outside yard. The cost of the latter reflects the value of time spent on collecting and bringing water into the dwelling or to a place convenient for hand- washing.59 Cost of soap consumption is calculated at Tk 35 per bar of soap. Time spent on handwashing is valued at 50 percent of average wage rate. The intervention includes a handwashing facility—a purpose-built 20-liter drum with tap, basin, and stand—at a cost of Tk 1,400 per facility (Ross et al. 2021). The cost is annualized over five years at an annual discount rate of 5 percent. The total cost of the intervention will be 5–10 percent lower for households that already have a handwashing facility. The intervention also includes an initial handwashing promotion program costing Tk 1,000 per household also annualized over five years. It is assumed that households with children under five years of age have one child of this age. The annualized cost per household for the first three household scenarios is the same. In the last household scenario, the promotion program only targets caretakers of children under five. Therefore, the recurrent cost is only for a caretaker and child and not for other household members. The annualized cost per household is a little less than half the cost for the first three-household scenarios. Time spent on handwashing constitutes 60 percent of total annualized cost. Soap consumption is the second largest cost com- ponent followed by the cost of incremental water consumption. Table 5.36 Annualized cost of handwashing with soap | Tk per household per year (1) (2) (3) (4) All households Households Households Caretaker and with without children under children children five only) under five under five Cost of water for handwashing 1,114 1,114 1,114 518 Cost of soap consumption 1,806 1,806 1,806 840 Cost of time spent on handwashing 5,393 5,393 5,393 2,508 Annualized cost of handwashing facility 323 323 323 323 Annualized cost of promotion program 231 231 231 231 Total annualized cost 8,867 8,867 8,867 4,421 Source: World Bank estimates. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 103 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.5.3.2 Benefits of hygiene interventions Handwashing with soap can reduce diarrheal disease and ALRIs. Estimating the reductions in these disease burdens requires knowing the risk of disease after adopting an intervention relative to before the intervention. Reviews of studies have found diar- rheal disease reduction of 30 percent (Ejemot-Nwadiaro et al. 2021) and ALRI disease reduction of 26 percent (Rabie and Curtis 2006) from handwashing with soap at critical junctures such as before food preparation and eating and feeding a child, and after going to the toilet. An estimated 13,500 deaths and 215 million days with diarrheal disease and ALRI can be avoided each year if all households adopt handwashing with soap. Currently, 53 percent of the population is not practicing adequate handwashing. These poten- tial health benefits are estimated using the potential impact fraction (PIF) formula in annex N and the disease-reduction rates above. The valuation of health benefits per household per year is estimated using methodology in appendixes H and I. Benefits per household are substantially higher for households with children under five than for households without children under five. Benefits would be even greater for households with more than one child under five. For the last scenario, with the promotion program only targeting caretakers and children under five, the household benefits are lower as only two individuals benefit from the program (table 5.37). Table 5.37 Benefits of handwashing with soap | Tk per household per year (1) (2) (3) (4) All households Households with Households without Caretaker and chil- children under five children under five dren under five only Annual health benefits 16,869 21,127 14,253 13,503 Source: World Bank estimates. 5.5.3.3 Benefit-cost ratios of hygiene interventions The BCRs of the handwashing with soap interventions range from 1.6 to 3.3 (figure 5.7). The BCR is largest for a promotion pro- gram that targets caretakers of children under five years of age (caretaker plus child only). For programs that target all household members, BCR is substantially higher for households with children under five. BCRs are slightly larger for households that already have a handwashing facility (HWF). The BCRs will only be slightly lower if only a portion of targeted households, or only a portion of household members responds to the handwashing promotion program because all costs and benefits are proportional to the number of households or individuals responding to the intervention, except for the cost of the promotion program which is a very small fraction of total cost. The BCRs are sensitive to the incremental time spent on handwashing due to its large share of total cost. However, the BCR ex- ceeds one (that is, benefits exceed cost) for time use up to 6 minutes per person per day in all scenarios in figure 5.7, and up to 14 minutes for caretaker plus child only. Figure 5.7 Benefit-cost ratios (BCRs) of handwashing with soap at critical junctures, 2019 Source: World Bank estimates. Note: HHs = Households; w/ = with; w/o = without; u5 = under five years of age; HWF = Handwashing facility. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 104 Cost-Benefit Analysis of Environmental Health-Risk Interventions 5.5.4 Conclusions on improved WASH interventions The drinking water, sanitation, and hygiene interventions assessed in this report have the potential to avert nearly 34,000 deaths per year if fully implemented and adopted. The largest potential is from household POUT of drinking water followed by handwashing with soap (table 5.38). Table 5.38 Summary of benefit-cost assessment of interventions Population in need of Potential averted Interventions BCRs intervention (%) deaths per year Household POUT of drinking water 1.8–4.7 90 21,783 Safely managed non-shared household sanitation 2.1–6.0 35 6,232 Handwashing with soap 1.6–3.3 53 13,515 Total 33,838 a Source: World Bank estimates. Note: a “Total” is estimated using joint attributable fraction formula. The interventions with the highest BCRs are household POUT with ceramic filter, safely managed improved non-shared sanita- tion for households currently having unimproved sanitation, and promotion of handwashing with soap targeting caregivers of children under five years of age (figure 5.8). Therefore, these interventions have the highest priority for implementation. However, their implementation should be followed by safely managed improved non-shared sanitation for households currently sharing sanitation with other households, and promotion of handwashing with soap to all household members as these interventions also have BCRs above 1, meaning that benefits exceed costs of intervention. Figure 5.8 Interventions with the highest benefit-cost ratios (BCRs) Source: World Bank estimates. 5.6 Benefits and costs of mitigating arsenic in drinking water Testing of drinking water continues to confirm that arsenic contamination of drinking water remains a health concern in Bangla- desh (BBS/UNICEF 2019). Annual deaths from population exposure to arsenic in drinking water are estimated at over 40,000 in 2019 along with 1.7 billion days lived with chronic illness. Arsenic contamination is far more prevalent in shallow tube wells than in deep tube wells. However, some deep tube wells, especially in Sylhet division, are also contaminated (BBS/UNICEF 2011). Therefore, an intervention to avoid arsenic exposure is the provision of deep tube wells in locations where deep tube wells will not be contaminated. Ponds with sand filter may be an option in locations where deep tube wells are likely to be contaminated with arsenic. Even tube wells with intermediate depth are often free from arsenic in locations with arsenic in shallow tube wells (Jamil et al. 2019). A third intervention is household point-of-use (POU) filtering, such as the SONO filter developed in Bangladesh that uses iron and sand filtration. The SONO filter BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 105 Cost-Benefit Analysis of Environmental Health-Risk Interventions has been demonstrated to effectively remove arsenic in drinking water (Neumann et al. 2013). However, wide adoption and sus- tained use of filters have been challenging to achieve (Kundu, Mol, and Gupta 2016; Sanchez et al. 2016). Three arsenic mitigation interventions are assessed: (a) deep tube wells; (b) community pond sand filter; and (c) household point-of-use (POU) filtering of drinking water. These interventions would be targeted at the nearly 17 percent of households in Bangladesh with more than 10 μg/L of arsenic in their drinking water (BBS/UNICEF 2019). Large-scale and continued arsenic testing of groundwater would form a solid basis for the interventions and would provide its own benefits in encouraging households to take actions to reduce exposure to contam- inated wells (Jamil et al. 2019). 5.6.1 Cost of arsenic-mitigation interventions The costs of arsenic-mitigation interventions are presented in table 5.39. The capital cost per household is highest for tube wells and pond sand filters. Th maintenance and repair cost is highest for pond sand filter and POU filter. A program to promote interventions is also included with a one-time initial cost. Incremental time use for the interventions is valued at 50 percent of average hourly rural wage rate because more than 85 percent of the population exposed to excessive arsenic in drinking water live in rural areas. 5.6.1.1 Deep tube wells and pond sand filters The cost of a deep tube well is about Tk 90,000 depending on the actual depth and flow capacity. The cost of a pond sand filter is about Tk 70,000. These cost estimates are based on UNICEF (2011) and Jamil et al. (2019) adjusted for inflation. The interven- tions are of a capacity to be shared by 10 households. It is assumed that households receiving a deep tube well or pond sand filter need to use five more minutes per day to fetch drinking water compared to their current source of drinking-water supply. 5.6.1.2 Household filtering of drinking water A household point-of-use (POU) device for filtering drinking water to remove arsenic is relatively inexpensive. The SONO filter developed in Bangladesh costs around Tk 3,400 and can produce as much as 30 liters of filtered water per hour and last at least five years (Akter and Ali 2011). Incremental time use of five minutes per household per day is also included for POU filtering of water. (See table 5.39) Table 5.39 Cost of arsenic-mitigation interventions Deep tube well Pond sand filter POU filter Capital cost (Tk per household) 9,000 7,000 3,400 Useful life (years) 20 20 5 Maintenance and repair (Tk per household year) 250 990 170 Program promotion (Tk per household) 1,000 1,000 1,000 Incremental time use (minutes per household per day) 5 5 5 Source: World Bank. Table 5.40 presents annualized costs of interventions per household with a discount rate of 5 percent. The largest annualized cost component is incremental time use that is valued at 50 percent of average rural wage rates. Program cost is annualized over the useful life of the intervention and is therefore higher for the POU filter. The total annualized intervention cost per household per year is highest for pond sand filter and lower for POU filter and deep tube well. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 106 Cost-Benefit Analysis of Environmental Health-Risk Interventions Table 5.40 Annualized cost of arsenic-mitigation interventions | Tk per household per year Deep tube well Pond sand filter POU filter Annualized capital cost 688 535 748 Annualized program cost 76 76 220 Recurrent maintenance and repair 250 990 170 Incremental time use 1,464 1,464 1,464 Total annualized cost 2,478 3,065 2,601 Source: World Bank estimates. 5.6.2 Benefits of arsenic-mitigation interventions The health benefits of the arsenic-mitigation interventions are estimated based on the elevated risk of premature mortality from long-term exposure to arsenic in Bangladesh (Argos et al. 2010; Sohel et al. 2009). An estimate of days lived with illness is also included. Each of the three interventions, if properly implemented, can mitigate nearly all health effects of elevated arsenic exposure. To com- ply with the WHO guideline of a maximum 10 μg of arsenic per liter of drinking water (10 ppb), 95 percent effectiveness is applied for deep tube wells since some deep tube wells are at risk of arsenic contamination. One-hundred-percent effectiveness is applied for pond sand filters since these filtering systems are designed to remove practically all arsenic. Ninety percent effectiveness is ap- plied for household POU filtering (SONO filter) based on test results reported in Neumann et al. (2013). However, diarrheal-disease incidence; may change—here assumed to increase by 10 percent with substitution from current drinking-water sources (that is, shallow tube wells) to pond sand filters as they can become contaminated during handling and storage. No change in diarrheal incidence is assumed by substitution from shallow to deep tube wells or use of POU filtering device for arsenic removal. Health effects associated with diarrheal disease are estimated using the PIF formula in annex N. Avoided deaths and illness from the interventions are valued by applying the methodologies in appendixes H and I. This gives benefits per beneficiary household in the range of Tk 92–100 thousand per year (table 5.41). Table 5.41 Benefits of arsenic-mitigation interventions | Tk per household per year Deep tube well Pond sand filter POU filtering Arsenic removal 97,048 102,156 91,940 Change in diarrheal disease 0 -2,375 0 Total health benefits 97,048 99,781 91,940 Source: World Bank estimates. 5.6.3 Benefit-cost ratios of arsenic mitigation interventions The BCRs of the interventions range from 33–39, indicating that benefits are Tk 33–39 for every Tk spent. The BCR is highest for deep tube wells and lowest for pond sand filters (figure 5.9). The BCR for tube wells would be higher where intermediate depth tube wells are arsenic-free because the cost of tube wells increases with depth. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 107 Cost-Benefit Analysis of Environmental Health-Risk Interventions Figure 5.9 Benefit-cost ratios (BCRs) of arsenic-mitigation interventions Source: World Bank estimates. The BCRs depend on the arsenic levels in drinking water and range from 23 to 28 for households with 10–50 μg/L arsenic and 38 to 45 for households with more than 50 μg/L arsenic in their drinking water (table 5.42). Table 5.42 Benefit-cost ratios (BCRs) of arsenic-mitigation interventions Arsenic (μg/L) Deep tube well Pond sand filter SONO filter 10–50 28 23 25 > 50 45 38 41 Source: World Bank estimates. 5.6.4 Conclusions on arsenic-mitigation interventions The BCRs of the three interventions for mitigating exposure to arsenic in drinking water are very high—about ten times higher than the BCRs for mitigating the bacteriological pollution associated with inadequate drinking water, sanitation, and hygiene and for mitigating household air pollution. Considering the serious health effects for the population exposed to arsenic and the very high BCRs of interventions, implementation of interventions stands out as a high priority. 5.7 Conclusions This chapter has presented assessments of costs and benefits of interventions to protect and improve environmental health in Bangladesh. Five environmental health-risk factors have been considered in these assessments. This chapter has examined a wide range of interventions for the control of PM2.5 ambient air pollution, addressing household air pollution, mitigating exposure and effects of lead (Pb), avoiding microbiological pollution from inadequate WASH, and avoiding exposure to arsenic in drinking water. Assessments of other potential environmental health risks such as exposure to arsenic in food and exposure to mercury and cadmium from different sources are not included but are much needed. The report finds that the BCRs of the assessed interventions reach as high as 134 for PM2.5 pollution control, from 1.9 to over 20 for controlling Pb, and from 1.6 to 45 for WASH interventions including addressing arsenic in drinking water. This indicates high rates of return on many investments for protecting health against environmental risks in Bangladesh. The largest range in BCRs is for ambient PM2.5 control interventions. There are interventions that provide extremely high BCRs but with limited ambient PM2.5 improvements. There are also interventions that may be achieved at no net cost, or even at net savings. There are also expensive interventions that have a BCR of 0.3 where costs are three times as high as the benefits. Overall, the BCR is as high as 8.8 for a package of comprehensive PM2.5 control measures that is estimated to reduce nationwide popu- lation-weighted ambient PM2.5 by as much as 20 μg/m3, or one-third of ambient PM2.5 concentrations. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 108 Cost-Benefit Analysis of Environmental Health-Risk Interventions The single most-effective intervention to improve ambient PM2.5 is reduction or elimination of household use of solid fuel for cooking by having households switch to LPG or electricity; this has the added benefit of reducing the health effects of household air pollution. The intervention is found to contribute to about half of the ambient PM2.5 improvement expected from the imple- mentation of a broader comprehensive package of PM2.5 control measures. Other interventions with high BCRs include banning agricultural residue burning in the fields, recycling waste that otherwise is burned, and controlling emissions from industry and the power sector. Further control of emissions from cars, buses, trucks, and two-wheelers either provides limited potential for im- provement in ambient PM2.5 or costs more than the estimated benefits. The BCRs for four interventions to control household air pollution range from 3.1 to 4.5. The BCRs for the two improved biomass cookstoves are higher than for LPG or conventional electric stoves, but similar or lower than the BCR for electric induction stoves since these stoves have very high energy efficiency. The improved biomass cookstoves provide limited health benefits compared to clean cooking technologies such as LPG and electricity. These interventions are the options for effectively combatting the health effects of solid fuels. In other words, improved biomass cookstoves may be an efficient but not an effective solution for im- proving the health of the population. Health benefits will be especially large when clean cooking is achieved community-wide. One priority that emerges from the analysis is to assess further the potential for promoting the use of electric stoves—especially induction stoves—for cooking. This is cheaper than LPG for small electricity users that can benefit from lower electricity tariff rates. With residential block tariffs for electricity pricing, cooking with electricity becomes feasible for less well-off households. Further assessment is also needed regarding the price and non-price obstacles and incentives for adoption of LPG for cooking. The BCRs of the three interventions to mitigate Pb exposure and impacts range from 1.2 to 21.9. This includes an iron-supplemen- tation intervention for young children with a BCR of 6.6–9.1; hot-spot ULAB site rehabilitation with a BCR of 1.9; and potentially, subject to further studies, an intervention to replace lead-contaminated cookware made from recycled aluminum with a BCR of 1.2–21.9 depending on the magnitude of contamination. Representative BLL measurement studies along with identification of sources of lead exposure are essential to identify further interventions. The BCRs of interventions for improving household WASH range from 1.6 to 6.0. The interventions with the highest BCRs for ad- dressing microbiological pollution are household point-of-use treatment of drinking water with ceramic filter, safely managed im- proved non-shared sanitation for households currently having unimproved sanitation, and promotion of handwashing with soap targeting caregivers of children under five. Boiling drinking water using wood or agricultural residues is the least attractive option for improving drinking-water quality, since this practice has negative health effects from generating household air pollution. The BCRs of the three interventions for mitigating exposure to arsenic in drinking water are very high—in the range of 23 to 45. Considering the serious health effects of arsenic exposure and the very high BCRs of interventions, implementation of interven- tions stands out as a high priority. The BCRs are highest for deep tube wells. Ponds with sand filters may be an option in locations where deep tube wells are likely to be contaminated with arsenic. A third intervention is household point-of-use (POU) filtering, such as the SONO filter that uses iron and sand filtration, which can effectively remove arsenic in drinking water. However, wide adoption and sustained use of filters have been challenging to achieve. In the short-term, further analysis on water pollution is needed to (a) assess the impacts of and measures to address other highly poisonous heavy metals in both drinking water and rivers, such as lead, mercury, and cadmium, (b) assess the impacts of and potential solutions for freshwater salinization, and (c) identify specific interventions to manage industrial effluent or liquid discharge as well as untreated municipal sewage water. Implementation of the interventions addressing the five environmental health-risk factors assessed in this report is estimated to prevent over 133,000 deaths per year. This is nearly half of the total annual deaths from the five risk factors. Most of the re- maining deaths are due to PM2.5 ambient air pollution and lead exposure among adults. A large share of the remaining deaths from ambient PM2.5 can only be avoided by Bangladesh cooperating with neighboring countries to address transnational pol- lution. The main benefit of the interventions to mitigate lead exposure is increased lifetime income from averting IQ losses in early childhood. Interventions must also be identified that mitigate adult lead exposure. For microbiological pollution causing infectious disease and mortality, more advanced interventions would be required to further reduce annual deaths. This includes interventions to improve, for instance, food safety and exposure to polluted surface water. Full implementation of the proposed interventions is expected to avert practically all health effects currently arising from household air pollution caused by the use of solid fuels and from exposure to arsenic in drinking water. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 109 Cost-Benefit Analysis of Environmental Health-Risk Interventions C5 References / Endnotes Ahmad, S. A., M. H. Khan, S. Khandker. F. M. Sarwar, N. Yasmin, M. H. Faruquee, and R. Yasmin. 2014. “Blood Lead Levels and Health Problems of Lead Acid battery Workers in Bangladesh.” Scientific World Journal 1–7. http://dx.doi.org/10.1155/2014/974104. Ahmed, N., and Z. Iqbal. 2018. “Benefits of Improved Cook Stoves: Evidence from Rural Bangladesh.” Bangladesh Development Studies 41 (4): 1–27. Ahmed, S., H. Sarma, Z. H. M. Rahman, Md. W. Ahmed, Md. A. Islam, E. W. Djimeu, M. N. Mbuya, T. Ahmed, and J. A. Khan. 2021. “Cost-Effectiveness of a Market- based Home Fortification of Food with Micronutrient Powder Programme in Bangladesh.” Public Health Nutr 24 (S1): s59–70. Akpan, E., S. J. Hossain, A. Devine, S. Braat, Md. I. Hasan, S. M. M. U. Tipu, Md. S. A. Bhuiyan, J. D. Hamadani, B.-A. Biggs, S.-R. Pasricha, and N. Carvalho. 2022. “Cost- effectiveness of Universal Iron Supplementation and Iron-Containing Micronutrient Powders for Anemia among Young Children in Rural Bangladesh: Analysis of a Randomized, Placebo-controlled Trial.” Am J Clin Nutrition 116: 1303–13. Akter, A., and M. H. Ali. 2011. “Arsenic Contamination in Groundwater and Its Proposed Remedial Measures.” Int J Environ Sci Tech 8 (2): 433–43. Argos, M., Kalra, T., Rathouz, P., Chen, Y., Pierce, B., Parvez, F., Islam, T., Ahmed, A., Rakibuz-Zaman, M., Hasan, R., Sarwar, G., Slavkovich, V., van Geen, A., Graziano, J., and Ahsan, H. 2010. Arsenic exposure from drinking water, and all-cause and chronic-disease mortalities in Bangladesh (HEALS): a prospective cohort study. Lancet 376: 252–58. BBS (Bangladesh Bureau of Statistics). 2022. Population and Housing Census 2022. Preliminary Report and additional data provided by BBS. Ministry of Planning. Government of the People’s Republic of Bangladesh. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2021. Statistical Yearbook Bangladesh 2020. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2011. Bangladesh National Drinking Water Quality Survey of 2009. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2019. Progotir Pathey, Bangladesh Multiple Indicator Cluster Survey 2019, Survey Findings Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. Berkeley Air Monitoring Group. 2022. “Bangladesh’s National Cookstove Program: Comparing Beneficiaries of IDCOL Stoves to Traditional Stoves by Exposure to Household Air Pollution.” Prepared in collaboration with the International Centre for Diarrheal Research, Bangladesh (ICDDR,B) for the Infrastructure Development Company Limited (IDCOL). Berkeley, CA: Berkeley Air Monitoring Group. Bhattacharyya, P., J. Bisen, D. Bhaduri, S. Priyadarsini, S. Munda, M. Chakraborti, T. Adak, P. Panneerselvam, A. K. Mukherjee, S. L. Swain, P. K. Dash, S. R. Padhy, A. K. Nayak, H. Pathak, S. Kumar, and P. Nimbrayan. 2021. “Turn the Wheel from Waste to Wealth: Economic and Environmental Gain of Sustainable Rice Straw Management Practices over Field Burning in Reference to India.” Science of the Total Environment 775: 145896. https://doi.org/10.1016/j.scitotenv.2021.145896. Bouhouch, R. R., S. El-Fadeli, M. Andersson, A. Aboussad, L. Chabaa, C. Zeder, M. Kippler, J. Baumgartner, A. Sedki, and M. B. Zimmermann. 2016. “Effects of Wheat- flour Biscuits Fortified with Iron and EDTA, Alone and in Combination, on Blood Lead Concentration, Iron Status, and Cognition in Children: A Double-blind Randomized Controlled Trial.” American Journal of Clinical Nutrition 104: 1318–26. doi:10.3945/ajcn.115.129346. Chowdhury. K. I. A. Chowdhury, S. Nurunnahar, Md. L. Kabir, Md. T. Islam, M. Baker, M. S. Islam, M. Rahman, M. A. Hasan, A. Sikder, L. H. Kwong, G. K. Binkhorst, E. Nash, J. Keith, A. McCartor, S. P. Luby, and J. E. Forsyth. 2021. “Child Lead Exposure near Abandoned Lead Acid Battery Recycling Sites in a Residential Community in Bangladesh: Risk Factors and the Impact of Soil Remediation on Blood Lead Levels.” Environmental Research 194: 110689. https://doi.org/10.1016/j. envres.2020.110689. Cairncross, S., C. Hunt, S. Boisson, K. Bostoen, V. Curtis, I. C. H. Fung, and W.-P. Schmidt. 2010. “Water, Sanitation and Hygiene for Preventing Diarrhoea.” Int J Epidemiology 39: i193–i205. Clasen, T. 2009. Scaling Up Household Water Treatment Among Low-Income Populations. Geneva, Switzerland: World Health Organization. Clasen, T., K. Alexander, D. Sinclair, S. Boisson, R. Peletz, H. Chang, F. Majorin, and S. Cairncross. 2015. “Interventions to Improve Water Quality for Preventing Diarrhoea.” Cochrane Database Syst Rev 10: CD004794. Crump, K., C. Van Landingham, T. Bowers, D. Cahoy, and J. Chandalia. 2013. “A Statistical Reevaluation of the Data Used in the Lanphear et al. (2005) Pooled- Analysis that Related Low Levels of Blood Lead to Intellectual Deficits in Children.” Crit Rev Toxicol 43 (9): 785–99. Dobrescu, A.-I., A. Ebenberger, J. Harlfinger, U. Griebler, I. Klerings, B. Nußbaumer-Streit, A. Chapman, L. Affengruber, and G. Gartlehner. 2022. “Effectiveness of Interventions for the Remediation of Lead-contaminated Soil to Prevent or Reduce Lead Exposure: A Systematic Review.” Science of the Total Environment 806: 150480. https://doi.org/10.1016/j.scitotenv.2021.150480. DoE (Department of Environment). 2023. Air quality monitoring data provided to the World Bank. Dhaka, Bangladesh: Department of Environment. Ministry of Environment, Forest and Climate Change. Ejemot-Nwadiaro, R. I., J. E. Ehiri, D. Arikpo, M. M. Meremikwu, and J. A. Critchley. 2021. “Hand-washing Promotion for Preventing Diarrhoea.” (Review). Cochrane Database of Systematic Reviews 1: CD004265. doi:10.1002/14651858.CD004265.pub4. Ericson, B., P. Landrigan, M. P. Taylor, J. Frostad, J. Caravanos, J. Keith, and R. Fuller. 2016. “The Global Burden of Lead Toxicity Attributable to Informal Used Lead- Acid Battery Sites.” Annals of Global Health 82 (5): 686–99. Fewtrell, L., A. Prüss-Üstün, R. Bos, F. Gore, and J. Bartram. 2007. “Water, Sanitation and Hygiene: Quantifying the Health Impact at National and Local Levels in Countries with Incomplete Water Supply and Sanitation Coverage.” Environmental Burden of Disease 15. Geneva, Switzerland: World Health Organization. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 110 Cost-Benefit Analysis of Environmental Health-Risk Interventions GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. Gottesfeld, P., and A. Pokhrel. 2011. “Review: Lead Exposure in Battery Manufacturing and Recycling in Developing Countries and Among Children in Nearby Communities.” Journal of Occupational and Environmental Hygiene 8: 520–32. Hanna, R., E. Duflo, and M. Greenstone. 2016. “Up in Smoke: The Influence of Household Behavior on the Long-Run Impact of Improved Cooking Stoves.” American Economic Journal: Economic Policy 8 (1): 80–114. Jamil, N., H. Feng, K. Ahmed, I. Choudhury, P. Barnwal, and A. van Geen. 2019. “Effectiveness of Different Approaches to Arsenic Mitigation over 18 Years in Araihazar, Bangladesh: Implications for National Policy.” Environ Sci Technol 53: 5596−04. doi:10.1021/acs.est.9b01375. Kar, A., and H. Zerriffi. 2015. “Adoption of Clean Cooking Solutions: A Theory-Based Approach to Understanding Household Energy Transition.” Working Paper. Institute for Resources, Environment and Sustainability, University of British Columbia, Vancouver, British Columbia, Canada. Kordas, K. 2017. “The ‘Lead Diet’: Can Dietary Approaches Prevent or Treat Lead Exposure?” Journal of Pediatrics 185 (June): 224–31.e1. doi:10.1016/j.jpeds.2017.01.069. Kundu, D. K., A. P. J. Mol, and A. Gupta. 2016. “Failing Arsenic Mitigation Technology in Rural Bangladesh: Explaining Stagnation in Niche Formation of the Sono Filter.” Water Policy 18 (6): 1490–507. https://doi.org/10.2166/wp.2016.014. Larsen, B. 2017. Benefits and Costs of Cooking Options for Household Air Pollution Control: Haiti Priorise Project. Copenhagen Consensus Center. https://www. copenhagenconsensus.com/sites/default/files/eng_larsen_cookstoves_bl.pdf Lewis, J., V. Bhojvaid, N. Brooks, I. Das, M. Jeuland, O. Patange, and S. Pattanayak. 2015. “Piloting Improved Cookstoves in India.” Journal of Health Communication 20: 28–42. McCartor, A. 2018. Toxic Sites Identification Program in Bangladesh. Prepared for UNIDO (United Nations Industrial Development Organization). New York, NY: Pure Earth. https://www.pureearth.org/wp-content/uploads/2018/12/Bangladesh-TSIP-Report-UNIDO.pdf. McCartor, A., and E. Nash. 2018. Project Completion Report: Reducing Lead Poisoning Among Children in Kathgora, Bangladesh. New York, NY: Pure Earth. https://www.pureearth.org/wp-content/uploads/2019/10/PCR-Report_Kathgora.pdf. McGuigan, K. G., R. M. Conroy, H. J. Mosler, M. du Preez, E. Ubomba-Jaswa, and P. Fernandez-Ibañez. 2012. “Solar Water Disinfection (SODIS): A Review from Bench- top to Roof-top.” J Hazard Mater 235–236: 29–46. Miller, G., and A. M. Mobarak. 2015. “Learning about New Technologies through Social Networks: Experimental Evidence on Non-Traditional Stoves in Rural Bangladesh.” Marketing Science 34 (4): 480–99. Mobarak, A. M., P. Dwivedi, R. Bailis, L. Hildemann, and G. Miller. 2012. “The Low Demand for New Cookstove Technologies.” Proceedings of the National Academy of Sciences 109 (27): 10815–20. Neumann, A., R. Kaegi, A. Voegelin, A. Hussam, A. K. Munir, and S. J. Hug. 2013. “Arsenic Removal with Composite Iron Matrix Filters in Bangladesh: A Field and Laboratory Study.” Environ Sci Technol 47 (9): 4544–54. NIPORT (National Institute of Population Research and Training) / ICF (IFC International Inc.). 2020. “Bangladesh Demographic and Health Survey 2017–18.” Dhaka, Bangladesh, and Rockville, MD: NIPORT and ICF International Inc. Olofin, I., C. M. McDonald, M. Ezzati, S. Flaxman, R. Black, W. Fawzi, L. Caulfield, and G. Danaei. 2013. “Associations of suboptimal growth with all-cause and cause- specific mortality in children under five years: a pooled analysis of ten prospective studies.” PLoS ONE 8: e64636. Pasricha, S.-R., M. I. Hasan, S. Braat, L. M. Larson, S. M. M.-U. Tipu, S. J. Hossain, S. Shiraji, A. Baldi, Md. S. A. Bhuiyan, F. Tofail, J. Fisher, S. Grantham-McGregor, J. A. Simpson, J. D. Hamadani, and B.-A. Biggs. 2021. “Benefits and Risks of Iron Interventions in Infants in Rural Bangladesh.” NEJM 385 (11): 982–95. Pasricha, S.-R., H. E. K. Kalumba, and B.-A. Biggs. 2013. “Effect of Daily Iron Supplementation on Health in Children Aged 4–23 Months: A Systematic Review and Meta-analysis of Randomised Controlled Trials.” Lancet Global Health 1 (2): e77–86. Pasricha, S.-R., A. Gheorghe, F. Sakr-Ashour, A. Arcot, L. Neufeld, L. E. Murray-Kolb, P. S. Suchdev, and M. Bode. 2020. “Net Benefit and Cost-effectiveness of Universal Iron-containing Multiple Micronutrient Powders for Young Children in 78 Countries: A Microsimulation Study.” Lancet Global Health 8 (8): e1071–80. Pillarisetti, A., M. Vaswani, D. Jack, K. Balakrishnan, M. Bates, N. Arora, and K. R. Smith. 2014. “Patterns of Stove Usage after Introduction of an Advanced Cookstove: The Long-Term Application of Household Sensors.” Environ Sci Technol 48: 14525−33. Pope, D., B. Nigel, M. Dherani, K. Jagoe, and E. Rehfuess. 2017. “Real-Life Effectiveness of ‘Improved’ Stoves and Clean Fuels in Reducing PM2.5 and CO: Systematic Review and Meta-Analysis.” Environment International 101 (April): 7–18. Pure Earth. 2023. “Lead in consumer goods: A 25-country analysis of lead (Pb) levels in 5,000+ products and foods.” New York: Pure Earth. www.pureearth.org. Prüss-Üstün, A., J. Wolf, J. Bartram, T. Clasen, O. Cumming, M. Freeman, B. Gordon, P. Hunter, K. Medlicott, and R. Johnston. 2019. “Burden of Disease from Inadequate Water, Sanitation and Hygiene for Selected Adverse Health Outcomes: An Updated Analysis with a Focus on Low- and Middle-income Countries.” International Journal of Hygiene and Environmental Health 222: 765–77. Rabie, T. and V. Curtis. 2006. “Handwashing and Risk of Respiratory Infections: A Quantitative Systematic Review.” Trop Med Int Health 11 (3): 258–67. Rosado, J. L., P. López, K. Kordas, G. García-Vargas, D. Ronquillo, J. Alatorre, and R. J. Stoltzfus. 2006. “Iron and/or Zinc Supplementation Did Not Reduce Blood Lead Concentrations in Children in a Randomized, Placebo-controlled Trial.” Journal of Nutrition 36: 2378–83. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 111 Cost-Benefit Analysis of Environmental Health-Risk Interventions Ross, I., J. Esteves Mills, T. Slaymaker, R. Johnston, G. Hutton, R. Dreibelbis, and M. Montgomery. 2021. “Costs of Hand Hygiene for All in Household Settings: Estimating the Price Tag for the 46 Least Developed Countries.” BMJ Global Health 6: e007361. doi:10.1136/bmjgh-2021-007361. Ruiz-Mercado, I., E. Canuz, J. Walker, and K. Smith. 2013. “Quantitative Metrics of Stove Adoption Using Stove Use Monitors (SUMs).” Biomass Bioenergy 57: 136–48. Saha, A., M. A. Razzak, and M. R. Khan. 2021. “Electric Cooking Diary in Bangladesh: Energy Requirement, Cost of Cooking Fuel, Prospects, and Challenges.” Energies 14: 6910. https://doi.org/10.3390/en14216910. Sanchez, T., D. Levy, M. H. Shahriar, M. N. Uddin, A. Siddique, J. Graziano, A. Lomax-Luu, A. van Geen, and M. Gamble. 2016. “Provision of Well-water Treatment Units to 600 Households in Bangladesh: A Longitudinal Analysis of Urinary Arsenic Indicates Fading Utility.” Sci Total Environ 563–64: 131–37. doi:10.1016/j. scitotenv.2016.04.112. Shahriar, M. H., M. A. H. Chowdhury, S. Ahmed, M. Eunus, S. B. Kader, B. A. Begum, T. Islam, G. Sarwar, R. Al Shams, R. Raqib, D. S. Alam, F. Parvez, H. Ahsan, and Md. Yunus. 2021. “Exposure to Household Air Pollutants and Endothelial Dysfunction in Rural Bangladesh.” Environmental Epidemiology 5: e132. doi:10.1097/ EE9.0000000000000132. Shupler, M., W. Godwin, J. Frostad, P. Gustafson, R. E. Arku, and M. Brauer. 2018. “Global Estimation of Exposure to Fine Particulate Matter (PM2.5) from Household Air Pollution.” Environ Int 120: 354–63. Sohel, N., Persson, LA., Rahman, M., Streatfield, PK., Yunus, M., Ekström, EC., Vahter, M. 2009. Arsenic in drinking water and adult mortality: a population-based cohort study in rural Bangladesh. Epidemiology 20 (6): 824–30. SREDA (Sustainable and Renewable Energy Development Authority). 2020. Comprehensive Assessment of the Availability and Use of Biomass Fuels for Various End-Uses with Special Attention to Power Generation. Ministry of Power, Energy and Mineral Resources. Dhaka, Bangladesh: SREDA. UNICEF (United Nations Children’s Fund). 2011. “Making Economic Sense for Arsenic Mitigation: A Case Study of Comilla District, Bangladesh.” Dhaka, Bangladesh: UNICEF Bangladesh. UNICEF (United Nations Children’s Fund). 2020. Sanitation Market Analysis: Summary Report Bangladesh. Lainchaur, Kathmandu, Nepal: UNICEF Regional Office South Asia. UNICEF (United Nations Children’s Fund) / WHO (World Health Organization). 2019. Progress on Household Drinking Water, Sanitation and Hygiene 2000–2017: Special Focus on Inequalities. New York, NY: UNICEF and WHO. Wagner, F., M. Amann, G. Kiesewetter, Z. Klimont, W. Schöpp, and M. Heger. 2020. The Natural Capital Index Report on Fine Particulate Matter (PM2.5) Pollution. Study Commissioned by the World Bank. Internal document. Washington, DC: World Bank. WHO (World Health Organization). 2016. “WHO Guideline: Daily Iron Supplementation in Infants and Children.” Geneva, Switzerland: WHO. https://apps.who.int/ iris/handle/10665/204712. WHO (World Health Organization). 2021. “WHO Guideline for Clinical Management of Exposure to Lead: Executive Summary.” Geneva, Switzerland: WHO. License: CC BY-NC-SA 3.0 IGO. Wolf, J., P. Hunter, M. Freeman, and O. Cumming. 2018. “Impact of Drinking Water, Sanitation and Handwashing with Soap on Childhood Diarrhoeal Disease: Updated Meta-analysis and Meta-regression.” Tropical Medicine and International Health 23 (5): 508–25. World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank. World Bank. 2019. Bangladesh—Beyond Connections: Energy Access Diagnostic Report Based on the Multi-Tier Framework. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/35267 License: CC BY 3.0 IGO. World Bank. 2021. Understanding Market-Based Solutions and Access to Finance Options for Clean-Cooking Technologies in Bangladesh. Washington, DC: World Bank. © World Bank. https://openknowledge.worldbank.org/handle/10986/35841 License: CC BY 3.0 IGO. World Bank. 2022. Striving for Clean Air: Air Pollution and Public Health in South Asia. Washington, DC: World Bank. https://www.worldbank.org/en/region/sar/ publication/striving-for-clean-air World Bank. 2023 World Development Indicators. Washington DC: World Bank. World Bank. Forthcoming. “A World without Lead Poisoning: Health, Development and Economic Impacts.” Washington, DC: World Bank. Zimmermann, M. B., S. Muthayya, D. Moretti, A. Kurpad, and R. F. Hurrell. 2006. “Iron Fortification Reduces Blood Lead Levels in Children in Bangalore, India.” Pediatrics 117 (6): 2014–21. 10.1542/peds.2005-2440. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 112 Cost-Benefit Analysis of Environmental Health-Risk Interventions Endnotes 38 Greenhouse Gas and Air Pollution Interactions and Synergies. 39 “Ambient PM2.5” in this section means population-weighted ambient PM2.5 unless otherwise stated. 40 Most of the categories contain multiple control measures with a range of emission-reduction potentials and costs per μg/m3 of ambient PM2.5 improvement. The measures in each category are ranked from lowest to highest marginal cost per μg/m3. The figure presents the comprehensive control measures for which the benefits exceed the marginal cost of a μg/m3 improvement in ambient PM2.5. 41 Costs are net annualized costs—that is, annualized investment costs (5 percent annual discount rate over the expected useful life of the investments) plus annual recurrent costs less any annualized cost savings that the control measures may provide. 42 Because of the nonlinearity or concavity of the IER functions from the GBD 2019. 43 PM2.5 control measures in Bangladesh will benefits neighboring countries since air pollution drifts across national borders. These benefits are not included in the estimated health benefits here. For estimates of South Asia regional effects of air pollution, see World Bank (2022). 44 The BCR of LPG for cooking is substantially higher here than in the section on benefits and costs of HAP control. This is because of differences in the treatment of benefits and costs in the BCR. Here, the BCR = health benefits / net cost, with the net cost for LPG being cost net of biomass fuel savings and cooking-time savings in order to be consistent with the GAINS cost-effectiveness analysis. As net cost becomes relatively small, the BCR becomes high. Fuel savings and cooking-time savings are treated as benefits in the section on the benefits and costs of HAP control. Thus, the BCR = (health benefits + fuel savings + cooking-time savings)/cost. This is consistent with the calculation of BCRs for the interventions addressing the two other environmental health- risk factors (that is, microbiological pollution and exposure to arsenic in drinking water). This reduces the BCR. 45 Ambient PM2.5 deducted from personal exposure was a rural annual average of 57 µg/m3 for the study by Shahriar et al. (2021) because Shahriar et al included measurements in both the dry and wet seasons. Ambient PM2.5 deducted from personal exposure for the study by Berkeley Air Monitoring Group (2022) was 112 µg/m3. This was average ambient PM2.5 during the dry season measurement period in the five divisions of the study (mainly January–February 2022). 46 Forty minutes for fuelwood collection and preparation (World Bank 2019) and 20 minutes assumed for agricultural-residue collection. 47 This likely somewhat underestimates the value of biomass fuel used by households since households also purchase some of their fuels at a higher price than reflected in the valuation of collection time. 48 Average household size is 4.3 (BBS/UNICEF 2019). 49 The energy efficiency of an electric induction stove can be as high as 90 percent. 50 Household use of solid fuels not only causes serious air pollution in the immediate household environment, but also contributes to outdoor ambient PM2.5 pollution. This is particularly the case if households use TCSs and cook outdoors or vent the smoke out of the dwelling. 51 This likely somewhat underestimates the value of biomass used by households since households also purchase some of their fuels at a higher price than reflected in the valuation of collection time. 52 In calculating the benefit-cost ratios (BCRs) of the interventions, the energy consumption by a TCS is treated as energy saving or benefit when switching to an ICS, LPG, or electric stove and placed in the numerator of the BCR. The energy consumption by an ICS, LPG, or electric stove is treated as cost and placed in the denominator. 53 The promotion-program cost is fixed per targeted household. Therefore, the cost per household that responds to the program increases with lower response rates. 54 EDTA is commonly used for treatment of lead poisoning in children and adults. Benefits and costs of the combination of iron and EDTA are not assessed here, since EDTA is not typically advocated for the general child population. 55 The disability weights are 0.004 for mild, 0.052 for moderate, and 0.149 for severe anemia. 56 https://www.iferi.com/products/6-pcs-stainless-steel-cookware-set-with-lid-kv6608 57 The health damage cost is adjusted by a factor of 0.77 as per appendix N. 58 Tk 3,396 * 2 / 3 = Tk 2,264. 59 The cost of water for households without piped water into their dwelling is calculated as follows: 4.3 minutes collection time per 20 liters of water with time valued at 50 percent of average wage rate. The calculation of the collection time is based on 77 percent of households having water on premises outside their dwelling (three minutes collection time), and 18 percent having water outside their premises (10 minutes collection time). The household water location is from (BBS/UNICEF 2019). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 113 Air Quality Management in the Greater Dhaka Area CHAPTER 6. AIR QUALITY MANAGEMENT IN THE GREATER DHAKA AREA 6.1 Introduction Managing a city’s air quality can involve several different goals, from reducing concentration of pollutant gases to reducing fine and coarse particulate matter; from reducing premature mortality numbers by reducing the annual average pollution levels that people are exposed to, to temporarily restricting polluting activities to bring down pollution levels during peak times. It could also focus on improving indoor air quality. This chapter presents an initial air quality management (AQM) strategy for the Greater Dhaka Area (GDA), that focuses on reduc- ing the population weighted annual average concentration of outdoor fine particulate matter (PM). The GDA, for the purposes of this initial strategy, comprises five of the Dhaka Division’s thirteen districts: Dhaka, Narayanganj, Gazipur, Narsingdi, and Munshi- ganj (figure 6.1). The reasons for focusing on the GDA are: • Bangladesh’s highest air pollution concentrations are in the GDA; therefore, the potential for the most substantive improve- ment in air quality and thereby in human health conditions can be developed and implemented in the GDA. • The GDA includes about 28 million people, or as much as 17 percent of Bangladesh’s population. • The most detailed air quality, source apportionment, and sector data are available for the GDA; therefore, the most precise AQM strategies and action plans can be developed. The chapter explores how the average GDA resident’s exposure to ambient PM2.5, the most harmful air pollutant for human health, could be brought down to the WHO’s annual Interim Target 1 of 35 µg/m3. It addresses the current understanding of the GDA’s air quality situation and quantifies the sources of ambient PM2.5 concentrations in the five GDA districts in 2019–20. It as- sesses how the contributions from the sources in the GDA will likely develop up to 2030. This assessment is based on projections of socioeconomic activities and assuming full implementation of already decided policies and measures to control air pollution. The chapter examines the scope of PM2.5 exposure reductions that could be achieved by measures that can be taken within the GDA and analyzes their cost-effectiveness. Subsequently, the chapter discusses the interplay between measures taken within the GDA and the inflow of pollution to the GDA from other areas within the Indo-Gangetic Plain (IGP) airshed and the role of that interplay in cost-effectively achieving ambient air quality targets. Figure 6.1 (1) Bangladesh, (2) Dhaka Division, and (3) Greater Dhaka Area (GDA) 1 2 3 Sources: (1) https://www.mediabangladesh.net/map-of-bangladesh/ (2) https://store.mapsofworld.com/digital-maps/country-maps-1-2-3/bangladesh/dhaka-divisions (3) GDA map (w/ AAQM stations) developed by World Bank. This chapter’s modeling results and its suggested strategies and policies for improving air quality in the GDA can help Bangla- desh strengthen its green growth strategy, as envisaged in the Bangladesh Perspective Plan 2021–2041 and in the current 8th Five-Year Plan (2021-25) (8FYP). Implementing the clean air programs to reach the air quality improvement targets suggested in BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 114 Air Quality Management in the Greater Dhaka Area this chapter will (a) generate substantive climate co-benefits relating to carbon dioxide (CO2) emissions and short-lived climate pollutants like black carbon (BC) and methane (CH4), (b) generate substantive new jobs in cleaner production, and (c) stimulate economic development in the lowest-income areas (World Bank 2022). 6.2 Air quality in Bangladesh Bangladesh’s air quality is among the world’s worst. Among cities in IGP countries (Bangladesh, India, Nepal, and Pakistan), ambient PM2.5 concentrations in Dhaka city ranks second, surpassed only by Delhi. The average ambient PM2.5 concentration in Bangladesh in 2022 was about 64 µg/m3. In Dhaka, the concentration was as high as 90 to 100 µg/m3. This is approximately 2.7 times Bangladesh’s ambient air quality standard of 35 µg/m3 and approximately 20 times the World Health Organization’s (WHO) air quality guideline (AQG) value of 5 µg/m3 for annual average concentrations of PM2.5. Combining ambient air pollution (AAP) and household air pollution (HAP), air pollution is currently the third-highest health risk factor in Bangladesh. That situa- tion is projected to stay as such to 2030 in the current “business-as-usual” (BAU) scenario for air pollution, given the very limited expected improvements in air quality that current policies offer. An important factor for the high PM2.5 concentrations in Bangladesh—and Dhaka in particular—is their location within the eastern part of the IGP, where Bangladesh, West Bengal, and parts of Jharkhand and Bihar form a natural airshed. This airshed is based on typography (surrounded by hills and mountains), meteorology (a prevailing west-to-east wind, particularly during dry season), and economic conditions (a largely diversified economy within the airshed that creates several pollution sources). Because of trans- boundary effects of air pollution, getting better air quality requires collective action. More importantly, by cooperating with other IGP countries, Bangladesh could benefit from faster and lower cost results in improving air quality. Based on a dialogue where the World Bank has supported the countries in the South Asia Region (SAR) to enhance AQM cooperation—particularly among the IGP countries—a Clean Air 2030 Vision has been developed (box 6.1). Box 6.1 SAR Clean Air 2030 Vision The SAR Clean Air 2030 Vision was developed in early 2021, recognizing that air pollution does not respect political bound- aries and that regional coordination of analytics and harmonization of policies will benefit all IGP countries to achieve clean air goals faster and cheaper than individual action. The goal of this vision is to achieve the WHO Interim Target 1 for annual ambient PM2.5 of 35 µg/m3 or better for the IGP countries by the beginning of the next decade. For SAR and Bangladesh, this would imply the improvements in air quality depicted in figure B6.1.1. By achieving the Clean Air 2030 Vision, most of Bangladesh would experience PM2.5 concentrations between 20 and 35 µg/m3. Figure B6.1.1 SAR Clean Air 2030 Vision 2018 2030 Source: World Bank 2022a. Source: World Bank. 2022a. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 115 Air Quality Management in the Greater Dhaka Area 6.2.1 Spatial trends in ambient PM2.5 in the Greater Dhaka Area Considering the higher population density in the GDA compared to other parts of the country, the population-weighted PM2.5 exposures are expected to be substantially higher in the GDA than elsewhere in Bangladesh. For the available four sites within Dhaka district, the measured annual ambient PM2.5 concentrations are in the range of 83 to 98 µg/m3, indicating relatively low spatial variation within the district. Sites located near Dhaka district, such as Gazipur and Narayanganj, also exhibit similar con- centrations. These areas are growing cities with land-use patterns comparable to those of Dhaka city. However, a site located approximately 100 kilometers away from Dhaka city, Cumilla (see figure 6.2), demonstrates lower concentrations compared to sites within the GDA. Figure 6.2 GDA monitoring stations and their annual ambient PM2.5 concentrations, 2019–20 District Station PM2.5 (µg/m3) Dhaka Darussalam 98 Gazipur district BARC 93 Gazipur Narsingdi district US Embassy 83 Narsingdi Savar 89 Savar Narayanganj Narajanganj 97 Dhaka district US Embassy BARC Gazipur Gazipur 81 Narayanganj Darussalam district Cumilla Narsingdi Narsingdi 67 Narayanganj Munshiganj None – Cumilla 55 Munshiganj district Source: World Bank based on sources from DoE. Note: – = Not available. 6.2.2 Air quality landscape: Long-term spatiotemporal trends in PM2.5 in Bangladesh Long-term trends in ambient PM2.5 are analyzed here from 2012 to 2022. Ten stations in Bangladesh have monitoring data for this period of which four are in the GDA. The sites in the GDA exhibit relatively higher concentrations, while the eastern sites of Sylhet and Chittagong have lower concentrations. Moreover, the western part of the country experiences higher concentrations. These regional differences in concentration levels can be attributed to variations in local source strength and the impact of trans- boundary pollution. The western sites, in particular, may be more influenced by the inflow of transboundary pollution from India and other parts of the IGP region, given the prevailing wind direction during the dry season (World Bank 2022a). Conversely, during the wet season, the prevailing winds from the Bay of Bengal contribute to transported-pollution levels that are relatively lower. Table 6.1 summarizes the rate of change in ground-level PM2.5 at the four monitoring sites in the GDA from 2012 to 2022. These sites experienced higher rates of increase than other sites nationwide. Outside of the GDA, the sites in Rajshahi, Khulna, and Bari- sal also showed an increase in ground-level PM2.5. The site in Sylhet displayed a decline of 1.5 µg/m3 per year, while the two sites in Chittagong showed no statistically significant change. Table 6.1 Rate of increase in annual mean PM2.5 in GDA, 2012–22 Increase per year % increase Location (µg/m3) per year Dhaka (BARC) 2.1 2.0 Dhaka (Darussalam) 2.3 2.2 Narayanganj 2.0 2.0 Gazipur 2.4 2.1 Source: World Bank based on monitoring data from the Department of Environment (DoE). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 116 Air Quality Management in the Greater Dhaka Area 6.3 Sources of PM2.5 Exposure in the Greater Dhaka Area in 2020 6.3.1 Methodology This section presents an initial comprehensive emission inventory of primary PM2.5 emissions and PM2.5 precursors and quantifies the contributions of the various emission sources to ambient PM2.5 in the GDA in 2019–20. This source apportionment was con- ducted with the GAINS City model tailored to the GDA. The model is a state-of-the-art scientific model of cost-effectiveness of air quality measures. It is applied to the GDA’s meteorological conditions and fed with an inventory of emissions of all PM2.5 precursor substances in the entire IGP airshed. Computed ambient PM2.5 is compared against available monitoring data, and the resulting population exposure in the GDA is estimated using fine-scale population data. The GAINS-City model is a new version of the widely applied GAINS model (Amann et al. 2011) that is tailored to the challenges of specific cities. The GAINS model provides the scientific backbone for the development of cost-effective regional AQM strategies in Europe under the Convention on Long-range Transboundary Air Pollution (CLRTAP) and in the European Union with its mem- ber states (Reis et al. 2012). Adapted to other world regions, the GAINS model is now also used to inform governments in China, India, and other countries about cost-effective AQM (for example, World Bank 2022a). The new GAINS-City model has evolved to support the development of investment strategies for specific urban agglomera- tions (World Bank 2021). Relying on the full scientific basis and the regional databases of the GAINS model, GAINS-City tailors its analyses to a given city, greatly reducing the demand for data and the complexity of analyses. At the same time, it improves the description of local conditions, with a focus on the sources most relevant for pollution exposure and greenhouse gas (GHG) emissions in the city. This section presents an initial comprehensive emission inventory of PM2.5 precursors for the GDA. The inventory is based primar- ily on local information collected for this study. Data gaps have been filled with information from other IGP regions compiled in previous work for the GAINS-IGP model (IIT Delhi and IIASA 2023) and adjusted to the GDA’s local situation. Emissions of primary PM2.5 as well as the precursors of secondary PM2.5—that is, SO2, NOx, and ammonia (NH3)—are estimated for the five GDA districts with a 1 km x 1 km spatial resolution, consistent with the complete inventory for the entire IGP airshed that has been developed for the GAINS-IGP model. This airshed approach enables a full cost-effectiveness analysis of a large range of emission-control measures. The model also estimates (a) emission-control costs of about 1,100 possible emission-control options in the GDA, (b) their impact on ambient PM2.5 concentrations and population exposure in the GDA, and (c) the cost-effectiveness of each emission-control measure for reducing PM2.5 exposure in the region. A ranking of the possible control options according to their marginal costs identifies portfolios of the most cost-effective control measures for achieving given targets for reducing PM2.5 exposure. Together with an understanding of the likely future inflow of pollution from other regions in the eastern IGP airshed, these data provide important information for setting realistic targets on air quality in the GDA and information on how these targets might be achieved in cost-effective ways. 6.3.2 GAINS-City for the Greater Dhaka Area The calculation of ambient PM2.5 considers the contributions of (a) primary PM2.5 emissions (soot, fly ash, road dust, and so on); (b) secondary particles, which are formed through chemical reactions from gaseous precursor emissions of SO2, NOx, NH3, and volatile organic compounds (VOCs); and (c) windblown soil dust. For each of these pollutants, the analysis identifies the sectoral origin and locations where they are emitted. Emissions of VOCs are considered in the source apportionment, although their sources are not addressed here in detail. Emissions of these substances in each of the five districts are computed, for each of the 400 source categories considered in GAINS, as a product of the amount of emission-generating activity (for example, fuel consumption) and an emission factor rep- resentative of local conditions, considering the efficiency of applied emission controls. The analysis for the GDA draws primarily on local information collected for this study. The analysis compiled activity data on household energy use, power plants, transportation, brick kilns, small industries, agriculture, and waste from multiple local sourc- es. Household energy use data are derived from the Multiple Indicator Cluster Survey 2019 conducted by the Bangladesh Bureau of Statistics (BBS 2019), providing information about cooking practices and fuel categories. The power-plant database is obtained from the Bangladesh Power Development Board, while yearly vehicle-registration information is sourced from the Bangladesh BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 117 Air Quality Management in the Greater Dhaka Area Road Transport Authority. District statistics from the Bangladesh Bureau of Statistics offer data on agricultural activities and the number of restaurants and small and medium industries, while waste data are obtained from the Bangladesh Waste Database 2014 compiled by Waste Concern. Specific industry information, such as brick kilns, steel factories, and cement factories, is gath- ered from an inventory by the Department of Environment (DoE). Local data on emission factors were not available for all source categories used in the GAINS modeling framework. Data gaps have been filled with information from other countries in the IGP that has been compiled in previous work for the GAINS-IGP model (IIT Delhi and IIASA 2023) and adjusted to the local situation. The local dispersion of primary PM2.5 emitted from sources within the GDA was computed with the Iowa Urban Dispersion model specially developed for this study. The resulting ambient PM2.5 concentrations are then superimposed on concentrations of primary and secondary PM2.5 from sources outside the GDA computed with the GAINS model. Anthropogenic precursor emissions of NM-VOC have not been further explored in this initial analysis since the analysis suggests that they have only a small impact on PM2.5 concentrations. Ambient PM2.5 concentrations are aggregated to annual mean, which is the most relevant metric associated with health im- pacts. PM2.5 population exposure is then calculated by multiplying PM2.5 concentrations computed with a 1 km x 1 km resolution for the whole GDA domain with respective population distribution. 6.3.3 Emissions of PM2.5 precursors Many of the underlying statistics for estimation of emissions were available only up to 2020 at the time of preparing this report. Since the COVID-19 lockdowns in 2020 made that year exceptional, the analysis focused on the two-year period 2019–20. Estimated primary PM2.5 and NH3 emissions were highest in the Dhaka district owing to the largest population, while SO2 and NOx emissions were highest in Gazipur and Narayanganj mainly due to its high density of industrial sources. However, emissions per capita were lowest in the Dhaka district, highest in Narajanganj for SO2 and NOx, and highest in Narsingdi for NH3 reflecting the significant differences in the economic structures across the districts. More than 40 percent of all primary PM2.5 emissions in the GDA originated from the residential sector, mainly from solid fuel used for cooking, municipal waste management, road dust, power generation, and industrial activities contributed about 10 percent each (figure 6.3). Figure 6.3 Sector contributions to emissions of PM2.5, SO2, NOx, and NH3 in the GDA, 2019–20 Primary PM2 SO2 NOx NH3 Source: World Bank calculations. The available data suggest sources that received high public attention in the past, such as road vehicle exhaust and brick kilns, are not the largest contributors to emissions. Over the entire GDA, road vehicles constitute a smaller share of primary PM2.5 emis- sions than in many other countries due to the much lower car ownership in Bangladesh. Obviously, compared to total emissions in the GDA, road vehicles contribute a larger share to PM2.5 concentrations in ambient air near busy roads in Dhaka city center BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 118 Air Quality Management in the Greater Dhaka Area where poor air quality is prominently perceived by the public. For brick kilns, the analysis employs a recent brick-kilns database from the DoE, which includes the specific location of individual brick kilns, annual production, kiln technology, and fuel type. Characteristic emission factors by kiln technology and fuel are drawn from the available research and related literature. In addi- tion, the seasonal pattern of brick production is considered here. The picture looks fundamentally different for the precursor emissions of secondary PM2.5. Power plants account for about two- thirds of total SO2 and 70 percent of NOx emissions, which are important precursors of secondary PM2.5 in the atmosphere. Brick kilns contributed 25 percent of total SO2 but only 3 percent of primary PM2.5 emissions. These estimates consider the typical brick- kiln technologies prevalent in the GDA in 2020 and the use of emission factors that have been measured for these technologies in other South Asian countries. Mobile sources (including non-road mobile machinery) account for only 15  percent of all NOx emissions. SO2, and to a lesser extent NOx, react in the atmosphere with NH3 to form ammonium sulphate and ammonium nitrate particles. An estimated 50 percent of total NH3 emissions in the GDA are caused by the application of mineral fertilizer and about 40 percent by the wastewater sewerage system. For non-road mobile machinery (construction, agriculture, and ships), a 9 percent contribution is estimated for NOx emissions and 2 percent for PM2.5 and SO2 emissions, respectively. Note that these numbers relate to the total GDA area; local situations at hot spots (for example, busy streets) will be higher. As might be expected, higher road and traffic densities in Dhaka city center cause higher emissions from road transport than in other areas. Households make large contributions to primary PM2.5 emissions throughout the GDA, even in Dhaka district where most of the wealthy households in the center have switched to clean fuels for cooking. However, there is still a considerable amount of solid-fuel use reported for the households in Dhaka district. 6.3.4 Ambient PM2.5 concentrations The GAINS-City model has been used to estimate annual mean concentrations of PM2.5 in ambient air in the GDA. The calcu- lation considers the spatial and temporal distributions of the various emission sources, their release heights, meteorological conditions of 2020, the chemical processes that produce secondary PM2.5, the inflow of PM2.5 from outside sources, and the background load from windblown soil dust. Annual ambient PM2.5 concentrations reach more than 100 µg/m³ in the Dhaka city center as well as in the vicinity of some power stations outside the city. The levels in rural areas are generally lower; however, throughout the whole region, concentrations ex- ceed the Bangladesh’s own PM2.5 standard and WHO PM2.5 Interim Target 1 (WHO 2021) both of 35 µg/m³ (figure 6.4). Figure 6.4 Computed mean annual ambient PM2.5 in GDA, 2019–20 µg/m³ 110µg/m³ 110 95 95 80 80 65 65 50 50 35 35 Source: World Bank calculations. