Policy Formulation in Bangladesh: An Analysis of Environment Policy, 1992

Like many other emerging democracies, most public policies in Bangladesh are generally framed by the traditional bureaucratic elite following a ‘top down’ approach. In general, the members of the bureaucracy at the ministries draft and process the policy in general and sometimes with tacit approval of the political executives. There is no culture among the policy makers to consult the civil society, NGOs and other stakeholders to make public policies people-oriented and truly responsive. However, during the formulation of the Environment Policy 1992, as a distinct departure from the previous trends, the government initiated a process of public consultation and involved civil society bodies, the professional groups and the NGOs. After analyzing the whole formulation process, the study has identified a number of actors and factors that played a critical role at policy demand, agenda setting, formulation and approval stages. From initiation to approval, the major institutional actors were: United Nations and some of the specialized agencies, selected donor agencies, specialized regional organizations, environmental NGOs, professional bureaucrats, key politicians and a set of consultants/ activists. These actors and factors had contributed significantly to the policy at different stages with varying degree of involvement. In brief, at the policy demand and policy agenda levels, actors and factors outside the government played the dominant role, whereas at the formulation and approval stages, the members of bureaucracy took the lead role. In the overall environmental policy-making process, UN bodies and the NGOs played effective roles in devising a perspective, through their supplementary support in the form of technical assistance and mobilization of public opinion.
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Policy outcome mainly depends on the environment in which it is conditioned. Policy environment is the combination of a number of actors and factors. It consists of a variety of factors, such as economic, social, political, geographical, demographical, religious, international etc. Policy makers, consultants, donors, the people, political parties, pressure groups, and many other actors are also active in the policy environment. Some of these are involved in the process due to their formal authority to formulate the policy, some to provide technical, financial or other kind of support, while others are to advocate their own interests. A policy is not constructed in vacuum, it is the result of interaction of all these actors and background factors with the desires, interests, and decisions of those who makes policies. So, neither individual decision makers nor the nature of the system appears capable alone of explaining policy outcomes. Instead, policy outcome depends on the one hand on nature, interest, capability, technical knowledge, power of the actors and on the other hand on intensity of the importance of the factors, and above all on the dynamics of the role of these factors and actors. These actors and factors play a role at different stages of policy making such as: problem identification, policy demand, policy agenda, policy formulation and adoption, policy implementation and policy evaluation (Islam, 2008, p7). The component of policy environment may vary depending on the socio-economic, cultural and political situation of the country as well as on the nature of the policy.

Research Questions

The study was conducted based on the following broad questions:

•     Who were the major actors involved in the formulation of the 1992 Environmental Policy of Bangladesh?

•     What were the crucial factors?

•     What role did the internal or the external actors and factors play in the dynamics of formulation of the Environment Policy of 1992?

•     Which of the actors played the dominant role in policy formulation process and how?

Answers to the above questions are expected to add a new perspective to the development debate and understanding of the dynamics of public policy formulation in a typical Third World setting like Bangladesh.


The exploratory research method has been followed for this study.

Both the primary and secondary sources were used for the collection of data. Primary data was collected from the former and present officials of DoE, MoEF, and people involved in the formulation process, and NGO officials. Secondary sources basically include different books, articles, newsletters, annual reports of different environmental organizations, and daily newspapers. Internet facilities have also been availed for collecting secondary data. Primary data were collected with the help of Content Analysis, Interview, and Informal Discussion.

Meaning of Public Policy

Public is defined as people in general, a group of people who share a particular interest or who have something in common (Oxford University Press, 1974). The most common social and political usage of the term policy refers to a course of action or intended course of action conceived as deliberately adopted, after a review of possible alternatives and pursued or intended to be pursued. Policy is a projected program of goal, values and practices: the policy process is the formulation, promulgamation, and application of identifications, demands and expectations (Lasswell, H. and Kaplan, A., 1970). The term public policy always refers to the actions of government and intentions that determine those actions. It may also be seen as a set of rules, which can be utilized to achieve certain desired objectives (Shaw, 1966). Dye defined ‘Public policy is whatever the government chooses to do or not to do’ (Dye, 1984, p3).

Environment Policy, 1992

Environmental Policy 1992 provides guidelines for ensuring sustainable development in Bangladesh. The policy incorporates 15 sectors that are discussed below (Islam, 2012):


Figure 1: Public policy at a glance




1. Agriculture

All agricultural resource bases are to be conserved and their environmental compatibility and long term use are to be ensured. The use of agro chemicals, artificial materials and inputs which have adverse impact on the fertility of the soil, man, and animals are to be controlled. The application of different natural fertilizers and insecticides is to be encouraged.

