SIA & EIA OF SIRAJGANJ ECONOMIC ZONE

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LIST OF ABBREVIATIONS

MD. ABDUL QUADER KHAN SOCIAL AND RESETTLEMENT SPECIALIST

BANGLADESH

PREPARED BY

Environmental & Social

Impact Assessment

Report of Sirajganj

Economic Zone

EIA & SIA of Sirajganj EZ

BANGLADESH ECONOMIC ZONES AUTHORITY (BEZA) PRIME MINISTER’S OFFICE

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BEPZA Bangladesh Export Processing Zones Authority

BEZA Bangladesh Economic Zones Authority

BMD Bangladesh Meteorological Department

BOD5 Biochemical Oxygen Demand

BOQ Bill of Quantities

BOT Build, Operate and Transfer

BRTA Bangladesh Road Transport Authority

CAGR Compounded Annual Growth Rate

CETP Central Effluent Treatment Plant

CNG Compressed Natural Gas

DoE Department of Environment

dB (A) Decibel Unit (Amplitude) DPP Development Project Proposal

ECC Environment Clearance Certificate

ECR Environment Conservation Rule

EHS Environmental, Health and Safety

EIA Environmental Impact Assessment

ESMF Environmental and Social Management Framework

EMP Environmental Management Plan

EMS Environmental Management System

EPC Engineering, Procurement and Construction

EPZ Export Processing Zone

ESC Environment and Social Cell

ESIA Environmental and Social Impact Assessment

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

ESO Environmental and Safety Officer

EU European Union

EZ Economic Zone

FABR Fluidized Aerobic Bio Reactor

FGDs Focus Group

Discussions FDI Foreign Direct Investment

FTE Full Time Equivalent

GCF Gross Capital Formation

GDP Gross Domestic Product

GRC Grievances Redress Committee

GRM Grievances Redress Mechanism

GVA Gross Value Added

HFL Highest Flood Level

ICR Implementation Completion Report

IDA International Development Association

IECs Important Environmental Components

IEE Initial Environmental Examination

ILO International Labour Organization

IUCN International Union for Conservation and Nature

IDC Interest During Construction

MIS Management Information Systems

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MSL Mean Sea Level

MLD Million Liters per

Day MFL Maximum Flood Level

MSW Municipal Solid Waste

NERP Northeast Regional Water Management Project

NOx Oxides of Nitrogen

NGO Non-Government Organization

NPV Net Present Value

OP Operational Policy

O&M Operations and Maintenance

PAP Project Affected Person

PEP Project Entitled Person

PD Project Director

PCU Passenger Car Unit

PFR Pre-Feasibility Report

PPP Public Private Participation

PSDSP Private Sector Development Support Project

PSIG Private Sector Investment Guidelines

PAU Project Affected Units

RAF Risk Assessment Framework

RAP Resettlement Action Plan

RMG Ready Made Garments

RSRP Resettlement and Relocation Programme

RSPM Respiratory Suspended Particulate Matter

RU Resettlement Unit

SEZ Sirajganj Economic Zone

SIA Social Impact Assessment

SPV Special Project Vehicle

STP Sewerage Treatment Plant

SPM Suspended Particulate Matter

SWM Solid Waste Management

ToR Terms of Reference

TDS Total Dissolved Solids

US United States

VOC Volatile Organic Compounds

WTP Water Treatment Plant

WQS Water Quality Standards

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TABLE O F C O N T EN T S

1 Executive Summary ................................................................................................................. 11

1.1 Introduction.......................................................................................................................... 11

1.2 Legislative considerations ................................................................................................... 12

1.3 Project description ............................................................................................................... 12

1.4 Description of the environment ........................................................................................... 13

1.5 Identification and evaluation of potential impacts ............................................................... 14

1.5.1 Construction stage impacts .................................................................................................. .14

1.5.2 Operation stage imacts......................................................................................................... 14

1.6 Alternative Analysis .............................................................................................................15

1.7 Mitigation measures.............................................................................................................. 15

1.8 Environmental Management plan (EMP) ........................................................................... .. 1 5

1.9 Environmental Monitoring and institutional development ................................................. ..1.6

1.9.1 Pre-construction stage monitoring....................................................................................... .. 16

1.9.2 Construction stage monitoring .............................................................................................. .16

1.9.3 Operation stage monitoring ................................................................................................. .16

1.9.4 Institutional arrangement .................................................................................................... 1 .6

1.10 Public consultations.............................................................................................................. .16

1.11 Summary............................................................................................................................... 17

2 Introduction.................................................................................................................................. 1 8

2.1 Background........................................................................................................................... 18

2.2 Scope of the study ................................................................................................................ 18

2.3 Methodology Adopted ......................................................................................................... 19

3 Applicable Environmental Regulatory Framework......................................................................22

3.1 National Environmental Policy, 1992 .................................................................................22

3.2 National Environmental Management Action Plan, 1995....................................................22

3.3 National Conservation Strategy, 1992.................................................................................. 23

3.4 Relevant National Legislation ..............................................................................................24

3.5 Ecologically Sensitive/ Protected Areas near the project region ......................................... 28

3.5.1 Ecologically sensitive areas...................................................................................................28

3.5.2 Protected Areas .....................................................................................................................29

3.6 Statutory Environmental Requirements for the project ........................................................32

3.6.1 GoB requirements .............................................................................................................. 32

3.6.2 WB requirements ................................................................................................................ 34

3.6.3 Concordance Analysis for Project Requirements ................................................................34

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4 Project description ....................................................................................................................... 35

4.1 Introduction To Sirajganj EZ (SEZ) .................................................................................... 35

4.2 Site and surroundings ........................................................................................................... 37

4.3 Land Use Plan ...................................................................................................................... 38

4.4 Infrastructure requirement ................................................................................................... 38

4.4.1 Basic infrastructure Requirement .........................................................................................39

4.4.2 Environmental infrastructure .................................................................................................40

4.5 Man power ........................................................................................................................... 45

4.5.1 Construction stage................................................................................................................. 45

4.5.2 Operation stage .................................................................................................................... 45

5 Description of the environment ................................................................................................... 47

5.1 General ................................................................................................................................. 47

5.2 Project Influence Area ......................................................................................................... 50

5.2.1 Determining factors for the project influence area .............................................................. 51

5.3 Physical Environment .......................................................................................................... 51

5.3.1 Atmosphere & Climate .................................................................................................... 51

5.3.2 Land condition ................................................................................................................. 53 5.3.3 Water resources ......................................................................................................................54

5.4 Biological Environment........................................................................................................60

5.4.1 Ecology......................................................................................................................... 60

5.4.2 Aquatic Flora.................................................................................................................60

5.4.3 Aquatic Fauna ...............................................................................................................61

5.4.4 Terrestrial Flora ............................................................................................................62

5.4.5 Terrestrial Fauna...........................................................................................................62

5.4.6 Protected Areas ............................................................................................................ 62

5.5 Natural hazards and risks ......................................................................................................62

5.5.1 Seismic Effects ............................................................................................................ 62

5.5.2 Cyclones and Storms ................................................................................................... 63

6 Identification and evaluation of Potential Impacts .......................................................................64

6.1 Pre-Construction stage environmental impacts.................................................................... 64

6.1.1 Natural flow stopped due to filling of water bodies ..................................................... 64

6.1.2 Loss of Trees ................................................................................................................ 64

6.1.3 Risk due to Earthquake................................................................................................. 65

6.2 Construction stage environmental impacts .............................................................................65

6.2.1 Disruption of earth Surface .......................................................................................... 65

6.2.2 Soil erosion and siltation .............................................................................................. 65

6.2.3 Surface water and ground water pollution .....................................................................65

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6.2.4 Traffic flow congestion .................................................................................................65

6.2.5 Air quality ......................................................................................................................66

6.2.6 Noise pollution ............................................................................................................. 66

6.2.7 Water resources .............................................................................................................66

6.2.8 Solid waste disposal.......................................................................................................67

6.2.9 Bridge structures ........................................................................................................... 67

6.2.10 Flora and fauna ............................................................................................................. .67

6.2.11 Historical and cultural monuments ............................................................................... 67

6.3 Operation stage environmental impacts.................................................................................67

6.3.1 Air Quality ....................................................................................................................68

6.3.2 Dust............................................................................................................................... 68

6.3.3 VOCs ............................................................................................................................68

6.3.4 Exhaust Gases ...............................................................................................................68

6.3.5 GAS-based power plant ................................................................................................69

6.3.6 Noise pollution ............................................................................................................. 69

6.3.7 Traffic flow/congestion ................................................................................................. 70

6.3.8 Water Pollution ............................................................................................................. 70 6.3.9 Solid waste.................................................................................................................... 72

6.3.10 Odour............................................................................................................................ ..73

6.3.11 Flooding ........................................................................................................................ 73

6.4 Evaluation of Impacts ........................................................................................................... .73

7 Analysis of Alternatives ..................................................................................................................74

7.1 The No Build scenario ..............................................................................................................74

7.2 Consideration of alternatives ....................................................................................................74

7.2.1 Alternative sites .............................................................................................................74

7.2.2 Site Analysis ................................................................................................................. 74

7.2.3 Socio-environmental considerations............................................................................. 75

7.2.4 Alternate production techniques for textile dyeing ...................................................... 78

8 Mitigation and enhancement measures .........................................................................................79

8.1 Mitigation measures.............................................................................................................. 79

8.2 Enhancement measures ........................................................................................................ .79

9 Environmental management plan (EMP) ....................................................................................... 93

9.1 Objective................................................................................................................................93

9.2 Environmental management measures proposed ................................................................. 93

9.3 Specific management plan .............................................................................................................93

9.3.1 storm water management plan........................................................................................93

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. 9.3.2 Wastewater management plan ..........................................................................................94

9.3.3 Solid waste management plan ........................................................................................97

9.3.4 Traffic management .......................................................................................................98

9.3.5 Landscaping/greenery ....................................................................................................98

9.3.6 Occupational Health & Safety Management Plan ....................................................,..98

9.3.7 Industrial risks and contingency plan ......................................................................... 100