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 119 Air Quality Management in the Greater Dhaka Area The geophysical approach of the atmospheric dispersion model employed by GAINS-City makes it possible to track the fate of emissions emerging from specific sources and to thereby quantify their contributions to total ambient PM2.5 concentrations throughout the GDA. Figure 6.5 displays the contributions from key emission-source categories computed for 2019–20. Over the whole area, power-generation sources that disperse their emissions through high stacks—especially plants located outside the Dhaka city center—make the largest contribution to PM2.5 concentrations, followed by brick kilns and rural households using solid fuels. The impacts of other sources are felt more locally where they can lead to high concentrations. Figure 6.5 Annual ambient PM2.5 concentrations originating from key emission sectors in the GDA, 2019–20 | µg/m3 Power generation Brick kilns Mobile sources – exhaust Urban households Rural households Road dust Urban waste Rural waste Legend µg/m³ 25 20 15 10 5 Source: World Bank calculations. An analysis of the relative contributions at individual locations (for example, for specific monitoring sites) provides important information for establishing compliance with air quality standards, since that analysis reveals the importance of the various emission sources for the different monitoring sites. As shown in figure 6.6, there are variations in the relative shares of the source categories across the GDA, depending on the locations of the monitoring sites and emission sources. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 120 Air Quality Management in the Greater Dhaka Area Figure 6.6 Source apportionment of annual mean PM2.5 concentrations for the monitoring sites, 2019-20 100 90 Other 80 Waste 70 Agriculture Road dust 60 Mobile machinery µg/m³ 50 Road exhaust 40 Rural households Urban households 30 Brick kilns 20 Industry 10 Power generation Other countries 0 Soil dust Source: World Bank calculations. In contrast to widely used air quality metrics that refer to the worst conditions, aggregated metrics are more informative to ad- dress the burden of air pollution on public health and to maximize the health benefits from pollution-control interventions. For this purpose, mean population exposure to annual PM2.5 has been found as a relevant metric. This report focuses on population exposure within the five GDA districts, considering the inflow of pollution from outside areas as well as the transport of pollution across the five districts. Due to the large spatial differences of population densities within each district, population-weighted exposure might be higher or lower than concentrations observed at fixed monitoring sites, depending on the station’s location (table 6.2). Table 6.2 Modelled ambient PM2.5 population exposure in GDA, 2019–20 District Population-weighted ambient PM2.5 (µg/m3) Dhaka 92 Narayanganj 88 Gazipur 73 Narsingdi 63 Munshiganj 72 GDA (all five districts) 84 Source: World Bank calculations. Cost-effective air quality management aimed at public health needs to tailor emission controls such that population exposure to PM2.5 will be reduced at least cost. The selection of cost-effective emission controls is informed by source apportionments for population exposure in the target region. Figure 6.7 provides such source apportionments for the five GDA districts. The graphs indicate the contributions to PM2.5 exposure that originate from (a) natural emission sources—that is, soil dust; (b) other countries; (c) districts in Bangladesh outside the GDA regions; (d) surrounding GDA districts; and (e) the district itself. Contributions are broken down by the source sector. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 121 Air Quality Management in the Greater Dhaka Area For Dhaka district, average population exposure is slightly lower than concentrations at the stations in the city center but higher than for all the GDA. Out of the total annual exposure of 92 µg/m³, about one-third originates from sources outside the GDA— that is, from other regions in Bangladesh, other countries, and from natural sources. About two-thirds are caused by emissions within the GDA, out of which about half is transported into the Dhaka district from emission sources in the other four GDA districts. The largest local sources of PM2.5 exposure include households (mainly solid-fuel cookstoves) and waste management. The inflow from other GDA districts is dominated by power-generation plants followed by household cookstoves and brick kilns. In contrast, agricultural sources (e.g. fertilizer application) cause the main inflow from sources that are outside the GDA but within Bangladesh. Annual population exposure in the four other GDA districts (~72 µg/m³) is lower than in Dhaka district. As in Dhaka district, lo- cal emissions contribute only a minor share (between 13 and 30 percent) to total exposure; the rest is imported from outside regions. Between 50 and 60 percent of total exposure originates from the GDA districts, and 20–37 percent from other regions in Bangladesh. Between 15 and 20 percent is linked to sources in other countries. Focusing on the GDA, 56 percent of population-weighted annual mean PM2.5 exposure of 84 µg/m³ is linked to emission sources within the GDA (figure 6.7). The largest share (28 percent) of this local contribution originates from households, mainly biomass cookstoves, followed by power plants in the GDA (24 percent). Thirteen percent emerges from brick kilns in the GDA and 11 per- cent from the open burning of municipal solid waste. Road dust accounts for about 8 percent, and exhaust emissions from road transport for 4 percent (mainly diesel heavy-duty vehicles). Around 65 percent of the population-weighted annual mean PM2.5 concentration in the GDA (84 µg/m3) is primary PM2.5 (PPM) and 35 percent is secondary PM2.5 (SPM). About half of SPM in the GDA is formed through chemical reactions from sources within the GDA—mainly from power plants (SO2 and NOx emissions) and some from brick kilns (SO2 emissions), while nearly one-third is from outside Bangladesh (mainly India) and the rest is from the rest of Bangladesh (mainly NH3 from agriculture). To control the generation of SPM, an equal effort must be done in neighboring countries and the rest of Bangladesh besides inside the GDA itself. Figure 6.7 Source apportionment of annual PM2.5 population exposure in the GDA in 2020 Source: World Bank calculations. The source apportionment analysis clearly demonstrates that effective air quality management strategies require cooperation across multiple jurisdictions. Even moderate air quality improvements in individual GDA districts must involve sources in the entire GDA. For approaching air quality targets such as the WHO Interim Target 1 (the same as Bangladesh’s new air quality stan- dard for annual PM2.5), coordination across the IGP airshed will be indispensable. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 122 Air Quality Management in the Greater Dhaka Area 6.4 Cost-effective emission controls in the Greater Dhaka Area This section presents a cost-effectiveness analysis that ranks available emission-control measures by pollution-control costs that occur for the entire economy over the full lifetime of pollution-control equipment. The section explores how ambient PM2.5 con- centrations could be brought down to the WHO’s annual Interim Target 1 and Bangladesh’s own PM2.5 standard of 35 µg/m3 by 2030. The section examines the scope for PM2.5 exposure reductions that could be achieved by measures taken inside the GDA and analyzes the cost-effectiveness of the individual measures. The section subsequently examines the air quality improvement that can be achieved in the GDA by emission control measures taken elsewhere in Bangladesh and in the larger IGP airshed that affects air quality in the GDA. The analysis of cost-effective emission-control measures for air quality improvements in this section is carried out with the GAINS model that has been tailored to the IGP. The model estimates emission-control costs in the GDA from possible control options, their impact on ambient PM2.5 exposure in the GDA, and the cost-effectiveness of each measure for reducing PM2.5 exposure in the region. A ranking of the possible options according to their marginal costs identifies portfolios of the most cost-effective measures for achieving ambient PM2.5 exposure reduction targets. Together with an understanding of the inflow of pollution from other regions in the eastern IGP airshed, these data provide important information for setting realistic targets on air quality in the GDA and information on how these might be achieved in cost-effective ways. 6.4.1 Baseline ambient PM2.5 projections in the GDA A baseline projection of ambient PM2.5 in the GDA for 2030 is first developed in this section that illustrates the likely consequenc- es of population and economic growth and progressive implementation of current emission-control legislation on air quality. The population in the GDA is assumed to increase by about one percent per year from 2020 to 2030. Along with the vision to become a high-income nation by the year 2041, GDP per capita is assumed to grow by 5.3 percent annually, so that total eco- nomic output in 2030 will be 80 percent higher than in 2020 considering population growth. Targeted economic policies will direct most of the additional activities to less energy-intensive sectors, while production volumes of brick kilns and steel rerolling will stabilize. This socioeconomic trend together with enhanced energy-efficiency policies will limit the increase in total primary energy consumption to less than 25 percent from 2020 to 2030. The demand for private mobility will more than double from 2020 to 2030 at an annual rate of 8.3 percent per year, and the freight transport volume will increase by about 150 percent. The baseline projection also reflects the effect on ambient PM2.5 of pollution-control measures that were already implemented in 2020 or for which implementation is expected by 2030 because of recent legislation (Table 6.3). Table 6.3 Measures assumed in the baseline ambient PM2.5 for 2030 Mobile sources: • Heavy-duty trucks and buses, diesel: In 2030, 50% of fleet with Euro IV, older vehicles Euro I • Light-duty vehicles (cars and vans), gasoline, diesel, LGP: In 2030, 50% of fleet with Euro 4, older vehicles Euro 1 • Light-duty vehicles (cars and vans), CNG: Stage 3 controls • Two-wheelers, gasoline: Stage 1 controls • Two-wheelers, CNG and LPG: Stage 3 controls Households: • Partial collection and centralized disposal of municipal waste in urban areas Industry: • Basic PM controls (cyclones/ESP1) in most industrial sectors (90% of fuel consumption) • Moderate PM controls (ESP2) in a few industrial sectors (cement, fertilizer) • Brick kilns: By 2030, 15% of total capacity will be modern kilns (zig-zag, Hofman, VSBK, tunnel kilns); the rest will be fixed-chimney bull’s trench kilns Source: World Bank analysis. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 123 Air Quality Management in the Greater Dhaka Area The socioeconomic assumptions listed above, and especially the adopted emission controls in table 6.3, imply a clear decou- pling of economic growth and PM2.5 precursor emissions, with only slight increases of PM2.5 precursor emissions from 2020 to 2030. This leads to only minor changes in population-weighted exposure to PM2.5 in the GDA with average exposure estimated to remain high at 84 µg/m³ in 2030. The source contribution to population-weighted ambient PM2.5 in 2030 is very similar to the situation in 2020. Nearly 35 µg/m3 of ambient PM2.5 is from emissions originating in the rest of Bangladesh, in other countries, and from natural sources (dust), while sources in the GDA contribute about 50 µg/m3 as depicted by the red rectangle in figure 6.8. This red rectangle refers to the sources that can be influenced by interventions within the GDA. Figure 6.8 Baseline source apportionment of ambient PM2.5 population exposure in the GDA in 2030 90 80 Other 70 Waste Agriculture 60 Road dust Mobile machinery 50 µg/m³ Road exhaust 40 Rural households Urban households 30 Brick kilns Industry 20 Power generation 10 Other countries, all sources Soil dust 0 Natural Other Rest of GDA districts All sources countries Bangladesh Source: World Bank calculations. The baseline ambient PM2.5 projection illustrates the consequences on ambient PM2.5 in the GDA of BAU from 2020 to 2030 with no additional emission control measures implemented than those presented in table 6.3. However, a wide range of policy measures is conceivable that could improve air quality. Considering the emission-control measures that are included in the GAINS model, the cost-effectiveness of technical control options that could reduce emissions and thereby lower ambient PM2.5 exposure in the GDA have been examined in this study with the GAINS-City model. This analysis does not address the potential from changes in human behavior that would affect the demand for energy services—changes such as turning up thermostats to reduce the demand for air conditioning or switching from cars to bicycles to reduce motorized mobility. 6.4.2 Cost-effective emission control measures The potential population-weighted ambient PM2.5 exposure reductions in the GDA and costs of the emission control measures from the GAINS-City model that may be implemented in the GDA are presented in table 6.4. About 90 measures emerge as potentially cost-effective means for reducing PM2.5 exposure at different costs and with different reduction potentials. These measures are clustered into 13 groups that deliver exposure reductions in the GDA by nearly 40 µg/m³ from 84 to 45 µg/m³ in 2030. The marginal cost of the measures ranges from net cost savings, or negative marginal cost of $28 million, to as high as $125 million per year per µg/m3 improvement in population-weighted ambient PM2.5. The total cost of implementing the measures is estimated at $285 million per year. The marginal costs of the measures are also presented visually in figure 6.9 as a marginal cost curve. The x-axis denotes the expo- sure-reduction potential of each measure, and the y-axis indicates the cost of the measure per unit of exposure reduction—that is, million $ per year per µg/m³ reduction in population-weighted ambient PM2.5 in the GDA. The curve starts from the right at the baseline exposure of 84 µg/m³ with the measures in increasing order from the lowest to the highest marginal cost. The blue curve represents the measures that can be implemented within the GDA. The red and green curves are discussed in section 6.4.3. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 124 Air Quality Management in the Greater Dhaka Area Some measures can improve air quality and deliver net cost savings. These measures are shown below the zero-cost line and have negative marginal costs, resulting in net cost savings to the society. The revenue from some municipal waste management options (for example, from the sale of recycled materials and landfill gas) outweighs the cost of separation, collection, and man- aged landfills of the waste. Similarly, the savings from more efficient energy use of modern brick kilns compensate for upfront in- vestments. For the GDA, this analysis reveals improved municipal waste management in urban and rural areas—that is, separation and collection of waste, centralized composting of food waste, recycling of paper and wood waste, and incineration of plastic and textile waste with heat recovery—as cost-saving options that can reduce waste burning and landfill gas emissions and contribute to improved air quality. Furthermore, complete replacement of current brick kilns with modern facilities (which is beyond what is already planned in the current legislation) will result in net cost savings, considering the savings in fuel costs. Together, these mea- sures could reduce ambient PM₂.₅ exposure in the GDA by more than 9 µg/m³ at a net saving of $132 million per year. Low-cost options include regular inspection and maintenance (I&M) of road vehicles and ban on open burning of agricultural waste albeit with relatively limited PM2.5 exposure reduction potentials; improved PM and NOx controls at power stations in the GDA with estimated exposure-reduction potential of 4.3 µg/m³; universal access to clean cooking fuels (LPG and electricity) to eliminate solid-fuel use in households with reduction potential of 9.7 µg/m³ as well as elimination of exposure to household air pollution; and road paving, street washing, and water spraying which could reduce PM2.5 exposure from road dust and construc- tion activities by about 3.8 µg/m³. However, experience in some Asian countries does not confirm the benefits of road washing for PM2.5. Together, these options could improve exposure by 19 µg/m³ at a cost of less than $6 million per µg/m³ per year with a total cost of $110 million per year. Control measures of moderate cost could reduce exposure by another nearly 10 µg/m³. These include more efficient PM controls at steel-rerolling plants and other industry PM controls, and the use of low-sulfur (0.5 percent sulfur) oil for SO2 control in power plants. The cost of these measures is estimated at $22 million per µg/m³ per year with a total cost of $212 million per year. The control measure with the highest marginal costs is PM controls from non-road mobile machinery (shipping and agriculture). This measure could reduce exposure by 0.76 µg/m3 at a cost of $95 million per year. Additional control of SO2 emissions from power plants in the GDA could reduce ambient PM2.5 by another 0.9 µg/m3 on top of the 5.7 µg/m3 reduction from the use of low sulfur (0.5 percent sulfur) oil. The cost of this additional control measure is uncertain and is therefore discussed in section 6.4.4. Table 6.4 Cost of population-weighted ambient PM2.5 exposure reduction in GDA Marginal costs Potential exposure Total costs Emission-control measures (groups) (million $ per µg/m³ reduction (µg/m³) (million $ per year) per year) Rural waste management 1.44 -28 -40 Urban waste management 5.43 -16 -89 Brick kilns: Switch to modern technologies 2.55 -1.1 -2.7 Fireworks: Ban 0.29 0.0 0.0 Regular I&M of heavy-duty vehicles 0.20 0.3 0.1 Agricultural waste burning: Ban on open burning 1.24 0.7 0.8 Powerplants: PM and NOX controls 4.40 3.9 17 Cook stoves: Switch to LPG or electric 9.66 5.1 49 Regular I&M of light-duty vehicles 0.15 6.3 1.0 Road dust: Paving and street washing 3.77 11 42 Powerplants: SO2 controls (0.5% S) 5.69 19 106 Industry: Improved PM filters 3.75 28 106 Inland shipping and agricultural machinery 0.76 125 95 Total 39.3 7.3a 285 Source: World Bank analysis. Note: a Average marginal cost of all measures BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 125 Air Quality Management in the Greater Dhaka Area Figure 6.9 Marginal cost of population-weighted ambient PM2.5 exposure reduction in GDA 120 Non-Road mobile machinery Without additional measures in other regions Powerplants – high eff SO2 controls With common measures in other BD 100 Marginal cost [millions € per year/Ɥg.m-3] With common measures in IGP Industry – PM controls 80 Powerplants – 0.5% S fuel oil Road paving and cleaning 60 I&M light duty vehicles Powerplants – PM & NOX controls 40 LPG and electric cook stoves Agr residue burning I&M light duty vehicles 20 Fireworks Brick kilns Baseline 2030 0 -20 Urban waste management Rural waste management -40 30 40 50 60 70 80 90 Population exposure [Ɥg.m-3 PM2.5] Source: World Bank analysis. The cost-effectiveness analysis presented above is restricted to the potential from technical emission-control measures that are usually discussed in air quality management. However, further air quality improvements could be achieved by additional measures that are beyond the conventional responsibilities of air quality managers. Energy-efficiency improvements and the enhanced use of cleaner fuels such as renewable energy could reduce the need for end-of-pipe emission controls. Transport policies addressing alternative options for mobility, such as public and nonmotorized transport, could alleviate the urgency of controlling vehicle emissions. Agricultural policies dealing with modern forms of agricultural practices are also important, includ- ing manure management and fertilizer use that all are important sources of PM2.5 precursor emissions. Importantly, behavioral changes can affect the demand for motorized mobility, consumption levels, cooling needs, and meat production, all with im- pacts on air pollutant emissions, air quality, and public health. Integration of air quality concerns into these sectoral policies could deliver multiple benefits on different policy priorities and reduce the cost of pollution controls compared to narrowly focused air quality policies. Thus, the cost figures derived in this analysis should be seen as conservative estimates, since they do not consider cheaper approaches that deliver benefits for multiple policy objectives. 6.4.3 Benefits from regional cooperation The measures in table 6.4 and the blue curve (GDA interventions) in figure 6.9 are not sufficient to reach WHO’s Interim Target 1 of 35 µg/m³. The target may be achieved either by increasingly expensive control measures from sources in the GDA or by emissions reductions elsewhere in Bangladesh (red curve) and the IGP airshed (green curve). The GDA is embedded in the IGP airshed and thus affected by significant transport of pollution from outside the GDA, with 40 percent of ambient PM2.5 caused by emissions originating elsewhere in Bangladesh and in other countries. Any measures within the IGP airshed will therefore reduce pollution in the GDA, and thereby help the GDA in reaching adequate air quality targets and in reducing the need for adopting the most expensive measures. Vice versa, other regions in the IGP airshed will benefit from action taken in the GDA. To explore the interdependencies of air quality management within the IGP, two scenarios are examined in which other IGP re- gions would adopt and implement a common set of emission-control measures (ref. red and green lines in figure 6.9 above and table 6.7). These sets comprise low-cost measures that emerged prominently in the World Bank Study for South Asia (World Bank 2022a), recent cost-effectiveness analyses for Uttar Pradesh and Bihar and ongoing work for GDA, Bangladesh and Eastern IPG. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 126 Air Quality Management in the Greater Dhaka Area Scenario 1 assumes that these measures will be applied in other regions in Bangladesh outside the GDA (red line). In 2030, this would reduce ambient PM2.5 in the GDA by about 7.5 µg/m³. The second scenario (green line) examines the implications for the GDA if the common set of measures were implemented throughout the IGP, particularly in Eastern IGP. This would deliver anoth- er 3.5 µg/m³ improvement in ambient PM2.5 the GDA. About half of this reduction potential is linked to emission controls in the neighboring Indian state of West Bengal. The remainder is associated with measures in the more distant Indian states of Bihar and Uttar Pradesh, for which prevailing wind patterns cause a considerable impact on air quality in the GDA. These scenarios result in a leftwards shift in the marginal cost curve for the GDA in figure 6.10. On its own, the GDA could achieve ambient PM2.5 of 45 µg/m3. With common measures implemented in the rest of Bangladesh, ambient PM2.5 could be reduced to 37.5 µg/m³, still above the WHO Interim Target 1. With common measures implemented throughout the IGP, ambient PM2.5 could decline to 34 µg/m3 and thus enable the GDA to achieve the WHO Interim Target 1 of 35 µg/m³. 6.4.4 Cost-benefit analysis of emission control measures Annual deaths from PM2.5 exposure in the GDA are estimated at 23,750 in 2019. Annual deaths rise to 27,500 in 2030 mainly due to population growth. These estimates are from exposure to both ambient PM2.5 and PM2.5 household air pollution from the use of solid fuels for cooking. They are based on population-weighted ambient PM2.5 of 84 µg/m3 in 2019, and, without comprehensive measures to control PM2.5 air pollution, 84 µg/m3 in 2030. Estimated annual deaths are 15 percent of deaths from PM2.5 in all of Bangladesh (see chapter 2 and appendix 2). This is proportional to the share of the Bangladeshi population living in the GDA. While ambient PM2.5 is substantially higher in the GDA, the share of the population using solid fuels and thus exposed household air pol- lution is substantially lower than in Bangladesh as a whole. Implementing the 13 groups of emissions control measures presented in table 6.4 is estimated to reduce population-weighted ambient PM2.5 from 84 to 45 µg/m3 (blue curve) and eliminate the use of solid fuels for cooking in the GDA. This is estimated to reduce deaths from PM2.5 exposure in the GDA by 8,500 in 2030 from 27,500 to 19,000.60 This is a 31 percent reduction in annual deaths. Reduction in illness is of similar magnitude. Further reducing population-weighted ambient PM2.5 to the WHO Interim Target 1 of 35 µg/m3 by undertaking emission control measures in other parts of Bangladesh and regionally as discussed in sec- tion 6.4.3 will reduce deaths in 2030 by an additional 4,200. The health benefits—or reduction in deaths and illness—in the GDA from reducing population-weighted ambient PM2.5 from 84 to 45 µg/m3 are valued at $35.87 billion over a period of 20 years from the time of implementation of the control measures. This is estimated by applying the methodologies in appendixes H and I. The cost of the control measures over the same time period is $3.56 billion. This gives a benefit-cost ratio (BCR) of 10.1 for the set of emission control measures in table 6.4. A provisional estimate of the impacts of measures taken in the GDA on population exposure in areas outside the GDA—that is, in the rest of Bangladesh and in neighboring countries has been derived with the GAINS model. For the measures listed in table 6.4, 58 percent of the overall reduction in population exposure occurs outside the GDA—that is, improvements in cumulative population exposure in downwind areas account for 138 percent of the improvement within GDA. This means that total exposure reductions throughout the IGP from measures taken in GDA are 2.4 times higher than the local benefits occurring within GDA. This is caused by the residence time of PM₂.₅ in the atmosphere of about one week, during which GDA emissions move over typically 1,000 kilometers given an average wind speed of about 1.7 meter per second. On average, only the first 50 kilometers of this distance occur over GDA while the remaining distance affects other areas in Bangladesh and in neighboring countries. Thus, the BCR of the control measures taken within the GDA is 24.0 when accounting for the total benefits throughout the IGP airshed (table 6.5). Table 6.5 Benefits and costs of PM2.5 control In other areas in the IGP Total throughout the In the GDA airshed IGP airshed Health benefits ($, billions) 35.87 51.9 85.42 Costs ($, billions) 3.56 n.a. 3.56 Benefit-cost ratio (BCR) 10.1 n.a. 24.0 Source: World Bank analysis. Note: n.a. = Not applicable. Benefits and costs are for a period of 20 years. Future benefits and costs are discounted at an annual rate of 5 percent. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 127 Air Quality Management in the Greater Dhaka Area For the nine groups of control measures with costs greater than zero the BCRs range from 0.55 to 231 when only accounting for benefits within the GDA and from 1.32 to 549 when accounting for the benefits throughout the IGP (figure 6.10). The assessment indicates that the benefits of PM2.5 control measures for inland shipping and agricultural machinery are just about half of the cost if only benefits within the GDA are accounted for but are 1.3 times the cost if benefits throughout the IGP are included. However, further analysis is required to determine how much of the benefits throughout the IGP accrue to Bangladesh and may show that the BCR for Bangladesh is less than one. Not implementing this measure is estimated to still bring ambient population-weighted PM2.5 in the GDA to below the WHO Interim Target 1 of 35 µg/m3. Figure 6.10 Benefit-cost ratios of PM2.5 control measures in the GDA Source: World Bank estimates. Control measures addressing emissions in the GDA from cooking with solid fuels; solid waste; and power plants account for as much as 26.6 µg/m3 or 68 percent of the total population-weighted ambient PM2.5 reduction potential. These control measures provide either net savings or BCRs of 3.7–18 when only accounting for benefits within the GDA and of 8.8–42 when accounting for benefits within the entire IGP. The largest ambient PM2.5 reduction potential in the GDA is from power plants. The reduction potential is estimated based on standard emission coefficients for primary PM2.5 and NOx and SO2 emissions from the burning of high sulfur fuel oil with 3.0–3.5 percent sulfur content (percent S). The control measure in table 6.4 and figure 6.10 for reducing SO2 emissions is switching to fuel oil with 0.5 percent sulfur (0.5 percent S). This removes around 85 percent of SO2 emissions. The GAINS model estimates that this can reduce population-weighted ambient PM2.5 by 5.69 µg/m3 in the GDA at cost of $106 million per year, as lower sulfur fuel is generally more expensive than higher sulfur fuel. The estimated annual cost is based on an incremental cost of $125 per ton of fuel oil and reflects fuel oil price differentials observed in the global markets in 2023.61 The BCR at this incremental fuel cost is 3.7–8.8. However, the incremental fuel cost fluctuates with global supply and demand. Especially, the recent introduction of the global 0.5 percent sulfur standard for international shipping imposed by the MARPOL Convention of the International Maritime Organization (IMO) caused rather high price variability, which however is expected to stabilize after 2025. Further SO2 emissions reductions can be achieved by switching to 0.1 percent S rather than to 0.5 percent S fuel. The GAINS model estimates that this can reduce population-weighted ambient PM2.5 by another 0.88 µg/ m3 in the GDA. The cost of this measure is, however, highly uncertain. As of mid-September 2023, the incremental cost of 0.1 percent S fuel versus 0.5 percent S fuel was around $300 per ton of fuel.62 However, an international study assessing the economic consequences of the introduc- tion of the recent IMO fuel quality standards projects that the incremental cost of 0.1 percent S versus 0.5 percent S fuel may settle at somewhat above $40 per ton of fuel (Cofala et al. 2018). The BCR for this range of incremental fuel cost is 0.22–1.69 if accounting for benefits only within the GDA and 0.54–4.02 if accounting for benefits in the entire IGP (table 6.6). The break-even incremental fuel cost (that is, BCR=1.0) is $68 per ton for benefits in the GDA only, and $160 per ton for benefits in the entire IGP. This means that switching to 0.1 percent S fuel instead of 0.5 percent S fuel in the GDA power plants will only provide Bangla- BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 128 Air Quality Management in the Greater Dhaka Area desh positive net benefits if the cost differential declines from its current $300 to somewhere in the range of $68–160 per ton. Precisely where in this range depends on how much of the benefits in the entire IGP is within the borders of Bangladesh. This requires further analysis to answer. An alternative option to low sulfur fuel at the GDA power stations is flue gas desulfurization (FGD). The cost-effectiveness and viability of this option requires an assessment of the specific technology of each power station (large stationary engines), the ex- pected remaining life times of the stations, operating regimes (base load or peak power), availability and costs of large quantities of limestone in GDA, transportation infrastructure, options and costs for disposal or re-use of by-products, and so forth. Table 6.6 Cost-benefit analysis of 0.1 percent sulfur fuel in oil-fired power plants in the GDA Low cost High cost Initial fuel oil (% S) 0.5% 0.5% Control measure: Lower sulfur fuel (% S) 0.1% 0.1% Incremental cost of fuel ($/ton) a 40 300 Total incremental cost ($, millions per year) 36 270 Reduction in ambient PM2.5 (µg/m ) 3 0.88 0.88 Health benefits in GDA per µg/m ($, millions per year) 3 69 69 Health benefits in GDA ($, millions per year) 61 61 Benefit-cost ratio (BCR) within GDA 1.69 0.22 Total benefit-cost ratio (BCR) in the IGP airshed 4.02 0.54 Source: World Bank analysis. Note: a Low cost is from from Cofala et al. (2018), and high cost is from https://shipandbunker.com. 6.4.5 Uncertainties The accuracy of the emission estimates presented in this chapter is hampered by important gaps in critical data found to be essential for developing robust emission inventories in other countries. These include the paucity of geo-referenced statistics on the current levels of socioeconomic activities (for example, population counts, transport volumes, industrial and agricultural pro- duction, and waste-management practices). Some of the available data date back 10 years or more and do not provide a reliable picture of the current situation given the dynamic economic, social, and technological trends in the rapidly urbanizing region. Moreover, given the divergence of available emission estimates for brick kilns, it would be important to revisit data on locations, technologies, and production volumes of brick kilns, which should capture all kilns as well as the ongoing restructuring process of the industry over time. Some of the key results from the source apportionment analysis reveal important new insights that might differ from long-held beliefs (for example, about the relative importance of some emission-source categories). Further validations of model outcomes could therefore increase trust in the results and thereby strengthen the basis for knowledge-based air quality management in the GDA. Although the number of air quality monitoring sites has increased in the recent past, there is still little information about PM2.5 levels outside the Dhaka city limits. Furthermore, temporal gaps in monitoring data make it difficult to establish reliable annual mean concentrations for many monitoring stations. In addition, there are no data available about the chemical com- position of PM2.5 and its seasonal patterns. Such information, which is now being collected in other South Asia countries, would be extremely valuable for comparisons with model results computed for the different chemical species. Most importantly, such chemically speciated monitoring data would also enable alternative source-apportionment methods such as the positive matrix factorization (PMF) method (USEPA 2014). Outcomes could then be compared with model results. While the results obtained from this first assessment of cost-effective measures to improve air quality in the GDA reveal the most important options for air quality improvements and the order of magnitudes of their potential air quality improvements in the GDA, a refined analysis will require improved input data. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 129 Air Quality Management in the Greater Dhaka Area 6.5 Priority measures for cost-effective improvement of air quality in GDA There is no single measure available in the GDA that alone could deliver clean air. A comprehensive AQM strategy therefore needs to develop an appropriate portfolio of measures that (a) delivers sufficient air quality improvements (for example, brings PM2.5 exposure below a certain target such as the WHO Interim Target 1 of 35 µg/m³); and (b) is economically, socially, administra- tively, and politically acceptable. The available measures vary not only in their exposure-reduction potentials but also in their im- plementation costs to the entire economy, welfare costs to the society (considering the benefits of clean air), and financial costs to the economic sectors that would have to implement these measures. Measures will have different impacts on the net burden to the government’s budget imposed by transfer payments such as investment and fuel subsidies. Furthermore, measures will differ in their ease of implementation and enforcement. The cost-effectiveness analysis in this report focuses on the measures’ economic costs and emission-reduction potentials, considering measures with a sizable potential for air quality improvements and low economic costs. The following six source sectors emerge as priorities for emission controls mainly due to their large emission-reduction potential: • Power generation contributed about 11.5 µg/m³ to total ambient PM2.5 population exposure to in the GDA in 2020. Tight PM, NOx, and SO2 controls could reduce that by up to 11 µg/m³ in 2030. In 2019–2020, 37 percent (2,276 MW) of all powerplants in the GDA were operating with large stationary engines with heavy fuel oil—that is, Kodda, Gazipur, Madanganj, Meghnaghat, Nababganj, Siddhirganj, and Kanchan Purbachal, as well as Ghorasal (the latter also with natural gas)—with a sulfur content between 3.0 and 3.5 percent. Heavy fuel oil accounted for about 27 percent of total fuel consumption in the GDA power- plants. In addition, 500 MW (Keranigonj, Bramhangoan, and Aurahati) were fueled with high density diesel (0.5 percent sulfur). These plants caused about two thirds of all SO2 emissions in the GDA. Several options are available to reduce these emissions. Use of low sulfur fuel oil, FGD or switching to natural gas could reduce ambient PM2.5 exposure by up to 6.6 µg/ m³ in 2030. Beyond the emission standards for power plants that have been established by the government in 2022, further tightening of requirements, especially for NOx and PM (equivalent to Stage IIIB standards of the European Union) turn out as a cost-effective way forward for additional ambient PM2.5 air quality improvements in the GDA of up to 4.4 µg/m³. • Households cooking with solid fuels in the GDA is a major source of ambient PM2.5 exposure. In addition, indoor exposure to PM2.5 and gaseous emissions from solid fuels causes serious health impacts, especially in women and children. In 2020, an es- timated 50 percent of rural and 5 percent of urban households in the GDA used solid biomass (wood/chalk/chopped wood, straw/leaves/bran/husk. charcoal/dried dung) as cooking fuel. With household cooking fuel consumption derived from the Bangladesh Demographic and Health Survey 2017–2018 (NIPORT and ICF 2020), emission factors from the scientific literature on studies performed in South Asia, and the GAINS atmospheric dispersion calculations it is estimated that solid fuel used by GDA households accounted for more than 12 µg/m³ of population exposure to PM2.5 in 2020. For 2030, it is assumed as a baseline that without further policy interventions the number of households using solid fuel would remain at the current levels, while the share declines somewhat due to population growth and continuing urbaniza- tion. Providing universal access to clean cooking fuels—that is, to electricity (for example, induction stoves), natural gas, LPG, solar power, or combinations of these—would reduce PM2.5 exposure in GDA by nearly 10 µg/m³ and eliminate the serious health impacts of indoor pollution from solid fuel use in households. In contrast, the replacement of traditional biomass cookstoves with improved cookstoves delivers far from optimal exposure reductions at higher costs. Thus, more would be required to achieve full exposure reductions than the current plans of the government to install improved cookstoves in 30 million households by 2030. • Management of municipal solid waste. In 2020, managed and unmanaged centralized and decentralized burning of mu- nicipal solid waste in urban and rural areas in the GDA contributed about 7.5 µg/m³ to ambient PM2.5 population exposure. Considering a further increase in the volume of municipal waste and the likely impacts of the 2021 solid waste management rules, measures that eliminate the open burning of solid waste could reduce PM2.5 exposure in the GDA by up to 4.5 µg/m³ in 2030. Such measures must address the whole waste chains in urban and rural areas, from waste separation at the source, separate collection, recycling, and managed centralized disposal with the remaining fraction with collection and re-use of landfill gas. In particular, centralized composting of food and biodegradable waste as well as the recycling of plastic, paper, textile, and glass appear as a very cost-effective options. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 130 Air Quality Management in the Greater Dhaka Area • Enhanced PM controls at large industrial sources (for example, steel rerolling) could yield up to 3.8 µg/m³ exposure reduc- tion. More efficient PM filters, such as high-efficiency de-dusters and electrostatic precipitators with three fields applied to large industrial sources, emerge as a cost-effective option. • Reduction of road and construction dust has a sizeable exposure-reduction potential of 3.7 µg/m³. Water spraying at con- struction sites has been proven as an effective means. Lowering road dust (for example, through further road paving) is a more complex issue, and especially road cleaning (washing and sweeping), while showing positive results on the visible coarse fraction of particulate matter, has shown mixed results in other Asian countries with little impact on the fine fraction— that is, PM2.5. • Modern brick kilns, such as Hoffman and tunnel kilns, with the complete replacement of traditional brick kilns could deliver PM2.5 exposure reductions of up to 2.6 µg/m³. The government has recognized the importance of this source category and issued several road maps and regulations, which will show a positive impact in the future. However, ensuring the full adoption of modern technologies will be important. Other options each offer smaller exposure reductions below 0.5 µg/m³. Some of them are available at negative costs, where their upfront investments are compensated for by subsequent cost savings or revenues from the sale of by-products (for example, the collection and recycling of paper, textile, and plastic waste). Other options come at high economic costs, such as stricter emission standards for agricultural machinery and shipping. For some sectors, the government has already issued regulations on emission standards which will show some effect in the future. However, the current regulations must be revised in most cases to achieve fundamental air quality improvements in the GDA. 6.5.1 The need for airshed-wide AQM Primary and secondary PM2.5 emissions from within each district in the GDA contribute only between 13 and 32 percent to total exposure in the GDA, so unilateral action of a GDA district can deliver only limited air quality improvements. However, 65 percent of ambient PM2.5 exposure originates from emissions within the GDA. Thus, the measures emerging from this cost-effectiveness analysis must be implemented throughout all five GDA districts. The impacts of the various measures will differ due to differ- ences in the emission-source structures across the five districts. For instance, universal access to clean cooking fuels will be more important in rural areas while, for example, reduction of road and construction dust is more critical in Dhaka city. At the same time, 35 percent of ambient PM2.5 in the GDA originates from sources outside the region. Thus, emission-control measures that could be taken within the GDA will not be sufficient to reach the WHO Interim Target 1 for PM2.5 of 35 µg/m³. Co- operation with other districts in Bangladesh and regions in the IGP in other countries is indispensable for achieving substantial air quality improvements in the GDA. At the same time, regionally harmonized strategies could alleviate the need to take the GDA’s most expensive measures. Particularly important at regional IGP scale is the control of SPM, including agricultural sources (balanced fertilizer application and manure management). Such sources must be addressed to control formation of secondary PM2.5, that is mostly NH3 emissions from imbalanced fertilizer use and livestock manure sources from outside GDA that reacts with SO2 and NO2 sources within GDA (power plants, industry, and transport), that is included in the list above. The GDA’s dependency on measures taken in areas surrounding GDA has also major implications on the perspective of how benefits from measures within GDA are seen. As revealed in section 6.4, about 58 percent of the total benefits of measures taken within GDA occur in downwind areas outside GDA—that is, in other regions of Bangladesh and in neighboring countries. Thus, a GDA-centric perspective that considers only local benefits suggests lower benefit-cost ratios than if the full benefits to the IGP airshed are included. Recognition of the full benefits of emission controls throughout the entire airshed is therefore an essential prerequisite for any common and coordinated air quality approach to air quality management across the IGP airshed can deliver substantial economic cost savings to GDA. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 131 Air Quality Management in the Greater Dhaka Area 6.6 A way forward As discussed in the chapter 3, Bangladesh has gradually enhanced its legal and institutional framework for AQM. Building on the Environment Conservation Act 1995, the Air Pollution Control Rules (APCR) 2022 sets national air quality standards based on WHO Guidelines Interim Goals, including a standard of 35 µg/m3 for annual average of PM2.5, and emissions limits and technical specifications for key sectors and industrial activities (for example, transport, power plants, brick kilns, construction work, incin- eration of municipal waste, cement, steel, textile, fertilizer, and pesticides manufacturing). The Rules expanded the coordination mechanisms and AQM leadership beyond the environment sector, by establishing the National Committee on Air Pollution Con- trol (NCAPC). As a multi-sector decision-making body presided by the Cabinet Secretary, the NCAPC will coordinate the APCR implementation and instruct relevant agencies on specific interventions to comply with the new rules, including emergency measures depending on the levels of air pollution. To fully implement the APCR, the Government of Bangladesh (GoB) must develop a National Air Quality Management Plan (NAQMP), a Heavy Air Pollution Contingency Plan, and detailed guide- lines and procedures for declaring air quality degradation of airsheds and developing management plans, publishing a list of highly air-polluting industries and activities, preparing prevention plans, and deploying monitoring and control systems. Other relevant regulations for AQM include the Brick Manufacturing and Brick Kilns Establishment Act 2013 (amended in 2019) and the Energy Efficiency and Conservation Rules 2016 (amended in 2023). Despite the improvement in the AQM framework, Bangladesh’s environmental management system remains focused on the environmental clearance process and based on command-and-control interventions. As recommended in chapters 3 and 10, the Government should (a) expand the range of policy instruments (for example, to market-based instruments that incentivize compliance of private sector with emissions standards), and (b) invest heavily in capacity building of environmental agencies and relevant units in line ministries, from developing specific technical guidelines, to staff training and automated monitoring systems. These measures would contribute to make both enforcement and abatement measures more efficient and effective. Additional analytical work is needed to ensure that future policies are based on reliable data. For that, the DoE needs to expand its air monitoring framework, and continue developing evidence through emissions inventories, chemical composition and source apportionment studies, and emission projections. The Government plans to compile all these measures in the NAQMP. The latter will set forth coordinated multi-sector actions to reach WHO PM2.5 interim targets by 2030. With the support of the World Bank, the DoE is designing the NAQMP to cover (a) in- terventions to improve overall AQM, air quality monitoring, establishment and maintenance of a national emission inventory, and the carrying out of source-apportionment studies; (b) cost-effective interventions (including policies and investments identified in the chapter) and time-bound targets in multiple sectors to control outdoor and indoor air pollution; and (c) mandates and responsibilities for implementation, and mechanisms for continuous stakeholder consultations and monitoring and evaluation. Additionally, MoEFCC plans to establish a Monitoring, Reporting, and Verification (MRV) framework to allow for reporting of emis- sions or emissions savings of short-lived climate pollutants (SLCPs; especially black carbon and methane). Through the Bangladesh Environmental Sustainability and Transformation (BEST) Project, under implementation, the GoB is expected to (a) improve environmental-management capacity through regulatory and institutional reforms; enhance the regu- latory capacity of the MoEFCC and the DoE; deploy advanced environmental monitoring, analytical, and information technology (IT) infrastructure; and (b) explore new green financing mechanisms and public-private partnership arrangements to promote private-sector participation in green investments over the long run. In parallel, the GoB has requested World Bank support for a new air quality operation, as part of the upcoming Regional Air Quality Program for the Indo-Gangetic Plain and Himalayan Foothills (IGP-HF) countries (Bangladesh, India, Nepal, Pakistan, and most likely Bhutan). (For related information, see table 6.7.) As seen above, GDA and Bangladesh can only achieve its own air quality standard for PM2.5 of 35 µg/m3 by ensuring positive spillovers from air quality improvements in neighboring countries. Regional outputs under this engagement could further benefit and support Bangladesh’s progress toward its AQM goals. This regional activity could result in additional financing to (a) establish the national emissions inventory and source-apportionment studies; (b) implement the MRV system for tracking SLCPs; (c) enhance AQM capacity in key sectors through technical specifica- tions for controlling emissions, standard procedures for line agencies, training, and awareness campaigns; and (d) design policy instruments (for example, fiscal incentives for green technology). Additionally, the potential operation would finance abatement interventions in targeted sectors, such as energy, agriculture, brick kilns, and transport (to be selected during project preparation). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 132 Air Quality Management in the Greater Dhaka Area Table 6.7 Common set of air pollution control measures assumed in the cooperative scenarios for the other IGP regions Mobile sources: • Effective inspection and maintenance for heavy-duty and light-duty road vehicles • Street paving and washing Power generation: • Stationary generators: Stage 3B controls Households: • Universal access to clean household fuels for cooking (LPG/electricity) to replace biomass fuels (fuelwood, dung) • Residential kerosene lamps: Switch to LPG or LEDs • Diesel generators: Stage 3B controls • Filters for restaurant kitchens • Electric cremation • Ban on fireworks • PM controls of commercial heating boilers • New/improved heating stoves burning solid fuels in households Industry: • Brick production: Zigzag kilns (55% of production capacity) and vertical shaft brick kilns (VSBK) with basic dust control (40% of production capacity) • Electrostatic precipitators at large industrial sources • Basic NOX controls for industrial boilers • Electrostatic precipitators at industrial furnaces • High-efficiency de-dusters (3-fields) in aluminum production • Flue gas desulfurization of large industrial boilers and furnaces • Basic SO2 controls (-50%) at cement, aluminum, steel plants, and refineries Agriculture: • Efficient urea fertilizer use • Stop open burning of agricultural residue Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 133 Air Quality Management in the Greater Dhaka Area C6 References / Endnotes Amann, M., I. Bertok, J. Borken-Kleefeld, J. Cofala, C. Heyes, L. Höglund-Isaksson, Z. Klimont, B. Nguyen, M. Posch, P. Rafaj, R. Sandler, W. Schöpp, F. Wagner, and W.  Winiwarter. 2011. “Cost-Effective Control of Air Quality and Greenhouse Gases in Europe: Modeling and Policy Applications.” Environmental Modelling & Software 26 (12): 1489–501. https://doi.org/10.1016/j.envsoft.2011.07.012. Cofala, J., M. Amann, J. Borken-Kleefeld, A. Gomez-Sanabria, C. Heyes, G. Kiesewetter, R. Sander, W. Schoepp, M. Holland, H. Fagerli, and A. Nyiri. 2018. “The Potential for Cost-Effective Air Emission Reductions from International Shipping through Designation of Further Emission Control Areas in EU Waters with Focus on the Mediterranean Sea.” International Institute for Applied Systems Analysis (IIASA). IIT (Indian Institute of Technology Delhi), and IIASA (International Institute for Applied Systems Analysis). 2023. “Establishment and Application of an Air Quality Management Model for the Indo-Gangetic Plain (IGP-AQM MOD).” Delhi, India: IIT. NIPORT (National Institute of Population Research and Training), and ICF (IFC International Inc.) 2020. Bangladesh Demographic and Health Survey 2017–18. Dhaka, Bangladesh, and Rockville, MD: NIPORT and ICF International Inc. Raza, Wameq Azfar, Iffat Mahmud, and Tamer Samah Rabie. 2022. “Breathing Heavy: New Evidence on Air Pollution and Health in Bangladesh.” International Development in Focus. Washington, DC: World Bank. doi:10.1596/978-1-4648-1919-3. License: Creative Commons Attribution CC BY 3.0 IGO. Reis, S., P. Grennfelt, Z. Klimont, M. Amann, H. Apsimon, J.-P. Hettelingh, M. Holland, A.-C. LeGall, R. Maas, M. Posch, T. Spranger, M. A. Sutton, and M. Williams. 2012. “From Acid Rain to Climate Change.” Science 338 (6111): 1153–54. https://doi.org/10.1126/science.1226514. USEPA (US Environmental Protection Agency). 2014. “EPA Positive Matrix Factorization (PMF) 5.0 Fundamentals and User Guide.” EPA/600/R-14/108. US Environmental Protection Agency. WHO (World Health Organization). 2021. “WHO Global Air Quality Guidelines.” Geneva, Switzerland: WHO. World Bank. 2021. “Clean Air and Cool Planet: Cost-Effective Air Quality Management in Kazakhstan and Its Impact on Greenhouse Gas Emissions.” Washington, DC: World Bank. http://hdl.handle.net/10986/36791. World Bank. 2022a. “Striving for Clean Air: Air Pollution and Public Health in South Asia.” Creative Commons Attribution CC BY 3.0 IGO. Washington, DC: World Bank. https://documents1.worldbank.org/curated/en/099030312132233780/pdf/P1682370b4ac4a0270ac2702e1cfb704198.pdf. World Bank. 2022b. “Bangladesh Country Climate and Development Report.” Washington, DC: World Bank Group. https://openknowledge.worldbank.org/server/ api/core/bitstreams/6d66e133-e49d-5ad9-b056-7b1a6c6206ed/content Endnotes 60 This is a 31 percent reduction in annual deaths and is less than the 47 percent reduction in ambient PM2.5 exposure because of the concavity of the integrated exposure-response (IER) health risk functions (see appendix B). 61 See fuel oil price data at https://shipandbunker.com for VLSFO (maximum of 0.5% S) versus IFO380 (maximum of 3.5% S). 62 See fuel oil price data at https://shipandbunker.com for LSMGO distillate (maximum of 0.1% S) versus VLSFO (maximum of 0.5% S). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 134 CGE Analysis of Green Policies in Bangladesh CHAPTER 7. CGE ANALYSIS OF GREEN POLICIES IN BANGLADESH 7.1 Introduction Shifting Bangladesh’s development model towards green growth requires environmental health and pollution management policies that are economic, social, and environmentally sustainable. In parallel, channeling financing and policy reforms to green growth can create a multiplier effect: reviving the economy, investing in projects to help Bangladesh prepare for the impending challenges of climate change while creating jobs, promoting low-carbon infrastructure, and building a more equitable society. This chapter analyzes the economic impact of alternative policies in Bangladesh for the pursuit of green growth objectives such as improved environmental quality and comprehensive human and social development. For the experiments, the policies were broadly based on fiscal interventions (taxes and subsidies), carbon market arrangements (carbon offsets) and public investment. The interventions were selected because of their potential to reduce air pollution and inadequate water supply, hygiene, and sanitation (WASH), two of Bangladesh’s environmental priorities and foundational steps towards green growth. 7.2 Methodology To address the challenge of investigating their possible direct and indirect impact on a variety of stakeholders, the study adopts a methodology based on the estimation and use of a computable general equilibrium (CGE) model. This model, the World Bank CGE Bangladesh Bioeconomic 101 (BB101), includes several innovative features for policy analysis, such as regionalized natural and human capital accounts, and heterogeneous agents’ behavior. It is based on a detailed estimation of a regionalized, environ- mental-extended social accounting matrix. Its solutions are used to produce impact estimates of the “as if” variety, that may give insights into the possible outcomes of the policy measures considered and their broad impact on Bangladesh economic, social, and biophysical environment. While estimates of parameters and exogenous variables are used to construct the model and its experiments, model simulations produce forecasts of the impact of the policies analyzed conditional to the estimates of the parameters and the exogenous variables used. Following the pattern of causal analysis, BB101 is not designed to predict actual values of endogenous variables. The model is developed “to systematically explore possible counterfactual scenarios, grounded in thought experiments—what might happen if determinants of outcomes are changed,” and forecast “the impacts of interven- tions (constructing counterfactual states associated with interventions) never previously implemented to various environments, including their impacts in terms of well-being” (Heckman and Pinto 2022, pp.3 and 11). The main advantages of these typologies of CGE model with respect to alternative analytical tools, such as econometric studies or statistical impact analysis, are their sound economic basis and their flexibility to incorporate changes in parameters and en- dogenous variables. Further advantages include the ability to (a) estimate shadow prices that better reflect true (social) values of market and non-market services; (b) develop full value-added accounts including natural resources; (c) estimate net benefits of alternative policy decisions on the use of natural capital, relative to a counterfactual; and (d) model the economy-wide effects of sudden shocks (for example, climate disasters) that destroy natural and produced capital. The wide use of CGE and associated Social Accounting Matrix (SAM) for a variety of country analyses and specifications (Perali and Scandizzo 2021; Scandizzo and Ferrarese 2015) also makes it possible to carry out intercountry comparisons and useful benchmarking exercises. The BB101 model is based on an extended SAM that comprises the following regional disaggregation: • Central region, which corresponds to the Dhaka division. This region is characterized by the most urbanized and industrial- ized areas of the country. According to the plan the main policy actions in this region will be enhancing water security and water use efficiency and regulating and monitoring industrial and water pollution. • South region, which includes the coastal zones characterized by floods and pressure on drainage capacity of coastal delta (Barishal, Chattogram and Khulna districts, Chattogram hills tracts, and part of the river system and estuaries). • North region, which corresponds to the rest of the country (basically the northern divisions of Rangpur, Rajshashi, Maimans- ingh, and Sylhet). This region includes the Barind and drought prone areas, characterized by drought and freshwater availabil- ity, and Haor and Flash Flood areas characterized by food insecurity due to longer period of annual flooding (eventually the region could be further divided according to these two hotspots). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 135 CGE Analysis of Green Policies in Bangladesh The BB101 model has been built as the final step of an integrated system of sequential modules that proceeds from the construc- tion of a database with all data needed (economic, social, and biophysical) to construct an environmentally extended SAM and CGE, and to a gradual buildup of various interdependent blocks. The first stage of the sequence consists in compiling the data- base from national accounts, economic and social statistics, and previous estimates of SAM and CGEs for Bangladesh. The second stage is the construction of the biophysical model to estimate and predict the levels of biological and physical factors driving the key processes studied in the economic model. In a third stage, this model is integrated into a system of bridge matrices (BMA) that are capable of transforming biophysical estimates directly and interactively into parameters of an underlying SAM and of a corresponding CGE. The BMAs include the data sets by year and geographic location of each variable (for example,, agricultural yields and prices, forest fires, health damages and so forth) and the functions mapping them into estimates of SAM coefficients and/or model parameters. 7.2.1 Model simulations and their characteristics The simulations performed with the model are comparative static experiments, where the CGE module produces a new general equilibrium solution after the equilibrium of a reference scenario has been perturbed by an exogenous shock. The new equi- librium yields endogenous quantities and prices for all domestic variables and endogenous levels of exports and imports for all traded variables for a projected scenario over ten years (in order to stress the fact that the simulation is not a forecast, the year of projection is indicated with T+ 10 where T is 2017 as the base year). Both the reference scenario (BAU) and the policy scenarios are obtained by solving the model under appropriate hypotheses on investment, export demand, international prices, and other exogenous variables. Consistency with World Bank macroeconomic projections across parameters overtime is achieved through model calibration within the chosen time horizon of ten years. Basically, two types of experiments can be performed to (a) run the model for the base year under different assumptions on parameters and exogenous variables; and (b) project the base year to a given time horizon (for example, T+10) to obtain a refer- ence solution (indicated as business as usual or BAU) to compare with the results of perturbing it with exogenous shocks. The first type of experiment essentially validates the model against the historical record and tests its performance with respect to different parameters and assumptions. It also establishes a benchmark against which changes can be evaluated. The second set of experiments enables the model to address more directly the impact of different policy instruments, by computing the quantity and price adjustments necessary to reconstitute the balance between demand and supply computed for the year of model calibration (the base year), disturbed by the exogenous shocks and compare these results with a reference solution. This solution in turn is obtained by constructing a counterfactual scenario of business-as-usual equilibrium, consistent with the World Bank macroeconomic model projections, for the same time horizon. Within this dual framework, in addition to model validation using the data base assembled, the calibration runs for the base year (2017), and the simulations to obtain the reference scenario, five sets of experiments were attempted and are reported below63: These experiments can be briefly described as follows: (a) the removal of energy subsidies; (b) the imposition of carbon taxes (c) different redistribution policies associated to government revenues generated by (a) and (b) policies; (d) the financing and implementation of two investment programs; (e) alternative combinations of the different measures in (a) through (d). 