2. Industry

Environmental Impact Assessment (EIA) is a must for all new industries both in public and private sectors. Ban on establishment of industries producing goods, causing environment pollution is required. It also suggests closing down such existing industries in phases.

3. Health & Sanitation

Healthy environment in the workplace, in urban and rural areas, and also in all developmental activities are to be ensured. Integration of environmental concerns into the National Health Policy and in health education curriculum is required.

4. Energy and Fuel

Reduce and discourage the use of fuel wood, agricultural residues and those fuels which pollute the environment and increase the use of environmentally sound and less harmful fuels are emphasized.

5. Water Developments, Flood Control and Irrigation

Environmentally sound utilization of all water resources is to be ensured. All steps taken for flood control, including construction of embankments, dredging of rivers, digging of canals etc. should be environmentally sound.

6. Land

Formulation of a balanced and environmentally sound national land use policy and plan is required. Necessary steps to be taken to prevent land erosion, salinity and alkalinity. Environmentally sound management of newly accreted land is recommended.

7. Forest, Wildlife and Bio-diversity

Stop depletion of forestland and forest resources to maintain the ecological balance is urged. Develop and encourage the use of substitutes of forest products to meet the socio-economic needs and reality is identified as priority areas for action.

8. Fisheries and Livestock

Ensure appropriate environment for the conservation and development of fisheries and livestock, prevent activities which diminish the wetlands/natural habitats of fish and encourage rehabilitative measures in this area are the main focus of this sector.

9. Food

The Environment Policy recommends following environmentally sound methods for production, preservation, processing, distribution of food and disposal of rotten or harmful food stuff and food crops.

10. Coastal and Marine Environment

Great importance is placed on the preservation and maintenance of coastal and marine eco-system and coastal resources. Prevention of all internal and external activities polluting the coastal and marine areas should be ensured.

11. Transport and Communication

Environmental Impact Assessment is compulsory for transport and communication related projects. The policy suggests that measures should be taken to ensure that roads, rails, air and inland water transport systems do not pollute the environment or degrade the resources.

12. Housing and Urbanization

The policy prefers to integrate environmental considerations into all housing and urban planning activities and research. It also suggests adopting that type of program and projects for planned urbanization that does not have adverse impact on overall environment of the urban areas as well as nation.

13. Population

Integration of environmental conservation and development concerns in the population policy and action program is required. Integrated and planned utilization of all manpower including women and unemployed should be ensured.

14. Education and Public Awareness

Ensure inclusion and dissemination of environmental knowledge and information in the formal and informal systems of education and media is to be ensured. Creation of widespread mass awareness regarding environmental conservation and improvement, sustainable, long term and environmentally sound utilization of all resources are suggested.

15 Science, Technology and Research:

Incorporate environmental concern into national science and technology policy is required. Necessary research and evolve technology to ensure long term, sustainable and environmentally sound utilization of all resources for conservation and improvement of environment is to be encouraged.

The Ministry of Environment and Forest was assigned the duty to coordinate the implementation of this policy. A National Environmental Committee was created with the head of the Government as the Chairperson to give overall direction for implementation of this policy. Department of Environment will make final review and approve all Environmental Impact Assessments (EIAs).

Formulation of ‘Environment Policy 1992’

As a result of international and domestic processes, environmental protection emerged as a noticeable issue in Bangladesh in the eighties. An important step in this regard was the formulation of the ‘National Environmental Policy’, which was approved by the cabinet in 1992. The government realized the fact that the relevant environmental problems could be tackled and the commitments can be fulfilled only within the gamut of a well-directed framework. Creation of a widespread mass awareness program; active participation of the people at all levels; immediate and long term solution of natural disasters treated as integral parts of environmental protection and development. Management of resources is identified as essential element in the formulation of the Environmental Policy.

This section focuses on dynamics of formulation of ‘Environmental Policy 1992’.

Policy Demand

Mass people, political parties, pressure/interest groups/stakeholders, media, advocacy groups/lobbyists, international agencies, donor agencies, regional bodies, international conventions, incremental learning of bureaucracy and feedback etc are some actors and factors involved at this stage. These are responsible for convincing the government that policy is needed for addressing a particular problem. A set of international, regional, and national factors and actors had created the demand for an environment policy. The following section concentrates on those factors and actors.

