COASTAL EMBANKMENT IMPROVEMENT PROJECT PHASE-I

ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

Executive Summary

Bangladesh Water Development Board Ministry of Water Resources,

Government of the People’s Republic of Bangladesh

April 3, 2013

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TableofContentsList of Acronyms ................................................................................................................................................................ ii 1. Introduction ................................................................................................................................................................ 1

1.1 Project Area ....................................................................................................................................................... 1 1.2 Strategic Context ............................................................................................................................................... 1 1.3 The Process Followed: EMF and SMRPF for the overall Project; EIA & RAP for the First Package ............. 3

2. Project Description .................................................................................................................................................... 5 2.1 Project Objective ............................................................................................................................................... 5 2.2 Project Component ............................................................................................................................................ 5 2.3 Project Interventions with Possible Environmental & Social Concern ............................................................. 7

3. Policy, Legal and Administrative Framework ........................................................................................................... 9 3.1 Applicable Environmental Legislation in Bangladesh ...................................................................................... 9 3.2 Applicable Social Legislation in Bangladesh .................................................................................................... 9 3.3 Other Relevant Legislation in Bangladesh ........................................................................................................ 9 3.4 International Treaties ........................................................................................................................................ 9 3.5 Implications of the World Bank Policies on CEIP & Environmental Category .............................................. 10 3.6 Compliance with Bangladesh Legislation and World Bank Safeguard Policies ............................................. 11

4. Project Alternatives .................................................................................................................................................. 12 5. Baseline Conditions of Project Area ........................................................................................................................ 14 6. Potential Impacts ...................................................................................................................................................... 20

6.1 Pre-construction Phase Impacts ...................................................................................................................... 20 6.1.1 Social Impacts ........................................................................................................................................ 20 6.1.2 Environmental Impacts ........................................................................................................................... 21

6.2 Impacts during Construction Phase ................................................................................................................. 21 6.2.1 Social and Gender Issues ........................................................................................................................ 21 6.2.2 Environmental Issues ............................................................................................................................. 22

6.3 Impacts during Post-construction Phase .......................................................................................................... 25 6.3.1 Social Impacts ........................................................................................................................................ 25 6.3.2 Environmental Impacts ........................................................................................................................... 25

6.4 Cumulative Impacts of all CEIP Interventions ................................................................................................ 26 6.5 Cumulative Impacts of Other Projects in the Area .......................................................................................... 27 6.6 Positive Impact of the Project ......................................................................................................................... 27

7. Environmental & Social Management Plans ........................................................................................................... 29 7.1 Social Action Plans ......................................................................................................................................... 29 7.2 Environmental Management Plans .................................................................................................................. 30 7.3 Institutional Capacity ...................................................................................................................................... 31

8. Consultations and Disclosure ................................................................................................................................... 33 8.1 Overview ......................................................................................................................................................... 33 8.2 Consultation Process and Outcome ................................................................................................................. 33 8.3 Disclosure........................................................................................................................................................ 34 

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List of Acronyms ARIPO Acquisition and Requisition of Immovable Property Ordinance (Ordinance II of 1982) BDT Bangladesh Taka BECA Bangladesh Environmental Conservation Act BUET Bangladesh University of Engineering and Technology BWDB Bangladesh Water Development Board CCP Chittagong Coastal Plain CEGIS Center for Environmental and Geographic Information Services CEIP Coastal Embankment Improvement Program CEIP-I Coastal Embankment Improvement Project, Phase I CHT Chittagong Hill Tracts CIP Country Investment Plan CRS Common Resource Structures DCSC Design and Construction supervision Consultants DOE Department of Environment EA Environmental Assessment EAP Environmental Action Plan ECA Environment Conservation Act ECC Environmental Clearance Certificate ECP Environmental Code of Practice ECR Environment Conservation Rules ECRRP Emergency 2007 Cyclone Recovery and Restoration project EIA Environmental Impact Assessment EM Environmental Monitor EMF Environmental Management Framework EMP Environmental Management Plan ES Environmental Screening FGD Focus group Discussion GDP Gross Domestic Product GEMP Generic Environmental Management Plan GOB Government of Bangladesh GPS Geographic Positioning System GRC Grievance Redress Committee GRM Grievance Redress Management GTP Ganges Tidal Plain HYV High Yielding Variety ICM Integrated Crop Management IEE Initial Environmental Examination IPM Integrated Pest Management IPSWAM Integrated Planning for Sustainable Water Management IWM Institute of Water Modeling LCS Labour Contracting Society MDP Meghna Deltaic Plain MOEF Ministry of Environment and Forest MoWR Ministry of Water Resources MSL Mean Sea Level NCA Net Cultivated Area NEMAP National Environmental Management Action Plan NGO Non-Governmental Organization NOC No Objection Certificate OHS Occupational Health and Safety O&M Operation and Maintenance PAP Project Affected Person

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PD Project Director PM Particulate Matter PMU Project Management Unit PRAC Physical Relocation Assistance Committee RAP Resettlement Action Plan SA Social Assessment SAP Social Action Plan SFYP Sixth Five Year Plan SIA Social Impact Assessment SM Social Monitor SMRPF Social Management and Resettlement Policy Framework TDS Total Dissolved Solids TOR Terms of Reference TRM Tidal River Management UNO Upazila Nirbahi Officer USD US Dollar VNR Vested and Non-Resident WB World Bank WMO Water Management Organization

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1. Introduction 1. The long term objective of Coastal Embankment Improvement Project is to increase the resilience of the coastal population to tidal flooding and natural disasters by upgrading the entire embankment system. Polders were originally designed to protect against tidal wave, without much consideration to storm surges. Recent cyclones brought substantial damage to the embankments and further threatened the integrity of the coastal polders. In addition to breaching of the embankment due to cyclones, siltation of peripheral rivers surrounding the embankment caused the coastal polders to suffer from water logging, which lead to environmental, social and economical degradation. Poor maintenance and inadequate management of the polders have also contributed to internal drainage congestion and external siltation. As a result, in some areas soil fertility and good agriculture production are declining because of water logging and salinity increase inside the polders. With an existing network of embankment of nearly 6,000 km long with 139 polders, the magnitude of such a project is enormous. Hence a multi-phased approached will be adopted over a period of 15 to 20 years. The proposed Coastal Embankment Improvement Project –Phase 1 (or CEIP-I) is the first phase of this long term program. A strategic polder assessment was undertaken and a multi criteria analysis was developed to guide the gradual selection of polders. The key criteria are: physical condition of the embankment and the drainage system, economic activities in the polders (agriculture or fishery), population and socio economic conditions, environmental condition and economic efficiency considerations. Based on this assessment a first priority group of 17 polders was selected. Among the seventeen, 4 (polders 32, 33, 35/1, 35/3) will be considered for the first package of investment.

1.1 Project Area 2. The coastal zone in southern Bangladesh adjoining the Bay of Bengal is the overall project area. The area is characterized by a delicately balanced natural morphology of an evolving flat delta subject to very high tides and frequent cyclones coming in from the Bay of Bengal encountering very large sediment inflows from upstream. The coastal zone, in its natural state, used to be subject to inundation by high tides, salinity intrusion, cyclonic storms and associated tidal surges. In 1960s, polderization was started in the coastal zone to convert this area into permanent agricultural lands (see Figure 1). The polders in this area are enclosed on all sides by dykes or embankments, separating the land from the main river system and offering protection against tidal floods, salinity intrusion and sedimentation. The polders were designed to keep the land safe from the daily tide to allow for agriculture activities. These polders are equipped with in- and outlet sluice gates to control the water inside the embanked area.

1.2 Strategic Context 3. Notwithstanding the security and enhanced resilience brought by polders, the vulnerability of the coastal population is on the rise due to climate change. Climate variability and change will accentuate the intrinsic risks facing coastal Bangladesh. These risks span: (i) cyclones and storm surges (ii) river bank erosion and vulnerability of islands and chars, (iii) sea level rise, (iv) saline intrusion and (v) coastal erosion. A lack of investment to retrofit and upgrade the polders scheme will weaken their capacity to militate against natural hazards and protect livelihood and assets. The Sixth Five Year Plan (SFYP) states that the direct annual cost to the national economy of natural disasters over the last 10 years is estimated between 0.5% and 1% of GDP. The SFYP emphasizes the need to continue investing in flood management schemes to raise the agricultural productivity of many thousands of kilometers of low-lying rural areas and to protect them from extremely damaging severe floods. In that spirit, the SFYP identifies polders as priority target for investment and calls for immediate action to repair and maintain existing coastal polders to protect and enhance agricultural productivity and mobilize communities against tidal flooding and intrusion of saline water. Restoration of the embankment system is a much needed catalyst to provide resilience to vulnerable communities and to revitalize the coastal zone’s ailing socio-economic engine

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Figure 1: Coastal Polders in Bangladesh

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1.3 The Process Followed: EMF and SMRPF for the overall Project; EIA & RAP for the Each Works Package

Environment Process (EMF/EIA)

4. The Environment Management Framework (EMF). The project will have considerable environmental impacts. An EMF has been developed for the overall project. The EMF is developed to ensure that neither the project activities (both in terms of needs and quality) nor the environment is compromised through this intervention The EMF provide a framework for screening, identifying, assessing, evaluating and mitigating the environmental risks emerging from the proposed project. The EMF is applicable to the entire CEIP project, irrespective of the source of financing. It includes the following specific processes: A detailed methodology for screening and scoping to identify polders that will require a more

thorough environmental assessment and management; A screening mechanism to evaluate the potential environmental impacts; A grievance redress mechanism; A sample TORs for carrying out detailed EIA for polders, which could be customized specific to

each polder; Specific procedures on public consultation and disclosure; Environmental monitoring arrangements covering selection, appraisal and implementation for each

polder; A plan to augment institutional capacity to manage environmental issues in the project.

5. The Environmental Impact Assessment (EIA). The project proposed to rehabilitate about 17 polders. Given the size of this investment, contract packages have been divided into 4 packages of 4 to 5 polders in each package. The first package of investment includes 4 polders (Polder 32,33, 35/1 and 35/3) for which detail design has already been completed. Based on the developed guidelines delineated in the EMF, the implementing agency (BWDB) has prepared individual EIA along with polders specific Environmental Management Plan (EMP) for 4 polders for the first package of investment. EIA for each remaining polders funded under this project will be carried out following the guidelines of the EMF before commencement of construction. Social Process (SMRPF/RAP) 6. The Social Management and Resettlement Policy Framework (SMRPF). Overall the project will have substantial benefit to the coastal population. By increasing their resilience to storm surges and natural disasters, the project will protect their livelihood and assets in case of storm surges and enhance agricultural productivity by reducing drainage congestion and reducing saline water intrusion. Nevertheless, in order to undertake this project and upgrade the existing embankment social issues (including social safeguard compliance) will arise due to the need to acquire land and displace population. 7. An SMRPF has been developed following the legislative and policy framework active in Bangladesh and the requirements of the World Bank social safeguard policies including the Operational Policy (OP) 4.12 on Involuntary Resettlement in terms of participation and social inclusion, recognition of losses, compensation for loss of assets at replacement cost, and livelihood restoration. The SMRPF has been developed to ensure that any adverse social impacts including social safeguard compliance are duly assessed during detail design of works package and Social Action Plan (SAP) and a Resettlement Action Plan (RAP) are prepared for mitigation of adverse social affected including social safeguards compliance issues. The SMRPF provides general policies, guidelines, and procedures for integration of required mitigation measures of possible safeguard impacts into the selection, design and implementation of the project. The SMRPF has also benefited from the experience in resettlement in similar others projects within BWDB and other infrastructure agencies of the Government of Bangladesh.

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8. The Resettlement Action Plan (RAP). BWDB has conducted census and socioeconomic survey of affected households and persons and developed a RAP for the 4 polders for implementation in the first works package. For all remaining polders, a Social Impact Assessment (SIA) will be carried out for each polder and SAP and RAP will be prepared, in accordance with the guidelines of the SMRPF. Both SAP/RAP will be agreed with the Bank before award of civil works construction.

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2. Project Description

2.1 Project Objective 9. The project development objectives are to: (a) increase the area protected in selected polders from tidal flooding and frequent storm surges, which are expected to worsen due to climate change; (b) improve agricultural production by reducing saline water intrusion in selected polders; and (c) improve the Government of Bangladesh’s capacity to respond promptly and effectively to an eligible crisis or emergency. These objectives will be achieved by strengthening and upgrading embankments as part of an integrated approach to improve the polder system in the coastal area.

2.2 Project Component 10. The project will comprise the following components.

Component A – Rehabilitation and Improvement of Polders ($291 million).

