The ADB conducted a Project Performance Evaluation Report on Khulna-Jessore Drainage Rehabilitation Project (KJDRP). The Coastal Development Project used the very same assessment tools employed by ADB to unmask the real evaluation of the project from the perspective of the Bangladeshi people.

1.1 Perspective

The OED's decision to include Khulna-Jessore Drainage Rehabilitation Project (KJDRP) in its 2007-2009 work-plan constitutes the first victory in the campaign to ensure the approach taken to manage drainage is not repeated in other ADB-funded projects in the region.

The ADB's Operation Evaluation Department (OED) has begun an evaluation of the Khulna-Jessore Drainage Rehabilitation Project in March 2007. Civil society organizations (CSOs) from Bangladesh and international NGOs had been pushing for a review of this project by the ADB for many months given its continuing adverse impacts on communities in the Southwest coastal region and their natural environment.  The OED's decision to include KJDRP in its 2007-2009 work-plan constitutes the first victory in the campaign to ensure the approach taken to manage drainage is not repeated in other ADB-funded projects in the region. This is an important concern given the on-going Southwest Area Integrated Planning and Water Management Project which also focuses on flood management and drainage.

The March visit included visits to the project-affected area, interviews with various stakeholders including the government, and hiring consultants to conduct a survey.  Bangladeshi CSOs, Uttaran, Pani Committee and Coastal Development Partnership (CDP), jointly organized a meeting with the ADB mission to allow CSOs who have monitored and advocated on KJDRP to share their perspectives and experiences regarding project impacts.  The meeting was held on March 24th.   Notwithstanding the meeting, there is still an underlying concern that affected people will find it difficult to provide candid comments for the evaluation. However, local CSOs are continuing their effort to amplify the concerns of project affected people given that the ADB has commenced its evaluation. 

The KJDRP has been highly controversial in Bangladesh.  According to the ADB's Project Completion Report (PCR, 2004), project outputs were satisfactory. This claim is heavily disputed by local and national civil society organizations. They fault the ADB for creating an ecological disaster by funding a project which, on the one hand, inundated several hundred hectares of land and on the other hand, caused rivers to dry up. They believe the project has deprived local people of their livelihood and forced them to live in inhuman conditions.

To conduct the Project Performance Evaluation Report, the operation Evaluation Mission of ADB has developed some working papers, Matrix and methodology.

The CSOs who are involved with KJDRP issues. consider this Evaluation Process as a scope, to unmask ADB's real face and an opportunity to prevent them to take any initiative to lower the standard in the present Safe Guard Policy Update Process.

To do so, Coastal Development Partnership took initiative to consult with the  project affected people and compiled their views on the basis of key questions of the matrix.

In this report  the brief description of the project (KJDRP). The major findings of Project Completion Report, Objectives of Evaluation Mission, their methodology and the people's opinion on the question of matrix are compiled.

1.2 Brief description of the project

The Khulna-Jessore Drainage Rehabilitation Project (the Project) was formulated under the Second Coastal Embankment Rehabilitation Project.2 The Project was appraised in July 1993. The loan negotiation took place in November 1993 and the Asian Development Bank (ADB) approved a loan3 of SDR35.914 million ($50 million equivalent) and a technical assistance (TA) grant4 for the Project. The loan became effective on 4 April 1994. The Project got one extension and closed on 18 March 2003. The Bangladesh

Resident Mission (BRM) took over implementation responsibility of the project from 1 July 2000. The Project closed 38 months later than originally planned. ADB fielded one fact-finding, one appraisal, one inception, nine review, six special project administration, one project specific consultation, and one project completion review mission. The project completion report (PCR) was prepared by ADB's BRM and circulated on 25 October 2004. The PCR rated both the Project and TA successful.

