BANGLADESH SUSTAINABLE ENERGY SUPPORT PROGRAM (P172183) Synthesis Report Table of Contents S. No. Title Page 1. Introduction and summary of activities 2 2. Pillar I: Sustainable Energy Transition 5 2.1. Appliances EE financing incentive mechanisms and buildings EE 5 rating guide and certification system 2.2. Assessment of battery storage options 10 2.3. Enhancing Renewable Energy Investments and Access to Land in 12 Bangladesh 2.4. Integrated system planning and analysis 15 2.5. Review and strengthening of regulatory frameworks 16 3. Pillar II: Roadmap for Meeting Energy Needs of Refugees and Host 18 Communities 3.1. Productive Use of Energy for Livelihood Generation and Quality of Life: 19 A Case Study on Cox’s Bazar 3.2. Review of Energy and Electricity Programs and Infrastructure for 20 Refugee Camps and Host Communities in the Vicinity 4. Pillar III: Public-Private Partnerships 21 5. Annex 23 1 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 1. Introduction and summary of activities (1/3) Development Objective: The objective of this programmatic ASA is to increase the capacity of the government of Bangladesh and its agencies to plan and implement policies and regulations, system operations and investments for sustainable energy development, access and transition. Brief description of activity: This programmatic ASA consists of analytical and capacity building activities supporting the Government of Bangladesh and its agencies in their efforts on sustainable energy sector development and transition, including lower-carbon development pathways. The activities under this ASA are organized under three pillars (Sustainable Energy Transitions, Roadmap for Meeting Energy Needs of Refugees and Host Communities, and Public-Private Partnerships ) and eight activities spanning power system planning, energy efficiency, emerging renewable energy technologies and energy storage, and institutional capacity building, regulatory reforms and energy market development. Table 1: Summary of funding sources and amounts Source Trust fund Amount (US$) PPIAF TF0B7820, Bangladesh : Enhancing Renewable Energy Investments and Access to Land in 300,000 Bangladesh TF0B7296, CREST - Bangladesh : Strengthening the PPP Institutional and Regulatory 50,000 Framework TF0B7295, Bangladesh : Strengthening the PPP Institutional and Regulatory Framework 300,000 ESMAP TF0B2221, Bangladesh : Energy Transitions 760,000 TF0B0886, Bangladesh – Roadmap for meeting energy needs of refugees and host 325,000 communities CIF-TA Facility TF0B4450, Implementation support on Building Energy and Environment Rating System in 350,000 Bangladesh and a Cool Roof Program in Dhaka-TAF Global Infrastructure TF083000, Bangladesh : Strengthening the PPP Institutional and Regulatory Framework 150,000 Facility Total 2,235,000 2 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 1. Introduction and summary of activities (2/3) Table 2: Summary of Deliverables and Outputs Deliverables Output documents Activities informed Pillar I: Sustainable Energy Transitions 1. Implementation i. Implementation support for Building Energy Efficiency and - Green and Climate Resilient support for energy Environment Rating (BEEER) System: Final Report Development Policy Credit (DPC) efficient green buildingsii. Green Building Rating Systems: Global Review of Experiences, (P179079) program and appliance Strategies and Implementation Practices - An update to the EE and Conservation standards, labeling and iii. Developing a Cool Surface Program for Energy Savings and UHI Rules rating systems Mitigation in Dhaka - A draft framework MEPS regulation to set iv. Cool Roofs Programs: Global Review of Experiences, Strategies and the basis for appliances categories, and Implementation Practices the specific standards and labels for v. Supporting BEEER System through Large-Scale Implementation of appliances. Appliances MEPS and EE Labelling Program - A draft Building Energy Efficiency and vi. Assessment on the building sector potential for GHG emission Environment Regulation (BEEER). mitigation in Bangladesh vii. Online Training on Buildings Energy Simulation viii. Knowledge Exchange on Sustainable Buildings and Energy Efficient Cooling ix. Training on passive building design strategies x. Financing Mechanisms & Role of Banks in promoting uptake of EE Appliances xi. Standards and Labeling: Transforming the Market for Energy Efficient Appliances 2. Assessment of battery i. Study of Distribution Network Climate Resilience and Distributed - A component to support BESS pilots in storage options Energy Resources in Bangladesh the Electricity Distribution Modernization ii. Assessing the value of BESS in the Bangladesh Distribution System Program (P174650) P4R. iii. ToR for “Accelerating the role for energy storage, grid-connected solar - A US$13 million bilateral grant from pv, and other distributed resources to support energy transition in Korean Institute of Advanced Bangladesh” Technologies (KIAT) to fund BESS pilots in BREB’s network. - A study on BESS co-funded by the Climate Support Facility (TF0B6148) and ESMAP (TF0B5508). 3 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 1. Introduction and summary of activities (3/3) Deliverables Output documents Activities informed Pillar I: Sustainable Energy Transitions 3. Enhancing RE i. Access to Land for Renewable Energy Investments - Encouraged by this study, Power Cell is investments and access to ii. Preliminary Bangladesh Land Administration Action Plan starting a detailed feasibility study at land in Bangladesh iii. Renewable Energy (Solar) Site Identification Methodology and Jamalpur. Application to Jamalpur Site - Ongoing dialogue on structuring PPP/JV iv. Repurposing of Coal Power Plant Sites for Renewable Energy RE projects with competitively selected private sector partners. 4. Integrated system i. Workshop on GIS and climate risk for planning energy assets in - It was agreed the GIS asset at PGCB planning and analysis Bangladesh would be deployed in the Transmission Grid Enhancement & Modernization Project (P179429). 5. Review and i. Report on stocktaking of institutional and regulatory reforms in the - This activity produced a reform roadmap strengthening of regulatory electricity sector in Bangladesh to strengthen Bangladesh’s institutional frameworks ii. Report on assessment of the readiness of the institutional and and regulatory framework which regulatory framework in the electricity sector in Bangladesh to continues to inform sector dialogue. respond to emerging challenges and opportunities iii. Roadmap for Institutional and Regulatory Reforms Pillar II: Roadmap for Meeting Energy Needs of Refugees and Host Communities 6. Assessment of energy i. Productive Use of Energy for Livelihood Generation and Quality of - Additional Financing of Emergency needs and options of host Life: A Case Study on Cox’s Bazar Multisector Rohingya Crisis Response communities and refugees ii. Review of Energy and Electricity Programs and Infrastructure for Project (P171779). in the Cox's Bazar region Refugee Camps and Host Communities in the Vicinity - Energy need assessment in Bhasan Char iii. Present and Future of Cox’s Bazar Energy & Electricity Service for 100,000 Rohingya refugees. - Host And Rohingya Enhancement Of Lives Through A Multi-Sectoral Approach (P501274) project, under preparation. Pillar III: Public-Private Partnerships 7. Potential PPP Pipeline i. Bangladesh Potential PPP Pipeline Report - Two