9.3.8 Appropriate contingency and emergency response measures..................................... 100

10 Environmental monitoring and Institutional development ....................................................... ..102

10.1 Monitoring plan .................................................................................................................. .102

10.1.1 General Features ...........................................................................................................102

10.2 Institutional arrangement .................................................................................................. …104

10.2.1 Roles and Responsibilities ............................................................................................105

10.2.2 Training ...................................................................................................................... ..106

10.2.3 Environmental Specifications .................................................................................... ..106

10.2.4 monitoring Program ................................................................................................... ..106

10.2.5 Reporting systemand record keeping .......................................................................... 111

10.2.6 Environmental audit .................................................................................................... 113

10.3 Implementation Schedule and Cost Estimates..................................................................... 113

10.3.1 Implementation Schedule ............................................................................................ 113

10.3.2 Cost Estimates ............................................................................................................. 113

11 Public Consultation ...................................................................................................................... 115

11.1 Objectives ............................................................................................................................ 115

11.2 Identification OF stakeholders ..............................................................................................115

11.3 Community concerns on project intervention ...................................................................... 116

11.4 Future consultation and disclosure plan ............................................................................... 116

12 Conclusions and recommendations .............................................................................................. 118

12.1 Key conclusions .....................................................................................................................118

12.2 Recommendations ................................................................................................................ 119

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Social, Gender and Resettlement Issues……………………………120-142

Annex 1 – Environmental Clearance from the DoE

Annex 2 – Consolidated Environmental Standards

Annex 3 – Water Balance Scheme for the project Annex 4 – List of Flora and Fauna Species

Annex 5 – Borrow Pit Guidelines Annex 6 – Environmental Clauses for the bid documents

Annex 7 – Impact Assessment Matrix

Annex 8 – EMP Implementation Schedule

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LIST O F FIGURE

EXHIBIT 1 LAND USE DISTRIBUTION AT THE SITE ...... ... .... ... .... ... ... .... ... .. .. .... ... ... .... ... ... .... ... ... . ... .... ... .... ... ..12

EXHIBIT 2 UTILITY DEMAND STIMATION.... ... .... .... ... ... .... ... .... ... ... ... . .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... ....13

EXHIBIT 3 PROPOSED ZONES IDENTIFIED UNDER SDSP. .... ... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ... ..18

EXHIBIT 4 OVERVIEW OF NATIONAL LEGAL INSTRUMENTS. ... .... ... ... .... ... ... ... . .... ... ... .... ... .... ... ... .... ... ... ....27

EXHIBIT 5 ENVIRONMENTALLY SENSITIVE AREAS IN BANGLADESH ...... ... .... ... ... .... .... ... ... .... ... .... ... ....28

EXHIBIT 6 NOTIFIED & PROTECTED AREAS OF NGL A D E SH .. ... .... ... ... .... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ..30

EXHIBIT 7 PROTECTED AREAS OF BANGLADESH (SOURCE: DEPARTMENT OF FOREST) ...... ... ... .... ..31

EXHIBIT 8 STEPS FOLLOWED FOR ENVIRONMENTAL CLEARANCE FOR RED CATEGORY PROJECT.... ...... .... .33

EXHIBIT 9 Concordance Analysis of EIA Requirements -------------------…..-.... ... ... .... ... .... ... ... .. .. .... ... ... .... ... ... .... .34

EXHIBIT 10 PROPOSED MASTER PLAN FOR SIRAJGNANJ ..... ... .... ... ... .... ... ... .... ... ... . ... .... ... .... ... ... .... ... ... ... . .36

EXHIBIT 11 SITE PHOTOGRAPHS ........ ... ... .... .... ... ... .... ... .... ... ... . ... .... ... ... .... ... ... .... ... .. .. ... .... ... .... ... ... .... ... ... .... ... ...37

EXHIBIT 12 LAND USE DISTRIBUTION AT THE SITE ....... .... ... ... .... ... ... .... ... ... . .... ... ... .... ... .... ... ... ... . .... ... ... .... ..38

EXHIBIT 13 INDUSTRIAL LAND-USE MIX ..... ... .... .... ... .... ... ... .... ... .... ... .... ... ... .... ... .... ... ... .... . ... ... ... .... ... ... .... ... ....39

EXHIBIT 14 ROAD BUFFER REQ U IR E M E N T S ..... ... .... .... ... ... .... ... .... ... ... .... . ... ... ... .... ... .... ... ... .... .... ... ... .... ... .... ... ..39

EXHIBIT 15 WATER DEMAND ESTIMATION STANDARDS ...... .... ... .... ... ... .. .. .... ... .... ... ... .... ... .... ... ... .... ... .... ..40

EXHIBIT 16 WATER CONSUMPTION PATTERN (FRACTION OF TOTAL DEMAND)... .... ... ... .... ... .... ... .... ..40

EXHIBIT 17 WATER CONSUMPTION PATTERN – POTABLE VS. NON-POTABLE ........ ... ... .... ... .... ... .... ... .41

EXHIBIT 18 WATER DEMAND JECT IO N S .... ... ... .... .... ... ... .... ... .... ... ... .... . ... ... ... .... ... .... ... ... .... ... . ... ... .... ... ... .... ... ....41

EXHIBIT 19 STORAGE RESERVOIR SIZE ESTI M A T IO N ...... ... .... ... ... .... .... ... ... .... ... ... .... ... .... ... ... .... ... .... ... .... ... .41

EXHIBIT 20 ALTERNATIVES OF TREATMENT OF WATER ..... ... ... .... ... ... .... .... ... ... .... ... .... ... ... .... ... .... ... ... .... ..42

EXHIBIT 21 SCHEMATIC OF WATER TREATMENT SYST E M .. .... ... .... ... ... .... ... ... .. .. .... ... .... ... .... ... ... .... ... .... ...43

EXHIBIT 22 WASTE WATER ESTIM A T I O N ... ... ... .... ... .... ... ... .... . ... ... ... .... ... .... ... ... .... ... ... .... ... . ... ... .... ... .... ... ... .... ..43

EXHIBIT 23 SOLID WASTE CONSTITUENTS ...... .... ... ... .... .... ... ... .... ... ... .... ... .. .. .... ... ... .... ... .... ... ... ... . .... ... ... .... ... ..44

EXHIBIT 24 SOLID WASTE GENERATION ASSU M PT IO N S ... ... .... ... ... .... ... .... ... . ... ... .... ... ... .... ... ... .... ... .... ... . .. ...44

EXHIBIT 25 SOLID WASTE GENERATION ESTIMATION ..... ... .... ... ... .... ... .... .. . .... ... .... ... ... .... ... .... ... ... .... ... ... ..45

EXHIBIT 26 MAN POWER FOR ADMINISTRATIVE LEV E L ... ... .... ... .... ... ... .... ... . ... ... .... ... ... .... ... .... ... ... .... ... ... ...45

EXHIBIT 27 MAN POWER FOR MAINTENANCE OF VAEIOUS ENVIRONMENTAL INGRASTRUCTURE……..46

EXHIBIT 28 SCOPING MATRIX..………………………………………………………... ... ... .... ... .... ... ... .... ... ... ..48

EXHIBIT 29 ENVIRONMENTAL ATTRIBUTES AND FREQUENCY OF MONITORING…….. ... .... ... ... .... ..49

EXHIBIT 30 AT A GLANCE RAJAPUR UP OF BELKUCHI & SAIDABAD UP………….…… . ... ... .... ... .... ...50

EXHIBIT 31 PROCEDURES FOR DETERMINING VARIOUS AIR QUALITY PARA M E T E R S.. .... ... ... .... ... ...52

EXHIBIT 32 AIR QUALITY RESULTS AROUND MEPZ AREA ...... ... .... ... ... .... ... ... .. .. .... ... ... .... ... .... ... ... .... ... ... ..53

EXHIBIT 33 PHYSIOGRAPHICAL MAP OF BANGLADESH ..... ... ... .... ... .... ... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ...54

EXHIBIT 34 FLOOD PRONE AREAS OF BANGLADESH ....... ... .... ... .... ... ... .... ... ... .... ... .... ... ... .... ... .... ... ... ... . ... .. 56

EXHIBIT 35 EATHQUAKE & FLOOD PRONE AREAS OF BANGLADESH ........ ... .... ... ... .... ... . ... ... ... .... ... .... ... . 63

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EXHIBIT 36 FLOW CHART FOR COMPOSITE TEXTILES ...... ... .... ... ... .... ... .... . .. .... ... .... ... .... ... .... ... .... ... ... .... .. 71

EXHIBIT 37 SUMMARY OF SITE CONSTRAINTS AND CORRESPONDING DESIGN ASPE C T .. ... ... .... ... 75

EXHIBIT 38 ENVIRONMENTAL QUALITY STANDARDS CONSIDERATION FOR ENGINEERING DESIGN ......... . .. . .. .. . .. . .. . .. .. . .. . .. . 75

EXHIBIT 39 MITIGATION MEASURES ....... ... .... ... ... .... ... .... .... ... ... .... ... .... ... ... .. .. ... ... .... ... .... ... ... .... ... ... .... ... .... . 92

EXHIBIT 40 SEWAGE COLLECTION & TRANSPORT NETWORK DESIGN CRITERIA ....... ... .... ... ... .... ... 94

EXHIBIT 41 RAW EFFLUENT CHA RA CT E RI ST IC S ... .... ... ... .... ... .... ... .. .. ... .... ... .... ... ... .... ... ... .... .... ... ... .... ... .... .. 94

EXHIBIT 42 TREATED EFFLUENT CHARACTERISTICS ...... ... .... ... .... ... ... .... . ... ... ... .... ... ... .... ... .... ........................... 95

EXHIBIT 43 RAW EFFLUENT CHA RA CT E RI ST IC S ... .... ... ... .... ... .... ... .. .. ... .... ... .... ... ... .... ... ... .... ... .... ... ... .... ... ... 96

EXHIBIT 44 TREATED EFFLUENT CHARACTERISTICS ...... ... .... ... .... ... ... .... ... .... ... ... .... ... .... ... .... ... ... .... . .. .... ..96