11. Component A1: Rehabilitation and Improvement of Polder ($286 million). This component will finance activities that aim to increase community resilience to tidal flooding and storm surges. Investments include: (i) rehabilitation of critical portions of polder embankments including slope protection work, (ii) increasing embankment height in some stretches to improve resilience, (iii) repairing and upgrading drainage and flushing systems within polders, and (v) improving operations and maintenance (O&M). The rehabilitation and improvement works will be designed with improved standards so that protection is for both tidal flooding and frequent storm surges. It is expected that about 17 polders will be rehabilitated under this component. Stakeholders and beneficiaries consultations and participation are central to carrying out the improvement works to the polder system. Beneficiaries will be consulted and work with BWDB on the operation and management of water infrastructure, through polder committees (PC) that either already exist or will be established through the project. In addition, participatory water management organizations (WMOs) will be piloted in 4 to 6 polders. WMOs will be involved in all stages of project implementation from identification of works, prioritization, design, construction as well as operation and minor maintenance (see Component B1 for more detail). Improving the embankment system will provide stronger protection to people living inside polders from storm surges; hence reducing the recovery time after a natural disaster such as a cyclone. Improving the internal drainage system will enhance agriculture production, which is the primary source of livelihood for coastal population. Protecting assets and enhancing agricultural production will bring in much needed economic growth to the coastal population.

12. Component A2: Afforestation ($5 million). Afforestation is critical to the security of embankment. Planting of selected mangrove and other salt tolerant species are planned as a protective belt on the tidal inundation zone on the riverside of the embankment. Planting of a range of commercial wood, fruit and other tree species in phase with livelihoods needs of landless, marginalized and poor villagers are proposed on the inside of embankments. Plantings would commence after clarification of land-use and land ownership issues and the completion of earthworks in restored embankments. The afforestation component will engage community participation in pro-poor approaches to encourage ownership and benefit sharing in an attempt to achieve social, environmental and economic sustainability. The component will finance efforts to build capacity of local government institutions, Water Management Organization, NGOs and community organizations in secondary maintenance schemes for improved O&M, foreshore and embankment afforestation and protection of embankment toe against erosion.

Component B–Implementation of Social Action and Environment Management Plans (US$56 million).

13. Component B1: Implementation of Social Action Plan (US$3 million). This component will support consultation with and strengthening of polders’ stakeholders and beneficiaries as well as formal and informal water management organization (like water management groups, water management associations and embankment management groups). Under this component, intensive social mobilization

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will be piloted in 6 polders to establish participatory WMOs that will be responsible for the operation and minor maintenance works of the polders. The establishment of WMOs will follow an eight step process, as identified in the Guidelines for Integrated Planning for Sustainable Water Resources Management, published by BWDB in 2008. Social mobilization is expected to last around two years, during which time the WMOs will be established and trained in participatory planning, as well as in operation and minor maintenance activities. It is expected that the detailed design of the polders identified under the pilot scheme will engage in a participatory planning exercise with BWDB in the identification of civil works, and that construction activities will be supported by local community members, where possible. Finally, small works, including minor periodic maintenance and operation of minor hydraulic infrastructure would be undertaken by the WMOs under a memorandum of understanding with BWDB. In the remaining polders, Polder Committee(s) will be established to determine the competing needs and uses for water resources, and to decide on the operation of hydraulic infrastructure. Should the participatory approach prove to be successful, it would be scaled up under the next phase of investments. Technical assistance will be provided to local NGOs executing the social mobilization for this sub component. It will also support the implementation of social action plan identified during the consultative, design and implementation phases. 14. Component B2: Implementation of Resettlement Action Plans (US$49 million). Polder scheme rehabilitation is a complex project that involves a variety of issues ranging from land acquisition, physical and economic displacement of people and other unanticipated impacts. Generally there are squatters on the embankments as they are safe structures. A Social Management and Resettlement Policy Framework (SMRPF) has been prepared and will be disclosed in accordance with Bank guidelines. This component will finance the implementation of the Resettlement Action Plans (RAP), embankment monitoring and public consultation plans. The component will finance the resettlement and rehabilitation of persons adversely affected by the project. It will also support the development of a system to computerize land acquisition and resettlement data with Global Position System (GPS) reference and independent institute to undertake surveys and verify field data in order to guard against improper targeting of beneficiaries and/or false delivery of benefits in case of SAP/RAP. 15. Component B3. Implementation of Environment Management Plan (US$4 million). An overall environmental assessment of the polder system; an Environmental Management Framework (EMF) for the project; and Environment Impact Assessment (EIA) for polders targeted under the first package of investment have already been prepared. This component will finance: (i) the preparation of EIAs for all remaining polders; (ii) the implementation of the Environment Management Plan (EMP) and environmental mitigation and enhancement measures; and (iii) the establishment of an environmental monitoring system in BWDB to enable it to track continuous improvement in environmental performance of the polder system. Some of the items under EMP will be integrated with the civil works and included in the budget of Component A1.

Component C- Construction Supervision, Monitoring & Evaluation of Project Impact, Supervision of Social and Environment Plans, and Delta Monitoring (US$32 million)

16. Component C1: Detailed Design and Construction Supervision (US$16 million). This component will cover consulting services for (i) surveys, designs of remaining polders to be included in the project (other than the 5 for which detailed designs have already been completed), and (ii) construction supervision of rehabilitation and improvement of coastal embankments. This will include facilitating consultations with local communities in identifying needs and suitable design of the embankment as well as with other stakeholders such as local government, upazilla and union level governments. The component will finance surveys required prior to construction work. 17. Component C2: Monitoring and Evaluation of Project Impact and Supervision of EMP, SAP/RAP (US$4 million). This component will cover consulting services for continuously monitoring project activities and providing feedback to the government and the implementing agency on the project’s

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performance. This includes supervising the implementation of the EMP, SAP and RAP. In addition, it will provide third party assessment and monitoring of key aspects of project implementation. The project will also look into the feasibility of undertaking an impact evaluation. 18. Component C3: Long Term Monitoring, Research and Analysis of Bangladesh Delta and Coastal Zone (US$12 million). The Bangladesh Delta and its coastal zone is a crucial region for Bangladesh, and it is subject to a multitude of complex natural phenomena that are not fully understood as of now. The region is experiencing fast paced changes due to changes in river morphology, fluvial processes, human intervention, and climate change. To tackle this knowledge gap and enhance people’s understanding of this complex environment, the project will support a comprehensive monitoring and morphological assessment of the Bangladesh Delta. A program to extend the current monitoring systems in Coastal Bangladesh is also essential to generate data, information, and new knowledge for assessments of effects of multiple drivers on the environment of coastal zone and guide future design, rehabilitation and improvement requirements. The monitoring will cover sediment rates and composition; erosion rates; sea level rise; subsidence rates; tidal dynamics changes; river cross section changes and meander migration; shoreline changes; and any relevant geomorphological attributes. This work will be carried out by key institutions in Bangladesh, such as IWM, CEGIS, Dhaka University, BUET, and BWDB, in cooperation and twining arrangements with international institutions and experts in the topic of estuarine and coastal morphology and geomorphology. This twining arrangement is needed to build in-house capacity and guide local institutions and experts to improve their understanding of the physical processes of such a complex delta system. The project will support the installation and operation of needed equipment and systems on the ground, technical expertise, provision of advanced technology and equipment, high resolution specialized remote sensing images, and the capability to analyze these images. The project will support procurement of goods, services, and incremental operation costs in carrying out this research and analysis, and the development of databases and information systems that will be made available widely both within and outside of Bangladesh. 19. Component D – Project Management, Technical Assistance, Training and Strategic Studies (US$21 million). This component will support BWDB in implementing the project through the establishment of a fully functioning Project Management Unit (PMU). It will provide resources for needed strategic studies (including the continuous updating of the strategic polder assessment as well as all necessary preparatory studies for following phases of the CEIP), institutional capacity building, technical assistance and training. 20. Component E – Contingent Emergency Response Component ($0 million). In case of a major natural disaster, the Government may request the Bank to re-allocate project funds to this component (which presently carries a zero allocation) to support response and reconstruction1. This component would allow the Government to request the Bank to cancel project funds from Immediate Response Mechanism (IRM) portfolio projects and designate them as IRM funds to be engaged to partially cover emergency response and recovery costs. This component could also be used to channel additional funds should they become available as a result of the emergency.

2.3 Project Interventions with Possible Environmental & Social Concern 21. The CEIP project will consists of typical interventions for upgrading embankments

22. Upgrading and Improvement of Embankment: Most of the embankments were constructed many years back and have subsided naturally and therefore existing crest level is reduced from the design level. Also, some parts of embankments breached due to tidal/ storm surges during cyclone. Therefore, almost all embankments need to be raised and the breaching point repaired considering the present and future scenarios of tidal/ storm surge level. This will be one of the major interventions under CEIP project. This intervention will include mainly earthworks. It may need to re-align the existing

1 Such a reallocation would not constitute a formal Project Restructuring.

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embankment, usually to provide additional setback to avoid on-going \bank erosion. This could cause additional disruption to some existing settlements, beyond the strip of land required for raising crest levels.

23. Repairing/Upgrading and Construction of Regulator Hydraulic Structures: Regulators and drainage cum flushing inlets/ sluices of many polders are not functioning properly due to natural sedimentation and poor maintenance of the structures. These structures will be rehabilitated under CEIP project to improve the drainage system in the polders. The improved structures are to be designed to accommodate higher precipitation and effect of sea level rise on river levels due to climate change.

24. Drainage Channel Re-excavation: Drainage channels in most of the coastal polders have been silted up which needs to be re-excavated to improve the drainage condition in the polder areas. The major activities for drainage channel re-excavation include disposal of spoil.

25. Afforestation: The component will support in secondary maintenance schemes for improved O&M, embankment afforestation for protection of embankment toe against erosion. The species for plantation will be selected appropriately. Species selection of trees on the slopes of the embankment will commence after the completion of earthworks in restored and new embankments.

26. Environmental & Social Management Plan: The project has incorporated implementation of Social and Environmental Management Plan as one of the components. The project is recognizing importance of social and environmental management in the rehabilitation of coastal polders which is a positive direction of recognizing the importance of environmental management in project implementation.

27. The key activities under these components for first four polders which will have environmental and social concern are summarized in Table 1.

Table 1: Summary of Works in Four Polders Proposed Interventions Polders Totals

32 33 35/1 35/3 Upgrading of embankment (km) 44.8 48 50 35 178 Retirement of embankment (km) 3.5 1.5 7.3 5 17.35 Forwarding of embankment (km) 0.5 0 5 0 5.5 Construction of drainage sluices 11 13 15 4 43 Construction of flushing inlets 2 12 17 10 41 Repair of drainage sluices 0 0 2 0 2 Repair of flushing inlets 21 5 3 0 29 Demolition of drainage sluices 3 0 0 0 3 Demolition of flushing inlets 3 2 3 0 8 Re-excavation of drainage channels (km) 17.5 63.21 70.50 23.50 174.71 Bank protection works (km) 1.50 1.45 1.00 1.70 5.65 Slope protection of embankment (km) 3.30 6.00 17.25 0.90 27.45 Closure hydraulic structure 1 0 0 0 1 Afforestation on the foreshore areas (Est. ha) 35 41 25 20 121

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3. Policy, Legal and Administrative Framework

3.1 Applicable Environmental Legislation in Bangladesh

The Bangladesh Environment Conservation Act, (1995) (amended in 2002), requires that all development projects obtain environmental clearance from the Department of Environment (DoE), Ministry of Environment and Forest (MoEF). Similarly, the World Bank’s environmental safeguard policies require an environmental assessment to be carried out for projects being considered for its financing. The EIAs carried out for the four polders fulfill both of these requirements.

Under the Environmental Conservation Rules (1997) a classification system has been established for development projects and industries on basis of the project objective. These categories include Green, Orange A, Orange B, and Red. The construction, reconstruction, expansion of polders and flood control embankment is categorized as Red in accordance with the DoE‘s classification. For ‘Red’ category projects, it is mandatory to carry out an EIA including and EMP and where necessary develop a Resettlement Plan for getting environmental clearance from DoE.

Guidelines for Industrial and Development Projects (1997) were prepared by the Department of Environment (DoE), the regulatory and enforcement organization under MoEF. The document provides guidance for preparing an EIA.