bridge projects have been identified Report ii. Addendum - Bangladesh Potential PPP Pipeline Report as potential PPP projects and the RHD 8. PPP handbook, i. Bangladesh PPP Handbook has requested a project definition grant operational manual & (PDA) from GIF to assess their feasibility. Training 4 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2. Pillar I: Sustainable Energy Transition 2.1. Appliances EE financing incentive mechanisms and buildings EE rating guide and certification system Introduction and context: - The government of Bangladesh aims to reduce primary energy intensity by 15% by 2020 and 20% by 2030, since demand-side energy efficiency (EE) can play a significant role in supporting Bangladesh’s sustainable energy transition in a cost-efficient manner. - To do so, the Energy Conservation Act (2014) provides a policy framework, and the Sustainable and Renewable Energy Development Authority (SREDA) was established to implement programs and formulate policies. The SREDA EE & Conservation Master Plan 2015-2030 proposes regulatory measures like energy audit, building rating and labeling system, and financial incentives. - In this context, SREDA has requested the World Bank’s support for the development of the institutional framework, delivery tools, business models and financing mechanisms related to Green Buildings Rating System and Labeling System of Appliances. Objective and Scope: This activity aimed to: 1. Provide implementation support for the Building Energy Efficiency and Environment Rating (BEEER) System, including baseline survey of energy use; development of a user manual; web-based development for application submission and assessment (Section 2.1.1); and assessment of potential for reducing cooling loads through cool surfaces in urban areas (Section 2.1.2). 2. Provide implementation support on Appliance Minimum Energy Performance Standards (MEPS) and EE Labelling (Energy Star labelling), including related awareness generation, capacity building and institutional frameworks (Section 2.1.3), and design of innovative manufacturer or consumer-based EE financing incentive mechanisms and delivery models (Section 2.1.4). Outputs: - This activity informed the measures to increase energy efficiency under the Green and Climate Resilient Development Policy Credit (DPC) (P179079). - The government of Bangladesh has approved an update to the EE and Conservation Rules, and is working on a framework MEPS regulation to set the basis for appliances categories, and to issue specific standards and labels for appliances. - A Building Energy Efficiency and Environment Regulation informed by this activity is expected to be adopted. 5 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.1.1. Implementation support on Building Energy Efficiency and Environment Rating (BEEER) System Objective and Key findings and recommendations: Scope: 1. Detailing of credits requirements: The 51 evaluation criteria (called credits) for applicant - SREDA has developed a buildings need to be described more clearly and in more detail. Pilot implementation of BEEER will green building rating system help in identifying further gaps and barriers, which should be used to create a detailed user guide. called the Building Energy 2. Implementation: The draft BEEER document and Environment Rating proposes a basic implementation framework, but System (BEEER) to improve more details are needed on stakeholder roles, public awareness about the especially for third parties, and it should be integrated energy and environment into the existing building permit process (see figure). performance of buildings, 3. An online registration and certification tool should be developed for BEEER in phased manner, and to benchmark it against starting with a web-based application form, then introducing calculators to estimate outcomes of the standard requirements select credits, online certification tools with basic, and finally advanced analysis capabilities. defined in BNBC. 4. Awareness and training: A detailed plan for capacity building of stakeholders has been proposed, - This study aimed to review whose summary is in Annex A.1. the draft BEEER document 5. Review, inspection and surveillance processes need to be elaborated in more detail; the review to identify potential gaps and and inspection process should be split in two phases – design/construction phase and post- use global best practices to construction phase; building performance assessment should also be done during the operations provide recommendations phase; and queries by applicants should be published online as BEEER FAQ. for strengthening the design and implementation of 6. Incentives: Property tax incentives, expedited permitting, and waiver of permitting fee should be BEEER system. considered for accelerating adoption of BEEER. 7. Monitoring, reporting and verification (MRV): An MRV system should be developed for BEEER. An action plan for addressing market barriers for energy efficiency is presented in Annex A.2. Scenario Energy savings (million kWh) Annual GHG emission reduction (tons of CO2 equivalent) Table 3: Potential impact of BAU 11 6,070 adoption of Moderate 214 120,000 BEEER Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report Optimistic 1029 590,000 2.1.2. Developing a Cool Surface Program for Energy Savings and Urban Heat Island (UHI) Mitigation in Dhaka Objective & Scope: Key findings and recommendations: - Large-scale deployment of 1. Benefits of cool surface solutions: Cool roofs can enable 7% to 15% savings in total cooling cool surfaces for buildings costs of the top floor of a multi-story building. Application of cool roofs, cool walls, green surfaces, can improve thermal comfort cool pavements etc. at the district or city level can reduce the overall temperature by 2–3 ⁰C. while achieving energy 2. Barriers to adoption of cool surface in Bangladesh include high cost, and lack of enabling savings, enhancing energy factors such as awareness, proof of concept, service providers, testing facilities, policy enforcement, security and promoting and technology promotion. climate resilience. 3. Recommendations to promote adoption of cool surface solutions in Dhaka: - SREDA has set a target of - Short term (1 to 3 years): Development of testing standards, pilot studies, skilling of local work covering 1 million m2 in force, and awareness creation. Dhaka with cool roofs. - Medium term (3 to 7 years): Creation of “demand pull” due to awareness of energy savings and - This study aimed to improved living conditions, and “demand push” by offering incentives for cool surface solutions. support and scale up this effort by identifying global - Long term (7 to 10 years): Making cool surfaces a mandatory requirement in new buildings (through best practices in the area of building codes) and by developing innovative business models. Cool Surfaces and 4. Financing mechanisms for cool surface program include (i) allocating funds for cool surface supporting the design of a programs in annual city budgets, (ii) utilizing public funds for health, energy or urban administration Cool Surfaces Program for departments for pilot programs, (iii) leveraging Corporate Social Responsibility (CSR) funds for low- Energy Savings and Urban income housing, (iv) development of a public fund to finance or incentivize cool surface projects, and Heat Island Mitigation in (v) green mortgages from financial institutions. Dhaka. Calculation Energy conservation Annual