In recent years, internationally, the importance of proper environmental protection and management has been duly recognized (Hossain, 1999). The United Nations Conference on the Human Environment held in 1972 was a landmark event in the growth of international environmentalism. The Stockholm conference played the pioneer role in creating environmental awareness in the international community. It was one of the most important international responses to the global environmental problems and challenges. Since the Stockholm Conference on Environment in 1972, the GoB has been trying to be proactive about various environmental issues and concerns (Mahfuz Ullah, 1999: 41)

By the mid 1980s most of the countries in the world had already recognized the importance of creating an appropriate legal basis for the prevention of continued environmental degradation and for the protection of natural resource base. The United Nations General Assembly passed a resolution in 1983 and created a commission named ‘The World Commission on Environment and Development’. The report of the Commission was published as ‘Our Common Future', in 1987. It also formed the basis for Agenda 21 and the UN Conference on Environment and Development (UNCED), held in Rio de Janeiro in June 1992. This conference is known as the ‘Earth Summit’. ‘Earth Summit 1992’was a follow up conference of Stockholm Conference. The decision to convene ‘the Earth Summit’ created enormous pressure on the Bangladesh government.

At around the same time, Bangladesh’s major development partners started showing interest in environmental matters. Most donors became more and more involved in environmental assistance at the government level and side-by-side NGO level. Consequently, both the government and NGOs became interested to take environment-related projects to fulfill the conditions of some loan agreements made with various donor agencies.

During that period, NGOs also began to show greater interest in environmental matters. As a result, a number of NGOs started to work exclusively for protecting environment or facilitating mobilization of people for environment. It played a very important role in creating awareness about environmental issues at the grassroots level and also at the policy-making level. The sector deserves the credit for making the government conscious about its responsibility in ‘environment protection’.

Influenced by the emergence of non-government organizations and expert groups and activities undertaken by the environmental NGOs as well as to secure funds from both bilateral and multilateral development agencies, the government has taken a wide range of initiatives. Since the mid-eighties the government has been making a number of moves to protect the environment. A legal framework for environment has evolved through the enactment and amendment of necessary laws and formulation of sectoral policies. But, for addressing environmental problems properly the government must be assumed to be responsible for creating a comprehensive policy framework that is conducive to addressing environmental issues and degradation. This realization formed the strong basis for the formulation of the environment policy.

In 1986, International Union of Conservation of Nature and Resources (IUCN) and the Bangladesh Center for Advance Studies (BCAS) organized a seminar on conservation and development in Dhaka. The seminar recommended that a National Conservation Strategy (NCS) be prepared for Bangladesh. Following the recommendations of the seminar, the GoB decided to prepare NCS. After three years of NCS, the decision to formulate the National Environment Management Action Plan (NEMAP) was taken by the government. One of the important decisions of the GoB, during that period, was to incorporate environmental matters in the Fourth Five Year Plan.

Against this backdrop, the government felt that implementation of government commitment to the environment and mitigation of other environment-related problems is possible only through a well-defined national policy.

The environmental policy was formulated at the peak period of the global environmentalism. In fact, all the important initiatives were taken from 1972 to 1992 not only in developing countries but also in developed countries. South Asian scenario was also the same, which had inspired the Bangladesh government to take positive action on the issue.

Briefly speaking, on the one hand evolution of environmentalism and on the other hand recognition of the importance of proper environmental protection and management by GoB played an active role in creating the background for environment policy in Bangladesh. At the same time, both external and internal actors were active

Policy Agenda

Different problems, issues and needs are presented to government for action. But, all the problems cannot draw attention of the government. Depending on the power, status, number of the people lobbying and the government priority

Only a few of these get a patient hearing or cognizance. The ‘few’, which are taken into consideration by the government, become policy agenda. Initiative has been taken here to discuss those actors and factors depending on which government put the ‘Environment Policy’ on the agenda (Islam, 2007, p90).

Like many other countries, Bangladesh, based on the recommendations of the Stockholm conference, prepared a country report highlighting development trends and environmental impacts, and response to environmental/development issues for presenting at the Rio conference in 1992, which could be considered a progress report. The Bangladesh government felt the need to have an environment policy before preparing the final draft of the country report, as an indicator of progress.

Different international organizations have helped the taskforce, comprising three members[i], formed for preparing the draft of the report .

Recommendations of the report of ‘Our Common Future’ published in 1987 by the World Commission on Environment and Development had also expedited the Environment Policy formulation process.

