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Phulbari Coal: A Parlous ProjectA critique of the GCM Resources PLC1 Environment and Social ImpactAssessment (ESIA) and Summary Environmental Impact Assessment(SEIA) for the Phulbari Coal Mine Project in BangladeshPrepared by Nostromo ResearchForBank Information Center12 November 20081Asia Energy plc changed its name, first to Global Coal Management, and then to GCMResources plc, the company which now has full management responsibility for the Phulbariproject. The earlier name is used throughout this report where it cites content of the PhulbariESIA and SEIA.

TABLE OF CONTENTSAcknowledgements3Documents Examined3Part I: The Various Pitfalls of Phulbari1.1 Complex Project in a Complex Setting1.2 Vague Assurances and Speculation in the SEIA and ESIA1.3 Over-Confidence in Monitoring and Mitigation Capabilities?1.4 Asia Energy - a Leader in Environmental Practices?1.5 Some Good Research, Undermined by Numerous Qualifications1.6 Four Unanswered Fundamental Questions1.7 Politics—there‘s the Rub1.8 The Burden of Global Greenhouse Gas (GHG) Emissions (GGE)1.9 In bed with Methane?1.10 Phulbari Land: Lost - and not Found1.11 Employment: a Numbers Game1.12 Additional Value?1.13 Water, Water Everywhere - but How Much to Drink?1.14 Failures to Identify and Prevent Acid Rock Drainage1.15 When the Earth Moves1.16 Air Quality Impact: An Unhealthy Proposition1.17 Sacred Spaces: Impacts on Archaeological and Other Sites of Significance1.18 Post—Mine Rehabilitation: no True ―Closure‖456778101012121415151819212223Part II: Coal Transportation ESIA2.1 The High Risks of Estimating ―Risk‖2.2 The Sunderbans Factor: Potential Impacts on Wetlands2.3 The Dangers of Dredging and Dumping242527Part III: Conclusion3.1 Securing the True Wealth of Bangladesh3.2 Summary of Key Points22930

AcknowledgmentsThis report was commissioned by the Bank Information Center (BIC) and prepared by RogerMoody of Nostromo Research, UK. The author is grateful to Dr Robert Goodland, ShefaliSharma, Mishka Zaman and Jennifer Kalafut for their comments on earlier drafts. BIC monitorsthe IFIs in partnership with civil society in developing and transition countries. BIC‘s objectivein commissioning this work was to provide Bangladeshi and international civil societyorganizations monitoring the Project with user friendly expert critiques of the environmental andsocial assessments prepared by GCM/Asia Energy. A critique of GCM/Asia Energy‘sInvoluntary Resettlement Plan for the Project was also commissioned by BIC and is publiclyavailable on its website.2Documents Examined For This CritiqueThe Phulbari Coal Project ESIA (Environmental and Social Impact Assessment) was prepared bySMEC International Pty Ltd, with geotechnical reports commissioned, inter alia, from GHD,MineConsult and Golder Associates. It was published by Asia Energy plc in May 2006, aftercompletion in April 2006. A separate ESIA was prepared to evaluate impacts of the coaltransport project and is referenced in this critique as ―ESIA coal transportation‖. A SummaryEnvironmental Impact Assessment for the Asia Development Bank (ADB) was published by AsiaEnergy plc in August 2006 and is here referred to as SEIA.Content of ESIA volume 4, chapter 1 (the PCDP – Public Consultation and Disclosure Plan, andvolume 4 chapter 4 (Draft Resettlement Plan, under revision at the time of writing this report)have been critiqued separately in Phulbari Coal Project: An Assessment of the Draft ResettlementPlan Prepared by Global Coal Management/Asia Energy Corporation, August 2008, by JenniferKalafut, co-director of the International Accountability Project and commissioned by BIC (US).These chapters are not considered in this critique; nor are the provisions for land acquisition andcompensation, or resettlement measures envisaged for the coal transport project – which have stillto be confirmed. However, the socio-environmental consequences of land acquisition and loss ofrelated resources are addressed here.The present paper also omits any examination of alternatives to the current mine and the coaltransport plans, as considered by the project proponents. Volume 2 chapter 2 - the feasibilitystudy (Revision B) prepared by GHD Pty Ltd (a leading Australian professional servicescompany) on coal geology and resource assessment – is in draft only, and therefore only brieflycitedStyle note: Statements which point to apparent weaknesses in the ESIA or SEIA arehighlighted in this critique using bold italics.2Phulbari Coal Project: An Assessment of the Draft Resettlement Plan Prepared by Global CoalManagement/Asia Energy Corporation November 3, 2008 (Acrobat pdf, 375 KB), InternationalAccountability Project, 3