3.2 Applicable Social Legislation in Bangladesh 28. Infrastructure development projects using lands in Bangladesh is designed and implemented under the legislative and regulatory framework to compensate the affected persons due to land acquisition using the power of eminent domain. Whenever it appears to the Government that any property in any locality is needed or is likely to be needed for any public purpose or in the public interest, the property is acquired using eminent domain. Land acquisition is governed by the Acquisition and Requisition of Immovable Property Ordinance, 1982 (Ordinance II of 1982, ARIPO 1982). The ordinance supersedes earlier laws including the Land Acquisition Law of 1894 and others that have been in force between 1947 and 1982. In addition to the Ordinance, acquisition of any land or forest area, in Chittagong Hill-Tracts (CHT) districts require consent under the Chittagong Hill-Tracts (Land Acquisition) Regulation 1958, the CHT Regional Council Act 1998 and the Forest Act (1927). There is no national policy in Bangladesh governing social effects of infrastructure development projects on the project area communities. However, the Constitution of Bangladesh and the national development strategy (Poverty Reduction Strategy Paper 2005-2009) provides some rights to the affected persons, communities and groups those are not upheld in the ARIPO 1982, the instrument followed for land acquisition.

3.3 Other Relevant Legislation in Bangladesh 29. In addition to the Bangladesh Environmental Conservation Act and Rules, there are a number of other policies, plans and strategies which deal with the water sector, agricultural development, coastal area, protected area disaster management and climate change. These are the National Water Policy, 1999; the Forest Act 1927 (last modified 30th April 2000); National Forest Policy, 1994; the National Conservation Strategy1992; National Environmental Management Action Plan (NEMAP), 1995; National Agricultural Policy, 2010; National Food Policy 2006; National Food Policy Plan of Action, 2008-2015; Food Grain Movement Policy, 2008; Bangladesh Country Investment Plan (CIP), 2011; National Fisheries Policy, 1996; Standing Orders on Disaster, 1999 (revised in 2010); Bangladesh Climate Change Strategy and Action Plan, 2009; National Plan for Disaster Management, 2010-2015.

3.4 International Treaties 30. Bangladesh has signed most international treaties, conventions and protocols on environment, pollution control, bio-diversity conservation and climate change. A list of some of these treaties is presented below.

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Protection of birds (Paris) Protection of birds in wild state Ramsar Convention Protection of wetlands Protocol Waterfowl Habitat Amendment of Ramsar Convention to protect specific habitats for

waterfowl World Cultural and Natural Heritage (Paris) Protection of major cultural and natural monuments Bonn Convention Conservation of migratory species of wild animals Prevention and Control of Occupational hazards

Protect workers against occupational exposure to carcinogenic substances and agents

Occupational hazards due to air pollution, noise & vibration (Geneva)

Protect workers against occupational hazards in the working environment

Occupational safety and health in working environment (Geneva)

Prevent accidents and injury to health by minimizing hazards in the working environment

Occupational Health services To promote a safe and healthy working environment Civil liability on transport of dangerous goods (Geneva)

Safe methods for transport of dangerous goods by road, railway and inland vessels

Safety in use of chemicals during work Occupational safety of use of chemicals in the work place Convention on oil pollution Legal framework and preparedness for control of oil pollution UN framework convention on climate change (Rio de Janeiro)

Regulation of greenhouse gases emissions

Convention on Biological Diversity (Rio de Janeiro)

Conservation of bio-diversity, sustainable use of its components and access to genetic resources

International Convention on Climate Changes (Kyoto Protocol)

International treaty on climate change and emission of greenhouse gases

3.5 Implications of the World Bank Policies on CEIP & Environmental Category

31. The project is classified as a Category A project, due to the environmental issues associated with project activities involving major civil works to upgrade and improve existing coastal embankment to protect against tidal flooding and storm surges. Since the coastal area is of high vulnerability certain negative environmental impacts may occur during the implementation and operational phase on overall polder system. There may be localized impact on the natural habitats especially on the fish spawning site and protected areas, during the implementation of the civil works. Sundarbans the largest Mangrove forest of South Asia is in close proximity of the 6 districts of 17 polders.

32. The environment assessment (OP/BP 4.01), natural habitats (OP/BP 4.04) and forests (OP/BP 4.36) policy have been triggered for the proposed operation. Although no direct impacts on physical cultural resources are expected, a screening mechanism has been incorporated into the EIA process to identify any impact on archeological, paleontological, historical, religious, or unique natural values. Physical cultural resources (OP/BP 4.11) are considered in the environmental framework preparation.

33. The legislatives and regulatory framework governing land acquisition for development projects in Bangladesh provides for compensation for lands to be acquired and any assets developed on the lands. The provisions of law are not adequate to deal with the adverse impacts associated with land acquisition and involuntary displacement of peoples for project purpose. The law does not cover project-affected persons without title and does not ensure replacement value of the property acquired. The law does not initiate any measure for restoration of livelihoods of the affected persons. As a result, land acquisition potentially diminishes productive base of affected families which is against the spirit of the Bank operational policy on involuntary resettlement (OP 4.12).

34. Private land will be acquired for rehabilitation and upgrading of existing embankments, and construction of hydraulic structures under the project. Project interventions will also displace household and persons from their place of living and livelihoods. The acts therefore, trigger the Bank OP 4.12 on involuntary resettlement. No tribal people are existent in and around the polders selected under the project. Therefore the Bank OP 4.10 is not triggered under this project.

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3.6 Compliance with Bangladesh Legislation and World Bank Safeguard Policies

35. The present status of compliance of the project with Bangladeshi legislation and harmonized safeguard policies is indicated in Table 2.

Table 2: Compliance of project with GOB legislation and World Bank Safeguard Policies

Legislation/Policy Actions taken to comply GOB Environment

Conservation Rules, GOB-EIA guidelines and conditions by DOE

TOR for EIA study approved by DOE EMP/IEE for sites prepared EIA for CEIP prepared and submitted for approval Permanent consultations with stakeholders and disclosure of EIA Application for ECC

EIA guidelines for Industrial Projects

Post Project Monitoring Plan included

International treaties Verification protected sites, Red List and protection of vulnerable habitats The Acquisition and Requisition of Immovable Property Ordinance 1982 (Ordinance II of 1982)

Land acquisition plans have been prepared for the four polders under the first package of civil works

World Bank and DOE

Early screening and Scoping

Previous environmental studies reviewed (IEE, EIA -WB)

Participatory approach 62 meetings, national and local workshops, consultation meetings and focus group discussions held

Integrate EA and SA Natural environment, human health, social aspects, physical cultural resources integrated in planning documents

Risk assessment Labour, health and safety risks determined Environmental Code of Practices (occupational health, labour) in tender documents contractor

Climate Change Impact climate change studied Cumulative impacts on the polder area determined Other relevant project activities have been studied

Alternatives Alternative with/without project analysed Environmental and Social Aspect analysed in terms of technical and economic point of view

Involuntary Resettlement

Census of affected persons irrespective of title to land has been carried out in the fours polders under the first construction package Replacement cost of affected land and other physical assets has been determined that will be updated prior to implementation Resettlement Action Plan has been prepared for the four polder under the first year package

Pollution Baseline survey of environmental quality carried out Stricter Environmental standards applied and Environmental Code of Practices (ECPs) included in contract documents

Natural habitats Verification of protected areas and vulnerable habitats carried out Wildlife survey (baseline) carried out

Physical and Cultural Resources

Verification carried out (Baseline Survey) Chance find procedure included in contract documents

Gender Women were particularly consulted during SIA and EIA Gender framework is included in the SMRPF Both genders are represented in the implementation arrangement of RAP and particular attention is given on women headed households

Consultation and Information Disclosure

Early consultations and participation of affected people in RAP and EMP Disclosure of EIA summary of each polder and EMF in Bangla Stakeholder consultation meetings, focus group discussions and formal public consultations held

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4. Project Alternatives 36. Without Project Alternative. From the environmental view point, an alternative analysis is an important tool for the best selection of the project, implementation process, and operation mechanism in terms of environmental acceptability of the chosen method. Hence a “no action alternative” has been undertaken and documented in the EMF report. It indicates that without the project the current vulnerable situation of the polders is likely to substantially worsen (there will be further tidal and storm surge flooding and inundation, more saline water intrusion, less productive agriculture and more damage if a cyclonic event was to occur).

37. With Project Alternative. Technical, Financial, Economic, Environmental, and Social Considerations of Selected Options. An attempt has been made to evaluate the technical, financial, economic, environmental, and social considerations of the selected option and is presented in Table.3 below. The proposed project is likely to have major environmental and social benefits. But in order to mitigate some of the negative impacts it will entail, a SMRPF and EMF have been prepared to ensure that these impacts are mitigated to the extent possible and that the CEIP is environmentally sound and sustainable as well as in compliance with the safeguard requirement of World Bank and GoB.

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Table 3: Technical, Economic, Environmental and Social Considerations

Intervention Considerations

Technical Financial/Economic Environmental Social Upgrading existing embankment (increase height andwiden slope) and Retirement of existing embankment

Better protection against cyclone surges(taking into account climate change impactsuch as sea level rise and storm surge intensification).

Protection to river bank erosion

Prevention of salinity intrusion in the polder

Economic savings from reduced damages caused by floods (including damages on houses, roads, and agriculture)

Improve cropping intensityand hence boosting the local economy

Improved surface water quality; improved natural vegetation

Reduced loss of lives and assets thanks to increase protection during cyclonic events. This will bring poverty reduction.

Improve employment and agricultural income especially to small farmers thus alleviating poverty.

Bank revetment, slope protection

Enhanced embankment protection against tidal wave action of rivers, provide erosion protection

Financial savings from reduced damages caused by the floods; increased life span for the infrastructure and associated water control structures; improved earnings of local people through employment during bank revetment works and slope protectionworks.

Improved embankment stability; reduced soil erosion; and provide good means of transportation

Reduced loss of lives and assets which would bring poverty reduction; increased employment opportunities for local people.

Foreshore plantation

Enhanced embankment protection against tidal wave action of rivers, provide erosion protection

Improved earnings of localpeople through employment during afforestation and benefits from plantation.

Improved embankment stability; reduced soil erosion; enhanced soil quality; improved air quality; enhanced aesthetic value of the area.

Employment opportunities for local people; income from timber and other plantation products.

Replacement of existing drainage sluice with drainage-cum-flushing sluice and construction of new flushing sluices where needed

Channel

re-excavation

Better functional performance in both flushing and drainage.Reduce water logging and drainage congestion

Financial savings against damages due to water logging, drainage congestion, and salinity intrusion.

Agricultural production will be boosted as dry season rice cropping would increase

Dredged soil can later be used in construction works and will save construction cost

Removal of inactive sluices would improvethe drainage characteristics

Water logging, drainage congestion would be reduced.

Increase navigability of water ways and fishhabitats would improve, the ecosystem will be enhanced

Increase agricultural production will improve people’s earnings and reduce poverty.

Increase in cultivable area, increased availability of irrigation water thus increased farm income for local community; increased farm labor opportunities.

Closure embankment

Better control against entry of silt free water. Restricts the entry of saline water as well. Increases the elevation head of water in the channel to ensure good flow

Better agricultural prospects (dry season boro cropping would be possible)

Environmentally compatible. Surface water quality inside the polder would be enhanced.

Better agriculture practice could be achieved which would improve cropping pattern, enhance local earnings, and reduce poverty.

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5. Baseline Conditions of Project Area 38. Topography. The polders covered under the project are located in the southwest region of Bangladesh. Topographically, this area is flat and developed by sedimentation process by the three mighty rivers of the country. Before construction of the polders, the area used to be inundated by tidal flooding and was vulnerable to storm surges because of its flat topography. The polder area is crisscrossed by a large number of creeks and water channels. The sea level rise caused by global warming would lead to permanent inundation, drainage congestion, salinity intrusion and frequent storm surges in the region.

39. Morphological condition: The coastal zone of Bangladesh comprises ‘Ganges Tidal Plain’ (GTP) that lies in the west of the Meghna estuary (bounded by the Tetulia River) and ‘Chittagong Coastal Plain’ (CCP) that lies in the south and east of the Meghna estuary. The GTP (West) is dominated by the Sundarbans forest, which covers the first 60 to 80 km inland from the coastline. Being a mature delta formation, the area has long drainage lines of low gradient. The rivers are sinuous and flow generally south through the plain. Tidal flows extend far inland. Many polders have been constructed, some of them 150 km from the coast. Due to the movement of the tidal wave from west to east along the coast, there is a net flow in the same direction in interconnecting tidal channels between the main river channels. Tidal river channels have tended to silt up and reduce their capacity in response to the reduced tidal prism caused by empoldering land areas. As a result, maximum water levels and inland tidal range are higher than before, such as at Khulna.