energy saving Annual cost saving (million Annual CO2 emission reduction approach measure (million kWh) USD) (million ton of CO2eq) Table 4: Top-down Application of cool surface (CS) 782 92 0.44 Potential impact of cool surfaces 33% penetration of CS 781 91 0.44 in Bangladesh Bottom-up 66% penetration of CS 1588 186 0.89 Bangladesh Sustainable Bangladesh Sustainable Energy Energy Support Support Program (P172183) – – Synthesis Synthesis Report 100% penetration of CS Program (P172183) 2402 Report 282 1.30 2.1.3. Large-Scale Implementation of Appliance Minimum Energy Performance Standards (MEPS) & EE Labelling Program Objective and Scope: Key findings and recommendations: - In 2018, SREDA, with its • The roles of different agencies with respect to MEPS and S&L should be defined along with mandate for promoting standard operating procedures. This includes a clear mandate for S&L implementing agency and energy efficiency of supporting agencies, and clear definitions of the roles of SREDA/ Ministry of Power, Energy and appliances, proposed a draft Mineral Resources (MPEMR)/ Power Division, and BSTI/ Ministry of Industries. S&L regulation in • The compliance of EE labels for air conditioners and refrigerators should be considered a priority. Bangladesh, which was later • Definition and updating of standards: revised in 2021. – For refrigerators, the labelling standard (BDS 1850) was last revised in 2012 and should be - However, there are still upgraded. barriers that exist in large- scale implementation related – For LED lamps, the MEPS (ideally 60-90 lumens/W) and labelling criteria should be defined in to enforcement of appliance BDS IEC 62612:2015 and performance testing should be made mandatory within 1-2 years. EE measures. – For ceiling fans, a market analysis should be done to develop energy labelling criteria with 5 - This study aimed to level rating plans. conduct a detailed • The development of MEPS and EE labelling for appliances should follow a holistic process assessment of policies for comprising of market and technical assessment, review of national and international test standards appliance MEPS and EE and best practices of international EE labelling, engagement with stakeholders, consistent rating labelling, highlight key gaps, plan and clear compliance requirements, thorough enforcement, periodic revision of labels, and challenges and opportunities transition from voluntary to mandatory standards and labels. associated with their • The ecosystem for testing needs to be developed by enhancing the capacity of existing testing implementation, and laboratories, increasing the number of testing facilities, and simplifying the process of acceptance of recommend improvement test reports from other countries for MEPS and EE labelling. areas for the MEPS and EE labelling ecosystem in • A guidebook for monitoring, verification, and enforcement (MV&E) of MEPS and EE labelling Bangladesh. should be developed by SREDA, which includes conducting label verification, check testing and challenge testing, and defining SOPs for implementing agencies in the enforcement process. 8 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.1.4. Assessment of financing and implementation mechanisms for deployment of EE appliances Key findings and recommendations: Three types of business models are recommended: A. Super ESCO-led deemed savings B. Super ESCO-led retrofit model for C. Building Energy Efficiency fund model for private sector public sector - Focus on appliances in residential & - Focus on appliances in public buildings. - Focus on retrofits in private buildings. commercial buildings. - Same super ESCO works with SREDA; - Implemented by non-banking financial - Super ESCO established as JV of PWD and relevant ministries as institution(s) such as IDCOL and BIFFL; utilities; SREDA as supporting agency. supporting implementation agencies. SREDA acts as the supporting agency. - Deemed savings are pre-determined - Deemed savings are pre-determined - Low-cost project finance for EE retrofits and procurement follows the demand and procurement follows the demand based on deemed savings, eventually aggregation route. aggregation route. leading to complex bespoke retrofits. 9 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.2. Assessment of battery storage options (1/2) Introduction and context: - Bangladesh's power sector has tripled its generation capacity to over 21 GW with US$15 billion invested since 2010. - However, the transmission and distribution systems have struggled to keep up, leading to frequent load shedding and economic losses. Moving forward, utilities in Bangladesh will need to incorporate the impact of extreme weather events and increased deployment of distributed renewable energy sources in network planning to ensure grid reliability. - Although industries rely on captive power plants, diesel fuel is expensive and contributes to air pollution. Thus, there is a need to explore if battery energy storage systems (BESS) can be a useful technology to address these issues. Objective and Scope: This activity aims to: 1. Identify and evaluate how BESSs (in combination with diesel generators) could improve electricity reliability while minimizing system costs different grid circles of Bangladesh under a range of cost and outage scenarios. 2. Evaluate how distributed solar PV, BESS and conventional distribution network solutions can contribute to climate resilience, network reliability, cost minimization and investment deferral in Bangladesh, and to identify the associated challenges. Outputs: - This activity informed the design of component to support BESS pilots in the ongoing Electricity Distribution Modernization Program (EDMP; P174650) P4R, financed by US$500 million from IDA SUW, and a US$15 million grant from the Clean Technology Fund. - The Bank also supported BREB to leverage parallel a US$13 million grant from the Korean Institute for Advanced Technology (KIAT) to fund piloting of BESS in the BREB network. - The activity also informed a follow-up study on BESS co-funded by the Climate Support Facility (TF0B6148) and an ESMAP grant from the utilities for energy transitions window (TF0B5508), which may support a lending operation under preparation with Power Grid Corporation of Bangladesh (PGCB). 10 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.2. Assessment of battery storage options (2/2) Key findings and recommendations: Table 5: Aggregate optimized capacity of BESS and diesel backup for all regions in Bangladesh Assessing the value of BESS in avoiding outages the $1000/MWh Unserved Energy; $100000/MW Unserved Load Bangladesh Distribution System: BESS MW BESS Diesel Load - BESS is cost-competitive with diesel in providing reliable backup Battery Costs MWh MW Shed generation across a wide range of scenarios. $375/kWh 1,475 1,876 1,025 - $200/kWh 1,828 2,837 660 - - The most cost-effective solution includes a combination of BESS and diesel, with BESS being used for shorter outages due to $100/kWh 2,342 4,466 155 - cheaper OPEX, and diesel used to fill in remaining power or energy Low OPEX for BESS 1,915 3,107 587 - needs during larger/longer outages (see Table 5). No BESS - - 2,503 - No Diesel CAPEX 493 1,971 2,003 - - The results are sensitive to the assumed cost of unserved energy $1000/MWh Unserved Energy; $500/MW Unserved Load and power to society. Thus, better estimates of this cost can help BESS MW BESS Diesel Load better determine the cost-effective