EXHIBIT 45 EFFLUENT COLLECTION & TRANSPORT NETWORK DESIGN ITERI A . .... ... .... ... ... ....................96

EXHIBIT 46 INTEGRATED SOLID WASTE MANAGEMENT METHODOL.. ... ... .... ... .... ... ... .... ... ... .. .. ... .... ... 97

EXHIBIT 47 EMP IMPLEMENTATION AND ORGANISATION STRU C T U R E ....... ... .... ... .... ... .... ... ... .... ... .... 104

EXHIBIT 48 MONITORING PROGRAM DURING PROJECT CYCLE ....... .... ... ... .... ... ... .... ... .... ... ... .... ... . .. .... 110

EXHIBIT 49 REPORTING SYSTEM ...... .... ... ... ..... ... ... .... ... ... .... ... .... ... .... ... .... ... ... .... ... ... .. .. .... ... ... .... ... .... ... ... .... . 112

EXHIBIT 50 TYPICAL RECORD KEEPING REQ U I R E M E N T S ..... .... ... .... ... ... .... ... ... . ... ... .... ... ... .... ... .... .. . ... ... 113

EXHIBIT 51 EMP BUD G E T .. ... ... .... ... .... ... .... ... .... ... ... .... ... ... .... . ... ... ... .... ... .... ... ... .... .. .. ... ... .... ... .... ... .... ... ............. 114

EXHIBIT 52 ENVIRONMENTAL CONCERNS/ISSUES OD SURROUNDINGS … . .... ... .... ... .... ... ... .... .... .... 116

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CHAPTER # 1 EXECUTIVE SUMMARY

1.1 I N T RO D U CT I O N

The Bangladesh Economic Zones initiative is a part of the vision 2021/MDG. As part of the initiative, a ECONOMIC

ZONES ORDINANCE WAS FORMULATED IN 2007-08 which is approved by the Government in 2010. Further,

Support to Capacity Building of Bangladesh Economic Zones Project assigned a Social Specialist (Consultants)

– to carry out the Resettlement and EIA/SIA of five sites to be developed as Economic Zones. The Sirjganj

Economic Zone Project (SEZ) is one of the four sites selected for the study.

This report summarizes the environmental and social impacts associated with the Sirajganj EZ Project proposed to

be located at Rajapur Union of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila of Sirajganj

district . The assessment of impacts has been based on the design of the project proposed. The EIA/SIA is done in

accordance with the environmental assessment requirements of the WB Safeguard Policies (OP 4.01, 4.12) and

the Environment Conservation Rules (ECR), 1997 under the Environment Conservation ACT, (ECA) 1995 and its

subsequent amendments, Government of Bangladesh. The Project is classified as “Category A” by the World

Bank.

The scope for the Environment and Social Impact Assessment is as follows:

A general description of the proposed sub-project and existing physical, environmental, biological

and socio-economic conditions;

Consultations with stakeholders involving affected people in identifying the

social/resettlement and environmental issues;

Identification and assessment of the potential impacts associated with infrastructure development

and industrial units’ activities within the study area on the natural and human environment; and

Identification of the means of mitigating negative impacts and development of an Environmental

Management Plan (EMP) including mitigation measures for negative impacts, measures for

pollution control and environmental monitoring.

For the EIA study, the following methodology is adopted:

Collection and review of documents relevant to Sirajganj Economic Zones reconnaissance, field visit to site

and neighborhood areas ;

Continuous interaction with design consultants

Stakeholder consultations

FGDs

Environmental data collection and analysis

Detailed legislative review

Identification, prediction and evaluation of significant/potential impacts

Formulation of Environmental Management and Monitoring Plan

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1.2 L E G I S L A T I V E CO N S I D E R A TIONS

The proposed project should comply with the relevant legislation and planning requirements of Bangladesh. Furthermore, the safeguard policies of the World Bank/any development partner also need to be followed (As required )

Key provisions of the same have been discussed in the report. Relevant Policies, Strategies and Plans (National Environmental Policy 1992, NEMAP 1995, NCS 1992) of the Government have been discussed to make the intervention in line with the Government Policies and Guidelines (DoE, EIA Guidelines for Industries). The National Environmental Quality Standards and International Standards have been assessed to make sure that the project interventions are consistent with those standards.

As per WB environmental categorization, the OP 4.01 (Environmental Assessment) is triggered by the project and therefore requires detailed EIA including specific EMP.

1.3 PROJECT DESCRIPTION

Considering the growing demand of foreign investors for industrial plots and experience from successful implementation of Dhaka, Chittagong, Comilla, Adamjee, Mongla and other Export Processing Zo nes (EPZs), Bangladesh Economic Zone Authority (BEZA) plans to develop an EZ at Sirajganj Several sites were identified initially as potential EZ for the project. After a site visit on May 2011 by BEZA, a site having an area of approx. 1035. 94 acres at western site of Bangabandhu Bridge was finalized. Based on the market study and assumptions related to the commercial positioning of the zone, the land use pattern in terms of industry mix was proposed by the consultants. The land use pattern is summarized in the following figure :

A. Industries %

Knitting 500.00 44.02 Spinning 300.00 26.41

RMG 97.94 8.62

B. Utilities %

Customs, Security, Admin, entrance plaza & Social infrastructure

25.00 2.20

Essential staff quarters 15.00 1.32

Road 70.00 6.16

Greenery 103.00 9.07 Warehouse 10.00 0.88

Gas Power Plant 15.00 1.32

Total 1,135.94 100.00

Figure 1 : Land Use Distribution at the Site

The general internal infrastructure and utilities envisaged for the Sirajganj EZ are:

Site grading, boundary wall

Road Storm drainage Power supply

Street lighting

Bridge The environment-related infrastructure designed includes:

Water supply & treatment system

Sewage collection, treatment and recycle

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Effluent Collection and Treatment System

Solid waste management system

The onsite infrastructure was designed based on the fact that the EZ would be developed in phases, for optimum project implementation & financial returns. Normative estimation of the demand for utilities etc. yielded estimates as summarized in the following figure :

Utility Aspect Projection ( Ultimate ) Power Demand 60 MVA

Water Demand 12.84 MLD Traffic Volume 12300 PCU/day

Effluent Generation 3 MLD Sewage Generation 4 MLD

Solid Waste Waste Generation 80.5 TPD Figure 2 : Utility Demand Estimation The design of onsite project infrastructure components and also the project cost estimation was carried out based on the aforementioned utility demand estimation projections. Also, the development of the overall EZ is likely to happen over two phases. 1.4 D E S CR I P T I O N O F T HE E N V I RO N MENT

The baseline data has been compiled for: Land Environment; Water Environment; Air Environment; Noise Environment; Ecological Environment and Socio-economic Environment. Primary data related to environmental attributes like air, noise level and water quality was collected through field studies. Information on other aspects was obtained from field observation as well as secondary sources.

Land Environment

Parameters involved in land environment are land use/land cover pattern, physiography, geology and minerals, soils, and seismicity.

The existing land use of the proposed Sirajganj EZ site is mostly dominated by low lying agricultural lands followed by surface water body of canals and Jomuna river channels. Most of the land is single crop agricultural land and rest is double cropped. The proposed site is located on the flood plain of Jamuna. Proposed site is located between western site of Bangobondu Multipurpose Bridge. Sirajganj Town is located North- west of the proposed project site The topography of the land varies from -2.363 to +5.765 m with respect to the Mean Sea Level (MSL) with moderate slope. The site is situated near the Jomuna Flood Plain. The dominant soil texture is sandy loam. The soil of the area is grey loam on the ridges and grey to dark grey clays in the basins. The dominant general soil type is non-calcareous grey flood plain soil. The area falls under Earthquake Zone II as per the NBC (National Building Code) of Bangladesh

Water Environment

The water bodies within the site are used for irrigation and drinking water supply as well as for inland river transport. The pollution level of water in the river is low as ascertained from the water sample analysis results. Therefore, although development of the EZ might lead to increase in the pollution levels, they are expected to be within the prescribed limits. However, contamination of ground water may be a significant problem. Development of industries in the region might lead to contamination of ground water which would disturb the drinking water supply to the nearby population. Rain water harvesting and ground water recharge structures have been proposed to ensure that the quality of ground water is maintained.

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Air Environment

The climate of the study area is humid and tropical. A hot and humid pre-monsoon from March to mid-May, a prolonged southwest monsoon or rainy season from mid-May to September, a pleasant post-monsoon or retreating monsoon from October to November and a cold pleasant winter from December to February are the characteristics of the climate. Summer runs concurrently with the later part of the pre-monsoon season and continues throughout the monsoon season. Air quality standards in the region are found to be within the prescribed limit. However, with several manufacturing industries being planned in the zone, emissions from the industries may lead to pollution of the ambient air quality. Noise Environment

Existing sound levels were found to be exceeding the normal limits. The reason for that is the existence of the industries as well as other commercial activities in the nearby region. Therefore, it is envisaged that mitigation measures for preventing noise pollution would be required for the region Ecological Environment

The ecosystem that evolved on the Jamuna floodplain and the Jamuna River is very important from biodiversity and economic point of view. This ecosystem supplies huge amounts of freshwater fish products Rajapur and Saidabad Union constitute a part of the Jamuna floodplain ecosystem and are inhabited by many important freshwater plants and fauna species. The channels of the Jamuna River and associated Jamuna Flood Plain are the habitat of many species of commercial freshwater fishes, native waterfowl and migratory birds. The proposed project site does not fall under the jurisdiction of any of the protected or sensitive areas in Bangladesh.

1.5 I D E N T I F I CA T I O N A N D E V A L U A T I O N O F P O T E N T I A L I M P A CT S

The primary function of an environmental impact assessment study is to predict and quantify the magnitude of impacts, evaluate and assess the importance of the identified changes and formulate plans to monitor and mitigate the actual changes. Environmental impacts could be positive or negative, direct or indirect, local, regional or global, reversible or irreversible. Impacts Identification: The potential impacts of the project on the environment can be in different phases of the project cycle viz. location, construction and operation. The type and magnitude of the impacts, however depends on the specific attributes of the given environment.