40. The Baleswar River forms the boundary between the west and east parts of the GTP. The rivers are generally more active morphologically than in the western part of the plain. Wind waves erode the bank line at water level over the tidal range and currents cause erosion and steepening of the bank under water at the outside of bends, leading to shear failure. This results in migration of the rivers and erosion of polder embankments.

41. The CCP is a narrow strip of land along the eastern side of the Bay of Bengal with relatively short drainage lines between the hills to the east and the coastline. The rivers are steep and flashy. The flood flows are sediment laden and with the reduction in slope from the hills to the coastal plain, the river channels tend to become severely meandering.

42. River functionalities and estuary processes: Dynamic river and estuary processes are, of course, mostly to be seen in the Meghna Deltaic Plain (MDP), rather than in the other three areas. The Brahmaputra and Ganges rivers, via the Jamuna and Padma rivers, bring roughly two billion tons of sediment per year into the system, of which some 70% is fine material, very fine sand and silt. Near the head of the Meghna estuary, around Chandpur and upstream, the dominant processes are fluvial, resulting in braiding and the migration of the thalweg (deepest or main channel). Further downstream, tidal and salinity effects begin to have an influence also, but as far south as Ramgati the migration of the thalweg is the most important process. Dramatic thalweg migration in the much smaller estuary of the Feni River is also eroding a polder embankment. When a thalweg approaches a river bank it tends to erode the bank mainly below water level, so that an embankment built close to the bank will be undermined or outflanked by removal of soil below the level of its toe. In the seaward parts of the estuary, tidal processes tend to dominate over fluvial ones. In many parts the tidal flow is bi-directional, but the ebb and flood velocities are unequal (tidal asymmetry, leading to ‘tidal pumping’ of sediment). In other places, notably north and west of Swandip Island, ebb and flood currents follow different routes (mutually evasive currents). In both cases tidal action moves sediment, often towards inland direction. Under some circumstances sediment can be trapped.

43. Sedimentation and Accretion: Land erosion and accretion are common natural phenomena in the coastal zone. Major stable accretions were found in the coastal belt of Patuakhali and southern part of Bhola district. The past rate of net accretion in this region was 12 sq. km per year. Erosion at the rate of 3 sq. km and accretion at the rate of 15 sq. km took place in the last 20 years. Islands in this region may grow by silting up of small channels. The past trend of erosion and accretion may continue to follow for

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the next 25 years2. Major threat of erosion in the next 25 years may be in the region of northern part of Bhola, Lakshmipur coastline, north and northeastern parts of Hatiya, north and western parts of Swandip. Slow accretion may take place in the southern part of Hatiya and Noakhali mainland. Erosion and accretion in the Feni coastal belt is expected to be insignificant.

44. Tropical Cyclones and Tidal Flooding. Cyclones have been hitting the coasts of Bangladesh very frequently in the recent decades. From 1901-1957 only 11 cyclones hit the coastal areas of Bangladesh, while from 1957 to 2009 a total number of 55 cyclones hit the area. So, in the last 52 years, the number of cyclones hitting coastal areas of Bangladesh has increased 5 times compared to the previous 57 years. In a frequency study carried out by Hennon, P. et al. (2010), the Bay of Bengal has been found to be the second most frequently visited place in the world by cyclones with about 20 cyclones per decade. Most recently, the cyclones Sidr (2007) and Aila (2009) severely affected the population in the area. The storms also affected the Sundarbans, which provides natural protection to the south west of Bangladesh. During Aila, surge water entered in most of the polders by overtopping the river banks and embankments. As a consequence, the embankments at various locations were badly damaged.

45. Drainage Congestion and Water Logging. The project area comprises of a number of khals and water channels with tidal influence. Most of these khals are used for drainage of the polder area. These channels are also interconnected by a lateral channel draining into the main rivers. The water channels and khals of the polders cannot drain out properly particularly during monsoon, due primarily to high siltation in these water bodies as well as due to the malfunctioning of regulators. Drainage performance of the linked khals has also been gradually decreasing due to sedimentation at both upstream and downstream of the regulators. Most of the water control structures are damaged which hampers proper drainage of the polder. Over the years, improper maintenance of internal khals and malfunctioning of regulators have resulted in drainage congestion. Up to 35 percent area of some polders has been affected by this problem. In addition, up to 40 percent area of some polders has been affected by water logging.

Environmental Quality 46. Air quality. Air pollution is not of much significance in the coastal area of Bangladesh. During field visits the overall air quality was found to be good. There is no heavy industry within the polders. Table 4 presents the ambient air quality measured in the polders included under the present study. The values suggest that the concentrations of the key air quality parameters (SPM, SOx, NOx) are well within the standard values for Bangladesh for the rural and residential areas.

Table 4: Ambient Air Quality Parameters in Project Area Sample Location

Air Quality Parameters

SPM (μg/m3) SOx (μg/m3) NOx (μg/m3) Polder 32 109 <25 18 Polder 33 120 <25 24 Polder 35/1 155 10 21 Polder 35/3 125 <25 20 Polder 39/2C 180 <25 18 Bangladesh standards (residential and rural areas) 200 80 80 Bangladesh standards (sensitive areas) 100 30 30 Source: CEGIS field survey, May 2012

47. Noise. Vehicular traffic on road is a source of noise in the polders, as shown in Table 5 below. Some of the measured noise values exceed the prevailing standards.

2 Integrated Coastal Management Zone Management Program (2001)

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Table 5: Ambient Noise in Project Area (Measured at 5 Polders) Sample Location

Noise Level

(dB)

Polder 32 58.60 Polder 33 56.50 Polder 35/1 82.42 Polder 35/3 84.30 Polder 39/2C 82.40 Bangladesh standards (residential areas) Daytime: 50; Nighttime: 40 Bangladesh standards (silence zone) Daytime: 45; Nighttime: 35 Source: CEGIS field survey, May 2012

48. Water quality. The surface water quality in polders is influenced by the hydrological connections of the water bodies within the polder area with the surrounding rivers. The rivers and lakes around the polders provide tidal inflow during the periods of high tide or low rainfall. The water bodies inside the polders are mostly free flowing khals, and apart from salinity intrusion during January to April, the other water qualities parameters remain within the acceptable range. Table 6 presents the water quality measured in the polders.

Table 6: Surface Water Quality(Measured at 5 Polders)

Sample Location Water Quality Parameters

Salinity (ppt)

Temperature (°C)

TDS (ppm)

EC (mS/cm)

DO (mg/L)

pH

Polder 32 5 22.6°C 1233 1.67 5.8 7.1 Polder 33 3 22.9°C 1334 1.79 4.9 7 Polder 35/1 3 22.0 1,654 1.88 5.6 7.0 Polder 35/3 3 22.2°C 1622 2.17 7.2 7 Polder 39/2C 3 19.0°C 1128 2.35 5.4 7 Standard Value (Bangladesh)

Irrigation - 20-30 - - 5.0 7.0-8.5 Fishing - 20-30 - - 4.0-6.0 6.7-9.5

Source: CEGIS field survey, December 2012 49. The groundwater quality parameters, measured in the polders during the month of May, were found to comply with the drinking water quality standards (ECR’97). The ground water quality of the polder area is presented in Table 7.

Table 7: Groundwater Quality

Groundwater Quality Parameters

Temp (°C)

pH Chloride

(mg/l) Iron (Fe)

(mg/l) SS

(mg/l) Arsenic (As)

(mg/l)

Coliforms

Polder 32 23.1 7.01 532 0.84 6 0 0 Polder 33 23.4 7.13 469 0.91 5 0 0 Polder 35/1 25.2 7.45 532 0.88 4 0 0 Polder 35/3 24.2 7.56 514 0.98 5 0 0 Polder 39/2C 25.4 7.56 355 0.78 5 0 - Drinking water quality standards ( ECR'97)

6.5 – 8.5 150 – 600 0.3 – 1.0 10 0.05 50 or less

Source: CEGIS field survey, May 2012 50. Climate and Meteorology. The climate of the project area is tropical in nature with three seasons namely summer/pre-monsoon from March to May, monsoon from June to October, and winter season from November to February. The rainy season is hot and humid with about 88 percent of the annual rainfall in the area. The winter is predominately cool and dry. The summer is hot and dry interrupted by

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occasional heavy rainfall. The Project area lies in the south west part of Bangladesh, where monsoon comes in the month of June and recedes in the late October. Temperatures are higher in April and May while January is the coldest month of the year. In the coastal region of Bangladesh , annual rainfall increases from a little over 1,700 mm in the west to over 3,200 mm at Cox‘s Bazar in the east. In the project area, the average annual rainfall is between 1,900 and 2,000 mm. Soil and Agriculture

51. Soils. Generally, there is a pattern of grey, slightly calcareous, heavy soils on river banks and grey to dark grey, non-calcareous, heavy silty clays in the extensive basins. Non-calcareous grey floodplain soil is the major soil type. Acid sulfate soils also occupy significant part of the area where it is extensively acidic during dry season. In general, most of the top soils are acidic and sub-soils are neutral to mildly alkaline. Soil texture is the relative proportions of sand, silt and clay, and is a very important aspect for crop production. The soil texture varies from clay to clay loam in the area.

52. Land Types. Land type classification in the country is based on depth of inundation during monsoon season due to normal flooding on agriculture land. There are five land types: High Land (HL, flooding: depth 0-30 cm); Medium Highland (MHL, flooding depth: 30-90 cm); Medium Lowland (MLL, flooding depth: 90-180 cm); Low Land (LL, flooding depth: 180-360 cm); and Very Lowland (VLL, flooding depth: above 360 cm). Land types in the polders consider for the first phase are presented in Table 8.

Table 8: Land Types in Polders Land Types/Flooding Polder 32 (ha) Polder 33 (ha) Polder 35/1 (ha) Polder 35/3 (ha)

High Land (0-30 cm) 2,847 1,653 1,155 1,208

Medium Highland (30-90 cm) 3,650 2,950 9,045 3,529

Medium Lowland (90-180 cm) 0 517 200 353

Lowland (180-360 cm) 0 0 - -

Very Lowland (above 360 cm) 0 0 - -

Total 6,497 5,120 10,400 5,090Source: Feasibility Report (Agriculture) of CEIP, 2012

53. Land use. The coastal region covers about 3.6 million acres of Net Cultivated Area (NCA) with average cropping intensity of 175%, where mostly local and hybrid rice crops are grown3. The 139 polders cover a gross area of about 1.12 million ha, of which about 64% are available for crop cultivation. Agriculture practices in the coastal zone are mainly rain-fed cropping and irrigated cropping system. About 20 percent area is covered by settlements, water bodies, and other structures.

54. Farming Practices. Farming practices within the polders under study have adjusted to agro-climatic conditions as well as to physical, biological, and socioeconomic factors prevailing in area. The siltation of rivers and channels cause drainage congestion/water logging during monsoon, natural calamities like cyclones and storm surges cause devastating crop damage in the area. Scarcity of suitable non-saline water for irrigation during dry months (December through April) is a major impediment towards expansion of irrigated agriculture in the Polder. The conditions in polder are also suitable for fish cum rice cultivation. A limited variety of crops are grown due to the conditions prevailing in the area. Rice is the main crop grown because of its adaptability to diversified ecological conditions. Sugarcane and banana are annual crops in the area. Various non-rice crops like, summer vegetables, winter vegetables, jute, oilseeds and spices are also grown in the area.

55. Cropped Area and Production. The existing cropping pattern is predominantly rice based. Rice covers a major portion of the total cropped area (approximately 75%). The remaining area includes other crops in both Kharif and Rabi seasons. Rabi crops are wheat, winter vegetables, bean, cowpea, pulses, oilseeds, potato, sweet potato, chili, cowpea, millet, water melon, ground nut, etc.

3 Bangladesh Bureau of Statistics, 2009

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56. Irrigation. Irrigation is generally provided to boro (HYV) crop. Irrigation also provided to other crops like chilies, potato, vegetables and spices in dry season. Surface water is the major source of irrigation. Most of the farmers provide irrigation with the help of surface water for raising seedlings, land preparation and transplantation up to mid March. The salinity of the surface water gradually increases and reaches beyond the tolerance limit during April-May (EC> 10.0 dSm-1). But they cannot use this source for irrigation purpose due to salinity of water from the start of March to May. The surface water becomes fresh due to onset of monsoon during rainy season (EC< 1.5 dSm-1). Rice verities such as T. Aus (LV), T. Aman (LV), T. Aman (HYV) are grown in rainfed condition.

57. Farm Labor. In the Project area, mostly manual labor is used for cultivation. Therefore, agricultural labor is considered as one of the essential inputs for crop production. The labor requirement does not remain the same throughout the year and varies from crop to crop.