level of back-up generation. Battery Costs MWh MW Shed Assessment of distribution network climate resilience and $375/kWh 476 1905 805 1209 distributed energy resources: $200/kWh 719 2878 494 1276 - Existing designs used by BREB for 11 kV lines are not adequate in $100/kWh 1110 4439 81 1299 case of high wind areas and should consider pole top insulation, Rated Breaking Strength (RBS) of poles, and maximum allowable Table 6: Cost-benefit outcome in Jessore-1 33kV network wind span. Reduction in Cost (million Benefits - An evaluation of conventional solutions for improving network Solution energy not US$) (million US$) served (MWh) resilience, rooftop solar PV, and BESS (both during BAU operations Underground cable 67.1 166 10.6 and extreme wind events) shows that: (i) alternative feeder arrangements are the least-cost option among conventional Alternative feeding 11.6 38 8.8 arrangement solutions (see Table 6); (ii) rooftop solar PV and BESS have multiple Feeder augmentation 16.2 122 9.9 benefits such as lower load on transformers and feeders, peak load Composite solution 45.3 229 11.4 management, investment deferral, improved voltage and lesser Solar (47 MWp) 41.5 205 81.1 losses; and (iii) A combined solar rooftop solar and BESS renders Solar + BESS operational flexibility to the network and can help in catering 62 264 81.4 (47 MWp + 15.8 MW) essential load of the system in case of storm related outages. 11 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.3. Enhancing RE Investments and Access to Land (1/2) Introduction and context: - Resource assessments indicate that Bangladesh could realize the installation of more than 40 GW of renewable energy capacity (both grid-connected and off-grid). - Bangladesh’s Nationally Determined Contributions and the Mujib Climate Prosperity Plan - Decade 2030 (2021) have set a target of 30% share of RE by 2030 and 40% by 2041. - However, there are extensive land-related challenges for RE, both in terms of identification of appropriate land, and access to the land for the purposes of utility solar (see the Annex A.3 for a summary of the challenges). - Thus, there is a need to investigate land access issues and requirements for accessing and establishing new RE sites in Bangladesh. Objective and Scope: This activity aimed to: 1. Assess the land administration and energy policy landscape in Bangladesh, identify challenges for the implementation of utility scale solar PV, and recommend methods and tools for identifying and accessing land suitable for RE investments (Section 2.3.1). 2. Assess the feasibility of repurposing five pre-identified coal plants for utility scale solar PV production and propose steps necessary to develop the five sites as RE projects with a focus on public private partnerships (PPPs) (Section 2.3.2). 3. Propose a methodology to systematically identify regions and subsequent sites of land that are suitable for utility scale solar and apply it to a test site in the Jamalpur area in Bangladesh (Section 2.3.2). Outputs: - Encouraged by this study, Power Cell is starting a detailed feasibility study for a utility-scale solar PV plant at Jamalpur. - This activity provided inputs for ongoing sector dialogue on structuring PPP/Joint Venture RE projects with competitively selected private sector partners. 12 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.3.1. Improvements to Land Administration to Enhance Access to Land for RE Investments Key findings and recommendations: 1. Develop a system to identify suitable land through co-operation between the Ministry of Power, Energy and Mineral Resources (MPEMR) and Ministry of Land (MOL). A Letter of Agreement or Memorandum of Understanding could help establish the objectives of the relationship, followed by establishment of policies to support cooperation between the two institutions. 2. Establish RE Investment Zones. Land areas that are clearly allocated for RE could be piloted as part of the MOL’s Mouza and Plot Based National Digital Land Zoning Project, and eventually linked to the planning processes undertaken by the Ministry of Local Government and Rural Planning (MLGRP). 3. Establish clear mechanisms on the optimization of land and review the current legal and policy framework around land use. Introducing a National Land Use Act, clarity on the land classification, restrictions on land use, and conversion of land use types 4. Prepare an integrated master plan for a digital land administration and management system, linking all current projects and activities. This plan would assess current activities, build strong processes, and make detailed recommendations to address shortfalls or gaps in the overall strategy. 5. Establish a digital plot-based record of land plots, for all private, public and state lands. A comprehensive land ownership record will create a single up-to-date database to which other systems like property taxation and service provisioning can be linked. 6. Introduce a unique plot identification (UPI) numbering system. This would keep track of plot subdivision, consolidation or other transactions or processes and support rapid identification of owners. 7. Introduce land record updating on demand. Updating the mouza map on a transactional basis by public/private surveyors will help address the huge quantity of land disputes that plague the system. 8. Establish a mechanism for identifying and repurposing technically suitable public and state land to meet national RE targets. This would include mechanisms for identifying land, accessing information about the land, and releasing and repurposing that land, including establishing standard processes such as standard contracts for lease agreements for solar and wind sites. 9. Introduce mechanisms to ensure land acquisitions for RE investments align with international standards and support gender equality. An RE risk investment framework should be adopted that mandates practical and adequate resettlement and compensation measures, aiming to protect communities impacted by RE-induced displacements including informal land occupiers. A gender integration policy should be mandated throughout RE investment projects to increase benefits of investments to all. 13 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.3.2. Repurposing of Coal Power Plant Sites and Methodology for RE Site Identification Table 7: Summary of site potential Key findings and recommendations: DC AC Capital NPV LCOE Repurposing of Coal Power Plant Sites for Renewable Energy: Capacity Capacity cost (US$ (US$ - The total potential capacity of the assessed sites is estimated to be (MW) (MWac) (US$ m) m) cents) about 3.8 GW for an investment of US$2.46 billion (see Table 7). Bangladesh- 460.964 380 305.7 137.8 7.4 Singapore - This represents more than a 17-fold increase on current utility scale solar PV in Bangladesh, and 24% of the Mujib Climate CPGCBL- 501.7 405 332 137 7.6 Sumitomo Prosperity Plan RE target for 2030 of 16,000 MW of installed RE. RPCL- - The proposed can enable reduced power prices for consumers, 129.413 107.5 92.7 16.2 8.7 Patuakhali since the LCOE falls well within the BPDB tariff ceiling of US$0.10 BPDB - per kWh for solar PV. 2462 1977.5 1575 888.3 6.9 Moheshkhali Renewable Energy (Solar) Site Identification Methodology and APSCL- Application to Jamalpur Site: 234.3 192.5 160.5 41.5 8.3 Patuakhali - This report outlines an initial methodology for utility scale solar land Total 3788.377 3062.5 2465.9 1220.8 identification (see Figure 1). - The methodology was applied to a test site in the district of Jamalpur, which finds that the site passes the threshold of the five- Stage 1: RE Zoning Tool stage methodology to move to a full feasibility study. Stage 2: Desk Site Assessment Use RE Zoning - The estimated LCOE is US$0.072 per kWh if a 230 kV substation tool to Stage 3: Field Site Assessment identify/confirm Take sites is constructed, which would reduce the required new transmission prospective within the zone Stage 4: Dashboard zones identified in Undertake the line from 25 km to 15.8 km and allow 2 GW capacity to be installed. Stage 1 and Field Based RE Stage 5: complete the (Solar) Site Insert results of Consultation - Efforts should be made to offer employment to the existing desk-based RE Assessment for stages 1-3 into population on the island site, and to invest not only on the site itself (Solar) Site- the highest- the RE (Solar) Discussion of Specific ranking site(s) Assessment results, but also in other social and economic goods for the existing Assessment Dashboard for consultation community – such as tourism or the fishing industry. each site (Optional) and decision on whether to proceed to full - Encouraged by this study, Power Cell is starting a detailed feasibility study feasibility study at Jamalpur. for selected site(s) 14 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.4. Integrated system planning and analysis Introduction and context: - The rapid decline in costs of RE and other new technologies globally, combined with fast changes in the Bangladesh economy, requires strengthening of power system planning capacities. - In the past, implementing the Government’s existing priorities and investment plans in the power sector was hindered by the lack of a recent, clearly defined Power Sector Master Plan (PSMP) and insufficient coordination of planning between the generation, transmission and distribution segement. - Thus, there is a need to strengthen the institutional and technical planning capacities of key sector actors, sharing of planning data between them, and integration of planning across generation, transmission and distribution. Objective and Scope: This activity aimed to provide support for setting up an online database using Geographical Information System (GIS) platforms for generation, transmission and distribution to facilitate integrated system planning and development. Outputs: - The Bank organized a workshop in Dhaka on July 9, 2023, on how GIS can be used to improve planning, operations and management of Power Grid Company of Bangladesh (PGCB). - The workshop was attended by PGCB, DISCOs, Bangladesh Power Development Board (BPDB) and Power Division, and was followed by discussions with both DISCOs and PGCB. - It was agreed that the deployment of the GIS asset at PGCB would be captured in a new transmission investment project to be funded by the Bank (Transmission Grid Enhancement & Modernization Project, P179429), and that the ESMAP activity would assist PGCB in developing the bidding document that would be used to implement the GIS asset. 15 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.5. Review and strengthening of regulatory frameworks (1/2) Introduction and context: The Power Cell in Ministry of Power, Energy and Mineral Resources and the Bangladesh Energy Regulatory Commission (BERC) have requested a comprehensive multi-year TA from the Bank to help strengthen the institutional and regulatory framework for an efficient energy market, optimized electricity price design and network regulation, increased share of RE, innovative digitalization, improved EE, enhanced cross-border trade and planning capacity, and strengthened human resources. Objective and Scope: This study presents a Roadmap for Institutional and Regulatory Reforms in Bangladesh, based on: 1. A study on “Stocktaking of Institutional and Regulatory Reforms in the Electricity Sector in Bangladesh: Issues, challenges and opportunities”, which provides an assessment of the evolution of institutional and regulatory reforms in Bangladesh electricity sector since the early 1990s, provides an evaluation of the impact of the reforms. The report also captures relevant international experience, highlights the constraints which impeded the implementation of certain reforms and summarizes lessons for future reform efforts. 2. A study on “Assessment of the readiness of the institutional and regulatory framework in the electricity sector in Bangladesh to respond to emerging challenges and opportunities”, which covers the global megatrends and innovative technologies in the power sector, key emerging areas including decentralized RE, smart grid, EVs, demand side management, and energy storage, and assesses the readiness of the institutional and regulatory framework in the electricity sector in Bangladesh to respond to emerging challenges and opportunities. 3. The work plans and programs of key stakeholders in Bangladesh power sector (e.g., Power Cell, BERC, SREDA and others), to ensure that these plans and programs are aligned with the key sector objectives identified in the above two studies. Outputs: The summary of the key options for reform roadmap that can be evaluated and implemented over the near term (0-24 months) and medium-term (24-48 months) to strengthen Bangladesh’s institutional and regulatory framework is presented on the next page. 16 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 2.5. Review and strengthening of regulatory frameworks (2/2) Table 8: Summary of Roadmap for Institutional and Regulatory Reforms in Bangladesh Component Near term (0 - 24 months) Medium-term (24 - 48 months) • Defining industry structure/ market design and way forward on • Implementation actions on institutional subsidy arrangements. reforms and performance improvement in • Planning on key actions for institutional reform and performance and key sector entities. Electricity efficiency improvement in sector entities. • Strengthening of internal policies and market reform • Initiating stakeholder consultation and communication and capacity procedures in sector entities as a part of and financial building measures for sector entities. institutional reforms. sustainability • Quick wins - e.g., ISO creation, key regulations (power market, open • Continuation of stakeholder consultation, access, transmission pricing, etc.), standard commercial agreements, communication and capacity building. transmission project auction framework, automation in merit order, etc. • Cost reflective tariff regulations. • Potential assessment, planning, policy preparation, framework for • Advanced policy framework and competitive procurement, supporting regulations for RE development. implementation actions for RE, EE&C, Decarbonizatio • Updating master plan on EE&C (including DSM and DR) along with energy storage, EVs, etc. n, distributed a supportive policy and regulatory framework. • Pilot projects on various RE energy • Roadmap, action plan along with supportive policy, regulatory and technologies, charging infrastructure for resources and institutional framework for smart grid, EV, storage, etc. EV, energy storage, etc. digitization • Training and capacity building. • Continuation of training to sector entities along with awareness generation. • Institutional strengthening through development and implementation • Continuation of capacity building and of proper HR policies and capacity building. training