Table l: Actors and Factors involved at the policy demand level and their role



Factors Major Impacts
United Nations •     Growth of international environmentalism

•     Beginning of environmental awareness among the international community

•     Emergence of the assumption that environmental problems can occur in developing countries also

•     Worldwide recognition of the importance of creating a legal basis for protecting environment

•     Recommendations of the report ‘Our Common Future’

•     Decision to hold the UNCED in 1992

Policy Demand
Donor Agency •     Greater interest of donors in environmental matters

•     Conditions imposed on loan agreements

Policy Demand
South Asian Nations •     Evolution of environmentalism in this region Policy Demand
Regional Organizations •       Policy Demand
Environmental NGOs   Policy Demand
MoEF •     Environmental initiatives taken by the government

•     Decision to prepare NCS

•     Decision to formulate NEMAP

•     Decision to incorporate environmental matters in Fourth-Five Year Plan

Policy Demand
Planning Commission •       Policy Demand
NGOs: IUCN, BCAS •     Environmental activities undertaken by NGOs

•     Awareness created by NGOs

Policy Demand

Preparatory committee meeting of UNCED played a major role in that respect. The United Nations General Assembly passed resolution 44/228 December 1989, based on which The United Nations Conference on Environment and Development (UNCED) was held in Rio de Janeiro in June 1992. One of the most important phenomenon of Resolution 44/228 of December 1989 was the organization of a large number of preparatory meetings. In fact, the two-week Earth Summit was the climax of a process that began in December 1989, of planning, education and negotiations among all member states of the United Nations. Bangladesh attended almost every preparatory committee meeting. An opinion expressed by the preparatory committee was that a country should formulate an environment policy. The government felt enormous pressure to formulate an environment policy to fulfill this commitment. In this context, policy advocates in Bangladesh felt it urgent to have an environment policy in order to both represent the country in the global forum and for inter-governmental negotiations.

One of the principal areas where donors’ opinion carries importance is the formulation and conduct of policy. In Bangladesh, among donor agencies, first IDA, NORAD, USAID, CIDA, UNDP, ESCAP, ADB showed interest about environmental issues. These donor agencies had undertaken a wide range of studies both of the state of the environment as a whole and of specific areas of particular concern. On the basis of these studies, the donor agencies suggested different measures to be taken by the government. To formulate an environment policy was one of the conditions for loan disbursement for different projects. The GoB had to comply with the conditions suggested by the donors, otherwise international agencies will not support Bangladesh[ii].

Though a number of environmental NGOs were working during that period but very few environmental NGOs were closely working with the government. Bangladesh Center for Advance Studies (BCAS), Coastal Area Resource Development and Management Association (CARDMA), International Union of Conservation of Nature and Resource (IUCN), and Forum of Environmental Journalists of Bangladesh (FEJB) had strong links with the government and consequently were able to exercise influence on the government. The non-government sector had made commendable advances in this respect through creating awareness, implementing projects, and organizing workshops/ seminars/ conferences etc. Through their activities this sector directly or indirectly pressurized the government to formulate an environment policy (Islam, 2007, p93).

A number of conferences/workshops organized by the NGOs/media had played an important role in putting the matter on the agenda:

A workshop was held at Dhaka on ‘Bangladesh Coastal Area Resource Development and Management’ on 3-4 October 1988 organized by CARDMA (CARDMA, 1988). A series of actionable recommendations were prepared and presented to the parliamentary committee and government. The conference expressed, “Environmental concern is now a global issue and must be addressed by all. Without such a national policy development efforts cannot be sustained over the long run” (Islam, 2007, p93).

The international seminar on ‘The Greenhouse Effect and Coastal Areas of Bangladesh’ held on March 5, 1989 was organized by CARDMA (CARDMA, 1989). The chairperson played an important role, through these conferences, in convincing the government to take particular initiatives. Consequently, there was the declaration of an environment year, declaration of environment decade, and the move to establish an environment ministry was made. Many other environmental decisions and the decision to formulate environmental policy were also taken.

An international seminar on “Bangladesh Floods: Regional and Global Environmental Perspectives” was organized in Dhaka from 4th to 7th March 1989 by the Bangladesh Research Bureau (BRB). The organizer of this conference had close relations with the President and Deputy Prime Minister. This conference had given the organizer the opportunity to convince the government about the severity of the environmental problems. As a result the government has taken different measures, including adoption of Environment Policy, to face environmental obligation (Islam, 2007, p95).

Centre for Sustainable Development (CFSD), organized a workshop at BARD, Comilla, from 21-24 March 1988, which is considered the first media workshop on environmental degradation and in launching campaigns against environmental degradation. The workshop recommended along with other suggestions formulation of a comprehensive national environmental policy by the government in collaboration with scientists, NGOs, relevant departments and interested persons concerned with environment and development issues. Consequently, the recommendations were sent to the government (Islam, 2007, p95).