Fisheries

58. Fisheries Resources: The polders are relatively moderate in fish biodiversity though with a decreasing trend because of morphological changes, obstruction to spawning migration, natural and anthropogenic drying up of wild fish habitats, indiscriminate fishing, and loss of river-khal connectivity and water regulatory structures on khals, as described earlier as well. Aquatic environmental quality is satisfactory in the Polder though some pollutants are released from cultivation fields affecting fish production. The water quality of internal khals is likely to be degraded particularly during dry season due to improper management of water regulators.

59. Fish habitat and production. Fish resources of the Project area are diversified with different fresh and brackish water habitats. Open water fish habitat of the Project area including surrounding rivers and khal, act as major arteries of fish migration into and within the Project area. Fish habitat of the polders can be classified under two broad categories: capture fisheries and culture fisheries. Internal khals are considered under capture fish habitat, whereas the ponds are classified under culture fisheries, comprising of four types including prawn ponds (galda gher), shrimp pond (bagda gher), homestead ponds and commercial ponds. Habitat distribution and fish production of the five polders is presented in the table below.

Table 9: Fish Habitats in Polder 35/1(Measured at 5 Polders)

Fisheries Category

Habitat Types Area (ha)

Fish Production (MT)

Polder 32 Capture Khal 241.00 36.10 Culture Ponds 95.00 134.95

Polder 33 Capture Khal 693.00 177.00 Culture Ponds 533.00 407.00

Polder 35/1 Capture Khal 187.00 24.00 Culture Ponds 2,358.50 2,182.00

Polder 35/3 Capture Khal 1,827.25 273.81 Culture Ponds 6,734.00 3,356.54

Polder 39/2C Khal 541.00 127.00 Ponds 378.00 601.00

Source: Draft final of fisheries report, Volume-I, CEIP, 2012 Ecosystem and Biodiversity

60. Bio-ecological Zones and Ecosystems. The project area supports terrestrial, aquatic, and mangrove ecosystems. The major divisions found within the terrestrial ecosystems are agricultural land, settlements/ homestead vegetation, embankment and roadside vegetation, and fallow lands. Aquatic habitat in this area includes external rivers, internal channels, some seasonal wetlands and homestead ponds.

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61. Forests: The southwestern part of coastal region houses world’s largest mangrove forest- the Sundarbans. The mangroves forests are transitional zones between fresh and marine waters, and are rich in marine and terrestrial flora and fauna. The Sundarbans Reserve Forest occupies an area of 601,700 hectares of which 406,900 ha forests, 187,400 ha water (rivers, rivulets, ponds, and canals), and 30,100 ha form wildlife sanctuaries, and 4200 hectares are sand bars. Some of the coastal polders fall within these protected areas, mainly within the 10 km peripheral area of the Sundarbans Reserve Forest which is declared as Environmentally Critical Area (in Satkhira, Khulna and Bagerhat district). 62. Wildlife. Bangladesh is a part of the Indo-Burma biodiversity hotspot. The coastal zone contains several ecosystems that have potential conservation values. The wildlife species available in these regions are generally classified as amphibians, reptiles, birds and mammals.

Socio economic conditions

63. According to the population census 2001, the total population of coastal area was about 28 million, which is about 22% of total population of Bangladesh. Adjusted population in 2010 was estimated about 31 million in the coastal area. Regionally the population is highest in Barisal (37%) and lowest in Noakhali (17%). The ratio of urban-rural population in the coastal region is 17:83. According to Population census 2001, the average population density is 719 per sq.km, average literacy rate is about 50% and average household size is 5.4 in the coastal zone.

64. The livelihood activities of coastal population are multidimensional. According to Population census 2001, agriculture, livestock and fisheries provide the principal source of income for around 60% of households in most parts of the coastal zone; although on the CCP the proportion is lower (53%). In this area, there are more households whose income comes from services and employment in the commercial, industrial and government sectors than in other parts of the coastal zone – 23% compared with 15-16% in the GTP and about 20% in the MDP. Across the whole coastal zone, “business” provides the principal source of income for about 13% of households.

65. The economic activities of farmers usually are concentrated to land and water resource based activities such as agriculture, fisheries, salt farming, etc. Similarly fishermen are engaged mainly in fisheries, agriculture, fish related business, salt farming, etc. The economic activities of wage labors are more diversified than other groups, although most of them are engaged in agriculture works. Woman are usually engaged in household based works like homestead gardening, poultry and livestock farming, cottage industry, small business, fish fry collection, etc.

66. In some areas, especially along the eastern coast and in the area north of the Sundarbans, brackish water aquaculture is important for the production of shrimp. Along the east coast there is also widespread production of salt during the dry season, often in association with shrimp during the wet season.

67. Economic activity in this zone is subject to damage and disruption by cyclones and storm surges, and erosion processes that are a permanent feature of the area. Hence the population of the area is very vulnerable to natural disasters. Protecting social and physical infrastructure and productive investments (in agriculture, industry and services) is an important component, in this zone, of the efforts to reduce poverty, improve livelihoods and increase economic activity.

68. In addition, a large part of the population has poor access to safe drinking water supply and sanitation and public health facilities due to poor infrastructures, communication system and natural hazards like arsenic and salinity. Improvement of the coastal polders may facilitate development of communication and infrastructures for supporting public utility services.

69. There are local government institutions and NGOs working in the coastal region. However, they are not institutionally and financially very strong and are largely dependent on the central government or development partners, which limit development activities that could be taken by them on priority basis. Regarding water management, BWDB has been establishing WMOs to manage water infrastructure in different projects. This initiative requires a long process of social mobilization, but once established WMO have proven to work quite successfully.

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6. Potential Impacts

6.1 Pre-construction Phase Impacts

6.1.1 Social Impacts 70. Involuntary Resettlement. Rehabilitation of embankments and upgrading of drainage structures in four polders under the first year package will require acquisition of about 162 ha of land mostly private. Implementation of the project in these four polders will cause physical and economic displacement of 4,417 households (of which 2,396 residential households, 1463 commercial enterprises, 289 both residential and commercial premises, 237 households will be losing only land (largely agricultural); 35 households will be losing fish pond/gher and 1 household will be losing trees). Civil works in the four polders will physical displace 152 common cultural properties. To address this involuntary resettlement, a RAP has been prepared for the four polders in accordance with the World Bank OP 4.12. Similar impacts are envisaged in all remaining polders for implementation under subsequent works packages for which RAPs will also be prepared. Before the commencement of the construction activities, the RAPs will be effectively implemented.

71. Losses of Land, Livelihood and Income. Compensation for loss assets will be provided at full replacement cost determined at the time of dispossession of the assets including land, structures, trees, etc. A total of 237 persons will be losing productive lands while another 1752 households will be losing commercial and business premises affecting their livelihood and income. The 2681 relocating households will be losing workdays during the transition from shifting to reconstruction. Mechanisms have been established for evaluation of replacement rates. Compensation package will include i) compensation payment as per the law and ii) the amount to bridge gaps between the amount under the law and the replacement rate ad determined by the evaluation committee (Property Assessment and Valuation Committee). Additionally, livelihood assistance is planned to include short and long-term assistance, with the objective to assistance in the achievement of livelihood restoration. Households physically displaced and affected economically will receive due compensation, relocation assistance and allowances in accordance with the project resettlement policy.

72. Relocation. The dynamics of squatters’ settlement have been considered in the development of relocation strategy for displaced households, business and community premises. The project identifies self-relocation (permanent), group relocation (permanent) and temporary relocation options as a strategy for relocation of the affected squatters and other households. The Project Affected People (PAPs) will be provided with adequate subsistence assistance to mitigate the livelihood disruption during relocation and reconstruction. The Physical Relocation Assistance Committee (PRAC), in consultation with the District and Upazila administration, will find out alternative land in the polder areas suitable for relocation of the squatters and other households and shops. The potential relocation sites can be vacant public land or unused BWDB land, untitled new lands suitable for resettlement, and unproductive private lands.

73. Embankment settlers having their own land inside the polder will be encouraged to move back to their own lands. The squatters/encroachers will be encouraged for self-relocation and assisted in the process of finding out alternative lands, where necessary. Project will undertake land search and assist the affected households/squatters/encroachers in relocation and resettlement on a more permanent site. Landless squatters can be organized in groups to facilitate their jointly purchasing alternative lands inside the polder with the compensation they will receive for replacement value of their structures and transfer and reconstruction of structures, and move out of the embankment permanently. This option has been found to be feasible as land market in the project area permits the resettlement assistance package to afford.

74. At critical circumstances of failure by the landless squatters to afford permanent alternative sites elsewhere within the polders, BWDB will allow landless squatters (having no land for homestead) back on the embankments after completion of earthwork. They will be moved temporarily in places of their choice during civil works construction by sections in affordable time of three to 6 months. After the construction is complete, they can move back again, if they choose to do so.

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6.1.2 Environmental Impacts

75. Changes in Land Use. Land would be needed to establish temporary facilities including contractor office, labor camps, equipment yard, and material yard. It is estimated that about 20 ha of land would be needed to establish these facilities for the rehabilitation works in each polder. Exact location of these facilities is not known at this stage, and contractor will select the sites under the guidance of the BWDB and Design and Construction Supervision Consultants (DCSC). This is a temporary in nature, but may change the land use of the area and thus potentially affect the communities.

76. Loss of Agriculture Land: Agricultural land may be permanently lost in case of realignment/retreatment of a certain section of the polder. It has been observed realignment/retreatment of many segments have already done in the field. In terms of loss of agricultural land the loss is irreversible. But realignment/retreatment is proposed where embankment and land under continuous river assault and such land loss is unavoidable due to the nature of the river in that location.

77. Loss of Trees: There will be loss of trees during pre-construction stage due to clearing of land for base widening of polder, realignment of polder in some areas and establishment of construction camps. The project has an afforestation component. The component should prepare an afforestation plan based on the local species and number of trees cut. This will reduce the negative impact substantially in the long run. The overall impact is expected to be negative to positive in the long run. However, there will be a transition phase of impact between immature tree at early stage and matured tree at the later stage.

78. Increased Vehicular Traffic during Mobilization. During mobilization of contractors, equipment, machinery, material, and manpower will be transported to the polders resulting in additional traffic on roads and in waterways. This traffic may potentially cause traffic congestion particularly at roads and jetties. Of particular importance are schools within 500 m of the embankment and markets. The bazaars already face traffic congestion and additional project-related traffic will aggravate this problem. To address this problem, each contractor will prepare a polder-specific traffic management plan for each polder.

79. Noise Quality. Mobilization of construction vehicles for equipment and material transport will affect the noise level at the surrounding sites. The traffic volume will be increased both in the road and river. The polder protected area is populated and number of common infrastructure like schools, madrasa, mosques is inside the polder. The increased traffic volume is anticipated to increase the noise pollution.

80. Preparation of Facilities for Contractors and Labor Force. Establishing the contractors’ temporary site facilities may involve land clearing, land leveling, excavation, and construction of buildings. These activities may potentially cause air and water contamination, noise generation, safety hazards, hindrance to local communities, and other similar impacts. To address these issues, contractor will prepare site establishment plan and obtain approval from the DCSC. Site facilities will be established at a safe distance from communities, avoiding schools, hospital, religious centers, market places, road junctions, densely populated settlements, productive agriculture lands, archeological sites, etc.

6.2 Impacts during Construction Phase

6.2.1 Social and Gender Issues

81. It is envisaged that about 60 percent construction workers will be recruited from within the polders while the remaining will come from other areas. The presence of outside laborers in the area may create friction and conflict between the local labor and outside labor, and between local community and outside labor. Presence of a large number of outside labor can potentially cause encroachment in the privacy of local population particularly women and their mobility can be negatively affected. To address these issues, awareness programs will be conducted through public consultation measures such as village scoping sessions, meetings, and placement of bill boards with assistance from the Union Parishad Chairman, Upazila Nirbahi Officer (UNO) and BWDB local officers; liaison with the communities will

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be maintained; cultural norms of the local community will be respected and honored; and GRM will be established to address the grievances of local as well as outside laborers. The project will provide a specific long-term employment opportunity for disadvantaged women, following established BWDB practice, through Labour Contracting Societies (LCS) for equitable physical works in the civil works construction and routine maintenance of polders. The women will be represented in the RAP implementation committees during implementation. The RAP provides special assistance to women affected persons for relocation and livelihood restoration.

82. Losses of Income and Livelihood. Persons whose livelihoods are affected as a result of the project will be supported with short-term income and livelihood restoration assistance, the transitional period. These short-term measures will be for immediate assistance and include the following: (i) compensation for land and other lost assets in full prior to relocation, (ii) temporary or short-term employment in construction activities at the construction sites; (iii) special assistance for vulnerable groups such as women, the aged and disabled. A long-term livelihood support program for post-relocation activities is recommended on the basis of needs after reviewing the performance of short-term assistance.