7.3 Model experiments of energy-subsidy removal 7.3.1 Main results Basic economic theory suggests, and several recent studies have demonstrated that energy subsidies are harmful for economic development for two distinct reasons: (a) they reduce economic efficiency by determining a gap between private and social costs, and (b) they are inequitable because they are largely absorbed by richer consumers with an important share of the pop- ulation still lacking access to modern energy services.64 Economic efficiency is mainly reduced by price distortions and longer term unsustainable fiscal burdens. By fueling energy overconsumption, energy subsidies may also tend to aggravate a series of harmful externalities produced by anthropogenic interaction with the environment and sabotage the efforts to reduce air pollu- tion, greenhouse gas (GHG) emissions and mitigate climate change. To understand the subsidy mechanism in Bangladesh, consider that for electricity, the consumer price is set at a level below its long-run marginal cost of production and this gap is closed by a government direct budget subsidy to the Bangladesh Power Development Board (BPDB), which is responsible for supplying electricity in the country. This subsidy to the BPDB was almost BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 136 CGE Analysis of Green Policies in Bangladesh $1,200 million in 2015 (Sadeque and Bankuti 2017). A subsidy is also indirectly paid to gas and electricity, which is a primary user of gas for energy production, by setting the price of gas at a level below its opportunity cost, which according to ADB (2013) is one of the lowest in the world (In 2015, the average price of domestically produced natural gas in Bangladesh was $2.61/GJ). Because of the connection between the gas and the electricity prices, we examine the removal of the subsidies under the two alternative hypotheses that subsidies are phased out on both gas and electricity and the ensuing savings are (a) redistributed as lump sum payments to all households, or (b) redistributed as lump sum payments only to those below the poverty line.65 Three experiments were conducted on the removal of the subsidies. In the first experiment, the savings from the removal are not reinjected into the economy and thus increase the government fiscal balance. In the second experiment, the savings are re- distributed through lump sum subsidies to the general population, while in the third the redistribution is only performed toward the people below the poverty line. In all cases, the subsidies removed include the subsidies explicitly given to reduce retail prices of electricity and those resulting from trade policies and translate into prices lower than opportunity costs for the electricity and gas consumers. As table 7.1 shows, the removal of the subsidies leads to an increase in GDP at shadow prices in the scenario without the redis- tribution, mainly due to the increased efficiency in resource allocation66. These efficiency gains are estimated by comparing the GDP results of the scenario where the subsidies are removed, but not redistributed, with a BAU scenario at shadow prices—that is, at the prices prevailing after the removal and thus not distorted by the subsidies). However, a negative demand effect arises from subsidy removal under the assumption that the resources saved from discontinuing the subsidy are not being reinjected into the economy (the no redistribution scenario). Table 7.1 Impact of the removal of energy subsidies on efficiency (cumulative Impact over 10 years) | $, billions Subsidy removal (C) BAU scenario (A) (T + 10) BAU scenario (B) (T + 10) C-A C-B (T + 10)   At market prices (assuming At shadow (second best) prices       a 6.5% annual growth rate) Value added 2,665 2,585 2,572 -93 -13 Net indirect taxes 158 158 214 56 56 GDP 2,823 2,743 2,786 -37 43 Source: World Bank. Note: GDP base year is 2017. Tables 7.2 and 7.3 show the main results of the experiments in terms of values and physical indicators. In both redistribution ex- periments GDP increases compared to the BAU reference case, with the larger increase resulting for the case where all subsidy proceeds are redistributed to the poor.67 All externalities68 are also reduced and positive net social benefits (GDP minus value of externalities) prevail for both redistribution scenarios and are highest for the case of redistribution to the poor. For the exter- nalities, the scenario with redistribution to the poor presents a lower environmental performance, with a smaller reduction of harmful externalities than the other scenario. The impact on GDP is larger in the case of transfer to poor households because it translates into greater total expenditure, due to the higher propensity to consume of poorer households and lower price elasticities for basic goods. On the one hand, the in- crease in GDP is obtained by increasing output in less energy intensive sectors (especially services) and reducing output in more energy intensive sectors (electricity and transport services). On the other hand, the composition of production determined by the consumption increases of poorer households is more energy and water intensive—see, for example, the data in Barnes et al. (2011); this is especially so in the South and Dhaka. These differences translate also into a lower reduction of harmful externalities, and more frequent and greater price increases in the case of redistribution to the poor. In both simulations, the removal of energy subsidies results in a significant surge in energy prices, with electricity costs, for instance, experiencing a notable 54 percent increase. This price hike leads to a reduction in con- sumer demand for energy, which subsequently affects energy production and distribution, facilitated by utilities. This ripple effect reverberates throughout the value chains, causing energy-intensive sectors across the economy to contract. Since the most energy-intensive industries are also the most polluting, this overall contraction results in a net decrease in emis- sion levels. Not only do electricity prices grow more under this redistribution assumption, but so do also the prices of items BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 137 CGE Analysis of Green Policies in Bangladesh such as textiles, transport, and construction, especially in the North, with a corresponding decline in production of energy and energy intensive activities. On the other hand, the transfer to the poor policy appears to cause a greater reduction in the growth of energy intensive activities, along with a surge in production of many agricultural and service sectors, including education, public administration, health, and community services. Overall, the price impact in the transfer to the poor scenario appears to be either neutral or favorable for consumers, with the consumer price index unchanging (with respect to BAU) in the North and decreasing in Dhaka and the South.69 Table 7.2 Impact of Subsidy Removal (higher or lower annual increases than the BAU from the baseline) Energy subsidy with general Energy subsidy with   redistribution redistribution to the poor (%) (%) Total GDP 2.40 4.34 Total value of external damages -12.36 -8.10 Carbon emission -3.47 -1.38 Mortality and morbidity due to inadequate WASH and to air pollution -14.48 -9.70 Forest losses and sector damages -1.14 -0.30 Source: World Bank. Table 7.3 Impact on externalities (lower annual increases than the BAU from the baseline) Energy subsidy with redis- Energy subsidy with general tribution   redistribution to the poor (%) (%) Mortality due to inadequate WASH -15.63 -15.92 (number of premature deaths) Mortality due to air pollution (number of premature deaths) -15.62 -8.81 Morbidity due to inadequate WASH and to air pollution -11.97 -6.99 GHG emissions (million tCO2eq) -3.47 -1.38 Flood damages in agriculture (Ha) -1.58 -1.97 Forest losses (Ha) -1.14 -0.3 Source: World Bank. The results also suggest that the increase in GDP is dominated by the increase in net government revenue due to the removal of the subsidies. This increase in turn is translated into income increases through the redistribution policies hypothesized. The macroeconomic effects of subsidy removal would be contractionary, at least in the short run, despite its positive effect on effi- ciency, (at least if evaluated at market prices) if the government were to retain the savings from the subsidy removal but would turn expansionary under both redistribution hypotheses. The subsidy could have a positive impact on economic growth even without redistribution because it could increase government revenues. This could lead to several positive effects, such as easing the burden of government debt on future generations and keeping the public budget on a sustainable course. These effects were indirectly measured by performing a series of experiments giving government revenue a weight greater than private con- sumption, as in cost-benefit analysis. The results show that the impact of the subsidy on GDP at market prices would be positive if the weight of government revenue with respect to private consumption were to be greater than 1.7. This amount would reflect the value of one additional unit of government revenue, either in terms of the public goods and services that the government can provide, or in terms of the opportunity cost of one additional unit of taxation or public debt. On the household income side, removal of the subsidies would improve incomes of all households (figure 7.1). Redistribution to the poor would be mainly paid by the non-poor income groups and by a deterioration in the foreign balance, while the govern- ment would see a further increase in its revenues despite its foregoing the proceeds from the subsidy removal. The distribution impact of the subsidy removal would be uniformly positive in the case of redistribution to the poor, with a larger income share BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 138 CGE Analysis of Green Policies in Bangladesh for both rural and urban poor in all regions, while a general redistribution would have a small but regressive effect. This result is an indication that the subsidy removal would tend to have a regressive impact unless it were complemented with policies of income transfer to poorer households. Figure 7.1 Impact of subsidy removal on income distribution: Household income shares by household group 10.68% 10.71% 12.50% 36.64% 36.70% 35.80% Rural Poor Rural non Poor 4.49% 4.53% 5.33% Urban Poor Urban non Poor 52.69% 52.60% 51.71% Income Share of All Poor 6.19% 6.18% 7.17% BAU Scenario (T+10) General Redistribution (T+10) Redistribution to the Poor (T+10) Source: World Bank. 7.3.2 Lessons from the subsidy-removal experiments The subsidies removed include those explicitly given to reduce retail prices and those resulting from trade policies and translate into prices lower than opportunity costs for the electricity and gas consumed. In particular, the model simulates a realignment of the electricity subsidized price and of the retail price of natural gas with its imported price (at the 2017 level) through an equiva- lent tax. The main results obtained from these experiments can be summarized in the following points: • Removing subsidies would be beneficial for the economy as a whole, because it would lead to more efficient resource allo- cation and increased government revenue. The negative impact on private incomes and employment would be more than offset by the potential benefits of increased government revenue and its reinjection into the economy for investment expen- diture or income transfers. • The increase in government revenue could be used to improve total well-being in a number of ways, such as by redistributing it to households or investing it in public goods. Without any reemission of government revenue, the aggregate effects on the economy would only be positive if government revenue were considered to be worth more than 1.7 times private consumption. • Phasing out subsidies would also yield aggregate benefits by reducing harmful externalities. These effects are large and con- sistent across different scenarios of redistribution. • One possible reemission policy would be to redistribute government savings from the subsidy removal to all households. This would lead to both an expansion of the economy and a reduction of negative externalities. • Another possible way to use the proceeds from subsidy removal is to redistribute them only to poor households. This would have a larger impact on the economy, but a smaller impact on reducing harmful externalities. However, this lower impact does not take into account the likely positive effects of the transfer on the substitution of more harmful cooking fuels. In any case, this policy would still lead to an improvement in net social benefit. This policy would also have significant and positive distributional effects, with a larger share of the gains accruing to the poor. • Subsidy removal appears to have positive effects on income distribution only under the policy of redistribution to the poor. This scenario would lead to the highest performance in terms of GDP, net social benefits, and income distribution improve- ment, but the lowest one for the reduction of externalities. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 139 CGE Analysis of Green Policies in Bangladesh 7.4 Exploring the introduction of carbon-pricing instruments 7.4.1 Introducing a carbon tax: Features and the mechanism of action A carbon tax at national level for Bangladesh would have the objective to enhance environmental awareness (both for CO2 emissions and in general), and to price carbon in a way that reflects its (external) opportunity cost and helps shifting consump- tion toward the use of cleaner fuels. The main source of GHG emission in the country is the use of fossil fuel, which is increasing with economic growth and encouraged by generous government subsidies on electricity and gas. Because of strong economic growth, urbanization, and industrial expansion, GHG emissions in Bangladesh grew at an annual average rate of 7.2 percent over 1970–2016 and accelerated to 9.2 percent a year for the more recent years (2004–2016).70 From a sectoral perspective, the power sector is the dominant emitter, but part of the responsibility falls on energy heavy users such as transport industry and even ag- riculture (with one of the largest power irrigation systems in the world). The existence of large fuel subsidies to final and intermediate users, as examined in the first part of this chapter, implies that a rationalization of taxation based on carbon emissions of all sectors, that could accompany the institution of the carbon tax, would not only help to curb emissions, but also reduce market distortions. This operation, though difficult to carry out, could bring the so called “double dividend”, given by the positive impact on the government finance without the deadweight loss that any taxation imposes upon the economy (Poterba 1989 Rausch et al. 2011). Distributional concerns derive from the fact that con- sumption of carbon related consumption goods of low-income households is a higher proportion of their income and display lower income and price elasticities. Lower income consumers could thus be the main losers from the first-round effects of the tax that would appear to impose a higher burden on their consumption budget relative to higher income households. However, several studies (see box 7.1) suggest that distributional effects are much more complex, and the prima facie negative effects on low-income households may be substantially mitigated or even reversed once lifetime incomes, factor returns, price and tax revenue distribution effects are considered. Box 7.1 Recent studies on the introduction of carbon taxation The distributional effects of carbon taxation have been the object of several studies (Bull, Hassett, and Metcalf 1994; Hassett et al. 2009; Metcalf 2007; 2019; Morris and Sterner 2013; Symons, Speck, and Proops 2002). However, perhaps not surprisingly, results appear to be diverse and to depend very heavily on circumstances, the openness of the economy and the distortions of the markets affected. Important factors are also the size of the tax and the way the proceedings are utilized and redistrib- uted. The regressivity finding, which is present in many studies, tends to display large variations in magnitude. For example, Metcalf et al. (2008) finds that a carbon tax in the US would reduce the after-tax income of taxpayers in the first decile by 3.7 percent, compared to just an 0.8 percent reduction for the wealthiest decile, with the lowest figure referring to the incidence measurement in terms of lifetime income. On the other hand, Gonzales (2012) and Hassett, Mathur, and Metcalf (2009) find that the indirect component of a carbon tax (that is, higher prices due to higher costs of production) is significantly more progressive, whereas the direct component, which focuses on the prima facie higher consumption costs for electricity of poor households, is regressive. Forward and backward linkages as well as timing are also relevant since the carbon tax can either fall forward in the form of higher con- sumer prices or backwards in the form of lower returns to factor inputs. The general equilibrium effects are thus complex and difficult to investigate without a reliable and comprehensive model. For example, although some studies—for example, Bovenberg and Goulder (2001) and Paltsev et al. (2007)—find that the short- and medium-term incidence of a CO2 tax falls primarily on consumer prices, other general equilibrium studies—for example, Gonzales (2012)—showed that the final effect depends on how goods and factor markets react to the tax characteristics, its impact on labor and employment and on the way the tax is raised against consumption or production of CO2. Sources: Bull, Hassett, and Metcalf 1994; Hassett et al. 2009; Metcalf 2007; 2019; Morris and Sterner 2013; Symons, Speck, and Proops 2002. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 140 CGE Analysis of Green Policies in Bangladesh 7.4.2 Carbon-tax experiments To assess the effects of a carbon tax, we have simulated the levy of a uniform tax on production across sectors, in proportion to their emissions. This approach is equivalent to levying a carbon tax directly on various fossil fuels, taking into account the carbon content of each fuel. This means that fuels with higher carbon content are taxed more heavily, reflecting their greater contri- bution to emissions, ensuring that each sector’s tax burden is proportionate to its carbon footprint. To explore the benefits and costs of such a tax, along the most important dimensions of its impact, we performed three series of experiments: (a) a carbon tax ranging from $3 to $60 per ton of CO2 emitted, raised across the board toward all producers, with no further reemission of the tax proceeds into the economy; (b) a carbon tax combined with a cap and trade system with the possibility of selling car- bon credits for producers with emissions below a threshold level equal to the average unit emission (CO2 per $ produced) in the economy, (c) a carbon tax with the same characteristics as in (a), but with redistribution of its proceeds to all households below the poverty line. If a carbon tax is raised in proportion to the CO2 emissions of a production activity, its effects will be similar to a targeted produc- tion tax, in the sense that it will change relative prices to incorporate the social costs of the carbon emissions. These costs concern not only carbon, through the global nature of climate change as a public good but include also those created by the association of carbon emissions with a host of harmful externalities, including PM2.5 emissions, loss of biodiversity and risks of forest fires. These correlations are due to the fact that environmental degradation is a complex phenomenon that is at the same time the effect and the cause of a bundle of externalities. Thus, for example, forest fires tend to simultaneously increase GHG and PM2.5 emissions, loss of biodiversity, and land degradation, thereby increasing the probability of more fires, higher degradation, and so forth. By better aligning individual incentives to social goals, carbon taxes may thus be used as a form of general environmental taxation addressed to a critical core of both global and local externalities. 7.4.3 A “pure” carbon tax on production The results of the pure carbon-tax experiment show that, in the absence of a reinjection of its proceeds, a carbon tax would have negative consequences for the economy, even if it reduced harmful externalities. The tax would lead to a decline in GDP, which would not be offset by the avoided externalities (table 7.4). This would result in negative net local and global social benefits, for all tax rates considered. The beneficial welfare effects of the tax appear to have a maximum at a relatively low tax rate of around $3/ ton. A reduction in the aggregate conversion factor (the ratio of market prices to shadow price index) is consistent with a steep linear increase in net social benefits. However, welfare effects at pre-tax prices are rather small and turn sharply negative above a $10/ton tax rate, while those at shadow prices are large and decrease slowly from a threshold of $5/ton. The potential benefit of the tax boost in the public sector’s balance can be examined by assuming that the government’s in- come should be more heavily valued than private consumption (because of the tax burden associated with imposition of a tax). Under this assumption, the effect on GDP at market prices becomes favorable for every tax rate only when the value attached to government proceeds is at a minimum of 2.5 times that of private consumption. This threshold is notably higher than what’s been estimated for the removal of energy subsidies, which is 1.5 times. In terms of income distribution, carbon taxation appears to have only a slight positive impact, with the income share of the poor increasing uniformly with respect to BAU from 10.68 percent to 10.88 percent throughout the tax range (figure 7.2). Table 7.4 Carbon-tax (Ctax) impact for different tax rates (higher or lower annual increases than the BAU from the baseline) | Percent   Ctax$3/ton Ctax$5/ton Ctax$10/ton Ctax$25/ton Ctax$40/ton Ctax$60/ton Total GDP -1.17 -1.95 -3.89 -9.69 -15.55 -23.83 Total GDP at shad- 22.63 21.85 19.93 14.18 8.37 0.15 ow prices Carbon emission -0.84 -1.41 -2.84 -7.26 -11.95 -18.89 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 141 CGE Analysis of Green Policies in Bangladesh Figure 7.2 Carbon-tax impact on income distribution: Household income shares by household group 10.68% 10.69% 10.69% 10.71% 10.75% 10.80% 10.88% 36.63% 36.67% 36.69% 36.75% 36.92% 37.10% 37.37% Income Share of All Poor Urban non Poor 4.49% 4.51% 4.51% 4.53% 4.60% 4.67% 4.78% Urban Poor Rural non Poor Rural Poor 52.69% 52.65% 52.62% 52.55% 52.33% 52.10% 51.76% 6.19% 6.18% 6.18% 6.17% 6.15% 6.13% 6.10% BAU Scenario $3/TON $5/TON $10/TON $25/TON $40/TON $60/TON (T+10) Source: World Bank. 7.4.4 Cap-and-trade experiments This experiment explores the possibility of reducing the negative efficiency effects of a pure carbon tax by using market forces. It is based on three components: (a) Producers are taxed based on the amount of CO2 they emit per dollar of production. However, this tax only applies to emissions that exceed a predetermined limit, which is set at the average emission level for the sector. (b) This tax effectively acts as a penalty for producers who exceed the emission limit. Producers who successfully emit below the limit are rewarded with carbon credits, which they can sell to producers who exceed the limit. This creates a market-based in- centive for compliance. (c) The experiment uses a specific type of carbon trading system through which producers can buy and sell carbon credits, based on the differences between their production and the limit fixed by the government, which give them the right to emit a certain amount of CO2. The experiment results suggest that this type of carbon trading system can significantly reduce emissions without having a ma- jor negative impact on economic efficiency. This is because the system allows producers to choose the most cost-effective way to reduce their emissions. Additionally, the system creates a market for carbon credits, which yields further efficiency benefits by expanding choices for producers. Overall, this experiment shows that carbon trading systems can be a more effective and efficient way to reduce emissions than traditional carbon taxes.71 More specifically, the cap-and-trade policy experiment appears to be a winner for small values of the tax imposed on emissions above the threshold (for $3 and $5 per ton), in the sense that it both increases GDP and reduces externalities with a positive net balance for social benefits. However, carbon trading has the side effect of lowering the performance of the tax in reducing the negative externalities. This is in part the consequence of the fact that, at least for low levels of the tax, trading tax allowances neutralize the price effects of the tax both because of the expansionary effects of reinjecting resources into the economy and of the comparatively higher level of production that carbon trading allows for producers above the threshold (table 7.5). From the income point of view, improvements are registered for all households for the smaller values of the taxes, but income distribution remains stable throughout the whole range of possible taxes (figure 7.3). Table 7.5 Carbon (Ctax) tax (with carbon trading) impact for different tax rates (higher or lower annual increases than the BAU from the baseline) | Percent   Ctax$3/ton Ctax$5/ton Ctax$10/ton Ctax$25/ton Ctax$40/ton Ctax$60/ton Total GDP 0.75 0.47 -0.27 -2.85 -6.09 -11.79 Carbon emission -0.41 -0.83 -1.89 -5.34 -9.22 -15.34 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 142 CGE Analysis of Green Policies in Bangladesh Figure 7.3 Income distribution impact of different tax rates (with carbon trading) | Percent of total income by household groups 10.68% 10.66% 10.66% 10.66% 10.66% 10.67% 10.69% 36.64% 36.64% 36.65% 36.68% 36.81% 36.95% 37.16% Income Share of All Poor Urban non Poor 4.49% 4.48% 4.49% 4.49% 4.51% 4.54% 4.59% Urban Poor Rural non Poor Rural Poor 52.69% 52.71% 52.69% 52.65% 52.53% 52.39% 52.15% 6.19% 6.18% 6.18% 6.17% 6.15% 6.12% 6.09% BAU Scenario $3/TON $5/TON $10/TON $25/TON $40/TON $60/TON (T+10) Source: World Bank. 7.4.5 Carbon tax with redistribution to the poor As a further enhancement of a carbon-tax measure, this experiment assumes that the proceeds of the tax are reinjected into the economy through lump sum payments to households below the poverty line. This policy combination displays net social bene- fits at shadow prices (but not at market prices) for all values of the tax, in the sense that it both increases GDP (at the second-best shadow prices under the cap-and-trade regime) and reduces externalities with a positive net balance for social benefits. Further- more, the benefits from externality reductions grow more than proportionally with the size of the tax and increasingly overper- form both the pure tax and the cap-and-trade scenarios (table 7.6). The impact on incomes is generally positive and increasing with the tax rate for the poor and negative for the non-poor. Income distribution improves progressively with higher tax rates, although it is only for the highest rates that the share of income of the poor undergoes a significant increase, both in absolute terms and in comparison, to the other two scenarios (figure 7.4). Table 7.6 Carbon-tax (Ctax) (with redistribution to the poor) impact for different tax (higher or lower annual increases than the BAU from the baseline) | Percent   Ctax$3/ton Ctax$5/ton Ctax$10/ton Ctax$25/ton Ctax$40/ton Ctax$60/ton Total GDP -0.63 -1.06 -2.17 -5.76 -9.85 -15.97 Total GDP at shadow prices 3.41 4.35 4.16 2.91 6.21 8.19 Carbon emission -0.63 -1.05 -2.14 -5.62 -9.50 -15.16 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 143 CGE Analysis of Green Policies in Bangladesh Figure 7.4 Income distribution impact of different tax rates (with redistribution to the poor) | Percent of total income by household groups 10.68% 10.70% 10.80% 10.90% 11.20% 11.90% 12.70% 36.64% 36.70% 36.70% 36.60% 36.50% 36.40% 36.10% Income Share of All Poor Urban non Poor 4.49% 4.50% 4.50% 4.70% 4.80% 5.10% 5.50% Urban Poor Rural non Poor Rural Poor 52.69% 52.60% 52.60% 52.60% 52.40% 52.80% 51.20% 6.19% 6.20% 6.20% 6.30% 6.40% 6.80% 7.10% BAU Scenario $3/TON $5/TON $10/TON $25/TON $40/TON $60/TON (T+10) Source: World Bank. 7.4.6 Summary of above findings The main results obtained from the carbon pricing experiments can be summarized as follows. Applying a carbon tax to pro- duction at a rate proportional to carbon emissions would have negative results on GDP at market prices, which would be almost completely countervailed by the values of externality reductions. However, social gains from a more efficient resource allocation and reduction of externalities are large and positive if market output is evaluated at shadow prices. Income distribution effects of the standalone tax would be slightly positive, but overall, the tax would be macroeconomic con- tractionary and probably reduce the rate of growth of the economy, at least in the short run. In the medium-long run, increases in government revenues unmatched by reemission into the economy could have a beneficial effect on economic sustainability. However, sensitivity analysis shows that their contribution to the economy would have to be valued at more than 2.7 times as large as private consumption to outweigh the advantages provided by reinjecting the funds into the economy. As in the case of the subsidy removal, the increase in government revenues represents a potential improvement in total well-be- ing, which could be obtained under several different policies of reemission of the financial resources raised into the economy. The pure tax appears also to yield aggregate benefits by reducing harmful externalities and these effects are large and consistent across the different tax rate scenarios examined. A carbon tax combined with a cap-and-trade system appears to be neutral for income distribution, but successful from an efficiency standpoint. The model simulations indicate that, at least for small values of the tax (for $5 and $10 per ton), this policy combination increases GDP and reduces externalities with a positive net balance for social benefits. However, carbon trading has the side effect of low- ering the performance of the tax in reducing the negative externalities. This is because trading tax allowances tend to neutralize some of the price effects of the tax both through the expansionary impact of reinjecting resources into the economy and of the comparatively higher level of production (and emissions) that carbon trading allows for producers above the threshold. A carbon tax combined with redistribution of its proceeds to households below the poverty line displays net social benefits at shadow prices (but not at market prices) for all values of the tax, in the sense that it both increases GDP (at the second-best shadow prices under the cap-and-trade regime) and reduces the externalities with a positive net balance for social benefits. Furthermore, the benefits from externality reductions increase more than proportionally with the increase of the tax and in- creasingly overperform both the pure tax and the cap-and-trade scenarios. This policy combination appears to have uniformly positive effects on poverty levels, with the share of income of the poor increasing in all regions. Income distribution improves progressively with higher tax rates, although it is only for the highest rates that the share of income of the poor takes a real leap both in absolute terms and in comparison, to the other two scenarios. In general, model simulations suggest that a carbon tax will have a contractionary effect from a macroeconomic standpoint, at least in the short run72, but this negative impact can be overcome by reinjecting resources into the economy either via a market mechanism (for example,, carbon trading) or through redistribution policies. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 144 CGE Analysis of Green Policies in Bangladesh 7.5 Water Investment Program 7.5.1 Structure of the program The Bangladesh Delta Plan 2100 (BDP) Investment Program consists of a total of 80 projects: 65 are physical projects, and 15 are institutional and knowledge development projects at the first phase up to 2030. The BDP total capital investment cost is project- ed to be BDT 2,978 billion ($37 billion) (GED 2018). This scale of investment is not large, considering Bangladesh growth achieve- ments and the pressing needs of its obsolete infrastructure and low productivity in the face of progressively worsening effects of climate changes. Presently the government spends about 0.8 percent of GDP on programs that for content and targets can be assimilated to BDP directions, but it is estimated that additional resources for at least an additional 1 percent would be needed. In the model experiments, we have tried to reproduce in stylized form the main characteristics of key BDP projects aimed at some of the main achievement targets outlined in table 7.7. For this purpose, we have implemented a main program package, focusing on improvement of water supply and management. Table 7.7 Main national strategies of Bangladesh Development Plan Strategy FR 1: Protect Economic Strongholds and Critical Infrastructure • Sub-strategy FR 1.1: Protection by development and improvements of embankments, barriers and water control structures (including ring dikes) for economic priority zones and major urban centers. • Sub-strategy FR 1.2: Construct buildings that are adaptive and resilient to flood-storm-surge. • Sub-strategy FR 1.3: Adopt spatial planning and flood hazard zoning based on intensity of flood. • Sub-strategy FR 1.4: Improve Flood Early Warning System services (both for basins and hotspots); and • Sub-strategy FR 1.5: Improvement of Drainage. Strategy FW 1: Ensure Water Availability by Balancing Supply and Demand for Sustainable and Inclusive Growth The freshwater strategy is aimed to ensure water availability by balancing supply and demand for sustainable and inclusive growth. The cross-boundary issues become important here. Sub-strategies include: • Sub-strategy FW 1.1: Ensure optimum water resource management in the country following basin wide management along with con- struction of necessary embankments. • Sub-strategy FW 1.2: New irrigation schemes for the major rivers of the country. • Sub-strategy FW 1.3: Excavate of local water reservoirs (canals, ponds and baors) for restoration of water and rainwater harvesting. • Sub-strategy FW 1.4: Construct Rubber dam preceded by appropriate feasibility study. • Sub-strategy FW 1.5: Enhance freshwater flows in urban and regional rivers. • Sub-strategy FW 1.6: Restore natural reservoir and water bodies along with their biodiversity conservation. • Sub-strategy FW 1.7: Preserve ground water level by restriction on excessive extraction of ground water; and • Sub-strategy FW 1.8: Increase the freshwater flow in urban and rural rivers and control of river pollution. Strategy FW 2: Maintaining Water Quality for Health, Livelihoods and Ecosystems This strategy is based on the second objective “water quality” of the freshwater strategy. Water quality is a growing concern for the coun- try, with many rivers and wetlands at serious environmental risk. To ensure healthy lives, livelihood and ecosystem of Bangladesh, the quality of water needs to maintain according to rules and regulation. Sub-strategy includes: • Sub-strategy FW 2.1: Appropriate waste management and reduction of pollution in urban and rural areas. • Sub-strategy FW 2.2: Monitor and control of pollution; and • Sub-strategy FW 2.3: Conduct action research for improved ecosystem services. Source: GED 2018. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 145 CGE Analysis of Green Policies in Bangladesh Box 7.2 Delta plan strategy and projects’ CGE Simulations The CGE model simulates the BDP investment plan in the projects’ construction phase through the implementation of an investment shock that yields direct, and indirect demand led effects on the Bangladesh economy. In the projects’ operational phase, the plan is analyzed as an activity added to the national economy as a more sustainable form of production which can be endogenously expanded as an alternative to traditional production technology and value chain composition. The water program analyzed is consistent with BDP investment priorities and include flood protection, control and drainage, river erosion control, river management, urban and rural water supply and waste management and institutional capacity building. Estimated investment costs are around $17.3 billion. The investment components are water infrastructure, such as installation of piped water supply system both in urban and rural areas, water treatment facilities, storage, transmission, and distribution networks, including house connections. An important component is an expanded and upgraded sanitation system, with comprehensive investments for sanitation septage, drainage and management of grey water and storm water flooding. Other investments include public toilet construction and management cleaning support from informal workers with equipment and training for fecal sludge management. Institutional capacity building will also be pursued by investing in institutional capacity on water sanitation and services through IT and accounting, water quality monitoring systems, con- tract management capacities, gender action plans and financial support. In the operational phase, the physical and human capital capacity realized in the projects’ construction phase is expected to bring several benefits. These are both estimated ex ante and endogenously quantified by the model. They include reduction of mortality and morbidity costs, of agricultural and nonagricultural water pollution, GDP increases and income and price effects. Source: World Bank. 7.5.2 Program simulation Tables 7.8 and 7.9 summarize the basic structure and Figures 7.5–7.8 report the economic results of the water supply and man- agement (WSM) program hypothesized for the 13 years covered by the CGE simulations. Estimated total economic benefits include both those generated by the employment expansion caused by the construction works and the longer-term increases in incomes and reduced externalities produced by the adoption of the program on the part of farmers and market operators in all regions of the country. Net benefits appear to be large both in terms of GDP gains and reduction of harmful externalities (figure 7.5 and 7.6). The results also suggest that the WSM program would have the largest impact on skilled labor incomes and returns to capital (Figure 7.7), thus engendering further investment in human and nonhuman capital, with positive income distribution effects, inverting the deterioration envisaged from the base year and bringing the total household income share of the poor from 10.6 percent to 11.3 percent (Figure 7.6). Table 7.8 Water Program target cash flow (direct costs) | $, millions   Total (2021–27) Present value Investment costs Construction 2,362.50 1,998.55 Services 590.63 499.64 Water distribution 1,771.88 1,498.92 Health 7,087.50 5,995.66 Total investment costs 11,812.50 9,992.77 O&M costs Construction 1,102.50 779.52 Services 275.63 194.88 Water distribution 826.88 584.64 Health 3,307.50 2,338.55 Total O&M costs 5,512.50 3,897.59 Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 146 CGE Analysis of Green Policies in Bangladesh Table 7.9 Water Program revenue target cash flow (financial revenues) | $, millions Revenues Total (2021–40) Present Value Reduction of mortality and morbidity costs 9,647 6,964 Reduction of agricultural water pollution 1,281 925 Reduction of non-agricultural water pollution 4,595 3,317 Reduction of CO2 emissions 4,339 3,132 Increasing GDP due to avoided working day losses 44,369 32,030 Total benefits 64,231 46,368 Source: World Bank. Figure 7.6 Economic impact of the water program (higher or lower growth than the BAU from the baseline) 13.70% 13.26% 6.22% -27.53% -31.77% -19.62% -3.10% Source: World Bank. Figure 7.7 Impact of the Water Program on externalities (lower growth than the BAU from the baseline) -32.98% -0.38% -8.90% -1.13% -14.14% Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 147 CGE Analysis of Green Policies in Bangladesh Figure 7.8 Impact on employment of the Water Program (higher growth than the BAU from the baseline) 0.32% 2.14% 1.28% 1.49% 1.59% 1.82% % Change Income % Change Prices % Change Employment 1.28% 1.91% 3.96% 1.49% Labor Unskilled Labor Skilled Capital Land Source: World Bank. Figure 7.9 Income distribution impact of Water Program: Percent of total income by household groups 10.68% 11.25% 36.64% 35.74% Rural Poor Rural non Poor 4.49% 4.78% Urban Poor Urban non Poor Income Share of Poor 52.69% 53.00% 6.19% 6.47% BAU Scenario (T+10) Water Project (T+10) Source: World Bank. 7.5.3 Summary of above findings The main results obtained from the water program experiments can be summarized as follows. The water project simulated by the model embodies several features of the ambitious program set up in the BDP. Consistent with BDP investment priorities, the project includes flood protection, control and drainage, river erosion control, river management, urban and rural water supply and waste management and institutional capacity building. Even though the model experiments do not cover the whole-time span of the program (up to 2040), estimated total economic benefits include both those generated by the employment expansion caused by the construction works. They also include, lim- itedly to the ten years considered, the increases in incomes and reduced externalities produced by the adoption of the program on the part of farmers and market operators in all regions of the country. The model experiments also aim to validate the ex-ante benefit and cost estimates by endogenizing the rate of adoption of the input package contained in the projects’ cash flow. The CGE results for the endogenously generated employment, production, income, and price variables, for both the construc- tion and the operational phases, appear to be in line with ex ante cash flow estimates and substantial both in terms of GDP gains and reduction of harmful externalities. The model simulations also indicate that the program would have the largest impact on skilled labor incomes and returns to capital, thus engendering further investment in human and nonhuman capital. The income distribution impact of the program would be significant, with a total income share of the poor raising from 10.7 percent to 11.3 percent. More generally, the model suggests that the water management components of the stylized investment program examined could be successful in terms of adoption rates and diffusion as alternative technologies for agricultural production. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 148 CGE Analysis of Green Policies in Bangladesh 7.6 Conclusions This chapter has analyzed several policy measures for Bangladesh development strategy with the help of a CGE Model (Ban- gladesh Bioeconomy CGE 101). The policies examined include the removal of energy subsidies, several carbon market measures aimed at setting appropriate carbon prices and a water supply and management development program. The results of the analysis can be summarized under the following main points. The analysis of the subsidy removal and the carbon-tax policies reveal different effects. The subsidies distort relative prices of energy and thus their removal increases economic efficiency by correcting a misalignment between market prices and private opportunity costs (directly of electricity and gas and indirectly of all other prices in the economy). In doing so they also tend to reduce the misalignment between private and social opportunity costs for carbon, but this is only a secondary effect, largely dominated by the impact on electricity and gas prices. The carbon tax, as well as other carbon pricing instruments, on their part, tend to correct the misalignment between the private and the social opportunity cost of carbon emissions across the whole economy. Thus, a carbon tax subsumes the effect of removing the subsidy and the simulation results suggest that it may be combined by a gradual removing of the subsidies, thus making its effects more incisive and more politically accept- able in the short run. The model’s results suggest that removing the current energy subsidies could be a good first step for a fiscal-policy intervention. This would have beneficial effects on both economic efficiency and environmental protection. The policy would also be benefi- cial for equity if the government savings were redistributed to the poor. While this redistribution would reduce the environmental benefits of the policy, the overall social benefits would still outweigh the costs. The policy would have positive effects on the environment and human health compared to the business-as-usual scenario. However, it is important to note that the environ- mental effects of the policy could be even more positive if we considered the impact of the transfer on the use of less polluting fuels by the poor. The transfer could help the poor to switch to cleaner fuels, such as solar energy or natural gas, which would reduce their emissions and improve air quality. Setting the stage for efficient carbon markets also appears to be a feasible policy for Bangladesh with several beneficial effects, especially if combined with suitable redistribution policies to poorer households. Applying a carbon tax to production at a rate proportional to carbon emissions would have negative results on GDP at market prices, but this would be almost completely countervailed by the values of externality reductions. Moreover, social gains from a more efficient resource allocation and reduc- tion of externalities turn out to be large and positive if evaluated at shadow prices. A carbon tax combined with redistribution of its proceeds to households below the poverty line displays net social benefits at shadow prices (but not at market prices) for all values of the tax. It also yields the best impact on income distribution and the conditions of the poor, even though this implies a lower effect on externality reduction. A carbon tax combined with a cap-and-trade system appears to be neutral for income dis- tribution, but successful from an efficiency standpoint since it both increases GDP and reduces externalities. As in the redistribu- tion case, however, by allowing the expansion of larger polluters, carbon trading has the side effect of lowering the performance of the tax in reducing the negative externalities. In sum, while a straight carbon tax would yield net benefits on purely efficiency grounds, a combination of a moderate tax with a program of lump sum transfer of its proceeds to the poor would achieve the best results in terms of income distribution and reduced external damages. Testing with the CGE simulations an ambitious water supply and management program designed in accordance with the BDP priorities, shows the potential benefits of a development strategy aimed at increasing productivity, improving water manage- ment, and protecting the environment. The CGE experiments focused on a water supply and management program that was simulated in detail to analyze costs and benefits for the country as well as for a range of its stakeholders. The experiments were designed to reproduce some of the main features of a large program aimed at boosting yields, protect the environment, and im- prove water management. The results suggest that this project typology could be highly successful in combining productive and environmental benefits and would be usefully complemented by the fiscal policies analyzed in the first two parts of the paper. The economic modeling exercise carried out to assess investment in water management suggests thus that this program could be highly beneficial. Unlike the other measures considered, it would mobilize local labor and other unemployed resources and it would not need to sacrifice value added to achieve sizable gains in shifting land and capital usage to reduce negative exter- nalities. However, this type of investment is itself only sustainable if government resource commitments are accompanied and followed by concurring private behavior. Convincing people to abandon traditional land and water management practices, and to switch from the present modes of production to more sustainable ones, requires both persuasive power and sufficient incen- tives. Combined with an effective information and extension program, public investment should be complemented by policies BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 149 CGE Analysis of Green Policies in Bangladesh aimed to nudge local agriculturists toward more sustainable land and water use practices, by not only providing feasible alterna- tives to the present form of agriculture and repairing some of its damages, but by also immediately increasing employment and economic activity in rural areas. The results presented are based on a large and detailed economic model and can be interpreted as indicating that the policy measures examined may be reasonably effective in generating benefits (reduction of externalities), increase GDP and improve the condition of the poor. At the same time, taken individually, none of the fiscal and investment policy measures alone is likely to be able to sustainably deliver the desirable increases in incomes and reduced externalities desired. Obstacles include low efficiency, possible unintended reactions to subsidy removal and tax levying, enforcement costs and noncompliance. In the case of the water program, while the model predicts high rates of adoption of improved practices and technologies, difficulties may arise from lack of experience, risk aversion and financing bottlenecks. Discontinuing energy subsidies, imposing carbon taxes, extending carbon credits, and other finance and fiscal instruments can usefully support sustainable agriculture and water management programs. The model results suggest that BDP investment pro- grams for agriculture and water should be carried out to the full extent envisioned by government planners. To enhance their ef- fectiveness, however, they should be combined with conservation incentives (such as carbon taxes) and/or supported by equiv- alent subsidies (payments for ecological services), as well as by targeted transfers to the poor. By aligning private incentives to social goals, these measures could ensure that the infrastructure financed be put to appropriate use and not ignored or even jeopardized by direct or indirect private actions. Finally, more research and analysis would be necessary to examine in greater detail the policies that would be likely to be more successful in the pursuit of a national strategy of sustainable and inclusive growth. In its present and further enhanced forms, the CGE model could support a comprehensive review of the Bangladesh investment plans to analyze and identify effective policy measures and their likely impact on a plurality of stakeholders. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 150 CGE Analysis of Green Policies in Bangladesh C7 References / Endnotes Acharya, R. H., and A. C. Sadath. 2017. “Implications of Energy Subsidy Reform in India.” Energy Policy 102: 453–62. ADB (Asian Development Bank). 2013. Energy Policy Options for Sustainable Development in Bangladesh. Manila, Philippines: ADB. Amin, S., L. Marsiliani, and T. Renstro. 2018. “The Impacts of Fossil Fuel Subsidy Removal on Bangladesh Economy.” Bangladesh Development Studies Vol. XLI. Bankable Frontier Associates. 2009. “The Mzansi Bank Account Initiative in South Africa.” Johannesburg: FinMark Trust. Barnes, D. F., Shahidur R. Khandker, and Hussain A. Samad. 2011. “Energy Poverty in Rural Bangladesh.” Energy Policy 39 (2): 894–904. https://www.sciencedirect. com/science/article/abs/pii/S0301421510008384 Barua, Sepul K., M. Boscolo, and A. Animon. 2020. “Valuing Forest-based Ecosystem Services in Bangladesh: Implications for Research and Policies.” Ecosystem Services 42: 101069. Boadway, R. 2006. “Principles of Cost-Benefit Analysis.” Public Policy Review. 2 (1): 1–44. Bovenberg, A., and L. H. Goulder. 2001. “Neutralizing the Adverse Industry Impacts of CO2 Abatement Policies: What Does It Cost?” In Behavioral and Distributional Effects of Environmental Policy, edited by Carlo Carraro and Gilbert E. Metcalf, 45–90. Chicago, IL: University of Chicago Press. Breisinger, C., A. Mukashov, M. Raouf, and M. Wiebelt. 2019. “Energy Subsidy Reform for Growth and Equity in Egypt: The Approach Matters.” Energy Policy 129: 661–71. Bull, N., K. A. Hassett, and G. E. Metcalf. 1994. “Who Pays Broad-based Energy Taxes? Computing Lifetime and Regional Incidence.” The Energy Journal 15 (3). Cervigni, R., and P. L. Scandizzo, eds. 2017. The Ocean Economy in Mauritius, Making it Happen, Making it Last. Washington, DC: World Bank. Damania R., S. Desbureaux, P. Scandizzo, M. Mikou, D. Gohil, and M. Said. 2019. “When Good Conservation Becomes Good Economics: Kenya’s Vanishing Herds.” Washington, DC: World Bank. Damania, R., and P. L. Scandizzo. (2017). “The Serengeti Eecosystem—Burden or Bounty?” Journal of Policy Modeling 39 (2): 185–205. Dartanto, T. 2013. “Reducing Fuel Subsidies and the Implication on Fiscal Balance and Poverty in Indonesia: A Simulation Analysis.” Energy Policy 58: 117–34. Del Granado, A. F. J., D. Coady, and R. Gillingham. 2012. “The Unequal Benefits of Fuel Subsidies: A Review of Evidence for Developing Countries.” World Development 11: 2234–48. Del Ninno, Carlo, Kalanidhi Subbarao, and Annamaria Milazzo. 2009. “How to Make Public Works Work: A Review of the Experiences.” SP Discussion Paper No. 0905. Washington, DC: World Bank. Dervis, K., J. de Melo, and S. Robinson. 1982. General Equilibrium Models for Development Policy. New York: Cambridge University Press. Elshennawy, A. 2014. “The Implications of Phasing Out Energy Subsidies in Egypt.” Journal of Policy Modeling 36 (5): 855–66. GED (General Economics Division). 2018. Bangladesh Delta Plan 2100: Bangladesh in the 21st Century—Volume 1: Strategy. Dhaka, Bangladesh: General Economics Division, Bangladesh Planning Commission, Ministry of Planning, GoB. Glomm, G., and J. Jung, 2015. “A Macroeconomic Analysis of Energy Subsidies in a Small Open Economy.” Econ Inq 53 (4): 1783–806. Gonzalez, F. 2012. “Distributional Effects of Carbon Taxes: The Case of Mexico.” Energy Economics 34 (6): 2102–15. Griffin, P., T. Laursen, and J. Robertson. 2016. “Egypt Guiding Reform of Energy Subsidies Long-Term Policy.” Research Working Paper 7571. Washington, DC: World Bank. Hassett, K. A., A. Mathur, and G. E. Metcalf. 2009. “The Incidence of a US Carbon Tax: A Lifetime and Regional Analysis.” The Energy Journal 30 (2). Heckman, J. J., and R. Pinto. 2022. “Causality and Econometrics” No. w29787. National Bureau of Economic Research. Hong, L., D. Liang, and W. Di. 2013. “Economic and Environmental Gains of China’s Fossil Energy Subsidies Reform: A Rebound Effect Case Study with EIMO Model.” Energy Policy 54: 335-42. Inchauste, G., and D. G. Victor, eds. 2017. The Political Economy of Energy Subsidy Reform. Washington, DC: World Bank Group. Jiang, Z., and J. Tan. 2013. “How the Removal of Energy Subsidy Affects General Price in China: A Study Based on Input–Output Model.” Energy Policy 63: 599–606. Jiang, Z., X. Ouyang, and G. Huang. 2015. “The Distributional Impacts of Removing Energy Subsidies in China.” China Economic Review 33: 111–22. Lofgren, H., R. L. Harris, and S. Robinson. 2002. A Standard Computable General Equilibrium (CGE) Model in GAMS. International Food Policy Research Institute. https://www.ifpri.org/publication/standard-computable-general-equilibrium-cge-model-gams-0 McKitrick, R. 2017. “Global Energy Subsidies: An Analytical Taxonomy.” Energy Policy 101: 379–85. Metcalf, G. E. 2007. “A Green Employment Tax Swap: Using a Carbon Tax to Finance Payroll Tax Relief.” Brookings Institution. Metcalf, G. E. 2019. “The Distributional Impacts of US Energy Policy.” Energy Policy 129: 926–29. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 151 CGE Analysis of Green Policies in Bangladesh Metcalf, G. E., S. Paltsev, J. Reilly, H. Jacoby, and J. F. Holak. 2008. “Analysis of US Greenhouse Gas Tax Proposals.” No. w13980. National Bureau of Economic Research. Morris, D. F., and T. Sterner. 2013. “Defying Conventional Wisdom: Distributional Impacts of Fuel Taxes.” Mistra Indigo Policy Paper 3. Paltsev, S., J. Reilly, H. Jacoby, A. Gurgel, G. Metcalf, A. Sokolov, and J. Holak. 2007. Assessment of U.S. Cap-and-Trade Proposals. MIT Joint Program on the Science and Policy of Global Change Report 146 (April). Perali, F., and P. L. Scandizzo, eds. 2018. The New Generation of Computable General Equilibrium Models: Modeling the Economy. Springer. Poterba, J. M. 1989 (Last revised: April 28, 2023). “Lifetime Incidence and the Distributional Burden of Excise Taxes.” NBER Working Paper No. w2833. Rao, N. D. 2012. “Kerosene Subsidies in India: When Energy Policy Fails as Social Policy.” Energy Sustain Dev 16 (1): 35–43. Rausch, S., G. E. Metcalf, and J. M. Reilly. 2011. “Distributional Impacts of Carbon Pricing: A General Equilibrium Approach with Micro-data for Households.” Energy Economics 33: S20–S33. Robinson, S., A. Yùnez-Naude, R. Hinojosa-Ojeda, J. D. Lewis, and S. Devarajan. 1999. “From Stylized to Applied Models: Building Multisector CGE Models for Policy Analysis.” The North American Journal of Economics and Finance 10 (1): 5–38. Sadeque, Z., and M. Bankuti, 2017. “A Bottom-up Financial Model of Power Generation in Bangladesh.” Background Paper. Washington, DC: World Bank. Sánchez-Triana, E., J. Ruitenbeek, S. Enriquez, and K. Siegmann, eds. 2019. Opportunities for Environmentally Healthy, Inclusive, and Resilient Growth in Mexico’s Yucatán Peninsula. Washington, DC: World Bank. Scandizzo, P. L. 2021. “Impact and Cost–Benefit Analysis: A Unifying Approach.” Journal of Economic Structures 10 (1): 1–13. Scandizzo, P. L., and C. Ferrarese. 2015. “Social Accounting Matrix: A New Estimation Methodology.” Journal of Policy Modeling 37 (1): 14–34. Schaffitzel, F., M. Jakob, R. Soria, A. Vogt-Schilb, and H. Ward. 2020. “Can Government Transfers Make Energy Subsidy Reform Socially Acceptable? A Case Study on Ecuador.” Energy Policy 137: 111120. Solaymani, S., and F. Kari. 2014. “Impacts of Energy Subsidy Reform on the Malaysian Economy and Transportation Sector.” Energy Policy 70: 115–25. Symons, E. J., S. Speck, and J. L. R. Proops. 2002. “The Distributional Effects of Carbon and Energy Taxes: The Cases of France, Spain, Italy, Germany and UK.” European Environment 12: 203–12. Timilsina, G. R., and S. Pargal. 2020. “Economics of Energy Subsidy Reforms in Bangladesh.” Energy Policy 142: 111539. Timilsina, G. R., S. Pargal, M. E. Tsigas, and S. Sahin. 2018. “How Much Would Bangladesh Gain from the Removal of Subsidies on Electricity and Natural Gas?” Policy Research Working Paper 8677. Washington, DC: World Bank. Weitzman, M. L. 1976. “On the Welfare Significance of National Product in a Dynamic Economy.” The Quarterly Journal of Economics 90 (1): 156–62. Yusuf, A. A., and B. P. Resosudarmo. 2008. “Mitigating Distributional Impact of Fuel Pricing Reform.” ASEAN Economic Bulletin 25 (1): 32–47. Official sources: Bangladesh Statistical Yearbook Report 2020, BBS publication 2020. Bangladesh Environmental Statistics Report 2020, BBS publication 2020. Bangladesh National Conservation Strategy Report 2016, GoB and IUCN 2016. Household Income and Expenditure Survey Final Report (HIES 2016), BBS, 2016. Road Map and Action plan for Implementing Bangladesh NDC, MoEFCC 2016. Poverty maps of Bangladesh, 2016, BBS and WFP, 2016. Bangladesh Disaster-Related Statistics Report, 2020, BBS, 2020. Bangladesh Delta Plan 2100 Report, 2018, GED Ministry of Planning, 2018. River Water Quality Report, 2015, MoEFCC, 2015. Surface and Groundwater Quality Report, 2016, MoEFCC, 2016. Bangladesh Bureau of Statistics (BBS) data. Ministry of Agriculture data. Ministry of Environment, Forest and Climate Change (MoEFCC) data. Ministry of Water Resources data. Labor Force Survey 2016–2017. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 152 CGE Analysis of Green Policies in Bangladesh Endnotes 63 The experiments are all performed under the assumption of a Keynesian closure—that is, the hypothesis of structural unemployment of part of the labor force and corresponding wage rigidity. 64 This literature review included the following studies: Acharya and Sadath (2017); Amin and Renstro (2018); Bresinger et al. (2019); Dartanto (2013); Elshennawy (2014); Glomm and Jung (2015); Griffin et al. (2016); Hong et al. (2013); Jiang and Tan (2013); Jiang et al. (2015); Shaffitzel et al. (2020); Solymani and Kari (2014); Timilsina and Pargal (2020); Timilsina et al. (2018); and Yusuf and Resosudarmo (2008). A recent study by Timilsina and Pargal (2020) for Bangladesh applied a CGE model to study the impact of the removal of price subsidies on electricity and natural gas. They considered four alternatives of funds reallocation with resulting positive impacts across the country’s economy. Their simulations included a 33 percent reduction of the electricity subsidized price and an increase in the domestic retail natural gas price to align it with the international price, bringing the weighted average price to 8.51 $/GJ. These price changes were combined with four redistribution schemes: (a) an excise tax reduction, where the savings were used to cut all other excise taxes on goods and services; (b) a cut in income taxes, where savings were used to reduce the income taxes on households and firms; (c) a lump-sum transfer, where savings were used to increase households’ disposable income; and (d) an investment program, where savings were used to invest directly in the economy to increase capital stock. Without redistribution, they found an increase in price of energy intensive goods and services and, consequently, negative effects on producers and consumers. With redistribution, the gross output and demand for all the four schemes of redistribution improved. The highest GDP increase occurred with the investment program, while the lowest increase was under the lump-sum scheme. 65 Lump-sum payments may be based on government transfer to the poor (G2P) that exploit existing financial networks of pension and relief payments and public work guaranteed schemes to transfer cash income by incurring in minimal efficiency costs. These programs include direct income supplements, as in China for people below the poverty line (Bankable Frontier Associates 2006, 2008, 2009), or workfare programs that create jobs to alleviate unemployment and help smooth income (del Ninno, Subbarao, and Milazzo 2009). For example, India’s National Rural Employment Guarantee Scheme made payments to 45 million poor people working on rural construction programs during fiscal year 2008–2009 (Ministry of Rural Development 2009). Since 2008, Bangladesh has also launched a program guaranteeing 100 days of employment for the poor each year (Reuters, September 15, 2008). More recently (2020), G2Ps have been advocated as an effective policy measure to contain the devasting social effects of the COVID-19 pandemic. For example, a paper of the United Nations Development Programme (UNDP), entitled “Temporary Basic Income: Protecting Poor and Vulnerable People in Developing Countries,” suggests that giving cash to the poorest 2.8 billion people in 132 developing countries would help contain the spread of the infection and provide substantial relief to the poor. 66 Following Weitzman (1976), GDP can be considered equivalent to a measure of efficiency if valued at shadow prices. 67 In the no-distribution scenario, while government expenditure is endogenous, the reduction of the deficit is not necessarily a benefit if the growth rate of the economy is above the interest rate on public debt. However, debt sustainability and future income trade-offs would depend on how exogenous variables evolve as well as on the efficiency of government expenditure. 68 Externalities include damages due to loss of forest and loss of output of other sectors (agriculture and industry) due to flooding. 69 The technical appendix presents sector details of the simulations. 70 Bangladesh CO2 Emissions - Worldometer (worldometers.info) 71 While institutional arrangements may be different (in terms of sectors, ways to implement the prices in different circumstances, and penalty levels and enforcement costs), carbon-price instruments are ultimately all taxes from an economic point of view. For example, a tax on fuels is implicitly a tax on emissions, while a tax on emissions has an equivalent tax impact on fuel. An ETS is a tax with its rate conditional to the trading and emission permits acquired at the government’s minimum auction price. If these are zero, as it was recently in California, an ETS is just a tax. 72 As for subsidy removal, the long-run impact of higher income revenues could be positive both because of higher financial sustainability of government debt and because of a lower burden of taxation on future generations. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 153 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management CHAPTER 8. ADDRESSING PLASTIC POLLUTION IN BANGLADESH THROUGH INTEGRATED SOLID WASTE MANAGEMENT 8.1 Introduction Waste management is a growing issue given Bangladesh’s 0.28 kilograms of waste per capita per day. This is far lower than the global (0.74 kilograms/capita/day) and regional averages (0.52 kilograms/capita/day) (Kaza et al. 2018). However, a large popula- tion and inadequate waste management mean high waste accumulation in the environment. Moreover, Bangladesh’s waste production is expected to double by 2050, putting further pressure on waste management and the environment (Geyer, Jam- beck, and Law 2017). Although plastic represents around 10 percent of the solid waste composition (World Bank 2021b), in Ban- gladesh, it poses a serious threat to the environment. Plastic waste is burned and openly dumped together with other solid waste streams. This leads to the enormous generation of mismanaged plastic waste and a mounting pollution crisis: The waste accumulates on land, the banks and beds of waterways and clogging drains, polluting ecological systems. This often leads to increased flooding and river pollution and creates health risks such as vector-borne diseases and respiratory illnesses from waste burning. Since rivers discharge into the sea, plastic pollu- tion in waterways is directly linked to marine pollution. Recycling of plastics in Bangladesh is mostly informal and unregulated, posing challenges and also opportunities to provide the base for a strong and inclusive circular economy. Technical and financial support to improve the reliability, scale, structure, and linkages with regional and global markets needs to be in place to further develop this sector. However, proper disposal and integrated waste management remain the key solution to address the plastic pollution problem. This requires investment and institutional capacity building supported by a strong policy framework. (See figure 8.1 and box 8.1.) Figure 8.1 Waste composition in Dhaka South City Corporation (DSCC), 2020 | Percent Others 2.73% Rags 0.73% Food and vegetables 82.45% Glass 0.93% Paper 2.93% Plastic 10.00% 0.00% 20.00% 40.00% 60.00% 80.00% 100.00% Source: Figure reproduced with modifications from World Bank (2021b) Note: The figure shows the waste composition at the source and the waste composition at disposal (landfilled waste). This chapter provides an overview of the impacts of pollution and elements of Bangladesh’s current plastic waste management system. The chapter also outlines the key policy recommendations that complement the Multisectoral Action Plan for Sustain- able Plastic Management in Bangladesh (World Bank 2021b) to support the transition towards circular economy and integrated waste management. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 154 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Box 8.1 Plastic waste is labeled as hazardous Since 2019, the Protocol on Liability and Compensation for Damage Resulting from Transboundary Movements of Hazard- ous Wastes and their Disposal of the Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and their Disposal considers some types of plastic waste as hazardous. Plastic waste that is destined for recycling in an en- vironmentally sound manner and almost free from contamination is presumed not to be hazardous. Thus, any mixtures of plastic wastes consisting of polyethylene (PE), polypropylene (PP), or polyethylene terephthalate (PET) that is not disposed in an environmentally sound manner is considered hazardous under the Basel Convention. Source: UNEP 2019. 8.2 Plastic waste consumption and disposal in Bangladesh Plastics are an integral and ubiquitous part of economic activity, waste generation, and modern life across Bangladesh. The qual- ities that make plastic useful—lightness, durability, strength, versatility, and low production costs—have resulted in fast-growing demand (Worm et al. 2017). With rapid growth and urbanization, Bangladesh’s annual per capita national consumption of plas- tics rose over the past fifteen years from 3.0 kg in 2005 to 9.0 kg in 2020 (figure 8.2) (Enayetullah, Sinha, and Khan 2005; World Bank 2021b). Annual plastic consumption rate in Dhaka, the center of Bangladesh’s economic progress and industrialization, is even higher and is estimated to be 22.25 kg per capita.73 Figure 8.2 Per capita plastic consumption in Dhaka and Bangladesh in 2005, 2014, and 2020 25 Per capita plastic consumption 20 15 (kilograms) 10 Bangladesh Dhaka 5 0 2025 2020 Year Source: Figure reproduced with modifications from World Bank (2021b). Households in Bangladesh produce more packaging waste than other types of plastic waste. Households in Dhaka generated over nineteen times as much low-density polyethylene (LDPE) (mainly used for packaging) in 2020 (323 tons per day) as they had in 2005 (16.8 tons per day) (World Bank 2021b). Packaging is responsible for 73 percent of plastic waste in Bangladesh (figure 8.3). Consumption of LDPE packaging increased fivefold in 2020 compared to 2005. At the household level, 40.6 percent of LDPE in waste composition comes from single-use shopping bags. The COVID-19 pandemic has increased the consumption of pack- aging and shopping bags made of LDPE because they were perceived to be safer than reusable options. According to a survey conducted in 2022 to determine plastic-use patterns in communities living near the canals and rivers of Dhaka City, 41 percent of respondents identified plastic bags as their plastic products with maximum use, 23 percent named bottles, and 21 percent used plastic buckets most often (World Bank 2023a). A similar pattern is found in Cox’s Bazar (box 8.2). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 155 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.3 Composition of household plastic waste, 2005 and 2020 | Tons per day 350 323 300 250 Plastic waste generation (tons/day) 200 2025 2020 150 96.9 96.9 100 64.6 47.6 50 34.9 32.3 32.3 16.8 20.4 20.6 18.5 14.69 0 0 LDPE HDPE PET PVC PS PP OTHER Source: Figure reproduced with modifications from World Bank (2021b). Note: LDPE = low-density polyethylene, HDPE = high-density polyethylene, PET = polyethylene terephthalate, PVC = polyvinyl chloride, PS = polystyrene, and PP = polypropylene. Box 8.2 Plastic consumption and disposal in Cox’s Bazar A qualitative survey and field observations of over 80 stakeholders in Cox’s Bazar, including businesses, customers, and government entities, indicated that single-use plastic cups, water bottles, and polyethylene bags were the most frequently used plastic products. The respondents reported using plastic due to its affordability, light weight, and durability. Hotel representatives reported using personal care products and cleaning materials. Those in the food-service business reported using food packaging. Customers used polyethylene bags and single-use food packaging, such as cups and cutlery, as well as personal-care products like soap and toothpaste packaging. The primary waste-disposal methods in Cox’s Bazar include open dumping and burying of waste, followed by segregating, littering, burning, and rarely, recycling. Source: World Bank 2023c. Most plastic waste generated in Bangladesh is not adequately managed. Of the 977,000 tons of plastic waste generated an- nually in Bangladesh, almost 70 percent is disposed of along roadsides, riverbanks, open dumpsites, illegally littered, or openly burned (World Bank 2021b). In 2022 in the capital Dhaka, 33 percent of plastic waste was openly dumped, 8 percent openly burned, 7 percent buried in the ground, and 3 percent disposed in nearby waterbodies, such as rivers, canals, drains, and ponds. Only 31 percent of plastic waste was managed by city corporations and other waste collectors (figure 8.4) (World Bank 2023a). Rural areas have lower collection coverage, estimated to be half that of an aggregate urban rate (Kaza et al. 2018). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 156 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.4 Plastic waste disposal methods in communities living near rivers and canals around Dhaka City 3% 3% 7% Open Places 8% Locations designated by city corporation 32% Burning in the ground 16% City corporation/waste disposal collectors Open burning Nearby waterbodies 31% Other Source: World Bank 2023a. Approximately 47,000 tons of plastic pollution was identified in terrestrial and riverine environments at 43 sites around Dhaka City (figure O.1 in appendix O). Plastic items identified include personal-care products, building materials, automobile compo- nents, medical equipment, food packaging, marine sourced-goods, furniture, and other items (World Bank 2023a). 8.3 Plastic pollution through abandoned, lost, or otherwise discarded fishing gear (ALDFG) The fishery sector is highly important in Bangladesh, with about 1.2 million people employed through inland fishing and 300,000 employed in marine fishing. Approximately 40,774 vessels spend approximately 201 days/vessel/year fishing with 360 kilograms of gear on average per vessel. The types of fishing gear commonly used in Bangladesh include demersal or bottom trawling fishing gear, fish aggregating devices, gillnets, handlines, longlines, pole and line, purse seines, set bags, and surrounding nets. As gear becomes compromised, it may become abandoned, lost, or otherwise discarded (ALDFG). A new pilot program has begun to promote gender-equitable ALDFG recycling programs in Bangladesh’s coastal communities (box 8.3). Bangladesh produced over 6,000 tons of ALDGF in 2021 (table 8.1) (World Bank 2023b). Although not apparent from the num- bers, many fishers in Bangladesh are in small commercial and artisanal fisheries that use monofilament gillnets. Monofilament gillnets snag and entangle easily. Thus, this gear is frequently discarded or otherwise disposed of. Reasons for ALDFG events vary and include theft (31 percent), oceanic/meteorological/weather conditions (26 percent), gear conflict/shipping interactions (6 percent), snagging (4 percent), and other/unspecified (31 percent) (World Bank 2023b). Table 8.1 Number, quantity (by weight), and value of ALDGF in Bangladesh in 2021 Measure Amount Number of ALDFG events per vessel 6 Total number of ALDFG events 237,018 Quantity of ALDFG from all vessels (tons) 6,085 Fraction of ALDFG compared to total gear onboard all vessels (%) 41% Cost of replacing ALDFG from all vessels ($) 72,383,573 Value of ALDFG compared to total value of gear onboard all vessels (%) 54% Source: World Bank 2023b. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 157 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Box 8.3 Piloting gender equitable value chains for recycling fishing nets in coastal communities in Bangladesh Obsolete fishing nets in Bangladesh are discarded into the river and sea, buried in the ground, thrown into a pond or ditch, or used as an alternative to fuelwood. A study conducted in 2022 identified a discarded net density near the seashore and in riverbanks of 2.48 items/m2 in Charfesson and 0.91 items/m2 in Cox’s Bazar. All types of discarded nets consisted of Nylon-6, which indicates that there are good prospects for establishing net recycling into yarn in coastal communities in Bangladesh. International recycling markets explored focus on recycling the nets into yarn. The global nylon market is growing and ex- pected to reach $30 billion by 2026 with a compound annual growth rate of 3.3 percent. To reduce the amount of ALDFG ending up in the environment, opportunities to create new, gender-equitable fishing-net recycling in Bangladesh are being explored in the international and local markets. The current fishing sector and local repair/ repurposing sector are primarily run by men so new recycling opportunities could also pose opportunities for furthering gender equity. Source: World Bank 2023d. 8.4 Impacts of plastic pollution Plastic waste and pollution have far-reaching economic, ecological, and health implications (figure 8.5). Single-use plastic pack- aging (especially polyethylene bags) increases waste accumulation and blockages in drainage systems, impeding the unob- structed flow of rainwater. In the last few decades, especially 9during monsoons, plastic waste blocking drainage systems has become a “risk multiplier” for flooding (McVeigh 2023). Local authorities incur significant costs in conducting cleanup operations. For example, the Dhaka Water Supply and Sewerage Authority (Dhaka WASA), which is responsible for managing sewers in Dha- ka, spent $23 million in 2018 to clean up city sewers, including the emergency excavation of 25 kilometers of canals and clearing 290 kilometers of drains (Molla 2018). Several studies indicate strong linkages between plastic trash and mosquito vector-borne diseases including dengue, malaria, and chikungunya infections, especially in countries and communities where trash collection, disposal, and management frame- works are in their nascent stage (Khan et al. 2023; Maquart et al. 2022). A study conducted in Kolkata shows that household wastes in urban and rural areas—mostly plastic waste—create favorable breeding environments and habitats for mosquitoes74 and are reservoirs for pathogens (Banerjee et al. 2015; Maquart et al. 2022). Between 2018 to 2023, the number of reported cases of dengue infection increased by nearly sevenfold, and mortality grew by 80.77 percent (WHO 2023). This has economic impli- cations: Studies show that the societal cost75 of treating one dengue episode in Bangladesh, including household and provider costs, was BDT 39,893 ($479) (Sarkar 2021). Plastic waste retained by aquatic vegetation and hydro-morphological processes in river and canal beds affects navigability and impedes dredging operations (Chowdhury et al. 2020). Since the inception of the dredging activities in the Karnaphuli River between 2018 and 2021, the amount of waste in the river increased from 42 lakh to 51 lakh per cubic meter, of which the layer of plastic and polythene ranged between two to 10 meters (Ali 2021; Dey 2020). Consequently, the project’s cost increased from BDT 2,580 million to BDT 3,210 million in 2021 (Ali 2021; Dey 2021). The Bangladesh Inland Water Transport Authority noted a similar situation in Barisal where layers of plastic waste stalled dredg- ing operations, which may lead to reduced navigability (Ghosh 2020; Parker 2023). Open dumping of waste occupies valuable agricultural land, while finding new sites for waste treatment and disposal facilities becomes increasingly difficult in a land-scarce country like Bangladesh. Scattered dumping of waste also drives the market and real estate values downward and negatively affects tourism and local economic development (World Bank 2021). Plastic pollution threatens Bangladesh’s water quality and food safety by generating microplastics, adsorbing other pollutants, and leaching plastic additives. Microplastics76 are plastics less than 5 millimeters in size, and nano-plastics are less than 1 micron in size. Microplastics also contain chemical additives that can leach into water and soil (Groh et al. 2019; Hermabessiere et al. 2017; Li et al. 2016; Wiesinger et al. 2021). Furthermore, microplastics accumulate other environmental pollutants, such as heavy metals and persistent organic pollutants (Rochman et al. 2013b; 2014), that can be transferred to fish and result in physiological stress (Rochman et al. 2013c). Aquatic animals routinely consume microplastics, which can threaten animal health and food safety. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 158 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Microplastics are widespread pollutants that are found in ecosystems and wildlife in Bangladesh. Analyses of different species of fish collected from the Bay of Bengal (Khan and Setu 2022) and the rivers around Dhaka (World Bank 2023a) show the presence of microplastics in aquatic animals inhabiting the riverine ecosystems as well as shallow coastal water, nearshore, and offshore areas (Hossain et al. 2019). Brown and Tiger shrimp from the Northern Bay of Bengal have also been noted to contain microplas- tics (Islam et al. 2022). About 35 percent of the commonly consumed fish rui or rohu (Labeo rohita) and 2 percent of sharputi (Puntius sarana) had mi- crobeads present in the gut (reviewed in Chowdhury et al. 2021). Furthermore, 100 percent of the 35 commercially-valuable Hilsa shad (Tenualosa ilisha) sampled from the Meghna River estuary in the Bay of Bengal had microplastics in the gastrointestinal tract. Hilsa had a range of 7 to 51 particles per fish—on average 19 microplastics (Siddique et al. 2022). For dried fish, a similar story unfolds. These findings are pertinent given that fish consumption is high in Bangladesh. Microplastic pollution concentrations vary depending on the season. A detailed study conducted in 2022 to quantify microplas- tics in the surface waters and sediments of rivers and canals around Dhaka City highlighted aquatic microplastic pollution con- centrations varying across time and geographies. In September, October, and November 2022, 51 samples total, each consisting of 200 liters of water, were analyzed from four rivers (Buriganga, Balu, Turag, and Dhaleshwari) around Dhaka City (figure 8.6 and shown in map in appendix L). Samples were collected in river and canal waters using a plankton net with a 300μm mesh size. Figure 8.5 Impacts of plastic pollution INCREASES DRAINAGE CON- CONTRIBUTES TO DAMAGES TO DAMAGES TO PUBLIC HEALTH GESTION/FLOODS IMPACTS AIR POLLUTION MARINE SPECIES Creates favorable breeding Blocks river channels canals Plastic burning releases Marine animals are environment for mosquito vec- & drainage systems toxic substances and physically harmed at risk tor-borne diseases including den- greenhouse gas (GHG), of the toxic effects of the gue, malaria, and chikungunya. Massive clean-up costs source of PM2.5 emissions chemicals in plastics Chemicals in plastic can increase the risks of diabetes, heart disease, birth defects, early puberty etc IMPACTS ON NAVIGABILITY and occupational health risks for OF RIVERS women. Plastic in river and canal beds impacts navigability IMPACTS ON TOURISM and impedes dredging Contaminates beaches operations and marine ecosystems, marine debris decreases the aesthetic quality and causes economic losses to CAUSE OF SOIL POLLUTION local toursim. Plastics/Microplastics can change soil physico-chem- CAUSE OF GHG ical properties and alter EMISSIONS microorganisms PLASTIC GHG emission at every stage of life cycle POLLUTION Source: World Bank. Microplastics flakes and fragments are the dominant shape of microplastics in sediments, while foam and line are infrequently observed. Microplastics undergo deposition into sediments and have been documented in concentrations with over 1,000,000 fragments and flakes per kilogram of sediments from the Buriganga, Balu, Turag, and Dhaleshwari Rivers combined in Novem- ber and September of 2022 (figure 8.7). In brief, sediments were collected using a grab sample and 1000 mg subsamples were to quantify microplastics. A greater number of microplastics (by count) were observed in sediments as compared to surface waters, likely due to the density of microplastics and increased density due to biofouling over time (Law 2017; De-la-Torre et al. 2023). On average, the greatest number of microplastics were found in September (approximately 250,000 particles), followed by November with 232,000 particles, and lastly October (approximately 147,000 particles). The greatest number of microplastics, 460,700, were observed in sediments upstream of Buriganga River, also in October 2022. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 159 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Microplastic fragments, fibers, foams, flakes, and lines have been documented in sediments in rivers and canals in Dhaka City, Bangladesh, and surface waters of the Bay of Bengal, with expected effects on resident animals, microbial communities, and nutrient cycling. Further research is needed to understand the effects of microplastics on sediment ecosystems in Bangladesh; however, we can draw conclusions on laboratory- and mesocosm-based studies. Organisms living in sediments or benthic areas, such as crustaceans, polychaetes, and bivalves, may consume microplastics if they are of the appropriate size, density, and chemical composition (reviewed in Van Cauwenberghe et al. 2015). Microplastics are known to alter sediment microbial communities and can even inhibit or promote nitrogen cycling depending on the type of plastic contaminating the sediment (Seeley et al. 2020). Figure 8.6 Microplastics found in the surface waters of rivers around Dhaka City | Particles per liter Dhaleshwari River - Upstream Balu River - Upstream Dhaleshwari River - Downstream Balu River - Downstream Buriganga River - Upstream Turag River - Upstream Buriganga River - Downstream Turag River - Downstream Source: World Bank 2023a. Figure 8.7 Microplastics found in the sediments of rivers around Dhaka City | Particles per kilogram of sediments Balu River - Upstream Balu River - Downstream Turag River - Upstream Turag River - Downstream Dhaleshwari River - Upstream Dhaleshwari River - Downstream Source: World Bank 2023a BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 160 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Microplastics are also widespread in terrestrial soil systems globally, and further research on microplastic quantification and envi- ronmental consequences in Bangladesh is needed (Chowdhury et al. 2021; Hossain et al. 2021). As is the case in the aquatic envi- ronment, microplastics in soil can enter the terrestrial food web, potentially resulting in toxicity to plants and animals (Kaur, Singh, and Singh 2022). Microplastics can also change soils’ physico-chemical properties, such as porosity, water-holding capacity, bulk density, function, and structure (De Souza Machado et al. 2022; Kaur, Singh, and Singh 2022). The direction of the alteration, such as increasing or decreasing water-holding capacity, varies based on the type of plastic present (De Souza Machado et al. 2022). Furthermore, microplastics alter the microorganisms, such as bacteria and fungi, in the soil, and can inhibit key enzyme activity in nutrient cycling (Kaur, Singh, and Singh 2022). In addition to affecting aquatic and terrestrial environments, plastic waste can result in significant air pollution, especially when plastic waste is openly burned. Burning plastics releases toxic substances and greenhouse gas (GHG) emissions that contribute to climate change. Humans are exposed to plastic-associated pollutants via many pathways, including inhalation, dermal exposure, and ingestion of contaminated food and water. The open burning of municipal solid waste (including plas- tic waste) is a major source of PM2.5 emissions in Dhaka (see chapters 2 and 4). Plastics and especially additives associated with plastics are known to have many adverse physical and chemical effects on the food web, including inhibition of plant growth, broken nutrient pathways, animals choking, impaired foraging, and chemical uptake in both plants and animals (World Bank 2020). Box 8.4 Plastic pollution disproportionately impacts women Women play a key role in all aspects of waste generation and management, from shopping and selection of products to waste picking and employment in waste management. Women in communities without proper waste collection face dis- proportionate risks in trying to manage waste on their own. Universal waste collection remains challenging, especially since many of the proposed solutions to plastic waste pollution do not incentivize the collection of some of the most hazardous types of plastic. Women tend to burn piles of household waste, which is linked to serious health concerns, such as exposure to the extremely carcinogenic compound dioxin (UNEP 2021). Women are also at risk of gender-based violence (GBV) when trying to find hidden or distant places to dispose of waste (GA Circular 2019). Specific occupational health risks are also pres- ent for women (particularly pregnant women) who work with plastic waste or live in communities where plastic waste is ille- gally disposed of and openly burned. Bisphenol A (BPA) is found in many types of hard plastics and is known as a hormone disruptor. It is known to increase the risks of diabetes, heart disease, birth defects, early puberty, and elevated levels of certain liver enzymes. Plastics marked as BPA-free still often contains some hormone-disrupting chemicals (Stann 2020). Women who have everyday contact with BPA from plastics have an increased risk of miscarriage, polycystic ovarian syndrome (which is known to cause infertility), baldness, and breast cancer (Cariati et al. 2019). Source: World Bank 2023f. Beyond significant local impacts, mismanaged plastic waste is a major source of marine litter (Jambeck et al. 2015). Reports suggest that the Bay of Bengal is one of the largest and most important marine ecosystems (Elayaperumal, Hermes, and Brown 2019). The Bay of Bengal receives water from the Ganges-Brahmaputra system and is at extreme risk from plastic pollution (IOC-UNESCO and UNEP 2016). While twenty percent of the estimated marine plastic pollution originates from sea-based ac- tivities, the rest leaks from land-based sources. The Ganges-Brahmaputra basin is the second-highest contributor of plastic pollution to the marine environment due to the combination of large tributaries, heavy rainfall, and large populations along their banks (Lebreton et al. 2017). Environmental impact quantification on the cost of environmental impacts caused by plastic waste in Bangladesh using Life Cycle Assessment (LCA) with focuses on end-of-life system boundaries shows that mismanaged plastic waste (unsanitary land- filling, rivers, and drains) causes as much as $45 million in environmental degradation costs (figure 8.8). The analysis considers baseline study estimates of 2020, which show 30 percent of plastics undergo recycling in Bangladesh (World Bank 2021b); this recycling allows to avoid nearly $108 million of environmental degradation costs (detailed methodology in appendix L2). Results show that mismanaged plastic packaging and non-packaging plastics present the greatest costs (99 percent of all plastic waste). Freshwater ecotoxicity presents the greatest fraction of costs (93 percent). Figure 8.9 shows that the recycling of plastics leads to savings of $300 to $1,104 per ton of plastic (figure 8.9). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 161 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.8 Environmental impact costs of plastics in Bangladesh in one year per impact category using Life Cycle Assessment (LCA) assessment | In $ (2022 value) Source: World Bank. Note: Five impact categories had extreme impact numbers: Either too low or too high in all four waste-treatment/disposal methods; therefore, these impacts were excluded from the results. They are (a) ionizing radiation, ecosystem quality; (b) water availability, freshwater ecosystems; (c) water availability, terrestrial ecosystems; (d) water availability, human health; and (e) thermally polluted water. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 162 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.9 Environmental impact costs of plastics in Bangladesh in one year per type of plastic | In $ (2022 value) Unsanitary landfill Recycling Khals/rivers Drains unserved areas Source: World Bank. Note: Five impact categories had extreme impact numbers: Either too low or too high in all four waste-treatment/disposal methods; therefore, these impacts were excluded from the results. They are (a) ionizing radiation, ecosystem quality; (b) water availability, freshwater ecosystems; (c) water availability, terrestrial ecosystems; (d) water availability, human health; and (e) thermally polluted water. 8.5 Governance of waste management Bangladesh has developed a legal framework for waste management that includes comprehensive laws and regulations. The time- line below (figure 8.10) presents a summary of the policies and regulations most relevant to the plastic supply chain in Bangladesh. In 2021, the MoEFCC adopted the Solid Waste Management Rules (SWMR) under the 1995 Environment Conservation Act (ECA), setting forth the mandates, principles, and overarching standards for solid waste management in Bangladesh. The SWMR 2021 created the National Solid Waste Management Coordinating Committee (NSWMCC) consisting of high-level representatives from the MoEFCC; line agencies such as the Ministry of Agriculture; Ministry of Finance; Ministry of Housing and Public Works; Ministry of Industries; Ministry of Local Government, Rural Development and Cooperatives; city corporations; academia; NGOs; Federation of Bangladesh Chambers of Commerce and Industry, and plastic manufacturers and importers. The rules require lo- cal governments to develop comprehensive SWM plans, covering waste reduction, reuse, and recycling (3R), following a national strategy and guidelines that still need development. The plans must be approved by the National Committee. Local governments must also submit annual reports to the National Committee. The SWMR 2021 requires separating solid waste at source into three categories: biodegradable, nonbiodegradable, and hazardous solid waste. The rules refer to the extended producer responsibility (EPR) (box 8.5) principle and include standards for composting, refined exudation, solid-waste incinera- tion, landfill requirements, and criteria for converting waste to fuel. The SWMR has appointed a National Coordination Commit- tee (NCC) as the oversight body and authorizes the NCC to frame and update the EPR guidelines. Box 8.5 Piloting an extended producer responsibility (EPR) scheme for e-waste in Bangladesh Electronic waste, referred to as e-waste, is frequently hazardous to human and environmental health due to the presence of toxic components such as lead and mercury. E-waste management in Bangladesh is not highly regulated and reliant on the informal sector. Although data specific to Bangladesh are sparse, an estimated 11 percent of e-waste is plastic (Wath, Dutt, and Chakrabarti 2011). A pilot under the World Bank funded Bangladesh Environmental Sustainability and Transformation Project (BEST) is under- way to develop a voluntary extended producer responsibility (EPR) system for e-waste. This program is led by the Depart- ment of Environment, Government of Bangladesh, with participation by key stakeholders in Dhaka. The goal of the pilot project is to test the e-waste collection system, recycle the e-waste at the Bangladesh Hi-Tech Park Authority, and use key findings regarding barriers and bottlenecks to inform the development of a scaled-up EPR system. The e-waste products that will be the focus of the pilot project include mobile phones and desktop/laptop computers. The goal of the pilot project is to divert 5 tons of e-waste from the informal collection system to the Bangladesh Hi-Tech Park Authority recycling center using the EPR collection scheme. Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 163 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Bangladesh was the world’s first country to ban plastic shopping bags through a regulatory order in 2002 under the 1995 Envi- ronment Act. There are indications that the ban was initially successful with a decrease in plastic-bag waste during the following years (Ahmed and Gotoh 2005). Unfortunately, this success appears to have been reversed due to a lack of public awareness, limited enforcement of the legislation, and the absence of cost-effective alternatives to carrier bags made of synthetic polymer (Uddin et al. 2019). According to Islam (2019) and others, the government has been successful in implementing the Jute Packag- ing Act 2010, which mandated the use of jute as a packaging material for essential commodities. In 2020, the Supreme Court of Bangladesh ordered the government to ban the use of single-use plastics (SUPs) in hotels and restaurants in coastal areas within a year to reduce plastic pollution in the Bay of Bengal (Paul 2020). Also in 2021, the MoEFCC endorsed the Action Plan for Sustainable Plastic Waste Management, a blueprint to achieve a plastic circular economy in Bangladesh and to reinforce the 3R strategy (reduce, reuse, recycle) to avoid, intercept, and redesign plastics to achieve a green growth pathway for Bangladesh. The Action Plan acknowledges that plastic management is one of the most complex challenges. There is not one single solution, but rather a holistic, integrated approach based on a mixture of legal, finan- cial, and communication instruments is needed (box 8.6). Additional policies broadly considered in reducing plastic pollution include the 8th Five Year Plan (2021-25) (8FYP), Regulatory Framework for Public-Private Partnerships (2019), River Master Plan (2019), Clean Dhaka Master Plan (2018–2032), and the E-Waste Management Rules (2021). There are several ministries in Bangladesh whose mandates and activities overlap on waste management issues. At the national level, the MoEFCC is responsible for framing policy and laws, while the city corporations and municipalities are responsible for the collection, transportation, and disposal of municipal waste. The governance system for waste management in Bangladesh is presented in figure 8.11. Figure 8.10 Timeline of policies and regulations on waste management in Bangladesh Polythene bag ban 1983 1995 2002 2008 2009 Jute Packaging Act 2017 2015 2013 2011 2010 2018 2020 2020 2021 2021 2021 2022 Source: World Bank 2023. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 164 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Box 8.6 Action Plan for Sustainable Plastic-Waste Management, 2021 Based on extensive multi-stakeholder consultations, the Action Plan identifies four targets focusing on each step of the plas- tic life cycle to ensure a holistic approach built on circular principles and to provide the road map for action, namely: Target 1: Achieve a 30 percent reduction in virgin-material consumption in plastic manufacturing by 2030 by facilitating circular material flows from the 2020/21 baseline; Target 2: Phase out targeted SUPs by at least 90 percent by 2026 from the 2020/21 baseline; Target 3: Reach a 50 percent rate of recycling plastic waste by 2025 and an 80 percent rate of recycling plastic waste by 2030 from the 2020/21 baseline; Target 4: Achieve a 30 percent reduction in annual plastic-waste generation by 2030 from the 2020/21 baseline. Source: World Bank 2021. The Ministry of Environment, Forest and Climate Change (MoEFCC) has the mandate for (a) coordinating and supervising the ap- plication and implementation activities of the SWMR’s provisions; (b) establishing the NSWMCC for the purpose of implementing the SWMR’s provisions; and (c) approving guidelines and directives on solid-waste management framed by the DoE. The DoE is mandated to enforce environmental rules and regulations including those on SWM, promote environmental awareness, imple- ment 3R projects, and provide services to the citizens to ensure a clean and healthy environment. The DoE has enforced the 2002 Plastic Bag Ban through unannounced inspections conducted by mobile (environmental) courts (see chapter 3 of this CEA). The Plastic Bag Ban applies to the use, production, sale, marketing, stocking, distribution, import, and trade of plastic bags. Viola- tion of this ban has been made punishable by imprisonment of up to 10 years and a fine of up to $9,392.75. However, polythene bags for export purposes were exempted. Although the Plastic Bag Ban was enforced well in the first two years of introduction through rigorous market monitoring and the creation of awareness among consumers, implementation of the ban was not necessarily achieved in the long term (Irin 2011). The failure can be attributed largely to a lack of institutional capacity to sustain the momentum, no effective control at the end of production, weakened market monitoring, and limited availability of practi- cal alternatives leading to consumer reluctance. The business sector also must share responsibility for the failure since they not only opposed the ban but also showed little interest in promoting alternatives. According to DoE data, in 2021, 2022, 2023, the mobile courts seized only 125.1, 154.4, and 180.3 metric tons of polyethylene, respectively. This volume is insignificant compared to the total generation of low-density polyethylene (LDPE) in the country, which was 323 tons per day in 2020 (World Bank 2021b). The city corporations and Local Government Institutions (LGIs) provide waste-collection systems, making the Ministry of Local Government, Rural Development and Cooperatives (MLGRDC) another key government stakeholder. The MLGRDC leads coor- dination with local government departments on housing and buildings, regional and rural policy, municipal and city admin- istration and finances, and elections. Local government authorities play an important role in sustainable waste management. According to the SWMR, subnational agencies are responsible for the separate collection and management of nonhazardous solid waste from organic, construction, and demolition sites, and from medical sources. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 165 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.11 Governance structure of integrated sustainable plastic waste management in Bangladesh MINISTRY OF MINISTRY OF LOCAL MINISTRY OF MINISTRY OF WATER MINISTRY OF ENVIRONMENT, GOVERNMENT, RURAL COMMERCE RESOURCES INDUSTRIES FOREST AND DEVELOPMENT AND (MoC) (MoWR) (MOI) CLIMATE CHANGE COOPERATIVES (MOEFCC) (LOID) MOEFCC oversees all LGRD oversees housing and MoC oversees the regulation MoWR advises on legislation, MOl formulates, imple- environmental issue building infrastructures, and implementation of strategies, programs, ments, monitors and up- regional and rural policy dates appropriate industries policies regarding domestic and regulation for water making and implemen- policies and is mandated tation, municipal and city and foreign trade including management to establish, develop and administration and finances; plastic products and recy- regulate eco-friendy and supervises conduct of cled materia safe industrial policies and elections infrastructure BANGLADESH SMALL AND DEPARTMENT OF EXPORT PROMOTION BANGLADESH WATER COTTAGE INDUSTRIES ENVIRONMENT CITY CORPORATIONS BUREAU DEVELOPMENT BOARD CORPORATION (DOE) (EPB) (BWDB) (BSCIC) DOE formulates and enforces OFFICE OF CHIEF CONTROLLER SMALL AND MEDIUM LOCAL GOVERNMENT regulations and rules related OF IMPORT AND EXPORT ENTERPRISE FOUNDATION DIVISION to SWM (CCIE) (SMEF) BANGLADESH STANDARDS SMALL, MICRO AND COTTAGE RURAL DEVELOPMENT AND AND TESTING INSTITUTE INDUSTRY FOUNDATION COOPERATIVES DIVISIONS (BSTI) (SMCIF) BUSINESS PROMOTION COUNCIL Source: World Bank. The responsibilities of waste generators, producers, importers, and other actors have not, however, been spelled out. The Ministry of Water Resources, including the Bangladesh Water Development Board (BWDB), is responsible for water management in the country. The BWDB is responsible for implementing, operating, and maintaining water-related projects (including drainage and cleanups from plastic pollution). The Ministry of Industries (MoInd) and Ministry of Commerce (MoC) also play central roles in promoting circularity and upstream solutions in plastic management. Through the National Plastic Industry Development Policy, 2023 (8th Draft), the MoInd identi- fies measures to reduce the impact of plastic waste and litter; improve the efficiency of plastics recovery, recycling, and product design; and create conditions for investments and innovations in the circular economy while reducing dependency on fossil fuels and exploring alternatives including biobased materials. The policy also endorses EPR requiring manufacturers to take responsi- bility for their product and packaging through all life-cycle stages, including disposal. Bangladesh imports and exports plastic and other relevant materials and products. The MoC oversees the regulation and implementation of policies regarding domestic and foreign trade including plastic products and recycled material in Bangladesh. 8.6 Bangladesh’s plastic economy Bangladesh manufactures plastic for both export and local use.77 The nation’s plastic industry maintains a substantial market size with an estimated value of $5 billion in 2020 (Mourshed et al. 2017). In 2018, imports and exports of plastics were valued at $1.9 billion and $1 billion, respectively (BIDA 2021).78 A range of stakeholders play a role in creating, distributing, using, and managing plastic across its value chain (figure 8.12). The main plastic products used domestically in Bangladesh include packaging such as garment packaging, bags, and hangers; medical products such as blood bags and saline bags; and household items such BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 166 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management as furniture, buckets, and tableware (BIDA 2021; Sultana 2019). The sectors with the highest use of plastic include infrastructure, agriculture, water management, and consumer goods (packaging) (World Bank 2021b). Government supports growth of Bangladesh’s plastic economy. For export diversification, the GoB has identified the plastics industry as a thrust sector. Official data show a 38.77 percent increase in export revenue from plastic products between fiscal 2018/19 and fiscal 2021/22 (EBP 2022). The value of plastics exported by Bangladesh has been expanding at a rate of 4.5 percent per year since 2014 and was valued at around $1 billion in fiscal 2018/19 (BIDA 2021). This $1 billion includes plastic goods as well as deemed export consisting of accessories and materials for the garment sector. The National Plastic Industry Development Policy of 2020 aims for a sector growth of 15 percent per year, raising plastics sector’s contribution in total GDP to at least 2 percent by 2026 (MoInd 2020). Both the Export Policy of 2022 (Ministry of Commerce 2022) and the National Industrial Policy (drafted in 2022) provide signifi- cant support to encourage growth. Export-orientated industries are facilitated with bonded warehouses allowing them to im- port materials with no duty or taxes (National Board of Revenue 1969). The government reduced import taxes for raw materials for plastic manufacturing from 25 percent in 2015 to 5 percent in 2022, while the manufacturers proposed to reduce the import duty on raw materials even more to 1–3 percent (Business Standard 2022). Figure 8.12 Stakeholders active across Bangladesh’s plastics value chain sectors Chemical Convertors, fabricators Producers, brand Waste collectors, Key Consumers companies processors owner, retailers Recyclers Plastics value chain Recycling Raw Monomer Polymer Processing / Marketing & Manufacturing Use Disposal materials production production conversion sales Landfill Interested parties Academia and Trade associations Certification & NGOs / Consumer Public Government research standards Groups Authorities Institutions Highly active and/or influential Sector growing in influence Sector not active or not influential X X sector in Bangladesh X in Bangladesh X X currently in Bangladesh Source: World Bank. Bangladesh has an active plastic-recycling industry, mostly concentrated in Dhaka. Informal recycling units, which consist mostly of small businesses and self-employed persons with little or no legal recognition, low capital investments and widespread collection systems, exist in urban and rural areas. The recycling rate for plastics in Dhaka is 37 percent (World Bank 2021b). In 2022, there were 5,000 plastics-recycling factories in Bangladesh, although only 300 were registered (Chakma 2023; Daily Star 2022; Sultana 2019). The plastic-recycling sector in Dhaka employs almost 5,400 workers (almost 0.3 percent of Bangladesh’s total employment) (World Bank 2021b). A network of feriwalas (collectors); wastebin tokais (youth collectors); bhangari (waste sorting, cutting, and pelletizing enterprises) (figure 8.14); brokers; and mohajans (wholesalers) are involved in collecting, sorting, cutting, and often transporting plastic waste. In Dhaka, there are reported to be about 90,000 active informal waste workers. The sorting is done manually (see figure 8.13), while cleaning, cutting, and pelletizing are done mechanically. This waste is pelletized in more formal industrial complexes most- ly in and around Dhaka and reused in local industries or exported abroad as recycled plastic flakes. The recycling sector faces the following challenges: (a) plastic waste is primarily sorted by product type (for example, bottles and containers) rather than by resin (for example, PP and PET), thereby affecting the quality of the recycled output, making it potentially unsuitable for some applications; (b) only 10 percent of recycling facilities have higher quality “hot wash” facilities. The remaining exporters rely on less expensive “cold wash”, which often includes direct use of running river water and which may contaminate plastic and make downstream uses difficult. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 167 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.13 Manual sorting of postconsumer plastic waste in Dhaka, 2023 | Sujat Nagar slum in Dhaka, 2016 Source: ©Nina Tsydenova / World Bank — Dominic Chavez/World Bank. Recycled plastics can be utilized domestically but are mostly exported. The GoB provides a 10 percent cash incentive on the export value of plastic products including recycled PET flakes79 (BIDA 2021). Traditionally, plastic-recycling companies in Bangla- desh have exported the flakes (Sultana 2019). PET recyclers export different types of recycled plastics to Austria, China, India, the Philippines, Taiwan, Thailand, Ukraine, Vietnam, and some European countries at a price that is a much higher than the domestic market (World Bank 2021b). In recent years, the low price of oil has decreased the price of virgin PET flakes, making PET recycling less lucrative in Bangladesh (World Bank 2021b). The global shift in the textile industry—from agro-based to recycled-plastic-based yarns—has provided a unique opportunity for Bangladesh to transition to recycled PET-based textile manufacturing. In 2022, the Bangladesh Textile Mills Association (BTMA) reported that a set of local manufacturers have invested BDT 16.7073 billion to make yarn and fabrics from recycled plastic bot- tles (Apparel Resources 2022; Mridha 2022). Establishing comprehensive recycling systems in Bangladesh encompassing various technologies and materials could result in the development of a domestic recycling market generating an annual revenue of $1.2 billion, which will create approximately 20,000 jobs through introducing new skill-based positions and by formalizing informal jobs in waste management and logistics (McKinsey & Co. 2021). 8.7 Policy recommendations for integrated plastic-waste management Bangladesh faces a serious environmental challenge due to unmanaged plastic waste. To address this issue, the country needs a comprehensive and coordinated strategy that combines legal, financial, and communication measures. This section presents the main policy recommendations for an integrated waste-management framework (including plastic) (figure 8.14). These policy recommendations are consistent with the roadmap developed and the four main targets outlined in box 8.6. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 168 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Figure 8.14 Framework for integrated waste management (including plastic) Public Health – Inclusivity – User Collection & Provider Sound Environment Institutions – Disposal Physical Governance And Proactive Policies 3Rs – Reduce, Financial Reuse, Recycle Sustainability Source: Wilson et al. 2015. The following recommended actions are based on the ongoing analytical work and will require financial resources to support their implementation and enforcement. • Develop an integrated waste-management framework to address the growing problem of plastic and municipal waste over- all. Integrated waste management involves waste collection, disposal, and recovery, as well as stakeholder engagement, poli- cy changes, community-led initiatives, and innovative financing. The framework should also encompass stricter requirements for incineration and improved landfill site management practices. The goal of integrated waste management is transition to a circular economy, where waste is minimized, reused, and recycled, and its environmental and social impacts diminished. • Support research and development on alternatives to single-use plastics, specifically LDPE and PS, in order to eliminate un- necessary plastic packaging and reduce its use by promoting the use of alternative materials. It is important to invest in new plastic materials that are practically biodegradable or compostable, but a detailed comparison of LCA and consumer accep- tance rates should be conducted before introducing any new material. • Develop a strategy to effectively implement the ban on plastic bags and extend its scope to other single-use plastic items. This will require clear definition of the ban’s scope, enforcement, and monitoring; judicial support; access to alternatives; de- velopment of national standards for biodegradable bags; and education and outreach. • Finalize and pilot extended producer responsibility (EPR) guidelines as per SWRM 2021 to enable industry co-funding of plastic-waste collection and recycling systems. This will require the development and effective implementation of the EPR scheme, mechanisms for monitoring and evaluation, defining the budget for the institutions tasked with implementation and enforcement, establishing technical norms and standards supporting the regulation, and conducting the technical stud- ies that underpin the packaging materials used to enhance recycling in the country. • Promote waste segregation at the household level, develop the missing infrastructure, and conduct behavior-change cam- paigns. This will require strategies and awareness-raising campaigns to educate and motivate citizens to sort waste at the house- hold and individual levels. • Harmonize plastic-management policies to promote circular economy. This will require establishing a unified approach to harmonize plastic-pollution control efforts into a cohesive, holistic policy approach, which will address all stakeholders of the plastic value chain and all relevant government agencies. • Review options and develop a strategy to reduce ALDFG pollution and harmonize with ongoing plastic waste policy and management schemes. This will require a review of the current options to reduce ALDFG and integrate it into ongoing efforts to reduce plastic waste in Bangladesh. • Utilize plastic cleanup and recovery schemes to reduce legacy plastic waste and mitigate associated impacts. This will require recovering legacy plastic pollution for waste management and recycling. • Create a monitoring system for SWMR 2021 and targets of the Plastic Action Plan from baseline. This will require the devel- opment of a monitoring framework considering the objectives of the SWMR 2021 and the strategies and targets set in the plastic action plan. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 169 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management C8 References / Endnotes Ahmed, S. U., and K. Gotoh. 2005. “Impact of Banning Polythene Bags on Floods of Dhaka City by Applying CVM and Remote Sensing.” In Proceedings. 2005 IEEE International Geoscience and Remote Sensing Symposium, 2005. IGARSS ’05. 1471–74. Presented at the 2005 IEEE International Geoscience and Remote Sensing Symposium. IGARSS. Seoul, Republic of Korea: IEEE. https://doi.org/10.1109/IGARSS.2005.1525403 Alam, R., Z. Quayyum, S. Moulds, M. A. Radia, H. H. Sara, M. T. Hasan, and A. Butler. 2023. “Dhaka City Water Logging Hazards: Area Identification and Vulnerability Assessment through GIS-Remote Sensing Techniques.” Environ Monit Assess 195: 543. https://doi.org/10.1007/s10661-023-11106-y Allen, A. S., A. C. Seymour, and D. Rittschof. 2017. “Chemoreception Drives Plastic Consumption in a Hard Coral.” Marine Pollution Bulletin 124: 198–205. https://doi. org/10.1016/j.marpolbul.2017.07.030 Apparel Resources. 2022. “Bangladesh Set to Become a Major Source of Recycled Yarn and Fabrics Made from Plastic Bottles: Reports | Apparel Resources.” March 8, 2022. https://apparelresources.com/business-news/sustainability/bangladesh-set-become-major-source-recycled-yarn-fabrics-made-plastic-bottles-reports/ Banerjee, S., G. Aditya, and G. K. Saha. 2015. “Household Wastes as Larval Habitats of Dengue Vectors: Comparison between Urban and Rural Areas of Kolkata, India.” PLoS ONE 10 (10): e0138082. https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0138082 BIDA (Bangladesh Investment Development Authority). 2021. “Plastics Industry.” https://bida.gov.bd/storage/app/uploads/public/616/6c2/ e5d/6166c2e5d02d6789146170.pdf Business Post. 2022. “10% Cash Incentive for Detergent, Melamine Exports Recommended.” https://businesspostbd.com/front/2022-01-26/10-cash-incentive-for- detergent-melamine-exports-recommended#:~:text=The%20government%20provides%2010%20per,to%20the%20Bangladesh%20Bank%20circular. Business Standard. 2022. https://www.tbsnews.net/bangladesh/plastic-makers-demand-tax-cut-better-competitiveness-394766 Cariati, Federica, Nadja D’Uonno, Francesca Borrillo, Stefania Iervolino, Giacomo Galdiero, and Rossella Tomaiuolo. 2019. “Bisphenol A: An Emerging Threat to Male Fertility.” Reproductive Biology and Endocrinology 17 (1). https://doi.org/10.1186/s12958-018-0447 Chowdhury, G. W., H. J. Koldewey, E. Duncan, I. E. Napper, Md. N. H. Niloy, S. E. Nelms, S. Sarker, S. Bhola, and B. Nishat 2021. “Plastic Pollution in Aquatic Systems in Bangladesh: A Review of Current Knowledge.” Science of The Total Environment 761: 143285. https://doi.org/10.1016/j.scitotenv.2020.143285 Coffin, S., 2023. “The Emergence of Microplastics: Charting the Path from Research to Regulations.” Environ Sci Adv 2023 (2): 356–67. doi:10.1039/D2VA00275B Daily Star. 2022. “5,000 Factories Recycling Plastic Waste.” January 12, 2022. https://www.thedailystar.net/star-multimedia/news-multimedia/news/5000- factories-recycling-plastic-waste-2937996. De-la-Torre, G. E., M. B. Romero Arribasplata, V. A. Lucas Roman, A. A. Póvoa, and T. R. Walker. 2023. “Marine Litter Colonization: Methodological Challenges and Recommendations.” Front Mar Sci 10: 1070575. https://doi.org/10.3389/fmars.2023.1070575 Dey, A., B. 2020. “Dredging Karnaphuli: Work Hindered by Plastic Waste.” Daily Star (February 15, 2020). https://www.thedailystar.net/frontpage/news/dredging- karnaphuli-work-hindered-plastic-waste-1868455 Dey, A., B. 2021. “Karnaphuli River: Tk 49cr Extra to Dredge Plastic!”  Daily Star (March 14, 2021). https://www.thedailystar.net/city/news/karnaphuli-river-tk-49cr- extra-dredge-plastic-2060045. Diana, Z., N. Sawickij, N. A. Rivera, H. Hsu-Kim, and D. Rittschof. 2020. “Plastic Pellets Trigger Feeding Responses in Sea Anemones.” Aquatic Toxicology 222: 105447. https://doi.org/10.1016/j.aquatox.2020.105447 Diana, Z., T. Vegh, R. Karasik, J. Bering, J. D. Llano Caldas, A. Pickle, D. Rittschof, W. Lau, and J. Virdin. 2022. “The Evolving Global Plastics Policy Landscape: An Inventory and Effectiveness Review.” Environmental Science & Policy 134: 34–45. https://doi.org/10.1016/j.envsci.2022.03.028 Dijkstra, H., P. van Beukering, and R. Brouwer. 2021. “In the Business of Dirty Oceans: Overview of Startups and Entrepreneurs Managing Marine Plastic.” Marine Pollution Bulletin 162: 111880. https://doi.org/10.1016/j.marpolbul.2020.111880 Elayaperumal, V., R. Hermes, and D. Brown. 2019. “An Ecosystem Based Approach to the Assessment and gGovernance of the Bay of Bengal Large Marine Ecosystem.” Deep Sea Research Part II: Topical Studies in Oceanography 163: 87–95. https://doi.org/10.1016/j.dsr2.2019.01.001 Ellen MacArthur Foundation. 2017. A New Textiles Economy: Redesigning Fashion’s Future. Enayetullah, I., A. H. M. M. Sinha, and S. S. A. Khan. 2005. Urban Solid Waste Management Scenario of Bangladesh: Problems and Prospects. Waste Concern Technical Documentation. Dhaka, Bangladesh. Export Promotion Bureau of Ministry of Commerce. Annual Report 2021–2022. http://www.epb.gov.bd/sites/default/files/files/epb.portal.gov.bd/annual_ reports/639b13d9_c254_4b94_b726_1b8b633a7f73/2022-11-13-08-43-79d5a77e9b37e4121bc62a1d3b7b0080.pdf. Fava, M. F. 2022. “Plastic Pollution in the Ocean: Data, Facts, Consequences.” Ocean Literacy Portal. https://oceanliteracy.unesco.org/plastic-pollution-ocean/. GA Circular. 2019. The Role of Gender in Waste Management: Gender Perspectives on Waste in India, Indonesia, the Philippines and Vietnam. Report commissioned by Ocean Conservancy. https://oceanconservancy.org/wp-content/uploads/2019/06/The-Role-of-Gender-in-Waste-Management.pdf. Geyer, R., J. R. Jambeck, and K. L. Law. 2017. “Production, Use, and Fate of All Plastics Ever Made.” Sci Adv 3 (7). https://www.science.org/doi/10.1126/sciadv.1700782 Ghosh, S. 2020. “Barishal River Port: Plastic Waste Slows Down Dredging Work.” Daily Star (November 18, 2020). https://www.thedailystar.net/city/news/plastic- waste-slows-down-dredging-work-1997489.  GoB (Government of Bangladesh). 2020. Eighth Five Year Plan (2020–2025). https://policy.asiapacificenergy.org/sites/default/files/Eighth%20Five%20Year%20 Plan%20%28EN%29.pdf BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 170 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Groh, K. J., T. Backhaus, B. Carney-Almroth, B. Geueke, P. A. Inostroza, A. Lennquist, H. A. Leslie, M. Maffini, D. Slunge, L. Trasande, A. M. Warhurst, and J. Muncke. 2019. “Overview of Known Plastic Packaging-Associated Chemicals and their Hazards.” Science of The Total Environment 651: 3253–68. https://doi.org/10.1016/j. scitotenv.2018.10.015 Hajkowicz, S. A., K. Tellames, and J. Aitaro. 2005. The Costs of Solid Waste Pollution to Palau: A Consultancy Report to the Office of Environmental Response and Coordination of the Republic of Palau. Brisbane, Australia: CSIRO Sustainable Ecosystems. Hasan, J., S. M. M. Islam, M. S. Alam, D. Johnson, B. Belton, M. A. R. Hossain, and M. Shahjahan. 2022. “Presence of Microplastics in Two Common Dried Marine Fish Species from Bangladesh.” Marine Pollution Bulletin 176: 113430. https://doi.org/10.1016/j.marpolbul.2022.113430 Hermabessiere, L., A. Dehaut, I. Paul-Pont, C. Lacroix, R. Jezequel, P. Soudant, and G. Duflos. 2017. “Occurrence and Effects of Plastic Additives on Marine Environments and Organisms: A Review.” Chemosphere 182: 781–93. https://doi.org/10.1016/j.chemosphere.2017.05.096 Hossain, M. Shahadat, Faisal Sobhan, Mohammad Nasir Uddin, S. M. Sharifuzzaman, Sayedur Rahman Chowdhury, Subrata Sarker, and M. Shah Nawaz Chowdhury. 2019. “Microplastics in Fishes from the Northern Bay of Bengal.” Science of The Total Environment 690. ISSN 0048-9697, https://doi.org/10.1016/j. scitotenv.2019.07.065. IOC-UNESCO (Intergovernmental Oceanographic Commission – United Nations Educational, Scientific and Cultural Organization) and UNEP (United Nations Environment Programme). 2016. “Large Marine Ecosystems: Status and Trends. Summary for Policy Makers.” Nairobi, Kenya: UNEP. Irin. 2011. “Plastics Proliferate Despite Ban.” The New Humanitarian. March 2, 2011. Islam, M. M. 2019. “Exploring Silent Negligence of Jute – The Golden Fiber of Bangladesh: A Historical Perspective.” https://ssrn.com/abstract=3461106 Islam, T., Y. Li, M. M. Rob, and H. Cheng. 2022. “Microplastic Pollution in Bangladesh: Research and Management Needs.” Environmental Pollution 308: 119697. https://doi.org/10.1016/j.envpol.2022.119697 Jagaran, Chakma. 2023. “Reuse of Plastic Waste Growing.” Daily Star (February 26, 2023). https://www.thedailystar.net/business/economy/news/reuse-plastic- waste-growing-3257351. Jahnke, A., H. P. H. Arp, B. I. Escher, B. Gewert, E. Gorokhova, D. Kühnel, M. Ogonowski, A. Potthoff, C. Rummel, M. Schmitt-Jansen, E. Toorman, and M. MacLeod. 2017. “Reducing Uncertainty and Confronting Ignorance about the Possible Impacts of Weathering Plastic in the Marine Environment.” Environ Sci Technol Lett 4: 85–90. https://doi.org/10.1021/acs.estlett.7b00008 Jambeck, Jenna R., Roland Geyer, Chris Wilcox, Theodore R. Siegler, Miriam Perryman, Anthony Andrady, Ramani Narayan, and Kara Lavender Law. 2015. “Plastic Waste Inputs from Land into the Ocean.” Science 347 (6223): 768–71. doi:10.1126/science.1260352. Karasik, R., T. Vegh, Z. Diana, J. Bering, J. Caldas, A. Pickle, D. Rittschof, and J. Virdin. 2020. 20 Years of Government Responses to the Global Plastic Pollution Problem. (No. NI R 20-05). Durham, NC: Nicholas Institute for Environmental Policy Solutions, Duke University. Kaur, P., K. Singh, and B. Singh. 2022. “Microplastics in Soil: Impacts and Microbial Diversity and Degradation.” Pedosphere 32 (1): 49–60. https://doi.org/10.1016/ S1002-0160(21)60060-7 Kaza, Silpa, Lisa C. Yao, Perinaz Bhada-Tata, and Frank Van Woerden. 2018. What a Waste 2.0: A Global Snapshot of Solid Waste Management to 2050. Urban Development. Washington, DC: World Bank. © World Bank. https://openknowledge.worldbank.org/handle/10986/30317 License: CC BY 3.0 IGO. Kershaw, P. J., and C. M. Rochman. 2015. Sources, Fate and Effects of Microplastics in the Marine Environment: Part 2 of a Global Assessment. Reports and Studies. IMO/FAO/Unesco-IOC/WMO/IAEA/UN/UNEP Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) Eng No. 93. Khan, A., Bisanzio, D., and F. Mutuku. 2023. “Spatiotemporal Overlapping of Dengue, Chikungunya, and Malaria Infections in Children in Kenya.” BMC Infect Dis 23: 183. https://doi.org/10.1186/s12879-023-08157-4  Khan, H. M. Shahnewaz, and Nahar Setu. 2022. “Microplastic Ingestion by Fishes from Jamuna River, Bangladesh.” Environment and Natural Resources Journal 20: 1–11. 10.32526/ennrj/20/202100164. Law, K. L. 2017. “Plastics in the Marine Environment.” Annual Review of Marine Science 9: 205–29. https://doi.org/10.1146/annurev-marine-010816-060409 Law, K. L., N. Starr, T. R. Siegel, J. R. Jambeck, N. J. Mallos, and G. H. Leonard.. 2020. “The United States’ Contribution of Plastic Waste to Land and Ocean.” Sci Adv 6: eabd0288(2020). doi:10.1126/sciadv.abd0288 Lebreton, Laurent C. M., Joost van der Zwet, Jan-Willem Damsteeg, Boyan Slat, Anthony Andrady, and Julia Reisser. 2017. “River Plastic Emissions to the World’s Oceans.” Nature Communications 8: 15611. Li, H.-X., G. J. Getzinger, P. L. Ferguson, B. Orihuela, M. Zhu, and D. Rittschof. 2016. “Effects of Toxic Leachate from Commercial Plastics on Larval Survival and Settlement of the Barnacle Amphibalanus amphitrite.” Environ Sci Technol 50: 924–31. https://doi.org/10.1021/acs.est.5b02781 Maquart, P. O., Y. Froehlich, and S. Boyer. 2022. “Plastic Pollution and Infectious Diseases.” Lancet: Planetary Health 6 (10): e842–e845. https://doi.org/10.1016/S2542- 5196(22)00198-X McVeigh, Karen. “Plastic Waste Puts Millions of World’s Poorest at Higher Risk from Floods.” Guardian (May 24, 2023). MoC (Ministry of Commerce). 2022. “Export Policy 2022.” (Gazette notification). http://www.mincom.gov.bd/sites/default/files/files/mincom.portal.gov.bd/ policies/7beeaaf5_e199_41dc_9d65_77ee3aff9cd1/%E0%A6%A8%E0%A7%80%E0%A6%A4%E0%A6%BF%20%E0%A7%A8%E0%A7%A6%E0%A7%A8%E0 %A7%A7-%E0%A7%A8%E0%A7%A6%E0%A7%A8%E0%A7%AA%20(%E0%A6%97%E0%A7%87%E0%A6%9C%E0%A7%87%E0%A6%9F).pdf MoInd (Ministry of Industries). 2020. National Plastic Industry Development Policy 2020 (7th Draft). Molla, M. 2018. “In the Rains, Plastic Bags Are Worsening the Flooding in Bangladesh’s Cities.” https://scroll.in/article/883236/in-the-rains-plastic-bags-are- worsening-the-flooding-in-bangladeshs-cities / BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 171 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Mourshed, M., M. H. Masud, F. Rashid, and M. U. H. Joardder. 2017. “Towards the Effective Plastic Waste Management in Bangladesh: A Review.” Environ Sci Pollut Res 24: 27021–46. https://doi.org/10.1007/s11356-017-0429-9 Mridha, Refayet Ullah. 2022. “Recycling Plastic Bottles to Make Garments.” Daily Star (March 5, 2022). https://www.thedailystar.net/business/economy/news/ recycling-plastic-bottles-make-garments-2976591. Mubin, A.-N., S. Arefin, Md. S. Mia, A. R. Md. T. Islam, A. B. M. M. Bari, Md. S. Islam, M. M. Ali, Md. A. B. Siddique, M. S. Rahman, V., Senapathi, A. M. Idris, and G. Malafaia 2023. “Managing the Invisible Threat of Microplastics in Marine Ecosystems: Lessons from Coast of the Bay of Bengal.” Science of The Total Environment 889: 164224. https://doi.org/10.1016/j.scitotenv.2023.164224 National Board of Revenue. 1969. Customs Act, 1969. Government of Bangladesh. Parker, L. 2023. “Plastic Wastes Dumped in Bangladesh River Hamper Dredging.” DredgeWire. January 11, 2023. https://dredgewire.com/plastic-wastes-dumped- in-bangladesh-river-hamper-dredging/ Paul, R. 2015. “Bangladesh to Ban Use of Single-Use Plastic in Hotels and Restaurants.” https://www.reuters.com/article/us-bangladesh-environment-plastic- idUSKBN1Z51BK Raza, Wameq Azfar, Iffat Mahmud, and Tamer Samah Rabie. 2022. Breathing Heavy: New Evidence on Air Pollution and Health in Bangladesh. International Development in Focus. Washington, DC: World Bank. doi:10.1596/978-1-4648-1919-3. License: Creative Commons Attribution CC BY 3.0 IGO Revel, M., A. Chatel, and C. Mouneyrac. 2018. “Micro(nano)plastics A Threat to Human Health Current.” Opinion in Environmental Science & Health 1: 17–23. Rochman, C. M., B. T. Hentschel, and S. J. The. 2014. “Long-Term Sorption of Metals Is Similar among Plastic Types: Implications for Plastic Debris in Aquatic Environments.” PLoS ONE 9: e85433. https://doi.org/10.1371/journal.pone.0085433 Rochman, C. M., M. A. Browne, B. S. Halpern, B. T. Hentschel, E. Hoh, H. K. Karapanagioti, L. M. Rios-Mendoza, H. Takada, S. Teh, and R. C. Thompson. 2013a. “Classify Plastic Waste as Hazardous.” Nature 494: 169–71. https://doi.org/10.1038/494169a Rochman, C. M., E. Hoh, B. T. Hentschel, and S. Kaye. 2013b. “Long-Term Field Measurement of Sorption of Organic Contaminants to Five Types of Plastic Pellets: Implications for Plastic Marine Debris.” Environ Sci Technol 47: 1646–54. https://doi.org/10.1021/es303700s Rochman, C. M., E. Hoh, T. Kurobe, and S. J. The. 2013c. “Ingested Plastic Transfers Hazardous Chemicals to Fish and Induces Hepatic Stress.” Scientific Reports (Nature Publisher Group) 3: 3263. http://dx.doi.org.proxy.lib.duke.edu/10.1038/srep03263 Rochman, C. M., C. Brookson, J. Bikker, N. Djuric, A. Earn, K. Bucci, S. Athey, A. Huntington, H. McIlwraith, K. Munno, H. D. Frond, A. Kolomijeca, L. Erdle, J. Grbic, M. Bayoumi, S. B. Borrelle, T. Wu, S. Santoro, L. M. Werbowski, X. Zhu, R. K. Giles, B. M. Hamilton, C. Thaysen, A. Kaura, N. Klasios, L. Ead, J. Kim, C. Sherlock, A. Ho, and C. Hung. 2019. “Rethinking Microplastics as a Diverse Contaminant Suite.” Environmental Toxicology and Chemistry 38: 703–11. https://doi.org/10.1002/etc.4371 Roy, Hridoy, Md. Shahinoor Islam, Shafaul Haque, and M. H. Riyad. 2022. “Electronic Waste Management Scenario in Bangladesh: Policies, Recommendations, and Case Study at Dhaka and Chittagong for a Sustainable Solution.” Sustainable Technology and Entrepreneurship 1 (3). https://www.sciencedirect.com/science/ article/pii/S2773032822000256 Sarker, Abdur Razzaque. 2021. “Epidemiological and Economic Burden of Dengue in Dhaka in 2019, Bangladesh.” Bangladesh Institute of Development Studies (BIDS), November 17, 2021. https://bids.org.bd/page/researches/?rid=222#:~:text=The%20average%20economic%20cost%20for,hospitals%20and%20private%20 hospitals%2C%20respectively Seeley, M. E., B. Song, R. Passie, and R. C. Hale. 2020. “Microplastics Affect Sedimentary Microbial Communities and Nitrogen Cycling.” Nat Commun 11: 2372. https://doi.org/10.1038/s41467-020-16235-3 Shawkat, Ali. “Not Enough Plastic Waste for Recyclers.” Business Standard. September 13, 2021. https://www.tbsnews.net/economy/not-enough-plastic-waste- recyclers-301621. Shen, M., W. Huang, M. Chen, B. Song, G. Zeng, and Y. Zhang. 