NCS and NEMAP played a very crucial role in taking Environment Policy as a policy agenda. More specifically, Environment Policy is considered as the byproduct of National Conservation Strategies (NCS) and National Environment Management Action Plan (NEMAP). The Bangladesh government decided to formulate NCS in 1986 and after a number of workshops, NCS was finalized in 1991. NCS has played an important pioneering role in catalyzing environmental awareness and the development of an environmental policy in Bangladesh in 1992. On the basis of NCS recommendations, a plan was made to formulate NEMAP. NEMAP was initiated in 1989-1990 by MoEF, with the funding from the UNDP, and completed in 1992. But, without a policy a plan is not logical because policy is higher-level decision, plan is mid-level decision and project is lower-level decision. To maintain the logical sequence, Environment Policy was formulated. From this point of view, NEMAP and NCS had a great influence on the formulation of the environment policy (Islam, 2007, p97).

The Fourth Five-year Plan (1990-1995) was the first important planning and policy document of the government where it talked about environmental issues. In order to promote, nurture, protect and expand nature and natural resources and link all developmental activities with environment towards improving the quality of life, the plan incorporates a number of objectives. In order to realize the above-mentioned objective, along with a set of strategies, formulation of a policy was emphasized (Islam, 2007, p97).

Over the last few decades, Bangladesh, in collaboration with the other members of the international community, has managed and adopted a significant number of Multilateral Conventions, Treaties and Protocols (ICTPs) with a view to addressing major global environmental problems. Donors gave importance to formulating environmental policies for effective implementation of ICTPs. The Bangladesh government felt the need to have an environment policy to fulfill the donors’ requirements as well as demand for legal framework supportive to the effective implementation and compliance with environmental treaty obligations (Islam, 1996).

Political will was another important factor. The Jatiya Party (JP) and the Bangladesh Nationalist Party (BNP) had ruled the country from 1989 to 1992. Especially, the JP deserves appreciation for its efforts. The President of the country and other leaders of the party in power and his associates were very enthusiastic about environmental concerns, which was reflected by their policies and initiatives pursued in the area of environment. The party talked of protecting the environment, rallied behind international initiatives and upheld different treaties and conventions to protect the nature (Islam, 2007: 98).

From the above discussion it is identified that a number of actors and factors were responsible for creating demand for an environment policy. Gradually, those actors and factors intensified their role and new actors and factors joined the queue. Consequently, demand for an environment policy got a new impetus and status. Their pressure, influence, and activities pushed the environment policy from policy demand to the policy agenda level. That means the government began to think seriously to formulate an environment policy and both internal and external influence played sensible role at this stage.

Policy Formulation

Policy formulation means drafting the policy document. It deals with what should be included and excluded in the policy content. Final policy document is prepared at this stage after many consultation and discussion with different people and organizations. During the formulation period, different people and organizations, e.g. concerned ministries, donor consultants, and NGOs played an active role. Policy makers had to take into consideration different factors. This section tries to find out who played the crucial role and what factors environmental policy makers had to consider.

MoEF was responsible for drafting the policy, which was a group effort. Some officials of the MoEF and DoE prepared the draft with the help of NGOs/civil society. No separate fund was allocated for Environment Policy. It was going parallel with NEMAP, NCS, and other environmental projects of the government and was financially supported by those projects. Interesting enough that the same group of persons[iii] prepared the first draft of Environment Policy, NEMAP, and NCS[iv]. Afterwards the responsibility was shifted to many other persons, a former deputy director of DoE drafted a certain portion of the policy (Islam, 2008, 16).

Some officials within the ministry also played an important role in drafting the policy, as for example one deputy secretary. The then Environment Minister gave him the responsibility to make arrangement for formulating an environmental policy. With this purpose, a ‘drafting committee’ was formed with one deputy secretary, and two assistant secretaries. The deputy secretary along with his colleagues took an active initiative to formulate the policy. The then ministers of the MoEF seriously cooperated with the officers in this respect. One of the ministers was very enthusiastic and he is still remembered for his positive role in formulating the Environment Policy.

Inputs for the contents of Environment Policy were picked from different sources.

Table-2: Actors and factors involved at policy agenda level of Environment Policy 1992

Actors Factors Role Played
United Nations •     Recommendations of the Stockholm conference Country report prepared for Rio conference

•     Recommendations of ‘Our Common Future’ published by the World Commission on Environment and Development

•     Resolution 44/228 of UN general assembly which contained the decision to start the preparatory process

•     Opinion expressed at the preparatory committee meeting

Donor Agencies- IDA, NORAD, USAID, CIDA, UNDP, ESCAP, ADB •     Conditions imposed on loan agreements

•     Donors’ requirement for environment policy for the effective implementation of different environmental projects

International Forum/Organizations •     Demand for legal framework conducive to implementation of ICTPs


NGOs- BCAS, CARDMA, IUCN, FEJB •     NGOs’ environment related activities

•     Organized workshops/ seminars/ conferences etc

Awareness building

Direct or indirect pressure

MOEF, Planning Commission, DOE •     Formulation of NEMAP and NCS

•     Incorporation of environmental matters in Fourth Five Year Plan

Political Party- Jatiya Party, Bangladesh Nationalist Party

Political Persons

•     Political will  

The UNCED preparatory process itself was an important source of policy input. The policy makers seriously took opinions expressed at the preparatory committee meetings into consideration. Through formulating the policy, the GoB tried to fulfill the commitment made at preparatory committee meeting.