PART ONE: The Various Pitfalls of Phulbari1.1 Complex Project in a Complex SettingThe integrated Phulbari coal mine, coal rail-river transport and coastal coal offloading project, isof such dimensions that it would prove highly challenging even for a ―developed‖ country: itposes not only numerous socio-environmental problems, but also demands a highly sophisticateddegree of regulatory adhesion, long-term monitoring and component implementation. Amongits design components are a mine with a life of at least 36 years [ESIA vol 1, chapter 1 page 8]3,at a maximum extraction rate of 16 million tonnes of coal per year at peak output, to depths of300 metres [ibid page 10]; and 5, 192 hectares of land required for mine development [ibid.] Anadditional 741 hectares will be requisitioned for town extension, new villages and transportinfrastructure. Although ―[e]nvironmental and social impacts associated with [these elements ofthe project] have not been assessed in detail in this ESIA‖ [ibid page 6], we are supposedlyreassured that ―sufficient information and assessment has been undertaken to demonstrate thatviable settlement design and coal transport options are available‖ [ibid; see also ESIA vol 1chapter 11]. Yet the project is being proposed, in its present form and dimensions, for a lesserdeveloping country with a poor record of environmental compliance and considerable weaknessesin regulatory enforcement. This is recognised in both the SEIA and the ESIA where it is stated(inter alia) that:―Many [Bangladeshi] laws are outmoded and most are not understood or are currently notenforced in terms of functional authority (IUCN2005)‖ [ESIA vol 1, chapter 2, page 5]―Bangladesh is inconsistent [in implementing] rules and regulations in many fields.‖[SEIA para 265]― Open cut mining is new to Bangladesh. Much of the mining legislation is outdatedand does not address contemporary issues such as rehabilitation, overburden placementand mine site water management‖ [ibid]―Water: There is no overarching water Act in Bangladesh ‖ [ibid page 9]―There is no legislation or policy directive in relation to aquifer operations‖ [ibid page10]―Although the Acquisition and Requisition of Immovable Property Act 1994 is the mainlegislation used for land acquisition, it has shortcomings that may hamper the properresettlement and rehabilitation of the affected people.‖ [ESIA vol 1, chapter 2, page 12]―Bangladesh is not a signatory to the Safety and Health in Mines Convention of 1995.‖[ESIA vol 2, chapter 7, page 80]3Page numbers in the ESIA are those appearing on the soft (on-screen) version of the report.Attempts to secure a hard copy of the full ESIA from the Asian Development Bank provedunsuccessful. The pdf version of the ESIA, as provided by the ADB, has been ―locked up‖ toresist either printing out or conversion to text by using any currently available softwareprogramme known to the author‘s IT advisor.4

Who, then, is to address these deficiencies, in the context of the most challenging mining projectthe country has ever faced? In most respects the operating company, Asia Energy plc, shouldcome up with management plans (MPs) to mitigate numerous legislative deficiencies, specificallyin relation to water management and many aspects of the coal transportation scheme.While ―the decision-making process of the government of Bangladesh (GoB) is not within thecontrol of Asia Energy (sic)‖, something admitted to have ― major implications for the grantingof the numerous government approvals required ‖ (ESIA vol 1, chapter 15, page 5), nonethelessthe company is expected to assist the GoB in building a range of capacities and instrumentalities,including acquisition of land titles [ESIA vol 1, chapter 2, page 13] and even framing new mininglegislation. It is quite extraordinary that the SEIA and ESIA envisage these highly demandingtasks be entrusted to a private company, rather than an established state enterprise or experiencedinternational agency. (One suspects, however, that the World Bank might resist such an invitationin view of its signal failure to implement capacities for Coal India Ltd through technical and2001[see: http://www.brettonwoodsproject.org/art-16077 ].1.2 Vague Assurances and Speculation in the SEIA and ESIAOf equal concern should be the degree to which the SEIA and ESIA depend on vague assurancesand a high degree of speculation about future measures that might (or, might not) be adopted tomitigate problems in the proposed overall project design. There are many instances of this todemonstrate that the ―Precautionary Principle‖ and the concept of ―Intergenerational Equity‖(―The present generation should ensure that the health, diversity and productivity of theenvironment is maintained or enhanced for the benefit of future generations‖ [ESIA vol 1, chapter3. page 5]) have merely been paid lip service.For instance:* ―The mine water balance indicates that water will be available throughout the drythus a third irrigation of crops should be possible‖ [ESIA, vol 1, chapter 6, page 60]:season,* ―Beels [wetland ponds] will be retained and maintained wherever possible‘ [SEIA paragraph107 (ii)]* ―Local indigenous species will be given priority where feasible [other species of trees andplants] will be planted where possible‖ [SEIA para 107 (vi)]* ―The proposed barging and shipping operations are considered unlikely to have any significantadverse impacts [on river hydrology et al]‖ [SEIA, para 144]* ―Small areas [of land] especially the area north of the mine site could be inundated [because ofland settlement resulting from extraction of groundwater] during a 100 year flood‖ [SEIA para84]* ― mine dewatering flows are unlikely to cause any hydrologic or hydraulic problems ‖[SEIA para 85]5