OUT OF THE TOTAL LAND, APPROXIMATELY 10% (103.59 ACRE) IS IN THE FORM OF OPEN WATER BODIES (RIVER/CANAL). Out of the remaining (932.35 acre) lands, 30 acres is homestead, 2.00 acres is common property and 900.35 acre is agricultural land. A total of 815 households, One Government Primary School, Two mosque, Two Madrasa, 02 non- government primary school will be affected by the project. There is 10 commercial and business enterprise within the proposed project area.

1.5.1 CO N S T RU CT I O N S T A G E IMPACTS

During the construction phase, IMPACT ON FAUNA IS EXPECTED TO BE THE MOST SIGNIFICANT IMPACT WHICH COULD BE IRREVERSIBLE. Other major impacts during construction would be noise, air and water pollution. These will need to be mitigated properly through good construction practices that are compliant with international standards.

1.5.2 O P E RA T I O N S T A G E IMPACTS

Only yarn and fabrics are expected to be the water-polluting units. Other industries are assumed to be only formulation (pharmaceuticals), apparel making (leather and jute) etc. and they do not produce any effluents. The major environmental components that are expected to be adversely affected by the activities of the project are water quality and ambient noise conditions. The EZ has been planned in such a way as to consider these impacts and

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reduce them to a minimum. For waste disposal, a separate area has been identified where a CETP has been proposed to treat the untreated effluent to meet ‘zero discharge’ standards i.e. no treated/ non- treated water and solid waste generated from the CETP will be let out to areas surrounding the EZ. As per the impact matrix, three parameters (surface water, noise, and odour) reach scores in the range of 72 to -96 which indicate major and irreversible impact, if not properly mitigated. It should be noted that parameters in the impact matrix relate to the impacts, assuming no mitigation Also, NO CUMULATIVE IMPACT IS EXPECTED TO BE CREATED, although there are few industrial settlements in the nearby region.

1.5.3 A L T E RN A T I V E ANALYSIS

Due to land scarcity in the country, seeking an alternative site for establishing an industrial zone is quite difficult. Also, land acquisition is a lengthy and complex procedure under the existing land acquisition law. Further, the project conceptual development over alternative sites is quite difficult because delay in overall land acquisition process might create social conflicts and risks for the project. This site has been selected by BEZA and some initial planning for land acquisition is in process. Part of this land is Government ‘khas’ land and the remaining needs to be taken from public. As per plot schedule provided by BEZA, the total amount of land to be acquired for the project is 1035.94 acres To minimize displacement and other adverse impacts on the settlements and privately owned land, the project is planned to be implemented mostly in paddy land. A total of 815 households, One Government Primary School, Two mosque, Two Madrasa , 02 non- government primary school will be affected by the project. About 10% (103.59 ACRE of the total land is open water bodies belonging to GoB.

1.7 M I T I G A T I O N M E A S U R E S

To avoid and minimize the impacts resulting from the activities of the project, measures and management plans, which are essential to mitigate the impacts discussed above, have been proposed. These are based upon appropriate technological design, improvements or adjustments, and policy including good site operational practices etc. The overall strategy has the following sequence:

Impact avoidance: Changing project location, design and construction methods to avoid impacts. Impact minimization: Where impacts cannot be avoided, implementing mitigation measures to

reduce the impact to acceptable levels.

Compensation: Arranging compensation where impacts cannot be avoided or sufficiently mitigated.

Enhancement: Measures, which, at insignificant cost to the project, give appreciable developmental benefits.

The mitigation plan has been recommended to highlight the procedures to avoid/minimize / control the impacts arising out of different project phases i.e. pre-construction, construction and operation, the plan is elaborately described as matrix format in the report.

1.8 E N V I RO N M E N T A L M A N A G E M E N T P L A N (EMP)

The EMP is based on five major principles:

The POLLUTER PAYS for pollution and prevention of pollution

The DEPARTMENT OF ENVIRONMENT (DOE) IS TO PLAY A CENTRAL ROLE in the environmental safeguarding of the project - regulation, supervision and enforcement.

Environmental SAFEGUARDS TO BE INCORPORATED FROM THE INCEPTION of all activities.

PRIVATE SECTOR DEVELOPMENT FOR EXECUTION AND IMPLEMENTATION of environmental safeguard related activities.

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All activities undertaken within the framework of the PSDSP or subsequent

developments are to be reviewed for their environmental impacts, and, when required, they need to

be included in relevant EFFECTIVE ENVIRONMENTAL MANAGEMENT PLANS aimed at off-

setting, preventing, or mitigating any such negative impacts.

Certain important and specific management plans with their respective action procedures for carrying out the overall EMP effectively are enumerated separately in the report. 1.9 E N V I RO N M E N T A L M O N I T O R I N G A N D I N S T I T U T I O N A L D E V E L O P M E N T

1.9.1 P RE - CO N S T RU CT I O N S T A G E M O N I T O RI N G Compliance monitoring during the pre-construction stage from the environmental perspective would consist of the following components:

Checking that the project’s design incorporates appropriate measures to avoid or minimize negative impacts

Incorporation of appropriate protective clauses in the contract documents that are to be followed by the developer(s

1.9.2 CO N S T RU CT I O N S T A G E M O N I T O R ING Compliance monitoring during the construction stage comprises:

Developer’s compliance with environmental clauses in their day-to-day activities

Implementation of site clearance activities after completion of work

1.9.3 O P E RA T I O N S T A G E M O N I T O RI NG Operations stage monitoring would involve the following:

Periodic monitoring and checking of environmental parameters within the EPZ Inspection of individual units to check whether the units follow the prescribed environmental and social norms or not

The rationale for the reporting system is based on accountability to ensure that the measures proposed as part of the Environmental Management Plan get implemented in the project.

1.9.4 I N S T I T U T I O N A L A RR A N G E M E N T The implementation of the EMP will be done by the project developer in case of the project being developed by a SPV and supervised by an Environment and Social Cell. Otherwise, the present BEZA structure with an additional Environmental and Social Cell has been recommended. The following key entities will be involved in the EMP implementation:

o Project Director/GM o Environmental and Social Cell (ESC) Supervision Consultant o Supervision Consultant o Developer

1.10 P U BL I C CO N S U L T A T I O NS

As per the requirements of World Bank guidelines, public consultations were undertaken to seek opinion and suggestions from various stakeholders that will provide inputs required for designing, construction and other implementation related issues of Sirajganj EZ Project.

The consultation program has three components as under:

Identification of key stakeholders

Consultation with all key stakeholders Public access to the outcome of the EIA Process and further information about the

project

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1.11 S U M M A RY

On critical review of the potential environmental impacts, the specific mitigation and monitoring measures proposed and the benefits described, it was found that the project is not expected to lead to any long term irreversible adverse impacts on the environmental quality and resources. The findings further suggest that major environmental components adversely affected during implementation of proposed EZ would be: loss of water bodies, trees, socio-economic environment, hydrology/drainage, back water effect, erosion, industrial effluent, and pollutant emissions to air, noise / vibration, accidental risk, occupational health and safety. The potential negative and long term problem could arise if the new bridge is incorrectly sized, leading to flooding and erosion. This could be avoided by USING A HYDRAULIC MODEL during the design process. INDUSTRIAL EFFLUENTS FROM INDIVIDUAL PROCESSING UNITS COULD BE A MAJOR SOURCE OF ADVERSE IMPACT during operational phase of the proposed project. This might create long term and irreversible effect to a certain degree on the receiving environment, if no mitigation measures are adopted. It is recommended that all industrial effluents be collected and conveyed through closed pipes to the CETP which will ensure zero discharge treated effluent by way of recycling.

Having reviewed all the potential environmental impacts and following the recommended mitigation measures as per this EIA, the proposed Sirajganj EZ Project is expected to proceed without having any unacceptable environmental impacts.

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2. INTRODUCTION

2.1 BACKGROUND

Economic Zones (EZs) have been set up in the country to promote exports and these have been relatively successful especially in sectors such as textiles. This is largely attributable to availability of serviced land, infrastructure and logistics. In addition, there is also an authority controlling the sector – the Bangladesh Economic Zones Authority (BEZA). However, the overall impact of EZs has been limited. The spillover effects into the local economy are also felt to be limited. Further, the EZs have been developed solely by the public sector, whose resource limitations constrain further growth. To overcome some of the shortcomings of the EZ sector, a new Economic Zones regime was contemplated by the Government. These would actively encourage private participation, cater to both exporters as well as the domestic market and have world class standards of infrastructure, environmental and social compliance. Towards this end, an Economic Zone ordinance was finalized and passed by the interim administration. The ordinance of BEZA already approved by the Government in 2010. The PSDSP program is one of the key initiatives designed to further the objective of EZ development.

Further, Bangladesh Economic Zones Authority appoint a Project Director for Support to Capacity Building of Bangladesh Economic Zones Authority. Project also appointed a Social Specialist – to carry out the Social and Environmental activities. The Sirajganj EZ is one of the 5 sites selected for the study, the details of the four sites is as follows: Location Area (Acre ) Proposed

Industries / Companies

Mirshorai,Chittagong 6615 .12 Multiproduct

Anwara, Chittagong 611.47 Shipbuilding Sherpur, Moulovibazar 352.89 Multiproduct

Mongla, Bagerhat 203 Multiproduct Sirajganj 1041.43 Multiproduct

Figure 3 : Proposed Zones identified by BEZA This EIA/SIA will examine the aspects of the project activities, which are likely to interact with and affect the surrounding environment and the community. The EIA and SIA report provides an Environmental Management Plan (EMP) and Social Screening issues along with specific mitigation measures with a view to reduce and/or control the level of adverse impacts upon the environment as well as to enhance measures for positive impacts resulting from the proposed project activities.