2020. “(Micro)plastic Crisis: Un-ignorable Contribution to Global Greenhouse Gas Emissions and Climate Change.” Journal of Cleaner Production 254: 120138. https://doi.org/10.1016/j.jclepro.2020.120138 Siddique, M. A. M., A. Uddin, S. Md. A. Rahman, M. Rahman, Md. S. Islam, and G. Kibria. 2022. “Microplastics in an Anadromous National Fish, Hilsa Shad Tenualosa ilisha from the Bay of Bengal, Bangladesh.” Marine Pollution Bulletin 174: 113236. https://doi.org/10.1016/j.marpolbul.2021.113236 Stann, Eric. 2020. “Think All BPA-Free Products Are Safe? Not So Fast, Scientists Warn.” Show Me Mizzou. News from the University of Missouri. February 18, 2020. https://showme.missouri.edu/2020/think-all-bpa-free-products-are-safe-not-so-fast-scientists-warn/. Sultana, Nasrin. 2019. “Plastic Recycling in Bangladesh.” Advance in Environmental Waste Management & Recycling 2 (1): 1–4. https://opastonline.com/wp-content/ uploads/2019/01/plastic-recycling-in-bangladesh-aewmr-19.pdf Syrett, Holly, Sandra Gonza, Sawers Corinne, Max Stenholm, Ann Runnel, and Harshitha Venati. 2021. “Scaling Circularity.” https://globalfashionagenda.org/ resource/sling-circularity-report/. Thornton Hampton, L. M., H. Lowman, S. Coffin, E. Darin, H. De Frond, L. Hermabessiere, E. Miller, V. N. de Ruijter, A. Faltynkova, S. Kotar, L. Monclús, S. Siddiqui, J. Völker, S. Brander, A. A. Koelmans, C. M. Rochman, M. Wagner, and A. C. Mehinto. 2022. “A Living Tool for the Continued Exploration of Microplastic Toxicity.” Micropl & Nanopl 2: 13. https://doi.org/10.1186/s43591-022-00032-4 Turer, Ahmet. 2012. “Recycling of Scrap Tires.” In Material Recycling: Trends and Perspectives, edited by Dimitris S. Achilias. ISBN: 978-953-51-0327-1, InTech. http:// www.intechopen.com/books/material- recycling-trends-and-perspectives/use-of-scrap-tires-in-industry Uddin, Mine Uddin, Kh. Mashfiqul Hasan, Md. Shahadat Hossen, and Md. Badiuzzaman Khan 2019. “People Perceptions about Using Polythene Bag and Its Impact on Environment at Mymensingh in Bangladesh.” https://www.researchgate.net/publication/330497456_People_perceptions_about_using_polythene_ bag_and_its_impact_on_environment_at_Mymensingh_in_Bangladesh_ARTICLE_INFO_ABSTRACT BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 172 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management UNEP (United Nations Environment Programme). 2019. Basel Convention On The Control Of Transboundary Movements Of Hazardous Wastes And Their Disposal file:///C:/Users/wb484797/Downloads/UNEP-CHW-IMPL-CONVTEXT.English.pdf UNEP (United Nations Environment Programme). 2021. “NEGLECTED: Environmental Justice Impacts of Marine Litter and Plastic Pollution.” UNEP-UN Environment Programme. http://www.unep.org/resources/report/neglected-environmental-justice-impacts-marine-litter-and-plastic-pollution Van Cauwenberghe, L., L. Devriese, F. Galgani, J. Robbens, and C. R. Janssen. 2015. “Microplastics in Sediments: A Review of Techniques, Occurrence and Effects.” Marine Environmental Research 111: 5–17. https://doi.org/10.1016/j.marenvres.2015.06.007 Waste Concern. 2016. Prospects of Plastic Waste Recycling in Bangladesh. Wath, S. B., P. S. Dutt, and T. Chakrabarti. 2011. “E-waste Scenario in India, Its Management and Implications.” Environ Monit Assess 172: 249–62. https://doi. org/10.1007/s10661-010-1331-9 WHO (World Health Organization). 2023. “Disease Outbreak News; Dengue in Bangladesh.” August 11, 2023. https://www.who.int/emergencies/disease-outbreak- news/item/2023-DON481 Wiesinger, H., Z. Wang, and S. Hellweg. 2021. “Deep Dive into Plastic Monomers, Additives, and Processing Aids.” Environ Sci Technol 55: 9339–51. https://doi. org/10.1021/acs.est.1c00976 Wilson, D. C., l. Rodic, M. J. Cowing, C. A. Velis, A. D. Whiteman, A. Scheinberg, R. Vilches, D. Masterson, J. Stretz, and B. Oelz. 2015. “‘Wasteaware’ Benchmark Indicators for Integrated Sustainable Waste Management in Cities.” Waste Management 35: 329–42. https://doi.org/10.1016/j.wasman.2014.10.006 World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank Group. World Bank. 2020. Ghana Country Environmental Analysis. Washington, DC: World Bank. © World Bank. https://openknowledge.worldbank.org/ handle/10986/33726 License: CC BY 3.0 IGO. World Bank. 2021a. Impact of COVID-19 on Plastic Waste Management in South Asia. Washington, DC: World Bank. https://documents1.worldbank.org/curated/ en/361871639027510564/pdf/The-Impact-of-COVID-19-on-Plastic-Waste-Management-in-South-Asia-Challenges-and-Policy-Recommendations.pdf World Bank. 2021b. Towards a Multisectoral Action Plan for Sustainable Plastic Management in Bangladesh. Washington, DC: World Bank Group. World Bank. 2021c. The Circular Economy of Plastics in Mozambique: Challenges and Opportunities. Washington, DC: World Bank. World Bank. 2022. Plastic and Climate Change. Unpublished. Washington, DC: World Bank. World Bank. 2023a. Assessment of Micro-Plastic (MP) Pollution in Rivers and Canals around Dhaka City. Unpublished. Washington, DC: World Bank. World Bank. 2023b. Baseline Study of Abandoned, Lost, or Otherwise Discarded Fishing Gear in South Asia: A Way Forward. Unpublished. Washington, DC: World Bank. World Bank. 2023c. Behavioral Insights for Plastic Waste Management in Bangladesh. Unpublished. Washington, DC: World Bank. World Bank. 2023d. Gender Equitable Value Chains for Mitigating Plastic Pollution in Coastal Communities in Bangladesh: Recycling Fishing Nets Waste and Single-Use Plastic Sachets. Unpublished. Washington, DC: World Bank. World Bank. 2023e. Plastic Waste in Road Construction: A Path Worth Paving? Washington, DC: World Bank. https://elibrary.worldbank.org/doi/ abs/10.1596/39839#:~:text=Industry%20standards%20for%20the%20use,short%2D%20and%20longterm%20research%20priorities. World Bank. 2023f. Building a Future for Women in South Asia’s Plastics Waste Management. https://documents.worldbank.org/en/publication/documents- reports/documentdetail/099092823145523204/p17645608d160802d0bfd40845cd079dcff Worm, B., H. K. Lotze, I. Jubinville, C. Wilcox, and J. Jambeck. 2017. “Plastic as a Persistent Marine Pollutant.” Annu Rev Environ Resour 42: 1–26. https://doi.org/10.1146/ annurev-environ-102016-060700 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 173 Addressing Plastic Pollution in Bangladesh through Integrated Solid Waste Management Endnotes 73 The 2020 consumption figure is based on a detailed survey on the waste composition of households and landfills in Dhaka City in 2020, which was extrapolated based on projections of urban-waste compositions of 2005 and 2014 to estimate the overall urban plastic consumption in Bangladesh. 74 This is especially true for the Aedes aegypti species of mosquitoes—the principal vectors implicated in the transmission of dengue disease. 75 Societal cost refers to loss of income, the costs associated with commuting back and forth to hospital/doctor stays/visits, and the costs of additional services/goods needed to aid the patient, and so forth. 76 Primary microplastics are engineered to be in this size range while secondary microplastics are produced through the fragmentation of larger plastics. Common sources of primary microplastics include microbeads from personal care products, such as shampoo, face wash, and toothpaste, and plastic preproduction pellets, which are used to produce plastic items. Due to weathering from physical stress, waves, sunlight, and changes in salinity or temperature, plastic waste produces secondary microplastics and nano-plastics. 77 Manufacturers produce plastic goods and packaging materials using imported virgin and recycled resins as raw materials. 78 Deemed exports refers to the indirect export of plastic goods including via the ready-made goods (RMG) industry in Bangladesh (including hangers and packaging). 79 To receive cash incentives from the Bangladesh Bank, exporters will have to show certified “freight on board value” and have membership in the relevant registered association. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 174 Enabling the Environment for Green Financing in Bangladesh CHAPTER 9. ENABLING THE ENVIRONMENT FOR GREEN FINANCING IN BANGLADESH 9.1 Introduction Bangladesh’s environmental agencies face significant budget constraints to implement their mandates. Line agencies also strug- gle with limited resources to implement pollution-abatement measures and improve environmental performance in their respec- tive sectors. Companies do not have adequate incentives for complying with environmental regulations or investing in research, innovation, and adoption of green technology (chapter 3). In parallel, financing climate action alone for Bangladesh is estimated to require more than $200 billion over the next two decades.80 Complementary plans and initiatives will also require billions of dollars to be fully implemented. According to research performed for the Perspective Plan 2041 (GoB 2020b), to achieve green growth, the country needs to increase its spending on programs related to environmental protection and climate change to 3 percent of GDP by 2031 and to 3.5 percent of GDP by 2041 (Ahmed 2017). Green financing is essential to maximize resources for both public and private initiatives for clean, efficient, and resilient pro- duction and services—key pillars for improving environmental quality and green growth. This chapter identifies the barriers for accessing green financing, especially to address environmental priorities, and proposes interventions to facilitate the flow of resources from green finance suppliers to sectors pursuing such resources. 9.2 Green finance Green financing aims to ensure sufficient and adequate financial flows to support the implementation of a green growth strategy, including key interventions to raise revenues for environmental management and address the country’s environmental priorities. The term “green finance” is traditionally used in reference to financial tools such as green bonds, green loans, or carbon-market in- struments, among others (Sachs et al. 2019). However, financing green growth goes beyond the establishment and use of financial instruments and should consider the demand side for green development with the supply of resources to do so. Both the demand and supply sides of green finance are necessary for the advancement of efforts that internalize negative environmental externalities and foster new environmentally friendly investments. Thus, when discussing green finance, this chapter refers to both the supply and demand of financing for the promotion of green growth. This definition aligns with that of Bangladesh Bank (BB) for sustainable finance: “any form of financial service that includes investment, insurance, banking, accounting, trading, economic and financial advice integrating environmental, social and governance (ESG) criteria into the business or investment decisions for lasting benefits of both clients and society at large” (BB 2020, 12). However, Bangladesh lags other emerging markets and developing economies in green finance due to structural weaknesses (World Bank 2022a). To better understand how to address those weaknesses, this chapter focuses on the enabling environment for promoting green financing in the country. To do so, the chapter will rely on the Green Financial Value Chain (GFVC), a frame- work that maps the main stakeholders, linkages, and processes associated with an environment that is more conducive for the flow of green finance in Bangladesh (see figure 9.1). The GFVC depicts a framework to understand green finance in Bangladesh and helps to identify the bottlenecks its stakeholders face and the role they could play to foster the channeling of financial resources to environmentally sustainable initiatives. These barriers and gaps are summarized from the borrowers’, financial in- stitutions’, and government’s perspectives, but they also involve other stakeholders like consumers, investors, and international organizations supporting a green growth agenda in Bangladesh. 9.3 Key green finance stakeholders in Bangladesh The 2020 Bangladesh Climate Fiscal Framework presents information about a wide range of climate-related policies, plans, strategies, and different sources funding them. The framework partially identifies the demand and supply for climate-related funds, including the resource allocation made by 25 ministries and government agencies, the financial sector, and NGOs/CSOs, among others (MoF 2020). However, the framework does not present a comprehensive list of sources financing GG—which in- cludes but is not limited to climate actions—and important information gaps remain. In contrast to public finance, private-sector commitments to climate and environmental finance are not well mapped in Bangladesh. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 175 Enabling the Environment for Green Financing in Bangladesh Regarding green banking, the BB has led the country through innovative regulations, policies, and incentives. Through its Sus- tainable Development Department and with technical support from the IFC, the BB issued its Green Banking Policy Guidelines for Banks (2011) and for Non-bank Financial Institutions (NBFIs) and New Banks (2013), and Sustainable Finance Policy for Banks and Financial Institutions (2020). Among these measures, the BB has established targets for direct green finance and sustainable finance at 5 percent and 15 percent of the total funded loan disbursements or investments made by banks and FIs, respectively81. Loans and investments are being directed to projects and initiatives in renewable energy, energy efficiency, alternative energies, waste management, recycling, recyclable products, and green brick manufacturing, among others. The BB has also pioneered the use of green central banking as an instrument to operate different green funds at concessional rates, like green refinancing schemes with its own resources and development-partner financing to provide concessional loans to eligible green investments. Yet, structural weaknesses in Bangladesh’s banking system have hampered the volume and range of green finance instru- ments. For fiscal year 2021, the share of green finance was 4.41 percent ($1.2 billion) of the total term loan disbursement. This is a sharp increase over previous years (figures 9.2 and 9.3), but low compared to emerging markets where the average is about 7 per- cent (World Bank 2022a). The pipeline of green projects is lean, and financial institutions have difficulty identifying green assets and projects due to a lack of clear standards and labels. The banks also rely on short-term deposits for funding, which does not position them well to finance climate and other green projects, most of which are long-term. Furthermore, even if banks were to meet the green finance target, this would amount to financing of around $600 million per year, a small dent in the financing gap82 (World Bank 2022a). The GoB remains the most relevant source of financing for environmentally sustainable development and green growth in general. In 2009, the government created the Bangladesh Climate Change Trust Fund from its own resources to combat cli- mate-change impacts in the country. The fund received $453 million and helped to implement the Climate Change Strategy and Action Plan 2009. In 2021, at least 8.1 percent of the government budget (0.8 percent of the country’s GDP) was directed towards addressing vulnerabilities related to environmental sustainability, adaptation, and mitigation. The thematic areas where these resources were invested included food security, social protection, and health; comprehensive disaster management; infra- structure; research and knowledge management; mitigation and low-carbon development; capacity building; and institutional strengthening (MoF 2020). The total public spending of the core ministries dealing with water, land, and environment-related services constituted about 0.39 percent of GDP that same year. These efforts, although important, are insufficient. Additional- ly, budget allocation across and within sectors does not necessarily respond to the country’s environmental and other green growth priorities (chapter 3). (See figure 9.2.) Figure 9.1 Green Financial Value Chain (GFVC) Government (MoF, BB, DoE,BSEC, and others) Create regulatory environment and enforce rules to Institutional Investors enhance green financing and green growth. Buy government bonds that can be linked with Green/Blue / Sustainable criteria. Green Financing Equity Investors Borrowers Consumers Invest in projects linked to (public & private) Projects and initiatives that Stable Capital Environmental, Social and meet green criteria; provide verified, transparent data; Seek low-cost Market Governance (ESG) impact. Prepare green and sustainable, meet expected financial projects, products, returns; and have positive effective products International services, technol- environmental impact that and services. Sustainable Organizations ogies, and adopt supports green growth. Investments environmentally Provide funding, technical sustainable assistance, and convening practices. power to support development Financial strategies linked to green, resilient, inclusive activities. Institutions Allocate financial resources through different green instruments to support green growth. COUNTRY ENVIRONMENT Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 176 Enabling the Environment for Green Financing in Bangladesh Figure 9.2 Green financing’s share of total term loan disbursements 99.5% 99.5% 99.5% 99.5% 99.5% 99.5% 0.5% 0.6% 0.7% 1.2% 1.4% 4.4% Source: Bangladesh Bank 2022. Figure 9.3 Green financing by category 3% 3.9% 6.1% 7.4% 55.2% 11% 13.4% Source: Bangladesh Bank 2022. Note: “Others” includes green Cottage, Micro, Small, and Medium Enterprises (CMSMEs), green agriculture, solid-waste management, green Socially Responsible Financing (SRF), and alternative energy. 9.4 Demand for green financing Financing climate action alone for Bangladesh is estimated to require at least $176 billion over the next two decades. Esti- mates from Bangladesh’s NDC to the Paris Agreement indicated that $67 billion in funding was needed for the country’s cli- mate-adaptation measures between 2015 and 2030 (GoB 2020b). According to the 2021 NDC Update, approximately $32 billion would be required to meet unconditional mitigation objectives and an additional $144 billion required to meet conditional objectives during 2021–30 (World Bank 2022b). Investment of at least $200 billion for the next two decades is needed for Ban- gladesh to reach its top-tier climate-mitigation targets and ambitions (Bangladesh Bank and IFC 2021) (see figure 9.4). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 177 Enabling the Environment for Green Financing in Bangladesh Figure 9.4 Bangladesh’s Climate-Smart Investment Potential (2018–30) | $, billions 4.0 3.2 9.1 13.0 23.0 118.8 Source: IFC 2019. In addition, Bangladesh has a myriad of plans and initiatives that will demand significant economic resources, like the Mu- jib Climate Prosperity Plan ($89.7 billion by 2030) and the Bangladesh Country Investment Plan for Environment, Forestry and Climate Change ($11.7 billion). The Bangladesh Delta Plan 2100 (BDP), which intends to secure the future of water resources and mitigate the likely effects of climate change and natural disasters, is estimated to require $38 billion by 2030 (in 2015 prices) for physical investments and institutional strengthening for implementation and monitoring (World Bank 2022b). Complementary plans and initiatives will also require billions of dollars to be fully implemented. The implementation of the Delta Plan 2100 will require about 2.5 percent of the total domestic income every year until 2030, with its first phase costing around $37 billion. According to research performed for the Perspective Plan 2041, to achieve GG, Bangladesh needs to increase its spending on programs related to environmental protection and climate change to 3 percent of GDP by 2031 and to 3.5 percent of GDP by 2041 (Ahmad 2017). Finally, interventions to strengthen Bangladesh’s environmental management system and address major environmental health-risk factors—ambient and household PM2.5 air pollution, lead exposure, and inadequate drinking water, sanitation, and hygiene—will require considerable resources (chapters 2 and 3). Detailed benefits and costs analysis of interventions that promise the greatest environmental health improvements or benefits per taka spent on the interventions are discussed in chap- ter 5 of this CEA. For example, the cost of the comprehensive PM2.5 control measures for which benefits exceed costs is $1.3 billion (Tk 109 billion) per year. Green financing could be directed to interventions that contribute to addressing those health risks. 9.5 Barriers to channeling green finance into Bangladesh’s green growth projects Bangladesh has taken substantial steps to spur a green economy by, among other steps, adopting green policies, pro- grams, and projects; establishing green regulations; and extending green incentives. However, several institutional bot- tlenecks remain that impede the implementation of Bangladesh’s objective of growing in an environmentally sustainable way. Within this context, financial institutions (FIs) continue to perceive “green” as riskier than “non-green” investments, while borrowers face a huge hurdle in adopting and financing green practices. At the same time, polluters do not feel the need to change their practices. This has resulted in insufficient financial flows, an inadequate pipeline of projects, and subsequently, ineffective green growth outcomes. Listed below are key bottlenecks and barriers that have been identified by examining the challenges faced by stakeholders mapped in the GFVC in the processes for financing green growth in Bangladesh. Conversations with key stakeholders as well as a review of previous studies carried out on green financing have been considered in this report when identifying the root causes of impediments to financing Bangladesh’s green growth. Addressing these bottlenecks is key to creating an enabling environment for advancing green financing in the country, as discussed in the next section. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 178 Enabling the Environment for Green Financing in Bangladesh Borrowers face significant hurdles in adopting and financing green practices, such as these: • Lack of capability to adopt and implement green practices and technologies. Adopting and implementing green practices and technologies requires borrowers to employ new sets of skilled resources (often new personnel or additional training) and new management systems. Without adequate understanding of those green practices and technologies, and without ade- quate experience in successfully operating them, entrepreneurs’ capacity to go green is affected (Cirera and Maloney 2017). In Bangladesh, the Sustainable Enterprise Project provides an example of the use of green finance and the development of capabilities in microenterprises to adopt environmentally sustainable practices and technologies (box 9.1). Box 9.1 Financing Environmentally Sustainable Practices in Bangladesh The World Bank’s Sustainable Enterprise Project (SEP) provides access to microenterprise (ME) loans through the Palli Karma-Sahayak Foundation and its partner NGOs to adopt cleaner and greener methods of operation. Since 2018, the SEP has directly supported 60,000 MEs across Bangladesh that have received loans and trainings for the adoption of environmentally sustainable practices (ESP). Close to 33,000 MEs have adopted at least one ESP, including practices that advance waste management (reduce, reuse, and recycle); the reduction of water and air pollution; and the use of energy saving technologies; among others. In addition, the SEP helps MEs to adopt practices that reduce occupational health and safety risks and improve workers livelihoods. These practices include the use of personal protection equipment (PPE); access to safe drinking/potable water, hygienic toilet, and safe handwashing facilities; improvement of air circula- tion systems with ventilation at the workplace; and access to sufficient lighting; among others. By providing basic services and health to workers, both workers and MEs can increase their productivity and ability to take up economic activities in environmentally sensitive, climate‐vulnerable, and disaster‐prone areas. The SEP has also encouraged non-banking financial institutions to support green growth initiatives and shift their portfolio assets to include environmental protec- tion, pollution and contamination reduction, and better workplace safety—considerations that are too often overlooked among Bangladesh’s MEs. Source: https://projects.worldbank.org/en/projects-operations/project-detail/P163250?lang=en • Limited knowledge and capacity to prepare bankable green projects. A BB study showed that 62 percent of SMEs do not maintain balance sheets, and those SMEs that maintain balance sheets lack audited balance sheets (BB 2013). In addition, small and medium enterprises (SMEs) are usually unable to provide loan collateral and cannot always prove there is enough demand for the green products and services they provide. Those factors increase investors’ concerns about the financial via- bility of investments in polluting sectors (for example, agriculture and industry) (Rahman, Khan, and Farin 2019; UKaid 2017a). • High capital investment requirements for going green, either for new technology or to retrofit existing equipment in certain polluting industries. Transitioning to a cleaner production path entails additional investment, including importing machinery, accessories, and other goods, usually with long return-on-investment, thus making green ventures expensive. In addition, administrative hurdles, fees, and issuance costs, among other transaction costs, reduce investors’ incentive to fund green projects and stop entrepreneurs from asking for funding (UKaid 2017a; Vivid Economics and Climate Bonds Initiative 2019). • Stringent requirements to borrow. Borrowing is hard due to stringent due diligence on the issue of loanees’ creditability, track record of business, environmental and social safeguard issues, strict guidelines on collateral, short repayment period, and unattractive refinancing schemes offered by banks and FIs. • Low demand for green products with consumers opting for cheaper goods. Polluting sectors in Bangladesh (for example, agriculture and manufacturing) can operate at lower cost, providing more-competitive goods and services for the domestic economy. Green products and services may be comparably more expensive due to up-front costs. Consumers tend to be unaware when goods are produced by polluting industries and negatively impact the environment. Most sectors identified in Bangladesh as eligible for receiving green finance have low investment demand, a situation driven in part by consumers’ lack of interest in green products and solutions, and entrepreneurs’ weak awareness of the opportunities of going green (UKaid 2017a). FIs continue to perceive green projects, businesses, and technologies as risky endeavors. FIs face these challenges: • Structural weaknesses in the financial sector limit the capacity of finance to reach underserved segments, like CMSMEs, economic sectors perceived as risky, and long-term projects. These structural weaknesses include the interest-rate cap, li- censing framework, corporate and regulatory governance structures, credit-underwriting capacity, operational inefficiencies, and underdeveloped capital markets (World Bank 2020). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 179 Enabling the Environment for Green Financing in Bangladesh • Low risk appetite and short-term focus contribute to slow green loan disbursement. The BB had set a 5 percent loan dis- bursement target, which FIs have been unable to meet. In Bangladesh, 8.1 percent of total loans in September 2021 were non- performing loans (NPLs)—on par with India but much higher than Nepal and Sri Lanka.83 In a systemic loan-default culture, such as in Bangladesh, banks tend to refrain from investing in unproved practices, technologies, and business models with unknown risks. At the same time, most green projects have long payback periods. Loans traditionally focus on short-term monetary gains and do not consider long-term environmental impacts due to vague policies and lax enforcement (UKaid 2017a). Although green projects address negative environmental externalities, lenders see little commercial value in that. • High cost of doing business attributable to on-site visits to projects in the green portfolio and the need for specialized human resources to inspect and verify project activities. Post monitoring of projects funded by banks under green finance requires continued oversight, which is an added burden on the traditional banking culture in place in Bangladesh. • Inadequate in-house technical capacity. The processing and administering of loans for green projects suffers from a lack of technical capacity to assess environmental and social goals (ESG) risks and the future potential of green technologies. The BB introduced guidelines on environmental and social-risks management in 2017. However, Bangladesh’s credit and financial institutions still need to improve their capabilities for evaluating the environmental and social risks associated with green proj- ects and the financial implications of those risks (Hossein 2018). Additionally, in the absence of an institutionalized third-party monitoring and verification system in Bangladesh, banks find it hard to keep track of whether borrowers have adequately addressed environmental issues. Consequently, banks are reluctant to finance green projects without substantial collateral to reduce the perceived risk to the bank. Financial institutions could learn from successful cases already present in Bangladesh in the garment industry (box 9.2). Box 9.2 Resource efficiency in the garment industry in Bangladesh Companies can play a major role through corporate social responsibility (CSR) and supply-chain initiatives. Leading inter- national brands in the textile and apparel industry have since 2014 been closely involved with the successful Partnership for Cleaner Textile (PaCT) program financed by the International Finance Corporation (IFC). PaCT works with global apparel brands and the Bangladesh Garment Manufacturers and Exporters Association (BGMEA) to support the entire textile value chain. This includes spinning, weaving, wet processing, and garment factories in adopting Cleaner Production (CP) practic- es and engages with brands, technology suppliers, industrial associations, financial institutions, and government to bring about systemic and positive environmental changes (https://www.textilepact.net/what-is-pact.html). Since its inception, PaCT has worked with more than 338 factories to reduce freshwater consumption by 25 million m3/year and cut wastewa- ter discharge by 21.08 million m3/year. These factories now save 2.5 million MWh/year in energy and avoid greenhouse gas emissions of up to 489,796 tons/year of CO2. To facilitate investment in resource efficiency technologies, PaCT has developed financial mechanisms and products to enable access to finance for textile factories and their value chain. It has also engaged in matchmaking between banks, businesses, and technology suppliers to build capacity for identifying and assessing bank- able projects. PaCT advocacy also helped to create the BB’s Green Transformation Fund, a $200 million refinancing scheme that facilitates access to finance for importing capital machinery and accessories for environment-friendly initiatives. Those initiatives include water-use efficiency in wet processing, water conservation and management, waste management, re- source efficiency and recycling, renewable energy, energy efficiency, heat and temperature management, air ventilation and circulation efficiency, and work environment improvement initiatives. Source: Bangladesh PaCT: Partnership for Cleaner Textile. https://www.textilepact.net/ The GoB lacks institutional structures for implementing its policies and targets and for effectively holding polluters respon- sible. Specifically, it faces the following challenges: • Low interagency coordination to advance a comprehensive national green growth strategy backed by a national action plan and green finance policy to support Bangladesh’s green growth commitments. With several agencies and ministries playing different roles that shape environmental management and investors’ decisions to invest in the country,84 Bangladesh lacks a dedicated body with the specific objective of improving and securing access to local and international green finance (UKaid 2017a). Chapter 3 of this CEA highlights some of the coordination failures government agencies experience when defining environmental priorities and action plans across relevant sectors. BB initiatives succeeded in creating a framework for the banking sector, but the enabling environment for ushering in a new development paradigm is still missing. Without BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 180 Enabling the Environment for Green Financing in Bangladesh a dedicated body, coordination failures and other inefficiencies may arise, making it difficult to advance a coherent national green finance strategy that connects all the existing elements that could help advance environmentally sustainable devel- opment. The lack of a coordinating body also contributes to deficiencies in monitoring and enforcement. Such deficiencies limit incentives for polluting industries to make green investments and improve their environmental performance, and for investors to provide adequate resources for green projects and initiatives. • Lax enforcement mechanisms to punish environmental offenders have profound implications for entrepreneurs willing to go green. Deficiencies in existing regulations and weak environmental monitoring and enforcement have provided limited incentives for polluting industries to make green investments and improve environmental performance through new green products and services (World Bank 2021). Without the impetus to acknowledge and internalize their actions’ social costs, Bangladesh’s industries can operate without consequences for the pollution they cause. Chapter 3 discusses the institution- al shortcomings facing the Department of Environment (DoE), the country’s main responsible agency for environmental protection and for penalizing companies or individuals for not complying with environmental standards or for damaging ecosystems. Inadequate organizational structure, insufficient budgetary and human resources, challenges with coordination across agencies and with local governments, and limited environmental data management and limited evidence-based decision-making are some of the key challenges that need to be addressed first before the DoE can enforce existing regula- tions and guidelines for activities affecting the environment. In other countries, like Korea, automated emissions-monitoring systems are in place to monitor emissions, charge polluters, and inform policy (box 9.3). Box 9.3 Korea’s automated emissions monitoring system The Korea Environment Corporation (K-eco), a quasi-governmental organization, manages a comprehensive data mea- surement and analysis system. For example, CleanSYS measures air pollutants emitted from stacks in real time using an automatic stack measuring device that connects online to K-eco control centers. While K-eco manages this monitoring network and analyzes the data, this information is then used by local government and the Ministry of Environment to charge fees and penalties from polluters and to inform policy formulation. The data are also shared with the Korea Envi- ronmental Industry and Technology Institute (KEITI), the Korea Institute for Advancement of Technology (KIAT), and other public agencies for purposes of financial decision-making. The point-source pollution monitoring system was initially manual but a telemonitoring system was introduced to reduce the administrative burden and enable an early warning and real-time data disclosure. Source: https://www.keco.or.kr/en/core/climate_air3/contentsid/1948/index.do • Inadequate expertise to evaluate green technologies and investments within the GoB, as well as in FIs assessing the viability of green investments. Further, Bangladesh at present lacks a dedicated institution to assess and evaluate green technologies that borrowers may want to adopt for managing their enterprises’ pollution (UKaid 2017b). • Lack of a project pipeline to attract investment in green sectors (for example, transport and urban planning). Currently, the GoB lacks a government institution to collate projects to share with donor agencies that might invest in green projects. To promote green growth, investors need better information regarding viable, commercial projects that promote green growth (Vivid Economics and Climate Bonds Initiative 2019). The GoB could help to develop such a pipeline by providing assistance to entrepreneurs when creating development plans, project ideas, and investment plans, as well as financial disclosures, since these steps are difficult and costly for businesses (IFC 2016). To support green growth, players along the GFVC require an enabling environment that is more conducive to connecting the demand for and supply of green finance. Figure 9.5 below presents an inventory of the key components of the enabling envi- ronment needed for financing GG in Bangladesh. These components are elements that need to be in place before each of the main stakeholders of the GFVC can maximize its contribution to the advancement of green finance in Bangladesh. Having those key elements in place requires a well-coordinated response from different actors and having proper incentive structures in place. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 181 Enabling the Environment for Green Financing in Bangladesh Figure 9.5 Components of the enabling environment needed for financing green growth in Bangladesh GOVERNMENT INSTITUTIONAL INVESTORS Targets and progress metrics on Capital-market framework Green finance policies sector and country level Low cost of doing business Guarantee to minimize risks System to track green activities, budgets, and investments Integration of environmental costs as part of budgeting process (e.g., payment for Sustainable investment criteria ecosystem services, carbon tax) Transparent disclosure of data and progress available Collection, monitoring, and verification of data Platforms for identifying green business/ investment opportunities Enforcement mechanisms FINANCIAL INSTITUTIONS CONSUMERS Financial returns Green targets Knowledge on product impact ENABLING System to track green activities and investments Access to green products and services ENVIRONMENT NEEDED FOR KEY ACTORS Technical capability to assess ESG risks Affordable products and services Track and aggregate progress Green banking/ sustainable banking network BORROWS Mandate to go green Access to green technologies Capabilities/ know-how to go green Access to low-cost and long-term financing Data to track progress Source: World Bank. To pinpoint the main areas for intervention, the barriers identified through the GFVC are “superposed” on the enabling en- vironment (figure 9.6). Figure 9.6 highlights the key barriers faced by each of the main stakeholder groups in financing green growth in Bangladesh. Eliminating or substantially reducing these barriers can help align the supply of financing with sectors that need to go green (for example, environment, infrastructure, transportation, manufacturing, and agriculture). Addressing those bottlenecks will require a well-coordinated response from key ministries and government agencies—a response that en- forces regulations, establishes incentive structures, and fosters strong environmental technical expertise within both the gov- ernment and the private sector. These actions will stimulate adoption of green practices and technologies and grow green businesses—essentially creating a pipeline of projects requiring green financing. Importantly, these actions would concurrently make FIs better able to identify the future potential of green investments. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 182 Enabling the Environment for Green Financing in Bangladesh Figure 9.6 Barriers affecting key actors when financing green growth in Bangladesh GOVERNMENT INSTITUTIONAL INVESTORS Low interagency coordination to advance a comprehensive national Structural weaknesses in the financial sector green growth strategy High cost of doing business Lax enforcement mechanisms to punish environmental offenders Inadequate in-house technical capabilities Inadequate expertise to evaluate green technologies and investments Lack of a project pipeline to attract investment in green sectors FINANCIAL INSTITUTIONS Structural weaknesses in the financial sector CONSUMERS BARRIERS AFFECTING Low risk appetite and short-term focus Low demand for green products KEY ACTORS High cost of doing business Inadequate in-house technical capabilities BORROWS Lack of capability to adopt and implement green prac- tices and technologies Limited knowledge and capacity to prepare bankable green projects High capital investment requirements for going green Low demand for green products Stringent requirement to borrow Source: World Bank. Closing the gap between those needing financing and those providing it is central to promoting green growth in Bangladesh. Areas of action are outlined in the next section (a) to lower the barriers in financing green growth and (b) to create an enabling environment to effectively fund green growth in Bangladesh. 9.6 Recommendations To promote an enabling environment that facilitates the flow of resources from green finance suppliers to sectors pursuing such resources, this chapter identifies three types of recommendations and associated actions, as presented below. An ac- tion plan, consisting of multiple policy alternatives from institutional to regulatory components, is presented in appendix P. Recommendation 1: Create a governance framework for green growth Adopt a broad-based national green growth strategy and a national action plan backed by a commensurate set of regula- tory and institutional frameworks. Building on the 8FYP, for Bangladesh to carry forward its national goal for promoting green growth, necessary first steps are a national green growth strategy and a national action plan for green growth that include clear goals and subgoals and the right mix of regulatory and institutional frameworks that lay out roles and responsibilities for minis- tries and government agencies (UNEP 2017). Providing a clear guidance for transitioning to a low-carbon economy and creating a conducive regulatory and institutional environment are key to reduce asymmetries of information and diminish risks, thus creating opportunities for investors to direct green finance towards sustainable investments. Constitute a high-level national oversight body to coordinate and monitor the progress of green growth efforts. A high-lev- el national committee situated under the head of the government could provide essential oversight at the start of the green growth strategy regarding the implementation of green growth actions. Such a body could address coordination failures and BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 183 Enabling the Environment for Green Financing in Bangladesh other inefficiencies that make it difficult to advance a coherent national green finance strategy that connects all the existing elements that could help advance environmentally sustainable development. This includes addressing some of the structural weaknesses currently present in the financial sector (for example, interest-rate cap, licensing framework, and corporate and reg- ulatory governance structures). The coordinating body could also contribute to advance monitoring and enforcement and create incentives for polluting industries to make green investments and improve their environmental performance, and for investors to commit resources to green projects and initiatives. Chapter 3 of this CEA provides examples of additional mechanisms that could improve coordination across agencies at different governmental levels for environmental priorities. Strengthen the institutional framework to collect and analyze point-source data to (a) inform policy design and enforcement, and (b) create a pipeline of verified investment-ready projects. An adequate monitoring system, one that collects information at the source of pollution and then assembles that information centrally for verification, analysis, and disclosure, will generate a credible enforcement mechanism. Systems for collecting point-source data allow for real-time monitoring of pollution. These systems reveal environmental externalities, thus motivating businesses to manage their environmental impact. This, in turn, can stimulate competition between firms and, with adequate enforcement or public disclosure, could hold polluters responsible. In addition, the collection and analysis of point-source data can reduce asymmetries of information by making it easier for investors to track the performance of green projects and initiatives, thus enabling the creation of a pipeline of verified investment-ready projects that attract green financing to Bangladesh. Most of these efforts need to happen inside the DoE; nonetheless, other governmental organizations also play a key role in strengthening the institutional framework that allows for the use of evidence to support prioritization and decision-making (chapter 3). Recommendation 2: Use a mix of incentives to boost environmental markets Encourage the adoption of green practices and promote green businesses and investments with positive environmental ex- ternalities. Incentives such as tax cuts and exemptions for pollution-control efforts; long-term low-interest financing for adop- tion of efficient/green technologies; subsidies; and preferential benefits for eco-friendly products make it easier for businesses to adopt green practices. Clusters of industries can also be supported to provide environmental infrastructure, like the government of Malaysia has done with its Waste Eco Parks initiative (box 9.4). Box 9.4 Incentives for clustering waste management in Malaysia The Malaysian government provides an example of clustering—providing incentives to Waste Eco Parks (WEPs) to promote waste management in a more integrated manner. WEPs aim to promote waste zero by relocating recycling companies (previously scattered and dispersed across multiple industries) to a central location within a WEP. This incentive is offered to companies in the WEP program, along with companies developing infrastructure for WEPs, companies managing WEPs, and industry stakeholders involved in waste recycling, recovery, and disposal. WEP developers (companies) may receive an income-tax exemption of 70 percent on statutory income derived from rental of buildings; rental received from the use of a waste collection and separation facility; and rental received from a wastewater treatment facility located in the WEP effective for 2016 until 2025. WEP managers (companies) may receive an income-tax exemption of 70 percent on statuto- ry income derived from activities including management, maintenance, supervision, and marketing of the WEP effective 2016–2025. WEP operators (companies) may benefit from an income-tax exemption of 100 percent for a period of 5 years on statutory income derived from the qualifying activities undertaken in the WEP or an income-tax exemption equivalent to 100 percent of qualifying capital expenditure (investment tax allowance) incurred within a period of 5 years. The allowance can be offset against 70 percent of statutory income for each assessment year. Other integrated waste-management com- panies that perform/invest in additional activities such as composting, storage, collection, or disposal in addition to recycling, recovery, or disposal of waste may be considered for the Green Investment Tax Allowance (GITA). Source: Malaysian Investment Development Authority (MIDA), Malaysia’s Green Technology. https://www.mida.gov.my/publications/malaysias-green-technology/ Adopt incentives that address the actual and perceived risks faced by FIs—incentives such as guarantees and publicly de- veloped eco-certifications. Such incentives minimize the cost to FIs, which in turn would allow businesses to have easier and cheaper access to financing. Mandates for public disclosure for information about enterprises’ green management can provide essential information for evaluating the viability of borrowers. In Korea, for example, a green certification scheme is used to re- duce risks and asymmetries of information faced by financial institutions that provide green loans to the private sector (box 9.5). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 184 Enabling the Environment for Green Financing in Bangladesh Box 9.5 Green certification system in Korea The Korea Institute for Advancement of Technology (KIAT), under the Ministry of Trade, Industry and Energy (MOTIE), plays a core administrative role as the green certification office. The certification covers technology and associated products that minimize GHG emissions and other pollutants, and specialized enterprises whose economic activities are related to green growth priorities. Governmental agencies from multiple sectors cooperate based on their green expertise for assessing applications through document review and field evaluation. Furthermore, these agencies provide operational guidance and associated incentives such as financial support and green public procurement for certified companies. The Korea Envi- ronmental Industry and Technology Institute (KEITI), under the Ministry of Environment, is one of the agencies that collects and analyzes environmental information to assess companies’ environmental pollution risk (for example, violation records of pollution regulations); environmental management activities (for example, green certificates, eco-label, and ISO certifi- cates); and environmental-management level. The evaluation results are shared with financial institutions, including banks, asset-management companies, and insurance companies for due diligence. The final evaluation results are provided to financial institutions that have signed an agreement to spread green finance. Source: https://www.greencertif.or.kr/ptl/cDefinitionC/operating.do; https://www.envinance.kr:442/info/info.do Boost private-sector adoption of green practices and technologies, and thereby boost the offering of green products and services. Gaps identified through this chapter will need further analysis regarding up-front financing required, estimated re- duction in pollution, partnerships to implement, and so on. For example, guarantee schemes may work for some sectors. Other sectors may require a partial tax along with use of the revenues to finance supporting programs for developing green know-how, technologies, products, and industries. Foster a collaborative institutional system to implement green financial incentives. This can provide the enabling environ- ment to effectively connect the flow of financing to those sectors that need to go green. Sustainable public procurement can also be used as an incentive to drive markets toward sustainable production. Recommendation 3: Strengthen institutional and borrower capabilities Build skills and expertise on green financing across sectors, from technocrats in government agencies to FIs, and from private businesses to students. Strengthening capacity and awareness across government and financial institutions is essential for the development of supportive policies and regulations, and to overcome knowledge barriers that constrain investments in green projects. Building foundational knowledge on green aspects and impacts across ministries would support the development of the needed policy framework and analysis. Importantly, provide overall education and awareness-raising support in addressing opposition to green investments, since such opposition can constrain investment and the development of the regulatory envi- ronment needed to advance green investing. Develop a pipeline of trainings to adopt across government, businesses, and FIs. Following are some examples of some train- ings to be adopted by entrepreneurs and CMSMEs, finance providers, and government institutions: Introducing technical cours- es on green technologies and green businesses in vocational institutions, promoting and building service institutions to lend services to entrepreneurs on green related topics, strengthening banks’ and FIs’ personnel working in sustainable financial units to deal with ESG and potential of green technologies and projects, and providing trainings on sustainability and sustainable fi- nancing for government officials different levels. This could disseminate knowledge on sustainability and green finance among society and contribute to addressing some of the barriers affecting investments in sustainable projects and initiatives. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 185 Enabling the Environment for Green Financing in Bangladesh C9 References / Endnotes Ahmed, Sadiq. 2017. “Background Paper on the Determinants of a Green Growth Strategy in Bangladesh.” Economic Dialogue on Green Growth (EDGG) Paper No. 5. Adam Smith Institute and UKAid. BB (Bangladesh Bank). 2013. Investigating the High Growth of SME Loan and Analysis of its Influence on the Economy: A Survey Report. BB. BB (Bangladesh Bank). 2020. Sustainable Finance Policy for Banks and Financial Institutions. https://www.bb.org.bd/mediaroom/circulars/gbcrd/ dec312020sfd05.pdf BB (Bangladesh Bank) and IFC (International Finance Corporation). 2021. Green Bond Taxonomy (Draft May 2021). BBS (Bangladesh Bureau of Statistics). 2020. https://thefinancialexpress.com.bd/national/virus-fuels-poverty-rate-to-294pc-shows-planning-commission- estimate-1601694926 Cirera, X., and W. Maloney. 2017. The Innovation Paradox: Developing-Country Capabilities and the Unrealized Promise of Technological Catch-Up. Washington, DC: World Bank. GGGI (Global Green Growth Institute). 2020. The Promise of Green Growth. GoB (Government of Bangladesh). 2020a. Nationally Determined Contributions 2020 (Interim): From Vision to Action. Government of Bangladesh. GoB (Government of Bangladesh). 2020b. Bangladesh Climate Fiscal Framework 2020. GoB (Government of Bangladesh). 2020c. 8th Five Year Plan July 2020 – June 2025: Promoting Prosperity and Fostering Inclusiveness. Government of Bangladesh. Hossein, M. 2018. “Green Finance in Bangladesh: Policies, Institutions, and Challenges.” ADBI Working Paper 892. Asian Development Bank Institute. IFC (International Finance Corporation). 2016. Climate Investment Opportunities in Emerging Markets: An IFC Analysis. IFC. https://www.ifc.org/wps/wcm/ connect/59260145-ec2e-40de-97e6-3aa78b82b3c9/3503-IFC-Climate_Investment_Opportunity-Report-Dec-FINAL.pdf?MOD=AJPERES&CVID=lBLd6Xq IFC (International Finance Corporation). 2019. Climate Investment Opportunities in South Asia. MoF (Ministry of Finance). 2020. Bangladesh Climate Fiscal Framework 2020. Parvez, Sohel. 2020. “Pandemic Doubles Extreme Poverty.” Daily Star (August 12, 2020). https://www.thedailystar.net/business/news/pandemic-doubles-extreme- poverty-1943653 Rahman, M., T. I. Khan, and S. M. Farin. 2019. “Blended Finance in Bangladesh: A Scoping Paper.” Occasional Paper Series No 46. Southern Voice. UKaid. 2017a. Financing Green Growth in Bangladesh: Challenges & Opportunities. https://www.greengrowthknowledge.org/sites/default/files/downloads/ resource/Financing%20Green%20Growth%20in%20Bangladesh%20Challenges%20and%20Opportunities.pdf UKaid. 2017b. “Governance for Green Growth in Bangladesh: Policies, Institutions, and Political Economy.” UKaid. UN (United Nations). 2015. Paris Agreement. United Nations Framework Convention on Climate Change. UNEP (United Nations Environment Programme). 2017. Enquiry Finance Progress Report. Vivid Economics and Climate Bonds Initiative. 2019. Green Bonds Development in Bangladesh. Weber, O. 2018. The Financial Sector and the SDGs. Interconnections and Future Directions. CIGI Papers No. 201 – November 2018. https://www.cigionline.org/ publications/financial-sector-and-sdgs-interconnections-and-future-directions/ World Bank. 2012. “Bangladesh Climate Change Resilience Fund.” News article, May 22, 2012. Washington, DC: World Bank. https://www.worldbank.org/en/news/ feature/2012/05/22/bangladesh-climate-change-resilience-fund-bccrf World Bank. 2017. People’s Republic of Bangladesh – Multisector Approaches to Delta Management – Investment Plan for the Bangladesh Delta Plan 2100 – Volume 1: The Plan (English). Washington, DC: World Bank Group. http://documents.worldbank.org/curated/en/890611546628658220/Peoples-Republic-of- Bangladesh-Multisector-Approaches-to-Delta-Management-Investment-Plan-for-the-Bangladesh-Delta-Plan-2100-Volume-1-The-Plan World Bank. 2020. Financial Sector Assessment Program. Washington, DC: World Bank. World Bank. 2021. “Bangladesh Environmental Sustainability and Transformation Project.” Washington, DC: World Bank Group. World Bank. 2022a. Bangladesh Country Economic Memorandum: Change of Fabric. Washington, DC: World Bank. https://openknowledge.worldbank.org/ handle/10986/38229 World Bank. 2022b. Country Climate and Development Report. Washington, DC: World Bank. https://openknowledge.worldbank.org/bitstreams/6d66e133- e49d-5ad9-b056-7b1a6c6206ed/download BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 186 Enabling the Environment for Green Financing in Bangladesh Endnotes 80 This amount represents the sum of investment need/opportunity assessments in the green economy in Bangladesh from a range of sources. These include the IFC report Climate Investment Opportunities in Emerging Markets (IFC 2016), the investment needs calculated in the Bangladesh Delta Plan (World Bank 2017), and the projections for future renewable power generation investment combined with current estimates of investment cost for such technologies from the International Renewable Energy Agency (IRENA). 81 Green finance aims to reduce negative externalities and/or promote positive externalities within the scope of the environment. Aims include the adoption of greener technologies through lending products and other financial instruments made available by banks and financial institutions, with the idea of increasing the level of financial flows from the public, private, and not-for-profit sectors to sustainable development priorities. Sustainable finance includes green finance, which is one of the sustainable finance components along with agriculture, CMSME, and socially responsible finance linked to sustainability (Bangladesh Bank 2020). 82 In the past five years, net credit to the private sector from banks averaged around $12 billion per year. 83 https://www.ceicdata.com/en/indicator/bangladesh/non-performing-loans- 84 Relevant ministries and agencies include the Bangladesh Bank (BB); Bangladesh Investment Development Authority (BIDA); Ministry of Agriculture; Ministry of Commerce (MoC); Ministry of Environment, Forest and Climate Change (MoEFCC); Ministry of Finance (MoF); Ministry of Housing and Public Works; Ministry of Industries (MoI); Ministry of Power, Energy and Mineral Resources; ; National Board of Revenue (NBR); and Palli Karma-Sahayak Foundation (PKSF). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 187 Expanding the Range of Environmental Management Tools in Bangladesh CHAPTER 10. EXPANDING THE RANGE OF ENVIRONMENTAL MANAGEMENT TOOLS IN BANGLADESH 10.1 Introduction By making environmental clearance its predominant environmental management tool and focusing on command-and-con- trol, Bangladesh has not taken sufficient advantage of more flexible and effective policy instruments to address its environ- mental priorities. 10.2 Types of environmental policy instruments Available environmental policy instruments can be categorized depending on the level of government involvement needed for their implementation. At one extreme, such instruments include fines or sanctions that are linked to traditional command-and-con- trol (CAC) regulations. According to Giner (2012), CAC regulations focus on preventing environmental problems by mandating stan- dards and technologies to control pollution. This approach generally relies on emissions standards, ambient standards, and tech- nology-based and performance-based standards in conjunction with enforcement programs. At the other extreme, they include laissez-faire approaches that require consumer advocacy or private litigation to act as incentives for improving environmental man- agement. In between are the more familiar tax-and-subsidy approaches, as well as the less familiar mechanisms relying on traded property rights (Sánchez-Triana et al. 2020). Table 10.1 illustrates the broad spectrum of instruments that might be available, all of which implicitly or explicitly have some incentive effect. Currently, the ECA, ECR and APCR only consider control-oriented mechanisms. ECC is used as a tool to manage the environmen- tal impacts of specific projects rather than to establish an analytical and participatory effort to incorporate the environmental and social concerns of different stakeholders into the decision-making of authorities. By focusing on the environmental impacts of specific projects, ECC has become a “de facto substitute” for the lack of, and weak enforcement of pollution control regulations and effective land-use planning. The inclusion of design and operation conditions as part of the ECC is akin to tailoring CAC reg- ulations to the specific characteristics of a proposed project. ECA and ECR only contemplate the preparation of IIEs and EIAs for projects, primarily industrial and infrastructure develop- ments. A first gap in Bangladesh’s institutional framework is therefore the absence of instruments to assess the environmental implications of policies, which can have a significant influence on the types of projects that are developed later to achieve policy goals. As recommended in chapter 4, the GoB might consider establishing the use of SEAs to assess the social and environmen- tal effects of policies, building on the experiences of other countries, such as Laos and Pakistan (Sánchez-Triana, Enriquez, and Afzal 2014; World Bank 2019). Policy-based Strategic Environmental Assessments (SEAs) can be used to (a) identify environmental priorities for poverty alleviation and analyze the capacity of natural resources and environmental services to support sector-wide economic activities and sector growth; (b) highlight institutional and governance gaps or constraints affecting environmental and social sustainability; (c) promote capacity building and institutional, legal, and regulatory adjustments critical for environ- mental and social sustainability of sector reforms; (d) strengthen accountability on the management of environmental and social risks through increasing transparency and empowering weaker stakeholders; and (e) institutionalize social learning processes around the design and implementation of public policies (World Bank et al. 2011). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 188 Expanding the Range of Environmental Management Tools in Bangladesh Table 10.1. Classification of environmental policy instruments based on flexibility in individual decision-making MINIMUM FLEXIBILITY MAXIMUM FLEXIBILITY Greater government involvement Greater private initiative Control oriented Market-oriented Litigation-oriented Regulations and Final demand Charges, taxes, and fees Market creation Liability legislation sanctions intervention General examples Standards Effluent or user charges: Tradable permits: Performance rating: Strict liability legislation: Government restricts Government charges fees to indi- Government establishes a Government supports label- The polluter or resource user nature and the amount vidual polluters or resource users system of tradable permits ing/performance rating pro- is required by law to pay any of pollution or resource based on amount of pollution or for pollution or resource gram that requires disclosure damages to those affected. use for individual pol- resource use and nature of receiv- use, auctions or distributes of environmental information Damaged parties collect settle- luters or resource users. ing medium. permits, and monitors on the final end-use product. ments through litigation and compliance. Compliance is mon- The fee is high enough to create Performance based on adop- the court system. itored and sanctions an incentive to reduce impacts. Polluters or resource users tion of ISO 14000 voluntary imposed (fines, closure, trade permits at unregulat- guidelines: zero pollution Subsidies: and jail terms) for non- ed market prices. discharge, mitigation plans compliance. Government provides subsi- submitted; pollution preven- dized inputs to encourage their tion technology adopted, adoption. reuse policies and waste recycling. Specific examples for Bangladesh, including instruments proposed under the Environmental Fiscal Reform • Pollution standards • Noncompliance pollution • Payment of ecosystem • Consumer product labeling • Damages compensation to (standards for water charges (proposed charges for services to forest owners (eco-labels) relating to pro- plaintiffs. discharges included in illegal dumping of household to ensure water protec- duction practices, energy • Liability placed on guilty firm’s the ECR). waste). tion ecosystem services. efficiency, and so forth. managers and environmental • Licensing of economic • Pollution charges (proposed • Designation of property • Supply chain intervention authorities. activities (ECC). taxes on air pollution emissions). rights to farmers to im- where intermediate buyers • Long-term performance prove irrigation water and insist on installation of • Land use restrictions • Source-based effluent charges bonds posted for potential or drainage management. Effluent Treatment Plants or zoning require- to reduce downstream water uncertain hazards from infra- for upstream product pro- ments (location treatment requirements • Deposit-refund systems structure construction. duction processes. clearances). (proposed taxes on industrial for solid and hazardous • “Zero net impact” require- effluents). wastes, including ULAB. • Education regarding recy- • Bans applied to ments for infrastructure cling and reuse. specific types of • Royalties and financial com- • Tradable permits for wa- projects. waste (prohibition of pensation for natural resources ter abstraction rights, and • Disclosure legislation polythene shopping exploitation (proposed timber water and air pollution requiring manufacturers bags). extraction taxes). emissions. to publish solid, liquid, and toxic waste generation. • Subsidies to construct Common Effluent Treatment Plants • Blacklisting of polluters. (government-funded industrial parks with CETPs). Source: Sánchez-Triana et al. 2020. The 8FYP mentions a future Environmental Fiscal Reform (EFR), including mainstreaming environment and climate change in planning and budgeting; creating a special fund for environmental conservation areas; adopting pollution charges; phasing out fossil fuels subsidies; setting pricing policies for water, sanitation, and solid waste management, among others. The fiscal reform would also comprise mechanisms to mobilize private finance, potential including through pricing, legal, and regulatory instru- ments, and co-financing through Public-Private Partnerships (General Economics Division 2020). Such an EFR would help the GoB expand the range of environmental management tools and potentially, to move away from the current emphasis on ECC and permit-based regulations. The GoB can benefit from substantial experience from developing and developed countries in implementing alternative environmental management instruments, including lessons about the institutional capabilities need- ed to implement them. While the EFR is not approved yet, the most efficient instrument has been international markets stan- dards required by purchasers of Bangladesh export goods, such as textiles and garments. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 189 Expanding the Range of Environmental Management Tools in Bangladesh 10.3 Market-oriented options 10.3.1 Charges, taxes, and fees A potential advantage of market-oriented instruments, such as charges, taxes, and fees, for environmental management in developing countries is that these are generally designed and implemented by fiscal authorities, which tend to have relatively strong institutional capabilities. Emission or effluent charges are applied to emissions that are released into the air, water or soil and are most suited for large stationary sources. They can be levied on emissions that are directly metered, on a proxy source (for instance, water consumption can be used as a proxy for wastewater emissions), a presumptive pollution level or in the form of a flat rate (The World Bank Group; United Nations Environment Programme; United Nations Industrial Development Organization, 1999). Given the lack of widespread monitoring in Bangladesh, a presumptive pollution level might be considered. Under this approach, a firm is compelled to pay the charge with no specific monitoring conducted, based on an international benchmark or available in-country data. If the firm wishes to reduce its tax burden, it must conduct monitoring at its own expense (but still subject to regulatory audit) to demonstrate that its actual pollution loads are less than the presumed loads. Another critical consideration in designing the taxes is ensuring that they target the specific pollutant that is causing the most significant effects. A common, but inefficient practice, has been to adopt taxes for water pollutants such as Biological Oxygen Demand or Total Suspended Solids. Taxing these pollutants is convenient because their discharges are measured and can be- come a significant source of tax revenues. However, it would be more efficient to tax pollutants that are known to cause the most significant environmental health risks, such as hazardous waste and chemicals. Similarly, the GoB might consider taxing the sources of air pollutants that are associated with the most significant health effects, considering higher rates for the most harmful emissions such as from coal-fired power plants and diesel vehicles (Thurston et al. 2021). Given that many of leading air pollutants also contribute to climate change and are emitted from the same sources, there might be opportunities to tax these same sources through carbon taxes, thereby building synergies between air quality management and climate change mitigation (chapters 6 and 7). Following this approach, the World Bank has helped client countries, including in the metropolitan area of Medellin, Colombia, to design taxes targeting primary and secondary PM2.5 from mobile and stationary sources. In Bangladesh the GoB could, for example, consider a carbon tax focused on the energy sector to be implemented progressively. This additional carbon tax would be introduced in the fuel tax system, requiring only limited administrative capacity with little scope for noncompliance (World Bank 2022). Additionally, the GoB should consider a policy reform to earmark part of the revenue generated from pollution charges to finance environmental and health activities. Before fixing the tax rate, governments need to carefully analyze the country’s economic, social, and political context. If not cor- rectly designed and implemented, pollution taxes may sometimes cause undesired effects or disproportionately affect low-in- come groups (Partnership for Market Readiness 2017). To prevent these cases from happening, the GoB should consider conduc- ing economic and distributional modeling to predicting potential leakage or distributional impacts and mitigation measures. As the GoB moves forward with the transition from subsidizing to taxing fossil fuels indicated in the 8FYP and other component of the EFR, it might consider using quantitative and qualitative methods to assess their effects on lower income households, as well as assessing the capacity of existing safety nets to protect the poor and vulnerable from potential shocks (chapter 7). For more specific guidance on how these assessments may be conducted, see the Energy Subsidy Reform Assessment Framework developed by the World Bank’s Energy Sector Management Assistance Program (see https://esmap.org/esraf). For example, this type of policy could be accompanied by income redistribution and other measures to avoid potential increase in the use of solid fuels by poor households, as a result of increased prices of LPG. 10.3.2 Deposit-refund systems Deposit-refund systems are another potentially relevant environmental policy instrument that has not been mentioned as part of the EFR under 8FYP. In such system, regulators impose a monetary sum that is paid when a product is purchased. This deposit is refunded when the item or its packaging is returned for recycling or appropriate disposal. This model has advantages over taxes that are applied directly to waste and has been successfully implemented in many countries, being a potential instrument for plastic waste management (chapter 8). A deposit-refund system can be effective in coping with some challenges that arise from waste management taxes that are applied directly to households. For instance, households might turn to waste burning or illegal dumping when waste disposal is directly taxed. Conversely, rebates for products that are returned constitute an incentive for appropriate waste management. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 190 Expanding the Range of Environmental Management Tools in Bangladesh In the United States, deposit-refund systems are applied to different products as lead-acid batteries, pesticide containers and tires. The Battery Council International (BCI), recommends retailers to charge a $10 deposit on all batteries sold, the fee is reim- bursed when the customer returns the used battery for recycling within 30 to 45 days of purchase. According to the BCI, lead batteries have a recycling rate of 99.3 percent and are the most recycled consumer product in the US. The rate of recycling is attributed to industry investment in a state-of-the-art closed-loop collection and recycling system which keeps more than 129 million lead batteries away from landfills annually (SmithBucklin Statistics Group 2019). As lead exposure is a major environmental health risk in Bangladesh, the GoB might consider establishing a deposit/refund schemes for the purchase of Lead Acid Batteries (LAB), a major source of lead pollution in Bangladesh (GAHP 2021). Under this policy instrument, a charge would be made on the new battery and returned to the customer when the used battery is returned to a shop that sells LAB for recycling. Another potential tool consists of a battery fee imposed on buyers that is transferred to formal sector recyclers after they demonstrate that they have purchased and safely recycled a Used Lead Acid Battery (ULAB). The additional income received from this fee should increase the amount that formal sector recyclers can pay for ULABs, there- fore reducing, and hopefully reverting, the disadvantage that formal collectors face in the market. This tool must be carefully designed to provide the appropriate level of incentive to the formal sector to bid more for ULABs. It should also be carefully ad- ministered to ensure that formal sector operators only receive the income from the fee only if they purchase and safely recycle a ULAB (Global Battery Alliance 2020). 10.3.3 Extended Producer Responsibility (EPR) Extended Producer Responsibility (EPR) refers to a policy that aims to make producers responsible for the environmental im- pacts of their products throughout the value chain, from the design to the post-consumer phases (OECD 2016). EPR systems have been adopted with the aim of alleviating municipalities’ burden for managing waste, reducing the amount of waste des- tined for final disposal, and increasing rates of recycling – another relevant policy for plastic and hazardous waste management, such as from lead acid batteries (chapters 5 and 8). In addition, by shifting the responsibility upstream toward the producer, EPR systems aim to provide incentives to producers to include environmental considerations in their products’ design. Hilton et al. (2019) identified about 400 EPR systems in operation worldwide, most of them in OECD member countries. Elec- tronics, tires, and packaging are products for which many EPR systems have been adopted worldwide. EPR systems may include a physical responsibility for adequately collecting and treating the waste and/or a financial obligation to pay for such collection and treatment. Bangladesh’s Solid Waste Management Rules 2021 include provisions based on the EPR. It will be important to monitor the effectiveness of this approach, and based on that information, assess opportunities to either expand it to other products or identify opportunities to strengthen it. EPR approaches could also be used to collect LABs at the end of their useful lives. These schemes, (also known as “Producer Take Back”) have been implemented in countries such as Brazil and aim at incentivizing manufacturers to create products that are more durable, recyclable, and less toxic and to develop a sales network that recovers the ULAB. In Brazil, regulations impose on battery manufacturers the responsibility to control and report on all processes involving ex- traction, utilization, and recovery of lead components. By adopting reverse logistics, retailers were able to collect and send back all ULABs to distributors, and for distributors to divert ULABs to legal smelters appointed by the manufacturers. The regulations helped legal, controlled organizations regain control of the lead reclaiming process, leading to a more upgraded industry and significantly lower environmental impacts. In 2007, before the regulations were adopted, global secondary production of lead accounted for 54 percent of the refined lead production in Brazil; this share climbed to 70 percent and was projected to reach up to 90 percent by 2020 (Global Battery Alli- ance 2020). Brazil’s “Producer Take Back” regulations were complemented by fiscal reforms that exempted taxes on ULAB cores parts, to discourage sales to the informal sector. This tax exemption contributed to decrease reliance on informal recyclers in the lead battery value chain, without reducing government revenues. As higher volumes of LABs were produced or retailed due to the higher quantity and lower cost of reclaimed lead stimulated by adopted regulations, government’s overall tax revenue increased (Global Battery Alliance 2020). To be successful, such mechanisms must try to avoid creating a financial burden on authorities, except for the relatively small costs associated with monitoring the scheme to ensure that LAB sales, including those in new vehicles, match ULAB recovery (Basel Convention 2004). Manufacturers should anticipate their batteries being recycled and returned to them and should create pathways to allow for this process through reverse logistics (Global Battery Alliance 2020). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 191 Expanding the Range of Environmental Management Tools in Bangladesh 10.3.4 Final demand interventions Final demand interventions provide information to investors, consumers, and the public, and decentralize decision making to the final consumer. These tools can encourage behavioral change of consumers towards long-term sustainability, encouraging producers to adopt more environmentally friendly approaches. One form of final demand intervention involves promulgating disclosure requirements. The GoB might consider establishing public disclosure schemes in key sectors, building on the experi- ences from other LMICs, such as label systems to raise awareness of companies’ environmental performance, and disclosure of pollution charges paid by firms. The Eco-watch program in the Philippines provided incentives to industries to comply with environmental regulations by setting up an environmental grading, color labeling system to categorize companies’ environmental performance. In 1997, before the program came into effect, over 92 percent of plants were found to be noncompliant; by 1998 the number of compliant plants increased to 58 percent (Kathuria 2008). For foreign buyers, the Accord on Fire and Building Safety in Bangladesh provides a good example of engagement with external stakeholders that could be adapted for environmental compliance. In 2013, this legally binding Global Framework Agreement was signed by global brands, retailers, and trade unions to improve safety and health con- ditions in the Bangladeshi Ready-Made Garment (RMG) industry. In Colombia, the Cauca Valley Corporation adopted a water pollution charge program. The effluent fees paid by firms were publicly disclosed and the publicity influenced the reputation and decisions of company leaders reducing the discharge of water pollutants (Sánchez-Triana and Ortolano 2005). Korea’s CleanSYS monitors the air pollutants emitted from stacks in real time using an automatic stack measuring device that connects online to control centers at the Korea Environment Corporation (K-eco). This information is then used to enforce regulations, inform new policy measures, and shared with public agencies for purposes of financial decision-making, including for credit application from the private sector. As the system is based on au- tomated telemonitoring devices, it reduces administrative burden and enable early warning and real time public disclosure of measurements85. While labels convey a signal of how environmentally friendly a product is, disclosure requirements provide information on the envi- ronmental performance of a firm, including emissions to air, wastewater discharges, waste, and compliance with standards. There are no sanctions attached to such disclosure, but it gives investors and consumers a better-informed choice among multiple goods, services and investments. 10.4. Litigation-oriented options: Liability legislation Liability for environmental harm is designed to compensate affected individuals or groups, with a particular focus on restoring or replacing damaged resources and/or compensating lost value (Jones et al. 2015). Litigation-oriented approaches to environ- mental management require only that legislation be in place that confers relatively straightforward rights and obligations to resource users. These approaches form a legal umbrella for court cases, which then consider the nature and extent of environ- mental damages on a case-by-case basis. Advocates of liability legislation argue that it is a highly efficient instrument to address externalities because it only requires monitoring of specific incidents, rather than a need to monitor behavior, as is required by regulation (Shavell 2013). Common challenges faced in developing countries include difficulties in estimating damages and the required compensation and limited accountability for ensuring that recoveries intended for restoration are spent to that end (Jones et al. 2015). Even in industrial countries, the use of liability legislation is hampered by the analytical difficulties of establishing cause and effect, or of ascribing blame or negligence. In the case of Bangladesh, the priority measures for enhancing the environmental court system are to (a) reform the Environment Court Act, expanding legal standing to all citizens and creating the roles of environmental prosecutors and technical experts, (b) adopt further rules and guidelines for applying the polluter pays principle (for example, criteria for setting the value of fines and imposing more severe penalties), and (c) invest in training for judges and court staff on major environmental issues (chapter 3). Furthermore, use of the courts to tackle environmental challenges must bring with it the awareness that these mechanisms of- ten discriminate against the poor and others with limited access to legal recourse. To address that, DoE could foster partnerships with the Public Attorney’s Office, the Bangladesh Bar Council, law schools and pro bono legal organizations. Disclosing environ- mental data, such as pollution levels in certain areas and detailed information of enforcement activities performed by DoE, is also essential to inform judicial processes and can be even more important when citizens obtain direct access to environment courts. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 192 Expanding the Range of Environmental Management Tools in Bangladesh 10.5 Conclusions and recommendations As Bangladesh continues to develop its institutional framework for environmental management, it should consider developing a wider range of environmental instruments, including (a) economic and market-based instruments, such as pollution charges, deposit-refund schemes, EPR, and final demand interventions, and (b) litigation-based instruments, including liability legislation. These instruments could initially focus on identified environmental priorities and gradually expand to cover additional areas. In this process, the GoB should carefully assess the interventions’ potential economic, social, and distributional effects, as well as identify mitigation measures for those impacts. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 193 Expanding the Range of Environmental Management Tools in Bangladesh C10 References / Endnote Ahmed, S. 2017. “Background Paper on Determinants of a Green Growth Strategy for Bangladesh.” Policy Research Institute of Bangladesh. UKaid, Economic Dialogue on Green Growth. Ahmed T., M. Q. Hasan, and M. O. Sarwar. 2021. “Trends in Punitive Actions against Environmental Pollution in Bangladesh.” IAIA Conference. https://conferences. iaia.org/2021/edited-papers/1246_AHMED_Trends%20in%20Punitive%20Actions.pdf Alvarado, M. J., A. E. McVey, J. D. Hegarty, E. S. Cross, C. A. Hasenkopf, R.  Lynch,  E. J.  Kennelly,  T. B.  Onasch,  Y.  Awe,  E. Sánchez-Triana,  and G.  Kleiman. 2019. “Evaluating the Use of Satellite Observations to Supplement Ground-Level Air Quality Data in Selected Cities in Low- and Middle-Income Countries.” Atmospheric Environment 218. Basel Convention. 2004. Training Manual: National Management Plans for Used Lead Acid Batteries. Basel Convention Series/SBC No. 2004/5. https://www. basel.int/Portals/4/Basel%20Convention/docs/meetings/sbc/workdoc/tm-ulab/tm_ulab.pdf DoE (Department of Environment). 2023. Annual Report 2021–2022. http://www.DoE.gov.bd/sites/default/files/files/DoE.portal.gov.bd/annual_reports/7b7587fa_ cfe1_4b2a_aa5c_f6b27202b8fa/2023-03-24-09-12-551f98f0ffba744894abfb8100b3b2af.pdf Enriquez, S., E. Sánchez-Triana, and M. G. Guerra Lopez. 2021. “Economic Instruments and Financial Mechanisms for the Adoption of a Circular Economy.” In An Introduction to Circular Economy, edited by L. Lerwen and S. Ramakrishna. Springer. Environmental Law Institute. 2010. India 2030: Vision for an Environmentally Sustainable Future: Best Practices Analysis of Environmental Protection Authorities in Federal States. Study commissioned by the World Bank. Washington, DC: World Bank. http://www.eli.org/pdf /india2030.pdf. Ericson, B., T. T. Duong, J. Keith, T. C. Nguyen, D. Havens, W. Daniell, C. J. Karr, D. Ngoc Hai, L. Van Tung, T. Thi Nhi Ha, B. Wilson, D. Hanrahan, G. Croteau, M. Patrick Taylor. 2018. “Improving Human Health Outcomes with a Low-Cost Intervention to Reduce Exposures from Lead Acid Battery Recycling: Dong Mai, Vietnam.” Environmental Research 161: 181–87, https://doi.org/10.1016/j.envres.2017.10.042. ESDO and UNEP (Environment and Social Development Organization and United Nations Environment Programme). 2021. National Strategy for Used Lead Acid Battery (ULAB) Recycling in Bangladesh: A Sustainable Strategy for ULAB Waste Management. Dhaka, Bangladesh: ESDO. https://wedocs.unep.org/bitstream/ handle/20.500.11822/36344/ULABSB.pdf?sequence=3&isAllowed=y ESDO, UNEP, and Pure Earth (Environment and Social Development Organization, United Nations Environment Programme, and Pure Earth). 2020. Comparative Review: Assessment of Regulations on ULAB in Bangladesh and Recommendations for Legislation. https://wedocs.unep.org/bitstream/ handle/20.500.11822/36330/CRRV.pdf?sequence=3&isAllowed=y Ferdous, B. F. 2017. Governance for Green Growth in Bangladesh: Policies, Institutions and Political Economy. United Kingdom Agency for International Development. https://www.greengrowthknowledge.org/research/governance-green-growth-bangladesh-policies-institutions-and-political-economy General Economics Division. 2020a. 8th Five Year Plan, July 2020 – June 2025: Promoting Prosperity and Fostering Inclusiveness. Bangladesh Planning Commission, Government of the People’s Republic of Bangladesh. General Economics Division. 2020b. Making Vision 2041 a Reality: Prospective Plan of Bangladesh 2021–2041. Bangladesh Planning Commission, Government of the People’s Republic of Bangladesh. Margulis, S., and T. Vetleseter. 1999. “Environmental Capacity Building: A Review of the World Bank’s Portfolio.” Environment Department Paper 68, Pollution Management Series, Washington, DC: World Bank. Nahar, N., S. Mahiuddin, and Z. Hossain. 2021. “The Severity of Environmental Pollution in the Developing Countries and Its Remedial Measures.” Earth 2: 124–39. https://doi.org/10.3390/earth2010008 Rana, M. 2021. “Law to Curb Air Pollution: Where Does Bangladesh Stand?” Opinion Pages, bdnews24.com. https://opinion.bdnews24.com/2021/06/06/law-to- curb-air-pollution-where-does-bangladesh-stand/ Rehfuess, Eva, Elisa Puzzolo, Debbi Stanistreet, Daniel Pope, and Nigel Bruce. 2014. “Enablers and Barriers to Large-Scale Uptake of Improved Solid Fuel Stoves: A Systematic Review.” Environmental Health Perspectives 122 (2): 120-30. http://dx.doi.org/10.1289/ehp.1306639 Sánchez-Triana, E. 2021. Environmental Challenges for Green Growth and Poverty Reduction: A Country Environmental Analysis for The Lao People’s Democratic Republic. Washington, DC: World Bank Group. http://hdl.handle.net/10986/36266 Sánchez-Triana, E., and L. Ortolano. 2005. “Influence of Organizational Learning on Water Pollution Control in Colombia’s Cauca Valley.” Water Resources Development 21: 493–508. https:// doi.org/10.1080/07900620500139168 Sánchez-Triana, E., S. Enriquez, J. Afzal, A. Nakagawa, and A. K. Shuja. 2014. Cleaning Pakistan’s Air: Policy Options to Address the Cost of Outdoor Air Pollution. Washington, DC: World Bank. doi:10.1596/978-1-4648-0235-5. Sánchez-Triana, E., S. Enriquez, B. Larsen, P. Webster, and J. Afzal. 2015. Sustainability and Poverty Alleviation: Confronting Environmental Threats in Sindh, Pakistan. Directions in Development. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/22149 Sharmin, N., F. Rahman, G. Mohiuddin, and A. S. Juel Miah. 2017. Climate Finance and Local Government Institutions: Governance in Project Implementation. Transparency International Bangladesh. https://www.researchgate.net/publication/353105019_Climate_Finance_and_Local_Government_Institutions_ Governance_in_Project_Implementation/link/60e7695b30e8e50c01f0360f/download von Stackelberg, K., P. Williams, E. Sánchez-Triana, and S. Enriquez. 2022. Recycling of Used Lead-Acid Batteries : Guidelines for Appraisal of Environmental Health Impacts. International Development in Focus. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/36593 World Bank. 2003. World Development Report 2003: Sustainable Development in a Dynamic World – Transforming Institutions, Growth, and Quality of Life. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/5985 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 194 Expanding the Range of Environmental Management Tools in Bangladesh World Bank. 2007. Republic of Peru Environmental Sustainability: A Key to Poverty Reduction in Peru (English). Washington, DC: World Bank Group. http:// documents.worldbank.org/curated/en/896441468296943537/Republic-of-Peru-environmental-sustainability-a-key-to-poverty-reduction-in-Peru World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh: Country Environmental Analysis 2018. Washington, DC: World Bank Group. http://hdl.handle.net/10986/30558 World Bank. 2019. Pollution Management in Kosovo. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/33041 World Bank. 2020a. Clearing the Air: A Tale of Three Cities. Washington, DC: World Bank. https://openknowledge.worldbank.org/handle/10986/34757 World Bank. 2020b. Mexico Environmental Sustainability and Urban Resilience Development Policy Finance. Program Document. Report No: PGD210. Washington, DC: World Bank. https://documents1.worldbank.org/curated/en/683551608519753087/pdf/Mexico-Environmental-Sustainability-and-Urban- Resilience-Development-Policy-Financing.pdf World Bank. 2022. “Bangladesh Country Climate and Development Report.” Washington, DC: World Bank Group. https://openknowledge.worldbank.org/server/ api/core/bitstreams/6d66e133-e49d-5ad9-b056-7b1a6c6206ed/content Endnote 85 Korea Environment Corporation (K-eco). https://www.keco.or.kr/en/core/climate_air3/contentsid/1948/index.do BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 195 A Way Forward CHAPTER 11. A WAY FORWARD Over the last decade, Bangladesh has made tangible progress in its policy regime and systems for environmental and pollution management. Yet, much more needs to be done to control environmental degradation and improve the people’s health and economic productivity. Based on the country’s environmental priorities, the CEA has identified priority interventions to improve environmental quality and accelerate Bangladesh’s transition towards green growth. The following recommendations cover pol- icies and investments to (a) enhance environmental governance, especially the institutional capacity of environmental agencies; and (b) control pollution at its sources with interventions in key economic sectors. Table 11.1 summarizes these recommendations, indicating their potential impact and timeline. 11.1 Interventions to address Bangladesh’s environmental priorities The CEA provides policy and investment options to the GoB to address household and outdoor air pollution; improve water, sanitation and hygiene (WASH); reduce exposure to lead; and improve plastic waste management. Approving a National Air Quality Management Plan (NAQMP) to reach WHO’s annual PM2.5 Interim Target 1 of 35 µg/m3 by 2030, coupled with a Heavy Air Pollution Contingency Plan (HAPCP) to reduce emissions and people’s suffering during times of ex- treme pollution, should be a top priority for the GoB. Interventions under those plans should be implemented through a clean air program based on diverse policy instruments. Interventions to reduce ambient PM2.5 should include (a) eliminating the burn- ing of solid waste, coupled with the separation of food waste and its collection and centralized composting in urban and rural areas; (b) improving the management of agricultural fertilizers and livestock manure; (c) controlling emissions from industry and the power sector, including by improving fuel quality; (d) reducing road and construction dust, covering nonmotorized mobility and traffic-management initiatives; (e) modernizing brick kilns and shifting from fired clay bricks to non-fired blocks or other alternative building materials; and (f) replacing the household use of solid fuel for cooking by switching to liquefied petroleum gas (LPG) or electricity. Item (f) is the most effective intervention to improve ambient PM2.5, and this step has the added benefit of reducing the health effects of household air pollution. To design the priority measures for controlling household air pollution, the GoB should (a) further assess the potential for promoting the use of electric stoves for cooking, and perhaps especially induction stoves. This is a cheaper option than LPG for small users of electricity that can benefit from lower residential block tariff rates for electricity; and (b) further assess price and non-price obstacles and incentives for adoption of LPG for cooking. In the transition to cleaner fuels for households, the continued expansion of improved cookstoves programs (particularly promotion of dual-burner stoves) will continue to be important for households that cannot afford cooking with LPG or electricity. A comprehensive program must include a portfolio of measures that deliver sufficient air quality improvements, while also being economically, socially, administratively, and politically acceptable. In parallel, health policies are needed to (a) enhance curative care of health problems brought on by air pollution; and (b) gather community-level data on the health issues in air pollution hotspots, coupled with meteorological and air quality data, to inform policy decision-making. Because of transboundary emis- sions, cooperation across Bangladesh districts and with countries of the Indo-Gangetic Plain is indispensable for achieving sub- stantial air quality improvements. At the same time, regionally harmonized strategies could alleviate the need to take the most expensive measures. To address the challenges of lead pollution and population exposure, which will still take time to solve, the GoB should prioritize undertaking representative BLL measurement studies along with identifying sources of lead exposure. These data will inform further policy formulation. In the meantime, to mitigate the impacts of lead exposure, the GoB may consider provisional inter- ventions to (a) supplement iron for children ages 6 to 59 months; (b) replace lead contaminated cookware made from recycled aluminum; and (c) rehabilitate abandoned used lead-acid battery (ULAB) recycling sites. The main benefit of these interventions is increased lifetime income from averting IQ losses in early childhood. Additionally, immediate action can be taken to (d) build the country’s laboratory capacity for measuring BLL and testing lead in food and other products; and (e) enhancing coordination across environmental, health, food safety and consumers agencies to improve data management, policy formulation and aware- ness of lead poisoning and prevention measures among key stakeholders such as health providers and community leaders. To improve WASH, the interventions with the highest benefit-cost ratios for addressing microbiological pollution that should be prioritized are (a) household point-of-use treatment of drinking water with ceramic filter; (b) safely managed improved non- shared sanitation for households currently having unimproved sanitation; and (c) promotion of handwashing with soap targeting caregivers of children under five. Further measures that should follow are (a) safely managed improved non-shared sanitation for BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 196 A Way Forward households currently sharing sanitation with other households; and (b) promotion of handwashing with soap to all household members. For mitigating exposure to arsenic in drinking water, three control interventions should be prioritized: provision of deep tube wells; ponds with sand filter; and household filtering, such as SONO filter that uses iron and sand filtration. Investing in a comprehensive program for water resources management, as envisaged in the Bangladesh Delta Plan 2100, could be highly beneficial not only to improve WASH, but also to mobilize local labor and other unemployed resources. In the short-term, further analysis on water pollution is needed to (a) assess the impacts of other highly poisonous heavy metals in both drinking water and rivers, such as lead, mercury, and cadmium, (b) assess the impacts of and potential solutions for salinity intrusion; and (c) identify specific interventions to manage industrial effluent or liquid discharge as well as untreated municipal sewage water. For improving plastic waste management, the GoB should adopt a holistic integrated approach based on a combination of le- gal, financial, and communication instruments. Recommended measures include (a) research and development of alternatives to single-use plastics; (b) effective implementation of the ban on plastic bags and extending its scope to other single-use plastic items; (c) mandatory Extended Producer Responsibility (EPR) guidelines to enable industry co-funding of plastic-waste collection and recycling systems and establish producer responsibility organizations (PROs); (d) an integrated waste management frame- work to address growing plastic waste and disposal in open places; (e) waste segregation at the household level, developing the missing infrastructure, and conducting behavior-change campaigns; (f) harmonization of plastic-management policies to promote circular economy; (g) plastic cleanup and recovery schemes to reduce legacy plastic waste and mitigate associated impacts; and (h) a monitoring system for the implementation of the Solid Waste Management Rules 2021 and targets of the Plastic Action Plan. 11.2 Strengthening environmental governance systems To design and implement the pollution management interventions, the GoB also needs to overcome shortcomings in its envi- ronmental governance framework. Additional measures are needed to inform policy and decision-making with reliable data; expand the range of environmental policy instruments beyond command-and-control; improve the organizational structure and institutional capacity of the MoEFCC and DoE, as well as their coordination with line agencies and local governments; fulfill environmental justice and promote citizen-driven accountability; and enable the environment for green financing. 11.2.1 Setting evidence-based priorities and decision-making. Bangladesh’s environmental governance system shows a misalignment between the country’s environmental priorities—such as air and water quality, control of lead and other hazardous chemicals—and its organizational structure, efforts, and resource allocation. This is largely due to (a) the absence of an integrated system of reliable data collection, management, and dissemi- nation, and the absence of organizational capabilities to provide analytical support to the decision-making process; (b) the lack of representation of vulnerable groups that are mainly affected by environmental degradation; and (c) the absence of a formal planning mechanism for allocating financial and human resources according to clearly defined environmental priorities that are linked to poverty alleviation and social priorities. To address those challenges, the GoB needs to enhance its environmental monitoring and data management capacity, includ- ing systematic evaluation of government interventions, automated air and water quality monitoring networks, outcome-orient- ed indicators to assess institutional performance, and adequate institutional presence in the field with sufficient and well-trained staff. Another key measure is the creation of a research and development unit at the DoE. This unit would conduct the analytical work in partnership with other government agencies and development partners to identify priorities and inform environmental planning—for example, through estimates of the cost of environmental degradation, cost-benefit analyses, and economic and distributional modelling. 11.2.2 Diversifying and strengthening environmental policy instruments As Bangladesh continues to develop its legal and institutional framework for environmental management, it should consider de- veloping a wider range of environmental instruments, including (a) economic and market-based instruments such as pollution charges, deposit-refund schemes, EPR, and final demand interventions; (b) litigation-based instruments, including liability legis- lation; and (c) information-based instruments, such as awareness campaigns on the health effects of pollution and measures to improve hygiene, and regular dissemination of environmental quality data and pollution loads, such as user-friendly alert systems on air quality and pollution hotspots, publication of lists of highly polluting industries, and detailed results of enforcement ac- BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 197 A Way Forward tivities. In designing the new policy instruments and associated investments, the GoB should carefully assess the interventions’ potential economic, social, and distributional effects, as well as identify mitigation measures for those impacts. These policy instruments could initially focus on identified environmental priorities, such as through a carbon tax and incentives for household use of cleaner fuels for cooking, and gradually expand to cover additional areas. As indicated by the experiments of the CGE Bangladesh Bioeconomic 101 model, the phaseout of existing energy subsidies may be a first choice for a fiscal policy intervention, with beneficial effects on both efficiency and environmental protection, especially for air quality. Its impact on in- clusiveness would also be beneficial if the policy were to be combined with a redistribution of government savings to the poor. Setting the stage for efficient carbon markets also appears to be a feasible policy for Bangladesh with several beneficial effects, especially if combined with suitable policies for redistribution to poorer households. Additionally, these policy options may be reasonably effective in generating benefits (reduction of externalities), increasing GDP, and improving the condition of the poor. However, a combination of policy measures seems more effective than isolated interventions. In addition, command-and-con- trol policies can be usefully complemented by fiscal and redistribution measures. Furthermore, compared to GDP, net social benefits tend to grow more than proportionally with policy combinations—and even more so if these policies include redistrib- utive policies. As for command-and-control, a comprehensive amendment to the Environment Conservation Act and its rules is needed to (a) modernize and make enforcement activities more efficient, including clear provisions to implement the polluter pays principle and set adequate sanctions and incentives for compliance with the ECA provisions; (b) set the mandates and foundations for further regulations on EPR and Payment for Ecosystem Services (PES); (c) mobilize green financing by establishing a permanent environmental fund, which could receive resources from the compensation for environmental damage envisaged in Article 7 of ECA and eventually from environmental taxes; (d) improve stakeholder engagement in environmental decision-making; (e) require Strategic Environmental Assessment for policies, plans, and programs to be further regulated through specific rules, among other themes. Such as a diverse, economically efficient policy and regulatory framework is essential to increase the effectiveness of environ- mental clearance system, especially to improve decision-making. As a first measure, the DoE should conduct an in-depth, in- dependent evaluation of ECCs approved for red and orange category projects, to extract common challenges and lessons to inform policy formulation—not only for improving the EC process, but also further regulate specific technical requirements. The GoB should amend the ECA or adopt a specific act to require SEAs for policies, programs, and plans, and establish the mandates and procedures for those assessments. Although the ECR 2023 is expected to improve the EC process, additional amendments and guidelines are required to clarify and strengthen assessment criteria and procedures related to key themes – for example, the screening of projects that are not pre-categorized in the ECR; monitoring and enforcement after ECC issuance; stakeholder consultations and access to information, including through ICT tools. 11.2.3 Strengthening organizational structure and institutional capacity The GoB should carry out a detailed analysis of the organizational structure under the MoEFCC and affiliated agencies to set clearer mandates and more efficient processes for environmental governance, including interagency coordination. The DoE needs specialized technical units to respond to identified environmental priorities with the necessary human, technical, and financial resources to fulfill their mandates. Rising the DoE’s budget is essential to strengthen its capacity to execute decisions, especially for monitoring and enforcement activities. The GoB could consider a policy reform to earmark part of the revenues generated from fines and pollution charges to finance environmental activities, such as those expected from the proposed EF. Additionally, establishing a cadre of environmental specialists and increasing DoE’s headcount will allow more qualified profes- sionals to reach senior official positions, attract and retain talented individuals, and ensure that decisions and policies are made by people with adequate background and experience. Completing the DoE’s decentralization process is also essential to expand its physical presence to all districts, with adequate staffing, equipment, and budget, and to expedite actions and better balance the needs and priorities of central government officials and politicians with local stakeholders. For that, a comprehensive infor- mation management system with automated monitoring for compliance and enforcement is essential for an effective decen- tralization process, as well as for gathering critical data to inform decision-making and public participation. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 198 A Way Forward 11.2.4 Strengthening environmental justice and citizen-driven accountability. Responding to priority environmental challenges in Bangladesh calls for a more systematic effort to raise awareness and social accountability regarding environmental issues. Also missing in the current institutional framework are mechanisms to incorpo- rate the concerns of groups most severely affected by environmental degradation into the GoB’s planning processes, as well as to allow citizens to directly litigate in environmental courts as plaintiffs. Ways to improve public information and promote trans- parency, accountability, and awareness include the publication of data in support of key environmental indicators (including pollution loads and environmental health statistics); wider use of public forums to air development initiatives; and broader and more detailed review and discussion of environmental management tools. Mechanisms to disseminate information in a manner that is easily interpretable can allow communities to serve as informal regulators. To improve the environment court system, the GoB should proceed with a comprehensive reform of the Environment Court Act, expanding legal standing to all citizens and creating the roles of environmental prosecutors and technical experts. An en- vironmental prosecution agency that is independent from the DoE and shielded from political interference could make the environmental courts system more effective. Additionally, the DoE could promote partnerships with the Public Attorney’s Office, the Bangladesh Bar Council, law schools, and pro bono legal organizations to support those citizens with limited access to legal recourse. Additional rules and guidelines are needed for applying the polluter pays principle effectively, including for example, criteria for setting the value of fines, precautionary measures, and more severe penalties such as confiscation of equipment, suspension of construction and productive activities, and payment of daily fine for not complying with court orders. Judges and court staff should be regularly trained on major environmental issues, especially those that are subject to the highest number of judicial cases (for example, illegal brick kilns). Disclosing environmental data, such as pollution levels in certain areas and detailed in- formation of enforcement activities performed by the DoE, is also essential to inform judicial processes and can be even more important when citizens obtain direct access to environment courts. 11.2.5 Building an enabling environment for green financing To facilitate the flow of resources from green finance suppliers to sectors pursuing these resources, the GoB should create an environmental management ecosystem by (a) adopting a broad-based national green growth strategy and a national action plan backed by a commensurate set of regulatory and institutional frameworks, (b) constituting a high-level national oversight body to coordinate and monitor the progress of green growth efforts, and (c) creating an ecosystem of ministries and govern- ment agencies that collect and analyze point-source data to enforce policies that create a pipeline of verified investment-ready projects. In expanding its range of environmental policy instruments, the GoB should use a mix of incentives to boost environmental markets by (a) encouraging the adoption of green practices and promoting green businesses and investments with positive environmental externalities, (b) adopting incentives that address the risks faced by FIs, (c) fostering a collaborative institutional system to imple- ment green financial incentives, and (d) reducing the risks perceived by financiers and boosting private-sector adoption of green practices and technologies, and thereby boosting the offering of green products and services. It is also essential to strengthen institutional and borrower capabilities by building skills and expertise on green financing across sectors, from technocrats in gov- ernment agencies to FIs, and from private businesses to students. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 199 A Way Forward Table 11.1 Summary of CEA recommendations Implementation period Type a Action Immediate Short-term Medium-term priority (2024–25) (2026–30) Pillar A. Addressing Bangladesh’s environmental priorities A.1 Improving ambient and household air quality (chapters 2, 5, 6, and 7) Adopt a National Air Quality Management Plan (NAQMP) based on diverse policy instruments, including measures to address both ambient and • household air pollution. Adopt a Heavy Air Pollution Contingency Plan (HAPCP) to reduce emissions and people’s suffering during times of extreme pollution, including • requirements and procedures for triggering a graded set of restrictions. Promote use of clean energy in cooking, switching from solid fuel use to liquefied petroleum gas (LPG) or electricity. • • • Further assess (a) the potential for promoting the use of electric stoves for cooking, and (b) price and non-price obstacles and incentives for adoption of • LPG for cooking. Control emissions from industry and the power sector including stricter emis- sion standards for coal and furnace oil-fired power plants; mandate the instal- lation of emission control devices on smokestacks; invest in renewables for electricity generation; restrict the installation of future coal-fired powerplants; • • • and provide incentives, subsidies, and tax breaks to manufacturers who invest in clean technologies. Improve quality of fuels (especially with low-sulfur diesel), enforce traffic control and effective management systems; enforce vehicle emissions inspections; restrict high-emission vehicles from roads (including heavy- duty vehicles); optimize urban layout strategies to prioritize sustainable • • • transportation modes; and incentivize mass, nonmotorized, and electric mobility. Improve fertilizers and livestock-manure management to control ammonia emissions. • • • Reduce emissions from waste through integrated solid waste management (see item A.4 below). • • • Reduce road and construction dust, including investments in paving and street-washing practices. • • • Modernize brick kilns and promote use of non-fired bricks. • • • Set the stage for carbon markets, including MRV systems, and adopt fiscal instruments to address air pollution, such as the phaseout of energy subsidies • • and a carbon tax, combined with redistribution measures to the poor. Conduct and regularly update emissions inventories and source apportionments, combined with other relevant analytics and data • • • management (see items B.1 and B.4 below). Collaborate with neighboring countries to address transboundary air pollution, especially PM2.5 emissions. • • • BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 200 A Way Forward Implementation period Type a Action Immediate Short-term Medium-term priority (2024–25) (2026–30) A.2 Reducing exposure to lead (Pb) and other heavy metals (chapters 2 and 5) Adopt temporary measures to reduce exposure to Pb: (a) supplement iron for children from 6 to 59 months, (b) replace Pb contaminated cookware made from recycled aluminum, and (c) rehabilitate abandoned used lead-acid • • battery (ULAB) recycling sites. Build the country’s laboratory capacity for measuring BLL and testing Pb in food and other products. • • Undertake representative BLL measurement studies along with identification of sources of Pb exposure in households, communities, schools, and specific • • sources, to inform further policy formulation. Improve analytical base on the impacts, sources, and measures to control other heavy metals (especially mercury and cadmium). • Adopt additional policies and investments to reduce exposure to heavy metals based on further analysis of its major sources and hotspots. • • Enhance coordination across environmental, health, food safety, and consum- er agencies to improve data management, policy formulation, and awareness of lead poisoning and prevention measures among key stakeholders such as • • • health providers and community leaders. A.3 Improving drinking water, sanitation, and hygiene (chapters 2, 5, 6, and 7) Prioritize (a) household point-of-use treatment of drinking water with ceramic filter, (b) safely managed improved non-shared sanitation for households cur- rently having unimproved sanitation, and (c) promotion of handwashing with • • • soap targeting caregivers of children under five. Complement these measures with (a) safely managed improved non-shared sanitation for households currently sharing sanitation with other households, • • and (b) promotion of handwashing with soap to all household members. Mitigate exposure to arsenic in drinking water through deep tube wells, ponds with sand filter, and household filtering. • • • Implement priority projects of the Bangladesh Delta Plan for water supply and water resources management. • • • Improve analytical base on the impacts of and potential solutions for salinity intrusion and identify specific interventions to manage industrial effluent or • liquid discharge as well as untreated municipal sewage water. A.4 Addressing plastic pollution (chapter 8) Promote research and development of alternatives to single-use plastics (SUPs). • • Implement the ban on plastic bags and extend its scope to other SUP items. • • Adopt mandatory extended producer responsibility (EPR) guidelines for plastic-waste collection and recycling. • BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 201 A Way Forward Implementation period Type a Action Immediate Short-term Medium-term priority (2024–25) (2026–30) Adopt a framework for integrated waste management including waste segregation at the household level, infrastructure development, behavior- change campaigns, stricter requirements for waste incineration, and • • improved landfill site management practices. Harmonize plastic-management policies to promote circular economy. • Implement plastic cleanup and recovery schemes to reduce legacy plastic waste and mitigate associated impacts. • • Establish a monitoring system for the implementation of the Solid Waste Management Rules 2021 and targets of the Plastic Action Plan. • Pillar B. Strengthening environmental governance systems B.1 Setting evidence-based priorities and decision-making (chapter 3) Enhance environmental monitoring and data management capacity, including automated air and water quality monitoring networks, and adequate institutional presence in the field with sufficient and well-trained • • • staff. Create a research and development unit at DoE. • Implement systematic evaluations of government’s interventions and outcome-oriented indicators to assess institutional performance of • environmental agencies. B.2 Diversifying and strengthening environmental policy instruments (chapters 3, 4, and 10) Adopt economic and market-based instruments, such as pollution charges, deposit-refund schemes, EPR, and final demand interventions. • • Adopt litigation-based and information-based instruments, including liability legislation, requirements and procedures for awareness campaigns, and regu- • • lar dissemination of environmental quality data and pollution loads. Amend or adopt, as applicable, the Environment Conservation Act (ECA), associated rules and guidelines to (a) modernize and make enforcement activities more efficient, based on the polluter pays principle; (b) set the mandates and foundations for further regulations on EPR and Payment • • for Ecosystem Services (PES); and (c) mobilize green financing through a permanent environment fund, among other themes. Amend or adopt, as applicable, the ECA, associated rules and guidelines to (a) strengthen the environmental clearance system and monitoring of projects after clearance, (b) require Strategic Environmental Assessment for • • policies, plans, and programs, and (c) improve stakeholder engagement in environmental decision-making. Conduct an in-depth, independent evaluation of effectiveness and efficiency of the environmental clearance system. • Revise the EIA Guidelines for Industries 2021, updating and expanding their contents as per the ECR 2023, and develop guidelines for non-industry proj- • ects. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 202 A Way Forward Implementation period Type a Action Immediate Short-term Medium-term priority (2024–25) (2026–30) B.3 Strengthening organizational structure and institutional capacity (chapters 3 and 4) Analyze the organizational structure under MoEFCC and affiliated agencies to set clearer mandates and more efficient processes for environmental • governance, including interagency coordination. Increase DoE’s budget and headcount. • • • Establish a cadre of environmental specialists for DoE. • Implement a comprehensive information management system with auto- mated monitoring for compliance, enforcement, and policy formulation. • B.4 Strengthening environmental justice and citizen-driven accountability (chapters 3, 4, and 10) Regularly disclose data in support of key environmental indicators (including pollution loads and environmental health statistics), use public forums to air development initiatives, and conduct broader and more detailed review and • • • discussion of environmental management tools. Proceed with a comprehensive reform of Environment Court Act, expanding legal standing to all citizens and creating the roles of environmental • prosecutors and technical experts. Adopt rules and guidelines for applying the polluter pays principle effectively, including criteria for setting the value of fines, precautionary measures, and • • more severe penalties. B.5 Building an enabling environment for green financing (chapter 9) Adopt a broad-based national green growth strategy, a national action plan backed by a commensurate set of regulatory and institutional frameworks. • Create an ecosystem of ministries and government agencies that collect and analyze point-source data to enforce policies and create a pipeline of verified • • • investment-ready projects. Adopt incentives to boost environmental markets, such as promotion of (a) green practices, green businesses, and investments with positive environmental externalities; and (b) incentives to address the risks faced by • • FIs or perceived by financiers; and (c) a collaborative institutional system to implement green financial incentives. Strengthen institutional and borrower capabilities by building skills and expertise on green financing across sectors. • • Source: World Bank. Note: a The meanings of the icons in the left-most column are presented below. Analytics and technical Coordination and stakeholder Policies and institutions Investments assistance engagement BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 203 Appendix A. Data and Methodology for Estimating Health Effects APPENDIXES Appendix A. Data and Methodology for Estimating Health Effects Estimating the health effects from the major environmental risk factors in Bangladesh requires a large amount of data. This in- volves establishing (a) the percent of the population exposed to each risk factor or type of pollutant, and (b) the level of pollution to which the population is exposed. A summary of these data is presented in tables A.1a–b and is further discussed in chapter 2. Nationwide population-weighted ambient PM2.5 air pollution is estimated based on a combination of air-quality modeling and ground-level monitoring. Some of the data on the percent of the population exposed to a risk factor or pollution are from the Bangladesh Population and Housing Census 2022 and annual nationally representative household surveys by the Bangladesh Bureau of Statistics (BBS 2019; 2021; 2022) (see tables A.1a and A.1b.) The population exposed to a risk factor or pollution includes the population using solid fuels as primary cooking fuel and thus exposed to PM2.5 household air pollution; the population with various types of drinking-water supply and sanitation; and the percent of the population with arsenic in their drinking water as well as arsenic concentration levels. Two measurement studies of PM2.5 personal exposure from Bangladesh were used to assess the level of PM2.5 household air pollution in households using solid fuels. For exposure to lead (Pb), the data are from blood lead level (BLL) measurement studies of children and adults in various locations in Bangladesh. These studies were conducted during 2000 to 2015. Therefore, a trend analysis was undertaken to estimate BLLs in 2019. Table A.1a Data on population exposure to pollution in Bangladesh Environmen- Average   tal health risk Exposure indicator Year(s) exposure Data sources factor level 1 PM2.5 ambient Population-weighted ambient PM2.5 2019–21 64 ug/m3 Estimated from DoE’s Monthly Air Quality air pollution Monitoring Reports (16 monitoring stations; see (AAP) DoE (2021) and GBD (2019) ambient exposure estimates 2 PM2.5 household % of population groups using solid 2022 Trend analysis of data from Bangladesh annual air pollution fuels as primary cooking fuel: SVRS reports (BBS 2019; 2021) and Population (HAP) • Rural population 90% and Housing Census 2011 and 2022 (BBS 2015; • Urban population 42% 2022) • National population 74% Household member average 2022 76 ug/m3 Shahriar et al. (2021) and Berkeley Air Monitoring personal PM2.5 exposure from Group (2022) measurement studies in Bangla- household use of solid fuels (net of desh ambient PM2.5) 3a Lead (Pb) Lead concentration in blood (BLL) in 2019 6.4 ug/dL Trend analysis of nine BLL measurement studies exposure children and adults of children and five BLL studies of adults in Ban- gladesh. 3b Lead (Pb) a) Workers at 15 used lead-acid 65 ug/dL Ahmad et al. (2014) exposure at “hot battery (ULAB) recycling and spots” recharging facilities in Dhaka b) Jewelry makers in Dhaka (and 2015 69 ug/dL Mazumdar, Goswami, and Ali (2017) workers in associated “back (16 ug/dL) offices”) c) Children living near abandoned 23 ug/dL Chowdhury et al. (2021); ULAB recycling sites McCartor and Nash (2018) Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 204 Appendix A. Data and Methodology for Estimating Health Effects Table A.1b Data on population exposure to pollution in Bangladesh Average Environmental health   Exposure indicator Year exposure Data sources risk factor level (%) 4 Arsenic in drinking Population with: water Arsenic above WHO guideline 2019 17 Bangladesh MICS 2019 (10 ppb) (BBS/UNICEF 2019) Arsenic above Bangladeshi standard (50 ppb) 2019 11 5 Household drinking Population with: water, sanitation, and Improved drinking water source 2019 99 hygiene (microbiological E. coli in drinking-water source 2019 40 pollution) E. coli in actual drinking water 2019 82 Safely managed drinking water (source water) 2019 48 Bangladesh MICS 2019 Point-of-use treatment (POUT) of drinking water 2019 10 (BBS/UNICEF 2019) Access to improved sanitation facility 2019 85 Shared sanitation facility with other households 2019 20 Access to improved non-shared sanitation facility 2019 65 Access to handwashing facility with water and soap 2019 75 Source: World Bank. The data on population exposure to environmental risk factors or pollution are applied in models that specify the relationship between various exposure levels and health effects. The models applied here to Bangladesh are from well-established method- ologies used globally to estimate health effects. In most cases, the models are based on studies of health effects that were con- ducted in a wide range of countries and regions. This includes the health effects of ambient PM2.5; household PM2.5 air pollution; children’s lead exposure; and inadequate drinking water, sanitation, and hygiene. Regarding the effects of lead exposure on adult health, four large studies from the United States were applied. In the case of arsenic’s health effects, two studies of mortality from Bangladesh were applied. A summary of the models and methodologies is presented in table A.2. They are further discussed in chapter 2 as well as in appendixes B–J. Table A.2 Methodologies for estimating health effects of exposure to major environmental health risk factors Environmental health Health-effect assessment Elevated exposure   Source of methodology risk factor methodology levels 1 PM2.5 ambient air pollution Increased risk of morbidity PM2.5 > 5 ug/m3 Global Burden of Disease (GBD) 2019 (AAP) and mortality (heart disease, based on global studies stroke, COPD, lung cancer, 2 PM2.5 household air ALRI, type 2 diabetes) pollution (HAP) 3 Lead (Pb) exposure IQ losses in children BLL > 0 ug/dL Analysis of global studies (Crump et al. 2013) Increased risk of cardiovas- BLL > 0 ug/dL Review of studies in the US (Brown et al. 2020) cular disease (CVD) mortality among adults 4 Arsenic in drinking water Increased risk of mortality As > 10 ppb Argos et al. (2010) and Sohel et al. (2009) studies in Bangladesh BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 205 Appendix A. Data and Methodology for Estimating Health Effects Environmental health Health-effect assessment Elevated exposure   Source of methodology risk factor methodology levels 5 Household drinking water, Risk of illness and mortality Lack of safe services Meta-analyses of worldwide studies GBD 2019 sanitation, and hygiene for each type of drinking-wa- and Wolf et al. (2014; 2018) (microbiological pollution) ter source, type of sanitation facility, and lack of access to handwashing facility Source: World Bank. The health effects estimated in this report have a cost to society. The health effects are of three types: (a) Premature mortality from exposure to pollution; (b) Illness from exposure to pollution; and (c) IQ losses among children exposed to lead. There are two main approaches to estimating the cost of these health effects: (a) productivity cost and (b) welfare cost. The productivity cost measures the effect of ill health or premature mortality on economic output. Ill health causes absenteeism from work and reduced productivity while at work. Ill health also involves medical treatment cost. Premature mortality causes a loss in future income if the individual is economically active. The cost of IQ losses in children is estimated in terms of lower lifetime income. Productivity cost captures only a portion of the cost of health effects to society. Ill health not only has productivity effects but also involves pain, discomfort, and loss of leisure time. Premature mortality involves complete loss of remaining years of normal life expectancy and not only income. The welfare cost approach was therefore developed to better capture the value that society places on good health and a long life. The welfare cost is usually substantially larger than the productivity cost. The welfare-cost approach to premature mortality involves estimating the value that society places on avoiding premature mortality. This is accomplished by estimating individuals’ willingness-to-pay (WTP) for a reduction in the probability of dying for instance this year. The WTP forms the basis for calculating the so-called value of statistical life (VSL). The VSL is the amount that a group of individuals or society is collectively willing to pay to reduce the risk of mortality to the extent that it saves one life. This is further discussed in appendixes H and I. The welfare approach can also be applied to illness by finding out individuals WTP to avoid or reduce the risk of an episode of illness. The cost of health effects in this report relies on the welfare-cost approach for mortality and the productivity-cost approach for illness and children’s IQ losses (table A.3). Table A.3 Cost of health effects   Environmental health risk factor Method for estimating cost of health effects Mortality: Welfare cost (VSL) 1 PM2.5 ambient air pollution (AAP) Illness: Productivity cost Mortality: Welfare cost (VSL) 2 PM2.5 household air pollution (HAP) Illness: Productivity cost Children’s loss of IQ: Productivity cost 3 Lead (Pb) exposure Adult mortality: Welfare cost (VSL) Adult morbidity: Productivity cost Mortality: Welfare cost 4 Arsenic in drinking water Illness: Productivity cost Mortality: Welfare cost 5 Household drinking water, sanitation, and hygiene Illness: Productivity cost Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 206 Appendix A. Data and Methodology for Estimating Health Effects References Ahmad, S. A., M. H. Khan, S. Khandker, A. F. M. Sarwar, N. Yasmin, M. H. Faruquee, and R. Yasmin. 