* ―The adverse effects of aquifer induced land subsidence can be minimised by adoptingappropriate remedial measures, such as installation of recharge wells and dykes‖ [ESIA vol 2,chapter 5, page 91]* ―The rail corridor operations are unlikely to cause gross groundwater contamination ‖[SEIA para 123]* ―The preliminary contamination assessment indicates that soil contamination is unlikely at theCoal Terminal site‖ [ESIA Coal transportation, chapter 9, page 16]* ―Where possible, place stripped soils into rehabilitation areas and re-vegetate immediately‖[SEIA Appendix 1- 2]* ―There is the potential for generation of employment opportunities created directly andindirectly by the Project. Indirect employment may be created due to availability of coal and otherby-product industries ‖ [ESIA vol 1, chapter 10, page 110]* ―Mines can generally be rehabilitated so that most of the affected and can be returned to theoriginal or alternative use‖ [ESIA vol 1, chapter 14, page 11]* ―It is not expected that combined ambient and mine emissions will be greater than the 24 hourmaximum World Bank limit‖ [ESIA vol 1, chapter 15, page 10]* [Re adverse groundwater drawdown]: ―This issue has a high severity/consequence of affectinggroundwater resources available to Phulbari and village communities surrounding the mine.Despite this there is a high degree of confidence that proposed aquifer injection and irrigationschemes will mitigate potential impacts‖ [ibid]* ―The impact of dewatering the Permian sediments are expected to be largely contained withinthe basin‖ [ESIA vol 2, chapter 3, page 32]* ―[T]he long term impacts of increased water levels [in the rivers] are unknown; it is possible inthe long term that there may be impacts to primary productivity with consequent impacts tospecies diversity, abundance and to fish production‖ [ESIA vol 3, chapter 3, page 135]* ―It is not likely that an oil spill would result in extreme mortality (sic) of established mangroveforests‖ [ESIA, chapter 12, page 53]1.3 Over-Confidence in Monitoring and Mitigation CapabilitiesThese are by no means the only examples of a lack of authority, or defects in evaluation,evidenced in the assessments. Clearly, the more frequent the speculative elements, the greater thepressure placed on GCM/Asia Energy, and its sub-contracted parties, to properly implement theproposed EMPs (environmental management plans) - specifically those relating to coaltransportation, which are supposed to be updated on an annual basis [ESIA volume 1, chapter 14,page 5]. An inordinate amount of confidence (compared with many other projects of this type) isbeing vested in the quality of monitoring of ―trigger‖ events, and the capacity of variouspersonnel to recognise such events, and then swiftly pre-empt them. Even the most accomplishedauthorities, or experienced mine managers, may have little or no prior warning of critical failures6