1.3 Objective and Scope of the Project

The principal  objective of the  Project was to  reduce  poverty through  increased agricultural production and creation of on-farm employment in the project area. This was to be achieved by (i) mobilizing beneficiary participation in design, implementation, and subsequent operation and maintenance (O&M) of the project facilities; (ii) rehabilitating the existing drainage infrastructure to reduce congestion and protect the project area from tidal and seasonal flooding; (iii) providing support for the expansion of agricultural extension services that was necessary as flooded lands were returned to productivity; and (iv) improving management of fisheries in polder areas to ensure continuing supply of non-commercial fishes caught  and consumed primarily by the poor. The Project was expected to cover approximately 100,000 hectares of flat, low-lying, alluvial lands with seasonally inundated depressions called "beels," supporting a population of 800,000 inhabitants in the Southwest Bangladesh. The TA provided for the Project was to help social preparation and beneficiary participation in Bangladesh Water Development Board (BWDB) projects by assisting BWDB in developing and implementing appropriate procedures. The TA scope included (i) development  of a  water  management  association (WMA)  plan; (ii) preparation  and implementation of information campaign; (iii) formulation of benefit monitoring and evaluation (BME) indicators, together with periodic impact assessment studies; (iv) formulation of land acquisition, compensation, and resettlement plan; (v) legal framework for the registration of WMAs; and (vi) recommendations of modifications of existing legislation or new legislation to allow registration of WMA as a legal entity.

During implementation, the Project encountered problems with social acceptance of the technical and structural design solutions and, as a result, the Project commissioned a feasibility study for overall drainage plan which was completed in March 1997. The Project finally adopted an apparently beneficiary-preferred TRM approach to alleviate drainage congestion problem.

1.4 Major Findings of the Project Completion Report

A project completion review mission was fielded from 4-29 February 2004.  BRM prepared the PCR in September 2004 and circulated it on 25 October 2004. Overall, the Project was rated as successful. The Project was rated highly relevant given its adherence to ADB's strategic objectives and its emphasis on   supporting greater private sector participation and market efficiency improvements. Likewise, it was assessed as consistent with the Government's development policy of poverty reduction. According to the PCR, beneficiary participation highlighted the relevance of the Project. Project   implementation   was seen   as efficacious   (effective) given   the following: (i) reduction of poverty incidence from 75% at appraisal to 53% at evaluation, (ii) cropping intensity increased by 27%, (iii) creation of 3.5 million person-days of employment per year, and (iv) strengthened institutional capability of the EA and WMOs. The Project was also rated efficient as it reportedly achieved its outputs and purpose such as (i) increased agricultural production; (ii) creation of both on- and off-farm employment; and (iii) the adoption of beneficiary approved, innovative, and cost effective TRM design. The PCR computed the Project's economic internal rate of return to 20.6%. Finally, project sustainability was rated as likely based on (i) sustained mitigation measures for chronic drainage congestion; (ii) perceived growth in agricultural production, employment, and household incomes based on a PCR survey, (iii) development of good management practices by the EA; (iv) demonstrated willingness of beneficiaries in sharing responsibilities and meeting the costs of O&M; and (v) the increased capacity of the WMO and EA in terms of skills, experience, and commitment. The PCR reported that the Project was assessed to have moderate institutional and development impacts and produced no adverse negative environmental externalities. A number of lessons drawn from the Project by the PCR included: (i) the adequate and timely  recognition  of local  wisdom,   knowledge,   practices,   and  experience  of  potential beneficiaries in project design and implementation; (ii) close and functional coordination among the   various   offices   and   similarly,   among   different   service   providers   during   project implementation; (iii) the importance of joint efforts between the EA and WMOs as prerequisites for sustainable O&M and efficient water use; and (iv) the need for effective policy and regulations to support water resource management.

1.5 Issues to be Addressed During Operations Evaluation Mission (OEM)

The proposed Project Performance Evaluation Report (PPER) aims to rate project performance based on assessment of relevance, effectiveness, efficiency, and sustainability of the Project. The issues during project implementation and the concerns raised by various stakeholders and by the in-depth OED review of the PCR require that the PPER be more comprehensive, which in a number of instances go beyond those addressed by the PCR. The OEM will also assess the validity of the concerns and claims expressed by NGOs. Key issues to be addressed in PPER are:

1.5.1 Institutional capacity of the Bangladesh Water Development Board

The Project lagged behind in the formation of Water User Groups (WUGs) and WMAs and only 35% of the beneficiaries had joined WUGs at the time of PCR. The WUG and WMA formation took place at a much later stage of the Project than originally envisaged and within a short period. However, beneficiary participation was recognized as a critical success factor for the Project at all stages, including project design, construction, and O&M. The Directorate of Land and  Water Use (DLWU) of BWDB were expected to mobilize beneficiaries with the help of local NGOs. The WMAs were supposed to be a focal point for EA interactions with project beneficiaries. Two of the six NGOs were dropped due to their poor performance. The OEM will assess whether DLWU had adequate capacity and commitment to engage NGOs and promote active beneficiary participation at different stages of the Project and the extent to which the Project contributed to strengthening beneficiary participation modalities in BWDB. The ongoing relationship between BWDB and WMAs and roles of NGOs in harmonizing better relationship between beneficiaries and the EAs will also be examined.

1.5.2 Design of drainage networks rehabilitation

The beneficiaries rejected the initial project design for drainage network rehabilitation, leading to more than 3 years delay in project implementation. Structural engineering solutions proposed by the Project were not compatible with the needs of beneficiaries and local wisdom. In the end, the Project adopted the TRM approach proposed by local beneficiaries to resolve the drainage congestion problem. The OEM will assess the initial consultation process adopted by the Project, which resulted in proposed solutions unacceptable to local population. While the initial performance of the TRM approach reportedly seems encouraging, the OEM will assess the effectiveness, viability, and sustainability of this approach in Bangladesh and its replicability elsewhere in the region encountering similar problems.

1.5.3 Poverty impacts

Two of the four components of the Project (agricultural development and fisheries management) were dropped in 1999 on the recommendation of an ADB review mission. Reportedly, the Project took this step to avoid duplication of efforts already undertaken by the Department of Agricultural Extension (DAE) and Department of Fisheries (DOF). However, the Project was conceived to have a strong poverty focus with considerable emphasis on increased agricultural productivity and improved management of fisheries in polder areas. This was seen as requiring active involvement of DAE and DOF. There are also concerns that some of the land acquisition claims remain uncompensated. The OEM will assess the extent to which the Project created on-farm employment and benefited the vulnerable population, including marginal and landless households; distributional benefits in terms of access to reclaimed land and productivity gains from agricultural development and fisheries management of polder areas; contribution of DAE and DOF activities in reducing poverty in the project area; and property right issues. The OEM will also consider whether the dropping of two components reflected design deficiencies (thus reducing relevance) or were a correct and timely response to changed circumstances. Furthermore, OEM will assess if the Project has had any implications for resettlement of households, particularly the poor and vulnerable ones previously benefiting from economic activities.

1.5.4 Environmental impacts

The rationale of classifying the Project in Environmental Category B is not clear. The OEM will assess the appropriateness of this classification. While PCR findings indicated no adverse environmental impacts due to the Project, it is not clear how the Project mitigated its impacts on fish migration routes and spawning areas, misuse of chemicals, and other agricultural inputs, disposal of dredged material, and potential increase in the incidence of diseases. The OEM will examine the extent to which adverse environmental impacts were mitigated by the Project and ways in which environmental monitoring data collected by the Project were used during project implementation and management decision-making. Based on available secondary data, the OEM will also review trends in prevalence of water-borne diseases and status of fishing habitats in the project area. The issues raised in OED's recent special evaluation study on environmental safeguards will be taken into account.

1.5.5 Sustainability

The PCR rated the Project to be likely sustainable. However, OED's in-depth review of the PCR noted that sustainability of the Project was significantly dependent upon satisfactory operations of management organizations; where only 35% of beneficiaries had joined water management organizations by project completion. The OEM will assess sustainability of the WMOs both in terms of their membership structure and growth and financial viability. The continued viability of WUGs and WMAs is important for project sustainability and, thus, the OEM will assess membership criteria as well as functional status of WUGs and WMAs. In addition, the OEM will also examine efforts of WMAs and WUGs in seeking technical assistance and other means of revenue generation for O&M for drainage network rehabilitation.