programs. Regulatory • Strengthening regulatory governance framework (revisiting BERC strengthening Act, policy and framework for disseminating regulatory decisions and enabling greater public participation, financial independence, etc.). • Develop tools to improve regulations and decision making. • Initiating development of policy, institutional and regulatory • Approved regulations, procedures, Facilitating framework for facilitating CBET. technical standards and guidelines for cross-border • Approved institutional set-up and policy framework for CBET. facilitating CBET electricity trade • Principles, mechanisms and standard documents for competitive procurement of power through CBET. 17 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 3. Pillar II: Roadmap for Meeting Energy Needs of Refugees and Host Communities Introduction and context: Cox's Bazar is a coastal district in southeastern Bangladesh with a population of about 2.65 million, which received an influx of over 1 million individuals belonging to the Displaced Rohingya Population (DRP), leading to a resource crunch for the refugees, host communities and the Government. While the donor community, UNHCR, and the the Refugee Relief and Repatriation Commission (RRRC) of the Government of Bangladesh are working to meet their energy needs, a comprehensive roadmap, plan, and additional investments are needed for meeting the energy needs of Rohingya refugees and host communities in Cox’s Bazar. Objective and Scope: This activity aimed to: 1. Assess the scope of livelihood generation in the rural areas of Cox’s Bazar through utilization of conventional and renewable energy technologies. 2. Review the energy interventions in the refugee camps as well as in the host communities in vicinity. Assess the current energy demand supply scenario and forecast the future energy demand and potential scope of energy interventions. 3. Review Cox’s Bazar energy and electricity demand and supply situation and way forward towards a green and resilient energy infrastructure. Thus, the activity aimed to contribute to a comprehensive and long-term solution for the energy needs of Rohingya refugees and host communities in Cox’s Bazar. Outputs: - This activity informed the design of the Additional Financing of Emergency Multisector Rohingya Crisis Response Project (P171779), which allocated USD 5 million to finance 100 solar nano-grids. - It will support an energy need assessment in Bhasan Char, which will accommodate 100,000 Rohingya refugees. - The assessment supported the design of the new project “Host And Rohingya Enhancement Of Lives Through A Multi-Sectoral Approach” (P501274), expected to be approved by FY 24. 18 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 3.1. Productive Use of Energy for Livelihood Generation and Quality of Life: A Case Study on Cox’s Bazar Objective and Scope: Key findings and recommendations: - This study assesses the scope of State of livelihoods in Cox’s Bazar: livelihood generation in the rural areas - RE solutions, particularly solar and wind projects, can fulfill unmet energy demand and of Cox’s Bazar through utilization of aid livelihood generation in agro-processing, fisheries, solar energy, and farm-based conventional and RE technologies. activities like water pumps, sprayers, and mini-grids. - It explores strategies to promote - Employment opportunities can be created by training the youth on production of low- Productive Use of Energy (PUE), cost solar refracting light tubes, installation and maintenance of solar home systems, and suggests ways to integrate PUE supply, installation, and knowledge transfer of improved cooking stoves. considerations into energy planning, - National policy reform is needed to encompass Rohingya refugees and host and showcases successful energy communities from a single lens of inclusive development and economic growth. initiatives in Cox's Bazar and neighboring regions. Social Inclusion and Gender Disparity: - It aims to inform the decision-making - Public awareness campaigns to sensitize the rights of women from a legal and religious of the government, potential donors, perspective can help encourage and sustain female employment and entrepreneurship. international organizations, and private - Home-based employment and training programs like handicrafts, food processing, and sector towards ensuring key sewing can enable vulnerable and unemployed women to meet day-to-day expenses. interventions in the Energy sector that Cold Storage Chain Infrastructure and Challenges: could lead to sustainable and improved livelihood and quality of life in the - Shortage of space, insufficient electrical power, and insufficient cold storage facilities region. act as a deterrent to the economic health of agriculture, fisheries, livestock, and related sectors. 19 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 3.2. Review of Energy and Electricity Programs and Infrastructure for Refugee Camps and Host Communities in the Vicinity Objective and Scope: Key findings and recommendations: - This study reviews the Electricity for All and Renewable Energy in Cox’s Bazar: energy interventions in the - Out of Cox’s Bazar’s population of 2.65 million, 91% of the people have electricity access (with a refugee camps as well as in few unconnected households on islands and in forests), but no grid electricity is provided to the the host communities in Displaced Rohingya Population of 1 million. vicinity. - The quality and reliability of grid electricity remains low, with voltage drops in certain areas of 33% - It assesses the current (the allowable range is +/-10%) and frequent interruptions due to limitations in transmission and energy demand and supply generation, maintenance challenges and long distribution lines. scenario and forecasts the - Cox’s Bazar has high solar and wind potential, especially along the southern coast. A 20 MW solar future energy demand and project, a 60 MW wind project (with another 50 MW planned), two island mini-grids of 250 kWp and potential scope of energy 100 kWp and many solar home systems (SHSs) already exist. interventions. Energy and Electricity Programs and Infrastructure for Refugee Camps: - It aims to recommend rational energy & electricity - Rohingya Refugee camps in Cox's Bazar have an estimated electricity demand of 42 MW, planning for Cox’s Bazar expected to reach 66 MW by 2030, requiring a new 132 kV sub-station. from a holistic view; and - A comprehensive and sustainable approach involves addressing challenges for grid connectivity highlight capacity such as eligibility issues, cost recovery, and energy efficiency, while using RE sources, such as development needs and SHSs and solar nano-grids to meet the growing electricity demand. suggest way forward to Cooking Fuel in Refugee Camps and Host Communities design the energy and electricity service delivery for - The primary sources of cooking fuel are firewood and charcoal, but overuse has led to the benefit of the end users deforestation. in both - The cooking fuel mix needs to be diversified by introducing electric/induction stoves, promoting micro-energy enterprises, providing financial support and post-purchase services, addressing safety concerns, and creating an effective distribution network for eco-friendly alternatives like charcoal briquettes and green charcoal. 