- such as the collapse of a waste dump, landslide of mine workings during a torrential downpouror earth tremor, or collision and capsizing of vessels at sea or in the river.1.4 Asia Energy – a Leader in Environmental Practices?Insofar as adverse – potentially severe consequences – from such eventsfall on the company, rather than the government, then the report‘s baldassurance that Asia Energy/GCM Resources plc is ―a leader inenvironmental practices‖ is highly questionable and verges on themendacious.It was listed on London Stock Exchange‘s AIM(Alternative Investment Market) only five years ago. It possesses nopedigree, as a company, in operating mining projects of any kind, letalone on the scale of Phulbari. While two members of its board andmanagement do have experience in coal mining, they have not faced theparticular challenges of a multi-faceted endeavour such as Phulbari (withthe possible exception of the Kaltim Prima coal mine in EastKalimantan). Indeed, GHD Pty Ltd, in its estimation of risks containedin the company‘s Admission to Trading document (―the prospectus‖),required before Asia Energy could be listed on AIM, noted that it was:― a recently formed company with a limited operating history uponwhich prospective investors may base an evaluation of its likelyperformance. In addition, the management team of the Group has ingeneral only had recent involvement in the activities of the Group.‖[Prospectus, Asia Energy plc, 13 March 2004, page 16].It possesses no pedigree, as acompany, in operating miningprojects of any kind, let aloneon the scale of Phulbari.While two members of itsboard and management dohave experience in coalmining, they have not facedthe particular challenges of amulti-faceted endeavour suchas Phulbari (with the possibleexception of the Kaltim Primacoal mine in East Kalimantan)Disturbingly, there is nowhere the recognition that, in view of the lack of the company‘sprovenance, it should post a realistic Bond (insurance) to cover all costs of unpredicted failuresand accidents and all aspects of post-mine reclamation, including compensation claims whichalmost inevitably will be made outside the compensatory process for land loss and resettlement(and which still has to be formulated).1.5: Some Good Research, Undermined by Numerous QualificationsMany elements of the project are well-researched, in particular those examined by GHD, and thediligent biodiversity study by NACOM. But this is not necessarily reassuring, since the deeperthe investigation has gone, in some cases the stronger the need for further research; such as incoping with pyritic material in stockpiles and waste dumps; the consequences of seismicdisturbances within the mine ―footprint‖; or the nature of benthic fauna and flora in the river andseabed earmarked for massive sediment dredging (see below).Taken as a whole, and given the excessive number of qualifications to many of their conclusions,the assessments are by no means encouraging. Even if it were possible to endorse one part of theentire project (such as a mine-mouth power plant), this should not automatically lend credibilityto its other aspects. As currently mapped, the project vests overwhelming economic viability onconveying coal mined in the Phulbari lease areas, through rail to India, and rail and river links tothe south of Bangladesh for sea-borne export from a coastal terminal. A ―worst event‖ (such asmentioned in paragraph 1.3 above) at any stage along this transportation route could reasonablybe construed as being more serious - both in the short and long term - than one occurring at themine itself, and a threat to the viability of the entire scheme.7

1.6: Four Unanswered Fundamental QuestionsClose scrutiny of the ESIA and SEIA elicits many unanswered questions (examined below).Additionally, four fundamental issues - which should have been adequately addressed beforeinitiating project design - remain unaddressed:1) Keeping the home fires burning – but at what cost to water?Will the majority of the mined coal remain in Bangladesh? If so, how much will be absorbed by apossible mine-mouth power plant, and what would be the likely demand on precious undergroundwater resources? Base load figures of 500MW, 1,000 MW and 2,500 MW for such a plant havebeen cited by the company at various times. Asia Energy‘s March 2004 prospectus for entry toAIM envisaged a power plant in two stages, with a total generating capacity of 15,400 GW perhour a year (sic) on completion, consuming nearly 5 million tones of coal per annum. Thisappears to conflict with the SEIA which earmarks 3 million tonnes pa for a 500 MW capacityplant, albeit with some minor local marketing of coal [SEIA paragraph 7].Significantly, the prospectus stated that: ―The power station water demand is expected to be lessthan that produced from aquifer and mine dewatering activities, making the [Phulbari] project selfsufficient in this regard. The majority (sic) of water is used for power station cooling purposes.Cooling tower design to suit local conditions will be carried out in the Feasibility Studies. Surpluswater is available for agriculture and drinking water‖ [Asia Energy plc Prospectus; Admission totrading on the Alternative Investment Market, 31 March 2004]. The ESIA, appearing a year afterAsia Energy‘s listing on AIM, settles for a ―proposed capacity‖ of 500 MW, with the ―potential‖to increase to 1,000 MW [ESIA vol 1, chapter 12, page 5].However, the prospectus excludes any estimation of the critical impacts on water availability andquality, for any mine-mouth power plant, since ―the Phulbari Power Station was not defined atthe time of assessment.‖ [ESIA, vol 1, chapter 12 ibid, page 8.]. Having admitted this, the ESIAnonetheless blandly asserts that the station‘s demand for cooling water – estimated at 40 M/l aday for a 500 MW plant - would be ―sourced from groundwater, either from the mine dewateringsystem or a new tube well field south of the mine footprint‖ [ibid].Implementing either one of these alternatives would arguably cause unacceptable attrition onavailable water supplies. We are told that: ―Installation of a new bore field to the south of thePhulbari Power Station has the potential to exacerbate the water drawdown in this area incomparison to that modelled for the Project alone.‖ The only consolation offered is that ― theaquifer system may make more water available in this area‖ [ibid]. Given existing deficiencies inwater availability, and the plethora of unaddressed issues over water requirements for the mineitself, it is highly likely that operating a captive power plant (even with a modest 500MW designoutput) would prevent adequate water reaching agriculture, fisheries, local industry andhousehold. (For further discussion see ―Water‖ section below).2) How much of the product coal will actually remain in Bangladesh or be transported by landto India?That ―the mine would not be viable without export revenues‖ has become the project‘s mantra[Phulbari Coal Project, Feasibility Study and Scheme of Development, Executive Summary,October 2005, page unnumbered]. According to the feasibility study, the majority of the output (8million tonnes) is earmarked for marine export [SEIA paragraph 7]. Indian buyers are presumedto become ready purchasers of some 4 million tonnes of Phulbari coal [SEIA ibid] with around 38