A workshop was organized on November 9, 1991 sponsored by ADAB, NGO Affairs Bureau and UNDP with the purpose of facilitating Bangladeshi NGO’s substantive contribution to UNCED. Along with many other recommendations they suggested “National policies to be meaningful, not framed bureaucratically at the top. These should be the result of the widest possible discussions and consultations among the people and should include inputs from NGOs. Only such policies can be effectively implemented.” Policy makers considered the recommendations of this workshop in making the environment policy.

As per the recommendation of the UN General Assembly, Bangladesh also participated in a number of regional meetings. The recommendations of these meetings had greatly influenced the Environmental Policy contents and also expedited the process. Some examples are as follows:

The Ministerial-level Conference on Environment and Development in Asia and the Pacific held in Bangkok in October 1990, organized by ESCAP, reviewed the state of the environment in the region and examined the implications of global environmental problems, such as the depletion of the ozone layer, climate change and the rise in sea-level. The ministers proposed to establish institutional mechanisms to foster regional cooperation and formulated a strategy to achieve environmentally sound and sustainable development. The meeting also emphasized the need to prepare a regional input to the UNCED, 1992. The meeting proclaimed: “We the ministers believe that to achieve sustainable development, policies must be based on the precautionary principles”.

A number of non-governmental organization symposiums have been organized in the region, of which a particularly important one, the NGO/Media Symposium on Communication for Environment was held in conjunction with the ministerial level conference in Bangkok in October 1990.

The Second Ministerial Conference of Developing Countries on Environment and Development was held in Kuala Lumpur, Malaysia from April 26 to 29, 1992. With many other countries, Bangladesh also participated in the conference.

Prior to the Rio Earth Summit, the South Asian Environment Ministers meetings, organized in Delhi in April 1992 by SAARC, outlined eight basic principles of fundamental importance to guide future international cooperation in the areas of environment and development: “The integration of environmental concerns into economic development policies and programs should be carried out without introducing any conditionality in aid or in development financing. Such integration should also not be used as a pretext for erecting trade barriers”.

From inception to approval (1989-1992), Environment Policy has been changed several times. It has gone through a lengthy modification process and ultimately took the final shape. The policy was drafted at the ministry level, and then it was sent to DoE and other concerned ministries and departments for opinion and recommendations. Several inter ministerial meeting were held (Islam, 2008, p17).

At the inter- ministerial meeting, NGOs and civil society members, e.g. IUCN, BCAS, FEJB, ADAB, were invited and were given full freedom to express their opinions[v]. Following the inter-ministerial meeting, MoEF enlisted the opinions of ministries, divisions, and concerned sections. The draft of Environment Policy and Action Plan was modified on the recommendations of inter-ministerial meeting. After much deliberation at different stages and comments made by different ministries the final draft was prepared (Islam, 2008, p17).

At the formulation stage, internal actors, the bureaucracy in particular played the crucial role. Though the bureaucracy played the most active role but it was very much influenced by politicians and civil society members. No doubt, policy makers had to give considerable attention to the recommendations made by international and regional actors, but the policy document was prepared keeping in mind of our own environmental situation.

Table- 3 presents the actors and factors involved at policy formulation level and their role.

Policy Approval

Policy can be approved at different levels. In Bangladesh, secretaries to the government (basic functional policies), ministers (substantive ministerial), Standing Committees of Ministers, cabinet (major inter-sectoral and policies with inter-ministerial implications), National Economic Council (NEC), National Implementation Committee on Administrative Reforms (NICAR) are involved at the policy approval level.

The Environment Policy 1992 was approved by the cabinet. After preparing the final draft, it was placed before the cabinet and discussion was held among the cabinet members. Different comments were passed in favor of and against the policy. Despite differences of opinion, the policy was unanimously approved on April 13, 1992 at the cabinet meeting.


This section attempts to draw broad conclusion of the study by presenting the important findings.

The findings of the study boil down to the following conclusions:

A large number of actors and factors were involved in the Environment Policy formulation process. These can be divided into external and internal as well as formal and informal types (Islam, 2007, 100). Among all the actors, United Nations and its specialized bodies and the bureaucracy played the most critical and decisive role. Informally, the civil society also exerted considerable influence in shaping the policy content.