1.6 Approach and Methodology

The PPER will adopt a mixed method approach and use qualitative and quantitative data collection techniques. The evaluation will involve:

1. A desk review of project files, reports and documents provided by the BRM, BWDB, and NGOs to understand operational performance and constraints experienced in project implementation and remedial actions taken by the Project;
2. Secondary data collection and analysis, in particular, environmental monitoring data collected by the Center for Environmental and Geographic Information Services, agricultural and fisheries statistics collected at the district level by DAE and DOF staff, poverty data collected by project Upzillas (local administrative units), health statistics (especially water-borne diseases) collected by Department of Health, and land use data collected by BWDB and DAE to ascertain project impacts on land use, fishing in polder areas, human health, economic and social well-being of affected population;
3. Key informant interviews with local and senior staff of relevant agencies (Ministries of Planning and Water Resources, BWDB, DAE, DOF, Center for Environmental and Geographic Information Services,
4. Associates [consultants for PCR]), local community and environmental leaders, and local consultants engaged by the Project in order to assess relevance of project design, consultative process adopted by the Project during design and implementation, reasons for delays and aggregate environmental and poverty impacts due to the project activities;
5. Focus group discussions with randomly selected 10 landless groups, 5 fisher-folk groups in polder areas, 30 WUGs, 4 WMAs and 1 Federation of Water Management Association representatives to gain first hand insight into operational modalities, revenue collection procedure, O&M mechanisms, and likely sustainability of local water management organizations;13
6. Visit to selected project sites to observe operations and management of drainage rehabilitation systems;
7. A 1-day workshop with concerned NGOs to better understand environmental and socioeconomic impacts due to project activities and the concerns of NGOs with respect to these;
8. Face-to-face structured interviews with randomly selected 240 (120 per district, 2 villages per district)14 household heads to assess income and poverty impacts of the Project; the respondents will include small and marginal farmers, landless, women and fisher-folks originally affected by flooding due to drainage congestion; household data will be collected from the respondents on their pre-project and post-project living conditions, including education of children, health conditions and access to drinking water, on-farm and off-farm employment, household production, access to and use of land resources, cropping patterns and intensities, women's access to and control over resources, access to services and markets, expenditure patterns, and on-farm and off-farm incomes; the survey sample will have equal representation of male and female respondents;
9. Appropriate use of baseline, BME and PCR data collected by the Project and associated NGOs; OED requested BRM for the Project's BME reports and a copy of the survey report completed for PCR; OED also requested BRM to provide original economic and financial analysis soft files used for the PCR; however, BRM advised OED that requested information are not available; this is most unfortunate; the OEM will reevaluate economic and financial rates of return using updated data on key parameters;
10. Establish counterfactuals based on information contained in baseline/ socioeconomic and environmental analysis prior to drainage rehabilitation, review of secondary data collected by various agencies in the project area and recall interviews with key informants and beneficiaries;
11. This will include disputes in land acquisition as well as claim associated with non-payment of compensation to and owners.
12. At the time of PCR, there were 507 WMGs, 58 landless groups, 48 fisher-folk groups, 58 water management committees, 9 WMAs and one Federation of Water Management Association .
13. Update the project Design and Monitoring Framework contained in the report and recommendation of the President (footnote 3) with PPER assessment and
14. Gather photographic evidence to support evaluation findings. The OEM will prepare structured and semi-structured questionnaires for the key informant interviews, focus group discussions and household surveys in consultation with the international and national consultants. The questionnaires will be pre-tested and amended as deemed necessary before conducting interviews and discussions. The Mission Leader, with the support from the staff consultants and an OED Evaluation Officer will analyze field data and prepare the PPER. The quality and consistency of data collected by the OEM will guide the specific method of data analysis, which will include univariate, bivariate and multivariate analyses, and data permitting.

1.B Objective of Engagement

Threat

There are some threats in the evaluation process. If the affected people and advocating NGOs can not understand the process properly and critically, if they can't develop and implement proper strategy and people's opinion will not incorporate properly, this evaluation will mislead people and will go against the people of south-west and will create more adverse effects in future on nature and biodiversity.

It is an important event and it is happening first time in our country. Through this process it is apprehended that the ADB will be more exposed and supposed to be accountable to the people.