6.2.2 Environmental Issues

83. Drainage Congestion and Water Logging. The Project activities particularly on regulators and sluices and in water channels may block or clog water drainage channels, potentially causing temporary water logging in the surrounding areas and negatively affecting the cultivation and the associated communities. After the completion of construction activities, this temporary water logging will disappear. In addition, excavation of canals (khals) in the polders is likely to disturb the drainage which takes place through these channels. To address these issues, contractor will be constructing bypass canal before construction of each regulator, sequence of work at the regulators and in the water channels will be carefully planned to avoid drainage congestion, contractor will ensure that drainage channels are not obstructed or clogged by the construction activities, contractor will ensure that construction activities do not cause any water ponding near cultivation fields.

84. Loss of Agriculture. The construction activities, movement of construction machinery, project related vehicular traffic, material stockpiling, waste disposal, and/or camp establishment can potentially damage crops or affect the cultivated land. To address this potential impact, compensation will be paid for any crop damage, contractors will avoid cultivation fields during construction, contractors will avoid agricultural land for material borrowing, material stockpiling, and labor camps, contractors will ensure that no vehicular movements take place inside cultivation fields, contractors will ensure that no material is dumped inside cultivation fields, and contractor will liaise with communities.

85. Impacts on Irrigation. Construction activities particularly on regulators and in water channels can potentially disrupt the crop irrigation thus negatively affecting cultivation. The works on sluices can cut off the incoming water from the river, while the excavation works in water channels can affect water conveyance through them. To address these issues, contractors will construct bypass canal before construction of each regulator, sequence of work at the regulators and in the water channels will be carefully planned to avoid irrigation disruption, and contractors will ensure no negative impacts on crop irrigation.

86. Impacts on Fish Habitat and Migration. Existing drainage sluices will be replaced by new ones as part of the Project. All of these sluices are connected with the khals of the polders. Construction activities on these sluices can potentially affect aquatic habitat and fish migration in the khals. Though the habitat in these khals is already modified as a result of construction of embankments and sluices in 1960s, some fish migration between outside rivers and internal khals still takes place particularly along those, which do not have any water control structure. During the construction activities, the fish migration between the outside rivers and internal khals is likely to be affected. Similarly, fish migration within the Polder between khals and beels can also be affected by the construction activities particularly the khal excavation. To address these potential impacts, contractors will construct bypass canal before construction of each regulator, sequence of work at the regulators and in the water channels will be

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carefully planned to minimize impacts on fish and their migration, and fish (particularly juvenile fish) will be transferred from rivers to polder water channels where appropriate.

87. Soil and Water Contamination. Wastes particularly effluents from the work sites may contaminate the soil and water. Construction material, demolition debris, and/or fuel/oils may enter the river or other water bodies causing contamination. The contractors’ camps will generate domestic solid waste and waste water including sewage. The contractors’ workshops will generate oily water, waste oils, oily rags, and other similar wastes. The stores and warehouse will generate solid waste such as empty cement bags, cardboards, and wooden crates. Improper disposal of these waste streams can potentially contaminate the soils and water resources of the area. Soil and water contamination can potentially have negative impacts on the local community, natural vegetation, agriculture, and biological resources of the area including aquatic flora and fauna. Borrowing material from the river banks may potentially cause increased turbidity in the rivers. Further, release of effluents, soil, and/or sand in water bodies may increase water turbidity, which would prevent sunlight to enter into the water that is necessary for promoting photosynthesis of aquatic plants. To address these problems, the contractors will prepare and implement polder-specific pollution control plans in each polder.

88. Soil Erosion. The construction activities particularly near banks of rivers and other water bodies can potentially cause soil erosion. Similarly, material borrowing can also potentially cause soil erosion. Soil erosion can increase the sediment load and turbidity in the water bodies thus decreasing the amount of sunlight penetrating in the water. To address these issues, operating heavy construction machinery and vehicles close to the banks of rivers and water channels (khals) will be avoided, appropriate erosion control measures (e.g, stone pitching) will be implemented where needed, borrow areas will be re-contoured where needed, untreated embankment slopes will be protected, and works will be avoided in rainy season.

89. Sedimentation. Borrowing material from the river banks may potentially cause increased sediments in the rivers. Similarly, re-excavation of water channels can potentially increase their sediment load. Excavated material from the channels if left along their banks may again enter the water thus increasing their sediment load. In addition, construction material, loose earth/soil, demolition debris, and other materials may enter the river or other water bodies causing increased sediments in them. Run off from construction sites, material yards, camps, and other temporary facilities may enter water bodies increasing their sediment load. To mitigate these potential impacts contractors will protect untreated embankment slopes, excavate channels after dewatering them, will not leave excavated earth and silt on channel banks, will implement measures to protect channels from run-off from work areas and camps, and will obtain borrow material from river banks in a manner not to increase siltation in rivers, and will not leave loose soil after excavation.

90. Safety and Public Health Hazards. The construction activities involving operation of heavy construction machinery, vehicular traffic, and excavation and filling operations may pose some safety hazards to the local population as well as for the construction workers. The fuel storage at the camp sites may also pose safety hazards for the construction staff as well as for surrounding population. Inappropriate waste disposal at the camps and construction sites, and air quality deterioration caused by the Project’s vehicular traffic and construction activities potentially pose health hazards for the construction staff and nearby population. Unhygienic condition and unavailability of safe drinking water for the construction staff will expose them to health risks. In addition, influx of construction staff can potentially expose the nearby population to communicable diseases. To address hazards associated with Royal Bengal Tiger, all the works in/near Bhola River will be carried out in the presence of forest guards. To address the other safety and health hazards, each contractor will prepare and implement polder specific Occupational Health and Safety (OHS) plan.

91. Air Quality Deterioration. Construction machinery and Project vehicles will release exhaust emissions, containing carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOX), and particulate matter (PM). These emissions can deteriorate the ambient air quality in the immediate vicinity of the project sites (particularly along the embankment, and around the channel excavation sites and borrow areas. Furthermore, construction activities such as excavation, leveling, filling and vehicular

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movement on unpaved tracks may also cause fugitive dust emissions. These emissions pose health hazards for the nearby communities as well as for the construction workers. In particular, the settlements and sensitive receptors such as schools near the work areas will be exposed to air contamination caused by the Project activities. To address these issues, demolition of the regulators will not be carried out during the school time (8 am to 1 pm) particularly near the schools, exhaust emissions from vehicles and equipment will comply with standards, proper tuning of vehicles, generators, and equipment will be carried out, to minimize exhaust emissions, construction material (sand/soil) will be kept covered while transporting and stock piled, water sprinkling will be carried out where needed, particularly on the earthen tracks near communities, and vehicle speed will be on low (15 km per hour) on earthen tracks particularly near communities.

92. Noise and Vibration. The construction activities particularly demolition of existing structures, excavation, compaction, operation of construction machinery, and vehicular traffic will generate noise and vibration which are likely to affect the nearby communities. In addition, camp sites may also generate noise. Increased noise levels may cause disturbance, nuisance and even health hazards for the nearby communities as well as for the construction workers. In particular, the settlements near the work areas will be exposed to noise and vibration generated by the Project activities; in addition sensitive receptors including schools along the embankment are likely to be more severely affected by noise. To address these issues, construction activities will be carried out during the day time, noise levels from vehicles, equipment and machinery to comply with national noise standards, vehicles and machinery will have proper mufflers and silencers, noise barriers will be provided at schools and other sensitive receptors, as needed, PPE (ear muffs and plugs) will be provided to labor.

93. Increased Inland and Waterway Traffic. Additional traffic at smaller jetties may cause traffic congestion and hindrance to other commuters, travelers, and transporters. Similarly, for the material transportation from the stock yard to the construction sites, polders’ internal roads can be used; alternatively, the outer rivers can also be used for this purpose. However not all water bodies around the polders are suitable for material transportation. To address these issues, contractors will prepare and implement traffic management plans, contractors will establish new, temporary jetties where needed, river crossing for material transportation will be carried out during nighttime where possible and appropriate, and material transportation will be carried out through rivers during high tide where needed.

94. Impacts on Benthic Fauna. Construction activities including re-excavation of khals, dredging of rivers and discharge of solid wastes and waste effluents can potentially impact the benthic communities of the water bodies. Most of the construction activities will be implemented during dry season, during which time the benthic fauna would be more vulnerable. To address these potential impacts, contractors will not release untreated wastes on soil or in water, and contractors will carry out khal excavation in segment thus minimizing impacts on benthic fauna.

95. Damage / Disturbance to Faunal Resources. Release of untreated waste effluents and contaminants in the rivers and water channels potentially affect the wildlife resources of the area. In addition, the south-western side of Sundarban may face disturbances due to construction activities particularly noise generation, any material borrowing or waste generation inside the Forest. To address these issues, no material will be borrowed from Sunderbans. Also no waste will be disposed in Sundarban, liaison with the Forest Department will be maintained to forestall any negative impacts on Sundarban, contractor will not release untreated wastes on soil or in water, and labor will not indulge in hunting, trapping, or shooting wild animals.

96. Hindrance for Pedestrian and Vehicle Movement. Several markets are located in the polders near the embankments. These markets play an important role by providing source of livelihood of the polder inhabitants as well as meeting the daily needs of the people. Rehabilitation activities along the embankments are likely to disrupt these markets. In addition, the tracks (mostly brick soled) on the embankments are the key transportation routes both for pedestrians and vehicles in the polders connecting the communities and markets. The construction activities along these embankments will result in removal of these tracks thus causing communication and transportation problems to the local population. To address these issues, the works on embankments will be carefully scheduled to minimize impact on local

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markets and transportation routes, the embankment works will be carried out in segments and soil will be placed linearly on half of the embankment, leaving the other half to be used as track and when the works are completed on the first half, it will be opened for local traffic while works will be undertaken on the other half of the embankment, work schedule will be finalized in coordination and consultation with local representatives and communities, local routes will not be blocked as much as possible. If unavoidable, alternative routes will be identified in consultation with local community.

97. Damage to Local Infrastructure. There could be some inadvertent damage to the roads, electricity lines, water channels, jetties, and other structures during the construction activities, transportation of equipment and material, and associated vehicular traffic. To address such eventualities, all damaged infrastructure will be restored to original or better condition.

6.3 Impacts during Post-construction Phase

6.3.1 Social Impacts 98. Livelihood impacts. Project affected persons and communities will experience loss of livelihood sources mainly due to loss of shops/commercial enterprises and agricultural fields. In addition wage earners such as employees in shops and businesses and workers on the agricultural field will also incur impacts on their incomes. To mitigate these impacts adequate provisions have been made in the first year RAP and similar provisions will be there in all future RAPs.

6.3.2 Environmental Impacts 99. Impact of Tidal Flooding. The tidal flooding is one of the major problems in coastal zone of Bangladesh, and polders under the present study are facing severe tidal flooding after Sidr for the existing breach points of the embankment and low height of the embankment. If the proposed implementation works are not implemented immediately, the problem will be further aggravated. To address these issues, embankment should be constructed to protect the area against tidal flooding during high tide; regular monitoring of embankment, regulators, and seepage of surface waters from rivers through the regulators will be conducted during dry seasons and necessary steps will be taken to check seepage, if any; and afforestation will be undertaken at both side of the embankment, which will help strengthen the embankment.

100. Impact on Sundarbans. The impact of the polder on the Sundarban ecosystem situated across the river is the intrusion of more water on the forest floor of Sundarban and erosion of forest bank. This will enhance the height of the tidal inundation of the forest. This enhanced tidal inundation, will imbalance the natural tide inundation features of the given ecosystem. It is commonly observed that in areas that have higher tide inundations, the species composition is different than that is found in the areas that have lower tide inundations. Although there is no definite study, from consultation with Bangladesh Forest Department it was found that if the width of the river in-between is 1.5 mile or more, polder will have no impact on the Sundarban ecosystem and banks across that. The implementing agency will stick to the existing alignment as much as possible or if necessary will consider maintaining adequate setback in case of realignment.

101. Bank Erosion: Polder may hinder soil accretion on the other side which may eventually cause bank erosion on the other bank. To overcome this situation, adequate setback will be provided in fixing the alignment of the polder.