2.2 S CO P E OF T HE S T U D Y

The scope of the report covers the environmental legislative, regulatory & policy guidelines and considerations relating to the implementation of the proposed EZ including the following:

Describe the proposed project and associated works together with the requirements for carrying out

proposed development;

Identify and describe the elements of the environment likely to be affected by the proposed

developments; Establish the baseline environmental and social scenario of the project area

Identify and quantify pollution sources and determine the significance of impacts on sensitive

receptors;

Identify, predict and evaluate environmental and social impacts expected during the construction and operation phases of the project;

Assess the opinion of the public/stakeholders observed in the consultation in identifying the

environmental issues;

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Develop mitigation measures so as to minimize pollution, environmental disturbance and

nuisance during construction and operation of the development; Design and specify the monitoring requirements necessary to ensure the implementation and the

effectiveness of the mitigation measures suggested; and Work out the cost of environmental mitigation and monitoring requirements

2.3 M E T HO D O L O G Y A D O P T E D

The methodology used for this study is based on the procedures described in EIA guidelines for industries published by DoE of the GoB as well as the guidelines embodied in World Bank’s safeguard policies.

The main objectives of EIA are to :

Identify the project or activity and the environment in which it will be implemented i.e. describe proposed new activities;

Predict the impacts of each activity on the different components of the environment i.e. relate the activities to planning regulations;

Evaluate the significance of predicted impacts and develop alternatives i.e. analyse primary and secondary environmental impacts: These are physical, ecological , social as listed in the ‘Impact Matrix’ for environment;

Formulate the basis for Environmental management plan together with monitoring program and controlling mechanism to protect local environment i.e. EIA methodology enables a participatory planning activity between industrial enterprise, government and community.

Communicate these impacts to decision–makers and affected communities and generate courses of action to reduce the impacts;

The overall activities of the EIA study include the following:

Kick-Off meeting with BEZA Officials: The study started with a kick- off meeting between the EIA/SIA Consultants and BEZA Officials in order to obtain project background, present status, sources of secondary data/reports, guidance, etc. and to finalize the work plan.

Collection and review of documents: Project Proposal of ‘Northern Economic Zone which is conducted by Industrial Development Company Ltd.. Several other documents were reviewed. The details are provided in the references

Site reconnaissance, field visit to site and neighborhood areas: The EIA team undertook reconnaissance and field visits to the study area of Sirajganj EZ area to observe the site- specific environmental concerns and to get perception within the vicinity of the area. During site visits the team addressed the following issues:

o Hydrological features of the area; o Land use and settlement pattern; o Aquatic and terrestrial flora and fauna; o Endemic, rare and threatened species; o Presence of sensitive features, reserve forest, wildlife sanctuary, religious

o structures etc. within and along the proposed EPZ area; o Public utilities/facilities; o Baseline Conditions o Effluent discharge route

Stakeholder Consultations: EIA Consultants held consultations with:

Board of Investment Bangladesh Economic Zones Authority

Department of Environment

Local administrative representatives

Local leaders, educated/business group etc

Project Affected Persons

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Environmental Data Collection and Analysis: Samples of water, air quality and noise level were collected from pre-determined sampling stations with subsequent analyses of various environmental quality parameters for baseline data generation.

Detailed Legislative Review: The applicable guidelines of GoB/World Bank were reviewed. This review

addressed social and environmental policies and requirements at following levels: o National Legislation o World Bank Safeguards Policy and guidelines relevant to the study

Deskwork for identification, prediction and evaluation of significant/potential impacts was carried out with the collected information and data through usages of ‘Impact Matrix’. Thereafter, possible mitigation measures to reduce/control negative impacts and enhancing measures for positive impacts have been identified.

Formulation of Environmental Management Plan for implementation of the proposed

Sirajganj EZ.

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CHAPTER # 2 REPORT LAYOUT

Chapter 2 of the report is an Introduction. It gives an overview of the objective, and scope of study and Methodology. The legal/ policy frameworks along with environmental standards are summarized in Chapter 3. In Chapter 4, a concise documentation is given on the proposed project activities and facilities including project features. Chapter 5 summarizes the environmental baseline data on physical, ecological and socioeconomic parameters. Chapter 6 highlights anticipated potential positive and adverse environmental impacts of the project. Environmental impacts due to the proposed park activities have also been quantified in this Chapter. Analysis of alternatives to the project has been presented in Chapter 7. An environmental strategy to offset/mitigate the probable adverse impacts has been outlined in Chapter 8. Chapter 9 provides recommendation for environmental management plan aimed at minimizing the negative environmental impacts of the project. Environmental monitoring requirements for effective implementation of mitigating measures during development as well as operation of the project have been delineated along with requisite institutional arrangements for their implementation in Chapter 10. Chapter 11 summarizes the consultation with interested parties and the general public and Chapter 11 Socio economic condition of project area.

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CHAPTER # 3 THE LEGAL/ POLICY FRAMEWORKS ALONG WITH ENVIRONMENTAL STANDARDS

3. A P P L I C A B LE E N V I RO N M E N T A L RE G ULA T O R Y F RA M E W O RK

The Government has developed a policy framework that incorporates environmental considerations into all economic development planning. The key policy documents are listed below:

o National Environmental Policy, 1992

o National Environmental Management Action Plan (NEMAP), 1995

o National Conservation Strategy, 1992

3.1 N A T I O N A L E N V I RO N M E N T A L P O L I CY , 1 9 9 2

The Bangladesh National Environmental Policy sets out the basic framework for environmental action together with a set of broad sectoral action guidelines. Key elements of the policy are:

o Maintenance of the ecological balance and overall progress and development of the country through protection and improvement of the environment;

o Protection of the country’s assets, properties and resources against natural disasters; Identification and regulation of all types of activities which pollute and degrade the

environment;\ o Identification and regulation of all types of activities which pollute and degrade the environment; o Ensuring sustainable utilization of all natural resources; o Promoting active association with all environment related international initiatives.

The environmental policy requires the following specific actions with respect to the ‘Industrial’

sector: o To phase in corrective measures in polluting industries; o To conduct Environmental Impact Assessment (EIAs) for all new public and private industrial

developments; o To ban, or find environmentally sound alternatives for, the production of goods that cause

environmental pollution; and o To minimize waste and ensure sustainable use of resources by industry.

Under the National Environmental Policy, Department of Environment is directed to review and approve all environmental impact assessments.

3.2 N A T I O N A L E N V I RO N M E N T A L M A N A G E M E N T A CT I O N P L A N , 1 9 9 5

The National Environmental Management Action plan (NEMAP) is a wide ranging and multi- faceted plan, which builds on and extends the statements set out in the National Environmental Policy. NEMAP was developed to address issues and management requirements and set out the framework within which the recommendations of the National conservation strategy are to be implemented.

NEMAP has the following broad objectives:

Identification of key environmental issues affecting the country;

Identification of actions necessary to halt or reduce the rate of environmental degradation;

Improvement of the natural environment; Conservation of habitats and bio-diversity;

Promotion of sustainable development; and Improvement of the quality of life of the people.

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3.3 N A T I O N A L C O N S E RV A T I O N S T RA T E G Y , 1 9 9 2

The National conservation strategy provides recommendations for sustainable development in the industrial sector as follows:

All industries shall be subject to EIA and adoption of pollution prevention/control technologies shall be enforced;

Hazardous or toxic materials/wastes shall not be imported as raw materials for industry;

Import of appropriate and environmentally sound technology shall be ensured; and Dependence on imported technology and machinery should gradually be reduced in favor of

sustainable local skills and resources.

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3.4 RELEVENT NATIONAL L E G I S L A T I O N

The following exhibit presents an outline of the National legal instruments that will have relevance to the proposed EPZ project with respect to the environment considerations.

Act/Rule/Law/Ordinance Responsible Agency- Ministry/Authority

Key Features-Potential Applicability project/Time Whether T riggered for the Frame

for Clearance and Responsibility

The Environment Conservation Act, 1995 and subsequent amendments in 2000 and 2002


Ministry of Environment and Forest

Declaration of Ecologically Critical Areas; Obtaining Environmental Clearance Certificate

Regulation with respect to vehicles emitting smoke harmful for the environment

Regulation of development activities from environmental perspective;

Promulgation of standards for quality of air, water, noise, and soils for different areas and for different purposes;

Promulgation of acceptable limits for discharging and emitting waste;

Formulation of environmental guidelines relating to control and mitigation of environmental pollution, conservation and improvement of environment

Yes/2 Months/BEZA

Environment Conservation Rules, 1997 and subsequent amendments in 2002 and 2003



Declaration of ecologically critical Area; Requirement

of Environmental Clearance

Certificate for various categories of projects;

Requirement for IEE/EIA according to the appropriate category of the project;

Renewal of the environmental clearance certificate within 30 days after the expiry;

25




Provision of standards for quality of air, water & sound and acceptable limits for emission/discharges from vehicles and other sources

Environment Court Act, 2000 and subsequent amendments in 2002

Judiciary

Ministry of Environment & Forest

GOB has given highest priority to environment pollution and passed ‘Environment Court Act 2000 for completing environment related legal preceding effectively

No

The Vehicle Act, 1927

The Motor Vehicles Ordinance, 1983

The Bengal Motor Vehicle Rules, 1940

Bangladesh Road Transport Authority (BRTA

Exhaust emission; Vehicular air and noise; Road safety; Licensing

Yes/Regulatory only

The Brick Burning (Control) Act, 1989

The Brick Burning (Control) Amendment Act, 1992

Ministry of Environment & Forest

Requires a license from the MoEF; Restricts brick burning with fuel wood Control of brick burning

Yes/Regulatory only

The Removal of Wrecks and Obstructions in inland Navigable Water Ways Rules 1973

Bangladesh Water Transport Authority

Removal of wrecks and obstructions in inland Navigable Waterways

No

Water Supply and Sanitation Act, 1996

Ministry of Local Government, Rural Development and Cooperatives

Management and Control of waste supply and sanitation in urban areas.

Yes/Regulatory only

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The Forest Act, 1927 and subsequent amendments in

1982 and 1989


Reserve Forests; Protected Forests; Village Forests

No

The Private Forests Ordinance Act, 1959

Regional Forest Officer Forest Department

Conservation of private forests and for the afforestation on wastelands

No

Bangladesh Wild Life (Preservation) Act, 1974


Bangladesh Wild Life

Advisory Board

Preservation of Wildlife Sanctuaries, parks, No reserves

No

The Protection and Conservation of Fish Act 1950 subsequent amendments in

1982

Ministry of Fishery Protection and Conservation of fishes in Government owned water bodies

No

Natural Water Bodies Protection Act 2000

Rajdhani Unnayan Kartipakkha/Town Development Authority/Municipalities

According to this Act, the character of water bodies i.e. rivers, canals, tanks, or floodplains identified as water bodies in the master plans or in the master plans formulated under the laws establishing municipalities in division and district towns shall not be changed without approval of the concerned ministry.