Scope

Coastal Development Partnership is one of the partners of Economic Justice theme. Another organization Uttaran is also partner of Economic Justice. Both these two organization are very much involved with KJDRP advocacy process. Both have grassroots linkages and CDP has wide range of working relationship with all other groups involved is KJDRP issues, CDP now is IC member of NGO Forum on ADB and has linkages with other international Networks. Now these two with other organizations are working together.

Objective of the Evaluation

There are long time demand by the project affected people and the advocating NGOs and POs that from the designing phase to implementation phase in every steps of KJDRP, peoples consultation were not done properly, local river management system, biodiversity were not considered properly, the cause of disaster were not analyzed accordingly. So the project design and drainage plans were faulty. People also apprehended that due to implementation of the project.  (as it was). The situation would be worsening. So two years after the project completion, now it is the high time to evaluate the whole process. The objective of the evaluation should be `Role and Responsibility of each stakeholders on project formulation and implementation will be evaluate properly, identify the causes of failure, so that in future, these should be avoided.

Objective of the engagements

The objective of CDP and other NGOs involvement in the process is to unmask the situation and empower the people.

1.C Findings

In the evaluation process, between the findings of ADB mission & people's opinion there are some specific differences:

Through the evaluation process, by using same matrix, two setup answers were received. One set represents people's views & other group represents formal findings of OED mission.

Through comparative review of the two groups of fundings it is found some specific differences between then.

Major comparative Matrix:

2. Monitoring South West Integrated Water Resource Planning and Management Project (SWIWRPMP).

Ashraf-ul-Alam Tutu

2.a) Background Information

2.1. Introduction

Bangladesh Water Development Board (BWDB), under the Ministry of Water Resources, has taken the initiative to implement this project with the funding assistance from Asian Development Bank (ADB) and other development partners. The project intends to revitalize the existing flood control and drainage/irrigation schemes in the region through participatory planning, development and management; and to achieve maximum development potentials in agricultural and fishery production as well as the incomes of beneficiaries in a sustainable manner. The project will be implemented in the northern Southwest areas and is expected to benefit about 0.8 million rural population with an estimated cost of US$43.4 million.

2.2 Project Objectives, Activities and Outputs

The project has three distinct objectives, being:

Objective A  Participatory Integrated Water Management Plans (IWMP) for the selected FCD/1 schemes;

Objective 8  Enhanced livelihood and livelihood opportunities impacted by integrated water resources management as a result of increased user participation and improved decentralized service delivery;

Objective C  Strengthened institutional and project management capacities for planning, implementing, operating maintaining and monitoring demand driven, participatory, integrated water resources management plans.

2.3. Location of the Project

The Southwest Area Integrated Water Resources Management Project selected Chenchuri beel Subproject and Narail subproject in Narail, Lohagara, and Kalia sub districts under Narail district. These two sample subprojects will cover 57,000 hectares (ha) of predominantly wetland areas in the district including Avoinagar sub district in Jessore district.

The Chenchuri beel sub project: The Chenchuri beel subproject has been designed to provide flood protection for a total of 25,560 ha (net cultivated area of 17,900 ha) through 86 kilometers of embankments (ADB, 2005). The area is criss-crossed by drainage channels of various sizes draining into the Chitra and programs with a long-term perspective. The key challenges now are to transform these initiatives into genuine sector operations".

2.4. Activities and Outputs

2.4.1 Objective A

Outputs of this component include:

1.         Pre-feasibility analysis of the short-listed sub-projects,

2.         Review, refinement and final approval of the sub-project selection crilena,

3.         Approved selection of remaining sub-projects, covering around 43,000 ha.

4.         Final and approved IWMPs for selected sub-project areas.

Priontization of investment fequiremenis for each District, based on feasibility level sludies will also be an important output of this proiect component.

2.4.2 Objective B

Part B related activities, being essentially derived from Objective A findings and decisions are refined to a higher level of detail compared to PPTA studies for the two already selected sub-projects Chenchuri Beel and Narail A first step to initiate this process is to engage an NGO for community mobilization, formation of Water Management Associations etc- for which a detailed Terms of Reference (ToR) has been prepared Once reviewed and approved the 6WDB will be able to procure such services-

The Implementation distinguishes seven sub-components:

1.                  Sub-unit delineation.

2.                  Preparation of Sub-unit Implementation Plans (SIPs) and WMO mobilization and formation. 3  Social mobilization. Including information campaigns, formation of WMOs and capacity building.