2014. “Blood Lead Levels and Health Problems of Lead Acid Battery Workers in Bangladesh.” Scientific World Journal 1–7. http://dx.doi.org/10.1155/2014/974104Argos et al. (2010) BBS (Bangladesh Bureau of Statistics). 2015. Population and Housing Census 2011: Socioeconomic and Demographic Report. National Report Volume 4. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2019. Report on Bangladesh Sample Vital Statistics 2019. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2021. Report on Bangladesh Sample Vital Statistics 2020. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics). 2022. Population and Housing Census 2022. Preliminary Report and additional data provided by BBS. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2019. Progotir Pathey: Bangladesh Multiple Indicator Cluster Survey 2019. Survey Findings Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. Berkeley Air Monitoring Group. 2022. Bangladesh’s National Cookstove Program: Comparing Beneficiaries of IDCOL Stoves to Traditional Stoves by Exposure to Household Air Pollution. Prepared in collaboration with the International Centre for Diarrheal Research, Bangladesh (ICDDR,B) for the Infrastructure Development Company Limited (IDCOL). Brown, L., M. Lynch, A. Belova, R. Klein, and A. Chiger. 2020. “Developing a Health Impact Model for Adult Lead Exposure and Cardiovascular Disease Mortality.” Environmental Health Perspectives 128 (9). https://doi.org/10.1289/EHP6552. Chowdhury, K. I. A., S. Nurunnahar, M. L. Kabir, M. T. Islam, M. Baker, M. S. Islam, M. Rahman, M. A. Hasan, A. Sikder, L. H. Kwong, G. K. Binkhorst, E. Nash, J. Keith, A. McCartor, S. P. Luby, and J. E. Forsyth. 2021. “Child Lead Exposure near Abandoned Lead Acid Battery Recycling Sites in a Residential Community in Bangladesh: Risk Factors and the Impact of Soil Remediation on Blood Lead Levels.” Environmental Research 194: 110689. Crump, K., C. Van Landingham, T. Bowers, D. Cahoy, and J. Chandalia. 2013. “A Statistical Reevaluation of the Data Used in the Lanphear et al. (2005) Pooled- Analysis that Related Low Levels of Blood Lead to Intellectual Deficits in Children.” Crit Rev Toxicol 43 (9): 785–99. DoE (Department of Environment). 2021. Monthly Air Quality Monitoring Report. Reporting Month: March 2021. Dhaka, Bangladesh: Department of Environment. Ministry of Environment, Forest and Climate Change. GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. Mazumdar, I., K. Goswami, and S. Ali. 2017. “Status of Serum Calcium, Vitamin D and Parathyroid Hormone and Hematological Indices Among Lead Exposed Jewelry Workers in Dhaka, Bangladesh.” Indian Journal of Clinical Biochemistry 32 (1): 110–16. doi:10.1007/s12291-016-0582-9. McCartor, A., and E. Nash. 2018. Project Completion Report: Reducing Lead Poisoning Among Children in Kathgora, Bangladesh. New York, NY: Pure Earth. https://www.pureearth.org/wp-content/uploads/2019/10/PCR-Report_Kathgora.pdf Shahriar, M. H., M. A. H. Chowdhury, S. Ahmed, M. Eunus, S. B. Kader, B. A. Begum, T. Islam, G. Sarwar, R. Al Shams, R. Raqib, D. S. Alam, F. Parvez, H. Ahsan, and Md. Yunus. 2021. “Exposure to Household Air Pollutants and Endothelial Dysfunction in Rural Bangladesh.” Environmental Epidemiology 5: e132. doi:10.1097/ EE9.0000000000000132. Sohel, N., L. A. Persson, M. Rahman, P. K. Streatfield, M. Yunus, E. C. Ekström, and M. Vahter. 2009. “Arsenic in Drinking Water and Adult Mortality: A Population- based Cohort Study in Rural Bangladesh.” Epidemiology 20 (6): 824–30. Wolf, J., A. Prüss-Üstün, O. Cumming, J. Bartram, S. Bonjour, S. Cairncross, T. Clasen, J. M. Colford Jr, V. Curtis, J. De France, L. Fewtrell, M. C. Freeman, B. Gordon, P. R. Hunter, A. Jeandron, R. B. Johnston, D. Mäusezahl, C. Mathers, M. Neira, and J. P. T. Higgins. 2014. “Assessing the Impact of Drinking Water and Sanitation on Diarrheal Disease in Low- and Middle-Income Settings: Systematic Review and Meta-regression.” Tropical Medicine and International Health 19: 928–42. Wolf, J., P. Hunter, M. Freeman, and O. Cumming. 2018. “Impact of Drinking Water, Sanitation and Handwashing with Soap on Childhood Diarrhoeal Disease: Updated Meta-analysis and Meta-regression.” Tropical Medicine and International Health 23 (5): 508–25. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 207 Appendix B. Health Effects of Particulate Matter Pollution Appendix B. Health Effects of Particulate Matter Pollution Particulate matter (PM) is the air pollutant that globally is associated with the largest health effects. It is a major outdoor ambient air pollutant and a major household air pollutant from the burning of solid fuels for cooking and, in cold climates, heating. Health effects of PM exposure include both premature mortality and morbidity. The methodologies to estimate these health effects have evolved as the body of research evidence has increased. The Global Burden of Disease (GBD) derived an integrated exposure-response (IER) function for health outcomes associated with exposure to PM2.5 both in the outdoor ambient and household environments (Burnett et al. 2014; Shin et al. 2013). The health outcomes assessed in the GBD up to 2016 are ischemic heart disease (IHD), cerebrovascular disease (stroke), lung cancer, chronic obstructive pulmonary disease (COPD), and acute lower respiratory infections (ALRI) (GBD 2013 Risk Factors Collaborators 2015; GBD 2015 Risk Factors Collaborators 2016; GBD 2016 Risk Factors Collaborators 2017; Lim et al. 2012; Mehta et al. 2013; Smith et al. 2014). The effects of PM2.5 exposure on type 2 diabetes were added in GBD 2017 (GBD 2017 Risk Factors Collaborators 2018) and neonatal disorders were added in GBD 2019 (GBD 2019 Risk Factors Collaborators 2020). The risk functions for IHD and cere- brovascular disease are age-specific with five-year age intervals from 25 years of age, while singular age-group risk functions are applied for lung cancer, COPD, ALRI, and type 2 diabetes. The IER function specifies the relationship between annual PM2.5 exposure and the relative risk (RR) of a health effect. The RR increases as PM2.5 exposure level increases. The RR is the risk of a health effect from exposure to PM2.5 relative to the risk of the health effect if there is no exposure to PM2.5 or if PM2.5 exposure is below a theoretical minimum-risk exposure level (TMREL). The TMREL used in the GBD 2019 is a uniform distribution of PM2.5 between 2.4 and 5.9 μg/m3. The IER has two main advantages over the methods that were previously used to estimate the health effects of PM2.5. First, IER allows for prediction of RR of health effects over a very large range of PM2.5 concentrations. Second, IER enables the estimation of health effects based on a country’s specific baseline structure of mortality, instead of the one-size-fits-all function that was previously available and ignored intercountry differences in the structure of mortality. The method for estimating the health effects of PM2.5 exposure is explained in GBD 2019 Risk Factors Collaborators (2020) (see Supplementary Appendix 1). The GBD 2019 first estimates the health effects of the total exposure to ambient PM2.5 and PM2.5 household air pollution from household use of solid fuels for cooking, and then apportions the health effects to ambient PM2.5 and household PM2.5 air pollution. The annual health effects of annual PM2.5 exposure are estimated as follows: B = D * PAFPM (B.1) where B is annual number cases of deaths or illness from PM2.5 among the exposed population, D is annual baseline number of cases of deaths or illness among this population, and PAFPM (population attributable fraction) is the fraction of baseline cases that is attributable to PM2.5 exposure among this population. PAFPM and B are calculated for each type of health effect covered by the GBD 2019. Annual baseline cases, D, for each type of health effect for Bangladesh is taken from the GBD 2019 (see www. healthdata.org). PAF for each health effect included in the GBD 2019 is calculated as follows: (B.2) where PA is the share of the population that is exposed only to ambient PM2.5 (that is, the population not using solid fuels for cooking), PH is the share of the population that uses solid fuels for cooking, RRA is the relative risk of health effects from ambient PM2.5 among the population exposed only to ambient PM2.5, and RRH is the relative risk of health effects from PM2.5 among the population exposed to PM2.5 household air pollution. PA + PH = 1. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 208 Appendix B. Health Effects of Particulate Matter Pollution The size of the relative risks of health effects among the population only exposed to ambient PM2.5 is: RRA = RR(AAP) / RR(TMREL) (B.3) where RR(AAP) is the relative risk of health effects at annual PM2.5 = AAP and RR(TMREL) is the relative risk at PM2.5 = TMREL. These relative risks are reported by the GBD 2019 for each type of health effect for a range of annual PM2.5 from 0.01 to 2,500 μg/m3 (see http://ghdx.healthdata.org/record/ihme-data/global-burden-disease-study-2019-gbd-2019-particulate-matter-risk-curves). TMREL may be chosen within the range of 2.4–5.9 μg/m3 used by the GBD 2019, or TMREL may be chosen to be larger or smaller. TRMEL may also be chosen as zero, in which case RR(TMREL) = 1. The size of the relative risks of health effects among the population exposed to household air pollution PM2.5 is: RRH = RR(HAP+AAP) /RR(TMREL) (B.4) where RR(HAP+AAP) is the relative risk at exposure level PM2.5 = HAP+AAP. This exposure level includes both exposure to PM2.5 from the use of solid fuels (HAP) and exposure to ambient PM2.5 (AAP). HAP+AAP is a so-called personal exposure level that is typically measured over a 24-hour to 48-hour period by a measurement device attached to a person (and assumed to reflect long-term exposure). The exposure level is generally different for each household member due to differences in activity patterns. Most personal exposure measurement studies have been for adult women, who usually are exposed to the highest level of PM2.5 in households cooking with solid fuels. The GBD 2019 uses a fraction of adult women exposure equal to 0.64 for adult men and 0.85 for children. Because of these differences in exposure levels, PAF is calculated separately for adult females, adult males, and children under the age of five years. The GBD 2019 then apportions the PAFPM to ambient and household air pollution as follows: (B.5) (B.6) where PAFAAP and PAFHAP are the population attributable fractions of deaths and illnesses due to ambient PM2.5 and household air pollution PM2.5 from the use of solid fuels, respectively; AAP is annual ambient PM2.5; HAP is personal PM2.5 exposure from the use of solid fuels; and PH is the share of the population using solid fuels for cooking. This approach to apportioning the health effects of PM2.5 ensures that: (B.7) The GBD 2019 estimates PAFPM, PAFAAP, and PAFHAP at small geographic units over which health effects are summed to the na- tional, state, province, or city level. Each geographic area is a 0.1° x 0.1° grid (corresponding to 11 x 11 km at the equator). However, equations B.5 and B.6 are less accurate if the PAFs are estimated for large geographic units, as done in this report for Bangladesh. In this case, an alternative approach to apportioning the health effects uses the following three steps: Step 1: (B.8) (B.9) BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 209 Appendix B. Health Effects of Particulate Matter Pollution which are “partial” PAFs for the population exposed only to ambient PM2.5 and the population exposed to household air pollution (the population using solid fuels). RRH in the “partial” PAF for household air pollution is for exposure level HAP+AAP. The next step involves separating the effects of AAP and HAP and adding the effects to the PAFs in equations B.8 and B.9. Step 2: (B10) (B.11) The result in Step 2 is such that: (B.12) The final step involves adjusting the two PAFs downwards so that the sum is equal to PAFPM . Step 3: (B13) (B.14) The two approaches give identical PAFs for PH = 0 and PH = 1.0. However, for 0 < PH < 1, the GBD approach results in a smaller PAF for ambient PM2.5 and a larger PAF for household air pollution PM2.5 than the alternative approach described in steps 1–3. The difference can be quite large when PM2.5 exposure from household air pollution is substantially higher than from ambient PM2.5 and increases as PH approaches 0.5 from either 0 or from 1.0. Therefore, the approach in steps 1–3 is recommended for estimating the health effects of ambient air pollution with exposure data reflecting relatively large geographic units, such as city by city, state by state, province by province, or urban and rural. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 210 Appendix B. Health Effects of Particulate Matter Pollution References Burnett, R. T., C. A. Pope III, M. Ezzati, C. Olives, S. S. Lim, Sumi Mehta, H. H. Shin, G. Singh, B. Hubbell, M. Brauer, H. R. Anderson, K. R. Smith, J. R. Balmes, N. G. Bruce, H. Kan, F. Laden, A. Prüss-Üstün, M. C. Turner, S. M. Gapstur, W. R. Diver, and A. Cohen. 2014. “An Integrated Risk Function for Estimating the Global Burden of Disease Attributable to Ambient Fine Particulate Matter Exposure.” Environmental Health Perspectives 122: 397–403. GBD (Global Burden of Disease) 2013 Risk Factors Collaborators. 2015. “Global, Regional, and National Comparative Risk Assessment of 79 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks in 188 Countries 1990–2013: A Systematic Analysis for the Global Burden of Disease Study 2013.” Lancet 386: 2287–323. GBD (Global Burden of Disease) 2015 Risk Factors Collaborators. 2016. “Global, Regional, and National Comparative Risk Assessment of 79 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks, 1990–2015: A Systematic Analysis for the Global Burden of Disease Study 2015.” Lancet 388: 1659–724. GBD (Global Burden of Disease) 2016 Risk Factors Collaborators. 2017. “Global, Regional, and National Comparative Risk Assessment of 84 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks, 1990–2016: A Systematic Analysis for the Global Burden of Disease Study 2016.” Lancet 390: 1345–422. GBD (Global Burden of Disease) 2017 Risk Factor Collaborators. 2018. “Global, Regional, and National Comparative Risk Assessment of 84 Behavioural, Environmental and Occupational, and Metabolic Risks or Clusters of Risks for 195 Countries and Territories, 1990–2017: A Systematic Analysis for the Global Burden of Disease Study 2017.” Lancet 392: 1923–94. GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. Lim, S. S., T. Vos, A. D. Flaxman, G. Danaei, K. Shibuya, H. Adair-Rohani, M. Amann, H. R. Anderson, K. G. Andrews, M. Aryee, C. Atkinson, L. J. Bacchus, A. N. Bahalim, K. Balakrishnan, J. Balmes, S. Barker-Collo, A. Baxter, M. L. Bell, J. D. Blore, F. Blyth, C. Bonner, G. Borges, R. Bourne, M. Boussinesq, M. Brauer, P. Brooks, N. G. Bruce, B. Brunekreef, C. Bryan-Hancock, C. Bucello, R. Buchbinder, F. Bull, R. T. Burnett, T. E. B., B. Calabria, J. Carapetis, E. Carnahan, Z. Chafe, F. Charlson, H. Chen, J. Shen Chen, A. T.-A. Cheng, J. C. Child, A. Cohen, K. E. Colson, B. C. Cowie, S. Darby, S. Darling, A. Davis, L. Degenhardt, F. Dentener, D. C. Des Jarlais, K. Devries, M. Dherani, E. L. Ding, E. R. Dorsey, T. Driscoll, K. Edmond, S. E. Ali, R. E. Engell, P. J. Erwin, S. Fahimi, G. Falder, F. Farzadfar, A. Ferrari, M. M. Finucane, S. Flaxman, F. G. R. Fowkes, G. Freedman, M. K. Freeman, E. Gakidou, S. Ghosh, E. Giovannucci, G. Gmel, K. Graham, R. Grainger, B. Grant, D. Gunnell, H. R. Gutierrez, W. Hall, H. W. Hoek, A. Hogan, H. D. Hosgood III, D. Hoy, H. Hu, B. J. Hubbell, S. J. Hutchings, S. E. Ibeanusi, G. L. Jacklyn, R. Jasrasaria, J. B. Jonas, H. Kan, J. A. Kanis, N. Kassebaum, N. Kawakami, Y.-H. Khang, S. Khatibzadeh, J.-P. Khoo, C. Kok, F. Laden, R. Lalloo, Q. Lan, T. Lathlean, J. L. Leasher, J. Leigh, Y. Li, J. K. Lin, S. E. Lipshultz, S. London, R. Lozano, Y. Lu, J. Mak, R. Malekzadeh, L. Mallinger, W. Marcenes, L. March, R. Marks, R. Martin, P. McGale, J. McGrath, S. Mehta, Z. A. Memish, G. A. Mensah, T. R. Merriman, R. Micha, C. Michaud, V. Mishra, K. M. Hanafiah, A. A. Mokdad, L. Morawska, D. Mozaffarian, T. Murphy, M. Naghavi, B. Neal, P. K. Nelson, J. M. Nolla, R. Norman, C. Olives, S. B. Omer, J. Orchard, R. Osborne, B. Ostro, A. Page, K. D. Pandey, C. D. H. Parry, E. Passmore, J. Patra, N. Pearce, P. M. Pelizzari, M. Petzold, M. R. Phillips, D. Pope, C. A. Pope III, J. Powles, M. Rao, H. Razavi, E. A. Rehfuess, J. T. Rehm, B. Ritz, F. P. Rivara, T. Roberts, C. Robinson, J. A. Rodriguez-Portales, I. Romieu, R. Room, L. C. Rosenfeld, A. Roy, L. Rushton, J. A. Salomon, U. Sampson, L. Sanchez-Riera, E. Sanman, A. Sapkota, S. Seedat, P. Shi, K. Shield, R. Shivakoti, G. M. Singh, D. A. Sleet, E. Smith, K. R. Smith, N. J. C. Stapelberg, K. Steenland, H. Stöckl, L. J. Stovner, K. Straif, L. Straney, G. D. Thurston, J. H. Tran, R. Van Dingenen, A. van Donkelaar, J. L. Veerman, L. Vijayakumar, R. Weintraub, M. M. Weissman, R. A. White, H. Whiteford, S. T. Wiersma, J. D. Wilkinson, H. C. Williams, W. Williams, N. Wilson, A. D. Woolf, P. Yip, J. M. Zielinski, A. D. Lopez, C. J. L. Murray, and M. Ezzati. 2012. “A Comparative Risk Assessment of Burden of Disease and Injury Attributable to 67 Risk Factors and Risk Factor Clusters in 21 Regions, 1990–2010: A Systematic Analysis for the Global Burden of Disease Study 2010.” Lancet 380: 2224–60. Mehta, S., H. Shin, R. Burnett, T. North, and A. Cohen. 2013. “Ambient Particulate Air Pollution and Acute Lower Respiratory Infections: A Systematic Review and Implications for Estimating the Global Burden of Disease.” Air Qual Atmos Health 6: 69–83. Shin, H. H., A. Cohen, C. A. Pope III, M. Ezzati, S. S. Lim, B. Hubbell, and R. T. Burnett. 2013. “Critical Issues in Combining Disparate Sources of Information to Estimate the Global Burden of Disease Attributable to Ambient Fine Particulate Matter Exposure.” Working Paper prepared for “Methods for Research Synthesis: A Cross- Disciplinary Workshop.” Harvard Center for Risk Analysis, Boston, MA, October 3. Smith, K. R., N. Bruce, K. Balakrishnan, H. Adair-Rohani, J. Balmes, Z. Chafe, M. Dherani, D. H. Hosgood, S. Mehta, D. Pope, E. Rehfuess, and others in the HAP CRA Risk Expert Group. 2014. “Millions Dead: How Do We Know and What Does It Mean? Methods Used in the Comparative Risk Assessment of Household Air Pollution.” Annu Rev Public Health 35: 185–206. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 211 Appendix C. Blood Lead Levels and Sources of Lead Exposure Appendix C. Blood Lead Levels and Sources of Lead Exposure C.1 Blood lead levels in children and adults Six studies of children’s BLLs in Dhaka are presented in table C1. These studies are the ones that best reflect the general BLL of the children in the city and metropolitan area since the banning of lead in gasoline in Bangladesh in 1999. Mean BLL declined from 15 μg/dL in 2000 to 7.6 μg/dL in 2022. Table C.1 Mean blood lead levels among children in Dhaka Age of Mean Sample Publication Study Location Description subjects BLL Source size year year(s) (years) (µg/dL) Dhaka city Children throughout Dhaka city 2-4 500 7.6 2022 1 2022 Dhaka Children from Araihazar Upazila in Narayanganj 14–16 697 9.9 2018 2 2013–16 Division District in Dhaka Division Children from low-income sections of Mirpur in Dhaka City <2 729 8.2 2018 3 2009–12 Dhaka City Dhaka Children from Araihazar Upazila in Narayanganj 8–11 303 11.5 2011 4 2008 Division District in Dhaka Division Dhaka Children from five neighborhoods in Dhaka City 7–16 73 12.0 2011 5 2008 Children from five schools representing various Dhaka geographic locations and socioeconomic strata 4–12 779 15.0 2001 6 2000 in Dhaka Sources: (1) icddr,b, n.d. (2) Wasserman et al. 2018; (3) Raihan et al. 2018; (4) Wasserman et al. 2011; (5) Linderholm et al. 2011; (6) Kaiser et al. 2001. Four additional studies shed light on children’s BLLs in rural and peri-urban Bangladesh (table C.2) Table C.2 Blood lead levels among children in rural and peri-urban Bangladesh Mean Age of Sample Study Location Description BLL (µg/ Publication Source subjects size year(s) dL) Dhaka 20–40 Children from rural Sirajdikhan Upazila 383 9.1 2020; 2018 1, 2 2010–13 Division months Rajshahi 20–40 Children from rural Pabna Upazila 351 4.5 2020 1 2010–13 Division months Rangpur Children from one rural school in the northern < 16 years 197 7.3 2012 3 2007–09 Division area of Chirirbandar, Dinajpur District Dhaka Children from peri-urban area in Azampur, Uttara < 13 years 57 2.5 2009 4 2007–08 Division 16 km northeast of Dhaka Sources: (1) Gleason et al. 2020; (2) Woo et al. 2018; (3) Mitra et al. 2012; (4) Mitra et al. 2009. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 212 Appendix C. Blood Lead Levels and Sources of Lead Exposure Three relevant studies of BLLs were identified for adults during the preparation of this report (table C.3). Table C.31 Blood lead levels among adults in Bangladesh Age of sub- Sample Mean BLL Publica- Study Location Description Source jects size (µg/dL) tion years Dhaka Pregnant women from rural Sirajdikhan Mean 23 383 7.3 2020 1 2010–13 Division Upazila years Rajshahi Pregnant women from rural Pabna Mean 23 351 2.7 2020 1 2010–13 Division Upazila years Mymensingh Pregnant women from rural Mymens- Mean 24 and Dhaka 430 4.7 2018 2 2012–13 ingh, Tangail, and Kishorenganji districts years Divisions Dhaka Adults from rural communities in 25–64 years 155 11.9 2019 3 2006–09 Division Araihazar Chittagong Adults from rural communities in Matlab 25–64 years 100 3.5 2019 3 2006–09 Division Sources: (1) Gleason et al. 2020; (2) Forsyth et al. 2018; (3) Bulka et al. 2019. C.2 Lead exposure from soil, dust, and drinking water Twenty-two studies of lead concentrations in soil and dust in Bangladesh are summarized in Majumder et al. (2021). Average lead concentrations in agricultural soils, garden soils and roadside soils and dust are 64–87 mg/kg (ppm). Lead concentrations are substantially higher in many industrial and mining areas and reached 224–445 mg/kg at three locations studied. Lead con- centrations in soil are often much higher at ULAB recycling sites. Lead concentrations reached over 100,000 mg/kg with a mean of 1,400 mg/kg at two abandoned sites in Kathgora, Savar in Dhaka Division before they were rehabilitated in 2018 (Chowdhury et al. 2021; McCartor and Nash 2018). Lead in air was a major source of lead ingestion during the times of leaded gasoline. Main sources of lead in air now include lead smelting and battery recycling, mining, resuspended dust containing lead, and possibly burning of agricultural residues contain- ing lead. Majumder et al. (2021) reports lead concentrations in air in eighteen locations from six studies. Five of the studies were published between 2012 and 2018 and one in 2003. Mean lead air concentrations were 0.36 µg/m3 with a range from 0.09 to 1.00 µg/m3 in sixteen of the locations. In Munshiganj, Pb air concentrations averaged 1.22 µg/m3 in eight residential air samples and as high as 377 µg/m3 at a battery manufacturing plant (Woo et al. 2018). Lead exposure also comes from drinking water. As many as 86 percent of the population in Bangladesh receives drinking water from tubewells/boreholes (BBS 2021; BBS/UNICEF 2019). About 12 percent of the population has piped tap water supply and two percent has drinking water from other sources. Overall, well over 95 percent of the population rely on groundwater (Shamsuddu- ha et al. 2019). A review of water pollution in Bangladesh reports lead concentrations in groundwater from four studies conduct- ed in seven locations (Hasan, Shahriar, and Jim 2019). Lead concentrations were 1 µg/L or less in six of the locations. In the seventh location, Rajshahi City, measurements were conducted from 180 representative shallow tubewells and 60 deep tubewells in forty locations in the City. Mean lead concentrations were 1,167 µg/L in the shallow tubewells and 1,120 µg/L in the deep tubewells (Mostafa, Uddin, and Haque 2017). A most recent review and meta-analysis reports lead concentrations in groundwater from four additional studies (Parvin, Haque, and Tareq 2021). Lead concentrations were less than 1 µg/L or below detectable levels in three of the studies, and 70 µg/L in Dinajpur coal mining area (Bhuiyan et al. 2010). A recent study of household water collected at eleven sampling points throughout northern and southern areas of Dhaka City found lead concentrations of less than 10 µg/L in all samples. Precise concentrations were not reported (Jamal et al. 2020). (See table C.4.) BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 213 Appendix C. Blood Lead Levels and Sources of Lead Exposure Table C.4 Lead (Pb) concentrations in soil and dust in Bangladesh | mg/kg Agricultural soils Industry and mining area soils Garden soils Roadside soils and dust Minimum 7 12 56 46 Maximum 119 445 87 148 Mean 64 162 70 87 Median 72 67 69 68 Source: World Bank produced from Majumder et al. (2021). C.3 Lead exposure from food Lead concentrations in rice, vegetables and fish in Bangladesh are reported by three review studies (Islam et al. 2018a; Kumar et al. 2022; Majumder et al. 2021) and some individual studies. These three food groups constitute nearly 80 percent of daily quanti- ty of food consumption in Bangladesh. Islam et al. (2018a) reviewed nine studies of vegetables and five studies of fish. Majumder et al. (2021) reviewed five of the same studies of vegetables as well as two additional studies. Majumder et al. also reviewed seven studies of fish, two studies of rice, and six studies of other foods. Kumar et al. (2022) reviewed thirty studies on measurements of Pb contamination in agricultural foods and food products. These studies contained lead measurements of 35 kinds of vegeta- bles, 5 kinds of pulses, 3 kinds of cereals, and 10 kinds of fruits. Rice: Rice is the single most important food consumed in Bangladesh, accounting for nearly half of daily food weight intake. Pb concentrations ranged from 0.08 to 9.64 mg/kg with mean and median of 2.23 and 0.65 mg/kg, respectively. The high of 9.64 mg/kg is attributed to unusually high concentrations of Pb in groundwater used for irrigation at the study location. The second highest concentration of 7.48 mg/kg was likely due to an abandoned lead acid battery recycling workshop that had contaminat- ed surrounding soils (Kumar et al. 2022). Jahiruddin et al. (2017) report on Pb concentrations in rice from measurements in four subdistricts (upazilas) in the Dhaka and Mymensingh Divisions. Measurements were undertaken of dry season irrigated Boro rice and wet season rainfed Aman rice, with mean concentrations of 0.26 and 0.15 mg/kg respectively (table C.5). Mean concentra- tions varied substantially across locations and were consistently higher in irrigated rice than in rainfed rice (table C.6). Table C.5 Pb concentrations in Aman and Boro rice | mg/kg Boro rice (dry season) Aman rice (wet season) Minimum 0.11 0.06 Maximum 0.60 0.35 Median 0.25 0.12 Mean 0.26 0.15 Source: Jahiruddin et al. 2017. Table C.6 Mean concentrations of Pb in rice grains | mg/kg Irrigated Rainfed Faridpur Sadar 0.18 0.12 Saltha 0.20 0.09 Gazipur Sadar 0.31 0.20 Mymensingh Sadar 0.26 0.12 Source: Jahiruddin et al. 2017. The Pb measurements reported in Jahiruddin et al. (2017) and Kumar et al. (2022) are not nationally representative since samples are often disproportionately from locations with significant sources of Pb pollution. Pb concentrations somewhere between the lowest and median values of measurements (0.08–0.2 mg/kg) reported by Jahiruddin may therefore provide a more accurate reflection of nationwide Pb concentrations than the means reported by Kumar et al. Nationwide concentrations may, however, be lower. Real, Azam, and Majed (2017) sampled ten rice varieties from Kawran Bazar, the largest wholesale market in Dhaka, and found Pb concentrations of 0.0–0.08 mg/kg. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 214 Appendix C. Blood Lead Levels and Sources of Lead Exposure Vegetables: Vegetables are the second most important source of food in terms of daily intake weight. Kumar et al. (2022) re- ported measurements of Pb in 35 kinds of vegetables. The mean Pb concentration was 0.87 mg/kg in 22 of the vegetables with multiple studies, and 1.16 mg/kg in the other 13 vegetables. The studies showed a large range in Pb concentration for each kind of vegetable. For the two vegetables with the most studies, the range was from less than 0.01 to over 2.5 mg/kg. Eleven studies reviewed by Islam et al. (2018a) and Majumder et al. (2021) reported a wide range of mean Pb concentrations from 0.017 mg/kg in vegetables sampled at markets to as high as 11.5–15.5 mg/kg around industrial areas in Dhaka. Four studies with measurements of 7–10 kinds of vegetables reported means in the range of 0.5–0.8 mg/kg (table C.7). Table C.7 Pb concentrations in vegetables in Bangladesh (mg/kg) # of Location Mean Median Reference Source a vegetables 7 Overall country: From markets 0.017 0.007 Shaheen et al. 2016 I 2 Kawran Bazar wholesale market, Dhaka 0.017 0.017 Real, Azam, and Majed 2017 I 8 Jhenaidah Industrial Area 0.5 0.5 Islam et al. 2018b M 10 Around the Paira River, Patuakhali 0.6 0.4 Islam et al. 2015 I&M 7 Pakshi, Pabna 0.6 0.4 Tasrina and Rowshon 2015 I 8 Dhaka: Surrounding the Turag River 0.8 0.2 Islam and Hoque 2014 I 2 Chittagong: Vatiary industrial area 0.9 0.9 Parvin, Sultana, and Zahid 2014 I&M 2 Gazipur: Near highway road 3.2 2.9 Naser et al. 2012 I&M 5 Rural area of Satkhira district 6.9 5.2 Uddin, Hasan, and Dhar 2019 M Dhaka: Surrounding Hazaribagh indus- 1 11.5 11.5 Mottalib et al. 2016 I&M trial area Surrounding Dhaka export processing 5 15.5 14.2 Ahmad and Goni 2010 I&M zone Source: World Bank based on Islam et al. (2018a) and Majumder et al. (2021). Note: a I = Islam et al. 2018a; M = Majumder et al. 2021. Results from additional studies of vegetables are presented in table C.8. Mean Pb concentrations range from 0.43 mg/kg in brinjal (eggplant) in northern Bangladesh to 8.15 and 8.4 mg/kg in two industrial area. Brinjal is the second most important vegetable in Bangladesh in terms of consumption. Bushra et al. (2022) sampled four brinjals directly from the field at each of twenty locations in two brinjal-producing upazilas in Jamalpur district. Pb concentrations ranged from 0.2 to 0.73 mg/kg with a mean and median of 0.43 and 0.39 mg/kg, respectively. The study also measured Pb concentration in the soil at the exact same locations as brinjal was sampled and found a mean concentration of 16.9 mg/kg. Haque et al. (2021) measured Pb in ten kinds of commonly consumed vegetables sampled from (a) Savar Kacha Bazar wholesale vegetable market in Savar Municipality, Savar Upazila northwest of Dhaka City; (b) agricultural fields in a nonindustrial area in Dhamrai Upazila about 50 kilometers northwest of Dhaka City; and (c) a heavily industrialized area in Savar Upazila. Mean Pb concentration in vegetables from the wholesale market was 1.03 mg/kg. This compares to 0.64 and 2.0 mg/kg in vegetables from the nonindustrial and industrial areas, respectively. Sultana et al. (2022) sampled nine kinds of commonly consumed vegetables from the Kawran Bazar wholesale market. This market is a supply center for vegetables to the entire Dhaka City. Samples were collected four times over a two-month period. Pb was detected in twelve of the 36 samples. Pb concentration in the twelve positive samples ranged from 0.68 to 6.0 mg/kg, with a mean Pb of 2.8 mg/kg. Mean Pb concentration in the overall sample was 0.93 mg/kg. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 215 Appendix C. Blood Lead Levels and Sources of Lead Exposure Table C.8 Pb concentrations in vegetables in Bangladesh from additional studies (mg/kg) # of vegetables Location Mean Source 1 Brinjal-producing upazilas in Jamalpur district 0.43 Bushra et al. 2022 7 Fields in Khulna 2.69 Dhar et al. 2019 10 Near Mongla industrial area 8.15 Ara et al. 2018a 6 Five locations in Jashore 5.45 Ara et al. 2018b 10 Savar Kacha Bazar wholesale market in Savar Municipality 1.03 Haque et al. 2021 10 Nonindustrial area in Dhamrai Upazila 0.64 Haque et al. 2021 10 Heavily industrialized area in Savar Upazila 2.00 Haque et al. 2021 9 Kawran Bazar wholesale market in Dhaka 0.93 Sultana et al. 2022 10 Tangail Industrial Area 8.40 Proshad et al. 2018 Sources: As noted in the table. Measurements of Pb concentrations in vegetables sampled at wholesale markets may provide the best indication of population exposure. Four of the studies reported above are from markets and are presented in table C.9. Two of the studies show very low Pb concentrations. This includes a study from fourteen village markets and three urban markets across Bangladesh with mean Pb concentrations ranging from 0.005 to 0.057 mg/kg in the vegetables, from 0.003 to 0.017 mg/kg in two of the fruits, and 0.642 mg/kg in mango (Shaheen et al. 2016). The two others show mean concentrations of 0.93 and 1.03 mg/kg. The studies by Real, Azam, and Majed (2017) and Sultana et al. (2022) are both from Kawran Bazar in Dhaka and show very different Pb concentrations, indicating that larger samples over a longer period of time covering both the rainy and dry seasons may be required to provide more accurate perspectives on Pb concentrations in vegetables nationally. Table C.9 Pb concentrations in vegetables sampled from markets (mg/kg) # of Location Mean Reference vegetables 7 Overall country: From markets 0.02 Shaheen et al. 2016 2 Kawran Bazar wholesale market, Dhaka 0.02 Real, Azam, and Majed 2017 10 Savar Kacha Bazar wholesale market in Savar Municipality 1.03 Haque et al. 2021 9 Kawran Bazar wholesale market in Dhaka 0.93 Sultana et al. 2022 Sources: As noted in the table. The studies of vegetables show large variation in mean Pb concentrations. Most of the studies from nonindustrial areas show mean concentrations in the range of 0.4 to 1.0 mg/kg. According to these studies, it appears that Pb in vegetables may be higher than in rice. Fish: Fish is the third most important food group in Bangladesh in terms of per capita quantity of consumption and the most important in terms of proteins. Bangladesh ranked third in the world in inland capture fisheries and fifth in culture fisheries pro- duction in 2019 (GoB 2020) and fishery production has increased nearly six-fold from 1985 to 2019. Inland culture fisheries expe- rienced the highest growth rate at 9.2 percent per year, followed by marine fisheries at 3.8 percent per year and inland capture fisheries at 2.9 percent per year. Islam et al. (2018a) and Majumder et al. (2021) reviewed seven studies of Pb concentrations in fish from six rivers. Mean concentrations ranged from 0.04 to 9.97 mg/kg (table C.10). Mean concentrations were highest in fish from sampling points in Dhaka in the Buriganga River and in Chittagong in the Karnafuli River. Mean concentrations in the three studies with the lowest Pb levels ranged from 0.04 to 0.74 mg/kg. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 216 Appendix C. Blood Lead Levels and Sources of Lead Exposure Table C.10 Pb concentrations in fish sampled from rivers in Bangladesh (mg/kg) # fish species Pb (mg/kg) Reference Source a Buriganga River 5 3.46 Ahmed et al. 2016 I&M Buriganga River 6 9.97 Ahmad et al. 2010 I&M Karnafuli River 4 3.32 Islam et al. 2013 I&M Paira River 8 0.68 Islam and Habibullahalmamun 2017 I&M Meghna River 6 2.20 Bhuyan et al. 2016 I Korotoa River 1 0.74 Islam et al. 2015 M Rupsha River 5 0.04 Samad et al. 2015 M Source: World Bank based on Islam et al. (2018a) and Majumder et al. (2021). Note: a I = Islam et al. 2018a; M = Majumder 2021. Majumder (2022) presents studies of Pb in fish from captured fisheries. Mean concentrations range from 0.13 to 11.6 mg/kg (table C.11). Four of the studies measured Pb in three to seven fish species and four measured Pb in a single species (pangasius or tila- pia). Mean Pb concentrations were 0.13 to 0.55 mg/kg in three of the studies, 1.35 to 1.67 mg/kg in three other studies, and 6.26 to 11.6 mg/kg in two studies. Some of the studies found high Pb concentration in commercial feed used at fish farms with mean Pb ranging from 6 to 10 mg/kg. These Pb concentrations in feed were highly correlated with Pb concentrations in farmed fish (Kundu et al. 2017; Saha, Mottalib, and Al-Razee 2021). Table C.11 Pb concentrations in cultured fish in Bangladesh (mg/kg) # of species Location Mean Pb Reference Cultured pangas, tilapia, and koi from markets across 30 3 0.04 Ahmed et al. 2015 agro-ecological zones 5 Cultured fish from Mymensing Sadar 0.43 Gosh et al. 2021 4 Rajshahi City (fish farms) 0.55 Mortuza and Al-Misned 2015 1 15 Tilapia ponds in Mymensingh 1.35 Alam and Haque 2021 1 15 Pangas ponds in Mymensingh 1.63 Alam and Haque 2021 1 Pangasius from six ponds at two fish farms in Noakhali 1.67 Das et al. 2017 7 Southern Part of Bangladesh (fish farms) 6.26 Saha, Mottalib, and Al-Razee 2021 1 9 Tilapia farms in Mymensingh 11.6 Kundu et al. 2017 Source: World Bank adapted from Majumder (2022). Two studies of Pb in fish from the Kawran Bazar fish market in Dhaka found very divergent concentrations. Real, Azam, and Ma- jed (2017) reported concentrations of 0.04–1.04 mg/kg while Shovon et al. (2017) reported a mean of 7.1 mg/kg in muscles of three common fish species. The studies with the lower mean Pb’s may best reflect nationwide population exposure to Pb in fish, while the studies with the higher mean Pb’s may indicate exposure levels for a relatively small share of the population. This suggests that nationwide population exposure to Pb from fish could be somewhere in the range of 0.04–0.74 mg/kg for capture fish and 0.13–1.6 mg/kg for culture fish. To calculate daily intake of Pb per person from fish consumption, Pb concentrations in fish report- ed in mg/kg dry weight must be converted to fresh weight by multiplying by a factor of 0.208 (Saha, Mottalib, and Al-Razee 2021). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 217 Appendix C. Blood Lead Levels and Sources of Lead Exposure References Ahmad, J. U., and M. A. Goni. 2010. “Heavy Metal Contamination in Water, Soil, and Vegetables of the Industrial Areas in Dhaka, Bangladesh.” Environ Monit Assess 166 (1): 347–57. https://doi. org/10.1007/s10661-009-1006-6. Ahmed, M. K., N. Shaheen, M. S. Islam, M. Habibullah-al-Mamun, S. Islam, M. Mohiduzzaman, and L. Bhattacharjee. 2015. “Dietary Intake of Trace Elements from Highly Consumed Cultured Fish (Labeo rohita, Pangasius pangasius and Oreochromis mossambicus) and Human Health Risk Implications in Bangladesh.” Chemosphere 128: 284–92. Ahmed, M. K., M. A. Baki, G. F. Kundu, M. S. Islam, M. M. Islam, and M. M. Hossain. 2016. “Human Health Risks from Heavy Metals in Fish of Buriganga River, Bangladesh.” Springer Plus 5 (1): 1–2. https://doi.org/10.1186/ s40064-016-3357-0. Alam, M. M., and M. M. Haque. 2021. “Presence of Antibacterial Substances, Nitrofuran Metabolites and Other Chemicals in Farmed Pangasius and Tilapia in Bangladesh: Probabilistic Health Risk Assessment.” Toxicol Rep 8: 248–57. Ara, M. H., A. R. Khan, M. Uddin, and P. K. Dhar. 2018a. “Health Risk Assessment of Heavy Metals in the Leafy, Fruit, and Root Vegetables Cultivated near Mongla Industrial Area, Bangladesh.” J Hum Environ Health Promot 4 (4): 144–52. Ara, M. H., U. K. Mondol, P. K. Dhar, and M. N. Uddin. 2018b. “Presence of Heavy Metals in Vegetables Collected from Jashore, Bangladesh: Human Health Risk Assessment.” J Chem Health Risks 8: 277–87. BBS (Bangladesh Bureau of Statistics). 2021. Report on Bangladesh Sample Vital Statistics 2020. Dhaka, Bangladesh: BBS. BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2019. Progotir Pathey: Bangladesh Multiple Indicator Cluster Survey 2019. Survey Findings Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. Bhuiyan, M. A. H., M. A. Islam, S. B. Dampare, L. Parvez, and S. Suzuki. 2010. “Evaluation of Hazardous Metal Pollution in Irrigation and Drinking Water Systems in the Vicinity of a Coal Mine Area of Northwestern Bangladesh.” J Hazard Mater 179 (1–3): 1065–77. doi:10.1016/j.jhazmat.2010.03.114. Bhuyan, M. S., M. A. Bakar, A. Akhtar, and M. S. Islam. 2016. “Heavy Metals Status in Some Commercially Important Fishes of Meghna River Adjacent to Narsingdi District, Bangladesh: Health Risk Assessment.” Am J Life Sci 4: 60–70. Bulka, C. M., M. Scannell Bryan, V. W. Persky, M. L. Daviglus, R. A. Durazo-Arvizu, F. Parvez, V. Slavkovich, J. H. Graziano, T. Islam, J. A. Baron, H. Ahsan, and M. Argos. 2019. “Changes in Blood Pressure Associated with Lead, Manganese, and Selenium in a Bangladeshi Cohort.” Environmental Pollution 248: 28–35. doi:10.1016/j. envpol.2019.01.129. Bushra, A., H. M. Zakir, S. Sharmin, Q. F. Quadir, M. H. Rashid, M. S. Rahman, and S. Mallick. 2022. “Human Health Implications of Trace Metal Contamination in Topsoils and Brinjal Fruits Harvested from a Famous Brinjal-Producing Area in Bangladesh.” Science Reports 12: 14278. https://doi.org/10.1038/s41598-022-17930-5. Chowdhury, K. I. A., S. Nurunnahar, M. L. Kabir, M. T. Islam, M. Baker, M. S. Islam, M. Rahman, M. A. Hasan, A. Sikder, L. H. Kwong, G. K. Binkhorst, E. Nash, J. Keith, A. McCartor, S. P. Luby, and J. E. Forsyth. 2021. “Child Lead Exposure near Abandoned Lead Acid Battery Recycling Sites in a Residential Community in Bangladesh: Risk Factors and the Impact of Soil Remediation on Blood Lead Levels.” Environmental Research 194: 110689. Das, P. R., M. K. Hossain, B. S. Sarker, A. Parvin, S. S. Das, M. Moniruzzaman, and B. Saha. 2017. “Heavy Metals in Farm Sediments, Feeds and Bioaccumulation of Some Selected Heavy Metals in Various Tissues of Farmed Pangasius hypophthalmus in Bangladesh.” Fisheries and Aquaculture Journal 8: 1–9. Dhar, P. K., N. Uddin, M. H. Ara, and N. T. Tonu. 2019. “Heavy Metals Concentrations in Vegetables, Fruits and Cereals and Associated Health Risk of Human in Khulna, Bangladesh.” J Wat Env Sci 3 (1): 453–59. Forsyth, J. E., M. Saiful Islam, S. M. Parvez, R. Raqib, M. Sajjadur Rahman, E. Marie Muehe, S. Fendorf, and S. P. Luby. 2018. “Prevalence of Elevated Blood Lead Levels among Pregnant Women and Sources of Lead Exposure in Rural Bangladesh: A Case Control Study.” Environmental Research 166: 1–9. doi:10.1016/j. envres.2018.04.019 Ghosh, P., Z. Ahmed, R. Alam, B. A. Begum, S. Akter, and Y. N. Jolly. 2021. “Bioaccumulation of Metals in Selected Cultured Fish Species and Human Health Risk Assessment: A Study in Mymensingh Sadar Upazila, Bangladesh.” Stochastic Environmental Research and Risk Assessment 35: 2287–2301. https://doi. org/10.1007/s00477-021-02026-9. Gleason, K. M., L. Valeri, A. H. Shankar, J. F. Obrycki, O. S. I. Hasan, G. Mostofa, Q. Quamruzzaman, R. O. Wright, D. C. Christiani, D. C. Bellinger, and M. Mazumdar. 2020. “Stunting and Lead: Using Causal Mediation Analysis to Better Understand How Environmental Lead Exposure Affects Cognitive Outcomes in Children.” Journal of Neurodevelopmental Disorders 12: 39 https://doi.org/10.1186/s11689-020-09346-x. GoB (Government of Bangladesh). 2020. “Making Vision 2041 a Reality: Perspective Plan of Bangladesh 2021–2041.” General Economics Division, Bangladesh Planning Commission, Ministry of Planning. Dhaka, Bangladesh: Government of the People’s Republic of Bangladesh. Haque, M., N. M. Niloy, A. Khirul, F. Alam, and S. M. Tareq. 2021. “Appraisal of Probabilistic Human Health Risks of Heavy Metals in Vegetables from Industrial, Non- industrial and Arsenic Contaminated Areas of Bangladesh.” Heliyon 7 (2): e06309. ISSN 2405-8440. https://doi.org/10.1016/j.heliyon.2021.e06309. Hasan, M. K., A. Shahriar, and K. U. Jim. 2019. “Water Pollution in Bangladesh and Its Impact on Public Health.” Heliyon 5: e02145. icddr,b. n.d.. Non-communicable diseases. A Brief Guide to Non-Communicable Diseases (NCDs) and their Impact Globally and in Bangladesh. https://www. icddrb.org/news-and-events/press-corner/media-resources/non-communicable-diseases. Islam, M. S., and M. Habibullahalmamun. 2017. “Accumulation of Trace Elements in Sediment and Fish Species of Paira River, Bangladesh.” AIMS Environ Sci 4: 310–22. https://doi.org/10.3934/environsci.2017.2.310. Islam, M.S., and M. F. Hoque. 2014. “Concentrations of Heavy Metals in Vegetables Around the Industrial Area of Dhaka City, Bangladesh and Health Risk Assessment.” Int. Food Res. J. 21(6): 2121–2126. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 218 Appendix C. Blood Lead Levels and Sources of Lead Exposure Islam, F., M. Rahman, S. S. Khan, B. Ahmed, A. Bakar, and M. Halder. 2013. “Heavy Metals in Water, Sediment and Some Fishes of Karnofuly River, Bangladesh.” Pollut Res 32: 715–21. http:// www.envirobiotechjournals.com/article_abstract. php?aid=4763&iid=165&jid=4. Islam, M. S., M. K. Ahmed, M. Habibullah-Al-Mamun, and M. Raknuzzaman. 2015. “The Concentration, Source and Potential Human Health Risk of Heavy Metals in the Commonly Consumed Foods in Bangladesh.” Ecotoxicol Environ Saf 122: 462–69. Islam, M. M., M. R. Karim, X. Zheng, and X. Li. 2018a. “Heavy Metal and Metalloid Pollution of Soil, Water and Foods in Bangladesh: A Critical Review.” International J of Environmental Research and Public Health 15 (12): 2825. https://doi.org/10.3390/ijerph15122825. Islam, R., S. Kumar, A. Rahman, J. Karmoker, S. Ali, S. Islam, and M. S. Islam. 2018b. “Trace Metals Concentration in Vegetables of a Sub-urban Industrial Area of Bangladesh and Associated Health Risk Assessment.” AIMS Environ Sci 15 (3): 130–42. https://doi. org/10.3934/environsci.2018.3.130. Jahiruddin, M., Y. Xie, A. Ozaki, M. R. Islam, T. V. Nguyen, and K. Kurosawa. 2017. “Arsenic, Cadmium, Lead and Chromium Concentrations in Irrigated and Rain-fed Rice and their Dietary Intake Implications.” Australian Journal of Crop Science 11 (7): 806–12. https://doi.org/10.21475/ajcs.17.11.07.pne408. Jamal, A. H. M. S. I. M., Md. A. Ahsan, S. Ahmed, S. Akter, R. Sultana, A. Nahar, and Md. R. Uddin. 2020. “Physicochemical and Microbiological Quality of Potable Water Supplied by DWASA in Dhaka City of Bangladesh.” American Journal of Biological and Environmental Statistics 6 (1): 1–6. doi:10.11648/j.ajbes.20200601.11. Kaiser, R., A. K. Henderso, W. R. Daley, M. Naughton, M. H. Khan, M. Rahman, S. Kieszak, and C. H. Rubin. 2001. “Blood Lead Levels of Primary School Children in Dhaka, Bangladesh.” Environ Health Perspect 109 (6): 563–66. doi:10.1289/ehp.01109563. Kumar, S., R. Islam, P. B. Akash, Md. H. R. Khan, R. Proshad, J. Karmoker, and G. R. MacFarlane. 2022. “Lead (Pb) Contamination in Agricultural Products and Human Health Risk Assessment in Bangladesh.” Water, Air, & Soil Pollution 233: 257. https://doi.org/10.1007/s11270-022-05711-9. Kundu, G. K., M. Alauddin, M. S. Akter, M. S. Khan, M. M. Islam, G. Mondal, D. Islam, L. C. Mohanta, and A. Huque. 2017. “Metal Contamination of Commercial Fish Feed and Quality Aspects of Farmed Tilapia (Oreochromis niloticus) in Bangladesh.” Bioresearch Communications (BRC) 3: 345–53. Linderholm, L., K. Jakobsson, T. Lundh, R. Zamir, M. Shoeb, N. Nahar, and A. Bergman. 2011. “Environmental Exposure to POPs and Heavy Metals in Urban Children from Dhaka, Bangladesh.” Journal of Environmental Monitoring 13: 2728. Majumder, A. K. 2022. “Support to Cost-Benefit Analysis of Interventions to Address Lead Contamination in Bangladesh.” Prepared for the World Bank. Washington, DC: World Bank. Majumder, A. K., A. al Nayeem, M. Islam, M. M. Akter, and W. S. Carter. 2021. “Critical Review of Lead Pollution in Bangladesh.” Journal of Health Pollution 11: 210902. McCartor, A., and E. Nash. 2018. Project Completion Report: Reducing Lead Poisoning Among Children in Kathgora, Bangladesh. New York, NY: Pure Earth. https://www.pureearth.org/wp-content/uploads/2019/10/PCR-Report_Kathgora.pdf Mitra, A. K., E. Ahua, and P. K. Saha. 2012. “Prevalence of and Risk Factors for Lead Poisoning in Young Children in Bangladesh.” Journal of Health, Population and Nutrition 30 (4): 404–09. Mitra, A. K., A., Haque, M. Islam, and S. A. M. K. Bashar. 2009. “Lead Poisoning: An Alarming Public Health Problem in Bangladesh.” Int. J. Environ. Res. Public Health 6: 84–95. doi:10.3390/ijerph6010084. Mortuza, M. G., and F. A. Al-Misned. 2015. “Trace Elements and Heavy Metals in Five Cultured and Captured Fishes from Rajshahi City, Bangladesh.” Biomedical Sciences Today 1: 1–9. Mostafa, M. G., S. M. Uddin, and A. Haque. 2017. “Assessment of Hydro-Geochemistry and Groundwater Quality of Rajshahi City in Bangladesh.” Applied Water Science 7: 4663–71. https://doi.org/10.1007/s13201-017-0629-y. Mottalib, M. A., S. H. Somoal, M. Aftab, A. Shaikh, and M. S. Islam. 2016. “Heavy Metal Concentrations in Contaminated Soil and Vegetables of Tannery Area in Dhaka, Bangladesh.” Int J Cur Res 8 (5): 30369–73. Naser, H. M., S. Sultana, R. Gomes, and S. Noor. 2012. “Heavy Metal Pollution of Soil and Vegetable Grown near Roadside at Gazipur. Bangladesh.” J Agric Res 37 (1): 9–17. https://doi.org/10.3329/bjar.v37i1.11170. Parvin, F., M. M. Haque, and S. M. Tareq. 2021. “Recent Status of Water Quality in Bangladesh: A Systematic Review, Meta-Analysis and Health Risk Assessment.” Environmental Challenges 6: 100416. doi:10.1016/j.envc.2021.100416. Parvin, R., A. Sultana, and M. A. Zahid. 2014. “Detection of Heavy Metals in Vegetables Cultivated in Different Locations in Chittagong, Bangladesh.” IOSR J Environ Sci Toxicol Food Tech 8 (4): 58–63. https://doi. org/10.9790/2402-08425863. Proshad, R., Md. Islam, and T. Kormoker. 2018. “Assessment of Heavy Metals with Ecological Risk of Soils in the Industrial Vicinity of Tangail District, Bangladesh.” International Journal of Advanced Geosciences 6: 10.14419/ijag.v6i1.9791. Raihan, M. J., E. Briskin, M. Mahfuz, M. M. Islam, D. Mondal, M. I. Hossain, A. M. S. Ahmed, R. Haque, and T. Ahmed. 2018. “Examining the Relationship between Blood Lead Level and Stunting, Wasting and Underweight: A Cross-sectional Study of Children under 2 Years-of-Age in a Bangladeshi Slum.” PLoS ONE 13 (5): e0197856. https://doi.org/10.1371/journal.pone.0197856 Real, I. H., H. M. Azam, and N. Majed. 2017. “Consumption of Heavy Metal Contaminated Foods and Associated Risks in Bangladesh.” Environ Monit Assess 189: 651. PMID: 29181620 doi:10.1007/s10661-017-6362-z. Saha, B., M. Mottalib, and A. N. Al-Razee. 2021. “Heavy Metals Accumulation in Different Cultivated Fish Tissues through Commercial Fish Feeds and Health Risk Estimation in Consumers in Bangladesh.” Chemical Review and Letters 4: 10–20. Samad, M. A., Y. Mahmud, R. K. Adhikary, S. B. Rahman, M. S. Haq, and H. Rashid. 2015. “Chemical Profile and Heavy Metal Concentration in Water and Freshwater Species of Rupsha River, Bangladesh.” American J Environ Protect 3 (6): 180–6. https://doi.org/10.12691/ env-3-6-1, Shaheen, N., N. Irfan, I. N. Khan, S. Islam, Md. S. Islam, and Md. K. Ahmed. 2016. “Presence of Heavy Metals in Fruits and Vegetables: Health Risk Implications in BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 219 Appendix C. Blood Lead Levels and Sources of Lead Exposure Bangladesh.” Chemosphere 152: 431–38. ISSN 0045-6535. https://doi.org/10.1016/j.chemosphere.2016.02.060. Shamsudduha, M., G. Joseph, S. Haque, M. Khan, A. Zahid, and K. Ahmed. 2019. “Multi-Hazard Groundwater Risks to the Drinking Water Supply in Bangladesh: Challenges to Achieving the Sustainable Development Goals.” Policy Research Working Paper 8922. World Bank, Washington DC. Shovon, M. N., B. C. Majumdar, and Z. Rahman. 2017. “Heavy Metals (Lead, Cadmium and Nickel) Concentration in Different Organs of Three Commonly Consumed Fishes in Bangladesh.” Fisheries and Aquaculture Journal 8 (3): 1000207. https://doi.org/10.4172/2150- 3508.1000207. Sultana, R., R. U. Tanvir, K. A. Hussain, A. S. Chamon, and Md. N. Mondol. 2022. “Heavy Metals in Commonly Consumed Root and Leafy Vegetables in Dhaka City, Bangladesh, and Assessment of Associated Public Health Risks.” Environ Syst Res 11: 15. https://doi.org/10.1186/s40068-022-00261-9. Tasrina, R. C., and A. Rowshon. 2015. “Heavy Metals Contamination in Vegetables and its Growing Soil.” Int J Environ Anal Chem 2 (3). doi:10.4172/2380-2391.1000142. Uddin, M., N., M. K. Hasan, and P. K. Dhar. 2019. “Contamination Status of Heavy Metals in Vegetables and Soil in Satkhira, Bangladesh.” J Mater Environ Sci 10 (6): 543–52. https://www.jmaterenvironsci.com/ Document/vol10/vol10_N6/57-JMES-Uddin-2019.pdf Wasserman, G. A., X. Liu, F. Parvez, P. Factor-Litvak, H. Ahsan, D. Levy, J. Kline, A. van Geen, J. Mey, V. Slavkovich, A. B. Siddique, T. Islam, and J. Graziano. 2011. “Arsenic and Manganese Exposure and Children’s Intellectual Function.” Neurotoxicology 32(4): 450–57. doi:10.1016/j.neuro.2011.03.009. Wasserman, G. A., X. Liu, F. Parvez, Y. Chen, P. Factor-Litvak, N. J. LoIacono, D. Levy, H. Shahriar, M. N. Uddin, T. Islam, A. Lomax, R. Saxena, E. A. Gibson, M. A. Kioumourtzoglou, O. Balac, T. Sanchez, J. K. Kline, D. Santiago, T. Ellis, A. van Geen, and J. H. Graziano. 2018. “A Cross-Sectional Study of Water Arsenic Exposure and Intellectual Function in Adolescence in Araihazar, Bangladesh.” Environment International 118: 304–13. doi:10.1016/ j.envint.2018.05.037 Woo, M. K., E. S. Young, G. Mostofa, S. Afroz, O. S. I. Hasan, Q. Quamruzzaman, D. C. Bellinger, D. C. Christiani, and M. Mazumdar. 2018. “Lead in Air in Bangladesh: Exposure in a Rural Community with Elevated Blood Lead Concentrations among Young Children.” International Journal of Environmental Research and Public Health 15: 1947. doi:10.3390/ijerph15091947 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 220 Appendix D. Estimating IQ Losses from Pb in Children Appendix D. Estimating IQ Losses from Pb in Children A well-established effect of lead exposure is neuropsychological impairment in children, measured as IQ loss. (Intelligence quo- tient—IQ—is a score on standardized tests designed to assess intelligence.) This impairment occurs even at blood lead levels (BLLs) of less than 10 µg/dL (Crump et al. 2013; Jusko et al. 2008; Lanphear et al. 2005; Surkan et al. 2007). IQ losses associated with BLLs > 10 µg/dL have been established long ago. Lanphear et al. pooled seven international longitudinal cohort studies in which 17 percent of children had peak BLL below 10 µg/dL (table D.1). One of the pooled studies is Canfield et al. (2003) which represent over 40 percent of the sample of children with BLL below 10 µg/dL in Lanphear et al. The largest study of children with BLL below 10 µg/dL is Surkan et al. (2007). Table D.1 Recent studies assessing the effect of blood lead level (BLL) on children’s IQ score Longitudinal cohort (7 Type of study Longitudinal cohort Cross-sectional Longitudinal cohort pooled studies) Lanphear et al. Jusko et al. Surkan et al. 2007 Canfield et al. 2003 2005 2008 Age of children < 1 to 5–10 years 0.5–6 years 6–10 years 6 months to 5 years Mean BLL (µg/dL) • Concurrent 9.7 5.0 2.2 5.8 • Lifetime 12.4 7.2 7.4 • Peak 18.0 11.4 11.1 Number of children 1,333 174 408 172 Children with BLL < 10 µg/dL 244 (peak) 94 (peak) 408 (concurrent) 101 (peak) Sources: As noted in the table. Note: Concurrent BLL is the BLL of a child at the time of IQ testing. Lifetime BLL is the mean BLL over the life of the child prior to IQ testing. Peak BLL is the highest BLL measured prior to IQ testing. Crump et al. (2013), using the same pooled data as in Lanphear et al., took the analysis further. Crump’s study confirmed that the log-linear function is a better predictor of IQ than a linear function. The log-linear function in Crump et al. is: (D.1) With a theoretical minimum-risk exposure level (TMREL) of X0, below which BLLs is assumed to have no effect on IQ, the function becomes: (D.2a) (D.2b) Crump et al. estimated the β coefficient for several measures of BLLs and concluded that concurrent BLLs (BLLs at the time of or just before an IQ test) provide the best description of the relationship between BLL and IQ. Most BLL measurement studies, however, involve samples of children of various ages (for example, ages 0–5 years or 0–7 years) with mean BLLs corresponding closer to lifetime BLLs (mean BLL from age 0 till the time of IQ test) than to concurrent BLLs. IQ losses based on lifetime and concurrent BLLs are compared in figure D.1 using equation D.1. IQ losses are somewhat larger for lifetime BLLs, with concurrent BLLs converted from lifetime BLLs by a factor of 0.78. The BLLs in the Lanphear et al. studies suggest that concurrent BLLs at ages 5 to 7 years are about 78 percent of lifetime BLLs. Therefore, lifetime BLLs are multiplied by a factor of 0.78 to arrive at estimates of concurrent BLLs. The difference is 0.43–0.54 IQ points across the BLL range of 2 to 30 μg/ dL, or 14 percent for a BLL of 2 μg/dL, 7.5 percent for a BLL of 10 μg/dL, and 4.7 percent for a BLL of 30 μg/dL. The percentage differ- ence in estimated IQ losses is therefore relatively small. Using concurrent BLLs also introduces an added element of uncertainty BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 221 Appendix D. Estimating IQ Losses from Pb in Children as concurrent BLLs will in most cases need to be estimated from lifetime BLLs as most BLL measurement studies do not have large enough sample of children of ages 5–7 years for estimation of concurrent BLLs. Therefore, lifetime BLLs are applied here to estimate IQ losses from lead exposure. Figure D.1 Loss of IQ points from lead exposure in early childhood Source: Produced from the log-linear function reported in Crump et al. (2013). Note: β = 3.246 for lifetime BLL and β = 3.315 for concurrent BLL. A BLL threshold (X0) below which there are no impacts on children’s IQ has not been identified in the international research liter- ature. Gilbert and Weiss (2006) argue for a BLL action level of 2 µg/dL and Carlisle et al. (2009) for a benchmark of 1.0 µg/dL based on the recent research evidence. The European Food Safety Authority (EFSA) uses a benchmark dose level (BMDL) of 1.2 µg/ dL for neurotoxicity in children (EFSA 2013). The United States Environmental Protection Agency (USEPA), in a recent economic analysis of lead abatement, employed three alternative IQ loss models, two of which applied a zero BLL threshold (USEPA 2020). A threshold value of X0 = 0 µg/dL is applied here. Total IQ losses in children are estimated by first calculating the children’s BLL distribution. The proportion of children (Pi) with BLL in the range xi-1 to xi (xi-1 < xi) is: (D.3) where FX(x, µ, σ) is the cumulative log-normal distribution function, x is BLL, and µ and σ are the natural logarithm of the mean and standard deviation of the BLLs, respectively. Total annual IQ losses in children under five years of age are then approximated by the following expression: (D.4) Box 6.1 where C is the total number of children under five years of age, with the expression divided by five by assuming that the children’s IQ points are lost throughout the first five years of life. An interval of xi – xi-1 = 0.5 µg/dL is applied to estimate IQ losses in this report, with n such that FX(xn, µ, σ) > 0.999. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 222 Appendix D. Estimating IQ Losses from Pb in Children References Canfield, R. L., C. R. Henderson, D. A. Cory-Slechta, C. Cox, T. A. Jusko, and B. P. Lanphear. 2003. “Intellectual Impairment in Children with Blood Lead Concentrations below 10µg per Deciliter.” NEJM 348 (16): 1517–26. Carlisle, J., K. Dowling, D. Siegel, and G. Alexeeff. 2009. “A Blood Lead Benchmark for Assessing Risks from Childhood Lead Exposure.” J of Environmental Science and Health Part A 44: 1200–08. Crump, K., C. Van Landingham, T. Bowers, D. Cahoy, and J. Chandalia. 2013. “A Statistical Reevaluation of the Data Used in the Lanphear et al. (2005) Pooled- Analysis that Related Low Levels of Blood Lead to Intellectual Deficits in Children.” Crit Rev Toxicol 43 (9): 785–99. EFSA (European Food Safety Authority). 2013. “Scientific Opinion on Lead in Food.” EFSA Panel on Contaminants in the Food Chain. Parma, Italy: EFSA. Gilbert, S. G., and B. Weiss. 2006. “A Rationale for Lowering the Blood Lead Action Level from 10 to 2 µg/dL.” NeuroToxicology 27: 693–701. Jusko, T. A., C. R. Henderson, B. P. Lanphear, D. A. Cory-Slechta, P. J. Parsons, and R. L. Canfield. 2008. “Blood Lead Concentrations < 10 ug/dL and Child Intelligence at 6 Years of Age.” Environmental Health Perspectives 116 (2): 243–48. Lanphear, B. P., R. Hornung, J. Khoury, K. Yolton, P. Baghurst, D. C. Bellinger, R. L. Canfield, K. N. Dietrich, R. Bornschein, T. Greene, S. J. Rothenberg, H. L. Needleman, L. Schnaas, G. Wasserman, J. Graziano, and R. Roberts. 2005. “Low-level Environmental Lead Exposure and Children’s Intellectual Functions: An International Pooled Analysis.” Environmental Health Perspectives 113 (7): 894–99. Surkan, P. J., A. Zhang, F. Trachtenberg, D. B. Daniel, S. McKinlay, and D. C. Bellinger. 2007. “Neuropsychological Function in Children with Blood Lead Levels < 10 µg/dL.” NeuroToxicology 28 (6): 1170–77. USEPA (US Environmental Protection Agency). 2020. “Economic Analysis of the Final Rule to Revise the TSCA Dust-Lead Post-Abatement Clearance Levels.” Office of Pollution Prevention and Toxics. Washington, DC: USEPA. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 223 Appendix E. Estimating Health Effects from Pb in Adults Appendix E. Estimating Health Effects from Pb in Adults Lead exposure has been found to increase cardiovascular disease (CVD) mortality risk in adults. Brown et al. (2020) identified and reviewed fifteen studies that assessed this relationship, of which four studies met their inclusion criteria for the development of a health impact model that used each study’s BLL concentration-response function. All four studies analyzed BLLs of the adult population in the United States from one or more of the nationally representative National Health and Nutrition Examination Surveys (NHANES) from 1988 to 2010 (CDC 2023). Participant BLLs were highest in the earlier surveys and lowest in the most re- cent survey. About 20 percent of the participants in the earliest survey 1988-1994 had BLLs above 5 µg/dL while this had declined to about 6 percent in the survey period 1999 to 2010 (table E.1). While all studies had a relatively large number of participants with BLLs of 5–10 µg/dL, the number of participants with BLLs greater than 10 µg/dL is relatively small. This raises questions as to the validity of the shape of the BLL–CVD mortality risk function estimated by the four studies for individuals with BLLs over 10 µg/dL. This is of relevance because over 25 percent of adults in low- and middle-income countries (LMICs) are estimated to have BLLs above this level. A study using the same data from 1988–94 as Menke et al. and Lanphear et al. reports that 6 percent of participants had BLLs over 10 µg/dL and estimates that the risk of CVD mortality is 1.29 for individuals with BLLs over 10 µg/dL relative to individuals with BLLs of 5–10 µg/dL (Schober et al. 2006). This relative risk is somewhat higher than the risk found by Menke et al. and Lanphear et al. for a BLL of 10 µg/dL relative to 5 µg/ dL and substantially higher than for a BLL of 15 µg/dL relative to 10 µg/dL. The difference in relative risk of CVD mortality for BLLs over 10 µg/dL is even larger compared to the risk found by Aoki et al. and Ruiz-Hernandez et al. suggesting that the risk functions in the four studies used by Brown et al. may be conservative for BLLs above 10 µg/dL. Similarly, a study using the NHANES from 1976 to 1980 found that the all-cause mortality risk from BLLs of 20–29 µg/dL was as high as 1.46 relative to BLLs below 10 µg/dL (Lustberg and Silbergeld 2002). Table E.1 Study participant blood lead levels and measurement period BLLs of study participants BLL measurement period Aoki et al. (2016) 5.3% of sample had BLL of 5–10 ug/dL, and 0.8% had BLL > 10 ug/dL 1999–2010 Menke et al. (2006) BLLs up to 10 ug/dL 1988–1994 Ruiz-Hernandez et al. (2017) BLLs of all participants 1988–1994 and 1999–2004 Lanphear et al. (2018) 20% had BLL > 5 ug/dL and 10% had BLL > 6.7 ug/dL 1988–1994 Source: World Bank derived from Brown et al. (2020). Based on Brown et al., the relative risk (RR) of CVD mortality from lead exposure is derived as: RR = BLLβ for BLL ≥ 1 μg/dL (E.1) with the β coefficient from the four studies given in table E.2. The estimated coefficient varies by a multiple of almost four, im- plying a wide range in estimated RR of CVD mortality across the four studies. Lanphear et al. (2018) found the largest RR when restricting the analysis to participants with BLL < 5 μg/dL. Menke et al. (2006) found the second largest RR when restricting the sample to participants with BLL < 10 µg/dL. For the full sample of participants, Aoki et al. (2016) found the smallest RR and Lan- phear et al. (2018) found the largest. As reflected by the size of the β coefficient, the estimated magnitude of relative risk of CVD mortality from elevated BLLs is sub- stantially larger in the three studies that used the earlier survey data with higher BLLs (β of 0.245–0.35) than in the Aoki et al. study that used the more recent data with lower BLLs (β of 0.115). This may suggest that the larger relative risks in Lanphear et al. and Ruiz-Hernandez et al. may be more relevant for LMICs since their populations generally have substantially higher BLLs than in HICs. However, the large relative risk in Menke et al. may not be relevant for most LMICs since Menke et al. restricted the sample to participants with BLL < 10 µg/dL. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 224 Appendix E. Estimating Health Effects from Pb in Adults Table E.2 Estimated β coefficient of the relative risk function for CVD mortality in adults β Lanphear et al. (2018) (for BLL < 5 μg/dL) 0.417 Menke et al. (2006) (for BLL < 10 µg/dL) 0.350 Lanphear et al. (2018) 0.278 Ruiz-Hernandez et al. (2017) 0.245 Aoki et al. (2016) (for whole blood BLL)* 0.115 Source: Derived from Brown et al. (2020) and Aoki et al. (2016). Note: *Brown et al. (2020) report the risk function from Aoki et al. (2016) for hematocrit corrected BLL. The β coefficient for whole blood BLL presented here is taken from Aoki et al. (2016). The disease burden from lead exposure is then estimated in several steps. First, the proportion of adults with BLL in the range xi-1 to xi (xi-1 < xi) is estimated: (E.2) where FX(x, µ, σ) is the cumulative log-normal distribution function, x is BLL, and µ is the mean and σ the standard deviation of the natural logarithm of the BLLs. The population attributable fraction of disease is then approximated by the following expression: (E.3) The disease burden (B) in terms of annual cases of CVD mortality due to lead exposure is then estimated by: (E.4) where D is the total annual baseline cases of CVD mortality. References Aoki, Y., D. J. Brody, K. M. Flegal, T. H. Fakhouri, D. A. Axelrad, and J. D. Parker. 2016. “Blood Lead and Other Metal Biomarkers as Risk Factors for Cardiovascular Disease Mortality.” Medicine 95 (1): e2223. PMID: 26735529, https://doi.org/10.1097/MD.0000000000002223. Brown, L., M. Lynch, A. Belova, R. Klein, and A. Chiger. 2020. “Developing a Health Impact Model for Adult Lead Exposure and Cardiovascular Disease Mortality.” Environmental Health Perspectives 128 (9). https://doi.org/10.1289/EHP6552. CDC (Centers for Disease Control and Prevention). 2023. National Health and Nutrition Examination Survey. Atlanta, GA: CDC. https://www.cdc.gov/nchs/nhanes/ index.htm. “ Lanphear, B. P., S. Rauch, P. Auinger, R. W. Allen, and R. W. Hornung. 2018. Low-level Lead Exposure and Mortality in US Adults: A Population-based Cohort Study. ” Lancet Public Health 3 (4): e177–84. PMID: 29544878, https://doi.org/10.1016/S2468-2667(18)30025-2. Lustberg, M. and E. Silbergeld. 2002. “Blood Lead Levels and Mortality.” Arch Intern Med 162 (21): 2443-9. doi:10.1001/archinte.162.21.2443. Menke, A., P. Muntner, V. Batuman, E. K. Silbergeld, and E. Guallar. 2006. “Blood Lead below 0.48 μmol/L (10 μg/dL) and Mortality among US Adults.” Circulation 114 (13): 1388–94. PMID: 16982939, https://doi.org/10.1161/CIRCULATIONAHA.106.628321. Ruiz-Hernandez, A., A. Navas-Acien, R. Pastor-Barriuso, C. M. Crainiceanu, J. Redon, E. Guallar, and M. Tellez-Plaza. 2017. “Declining Exposures to Lead and Cadmium Contribute to Explaining the Reduction of Cardiovascular Mortality in the US Population, 1988–2004. ”International Journal of Epidemiology 46 (6): 1903–1912. PMID: 29025072. https://doi.org/10.1093/ije/dyx176. Schober, S., L. Mirel, B. Graubard, D. Brody, and K. Flegal. 2006. “Blood Lead Levels and Death from All Causes, Cardiovascular Disease, and Cancer: Results from the NHANES III Mortality Study.” Environmental Health Perspectives 114: 10. CID: https://doi.org/10.1289/ehp.9123. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 225 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene Inadequate water, sanitation, and hygiene (WASH) is directly and indirectly affecting population health. Directly, inadequate WASH causes diarrheal infections and other health effects that in turn lead to mortality especially in young children. Indirectly, in- adequate WASH contributes to poor nutritional status in young children through the effect of diarrheal infections (Fewtrell et al. 2007; Larsen 2007; World Bank 2008). Repeated infections, and especially diarrheal infections, have been found to significantly impair weight gains in young children. Studies documenting and quantifying this effect have been conducted in communities with a wide range of infection loads in a diverse group of countries. World Bank (2008) provides a review of these studies. Poor nutritional status in turn increases the risk of child mortality from disease (Black et al. 2008; Fishman et al. 2004; Olofin et al. 2013). Child underweight is the nutritional indicator most commonly used in assessing the risk of mortality from poor nutritional status (Fishman et al. 2004). F.1 Direct effects Relative risks (RR) used by the Global Burden of Disease 2019 (GBD 2019) are applied here to estimate the attributable fraction of diarrheal disease morbidity and mortality from inadequate drinking water, sanitation, and handwashing in Bangladesh. The GBD 2019 derived the relative risk estimates for drinking water and sanitation largely from meta-analyses by Wolf et al. (2014; 2018) and for handwashing with soap from meta-analyses by Cairncross et al. (2010) and Rabie and Curtis (2006). The GBD 2019 distinguishes between four classes of drinking water and whether or not the household treats the water at point of use (table F.1). RRs range from 1 for high quality piped water that is treated by the household to 11.08 for untreated drinking water from unimproved water sources. The RR for treated water is for water filtering. As boiling of water is equally prevalent as filtering in Bangladesh, the RRs reported by the GBD 2019 for filtering is here also applied to boiled water. The RR for filtering or boiling relative to untreated water is the ratio of RR for treated over the RR for untreated—that is, 0.48, indicating that household water treatment reduces the risk of diarrheal disease by 52 percent. The GBD 2019 also includes chlorination as a treatment method. This method is rarely used by households in Bangladesh according to the Bangladesh MICS 2019 is therefore not reported here. The GBD 2019 distinguishes between “high-quality piped” and “piped water”. According to this classification, piped water in Bangladesh mostly falls into Class II. Water from tubewells/boreholes is Class III. An alternative classification is to assign all piped water and water from tubewells/boreholes as Class I instead of Class II and III, while water from other improved sources would remain as Class III. According to the GBD 2019 classification, nearly 87 percent of the population in Bangladesh had Class III drinking water (mostly tubewells/boreholes) while nearly 12 percent had Class II (piped water). The alternative classification assigns over 97 percent of the population to Class I (piped water and tubewells/boreholes) (table F.1). The impact of the difference in classification on the estimated attributable fraction of diarrheal disease and mortality from drinking water is substantial as seen further below, but much smaller on the joint attributable fraction from inadequate drinking water, sanitation, and hygiene. Table F.1 Relative risk of diarrheal disease from drinking water in Bangladesh, 2019 Treated Population Population RR GBD 2019 Alternative (filtered or distribution distribution (GBD 2019) classification classification boiled) (%) (%) Yes 1.00 0 Piped water and 9.2 Class I High-quality piped No 2.08 0 tubewell/borehole 88.0 Yes 3.31 1.1 0 Class II Piped water No 6.88 10.5 0 Yes 4.33 8.3 0.1 Class III Other improved Other improved No 8.99 78.6 1.2 Yes 5.33 0.3 0.3 Class IV Unimproved Unimproved No 11.08 1.2 1.2 Source: World Bank based on Bangladesh MICS 2019 (BBS/UNICEF 2019) and GBD Risk Factor Collaborators (2020) Supplement 1. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 226 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene The GBD 2019 distinguishes between three forms or classes of household sanitation. The relative risks of diarrheal disease and mortality from sanitation are relative to households with flush or pour flush toilets connected to a sewer network or a septic tank (table F.2). An alternative classification is based on the Bangladesh MICS 2019 definition of “safe disposal in situ of excreta from on-site sanitation facilities” which accounts for 90 percent of the population with septic tanks and other improved sanitation. This classification assigns the majority of the population in Class I. As in the case of drinking water, the impact of the difference in classification on the estimated attributable fraction of diarrheal disease and mortality from sanitation is substantial as seen further below, but much smaller on the joint attributable fraction from inadequate drinking water, sanitation, and hygiene. Table F.2 Relative risk of diarrheal disease from sanitation in Bangladesh, 2019 Population Population RR GBD 2019 classification distribution Alternative classification distribution (GBD 2019) (%) (%) Sewer connection and safe Class I 1.00 Sewer connection or septic tank 30.0 76.9 disposal of excreta Class II 2.71 Other improved sanitation 54.6 Other improved sanitation 7.7 Class II 3.23 Unimproved sanitation 15.4 Unimproved sanitation 15.4 Source: World Bank based on Bangladesh MICS 2019 (BBS/UNICEF 2019) and GBD Risk Factor Collaborators (2020) Supplement 1. Handwashing with soap and water is effective in reducing diarrheal disease (Cairncross et al. 2010). The GBD 2019 reports the relative risk of diarrheal disease and mortality from households not having access to a handwashing station with available soap and water, and the Bangladesh MICS 2019 reports that 25 percent of the population do not have access to such a station on household premises (table F.3). Table F.3 Handwashing with soap and relative risk of diarrheal disease in Bangladesh, 2019 RR Population (GBD 2019) distribution Access to a handwashing station with available soap and water 1.00 74.8 No access to a handwashing station with available soap and water 1.52 25.2 Source: World Bank based on Bangladesh MICS 2019 (BBS/UNICEF 2019) and GBD Risk Factor Collaborators (2020) Supplement. The attributable fraction (AF) of diarrheal disease and mortality is calculated as follows: (F.1) Where Pi with i=1,…,n) is the population distribution and RRi is the corresponding relative risk in tables F.1–3. The estimated AFs of diarrheal disease and mortality are presented in table F.4. The largest AF is from inadequate drinking water, followed by sanitation. The joint attributable fraction of diarrheal disease and mortality from inadequate drinking water, sanita- tion, and handwashing is in the range of 72–95 percent. The joint AF is calculated by as in Prüss-Üstün et al. (2014), where k refers to drinking water, sanitation, and handwashing. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 227 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene Table F.4 Estimated attributable fractions of diarrheal disease from inadequate WASH in Bangladesh, 2019 | % of baseline disease Based on GBD 2019 Based on alternative classifications classification Inadequate drinking water 88.0 54.1 Inadequate sanitation 53.3 31.2 Inadequate handwashing with soap 11.6 11.6 Inadequate drinking water, sanitation, and hand hygiene 95.0 72.1 Source: World Bank. The GBD 2019 also provides a relative risk (RR = 1.32) of acute lower respiratory infections (ALRI) from inadequate handwashing. Based on population distribution in table F.3, the AF of ALRI from lack of handwashing station with soap and water at premises is 7.5 percent. The disease burden (B) in terms of annual cases of diarrheal disease and mortality due to inadequate drinking water, sanitation, and hygiene is estimated by: (F.2) where Dl is the total annual baseline number of cases of diarrheal disease and mortality and ALRI morbidity and mortality. Dl for Bangladesh is taken from the GBD 2019 (see www.healthdata.org). F.2 Indirect effects Estimating the indirect mortality effects of diarrhea from inadequate WASH is here undertaken in two stages. First, the fraction of under-five child mortality attributable to child underweight is estimated. This follows the methodology in Olofin et al. (2013). Second, a fraction of under-five child mortality from underweight is attributed to diarrheal infections and inadequate WASH using the approach in Fewtrell et al. (2007). An alternative approach to estimating the fraction of mortality attributable to diarrheal infections is the methodology developed in Larsen (2007) and World Bank (2008). However, this requires estimation of counterfactual prevalence rates of child under- weight (prevalence of underweight in the absence of diarrheal infections) from original survey data of child nutritional status. The approach in Fewtrell et al. gives a somewhat lower estimate of indirect mortality from inadequate WASH than the Larsen and World Bank methodology. Estimates of increased risk of cause-specific mortality in children under five years of age with mild, moderate, and severe under- weight are presented in table F.5 based on Olofin et al. (2013). Table F.5 Relative risk of mortality from underweight in children under five years of age Severe Moderate Mild None Acute lower respiratory infections (ALRI) 10.10 3.11 1.85 1.00 Diarrhea 11.56 2.86 1.73 1.00 Measles 7.73 3.12 1.00 1.00 Malaria 1.29 1.65 1.26 1.00 Other infectious diseases 8.28 1.58 1.54 1.00 Source: Olofin et al. 2013. Note: Relative risks are in relation to severe, moderate, and mild underweight according to the WHO Child Growth Standards. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 228 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene These relative risk ratios are applied to prevalence rates of child underweight to estimate attributable fractions (AFj) of mortality by cause, j, from child underweight as follows: (F.3) where RRji is relative risk of mortality from cause, j, for children in each of the underweight categories, i, in table 2E.5; and Pi is the underweight prevalence rate. Prevalence rates of child underweight are from the Bangladesh MICS 2019. Annual cases (M) of mortality from child underweight (by cause, “j”, in table F.5) are estimated as follows: (F.4) where Dj is the total annual baseline number of cases of mortality from cause “j” among children under five. Dj for Bangladesh is taken from the GBD 2019 (see www.healthdata.org). Annual under-five child mortality from inadequate drinking water, sanitation, and hygiene (W) is then estimated as follows: (F.5) where γj is the fraction of child underweight mortality (Mj) attributed to inadequate drinking water, sanitation, and hygiene through diarrheal infections in early childhood. WHO (Fewtrell et al. 2007) uses γj = 0.5 for ALRI, measles, malaria, and “other infectious diseases.” This is here adjusted by the fraction of diarrheal disease attributed to inadequate drinking water, sanitation, and hygiene in table F.4. “Other infectious diseases” are here limited to meningitis. References BBS (Bangladesh Bureau of Statistics) / UNICEF (United Nations Children’s Fund). 2019. Progotir Pathey: Bangladesh Multiple Indicator Cluster Survey 2019. Survey Findings Report. Dhaka, Bangladesh: BBS and UNICEF Bangladesh. Black, R., L. Allen, Z. Bhutta, L. E. Caulfield, M. de Onis, M. Ezzati, C. Mathers, and J. Rivera. 2008. “Maternal and Child Undernutrition: Global and Regional Exposures and Health Consequences.” Lancet 371: 243–60. Cairncross, S., C. Hunt, S. Boisson, K. Bostoen, V. Curtis, I. C. H. Fung, and W.-P. Schmidt. 2010. “Water, Sanitation and Hygiene for Preventing Diarrhoea.” Int J Epidemiology 39: i193–i205. Fewtrell, L., A. Prüss-Üstün, R. Bos, F. Gore, and J. Bartram. 2007. “Water, Sanitation and Hygiene: Quantifying the Health Impact at National and Local Levels in Countries with Incomplete Water Supply and Sanitation Coverage.” Environmental Burden of Disease 15. Geneva, Switzerland: World Health Organization. Fishman, M. S., L. E. Caulfield, M. De Onis, M. Blossner, A. A. Hyder, L. Mullany, and R. E. Black. 2004. Childhood and Maternal Underweight. In Comparative Quantification of Health Risks—Global and Regional Burden of Disease Attributable to Selected Major Risk Factors – Vol. 1, edited by M. Ezzati, A. D. Lopez, A. Rodgers, and C. J. L. Murray. Geneva, Switzerland: World Health Organization. GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. GBD (Global Burden of Disease) 2019 Risk Factors Collaborators. Supplement 1. 2020. “Global Burden of 87 Risk Factors in 204 Countries and Territories, 1990–2019: A Systematic Analysis for the Global Burden of Disease Study 2019.” Lancet 396: 1223–49. Larsen, B. 2007. Cost of Environmental Health Risk in Children under Five Years of Age: Accounting for Malnutrition in Ghana and Pakistan. Background report prepared for the World Bank. Environment Department. Washington, DC: World Bank. Olofin, I., C. M. McDonald, M. Ezzati, S. Flaxman, R. Black, W. Fawzi, L. Caulfield, and G. Danaei. 2013. “Associations of Suboptimal Growth with All-Cause and Cause- Specific Mortality in Children under Five Years: A Pooled Analysis of Ten Prospective Studies.” PLoS ONE 8: e64636. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 229 Appendix F. Health Effects of Inadequate Water, Sanitation, and Hygiene Prüss-Üstün, A., J. Bartram, T. Clasen, J. Colford, O. Cumming, V. Curtis, S. Bonjour, A. Dangour, J. De France, L. Fewtrell, M. Freeman, B. Gordon, P. Hunter, R. Johnston, C. Mathers, D. Mausezahl, K. Medlicott, M. Neira, M. Stocks, J. Wolf, and S. Cairncross. 2014. “Burden of Disease from Inadequate Water, Sanitation and Hygiene in Low- and Middle-Income Settings: A Retrospective Analysis of Data from 145 Countries.” Trop Med Int Health 19: 894–905. Rabie, T., and V. Curtis. 2006. “Handwashing and Risk of Respiratory Infections: A Quantitative Systematic Review.” Trop Med Int Health 11 (3): 258–67. Wolf, J., A. Prüss-Üstün, O. Cumming, J. Bartram, S. Bonjour, S. Cairncross, T. Clasen, J. M. Colford Jr, V. Curtis, J. De France, L. Fewtrell, M. C. Freeman, B. Gordon, P. R. Hunter, A. Jeandron, R. B. Johnston, D. Mäusezahl, C. Mathers, M. Neira, and J. P. T. Higgins. 2014. “Assessing the Impact of Drinking Water and Sanitation on Diarrheal Disease in Low- and Middle-Income Settings: Systematic Review and Meta-regression.” Tropical Medicine and International Health 19: 928–42. Wolf, J., P. Hunter, M. Freeman, and O. Cumming. 2018. “Impact of Drinking Water, Sanitation and Handwashing with Soap on Childhood Diarrhoeal Disease: Updated Meta-analysis and Meta-regression.” Tropical Medicine and International Health 23 (5): 508–25. World Bank. 2018. Enhancing Opportunities for Clean and Resilient Growth in Urban Bangladesh. Country Environmental Analysis 2018. Washington DC: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 230 Appendix G. Valuation of IQ Losses Appendix G. Valuation of IQ Losses An individual’s IQ has an effect on lifetime income. This has long been established by, for instance, Schwartz (1994) and Salkever (1995). The first study estimates that a loss of one IQ point is associated with a 1.76 percent decline in lifetime income. A little over one-quarter is the direct effect on earnings while nearly three-quarters is the indirect effect through reduced schooling, and through reduced labor force participation. The second study estimates that a loss of one IQ point reduces male and female lifetime income by 1.9 and 3.3 percent, respectively, including the effect on labor force participation. Johnson and Neal (1998) estimated an overall direct and indirect income effect of about 2.8 percent per IQ point with a much larger effect for females than for males as also found by Salkever (1995). The estimate does not include labor force participation effect. Zax and Rees (2002) found a much smaller direct and indirect effect of 0.39–1.39 percent per IQ point for white males. Salkever (2014) argues, however, that this size effect is not representative as the study does not include females and minority groups for which size effects are found to be much larger by Salkever (1995) and Johnson and Neal (1998). The size of the effect of IQ on lifetime income continues to be debated. Grosse (2014) argues that the effect is smaller than found by Salkever (1995) while Salkever (2014a,b) defends the estimates on the basis that other studies often omit females and minorities and do not include the effect on labor force participation. Attina and Trasande (2013) applied a lifetime income effect of 2 percent per IQ point for their estimate of the cost of lead expo- sure in children in LMICs. Most recently Grosse and Zhou (2021) applied an effect of 1.4 percent per IQ point as a conservative estimate based on a review of the literature that includes recent studies by Lin, Lutter, and Ruhm (2018) and Lundborg, Nystedt, and Rooth (2014). USEPA (2020) undertook a reanalysis of Salkever (1995) using a more recent version of the data set used by Salkever. The reanalysis found a lifetime income effect per IQ point of 1.86 percent for males (slightly below Salkever (1995)) and 3.4 percent for females (somewhat above Salkever (1995)). In this report an effect of 2.0 percent decline in lifetime income per lost IQ point is applied to all children eventually participating in the labor force. This is slightly above the value used by Grosse and Zhou (2021) but substantially below the value in Johnson and Neal (1998), Salkever (1995), and USEPA (2020). Lifetime income for a person that is or will be in the labor force is calculated as follows: (G.1) where PV0 (I) is the present value in year 2019 of lifetime income, I0 is annual income in year 2019, g is annual growth in real in- come, and r is the discount rate of future income. The equation allows for income to start from year k and end in year n. Present value of lifetime income is calculated for a child at the age of 2.5 years—that is, at the midpoint of 0–5 years during which IQ losses are assumed. Therefore, k is the age of entering the labor force less 2.5 years, and n is the age of retirement less 2.5 years. A person’s annual income in year 2019 is calculated as follows: (G.2) where GDP is the country’s total GDP, L is total labor force, and s is labor compensation share of GDP in 2019. S is from PENN World Table, Version 10. Annual cost of IQ losses is then: (G.3) where α is the effect of IQ on lifetime income (2.0 percent per IQ point), PV0(I) is the present value of lifetime income in 2019, p is the probability of future labor force participation (LFP), and ΔQT is a country’s total annual IQ points lost in 2019 due to lead exposure. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 231 Appendix G. Valuation of IQ Losses The parameter values for equations F.1–3 are presented in table G.1. Long-term future per capita income growth is set at 2.5 per- cent per year. The discount rate of future income is set at twice the per capita income growth rate as proposed by the World Bank for project economic analysis (World Bank 2016). The probability of future LFP is set at the LFP rate in 2019 reported by the World Bank (2023). Table G.1 Parameters for estimation of the cost of IQ losses Parameter Bangladesh Effect of lifetime income per IQ point α 2.0% Long-term future income growth per year g 2.5% Rate of discounting of future income r 5.0% Future labor force participation rate p 62% (current rate) Labor force participation (age) 18–65 years Source: World Bank. Note: Parameters are from equations G.1 and G.3. References Attina, T., and L. Trasande. 2013. “Economic Costs of Childhood Lead Exposure in Low- and Middle-Income Countries.” Environmental Health Perspectives 121 (9): 1097–102. Grosse, S. D. 2014. “Response to Salkever: More Information Needed to Estimate the Effect of Childhood IQ on Adult Earnings.” Association of Environmental and Resource Economists (AERE) Newsletter 34 (2): 29–34. Grosse, S. D., and Y. Zhou. 2021. “Monetary Valuation of Children’s Cognitive Outcomes in Economic Evaluations from a Societal Perspective: A Review.” Children 8: 352. https://doi.org/10.3390/children8050352 Johnson, W. R., and D. Neal. 1998. “Basic Skills and the Black–White Earnings Gap.” In The Black–White Test Score Gap, edited by C. Jencks and M. Phillips. Washington, DC: Brookings Institution Press Lin, D., R. Lutter, and C. J. Ruhm. 2018. “Cognitive Performance and Labour Market Outcomes.” Labour Econ 51: 121–35. Lundborg, P., P. Nystedt, and D. O. Rooth. 2014. “Height and Earnings: The Role of Cognitive and Noncognitive Skills.” J Hum Resour 49: 141–66. Salkever, D. S. 1995. “Updated Estimates of Earnings Benefits from Reduced Exposure of Children to Environmental Lead.” Environmental Research 70: 1–6. Salkever, D. S. 2014. “Assessing the IQ-earnings Link in Environmental Lead Impacts on Children: Have Hazard Effects Been Overstated?” Environmental Research 131: 219–30. Schwartz, J. 1994. “Societal Benefits of Reducing Lead Exposure.” Environmental Research 66: 105–12. USEPA (US Environmental Protection Agency). 2020. “Economic Analysis of the Final Rule to Revise the TSCA Dust-Lead Post-Abatement Clearance Levels.” Office of Pollution Prevention and Toxics. Washington, DC: USEPA. World Bank. 2016. Discounting Costs and Benefits in Economic Analysis of World Bank Projects. OPSPQ. May 2016. Washington, DC: World Bank. World Bank. 2023. World Development Indicators. Washington DC: World Bank. Zax, J. S., and D. I. Rees. 2002. “IQ, Academic Performance, Environment, and Earnings.” Rev Econ Stat 84: 600–16. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 232 Appendix H. Valuation of Illness Appendix H. Valuation of Illness Two valuation techniques are commonly used to estimate the cost of morbidity or illness. The cost-of-illness (COI) approach in- cludes the cost of medical treatment and value of income and time lost to illness. The second approach equates cost of illness to individuals’ WTP for avoiding an episode of illness. Studies in many countries have found that individuals’ WTP to avoid an ep- isode of illness is generally much higher than the cost of treatment and value of income and time losses (Alberini and Krupnick 2000; Cropper and Oates 1992; Dickie and Gerking 2002; Wilson 2003). In most studies of the health effects and cost of air pollution it is estimated that cost of mortality represents 70 to 90 percent of total cost and cost of morbidity or illness represents 10 to 30 percent. It is therefore more important to reach a consensus on valuation of mortality risk than on incidence of morbidity. For infectious diseases from inadequate drinking water, sanitation, and hygiene, the cost of morbidity can be quite a substantial share, especially in countries with low fatality rates (but high nonfatal incidence rates) of these infectious diseases. Estimating the cost morbidity often requires much more and less accessible baseline health and cost data than estimating the cost of mortality. One option is therefore to use the estimates of “years lived with disability” (YLD) for the relevant illnesses in Bangladesh from the GBD studies. YLD can then be converted to days lived with disease by applying the disability weights in the GBD studies. The cost of days lived with disease can then be estimated. The approach applied in this report involves the following steps: 1. Estimates of YLDs are converted to days lived with disease by applying the disability weights in the GBD 2019 for Bangladesh (tables H.1–3). 2. The cost of a day lived with disease is then approximated as a fraction of the average daily wage rate to reflect income losses from illness, health expenditure, time losses and the welfare cost of pain and suffering. 3. The cost of a day of illness is also applied to individuals without income because illness prevents most of these individuals from undertaking household work and other activities with a social value, as well as involves all the non-income impacts of illness. The cost of morbidity is thus estimated as follows. First, days lived with disease (M) are calculated as: (H.1) where YLDi is years lived with disability from disease, i, and di is the disability weight for disease, i. The disability weight for each disease is calculated from the GBD 2019 for Bangladesh. Disability weight is a measure used in GBD to calculate YLDs from days lived with illness, disease, or injury. The disability weights for the diseases associated with ambient and household PM2.5 air pollution exposure; adult lead exposure; and inadequate drinking water, sanitation, and hygiene in Bangladesh are presented in tables H.1–3. The weighted average disability weight for diseases associated with arsenic exposure is 0.056 based on disability weights for twelve noncommunicable disease categories. Table H.1 Disability weights for Bangladesh for diseases associated with PM2.5 exposure Disability weights IHD 0.017 Stroke 0.152 COPD 0.110 Lung cancer 0.231 ALRI 0.060 Type 2 diabetes 0.081 BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 233 Appendix H. Valuation of Illness Disability weights Neonatal disorders 0.209 Cataract a 0.073 Source: Disability weights for Bangladesh are calculated from GBD 2019 data at http://www.healthdata.org/ Note: a Morbidity health effect of household air pollution. Table H.2 Disability weight for Bangladesh for cardiovascular diseases associated with adult Pb exposure Disability weight Cardiovascular disease 0.054 Source: Disability weights for Bangladesh are calculated from GBD 2019 data at http://www.healthdata.org/ Table H.3 Disability weights for Bangladesh for diseases associated with inadequate drinking water, sanitation, and hygiene Disability weights Diarrheal disease 0.112 Typhoid/paratyphoid 0.167 ALRI 0.060 Source: Disability weights for Bangladesh are calculated from GBD 2019 data at http://www.healthdata.org/ Second, the cost (c) of a day lived with disease, i, is thus a fraction of the daily wage rate, with the fraction proportional to the severity of disease: (H.2) where w is average daily wage rate and di disability weight for disease, i, and D is a disability weight that corresponds to a severity of disease for which the cost of a disease day is assumed equal to the average wage rate. D is here set at 0.4. This is a disability weight associated with severely restricted work and leisure activity from disease and substantial medical cost—for example, se- vere COPD (d = 0.41), distance vision blindness (d = 0.19) and Stage V chronic kidney disease (d = 0.57) due to diabetes, and stroke with severity level 3 (d = 0.32) and 4 (d = 0.55). Third, cost of morbidity (C) is calculated as follows: (H.3) Average daily wage rate is estimated as follows: (H.4) where GDP is the country’s total GDP, L is total labor force, s is labor compensation share of GDP, and annual working days is averaging 250. S = 0.52 is applied to Bangladesh, using the value for India from PENN World Table, Version 10. Average wage rates are also used in the cost-benefit analyses of interventions, using projected wage rates for the year 2026 as a midpoint of the time horizon of the analyses till 2030 (table H.4). BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 234 Appendix H. Valuation of Illness Table H.4 Projected GDP per capita and wage rates, 2019–26 2019 2026 GDP per capita (constant 2019 Tk) 178,280 235,565 Labor force (% of population) 42% 42% Labor income share of GDP 52% 52% Rural population share 62.6% 57.2% Wage rate, daily (constant 2019 Tk) 832 1,100 Rural wage rate, daily (constant 2019 Tk) 606 770 Female rural wage rate, daily (constant 2019 Tk) 484 616 Wage rate, hourly (constant 2019 Tk) 104 137 Rural wage rate, hourly (constant 2019 Tk) 76 96 Female rural wage rate, hourly (constant 2019 Tk) 61 77 Sources: GDP per capita in 2019 is from BBS (2022), labor force and rural population share in 2019 are from World Bank (2023). The remaining figures are World Bank estimates. References Alberini, A., and A. Krupnick. 2000. “Cost-of-Illness and Willingness-to-Pay Estimates of the Benefits of Improved Air Quality: Evidence from Taiwan.” Land Economics 76: 37–53. BBS (Bangladesh Bureau of Statistics). 2022. Statistical Yearbook Bangladesh 2021. Dhaka, Bangladesh: BBS. Cropper, M., and W. Oates. 1992. “Environmental Economics: A Survey.” Journal of Economic Literature 30: 675–740. Dickie, M., and S. Gerking. 2002. “Willingness to Pay for Reduced Morbidity.” Paper presented at “Economic Valuation of Health for Environmental Policy: Assessing Alternative Approaches,” Orlando, FL, March 18–19. Wilson, C. 2003. “Empirical Evidence Showing the Relationships between Three Approaches for Pollution Control.” Environmental and Resource Economics 24: 97–101. World Bank. 2023. World Development Indicators. Washington DC: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 235 Appendix I. Valuation of Mortality Appendix I. Valuation of Mortality The predominant measure of the social cost of premature death used by economists is the value of statistical life (VSL). VSL is based on valuation of mortality risk. Everyone in society is constantly facing a certain risk of dying. Examples of such risks are occupational fatality risk, risk of traffic accident fatality, and environmental mortality risks. It has been observed that individuals adjust their behavior and decisions in relation to such risks. For instance, individuals demand a higher wage (a wage premium) for a job that involves a higher occupational risk of fatal accident than in other jobs, individuals may purchase safety equipment to reduce the risk of death, and/or individuals and families may be willing to pay a premium or higher rent for properties (land and buildings) in a cleaner and less polluted neighborhood or city. Through the observation of individuals’ choices and willingness to pay for reducing mortality risk (or minimum amounts that individuals require to accept a higher mortality risk), it is possible to estimate the value to society of reducing mortality risk, or, equivalently, measure the social cost of a particular mortality risk. For instance, it may be observed that a certain health hazard has a mortality risk of 2.5/10,000. This means that, on average, one individual dies from this hazard for every 4,000 individuals exposed. If each individual on average is willing to pay $40 for eliminating this mortality risk, then every 4,000 individuals are collectively willing to pay $160,000. This is the VSL, or the value that individuals collectively are willing to pay to avoid one death. Mathematically it can be expressed as follows: (I.1) where WTPAve is the average willingness-to-pay per individual for a mortality risk reduction of magnitude R. In the illustration above, R = 2.5/10 000 (or R = 0.00025) and WTPAve = $40. Thus, if 10 individuals die from the health risk illustrated above, the cost to society is 10* VSL = 10* $0.16 million = $1.6 million. The main approaches to estimating VSL are through revealed preferences and stated preferences of people’s WTP for a reduction in mortality risk or their willingness-to-accept (WTA) an increase in mortality risk. Most of the studies of revealed preferences are hedonic wage studies, which estimate labor market wage differentials associated with differences in occupational mortality risk. Most of the stated-preference studies rely on contingent valuation methods (CVM), which in various forms ask individuals about their WTP for mortality risk reduction. Studies of WTP for a reduction in risk of mortality have been carried out in numerous countries. A commonly used approach to estimate VSL in a specific country is therefore to use a benefit transfer (BT) based on meta-analyses of WTP studies from other countries. Many meta-analyses have been conducted in the last two decades. Meta-analyses assess characteristics that deter- mine VSL, such as household income, size of risk reduction, other individual and household characteristics, and often character- istics of the methodologies used in the original WTP studies. Most of the meta-analyses of VSL are entirely or predominantly based on hedonic wage studies. However, a meta-analysis pre- pared for the OECD was based exclusively on stated-preference studies, arguably of greater relevance for valuation of mortality risk from environmental factors than hedonic wage studies (Lindhjem et al. 2011; Navrud and Lindhjem 2010; OECD 2012). These stated-preference studies are from a database of more than 1,000 VSL estimates from multiple studies in over 30 countries, in- cluding in developing countries (www.oecd.org/env/policies/VSL). The World Bank (2016) presents a benefit transfer methodology for valuing mortality from environmental health risks, drawing on the empirical literature of VSL, especially OECD (2012). The methodology is applied in the recent publication by the World Bank and IHME (2016) on the global cost of air pollution. The proposed benefit transfer function is: (I.2) where VSLc,n is the estimated VSL for country c in year n, VSLOECD is the average base VSL in the sample of OECD countries with VSL studies ($3.83 million), Yc,n is GDP per capita in country c in year n, and YOECD is the average GDP per capita for the sample of OECD countries ($37,000), and ɛ an income elasticity of 1.2 for low- and middle-income countries and 0.8 for high income countries. All values are in purchasing power parity (PPP) prices. Therefore, VSLc,n must be converted to local currency using BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 236 Appendix I. Valuation of Mortality PPP exchange rates, available in World Bank (2023). This approach provides a VSL for Bangladesh in the amount of Tk 12.7 million in 2019. The VSL is calculated based on a GDP per capita of Tk 178,280 in 2019 (BBS 2022). VSL increases to Tk 17.7 million in 2026 with rising GDP per capita. The VSL/GDP ratio in- creases from 71 times GDP per capita in 2019 to 75 in 2026 (table I.1). This increase is due to the income elasticity of 1.2. Table I.1 Value of statistical life (VSL) in Bangladesh, 2019–16 2019 2026 GDP per capita (constant 2019 Tk) 178,280 235,565 GDP per capita, PPP (constant 2019 international $) 5,698 7,529 VSL (constant 2019 international $) 405,713 566,798 VSL (constant 2019 Tk) 12,694,133 17,734,234 VSL/GDP per capita ratio 71 75 Sources: GDP per capita in 2019 are from BBS (2022) and GDP per capita, PPP, is from World Bank (2023). Remaining figures are World Bank estimates. References BBS (Bangladesh Bureau of Statistics). 2022. Statistical Yearbook Bangladesh 2021. Dhaka, Bangladesh: BBS. Lindhjem, H., S. Narvud, N. A. Braathen, and V. Biausque. 2011. “Valuing Mortality Risk Reductions from Environmental, Transport, and Health Policies: A Global Meta-Analysis of Stated Preference Studies.” Risk Analysis 31 (9): 1381–407. Navrud, S., and H. Lindhjem. 2010. “Meta-Analysis of Stated Preference VSL Studies: Further Model Sensitivity and Benefit Transfer Issues.” Prepared for the Environment Directorate. Paris, France: OECD. OECD (Organisation for Economic Co-operation and Development). 2012. “Mortality Risk Valuation in Environment, Health, and Transport Policies.” Paris, France: OECD. World Bank. 2016. Methodology for Valuing the Health Impacts of Air Pollution: Discussion of Challenges and Proposed Solutions. Prepared by N. Urvashi and C. Sall. Washington DC: World Bank. World Bank. 2023. World Development Indicators. Washington DC: World Bank. World Bank and IHME (Institute for Health Metrics and Evaluation). 2016. The Cost of Air Pollution: Strengthening the Economic Case for Action. Washington, DC: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 237 Appendix J. Adjusting Mortality Estimates for Multiple Risk Factors Appendix J. Adjusting Mortality Estimates for Multiple Risk Factors Several of the environmental risk factors assessed in this report cause an increase in the same disease among the same popu- lation. This is the case for ALRI associated with ambient air pollution (AAP), household air pollution (HAP), and water, sanitation, and hygiene (WASH); for cardiovascular disease associated with AAP, HAP, lead (Pb), and arsenic (As); and for COPD, lung cancer, and type 2 diabetes for AAP and HAP (table J.1). Table J.1 Disease-specific mortality caused by environmental risk factors Disease-specific mortality Environmental risk factors ALRI AAP, HAP, and WASH Cardiovascular disease AAP, HAP, Pb, Arsenic COPD, lung cancer, and type 2 diabetes AAP, HAP Source: World Bank. When more than one of the environmental risk factors cause the same disease, then the total disease burden from these risk fac- tors is overestimated if simply added up by risk factor. To avoid this double-counting the joint attributable fraction (AFT) formula for n risk factors is applied to estimate total mortality from the specific disease (i): (J.1) This formula is applied to estimate total disease and mortality from the environmental risk factors assessed in this report. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 238 Appendix K. Organogram of Bangladesh Department of Environment Appendix K. Organogram of Bangladesh Department of Environment Source: DoE 2023. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 239 Appendix L. Need for Regular and Reliable Production of Environmental Data and Statistics Appendix L. Need for Regular and Reliable Production of Environmental Data and Statistics For the GoB to prioritize policies and to achieve a green, resilient, and inclusive development (GRID) pathway, better environ- mental data and statistics are required. This includes environmental pollution monitoring data (for example, ambient air and water quality, solid and water-related waste, hazardous waste, emissions from industries, and so forth), disaggregated biophysical data on ecosystems, data on ecosystem services, and socioeconomic data on the impact of the environment on the local econ- omies and livelihoods, among others. Better environmental data and statistics will contribute to the target monitoring of GoB’s 8FYP, allowing for the incorporation of criteria to prioritize and monitor green growth interventions and embed GRID principles in budget planning. Furthermore, such data would enhance polluters’ accountability and improve compliance and enforcement of environmental management. The GoB has already taken steps to improve the availability, quality, and reliability of its environmental statistics. In 2016, the BBS embarked upon an ambitious process to improve environmental statistics and developed the BESF 2016–2030, which aligns with the Statistical Act 2013, the National Strategy for the Development of Statistics, and other relevant policies. The BESF was developed as a strategic action plan for GoB to move towards an integrated approach to collecting, analyzing, and dissem- inating environmental data and information based on national priorities and future plans, including achieving Bangladesh’s green growth potential. Despite these efforts, the GoB faces several limitations and challenges in its successful implementation of the BESF, resulting in weak disclosure and accessibility of timely environmental data. Specific challenges include (a) lack of inter-ministerial and inter-agency coordination; (b) lack of a common format and platform for collecting, organizing and sharing environmental data; (c) absence of proper mechanisms to ensure the quality of data provided by respective responsible government agencies; (d) insufficient financial resources and inefficient methods for data collection, compilation, processing, and dissemination of envi- ronmental data; (e) absence of designated focal point officers in respective data providing government agencies; (f) shortage of skilled human resource capacity, (g) overly ambitious goals for data production that lack prioritization, among others. There is a strong need to improve the capacity of BBS and relevant data-producing government departments to ensure the sustainable production of timely and quality environmental statistics. To operationalize the Bangladesh Environmental Statistics Framework (BESF) , the GoB needs to (a) improve and/or newly develop mechanisms for inter-agency coordination for the generation, management and sharing of environmental data and statistics; (b) boost human resource capacity of BBS and relevant government ministries and departments, including introducing quality control measures and regular training; (c) intro- duce innovative technology and data ICT infrastructure for the efficient production, management and public sharing of environ- mental data and statistics (for example, apps to display real-time automated pollution data, drone technology for monitoring mangrove health, and so forth); (d) invest in strengthening the coverage and quality of environmental and natural capital data and statistics with the specific goal of prioritizing for, tracking the progress of, and streamlining green growth policies; and (e) take a phased approached to data production, starting with the most polluted hotspots and GoB priorities on environmental conser- vation and sustainable natural resource management. The GoB may also consider the monitoring and reporting of area-based (for example, for airshed, water basin, ecosystems, and so forth) environmental quality data as a legally binding requirement. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 240 Appendix M. Bangladesh Environmental Sustainability and Transformation Project Appendix M. Bangladesh Environmental Sustainability and Transformation Project The BEST project aims to strengthen the capacity of the GoB in environmental management and to pilot new financing mech- anisms to promote green investments in targeted sectors. The project is co-financed by the World Bank ($250 million) and the Agence Française de Développement (EUR 40 million) and is planned to be implemented in five years. Component 1 on Environmental Governance and Infrastructure will support the DoE to (a) develop regulations and policies to expand the regulatory mandate of the DoE from controlling individual pollution sources to protecting and improving environ- mental quality and promoting green growth, (b) continue decentralization and improve specialization of the DoE with increased human and financial resources, (c) create and capitalize an Environment Fund, (d) enhance institutional capacity and environ- mental infrastructure for DoE and its key stakeholders on environmental management, including through improved air and water quality monitoring, laboratories, information systems, training and awareness campaigns. Component 2 on Green Financing for Air Pollution Control will support BB to pilot a green credit guarantee facility to incentivize the financial sector to support green investments to reduce pollution directly or indirectly from the brick kiln sector, municipal waste management, clean cookstove (biogas), and rooftop solar systems. This component will help BB to further develop the country’s green financing ecosystem to mitigate or remove regulatory, technological, financial, technical capacity, and market barriers that have prevented the polluting private sector from investing in green technologies and achieving environmental compliance. BB will organize training and technical promotional events to solicit investment demands from all participating financial institutions (PFIs) and the targeted sub-borrowers. The BB will also select technical institutes, individual experts, or both during project implementation to support PFIs and target- ed sub-borrowers on technical, environmental (including climate), health, safety, social, and gender issues of their investments. Furthermore, this subcomponent will support BB in carrying out targeted awareness-raising events to persuade consumers to reduce their demand for products from traditional technologies and increase their demand for green products. It is expected that the informed public and consumers will eventually exert public and market pressure for the targeted sectors to adopt green technologies and improve their environmental performance in a changing environment. Coordination with IFC is ongoing to promote good environment, social, and governance practices among participating financial institutions. Component 3 on vehicle-inspection control will support BRTA to pilot public-private partnership modalities to develop and operate vehicle inspection centers (VICs) regulating vehicle emissions effectively—a key and growing source of air pollution—in Bangladesh. This component will finance (a) the construction of four new VICs and the operation of these centers through pub- lic-private partnerships, and (b) technical assistance to improve BRTA’s capacity in vehicle inspection. Successful implementation of this component will help BRTA develop a national vehicle inspection program with additional VICs beyond the project and gradually remove unsafe and high GHG and pollution emission vehicles from its roads. Component 4 will support Bangladesh in piloting an effective public-private partnership model to attract private investments in e-waste management infrastructure. This component will support (a) the development of a pilot e-waste management in- frastructure through design-build-finance-operate arrangements to demonstrate technical, financial, environmental, and social feasibility of e-waste management and (b) technical assistance for proper operations of the new facility by promoting EPR schemes, formalizing value chains, and implementing related regulatory requirements. Successful piloting of this model will support its adoption in the development of other types of environmental infrastructure. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 241 Appendix N. Estimation of Health Benefits of Interventions Appendix N. Estimation of Health Benefits of Interventions The potential impact fraction (PIF) formula is applied to estimate the disease burden expected to be avoided by an intervention: (N.1) where Pi is the pre-intervention population distribution in relation to level of health-risk exposure, RRi, and Pi’ is the post-interven- tion population distribution in relation to RRi. The avoided disease burden or health benefit (B) of interventions is then: (N.2) where B is annual cases of mortality and morbidity prevented, BDB is the baseline disease burden or annual cases of mortality and morbidity in Bangladesh. However, interventions are unlikely to instantaneously provide full health benefits for health outcomes that develop over long periods of exposure to pollution. This is the case for heart disease, stroke, chronic obstructive pulmonary disease (COPD), lung cancer, and diabetics associated with long-term PM2.5 exposure, as well as for other noncommunicable diseases (NCDs) associ- ated with long-term arsenic exposure. Therefore, it is assumed that reduced incidence of, and reduced deaths from, NCDs are gradually realized over ten years. However, for acute lower respiratory infections (ALRIs) from PM2.5 exposure and inadequate handwashing, and diarrheal disease from microbiological pollution, full health benefits are realized in the same year that en- vironmental improvements occur. Thus, over a 20-year period, annualized health benefits are 72 percent of full benefits for interventions addressing arsenic in drinking water, and 77 percent for PM2.5 ambient air pollution (AAP) and PM2.5 household air pollution (HAP), using a discount rate of 5 percent. Sanitation and hygiene health benefits are fully realized from the first year of interventions in the case of household drinking water. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 242 Appendix O. Plastic Waste in Riparian Land and Waters of Rivers and Canals around Dhaka City Appendix O. Plastic Waste in Riparian Land and Waters of Rivers and Canals around Dhaka City Source: World Bank 2023a. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 243 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh Appendix P. Green Finance Roadmap for Green Growth in Bangladesh An action plan, comprising a mix of policy choices spanning from institutional to regulatory components, is presented in tables P.1, P.2, and P.3 below. The plan offers guidance to promote the channeling of green finance to projects and activities re- lated to green growth. The proposed actions allow for a gradual transition to a low-carbon and sustainable economy. To advance the financing of green growth in Bangladesh, the plan below identifies 27 priority actions (10 short-term, 11 medium-,term and 6 long-term) that the GoB can implement. These priority actions are listed along with their proposed implementers, beneficiaries, barriers to be addressed, and the extent (if any) to which these actions are already in place. Table P.1 Short-term (1–2 year timeline) actions to facilitate financing of green growth in Bangladesh Does it exist? Who Recommended action Who could implement Barrier addressed Yes/No/ benefits Partially Intervention: Governance framework for green growth Set up system to track inflow of foreign • Ministry of Finance (MoF), Investors • Inadequate in-house Partially resources and publicly disclose use of Bangladesh Bank (BB), Bangla- technical capacity these funds to create trust in the capital desh Investment Development faced by FIs market and to attract sustainable inves- Authority (BIDA), Bangladesh tors. Securities and Exchange Com- mission (BSEC), and others. Set up separate unit to evaluate green • Ministry of Environment, Forest FIs • Inadequate in-house No technologies, products, and services to and Climate Change (MoEFCC) technical capacity provide technical assistance to evaluate to lead, but it will also require faced by FIs. their future potential. the training of experts within • Lack of project pipe- the FIs. line to attract foreign investment in green sectors. Develop and approve the national green • MoEFCC and MoF. Investors • Inadequate expertise No taxonomy (a framework for defining what FIs to evaluate green can be called environmentally sustainable Borrowers technologies and investments). investments. • Lack of project pipe- line to attract foreign investment in green sectors. Intervention: Incentives BB and domestic banks reduce install- • BB to take policy decisions to Borrowers • Stringent require- No ment size and extend grace period to further rationalize loan-repay- ments faced by lessen fiscal burden on entrepreneurs ment tenure, reduce instalment borrowers. seeking green finance loans. size and grace period, and ad- dress other factors applicable to green finance transactions. • Commercial banks and FIs will implement policy decisions. • The above actions will increase banks and FIs’ loan disburse- ments from their current level. Carry out further analysis to determine • MoEFCC with MoF. Borrowers • Low risk appetite. Yes the right mix of fiscal incentives to FIs • Short-term focus. address high-polluting industries, boost Investors green markets, and attract private invest- ments. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 244 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh Does it exist? Who Recommended action Who could implement Barrier addressed Yes/No/ benefits Partially Adopt green guarantee scheme to min- • BB to introduce a credit-guar- FIs • Low risk appetite. Partially imize perceived risk to FIs (this is a cred- antee scheme dedicated to Borrowers • Short-term focus. it-guarantee program to lessen lenders’ green finance. risks in issuing green loans). • Stringent require- ments faced by borrowers. Intervention: Capabilities Strengthen Sustainable Finance Units • Banks to implement in their Borrowers • Inadequate in-house Yes (SFUs) with skilled human resources to own offices. technical capacity (a) evaluate green products, projects, faced by FIs. • BB to provide guidance on and technologies more readily; and (b) skills and certifications to be monitor the different phases of imple- required for officials engaged in mentation of projects and activities. These green financing operations. actions will reduce the perception of green-financing risk for banks. Set up banking agents in outreach (re- • BB to take policy decisions to Borrowers • Limited knowledge Partially mote, less accessible, underserved) areas allow FIs to employ agent bank- Investors and capacity to pre- to receive applications from entrepre- ing for receiving loan applica- pare bankable green neurs there to enable entrepreneurs in tions in outreach areas. projects faced by remote and less-accessible areas to access borrowers. green finance. • Lack of project pipe- line to attract foreign investment in green sectors. Establish a dedicated unit to help entre- • Small and Medium Enterprise Borrowers • Limited knowledge No preneurs overcome barriers to accessing (SME) Foundation to set up a and capacity to pre- finance. dedicated unit within its institu- pare bankable green tional structure at its headquar- projects faced by ters and at branches to help borrowers. entrepreneurs have smooth access to green finance. Integrate carbon pricing into GoB’s cli- • GoB to finance some of its en- Government • Lack of interagency No mate strategies. vironmental initiatives through Borrowers coordination. decarbonization projects and • Lack of project pipe- carbon-pricing instruments. line to attract foreign investment in green sectors. Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 245 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh Table P.2 Medium-term (2–3 year timeline) actions to facilitate financing of green growth in Bangladesh Does it Action Who could implement Who benefits Barrier addressed exist? Intervention: Governance framework for green growth Adopt national green growth strategy • MoF and MoEFCC to lead. Government • Lack of interagency No and a national action plan backed by Borrowers coordination. appropriate combination of regulatory FIs and institutional frameworks. Investors Establish a national green finance • MoF, MoEFCC, and Ministry of Government • Lack of interagency No strategy for greening the industrial and Industries (MoI) to lead, but BB, Borrowers coordination. service sectors. BSEC, and BIDA should be key FIs • Lack of project pipeline participants. Investors to attract foreign invest- ment in green sectors. Constitute a high-level national • MoF and MoEFCC to lead. Government • Lack of interagency No oversight body to monitor progress in Borrowers coordination. greening economic growth. FIs • Lax enforcement of Investors laws against environ- mental offenders. Engage local government bodies to • Ministry of Local Government, Borrowers • Lack of interagency No have strong oversight to safeguard Rural Development and coordination. environmental and ecological services Co-operatives with support of at the grassroots in local-level project MoEFCC to lead in formulating development, planning, and imple- policies to safeguard environ- mentation. ment and ecological services at the grassroots. Internalize green accounting system • MoF and MoEFCC to lead in Government • Lack of interagency No and introduce green budgeting with a introducing green budgeting. Borrowers coordination. sound tracking system of resource allo- FIs • Lack of project pipeline cation and expenditure for promoting Investors to attract foreign invest- inclusive green growth. ment in green sectors. Adopt policy and strategy to establish • MoEFCC, Department of Government • Lax enforcement of Partially a system for collecting point-source Environment (DoE), Aspire to FIs laws against environ- data to monitor pollution levels and Innovate (A2I) to lead. Borrowers mental offenders. contribute to the analysis by FIs. Investors • Inadequate in-house technical capacity faced by FIs. • High cost of doing business. Strengthen capacity for monitoring, • MoEFCC, BB, and BSEC to lead FIs • Inadequate in-house Partially reporting, and verification (MRV) to in creating policies and prac- Investors technical capacity enable commercial lending institutions tices that promote monitoring, faced by FIs. and BSEC to streamline the monitoring reporting, and verification. • Lack of project pipeline of green-finance impacts. to attract foreign invest- ment in green sectors. • High cost of doing business. Intervention: Incentives Strengthen capital market to promote • MoF, BB, and BSEC to lead in Borrowers • High capital Partially alternate financing by using innovative enabling a conducive atmo- investment. bonds. sphere for green investment by using green and blue bonds. Intervention: Capabilities BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 246 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh Does it Action Who could implement Who benefits Barrier addressed exist? Introduce information and communi- • BB to institute a robust ICT- FIs • High cost of doing busi- Partially cation technology (ICT)-based central- based setup in its Sustainable Investors ness for FIs. ized system with borrowers’ financial Finance Division. Borrowers • Low risk appetite. information to enable BB and lending • Setup to include a network with agencies to have strong oversight of • Short-term focus. banks and FIs to monitor envi- ESG and green finance impact. • Stringent requirements ronmental-safeguards compli- ance in every stage of project faced by borrowers. implementation including the business-operations phase. Provide training on sustainability and • Bangladesh Civil Service Ad- Government • Inadequate expertise in Partially sustainable financing to civil servants ministration Academy Borrowers government agencies within MoF, Planning Commission, city to evaluate green corporations, and so forth. technologies and investments. Undertake national awareness-build- • Relevant government ministries Consumers • Low demand for green No ing campaign to promote green such as MoI, Ministry of Agricul- Borrowers products. products and services among the ture, MoEFCC, and Ministry of consumers. Information and Broadcasting These actions will contribute to achiev- to direct their subordinate ing a national green growth vision. agencies to pursue a nation- wide campaign. Source: World Bank. BUILDING BACK A GREENER BANGLADESH / COUNTRY ENVIRONMENTAL ANALYSIS 2023 247 Appendix P. Green Finance Roadmap for Green Growth in Bangladesh Table P.3 Long-term (3–5 year timeline) actions to facilitate financing of green growth in Bangladesh Does it Actions Who could implement Who benefits Barrier exist? Intervention: Governance framework for green growth Introduce environmental management • MoI and SME Foundation to lead Borrowers • Lack of capabilities to Partially system (EMS) in SME sector to comply in introducing EMS in small and FIs adopt and implement with international standards. medium industries. Investors green practices and These include the International Organi- technologies. • The new Industrial policy and Ban- zation for Standardization’s (ISO’s) IS0 gladesh export policy recognized • High cost of doing 14000 (set of standards on environmental the importance of motivating business. management) and ISO 9000 (set of stan- SMEs to introduce EMS and follow dards for organizations to ensure they • Inadequate expertise ISO guidelines. comply with regulation). to evaluate green • This will, in the long run, expand technologies and opportunities for Bangladeshi investments. products in international markets. Intervention: Incentives Implement polluters pay principle • National Bureau of Revenue (NBR) Borrowers • Lax enforcement of No through carbon and fossil-fuel taxes, and to lead this action and to execute Consumers laws against environ- emission trading system. polluters pay principle with sup- mental offenders. Tax, in the form of additional tax and port of MoF, MoEFCC. • Low demand for green VATs, goods and services produced by products. polluting industries. Create green fund by using the resourc- • MoEFCC and MoF to lead in Borrowers • Lax enforcement of No es from emission tax, pollution tax, and setting up green fund with clear laws against environ- so forth. objectives for using these resourc- mental offenders. This fund to be leveraged with refinanc- es for green activities. • Low demand for green ing schemes to the advantage of small products. and medium entrepreneurs and to restore degraded natural ecosystems. Introduce cluster financing for shared • BB to introduce cluster financing Borrowers • High capital No technologies or practices adopted scheme on a pilot basis. investment. among related businesses. • Based on the success of the policy • Stringent requirements This will enable entrepreneurs to have decision, this could be scaled up. faced by borrowers. enhanced access to finance. Establish green public procurement to • Central Procurement Technical Borrowers • Low demand for green No boost demand for eco-certified products. Unit (CPTU) under Planning Com- products. mission. Intervention: Capabilities Prepare projects to access the Green Cli- • SME Foundation, Palli Karma-Sa- Borrowers • Lack of capabilities to Partially mate Fund (GCF) for resilience building of hayak Foundation (PKSF), MoF, adopt and implement climate-vulnerable SMEs in coastal areas. DoE, and BB. green practices and technologies. • Limited knowledge and capacity to pre- pare bankable green projects. Source: World Bank.