million (at full output) remaining in the country, ―some for a possible mine-mouth power plant‖[Phulbari Coal Project Feasibility study op cit]. However, these calculations were made in 2006.New Indian coal fields have been opened, or expanded, during the two years since, while theworld‘s biggest exporters of thermal and metallurgical coal (Xstrata, Rio Tinto, BHP Billiton)have all significantly increased production to meet rising global demand. This is not the place torehearse arguments over the economic viability of the project‘s export component. Nonetheless, itseems clear that the environmental, land acquisition and ―resettlement‖ impacts of the proposedrail-river-sea linkages are very damaging – and these have export as their only rationale. (Itshould also be noted that the Asian Development Bank‘s policy (Energy Policy 1995) regardingits funding for Coal projects requires that the project be a mine-mouth project primarily gearedtowards domestic production. It therefore seems likely that the power plant proposal was insertedinto the SEIA to ensure that the private sector department of the ADB could justify its funding,even though the technicalities of the project are geared towards coal exports.).3) How much (if any) of the metallurgical grade coal will be utilised within Bangladesh, thusproviding potential value addition? Which (if any) industrial plants are realistically on thedrawing-board as customers of such coal?Tata has now withdrawn a 2004 proposal to exploit Bangladesh‘s gas reserves for its ownpurposes, and to use metallurgical quality, ―coking‖, coal for a steel plant(s). Although the Indiancompany planned to access this supply from north-eastern Bangladesh, Tata was a potentialcustomer for Phulbari. Calculations of how much metallurgical grade coal might enter the marketdo not exist - primarily because there are no confirmed customers for it within Bangladesh.4) Going underground?Has it been proven that the Phulbari ore body is not amenable to underground exploitation?Comparisons are drawn in the ESIA with the nearby Barakupuria underground coal mine whosepollution, and accident rates, have clearly been unacceptable. But the arguments presented againstunderground exploitation of Phulbari coal itself appear flimsy, under-rehearsed, inadequatelytested, and motivated by economic rather than technical or socio-environmental concerns – to theextent that open-pit mines are far cheaper to construct and manage.Asia Energy‘s rationale for rejecting underground mining was summarised in the SEIA asfollows: “Extraction of coal with the underground mining methods was considered but ruled outon the basis of poor coal resource recovery, low production rates, and the fact that groundcaving following coal extraction would eventually interact with the highly permeable Tertiaryaquifer system. This presents an unacceptable operational risk associated with ground collapseand mine flooding” [SEIA para. 201]. To “reduce the degree of breaching of the overlying rock,an underground mine at Phulbari would require maintaining significant ground-supportingpillars, resulting in difficult mining conditions and low coal production. It is estimated that a coalrecovery ratio of less than 10% would be achieved; thus, most of the in-situ coal reserve wouldnot be extracted and the majority of this valuable resource would be left under the ground withno way of extracting it” [ibid para 202]. It was further claimed that: “Underground longwallmining can also cause land subsidence, the extent dependant on the depth of coal, overlyingstrata and width and height of the longwall. Subsidence can cause damage to structures andsignificant hydrological and land use impacts. At Phulbari the depth to the most significant coalis around 150–250 m and land subsidence of several meters could be expected.” [ibid para. 203]These are all critical considerations; the most important of which is the possibility of post-mineground subsidence. But, without provision in close detail of the alleged ―difficult [underground]9