3.                  Water management and associated infrastructure.

4.                  Support services geared for enhanced agriculture, fishery production and livelihood enhancement

5.                  Sustainable Operation and Maintenance.

6.                  Management transfer

Outputs of this component include productive and sustainable water management systems set up through IWMP implementation in the selected sub-project areas. More tangible outputs Include:

1.                  Established, well trained and functioning Water Management Associations.

2.                  Sub-unit specific implementation plans.

3.                  Rehabilitated and newly constructed water management infrastructure.

4.                  Effective operation and maintenance guidelines and Implementation arrangements developed and in place etc.

5.                  Well funclioning and productive support services

The implementation of the IWMPs will be environ mentally screened and required resettlement will be detailed in Resettlement Plans. Poverty alleviation related supporting activities In the field of agriculture extension, fisheries and income generation. The project will support income-generating activities undertaken on public lands relevant to project infrastructure (e.g. canal banks, embankments} by the poorest sub-group formed in the WMO. along with other priority livelihood enhancement initiatives Priority will be given to creating opportunities for landless groups and women to increase their income and to actively participate in economic activities. The Project will ensure that specially directed programs will therefore focus on the training of women to enable them to participate more effectively in rural development related efforts.

A Gender Action Plan (GAP) has been prepared for the project to ensure that the gender concerns are addressed and effectively dealt with. Beside Ihe activities directly addressing the rural women, the GAP also includes provision to ensure gender balanced employment opportunities and to train project personnel in gender sensitivity and participatory gender responsive planning, budgeting and implementation including monitoring and evaluation.

2.4.3 Objective C

Apart from a change in the timing of activities and a revision In the slaffing schedule no major deviation from the approach and methodology, proposed by the Consultant, for the implementation of the activities for this component is foreseen and is further detailed in the Inception Report and will be further developed as the project progresses,

Outputs of this component will include:

1.         Developed, tested and established proiect management toots like a Management Information System (MIS) and related Monitoring and Evaluation System, a Financial Management System (FMS) for the Project Management Office (PMO).

2.         Established, trained and effectively functioning management structures such as the Project Management Office itself, Joint Management Committees (JMCs) and Sub-project Management Offices-(SMOs).

3.         The main output of the activities related to institutional strengthening and capacity building will be an institutionalizing of a participatory and integrated business processes, including the development of extensive training and coaching modules delivered to staff of the implementing agencies concerned with water management and related services. A major output will be a pool ot professionals with enhanced skills related to the entire project cycle, from need assessment, through design to construction supervision but with emphasis on participatory planning, stakeholder consultation and enhanced knowledge and skills in Ihe preparation of environmental impact assessments and management plans, resettlement plans and planning and implementation of gender development and livelihood enhancement related activities,

2.b) Objectives of Engagement:

Coastal Development Partnership, tries to understand, from the failure of KJDRP, what learning's ADB and Water Development Board has taken. Because the project is a large project and its intended environmental, social and economic impacts will be much more and long term. So to understand the project is very much important for the livelihood of the large members of people and for Sustainable development of the South West Coastal Region of Bangladesh.

2. c Key Concerns;

The project documents claim that the project proponents have studied people's perceptions regarding their aspirations, well being and risks. However, the Independent Review Team found a clear lack of information among local stakeholders, particularly those who would have to contribute the projects by providing land. Most of the community people had not heard of the planned developments and could not perceive the potential benefits and/or risks on their livelihoods to be caused by the project activities. This lack of participation by fisher-folk further adds to their existing social exclusion in the community, with most fisher-folk representing the poorest and most marginalised minority groups of the community.