20 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 4. Pillar III: Public-Private Partnerships (1/2) Introduction and context: - The Government of Bangladesh recognizes the importance of enhancing private sector investment through Public Private Partnerships (PPPs) for sustainable infrastructure development. - They have established a strong PPP framework, including a PPP Law, guidelines, and the Public Private Partnership Authority (PPPA). The PPPA works with ministries/agencies to identify, develop, and deliver PPP projects to international standards. - However, more resources, capacity building and tools are needed to more effectively implement PPP projects in Bangladesh in line with global best practices. Objective and Scope: This activity aimed to: 1. Develop a PPP Handbook, Operations Manual, and conduct training sessions to draw on international best practices to help various stakeholders (both public and private) develop a better understanding of PPPs, explain the process for identifying, preparing, procuring and managing PPP projects in the context of Bangladesh, and to build the capacity of the PPPA. 2. Develop a Potential PPP Pipeline Report that uses a screening and scoring methodology to assess the suitability of projects and identify a pipeline of potential PPP projects in Bangladesh. Outputs: - As a result of the discussions between the World Bank and the various ministries/agencies to develop the potential PPP pipeline, two bridge projects have been identified as potential PPP projects and the RHD has requested a project definition grant (PDA) from GIF to help further study the projects to assess their feasibility to be undertaken as PPPs. 21 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 4. Pillar III: Public-Private Partnerships (2/2) Key findings and recommendations: Table 9: Projects in the potential PPP pipeline identified in Bangladesh PPP Handbook, Operational Manual, and Training: Rank Name Sector Stakeholder - The objective of the PPP Handbook is to provide a wide Construction of Dhaka Subway, Bangladesh Bridge 1. Route ‘O’, from Tongi Junction to Transport range of stakeholders with a basic understanding of PPPs Jhilmil via Mohakhali and Sadarghat Authority based on international best practices, while elaborating the PPP concept and the lifecycle approach of a PPP project. Construction of Dhaka Subway Route Bangladesh Bridge 2. Transport ‘B’ from Gabtoli to Mastul Authority - The PPP Operations Manual supplements the handbook by Construction of Dhaka Subway Route Bangladesh Bridge providing a more detailed explanation of the lifecycle of a PPP 3. Transport ‘S’, from Keraniganj to Sonapur Authority project, taking into account the institutional, legal and regulatory framework for PPPs in Bangladesh. Construction of Dhaka Subway Route Bangladesh Bridge 4. ‘T’ from Narayanganj to Uttara Transport Authority Bangladesh Potential PPP Pipeline Report: Sector-13 - This report explains the approach and methodology used to Improvement of Kashinathpur – Roads and Highways 5. Transport identify a pipeline of potential PPP projects that are Rajshahi – Sona Masjid Highway Department sustainable and resilient. Improvement of Nabinagar – Aricha – Roads and Highways 6. Transport - The approach comprised of (i) development of an initial long Paturia Highway Department list of projects based on discussions with a wide range of Improvement of Bhanga – Bhatipara Roads and Highways 7. Transport ministries and agencies identified by the PPPA, (ii) shortlisting – Katakhali Highway Department of projects for the PPP pipeline based on a project screening Improvement of Rangpur – Barabari – Roads and Highways and prioritization methodology, and (iii) preparation of Project 8. Transport Kurigram Highway Department Concept Notes for the projects in the potential PPP pipeline. Solar Power Plant at Bangababdhu Bangladesh Economic 9. Energy - The table on the right provides a list of the projects in the Sheikh Mujib Shilpa Nagar (BSMSN) Zones Authority potential PPP pipeline identified using this method, with the Development of Cox’s Bazar Airport Civil Aviation Authority, projects ranked from highest to lowest based on their scores. 10. Transport (Phase-II) at Cox’s Bazar Bangladesh - The report also provided concept notes on shortlisted 2nd Syed Nazrul Islam Bridge Road and Highways 11. Transport projects having sufficient information, to provide an overview (Bhairab Bridge) Department of the underlying project, and highlight recommendations for Road and Highways next steps in their PPP development process. 12. 2nd Tora Bridge Transport Department 22 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report 5. Annex A.1. Detailed plan for capacity building of stakeholders for BEEER S. No. Stakeholder Method/mode Common content Stakeholder-specific contents • Alignment between existing regulations (such as BNBC) and BEEER. • Awareness Workshops • Potential policy interventions to be employed to support BEEER • Seminars and webinars implementation in early phases 1 Policy Makers • Constitution of national/regional green • Roles and responsibility of different departments involved in the building association/chapters implementation of BEEER • Understanding on MRV • Operational manual • Compliance requirements for BEEER criteria • Awareness workshop • Documentation formats, parameters to be assessed in documentation 2 Administrators • Certification course and review techniques • Constitution of national/regional green • Understanding on MRV building association/chapters • Testing standards for green construction material and EE appliances • Online and offline classroom training • Climate change and • Training on criteria, eligibility, structure, scoring, methodology and • Certification programs impact of buildings implementation framework Auditors and • Implementation guide/checklist • Brief about EE 3 • Training on MRV assessors document design and green • Training on building energy simulation software • Constitution of national/regional green rating systems • Testing standards for green construction material and EE appliances building association/chapters • Benefits of resource efficient construction • Green and resource efficient construction techniques material, EE design • Benefits of green buildings in terms of financial savings Real estate • Conferences and appliances • Policy support and incentives for green buildings 4 • Seminar or webinars • Case studies for developers • Human resources for BEEER implementation • Tutorials comparing green • Procedure for obtaining BEEER certification • Constitution of national/regional green building with • Testing standards for green construction material and EE appliances building association/chapters conventional building Material • Different green building materials, their availability, and market potential 5 • Setting up of testing facilities and • Introduction of suppliers • Testing standards for green construction material and EE appliances development of testing standards BEEER and Architects and procedures for • Technical knowledge about green building design 6 designers obtaining BEEER • Detailed information about credit points in BEEER certification • Technical knowledge about green building design • Structure and components of BEEER Academic • Updating course curriculum • Inclusion • BEEER Scoring methodology and compliance 7 institutions of new courses and R & D projects • Use of Building energy simulation software • Research and development opportunities • Testing standards for green construction material and EE appliances • Seminar or