Whatever may be identified as motivating actors/factors for the environment policy, United Nations and selected donor agencies were active behind the scene. Their thinking and doings greatly influenced the government (Islam, 2007, 100) and that got reflected in the policy document. The specialized bodies of UN had also indirectly influenced all the actors and factors.

As a matter of fact, ‘Environmental Policy of 1992’ was not an outcome of the effective participation of all disadvantaged stakeholders e.g. farmers, weavers, small traders, fisher folks, village women, and professionals. But, the point that must be taken note of is that selected NGOs had also played an important role. NGOs played a strong role in influencing the government’s position from policy initiation to approval process through participating.

Actors, factors and their role presented in above-mentioned tables could be summarized in figure 2.

The study revealed that there were interrelationship between and among the major actors and factors (Islam, 2007, 100). For example, ‘enthusiasm of bureaucrats’ was the result of the political will of the party in power, interest shown by donors, and certain important decisions of GoB and UN agencies. On the other hand, ‘political will’ of the party in power was the outcome of the certain important decisions of the GoB and UN, and interest of donor agencies. Critics tend to complain that GoB makes commitment at different international and regional forum without considering its capability and in most of the cases the government fails to translate those commitments into specific action.

The findings of this study, however, disprove the fact keeping environment policy in focus. It was revealed from the study that the GoB was sincere to its ‘commitment’ on the Stockholm Conference protocols and preparatory committee meeting of UNCED. In response to its commitment, GoB formulated its Environment Policy before the Rio Conference held in 1992 (Islam, 2007, 100).

Table-3: Actors and factors involved at policy formulation of Environment Policy 1992

Actors Factor Role Played
MoEF, DoE, Bureaucrats •     Country report prepared by government

•     NCS, NEMAP, Fourth five Year Plan

Draft preparation

Give inspiration

Consultants •       Draft preparation
Concerned Ministries •     Inter ministerial meeting Opinion
NGO and Civil society members •     Inter ministerial meeting Opinion
ADAB, and NGO affairs Bureau •     Recommendations of workshop organized by NGOs Policy input
Regional Organization :ESCAP, SAARC •     Recommendations Policy input
Regional Countries •     Environmental policy, laws, and acts collected from India, Sri Lanka, Nepal, Singapore, Thailand, Pakistan  
United Nations •     Recommendations of Stockholm conference

•     Recommendations of World Commission on Environment and Development

•     Preparatory committee meeting

Donors •     Condition imposed on loan agreement Financial support

Table-4: shows actors and factors involved at policy approval level and their role (Islam, 2008, p17).

Actors Factors Role Played
•     Cabinet members

•     Prime Minister


Figure -2: Actors, factors and their role in policymaking process

The Environment Policy was conceived not from perceived immediate necessity but because of external pressure, which was channeled through the international development, aid, lending agencies and NGOs. As a result, the perspective of national planning, resource availability, and allocation principles became secondary consideration and consequently environmental policy proved highly ambitious.

The study highlighted that ‘personal relationship’ of NGOs/civil society with the government could be considered as an important factor in achieving policy goals. Personal relationship of some NGO personalities with the then government worked as a motivating force to make the government politically committed towards making a national policy on environment (Islam, 2007, 100).

Political leaders exhibited somewhat contradictory attitudes during the environment policy formulation process. When the leaders were in power, they acted as ‘catalysts’ for making the environment policy, and the same people in the opposition tended to maintain an inactive role in influencing the policy issues concerning environment.

Power elite--President, Vice President, Ministers, Prime Ministers, senior bureaucrats--of the government did show a noticeable interest in environmental issues. Their interest about Environment Policy trickled down to the lower level of the administration, which in turn ensured the quick and timely formulation of the policy (Islam, 2007, 100).

During the period when the policy was formulated, there was an acute shortage of environmental expertise in Bangladesh, both inside and outside the government. A team headed by the same person produced the National Conservation Strategy, early drafts of National Environment Management Action Plan, and the first draft of Environment Policy. Although the contents of these reports were presented in different structures and forms, the findings, conclusions and future strategies were fairly similar. Early drafts of the three documents were the brainchild of the same persons and remained essentially within same mode of thinking.

Findings of this study tend to prove that international pressure is not always harmful; sometimes it can bring good results for a developing country like Bangladesh. A significant number of important policy measures taken since independence in Bangladesh were found to be donor driven which in turn emphasized the need for Bangladesh’s capacity to coup up with advancements in challenging international context (Islam, 2007, 100).