Yes/Regulatory only

The Embankment and Drainage Act 1952

Ministry of Water Resources and FCD

An Act to consolidate the laws relating to embankment and drainage and to make better provision for the construction, maintenance, management, removal and control of embankments and water courses for the better drainage of lands and for their protection from floods, erosion and other damage by water

Yes/Regulatory only

Antiquities Act 1968 Cultural Ministry of Affairs This legislation governs

27




preservation of the No national cultural heritage, protects and controls ancient monuments, regulates antiquities as well as the maintenance, conservation and restoration of protected sites and monuments controls planning, exploration and excavation of archaeological sites

The Building Construction Act 1952 (with amendments)

Ministry of Works An Act to provide for the prevention of haphazard construction of building and excavation of tanks which are likely to interfere with the planning of certain areas in Bangladesh

Yes/Regulatory only

The Land Acquisition Act, 1894 and The Acquisition and Requisition of Immovable Property Ordinance 1982 and subsequent amendments in

1994, 1995 and 2004

Revenue Department Current GoB Act & guidelines, relating to acquisition of land Yes/8-12

months*/BEPZA Depending on quantity of land to be

acquired

The Factories Act, 1965

Bangladesh Labour Law, 2006

Ministry of Labour This Act pertains to the occupational rights and safety of factory workers and the provision of a comfortable work environment and reasonable working conditions.

Yes/Regulatory

only

Figure 4 : Overview of National Legal Instruments

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3.5 E CO L O G I CA L L Y S E N S I T I V E/ P RO T E CT E D A RE A S N E A R T HE P R O J E CT RE G I O N

3.5.1 E CO L O G I CA L L Y S E N S I T I V E AREAS

Ecologically sensitive areas as defined by the World Bank (OP 4.04) are areas that may contain unique features, maintain key natural processes, support endangered, endemic or threatened plants or animals and their habitats, or provide breeding areas for wildlife. Some ecologically sensitive areas are natural, while others may have been significantly altered by certain human activities.

Criteria given by the World Bank for Ecologically sensitive areas, and the corresponding areas in Bangladesh, are listed in the exhibit below under categories A-E. Areas that are socio-culturally sensitive are listed under categories F and G. The Environment Conservation Act, 1995 and the Environment Conservation Rules, 1997, also refer to Environmentally Sensitive Areas (called Ecologically Critical Areas in the legislation). According to this legislation, environmental protection is deemed particularly relevant in Ecologically Critical Areas, which are defined by the Government as areas where degradation of the environment has reached or threatens to reach a ‘critical’ state. Specifically, under the Environment Conservation Act and Rules, the Government will take into special consideration areas such as human settlements, ancient monuments, archeological sites, forest sanctuaries, national parks, game reserves, wildlife habitats, wetlands, mangroves, forested areas, biodiversity areas, and other similar areas. Environmentally sensitive areas, category-wise in the country, are presented in exhibit below:

Category Environmental Sensitive Areas

Location in Bangladesh

A Areas that provide protection to steep slope Protected Areas, especially in watershed areas, against erosion

Forests on steep watersheds generally these areas

occur in the Chittagong Hill T racts

B Areas that regulate and purify water flow

Wetlands - 10 More-or-less permanent wetlands

such as rivers, beels, haors, baors, dhours and djheels, containing water at the peak of the dry

season; & wetlands included in the Directory of

Asian Wetlands

C Areas that provide conditions essential for the perpetuation of species of medicinal and genetic conservation value

Mainly Forest Reserves (especially the Sunderbans) and important wetlands (listed in Directory of Asian Wetlands) but also unusual habitats such as St Martin's Island (coral reef)

D Sites that maintain conditions vital for the perpetuation of species that enhance attractiveness of the landscape or the viability of protected areas

Mainly Forest Reserves (especially the Sunderbans) and important wetlands (listed in Directory of Asian Wetlands) but also unusual habitats such as St Martin's Island (coral reef)

E Sites that provide critical habitat that threatened species use for breeding, feeding or staging

Freshwater and coastal wetlands, sites recorded in the Directory of Asian Wetlands

F Areas of cultural or historical significance

Graveyards, tombs, forts, mosques, temples, churches etc

G Areas that are densely populated and are important for human habitation

All Urban centers

Figure 5 : Environmentally sensitive areas

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3.5.2 PROTECTED AREAS Protected Areas’ in Bangladesh cover an area of 2,43,435 hectare which accounts for 16% of the total area managed by the

forest department and almost 2% of total area of Bangladesh. It includes 8 national parks, 7 wildlife sanctuaries, 1 game

reserve and 5 other conservation sites.

Protected Areas include Wildlife Sanctuary, National Park and Game Reserve. Their definitions in the Bangladesh Wildlife (Preservation) Order, 1973 (henceforth Wildlife Order) is as follows: Wildlife Sanctuary means an area closed to hunting, shooting or trapping of wild animals and declared as such under Article 23 by the government as undisturbed breeding ground primarily for the protection of wildlife inclusi ve of all natural resources such as vegetation soil and water (paragraph) (p) of Article 2). National Park means comparatively large areas of outstanding scenic and natural beauty with the primary object of protection and preservation of scenery, flora and fauna in the natural state to which access for public recreation and education and research may be allowed (paragraph) (p) of Article 2). Game Reserve means an area declared by the government as such for the protection of wildlife and increase in the population of important species wherein capturing of wild animals shall be unlawful (paragraph) (c) of Article 2) •. Article 23 of the Wildlife Order has provisions for declaration of Protected Areas and also has regulations prohibiting activities in the Protected Areas.

Sl. No. National Parks Location Area (ha.) Established

1 Bhawal National Park Gazipur 5022 11/5/1982

2 Madhupur National Park Tangail/ Mymensingh 8436 24-2-1982

3 Ramsagar National Park Dinajpur 27.75 30-4-2001

4 Himchari National Park Cox's Bazar 1729 15-2-1980

5 Lawachara National Park Moulavibazar 1250 7/7/1996

6 Kaptai National Park Chittagong Hill T racts 5464 9/9/1999

7 Nijhum Dweep National Park Noakhali 16352.23 8/4/2001

8 Medhakachhapia National Park Cox's Bazar 395.92 8/8/2008

9 Satchari National Park Habigonj 242.91 15-10-2005

10 Khadimnagar National Park Sylhet 678.8 13-04-2006

11 Baroiyadhala National Park Chittagong 2933.61 6/4/2010

12 Kuakata National Park Patuakhali 1613 24-10-2010

13 Nababgonj National Park Dinajpur 517.61 24-10-2010

14 Singra National Park Dinajpur 305.69 24-10-2010

15 Kadigarh National Park Mymensingh 344.13 24-10-2010

16 Altadighi National Park Naogaon 264.12 24-12-2011

17 Birgonj National Park Dinajpur 168.56 24-12-2011

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B) Wildlife Sanctuaries :

Sl. No. Wildlife Sanctuaries Location Area (ha.) Established

18 Rema-Kalenga Wildlife Sanctuary Hobigonj 1795.54 7/7/1996

19 Char Kukri-Mukri Wildlife Sanctuary Bhola 40 19-12-1981

20 Sundarban (East) Wildlife Sanctuary Bagerhat 31226.94 6/4/1996

21 Sundarban (West) Wildlife Sanctuary Satkhira 71502.1 6/4/1996

22 Sundarban (South) Wildlife Sanctuary Khulna 36970.45 6/4/1996

23 Pablakhali Wildlife Sanctuary Chittagong Hill T racts 42087 20-9-1983

24 Chunati Wildlife Sanctuary Chittagong 7763.97 18-3-1986

25 Fashiakhali Wildlife Sanctuary Cox's Bazar 1302.43 11/4/2007

26 Dudpukuria-Dhopachari Wildlife Sanctuary Chittagong 4716.57 6/4/2010

27 Hajarikhil Wildlife Sanctuary Chittagong 1177.53 6/4/2010

28 Sangu Wildlife Sanctuary Bandarban 2331.98 6/4/2010

29 Teknaf Wildlife Sanctuary Cox's Bazar 11615 24-03-2010

30 Tengragiri Wildlife Sanctuary Barguna 4048.58 24-10-2010

31 Dudhmukhi Wildlife Sanctuary Bagerhat 170 29-01-2012

32 Chadpai Wildlife Sanctuary Bagerhat 560 29-01-2012

33 Dhangmari Wildlife Sanctuary Bagerhat 340 29-01-2012

34 Sonarchar Wildlife Sanctuary Patuakhali 2026.48 24-12-2011

35 Nazirganj Wildlife (Dolphin) Sanctuary Pabna 146 1/12/2013

36 Shilanda-Nagdemra Wildlife (Dolphin) Sanctuary Pabna 24.17 1/12/2013

37 Nagarbari-Mohanganj Dolphin Sanctuary Pabna 408.11 1/12/2013

Other Conservation Sites C Name Location Area (ha.) Established

1 National Botanical Garden Dhaka 84.21 1961

2 Baldha Garden Dhaka 1.37 1909

3 Madhabkunda Eco-Park Moulavibazar 265.68 2001

4 Sitakunda Botanical Garden and Eco-park Chittagong 808 1998

5 Dulahazara Safari Parks Cox's Bazar 600 1999

6 Modhutila Eco-Park Sherpur 100 1999

7 Banshkhali Eco-Park Chittagong 1200 2003

8 Kuakata Eco-Park Patuakhali 5661 2005

9 T ilagar Eco-Park Sylhet 45.34 2006

10 Borshijora Eco-Park Moulavibazar 326.07 2006

Protected Area Covers 10.72% of Total Forest Area , Figure 6 : Notified & Protected Areas of Bangladesh

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Figure 7: Protected areas of Bangladesh (Source: Department of Forest)

The proposed Sirajganj EZ site does not fall under the jurisdiction of any of the protected or sensitive areas.