webinars • Development of capacity for appraisal of green building projects Financial 8 • Certification courses on project • Benefits of financing BEEER certified buildings institutions appraisal • Developing an understanding of green mortgage • Media and community connects Users/general • Benefits or incentives of BEEER certified buildings as an end -user 9 • Web-site development public • Procedure of BEEER certification • Advertisement and press release A.2. Detailed action plan for addressing market barriers for EE Pillar Short-term actions Medium-term actions Long-term actions • Expansion of the EE labelling to include • Ratcheting up of the EE labelling commercial and industrial criteria to drive market towards • Finalization of S&L regulation of Bangladesh appliances/equipment. higher efficiencies • Revision of MEPS and EE labelling requirements for • Public procurement of EE or higher star-rated • Enabling market transformation Policy and appliances with existing EE standards. appliances towards energy-efficient regulation • Enforcement of MEPS and labelling schemes for appliances • Monitoring impact of EE labelling of appliances/equipment in the with existing EE standards. appliances. building and industry sectors • Regulation for implementing BEEER • Mandate for high-energy consuming buildings • Transitioning EE labelling to report energy and environmental programs from voluntary to performance in line with BEEER. mandatory phase. • Establish governance and coordination mechanisms between • Identifying sub national level bodies for implementing bodies of S&L regulation. implementation of MV&E of S&L regulation. • Ensuring long term alignment of • Creation of dedicated department within implementing • Identify agencies for EPC contracting for bulk EE labelling implementing Institutions agencies for day-to-day activities of the S&L regulation. procurement by the Super ESCO and M&V agency. • Creation of a Super ESCO as an electricity utility-led JV contracting by SREDA for the • Accreditation mechanism for • Creation of department within SREDA for due diligence of EE operationalization and roll out of respective empanelment of private ESCOs projects and to oversee M&V of the building EE program. building EE programs. • Increasing capacity of existing labs for testing of appliances. • Capacity building of implementing and • Accreditation of energy professionals and organizations partner agencies on building EE providing building EE services. • Establishment of new laboratories for • Training of trainers, government officials, retailers, appliances and construction materials. Technical • Capacity building continuous manufacturers on EE labelling scheme and regulation. • Promoting testing of appliance in capacity support • Publish guidebooks & SOPs for implementation of S&L manufacturer premises by facilitating regulation accreditation of their in-house laboratories. • Technical support for implementation of S&L and BEEER • Perform energy audits to create a pipeline of regulation investment-ready EE projects. • Allocation of funds and resources to support implementing • Model documents for energy savings • Implementation of full-scale of agencies for mobilizing the S&L implementation. performance contract projects based on more EE investment • Fund allocation for the simpler building EE program (Super complex business models • Standard templates for complex Finance ESCO program for public and private buildings and building EE • Introduction of risk mitigation instruments energy savings performance fund for retrofits in private buildings) • Scaled-up EE investment in buildings contracts with associated M&V • Mobilize grant and concessional climate finance for increasing including passive EE measures protocols uptake of EE technologies Development of mobile appliance • Elaborate new guidelines and manuals on S&L Information and inclusion of QR code on • Public awareness and media campaigns on building EE • Consumer and retailer awareness campaigns & awareness labels for ease of verification of programs and S&L. labels and information access 25 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report A.3. Challenges related to identification and access of land for utility-scale solar Land Tenure and Administration Structure 1. The land functions of the Ministry of Lands (MOL) are closely linked with the functions of local government under the Ministry of Public Administration, but the division of labor between different Ministries complicates efforts to streamline land administration at the national level. 2. The handling of recording, registration and settlement by different offices increases the time needed to access land and reduces the coherence of land information. Land Administration Practice 3. The khatian and mouza map records and deeds are not linked digitally, often leading to inconsistencies and ownership disputes. 4. The separation of the settlement system under the Department of Land Records and Survey (DLRS) from the land records system at the Union Land Office (ULO) contributes to the huge quantity of disputes and absence of data. Additionally, the absence of a contemporaneous update mechanism, means that land records, and particularly a definitive and accurate description of the land plot, are generally not complete. 5. Informality in land transactions and occupation leads to uncertainty around who to negotiate with when accessing land for RE. 6. The complexity of laws and regulations, as well as delays experienced in record making operations, maintenance activity and the presence of ongoing and unresolved disputes means that there is no unified conclusive record that sets out the private, public land and khas land in a given location as well as the use of that land, making it difficult for RE investors or the government to conclusively ascertain who has a beneficial interest in the land to be acquired and the physical boundaries of that interest. 7. The lack of clarity around the status of khas land (i.e., not-identified, identified but not allocated, allocated) and pervasive informal occupancy of khas lands compounds existing challenges of accessing any land for RE that partly or wholly falls under this category. 8. The lack of a centralized view of public land leads to possible duplication or difference in what is owned by government agencies. Land planning 9. The Land Use Policy does not have any standards or provisions on where national infrastructure (including RE) should be placed. 10. There is no coherent system or spatial plan in place to understand existing and future land uses in a specific area. 11. Policy preferences around the restricted utilization of state (khas) agricultural lands precede more recent documents such as the MCPP, and do not allow for using (some) reclaimed (usually unfertile/vacant) khas land for RE. National E&S Risk System 12. There is insufficient national data on which groups are occupying the non-alluvial lands targeted for RE and their socio-economic vulnerabilities. 13. There is no formal resettlement policy or law to guide the resettlement of people on land targeted for RE. 14. The compensation process in the Acquisition and Requisition of Immovable Property Act 2017 does not adequately protect informal landowners. 15. Knowledge of rights and access to justice is limited for groups occupying lands informally and even for formal landowners. 26 Bangladesh Sustainable Energy Support Program (P172183) – Synthesis Report