The Sundarbans

• Pollution of marine waters
• Changes to oceanic waters (High level of salinity, sea level rise)
• Water infrastructure (Reduction in freshwater inflows, dredging of the Pashur River)
• Management systems/management plan (Overall governance and management of the property)
• Storms (Loss of monitoring capacity due to cyclone damage)
• Illegal activities (Tiger poaching)
• Forestry/wood production (Unsustainable harvesting of timber and non-timber forest products)
• Non-renewable energy facilities (Thermal Power Plant project such as the Rampal power plant development project)
• Need for a Strategic Environmental Assessment (SEA) of the entire property, in particular for the South-West region of Bangladesh

Total amount granted: USD 32,590 from Switzerland following a Special Appeal by the Sector for External Relations of UNESCO; 2017: USD 32,527 from the UNESCO Netherlands Funds-in-Trust for technical support to the Sundarbans World Heritage property

On 4 December 2018, the State Party submitted a report on the state of conservation of the property, a summary of which is available at http://whc.unesco.org/en/list/798/documents/. The report notably provides the following information:

• No environmental clearance or permission has been given to any large-scale industrial projects adjacent to the property;
• An overview of current and future development plans until 2041 in the Southwest region of Bangladesh has been undertaken in preparation for the Strategic Environmental Assessment (SEA). A consultancy firm to undertake the SEA was to be shortlisted in January 2019;
• An integrated freshwater inflow management plan is being implemented to maintain freshwater flow and improve water quality. Gorai River is dredged during the dry season to divert water to the Southwest region of Bangladesh. Several additional projects are underway in the region to dredge numerous other waterways;
• An India-Bangladesh Joint Working Group on Conservation of the Sundarbans (JWG) has been created, which has led to an agreement to conduct joint studies on the indicators to monitor the health of the Sundarbans ecosystem and the impacts of climate change, and to protect the Bengal Tiger;
• In June 2017, the Government of Bangladesh more than doubled the area of the three wildlife sanctuaries to cover the area beyond the property’s boundaries, to prohibit resource exploitation;
• Spatial Monitoring and Reporting Tool (SMART)-based patrolling is being implemented across the Sundarbans Reserve Forest (SRF), which has led to a significant increase in the number of arrests made. In addition, following a successful operation by law enforcement agencies, the Prime Minister of Bangladesh declared the Sundarbans “pirate-free” on 1 November 2018;
• A 2018-2027 Tiger Action Plan has been finalized and a 2017-2022 National Tiger Recovery Program developed to accelerate the implementation of the Action Plan;
• A Bangladesh Delta Plan 2100 has been adopted to give a hundred-year strategic pathway to protect and expand the Sundarbans;
• The draft ‘National Oil Spill and Chemical Contingency Plan’ (NOSCOP), which provides guidance to prevent, control and manage oil and chemical spillages, is undergoing stakeholder consultations;
• Any future dredging of the Pashur river will be subject to an Environmental Impact Assessment (EIA), including an assessment of impacts on the Outstanding Universal Value (OUV) of the property;
• The Mongla-Ghasiakhali channel is continuously dredged to act as the main transport route, which does not traverse the Sundarbans;
• Details are provided on mitigation measures that will be implemented for the construction of the Maitree Super Thermal Power Plant (Rampal), including state of the art emission control techniques.

On 25 March 2019, the World Heritage Centre sent a letter to the State Party, following the receipt of third-party information relating to the state of conservation of the property. On 22 April 2019, the State Party provided the following response:

• The Taltoli and Kolapara coal-based power plants on Payra River, approximately 20 km from the eastern boundary of the property, are being constructed following an EIA. No large-scale development is permitted within the SRF or its 10 km buffer zone (Ecological Critical Area – ECA);
• The State Party considers that Decision 41 COM 7B.25 did not include a request to put the construction of the Rampal Project on hold;
• As of April 2018, 190 industrial projects are approved in the ECA around Mongla Port (ca. 65km from the property), 154 of which are active and operating;
• Five consultancy firms have been shortlisted to undertake the SEA and are requested to submit a ‘Request for Proposal’ by 18 April 2019.

On 20 May 2019, the State Party submitted copies of EIAs for the Rampal project and Taltoli power plant to the World Heritage Centre.

Positive developments, such as the implementation of the integrated freshwater inflow management plan, the implementation of SMART, the development of the Tiger Action Plan and recovery programme, and the expansion of the wildlife sanctuaries are welcomed. The creation of the India-Bangladesh JWG is also welcomed, and such a collaboration should be encouraged for the long-term protection of the property. The confirmation that any future dredging of the Pashur River will undergo an EIA is appreciated, but it should be noted that this should apply to dredging of any scale. The Committee should remind the State Party that EIAs should be conducted in line with the IUCN World Heritage Advice Note on Environmental Assessment and include a specific section on the potential impact of the project on the OUV of the property.

However, little progress has been achieved to address other significant threats to the property. Despite the Committee’s requests, no serious consideration was given to possible alternatives to the construction of the Rampal power plant, and its construction is progressing. The Committee’s concerns regarding the high risk of downstream impacts on the property arising from air and water pollution, a substantial increase in shipping and dredging, and an additional removal of freshwater from an already increasingly saline environment, were not properly addressed or assessed as part of the SEA, as was requested by the Committee, while the construction of the power plant proceeded. It should be reiterated that, in Decision 41 COM 7B.25, the Committee requested the State Party to ensure that no “large-scale industrial and/or infrastructure developments” are allowed to proceed before the SEA for the Southwest region of Bangladesh, including the World Heritage property, has been completed. The Committee’s decision does not make any exception for the Rampal Project and specifically requests that the State Party assess the various impacts of the project on the property as part of the SEA, as recommended by the 2016 Reactive Monitoring mission. In the absence of such an SEA, it is of particular concern that other coal power plants, Taltoli and Kolapara, are also being constructed on the Payra River, despite the Committee’s requests. The Payra River ecosystem, in which these coal power plants are being constructed, opens out into the same bay as the property, which consequently could be affected by contaminated water and other threats. Furthermore, the 154 industrial projects around Mongla Port are expected to lead to a substantial increase in shipping and dredging, and the individual industries have the potential to multiply impacts on the OUV. The continuation of the construction of the Rampal power plant, as well as construction of two additional power plants on the Payra River, proceeding in the absence of the SEA, together with the numerous other industrial projects represent both an ascertained and potential danger to the OUV of the property and the ecological and hydrological dynamics which underpin the property’s OUV and integrity, in line with Paragraph 180 of the Operational Guidelines. It is therefore recommended that the Committee inscribe the property on the List of World Heritage in Danger and request the State Party to invite a joint World Heritage Centre/IUCN Reactive Monitoring mission to the property to assist the State Party with the preparation of a set of corrective measures and a Desired state of conservation for the removal of the property from the List of World Heritage in Danger (DSOCR).

Furthermore, it is regrettable that the National Oil Spill and Chemical Contingency Plan (NOSCOP) has still not been finalized, and that no details on financial and human resource allocation have been provided for its implementation. Data on the monitoring of long-term impacts from recent shipping incidents have also not been submitted, despite the Committee’s request.