The Sundarbans

• Pollution of marine waters(High level of salinity)
• Management systems/management plan
• 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)
• Water infrastructure (Dredging of the Pashur River)

Total amount granted: USD 32,590 from Switzerland following a Special Appeal by the Sector for External Relations of UNESCO

From 22 to 28 March 2016, a joint World Heritage Centre/IUCN Reactive Monitoring mission visited the property, as requested by the Committee in Decision 39 COM 7B.8. On 10 October 2016, the State Party provided a detailed response to the mission report and, on 28 November 2016, submitted a report on the state of conservation of the property. All these reports are available at https://whc.unesco.org/en/list/798/documents. The following information was provided regarding issues previously raised by the Committee:

• The Environmental Impact Assessment (EIA) for the dredging of the Pashur River has not been updated to include an assessment of potential impacts to the Outstanding Universal Value (OUV) of the property. It is stated that such assessments will be undertaken for future dredging of the Pashur River;
• A decision was made to carry out a Strategic Environmental Assessment (SEA) for the South-West region of Bangladesh, including the property, which would include an assessment of the indirect and cumulative impacts on the OUV arising from the proposed 1320 MW Maitree Super Thermal Power Plant (Rampal power plant) and other developments in its vicinity;
• A wide range of proposed mitigation measures to be implemented at Rampal is listed. It is proposed that an independent monitoring team should have oversight over the Rampal power plant project from the construction to the end of the operation phase. The mission’s recommendation to cancel and relocate this project to a more suitable location is not accepted by the State Party;
• The proposed Orion power plant has not been approved, and the proposed second phase of the Rampal power plant will not be pursued;
• Further information is provided on ecological monitoring and results are provided for certain mangrove species, tiger, crocodile and cetaceans;
• Sea level rise in the Bay of Bengal is stated to occur faster than the global average, and adaptation and mitigation measures are being taken. Sea level rise, salt intrusion and a reduction of freshwater flows are noted to be posing a threat to the Sundarbans ecosystem. The State Party is committed “to secure maximum resilience [of the Sundarbans] in the face of climate change impacts”;
• Measures have been taken to increase preparedness and response capacity in case of an oil spill, including the development of a draft National Oil Spill and Chemical Contingency Plan (NOSCOP), and the procurement of three ships with oil spill collection systems. The December 2014 oil spill is noted to have been “just an accident”.

During a meeting at the World Heritage Centre held on 16 March 2017, the States Parties of Bangladesh and India informed the Director of the World Heritage Centre that they intend to reinforce transboundary cooperation to protect the World Heritage properties of the Sundarbans and the Sundarbans National Park.

The State Party’s decisions not to approve the Orion power plant, not to pursue a second phase of the Rampal power plant and to carry out a SEA for the South-west region of Bangladesh are welcome as they address two key recommendations made by the 2016 Reactive Monitoring mission. It is recommended that the Committee request the State Party not to permit that any large-scale industrial and/or infrastructure developments (including the Rampal power plant) proceed before the SEA has been completed.

It is regrettable that the EIA for the dredging of the Pashur River has not been updated as requested by the Committee. While the State Party states that EIAs for future dredging will consider impacts on the OUV of the property, this does not address the Committee’s concern that these impacts have not been adequately assessed for the currently planned dredging. It is therefore recommended that the Committee reiterate its request to the State Party to ensure that no dredging activities are conducted before the current EIA is revised in accordance with IUCN’s World Heritage Advice Note on Environmental Assessment.

The information provided on ecological monitoring is welcome. The State Party confirmed the mission’s finding that sea level rise, salt intrusion and a reduction in fresh water flows are posing a threat to the Sundarbans ecosystem. It should be noted that the property, located in the southern part of the Sundarbans Reserved Forest (SRF), is particularly vulnerable to increasing salinity. The mission concluded that without adequate water influx from the Ganges basin, the property’s OUV cannot be adequately protected and maintained in the long term. In that regard, the intention to reinforce transboundary cooperation between the States Parties of Bangladesh and India for Sundarbans properties is noted. 

The mission also concluded that the planned development of Rampal power plant as close as 14 km to the SRF and 65 km to the property, has a high likelihood for downstream impacts on the property arising from air and water pollution, a substantial increase in shipping and dredging, and additional removal of freshwater from an already increasingly saline environment. Furthermore, the project’s EIA did not address impacts on the OUV of the property, nor does it provide convincing evidence that impacts will be mitigated. While the State Party provides a long list of measures taken to limit and mitigate negative impacts on the environment, the concern remains that there is insufficient supporting evidence that these measures would prevent impacts on the property from air emissions, coal ash hazards, and shipping and dredging plans to transport coal to the project site. In light of these concerns and the mission’s conclusions, it is recommended that the Committee request the State Party not to proceed with the Rampal power plant project in its current location and to relocate it to a more suitable location where it would not negatively impact the OUV of the property. Further steps in implementing this project would not be appropriate considering the concerns raised, and the potential impacts on the OUV of the property have not been comprehensively assessed in accordance with IUCN’s World Heritage Advice Note on Environmental Assessment. Further information would be needed to allow prior consideration by the Committee of such large-scale industrial developments in the areas surrounding the property.

The development of the draft NOSCOP and the procurement of additional ships with oil spill collection systems are welcomed. However, it is of concern that the December 2014 oil spill is reported to have been “just an accident” and that the State Party does not discuss the impacts of four other similar incidents that occurred in May 2015, October 2015, March 2016, and January 2017, spilling large quantities of coal in proximity to the property, as well as one case of potash fertilizer. The mission noted that long-term impacts from these spills on the Sundarbans ecosystem cannot be excluded. In addition, the anticipated increase in shipping traffic associated with the development of the Rampal power plant and the proposed expansion of Mongla Port could further exacerbate the risk of shipping incidents. It is recommended that the Committee request the State Party to ensure that adequate human and financial resources are provided for the implementation of the NOSCOP once it is adopted, and to provide further information and data on monitoring of the long-term impacts from recent shipping incidents.

Finally, it is recommended that the Committee request the State Party to take urgent measures to fully implement all the recommendations made by the mission. While the mission concluded that the property does not currently meet the requirements for inscription on the List of World Heritage in Danger, the mission noted that immediate implementation of the mission recommendations related to the freshwater flows, large-scale developments in the vicinity of the property and integrated management is imperative to prevent the OUV of the property from becoming irreversibly damaged. It is therefore recommended that, in the absence of substantial progress with the implementation of the above, the Committee should consider inscribing the property on the List of World Heritage in Danger at its 42nd session.