102. Risk of Embankment Failure. Rain cuts and public cuts are the major causes of embankment breaching of the polders. Lack of regular maintenance will create weak point at the sensitive locations of the embankment. Poor maintenance and increasing intensity and magnitude of the cyclone and storm surge simultaneously have accelerated the risk of embankment failure. Counter clockwise circulation of the cyclone of the Bay of Bengal will make the eastern embankment more susceptible to breaches. To address these issues, regular monitoring and careful maintenance of the embankment and existing water control structures especially along the eastern side of the Polder will be ensured; available cyclone and flood shelter will be prepared as a contingency measure during emergency situation; WMG will develop a

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fund for this kind of emergency situation; and structural measures like geo bag and sand bag will be kept in local BWBD offices and stores.

103. Drainage Congestion and Increased Sedimentation in Water Channels and Rivers. Drainage congestion is a key issue in southwest zone of Bangladesh, and polders are facing this problem due to siltation of khals and external rivers. However, it is a recurring problem and silt deposition in the rivers outside and water channels inside the polders is likely to continue. Particularly, the low lying areas of the polders and tail ends of khals may face severe drainage congestion in the future. To address these issues, an ongoing program of de-silting of water channels will be considered with full community involvement and participation. Water Management Group (WMGs) will take the lead for this purpose; proper land zoning plan will be prepared in the Polder for controlling unplanned development works; union parishad will be authorized to monitor the development activities; training program in connection with land zoning and monitoring system will be undertaken. Manual will be prepared for sluice gate operation and provide training to WMOs; and conflicts between farmers and fishermen will be reduced.

104. Increase Salinity Intrusion Due to Leakage of Regulators. Improper operation and leakage of regulators will result in salinity intrusion during the low flow season, causing severe damage to the soil, water resources, and crops in the polders. The proposed project has been designed to address such damages which are currently caused by the salinity intrusion. Mishandling and or poor upkeep and maintenance of these control structures will undermine the very objective of the Project. To address these issues, regular monitoring and careful maintenance of the water control structures will be ensured; standard operating procedures will be prepared and implemented for the water control structures, these procedures will be translated in Bangle as well; and capacity building of WMOs will be carried out.

105. Water Contamination and Reduced Soil Fertility. At present, a small portion of land is under boro (rice) cultivation in the polders. After the completion of the proposed Project, considerable amount of water will be available from the internal canal system. This will allow significant expansion of area under irrigated cultivation of boro and aus varieties of rice. This expansion of irrigated cultivation is likely to result in decreased soil fertility and increased use of chemical inputs including fertilizers and pesticides. Runoff from such cultivation fields may potentially pollute the water bodies and even drinking water sources thus causing health hazards for the communities. This runoff may also lead to eutrophication of the water bodies, a phenomenon which would decrease the dissolved oxygen in the water and thus negatively affecting the aquatic fauna. To address these potential problems, capacity building and awareness raising of the farmers will be carried out to practice less chemical fertilizers or pesticides and Integrated Crop Management – in order to minimize usage of chemical inputs; farmers group will have close contact with the Department of Agriculture Extension for adoption of various measures; farmers will be encouraged to use organic manure to increase soil fertility while avoiding water contamination; and farmers will be encouraged to cultivate leguminous crops to enhance the soil quality.

106. Reduced Fish Migration. Construction of new water control structures on water channels which are currently directly connected with the outer rivers will potentially result in reduction in fish migration. This can potentially result in decrease of fish population in the polders thus adversely affecting the fish catch and fishermen due to improper sluice gate operation. To address this problem, proper sluice gate operation will be ensured allowing fish migration; trainings will be provided to WMOs; and community will be trained to transfer juvenile fish from rivers to polders, where appropriate.

6.4 Cumulative Impacts of all CEIP Interventions

107. Since the coastal polders will be rehabilitated and improved in phases, the improvement of one polder might have impacts on flooding or salinity pattern outside the polder. For instance, when considered individually, the raising and strengthening of embankments in a given polder to withstand higher storm surges will benefit the people inside the polder and will have very little long term impact. The higher embankment has an impact only during the rare occurrence of a storm surge affecting that particular polder (say once in 10 years or so), and that also for a day or two. Such events do not cause long term morphological change or salinity impacts except within polders that have been flooded.

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However, there is a related impact on storm surge levels outside the polder. If more and more polders are protected from storm surges by higher embankments, their cumulative effect would drive the storm surge levels even higher, and possibly further upstream along the river system. Preliminary analysis of the location and proposed design specification (including climate change impacts) of 17 polders in CEIP-I shows that most of the polders will not have significant impact on storm surge level and cumulative impact on other polders, as they are located either on the bank of big river and sea or far from the coast on the northern side of the Sundarbans. Only a few polders (39/2C, 41/1, 43/2C, 47/2) might face slight impact of increasing storm surge level and cumulative impact on other surrounding polders.

6.5 Cumulative Impacts of Other Projects in the Area

108. Emergency 2007 Cyclone Recovery and Restoration Project (ECRRP). In order to facilitate recovery from damage to livelihoods and infrastructure caused by Cyclone Sidr and to build long-term preparedness through strengthened disaster risk management, the GoB implemented the ECRRP in 13 districts (Barguna, Bagerhat, Barisal, Khulna, Bhola, pirojpur, Jhalokati, Noakhali, Feni, Chittagong, potualkhali, Sathkhira, Laksmipur) of Bangladesh. A major component of this project is rehabilitation of coastal embankments in five upazilas of Barguna district (Amtali, Bamna, Betagi, Barguna sadar, Patharghata), two upazillas of Pirojpur district (Bhandaria, Mathbaria), and three upazillas of Patuakhali district (Dashmina, Galachipa, Kalapara). Among the 35 polders considered for rehabilitation, polder 39/1C is located near the left bank of Baleswar River, at the opposite side of polder 35/1. The design height of embankments in Polder 39/1 is 4 m (from mean sea level) and this polder will tend to divert the flow of Baleswar River further downstream. Consequently, the lake in the southern periphery of polder 35/1 (Bogi lake) will be subjected to inflow of huge amount of silts and will be reduced in depth in future. Due to the reduced depth of Bogi lake, existence of mangrove flora may be expanded towards the polder in future. Places near Bogi lake may undergo the diversion of new mangrove species because of the chances of expansion of saline habitats in the polder. Meanwhile, easy access from Sundarbans to polder 35/1 through Bogi lake would lead to frequent migration of animals from the Sunderbans. The fish species sustainable in brackish water would also migrate into the polder. This may result in more frequent migration of flora-fauna in polder 35/1 from Sundarbans.

109. Also due to development of polder 39/1 under ECRRP, the Baleswar River may experience increased siltation. This may affect polder 35/1 in a number of aspects. The wave action of Baleswar River may cause damage to polder 35/1 and river water may overtop the embankment of the polder due to rise in cyclonic surges beyond the design level.

6.6 Positive Impact of the Project

110. Employment Generation: The construction work will generate a significant amount of employment over its construction period to local people and other associated professionals. People will also be involved to carry put operation and maintenance related jobs to operate the hydraulic structures. It is expected the agriculture production will be increased; water logging will be decreased due to the project which will create jobs indirectly from agriculture, business and commercial services. 111. Gender Promotion: Construction work requires various types of skilled and unskilled labors. It is found that in Bangladesh a portion of construction labors are female. These females are vulnerable to natural disaster and mostly distressed and widow who are dependent on others and do not have any definite source of income. Therefore, employment access to them in the construction works and during operation/maintenance phase is significantly positive. 112. Livelihood Development: The project is expected to increase resilience of people within Polders. Agriculture production increase, reduction of drainage congestion, income generation is expected to improve the livelihood of the people.

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113. Afforestation: The project will promote afforestation which is expected to mitigate the negative impact associated with felling off the trees. However the impact is expected to be positive in the long run. 114. Capacity building of BWDB: The project has in built component which will facilitate implantation of Environmental Management Plan. Under the project, the capacity building for environmental management of BWDB and WMO will be performed. The project is expected to have long term positive impact on institutional development of BWDB and WMO for ensuring environmental sustainability.

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7. Environmental & Social Management Plans

7.1 Social Action Plans 115. The SMRPF. The principles and guidelines as proposed in this SMRPF will apply to all polders under CEIP-I that will involve land acquisition from private ownership and/or displace people from the existing right of way (public/BWDB land), which they may have been using for residential, agricultural, commercial or other purposes with or without formal authorization. To mitigate adverse impacts, BWDB will prepare and implement RAPs documenting the PAP and valuation of affected assets, impact mitigation measures and budget, and an implementation schedule for each works package. The ARIPO 1982 will be used to legalize acquisition, and the World Bank OP 4.12 will be the basis to adopt and implement impact mitigation measures. 116. BWDB will avoid or minimize acquisition of private lands; avoid or minimize (i) displacement from homesteads, (ii) loss of land valued higher in terms of productivity and uses, (iii) loss of buildings/structures that are used for permanent business/commercial activities; dislocation of non-titled users of land; and impacts on community facilities, such as educational institutions, places of worship, cemeteries, etc., and buildings/structures that are socially and historically important, and avoid adverse impacts on cultural property. 117. Where adverse impacts are found unavoidable, BWDB will plan to mitigate them in accordance with the principles adopted in the SMRPF. Regardless of their tenure status to the lands used for a subproject, the project affected households and persons will be eligible for compensation and assistance. The private land owners, non-titled users of land/embankment, owners of displaced businesses, employees of affected businesses, rental income earners, owner users of affected vested and non-resident (VNR) property, usufruct rights holders and community and groups will be recognized for compensation and assistance under the policy framework. Non-title holders of lands and informal settlers on embankments will be compensated for their structures/relocation and livelihood restoration. 118. Resettlement Action Plan (first package). The first construction package of the CEIP-I is designed to improve four polders in Khulna and Bagerhat districts. Major civil works for improvement of these polders include embankments upgrading and re-sectioning of existing embankments to protect against storm surges (including the impact of climate change), construction of water control structures, and excavation/re-excavation of canals. According to the census survey carried out as of February 2012, the first package will affect 4417 households and persons in their residence, place of businesses and other assets, and 152 common resource structures (CRS) largely on the existing embankments. Unlike the project affected households on the lands proposed for acquisition, the households, shops and CRSs on the existing embankments will need to be relocated from the existing embankments during civil works construction temporarily or permanently. The RAP has, therefore proposed a compensation mechanism in the form of assisted relocation and livelihood restoration and a living allowance (“rent”) for landless embankment settlers for the temporary period of physical displacement. The project preparation consultant has estimated the RAP cost for the first package at BDT 928 million (USD 11.6 million). A total of 162 ha of lands have been proposed for acquisition for improvement of the four polders. Land acquisition and resettlement of the project affected persons will be financed from project fund. 119. RAP for subsequent works packages will be developed following detailed engineering design during implementation including inventory of assets, number of eligible affected persons for compensation and assistance, budget, and implementation arrangement. 120. Social Action Plan (SAP). The project will support consultation with and strengthening of polders’ stakeholders and beneficiaries as well as formal and informal water management organizations. Under Component B1, the project will pilot intensive social mobilization in 6 polders to establish participatory WMO. The establishment of WMOs will follow a six step process, as identified in the

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Guidelines for Integrated Planning for Sustainable Water Resources Management, published by BWDB in 2008. Social mobilization is expected to last around two years, during which time the WMOs will be established and trained in participatory planning, as well as in operation and minor maintenance activities. Small works, including minor periodic maintenance and operation of minor hydraulic infrastructure would be undertaken by the WMOs under a memorandum of understanding with BWDB. In the remaining polders, Polder Management Committee(s) will be established to determine the competing needs and uses for water resources, and to decide on the operation of hydraulic infrastructure. Should the participatory approach prove to be successful, it would be scaled up in more polders. 121. BWDB will follow a strategy of gender inclusive project design, implementation, and operation. Women in the communities are and will continue to be consulted at each stage of project cycle and their representation will be ensured in project management including inventory of resettlement impacts, valuation of affected property, grievance resolution and relocation. BWDB will encourage the employment of poor women in earth work through the Labor Contracting Societies (LCS) and it is expected that at least 30% of WMOs members will be women. BWDB will provide gender-related training to sensitize its officials and increase capacity of the LCS and WMOs. 122. Grievance Redress Mechanism (GRM). BWDB will establish a GRM to address grievances and complaints that PAP or their communities bring during implementation of the project. Grievance Redress Committees (GRC) will be formed at each union for receiving complaints and grievances related to land acquisition, resettlement and other social issues. All complaints will be received at the GRCs facilitated by the implementing NGO. The aggrieved persons may opt to make complaints directly to the Project Director or Secretary of the MoWR. The NGO will review and sort the cases in terms of nature of grievance, urgency of resolution, and schedule hearings in consultation with the Convener. All cases will be heard within two weeks from the date of receiving the complaints. The GRM will not restrict any aggrieved person in lodging their complaints to the court of law. 123. The PAPs and their communities will be informed of the project’s GRM in open meetings at important locations and in PAP group meetings. Bangla translations of the SMRPF and the GRM in the form of information brochures will be distributed among the project affected people. The PAP will also be briefed on the scope of the GRC, the procedure for lodging grievances cases and the procedure of grievance resolution at the project level. To ensure impartiality and transparency, hearings on complaints will remain open to the public. The GRCs will record the details of the complaints and their resolution in a register, including intake details, resolution process and the closing procedures. 124. Monitoring and Evaluation: Preparation and implementation of SAP/RAP will be monitored by BWDB through the Social, Environment and Communication Unit of the PMU with assistance from the DCSC. BWDB will prepare the Quarterly Progress Report on social management and will share with World Bank for review. In addition, the effectiveness of screening, monitoring and implementation of RAP/SAP will be carried out by the third party monitoring firm along with the project component activity monitoring annually. The independent monitor will also carry out a mid-term review and end-term evaluation of the project on social safeguards.