mining conditions‖ and measures that might be taken to compensate for them, it is impossible tojudge whether the assumed recovery ratio of ―less than 10%‖ is realistic, or intentionallypessimistic. While it is true that modern underground longwall mining often results in subsidence,defenders of the technology claim that this can be ―controlled‖, and its worst impacts pre-empted.Coal recovery rates are also considerably higher than from typical ―room and pillar‖ extractionmethods.This is not to implicitly defend an underground mine at Phulbari. It is, however, to point out thatGCM/Asia Energy appears to have treated this option with cavalier disregard. Moreover, twojustifications given for rejecting the underground alternative - adverse impacts on the tertiaryaquifer system and the likelihood of severe water ingress to the workings – themselvesundoubtedly apply to the present open-pit proposal.According to one Bangladeshi mineral geologist, who maintained close contact with BHP (nowBHP Billiton) when the Australian company was assessing the Phulbari deposit in the 1990sbefore the license was handed over to Asia Energy: “We knew BHP would not be able to fulfilenvironmental requirements similar to Australian standards for strip mining at more than150metres below the ground. BHP could not locate a shallow coal deposit around 100m depth;the Phulbari deposit is much deeper between 150m and 260m. BHP knew very well that an opencut mine at such depth would need multi-dimensional long-term environmental studies besidestackling geological and engineering problems. Considering flood-prone deltaic region havingnumerous rivers with heavy monsoon rainfall, it is easy to understand that it would be ratherimpossible to pass environmental regulations of any country, not to speak of comparableAustralian standards.” [Nazrul Islam ―Reflections on Phulbari Coal Project‖, New Age, Dhaka,14 September 2008].1.7 Politics – there’s the KeyThese, and other, questions carry clear political connotations. So long as the citizens ofBangladesh fail to agree a comprehensive energy policy (or are inhibited from doing so) - andthen a national coal policy – the questions cannot be answered. Vital decisions have still to bemade through a truly democratic process, freed from the intimidations and human rights abuseswhich have characterised much of the Phulbari discourse (or lack of it) to date. Anenvironmental critique of the project as it stands can certainly make important judgments. Forinstance, abandoning the sea borne export segment of the project would avoid pollution risksposed to the Bhairab-Rupsa-Pussur river system, and more particularly to the SunderbansProtected Forest (SPF), a Ramsar Convention/World Heritage site.It could be argued that Asia Energy was not required to test this, or other, alternatives; in any casethey fall outside the company‘s remit [see: SEIA paragraph 112]. Nevertheless, until a coherentnational energy and subsequently a coal policy are determined, the strong impression will persistthat the company, with the backing of some in the Bangladesh administration and the explicitsupport of the British government, has been driving its own furrow through Phulbari and beyond guided overwhelmingly by its own commercial considerations.1.8 The Burden of Global Greenhouse Gas (GHG) Emissions (GGE)The World Bank‘s Extractive Industries Review (EIR), performed under the aegis of Emil Salim(a former Minister for the Environment in Indonesia and director of a national coal company) was10

submitted to the Bank in January 2004. It set out a ―pro-poor‖, environmentally sustainableagenda for the Bank‘s investments. Among its recommendations was the immediate phasing-outof loans for coal projects and new funding to be provided for generating renewable energy. Theneed to ―de link‖ coal-fired plants from their role in generating GHG/GGE was a keyjustification, provided in the EIR, for advising a change in the Bank‘s lending policies [―TheExtractive Industries Review: Striking a Better Balance‖, World Bank, January 2004]. Althoughthe Bank rejected this recommendation, it has more recently (however shakily) ―show cased‖ itsconcerns about increased global warming. Many other authorities have also pointed to theuniquely heavy contribution that coal burning makes to adverse climate change, which is widelyrecognised today as the largest single environmental threat to the planet.It is, therefore, puzzling – to say the least – that the potentialIt is increasingly accepted (e.g. bycontribution of the Phulbari project to additional globalgreenhouse gas emissions (both at construction phase and as anthe UK Carbon Disclosureoperating mine) is barely considered in the ESIA; and where itProject) that embedded carbonhas been, is minimised. Nor is there any consideration ofGHG carbon capture and sequestration (CCS) - although it values in coal should be taken intoshould be noted that a number of authorities question theaccount when judging a company,viability of this largely untried technology. In the context ofor project‘s, likely contribu

3.1 Securing the True Wealth of Bangladesh 29 3.2 Summary of Key Points 30 . 3 . SMEC International Pty Ltd, with geotechnical reports commissioned, inter alia, from GHD, MineConsult and Golder Associates. It was published by Asia Energy plc in May 2006, after . Management/Asia Energ