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3.6 ST A T U T O RY E N V I R O N M E N T A L RE QU I R E M E N T S F O R T H E P RO J E C T

3.6.1 G O B R E Q U I RE M E N TS

Bangladesh is a signatory to a number of International T reaties and Conventions, which require safe protection of the environment from degradation and environmental concerns of global scale, protect workers against hazards arising from occupational exposure to harmful substances and agents in the working environment. Section 12 of the Environment Conservation Act (ECA) stipulates "No industrial unit or project shall be established or undertaken without obtaining environmental clearance from The Director General of the Department of Environment (DG, DoE) in the manner prescribed by the ECR 1997". The Department of Environment (DoE), which is a statutory body under the Environment Conservation Act, is responsible for reviewing and evaluating the IEE and EIA of various types of development projects in Bangladesh.

Environmental Clearance: The Department of Environment (DOE), the technical arm of the Ministry of Environment and Forest (MOEF) is the enforcement agency. Depending upon location, size and severity of pollution loads, projects/activities have been classified in ECR,’97 into four categories: Green, Orange A, Orange B and Red corresponding respectively, to nil, minor, medium and severe impacts on important environmental components (IECs). Categorized industries are listed in Schedule 1 of ECR’ 1997. It is to be noted that the list of industries under Green, Orange – A, Orange – B and Red categories is not updated since 1997.

Since the proposed EZ (as industrial estate) falls under red category (described under Item 39, Schedule -1, page 3121 of ECR –97), IEE and EIA have to be conducted as mandatory requirement. As per the provisions of the ECR’ 97 (Section 7 and subsection 4 of SRO 197), the Director General of the Department of Environment can accord Environmental Clearance for the project without site clearance. This section 7 and subsection 4 also provides provision for submitting EIA report based on an approved TOR of comprehensive EIA as an alternative to IEE. Procedural steps to be followed for obtaining Environmental Clearance Certificate (ECC) in connection with establishing industrial estate project (under Red Category) from DOE is outlined in the Exhibit below. The snapshot of relevant DOE related form has been annexed to this report.

For Sirajganj EZ, Bangladesh Economic Zone Authority (BEZA) will be responsible for obtaining the ECC. Necessary actions will include:

Liaison with DoE to confirm the submission requirements;

Preparation of all required documentation, including any approvals required from other agencies;

Submission of the application to DoE in a timely manner, such that no delay occurs to the award of contracts for construction;

Attendance at meetings with the DoE;

Undertaking any further actions as required by DoE prior to issue of the ECC

33

Figure 8: Steps Followed for Environmental Clearance for Red Category Projects Source: Guide to the Environmental Conservation Act 1995 and Rules 1997, Prepared by Bangladesh Centre for Advanced Studies, 1999.

RED CATEGORY PROJECT

Issuance of Site

Clearance , IEE,

NOCs and

Others

Supporting

Within 60

working Days

from date of

To prepare and submit the application to the DG, DOE, for the exemption of the site clearance procedure;

Within 15 working days from date of

May start land and

infrastructural

development

Submission for

approval of the EIA

and ETP Des ign

Approval of EIA & ETP Design

within 60 days of Submission

Installation of ETP / Implementation of

a l l necessary mitigation measures

which i s ci ted in the EIA Report

Apply for ECC

Issuance of ECC within 30

days

Project Starts

Renew ECC every years 30 days before date

of expire

34

3.6.2 WORLD BANK/DONOR REQUIREMENTS Environmental Assessment is one of the safeguard policies of the World Bank. It is used in the World Bank funded projects to examine the environmental risks and benefits associated with the Bank lending operations.

The Bank's environmental assessment procedures are described in Operational Policy (OP)/ Bank Procedure (BP) 4.01. This policy is considered to be the umbrella policy for the Bank's "safeguard policies" which among others include: Natural Habitats (OD 4.04); Pest Management (OP 4.09); International Waterways (OP 7.50); Indigenous People (OP 4.10); and Involuntary Resettlement (OP 4.12). In the World Bank operations, the purpose of Environmental Assessment is to improve decision-making and to ensure that project options under consideration are sound and sustainable.

According to WB criteria, a proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. On the other hand a proposed project is classified as Category B if it’s potential adverse environmental impacts on human populations or environmentally important areas — including wetlands, forests, grasslands, and other natural habitats — are less adverse than those of Category A projects. These impacts are site-specific; few, if any of them, are irreversible; and in most cases migratory measures can be designed more readily than for Category A projects. As per WB environmental categorization, the proposed Sirajganj EZ project triggers OP 4.01 (Environmental Assessment) and requires detailed EA including specific EMP.

3 . 6 . 3 C O N C O RD A N CE A N A L Y S I S F O R P R O J E CT RE QU I RE M ENTs

3.6.3.1 EIA REQUIREMENTS In order to ensure that the proposed project has addressed the requirements of the GOB and World Bank Group (WBG), an analysis has been undertaken to examine the concordance of policies, procedural issues, and guidelines of the two:

Issue World Bank Guidelines Bangladesh Rules

Environmental Quality Standards EHS

1 ECR

3

Project Description OP 4.01 EIAGFI

3

Physical Resources OP 4.01 EIAGFI

Ecological Resources OP 4.01 /OP 4.04 EIAGFI

Socio-Economic Development OP 4.01 EIAGFI

Quality of Life and Cultural Values OP 4.01 /OP 4.11 EIAGFI

Anticipated Env ironmental Impacts OP 4.01 EIAGFI

Mitigation OP 4.01 EIAGFI

Monitoring OP 4.01 EIAGFI

Compensation OP 4.01 Not specified

Disclosure OP 4.01 Not specified

Resettlement OP 4.12 EIAGFI

Site Selection OP 4.01 EIAGFI

Alternatives OP 4.01 EIAGFI

Cost Benefit Analysis Not specified EIAGFI

Figure 9: Concordance Analysis of EIA Requirements

3.6.3.2 ENVIRONMENTAL STANDAR DS AND GUIDELINES All parameters of effluent, gaseous emission, noise, solid waste, hazardous waste, etc. shall be within the limits as prescribed in the Environment Conservation Rules, 1997 and the World Bank guidelines/global best practices (annexed to the report). The stringent of the two shall apply.

35

CHAPTER # 4 PROPOSED PROJECT ACTIVITIES AND FACILITIES

4. PROJECT DESCRIPTION

4.1 I N T RO D U CT I O N T O SIRAJGANJ EZ

Considering the growing demand of foreign investors for industrial plots and experience from successful implementation of Dhaka, Chittagong, Comilla, Adamjee and other Export Processing Zones (EPZs), Bangladesh Economic Zones Authority (BEZA) plans to develop an EZ at Sirajganj for creation of employment at Northern area of Bangladesh .

Several sites were identified initially as potential candidates for the project. After a joint site visit on 2

nd November

may 2011 by BEZA, a site having an area of approx 1035.94 acres at Sirajganj was finalized.

The identified site is adjacent to the Dhaka- Sirajganj highway, at the western end of the Bangobondu Multipurpose Bridge. The site lies between Tangail and Sirajganj, with an approximate distance of 130 km from Dhaka. The location of proposed site is shown in Figure below.

The layout of the site is planned keeping specific activity areas integrated with the ambient environment. The entire built environment is planned to be developed in tune and harmony with nature. Layouts of industrial land parcels are schematically planned so as to relate better with the existing and proposed landscape. The exhibit below shows layout master plan of the proposed Sirajganj Economic Zone.

36

Figure 10: Master Plan of Sirajganj EZ

37

4.2 S I T E A N D S U R RO U N D I N G S

The existing land use of proposed site is mostly dominated by low lying agricultural lands followed by surface water body of canals and Jamuna River channels A total of 815 households , One Government Primary School, Two mosque, Two Madrasa , 02 non- government primary school will be affected by the project. The overall site is 8-10 feet lower than the flood level and inundates for almost 5 months in a year.

A 40 feet wide National Highway (Dhaka-Siragjang highway) Northern side of project, Jamuna river passes by the eastern boundary of the site.

Physiographically, the proposed site is located on the flood plain of the Jamuna. Sirajganj Sadar Upazila is located at 24.4583°N 89.7000°E, as is the site. On the eastern side is the Jamuna river and on the western side is Sirajganj-Belkuch Highwa. Bangobondu Multpurpose Bridge located North-East site of proposed project area.

Figure11: Site Photographs

http://tools.wmflabs.org/geohack/geohack.php?pagename=Sirajganj_Sadar_Upazila&params=24.4583_N_89.7000_E_

38

4.3 L A N D U S E P L A N

Based on the market study of the target industries to be established at this zone, the industrial land use pattern was arrived

at. The industry mix thus obtained was further combined with the supporting infrastructure land utilization, to arrive at the

overall land use pattern. The following exhibit captures a snapshot of the land use pattern considered for the design

A. Industries %

Knitting 500.00 44.02

Spinning 300.00 26.41

RMG 97.94 8.62

B. Utilities %

Customs,Security, Admin, entrance plaza & Social infrastructure

25.00 2.20

Essential staff quarters 15.00 1.32

Road 70.00 6.16

Greenery 103.00 9.07

WareHouse 10.00 0.88

Gas Power Plant 15.00 1.32

Total 1,135.94 100.00

Figure 12 : Land Use Distribution at the Site

Figure : 13 Industrial Land-use Mix

4.4 I N F RA S T RU CT U RE REQU I RE M E N T

The infrastructure requirement for the proposed Sirajganj EZ has been broadly classified into the following two heads:

Basic Infrastructure: It includes construction material, site grading, boundary wall, roads, storm

drainage, power supply, street lighting, bridge etc.

44.02

26.41

8.62

2.20

1.32 6.16 9.07 0.88 1.32

100.00

Knitting

Spinning

RMG

Customs,Security, Admin,entrance plaza & Social

infrastructure

Essential staff quarters

39

Environmental Infrastructure: It comprises of water supply and treatment system, sewerage collection,

treatment and recycling, effluent collection and treatment system and solid waste management system

4.4.1 BA S I C I N F RA S T RU CT U RE RE QU I RE M ENT In this section, we highlight the major basic infrastructure requirements for the Sirajganj EZ from the environmental perspective.