7.2 Environmental Management Plans

125. A comprehensive EMP which focuses on managing construction phase-related impacts should suffice in managing the potential construction and operation phase impacts. Mitigation measures should be considered starting with Environmental Assessment process. It is important therefore, that there is good integration between the EIA team and project design engineers. Project specific environmental construction guidelines should be developed. Impacts identified severe in consequence category and or likelihood category will be further analyzed to identify additional mitigation measures that are potentially available to eliminate or reduce the predicted level of impact. Potential mitigation measures will include:

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habitat compensation program species specific management program engineering design solutions alternative approaches and methods to achieving an activity‘s objective stakeholders participation in finalizing mitigation measures construction practice, including labor welfare measures. operational control procedures management systems

126. Based on the past experience, a generic Mitigation Measures for EMP has been developed. The EMP will be attached with the Bidding Document. The environmental management parameter will be included in the BoQ. Since many contractors do not have clear understanding the need of environmental management, some tend to quote very low price for implementation of EMP and eventually cannot implement EMP as per design. To avoid this problem, it is proposed to use a fixed budget for the EMP implementation. The contractors may need orientation on the requirement of the EMP in the pre-bidding meeting. The contractor needs to submit an Environmental Action Plan (EAP) based on the EIA and EMF in line with the construction schedule and guideline. The EAP needs to be reviewed by the supervision consultant and cleared by BWDB and World Bank. 127. Extensive monitoring of the environmental concerns of the CEIP-I project will be required as per World Bank guideline. The monitoring program will help to evaluate: (i) the extent and severity of the environmental impacts against the predicted impacts and baseline; (ii) the performance of the environmental protection measures or compliance with pertinent rules and regulations; (iii) trends in impacts; and (iv) overall effectiveness of the project environmental protection measures. The monitoring plans should be included in the EMP for specific activities. Moreover, for all type of monitoring, a comprehensive database of the polder specific Environmental Impact and Monitoring information should be created, which will help to evaluate the impacts easily. 128. Reporting: BWDB will prepare the Quartely Progress Report on environmental management and will share with World Bank for review. Contributing development partners (if any) may join the field visit to understand the environmental compliance of the project. In addition, the effectiveness of screening, monitoring and implementation of EMP will be carried out by the third party monitoring firm along with the project component activity monitoring annually. The Annual Environmental Audit Report prepared by the third party monitoring firm will be shared with the safeguards secretariat.

7.3 Institutional Capacity 129. The overall responsibility of EMP implementation and fulfilling other environmental obligations during the Project rests with the PD. For this purpose, the PD will be supported by environmental and social staff of the PMU, Design and Construction Supervision Consultants (DCSC), and contractors.

Construction phase 130. The Social, Environment and Communication Unit (SECU) within the PMU: BWDB will set up a PMU, led by a PD, to implement the project. To manage and oversee the environmental and social aspects of the Project, the PMU will create a SECU with the following composition and functions:

The SECU Unit will include a Senior Environmental Specialist, a Senior Social Specialist, a Senior Forestry Specialist, a Revenue Staff and a Communication Specialist based in Dhaka. One environment specialist, two Social Specialists and a Revenue Staff will be posted at the field level to support all three divisions.

The SECU will manage the EIA/SIA process and supervise compliance with and implementation of the EMP, RAP/SAP.

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The SECU will be responsible for updating EIA after receiving pending information and carry out the EIA and SIA for the rest of the polders;

It will maintain liaison with WB safeguards team, national regulatory agencies, and other stakeholders during project implementation.

It will also coordinate with the environmental and social staff of the DCSC. The SECU will be established before awarding the contract to contractor.

131. Environment and Social Staff with DCSC Consultants: The DCSC consultants will be responsible for overall supervision of polder rehabilitation related activities. The DCSC consultants will ensure quality control and report to PD. The DCSC consultants will also assist and coordinate with the SECU for ensuring environmental and social compliance and monitoring of progress including EMP, RAP and/or Environmental Code of Practice (ECP) implementation. The DCSC consultants will supervise the contractors, ensuring design compliance and quality of works. For supervising the EMP and RAP implementation, DCSC consultants will have dedicated and adequately qualified and experienced environmental and social staff including field-based environmental monitors and social monitors. The environmental monitors will supervise and monitor contractors to ensure compliance with the EMP. 132. Contractor’s Environment Supervisors: The construction contractors will have adequate number of dedicated, properly qualified and experienced, site-based Environment Supervisors (ESs) at the construction sites. The ESs will be responsible to implement various aspects of the EMP particularly the mitigation measures to ensure that the environmental impacts of the construction works remain within acceptable limits. The ESs will maintain coordination with the DCSC (EMs) at the site level. The ESs will also be responsible to conduct environmental trainings for the construction crew. Post-construction Phase 133. BWDB core unit has posts of 4 Assistant Chief and 2 Deputy Chief to oversee the overall environmental compliance of BWDB implemented projects. Under CEIP, the SECU will provide training to the BWDB people responsible for monitoring of environmental compliance. Thus smooth transition to BWDB will happen to ensure environmental compliance during the O&M after the project completion. These staff will be responsible to manage the environmental aspects of the operation and maintenance of Polder, its water control structures, and other relevant issues such as protection of key environmental resources of the Polder and fish migration. WMO will be formed under the Bangladesh Guidelines for Participatory Water Management (Nov 2000) and the IPSWAM guidelines (2008) and involve the beneficiary communities. WMOs will be trained by BWDB to ensure environmental management during project operation. Environmental Management Unit of BWDB will ensure and oversee the environmental management during project implementation and operation. The Water Management Organization will also be trained and involved in EMP implementation during the operation phase. 134. Capacity Building: The institutional capacity-building plan in the EMF and SMRPF proposes specific activities aiming to enhance environmental and social management skills, training, and equipment. These measures comply with the functions expected from the SECU such as (a) supervision of compliance with environmental and social laws and procedures (b) preparation of TORs and budgets for the execution of the environmental and social studies, tools, and works; (c) support of the Procurement and Finance Unit and others as needed to ensure compliance on environmental and social issues; (d) coordination with the SECU or whatever instance the issues relating to the management plans in compliance with the EMF and SMRPF; (e) monitoring of the activities results according to specific indicators to compare with pre-established standards, and if necessary; (f) the proposal of corrective measures. A specific budget has been allocated for capacity building and will be executed during project implementation.

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8. Consultations and Disclosure 8.1 Overview 135. The Environment and Social studies of the first batch of five polders have been conducted after consulting with local communities, non-governmental organizations (NGOs) and concerned government departments/ organizations dealing particularly with related fields, thus ensuring that their views and concerns are taken into account in the study. The key objectives of these consultations include:

To provide key Project information and create awareness among various stakeholders about project intervention;

To have interaction for primary and secondary data collection with project beneficiaries, affectees, and other stakeholders;

To identify environmental and social issues such as displacement, safety hazards, employment, and vulnerable persons;

To begin establishing communication and an evolving mechanism for the resolution of social and environmental problems at local and Project level;

To involve Project stakeholders in an inclusive manner; and To receive feedback from primary stakeholders on mitigation and enhancement measures

to address the environmental and social impacts of the Project.

8.2 Consultation Process and Outcome 136. A total of 62 consultation meetings and focus group discussions (FGDs) were conducted at different locations of the polders. Two national level workshops were conducted on the EMF and the Environmental Impact Assessment of five polders. The main participants of the consultation meetings and FDGs included public representative, farmer, trader and daily-wage laborers of the polders and nearby areas. A total of 571 participants attended these consultation meetings and FDGs. In addition, 19 meetings were held during the preparation of resettlement action plan (RAP); a total of 431 participants attended these meetings. The key issues discussed and suggestions/recommendations received during these consultations are summarized below.

Table 10: Community Concerns and Suggested Solutions

Topics Concerns/Issues/Problems Suggested Solution/Remedies

Overall Water logging, tidal flooding, salinity intrusion and cyclone are the main community concerns in the polders.

Comprehensive rehabilitation of the polder should be taken up at the earliest with the active involvement of the local community.

Water Resources

1. The people of these polders have identified tidal flooding and salinity intrusion as major natural problems of water resources in the area. There is high salinity in ground and surface water.

2. Some khals are open, without any water control structures. There is no embankment in some parts of polders that creates drainage congestion severely.

3. Erosion is a common problem in south-west coastal area. Embankments are damaged during cyclone Sidr and subsequently extended during Aila period. Some segments of the embankments have fallen under thrust of wave action and engulfed by the river erosion. In addition, regular tidal wave has affected the weakened embankment that makes it more vulnerable.

4. Sedimentation is also a problem in the polder area. Some rivers have sandy beds and mud banks along the shore

1. The slope of the embankment at some places have fallen under the thrust of wave action and damaged during monsoon where slope protection with CC block is needed including afforestation on the foreshore area;

2. New embankment is required to be constructed by developing village road;

3. The intrusion of saline water might be controlled by the improvement of

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Topics Concerns/Issues/Problems Suggested Solution/Remedies

whereas tidal creeks tend to be choked with very fine sediments. Sedimentation is taking place in internal khals of the polders.

5. Salinity is another problem in the polder areas. Salinity intrusion in the polder through surrounding channels. Salinity contamination in the polders is very frequent due to lack of embankment as well as improper operation of water control structures.

6. The most devastating cyclones (Sidr, 2007 and Aila, 2009) hit the polders. The cyclone Sidr was most disastrous for the project area than Aila. The surge water entered the polder areas by overtopping and through breaches in the protection embankment.

7. Tidal motion dominates during pre-monsoon and post monsoon period. Tidal water frequently enters into the polder areas and damages crops, where embankment is either damaged or is absent altogether.

8. Scarcity of fresh water is another problem in the polder area during dry season. Due to malfunctioning of water control structures, lack of reserve sweet fresh water in khals for irrigation during dry season. Absence of embankment along the rivers also makes the surface water unavailable for the users. Saline water is trapped for long time in vast area and this is responsible for intrusion of salinity in the groundwater aquifers.

9. The labor out-migration is estimated 25% from the study area. At least 25% of the unemployed day laborers and farmers of the polders use to migrate out to the nearby city and towns for temporary employment.

10. Around 20% of the households in average are in the ‘deficit’ category. These deficit households were identified in the PCM as the poor households of the polder area.

11. The local inhabitants of the polders identified tidal flooding, salinity intrusion, cyclone, and riverbank erosion are major hazards creating disasters in the area. The tidal flooding and salinity intrusion is gradually becoming a severe problem in this study area.

embankment. Introduce re-excavation program in internal canals, increase height of the embankment and improvement sluice gates are very essential;

4. Scope of sweet water storage will be improved dramatically within internal khals and protective ponds due to proper functioning of associated water control structures;

5. Need formation of WOs) to manage properly water control structures i.e. embankment, sluice gate, regulator, inlets, culverts etc and growing of consciousness among the community in the scheme;

6. Need awareness building among the communities about water management;

7. The Government should rehabilitate the affected farmers who are affected by salinity intrusion;

8. Salt tolerant varieties of rice need to be practiced and in this regard necessary extension works need to be organized by the respective departments;

8.3 Disclosure 137. The project EMF and SMRPF as well as the EIA and RAP for four polders have been disclosed locally in BWDB website. The last National Workshop was held in Dhaka on environmental and social impact assessments on 28 February 2013. The documents are translated into Bangla for local disclosure. The Draft EMF, EIA for 4 polders and the RAP have been disclosed on the World Bank Bank InfoShop on February 14, 2013. Updated and future reports will continue to be disclosed locally and in Bank InfoShop as they become available.