It is often heard that irrationality and traditional thinking persist even among the highly educated bureaucrats. Bureaucrats are very much confined within themselves and are not interested in cooperating with the NGOs/civil society members. But this study reveals the fact that if situation demand bureaucracy could go beyond their limit (Islam, 2007, 100).

Lack of systematic data on natural resources was a hindrance to developing the Environmentally Policy. Because of the lack of strong data bank, the government had to collect relevant data, information and documents from Netherlands, Singapore, India, Pakistan, Sri Lanka through Bangladesh High Commission for preparing the policy, which was very much a time consuming process.

The government acknowledged that an effective plan could be made with the combination of theoretical knowledge and practical experiences. In the formulation of Environment Policy, the practical experience of the NGOs/civil society and the wisdom of experts have been blended together, which is another learning for Bangladesh

The study noted that international consultants are not necessarily an imperative for producing a policy document. The government did not hire any international consultant and engaged only two national consultants for a short period of time. Virtually the policy document was produced by the taskforce with the help of NGO/civil society members.


Based on the empirical observations, the study put forward the following broad policy options and recommendations:

Policy should be a synthesis of perceptions of the government, NGOs and the people on environmental issues and the actions required to address them. A proactive public consultation process, where people would have an opportunity to define their environmental concerns, prioritize problems, and suggest solutions, should be created.

In the whole policy formulation process, both the politicians and bureaucrats showed to a great extent a supportive attitude. So attempt should be made to create and keep a favorable policy environment to elicit the best performance from them.

The government should attach due importance not only to consultations with NGOs/civil society but should also be serious in developing institutional means to consolidate their views in the policy-making process.

NGOs play an important role in creating public awareness. Technical assistance could be provided to further enhance the NGOs’ knowledge of the environmental and legal matters and to promote their participation in the development process.

Environmental policies must be made on the basis of the country’s environmental and natural resources’ profiles and other information on developmental priorities. For realizing this purpose, existing information and expertise can be used to initiate an environmental information system and greater importance should be given to environmental research.

Cooperation between the government and the donors was found to be effective and should be strengthened to further ensure technical, administrative, financial support for sound environmental planning and policy.


Like many other policies in Bangladesh, the bureaucracy played the most crucial role in the formulation of the Environment Policy. The other important actors in the formulation of the policy were the selected agencies of the United Nations. In a sense, the UN worked as a source of inspiration, especially the important decision to hold the Rio conference acted as a booster. The United Nations through its decisions, documents, and meetings had influenced the government to formulate the policy. The Environment Policy was thus the outcome of the dynamic interaction among different actors and factors within the government. The special feature of this policy was the first ever-direct involvement of the civil society and NGOs. There is no such culture in Bangladesh public administration to involve and/ or consult civil society and NGOs in policy-making and planning initiatives. Members of the bureaucracy have been traditionally very much confined within themselves and tend to maintain ‘resistance to change” of the system, process and maintenance of their “exclusive domain”. Through the formulation process of the Environment Policy, for the first time in its history Bangladesh government took a progressive step to get the bureaucracy out from the conventional boundary. The participatory approach was followed with the active assistance of civil society members and NGOs. Civil society members and NGOs have been involved in working at the grassroots level keeping direct contacts with the mass people. Such departure of the institutional role of bureaucracy has been a remarkable shift and has set a new perspective in the whole process of policy formulation.

The non-government sector deserves the credit for building awareness not only among mass people but also among the policy makers at the national level. This sector succeeded in convincing the government that Bangladesh should develop an Environment Policy based on participative approaches and models.

From the above analysis following broad conclusions can be drawn:

The focal point of all the governmental activities is people. Thus, for preparing long-term plans and policies due importance should be given to the mass people. Their opinions, practical experiences, and suggestions must be reflected in the policy documents. NGOs and Civil Society can be considered as important agents through which ‘people’s views’ can reach the policy makers. The Environment Policy 1992 has shown a definite space for NGOs and civil society in linking ‘people’ with the government. This researcher strongly believes that policy relevance would be far more if such link is further institutionalized.

External agents especially UN bodies play a non-threatening role on policy process and thus far more effective and as a strategy for external collaboration, government should try to develop and sustain mutually benefiting long term institutional ties with the specialized development agencies under the UN umbrella (Islam, 2997, 101).


[i] Following members of public

[ii] This opinion was expressed by Mr. Fazlul Haq (retired joint secretary)

[iii] Dr. Monwar Hossain (chief, Multidisciplinary Action

[iv] Opinion expressed by M.A.H.Pramanic (director general, DoE)

[v] Opinion expressed by Mr. Fazlul Haque (former deputy secretary of the GoB).