Decision to lease back the re-excavated cannels to the people for fish culture through the institutional mechanism of the Water Management Associations (WMAs) is also problematic. Though the project suggests helping irrigated agriculture by enhancing protection from flooding and by expanding coverage of irrigation; however, this might not be that helpful to those poor farmers whose lands are away from the canal system. Due to their poor economic conditions, the poor farmers will not be able to take advantage of the canals and thereby would not be in a position to reap benefit from such activities. Moreover, their lands will become relatively less productive compared to the properly irrigated lands in the community. Even if the poor farmers tend to sell their lands, there price would decrease due to having apparently less productive lands. Another aspect is the anticipated effects of sea level rise. The project area falls within tidal zone of Bangladesh. Increased water logging within the polder system will only enhance vulnerability to inundation along the low-lying southern crop lands. On the other hand, due to rising sea levels, there will be a 'head difference' in water levels inside the polders and outside the polder system, which would further aggravate the water logging situation. Therefore, it can be argued that the project proponents have completely failed to be participatory amongst the diverse stakeholders in the planning and design, and in its proposed implementation. This lack of participation is against a number of ADB and GoB policies and strategies; i.e. Article 4.2.c - 'people's participation'; Article 2.4.i - "... make social and environmental assessment mandatory in all plan development"; Article 4.9.a - "fisheries and wildlife will receive due emphasis in water resource planning ... where their social impact is high"; Article 4.9.d - "water bodies...will ... be reserved for fish production and development; Article 4.13.a - "... natural water bodies ... will be preserved for maintaining the aquatic environment ..." - of National Water Policy; and Article 5.2 -  provisions... in favour of real fishermen to initiate production based management system in lieu of lease-based management system"; Article 5.4 -"... low-lying lands across the country where 50 cm or more water depth is found standing for at least 3 months or may be kept inundated accordingly ..." - of National Fishery Policy.

Recommendations:

In view of above findings, the IRT reached at the inferences that

1)         The proposed project, in its present form, should not be implemented by the BWDB;

2)         There is ample evidence that a number of project elements have been designed in such a fashion that National Policies would be violated if implemented;

3)         The level of understanding regarding the project has been inadequate and it needs to be improved;

4)         The proposed activities outlined under the project require further investigations;

5)         More diverse stakeholders' viewpoints need to be incorporated into the project design. It should oim to include the voices of the poorest and be based on people's aspirations, considering conceivable risks and risk management options; 6) To re-examine the project seriously in response to increase access and control over public resources and services by the poor and marginalized citizens through promoting voice.

References

ADB, 2005a. Report and Recommendations of the President to the Board of Directors: Southwest Area Integrated

Water Resources Planning and Management Project, Asian Development Bank, Manila.

ADB, 2005b. Southwest Area Integrated Water Resources Planning and Management Project in Bangladesh,

Summary Environmental Impact Assessment, Asian Development Bank, Manila.

ADB, 2004. Fighting Poverty in Asia and the Pacific: The Poverty Reduction Strategy of the Asian Development Bank,

Asian Development Bank, Manila. CEGIS. 2006. Coastal Land Use Zoning in the Southwest: Impacts of Sea Level Rise on Landuse Suitability and Adaptation Options, Center for Environmental Geographic Information Services (CEGIS), Dhaka.

Cooke, B and Kothari, U 200), Participation: The New Tyranny, Zed Books, London/New York

GoB-MOFL, 1998. National Fisheries Policy, Ministry of Fisheries and Livestock (MOFL), Government of the People's

Republic of Bangladesh (GoB), Dhaka.

GoB-MOWR, 1999. Notional Water Policy, Ministry of Water Resources (MOWR), Government of the People's Republic of Bangladesh (GoB), Dhaka.

GoB-PC, 2005. Unlocking the Potential: National Strategy for Accelerated Poverty Reduction. General Economics

Division, Planning Commission (PC), Government of the People's Republic of Bangladesh (GoB), Dhaka.

Huq, S., Z. Karim. M. Asaduzzaman, and F. Mahtab (eds.), 1999. Vulnerability and Adaptation to Climate Change for

Bangladesh, Kluwer Academic Publishers, Dordrecht, pp. 143.

Farid Ibne Touhid:  Ornamented Participation and the Permanent of Good Governance.

Project Documents.

Accredation

We are very much gratefull to Mr Touhid Ibne Farid for the article `Ornamented Participation and the Permanent of Good Governance' written by him.

The article is widly used to develop this report.