4.4.1.1 CONSTRUCTION M ATERIAL

The major materials required for construction of the proposed project are steel, cement, bricks, metal, flooring tiles/stones, wood, sanitary and hardware items, electrical fittings, water, etc. All the materials to be used in the proposed project will be as per the national building code specifications.

4.4.1.2 SITE GRADING

It is recommended to carry out site grading works for the entire site area. The topography survey provides essential inputs to this exercise. To maintain the existing water bodies as well as to ensure prevention of water logging/ inundation at the site, filling of a part of the site area has been envisaged. The master plan drawing depicts the conserved water body within the site.

It is recommended to have the finished ground level of the EZ above the maximum flood level at the site.

4.4.1.3 STORM WATER DRAINAGE The area under study is proposed to be leveled by filling. It is planned to collect the storm water flow at low-lying areas within the site. Roads and drains within the individual plots of the industrial zone are recommended to be provided by the user industry. The storm water is proposed to be discharged at strategic locations on the river nearby, considered in the design of the storm drainage network. The proposed drainage system would be designed to cater to the surface runoff within the project area by gravity flow. Drains are proposed to be provided on both sides of the roads on site. Closed rectangular drains are adopted for the surface run off collection for the reasons of easy maintenance and land optimization. The entire zone area is designed to be covered under this collection system. Drains are designed on both sides of the road. Foot path is planned on top of the drain slab. RCC box culverts of suitable sizes are designed for road crossings. Rainwater harvesting structures are envisaged along the drain.

4.4.1.4 BUFFER REQUIRMENTS Buffer areas are areas between the roadside and the construction of the units in the plots. They consist of a green buffer and a physical buffer. The green buffer is meant for tree planting / turf and small ancillary structures. Within the physical buffer, driveways, car / lorry parks, and other ancillary structures can be developed. The buffer requirements vary depending on the width of the road along which the buffer is designed. The exhibit below captures a snapshot of the buffer requirements designed for the Sirajganj EZ

Road Width (m) Green Buffer (m) Physical Buffer (m) Total Buffer (m)

30 6 6 12

24 4 4 8

22 4 4 8

18 4 4 8

15 2 2 4

Figure: 14 Road Buffer Requirements

40

4.4 . 2 E N V I RO N M E N T A L I N F RA S T R U CT U RE

4.4.2.1 WATER SUPPLY AND TRE ATMENT SYSTEM

Presently, in and around Jamuna, underground water is the main source of water. Samples from Sirajganj Sadar Upazila show a considerable amount of variation in arsenic concentration level in the site proximity. According to the environmental provisions, surface water can be utilized from the Jamuna River for the EZ. By developing an intake well followed by proper treatment, the river water can be utilized for potable water consumption.

Water requirement of 60 m3 per day per hectare has been considered for the processing industries i.e. Knitting manufacturing industry, as per the prevailing standards for these industries. 50% of the requirement is considered for various processes involved during manufacturing and the balance 50% has been considered for drinking, sanitary and other purposes within the industry.

Demand requirement of 60 m3 per day per hectare has been considered for other industries, utilities, amenities,

institutional areas and 368 m3

per day per hectare for public green, and roads which are the norms as per the International Standards.

The water requirement for management accommodation is arrived at based on the total population which has been calculated based on the allocated area, floor area ratio, maximum allowed built-up area, population density and water demand per capita at the rate of 135 LPCD (Litres Per Capita Per Day) as per the BNBC (Bangladesh National Building Code). The summary of the assumptions is shown in the following exhibit.

Description LPCD Cu.m/ ha/ day

Knitting 60

Spinning 60

RMG 36

Staff Quarter 135

Figure 15 : Water Demand Estimation Standards

Water losses occur in the distribution and transmission network. The percentage of loss depends on the pipe material,

jointing system, etc. As this is a complete loss, it is recommended to be kept below 10% of the total demand, by

implementing efficient network design and construction as well as operation

Potable water has been considered to be used for bathing and washing, cooking and drinking. Non potable water has

been considered to be used for gardening, cleaning and toilet flushing. The water consumption pattern assumed is as in

the exhibit below

Bathing and Washing clothes 47%

Cooking, drinking and washing vessels 23%

Gardening and cleaning 9%

Toilet flushing 21%

Figure 16 Water consumption pattern (fraction of total demand)

For areas other than hospital and management quarter area (no bathing and washing facility)

Potable Water 44%

Non Potable Water 56%

41

For Hospital and management quarter area (bathing and washing facility envisaged)

Potable Water 70%

Non Potable Water 30%

Figure 17 Water Consumption Pattern – Potable vs. Non-potable

The following figure presents the water demand projection carried out for the Sirajganj EZ. It may be noted here that

the firefighting demand has been considered as one time usage driven, and therefore not been considered for daily water demand estimation. The water balance chart for the project has been annexed to the report.

Figure 18 Water demand projections Based on the estimates of water demand, the following water treatment, storage and distribution infrastructure is proposed for the EZ. Underground storage reservoirs (sumps) are recommended for water storage, including water stored for firefighting demand. The following exhibit captures a snapshot of the recommended capacity of such storage reservoirs.

Description Capacity in cu.m.

Potable Water Non Potable Water

Ground level storage reservoir 15000 & 100 10000 & 2550

Elevated storage reservoir 725 & 150 625 & 155

Figure 19 Storage Reservoir Size Estimation

A. Industries %

Total Area Water

Demand, cum / ha in %

Water Demand,

Cum/Day

Loss@ 10%

Cum/day

Total water

demand Cum / day

Potable water

demand Cum / day

Non - Potable water

demand Cum / day

Knitting 500.00 44.02 60

12,145.00

1,214.50

13,359.50 9,595.00 3,760.00

Spinning

300.00 26.41 60

7,287.00

728.70

8,015.70 5,757.00 2,256.00

RMG 97.94 8.62 36

2,378.96

237.90

2,616.86 1,879.47 736.51

B. Utilities - - - - -

Customs, Security, Admin, entrance

plaza & Social infrastructure

25.00

2.20 36 607.25

60.73 667.98 479.75 188.00

Essential staff quarters

15.00 1.32 135

364.35

36.44

400.79 287.85 112.80

Road 70.00 6.16 1.8

1,700.30

170.03

1,870.33 1,343.30 526.40

Greenery

103.00 9.07 1.8

2,501.87

250.19

2,752.06 1,976.57 774.56

Warehouse

10.00 0.88 36

242.90

24.29

267.19 191.90 75.20

Gas Power Plant 15.00 1.32 432.84

364.35

36.44

400.79 287.85 112.80

Total 1,136 100 799

27,592 2,759

30,351 21,799 8,542

mailto:Loss@%2010%25%20Cum/day



42

4.4.2.2 WATER PUM PING STATION

Water pumping station for potable and non-potable water is required for pumping clear water from the underground storage tank to respective elevated water tanks. Elevated tanks are proposed in order to cater to the entire area and their size is planned to be proportionate to the demand. The water supply scheme including distribution is planned to be designed and based on the assumptions set out below.

The peak flow factor is assumed to be 2.0. Minimum residual pressure at the inlet of the underground sump of each plot is assumed to be 7 m equivalent. The pipe material is assumed to be DI / HDPE.

4.4.2.3 ELEVATED STORAGE TANK

Two hours storage requirement is proposed for the elevated level storage tank

4.4.2.4 WATER DISTRIBUTION NETWORK

It is proposed to provide separate water distribution network for potable and non potable supply. Four elevated level

service reservoirs (ELSR) are proposed to be provided for potable and non potable water for the entire

4.4.2.5 T REATMENT OF WATER

Information from the socio-environmental baseline study reveals that there is a relatively high content of arsenic in the local water. The water treatment system is thus recommended to treat water towards removal of the arsenic content. The figure below enunciates the various alternatives possible for treatment of water.

Figure 20 Alternatives of Treatment of Water

The system selected shall ensure that the quality of water is within the acceptable drinking water standards. The arsenic removal shall be accomplished through the following process:

Coagulation/Microfiltration Fixed Bed Adsorption Technologies Coagulation/Filtration

Based on the above, the water treatment system with coagulation followed by filtration is recommended to encompass:

Primary treatment Aerator Flash Mixer Clarifloculator Secondary Treatment Rapid Sand Filter Filtered Water Tank Sludge handling Thickener , Auxiliary units: as required

A schematic diagram of the system is shown in the exhibit below :

43

Figure 21 Schematic of Water Treatment System

4.4.2.6 EFFLUENT, SEWERAGE A ND SULLAGE SYSTEM

The domestic sewage and sullage to be generated has been assumed to be 90% of the domestic water consumption in

addition to infiltration of 10%. Based on the general wastewater generation pattern, the amount of wastewater

generated in domestic premises is classified in the exhibit below

Description % Fraction Bath/ Shower & Laundry 55%

Hand Basin, Kitchen 10% Toilet 35%

Figure 22 Waste Water Estimation

Waste water generation from bath / shower etc. in the EZ is expected to be relatively insignificant. Also, based on the water consumption by the industrial sub-zones within the EZ, normative indications towards the effluent generation were utilized to estimate the effluent generation.

It may be noted here that considering optimal land usage and viability aspects of industrial land use mix, only the yarn and fabric industries are assumed to be polluting units. The other industries are assumed to be only formulation (in case of Pharma), apparel-making (in case of Leather and Jute) etc. and not producing any effluents. 4.4.2.7 SOLID WAST E GENERAT I ON On a normative basis, the components of the solid waste considered for the project are summarized in the following exhibit.

Solid waste component

Constituents

Domestic waste Kitchen and wood waste, plastic, paper, floor sweepings, etc

Industrial waste Sludge generated during production process, effluent treatment waste, chemical waste including hazardous and toxic waste, burnt fuel solid waste, oil slurry, packing waste etc.

Road, garden & foliage waste Leaves, branches, plants, road sweepings

44

etc Construction waste Earth, asphalt, concrete, brick, plaster, wood, glass,

stones etc.

Bio – Medical Waste from the health care

facility.

Exhibit 23 Solid Waste Constituents

The solid waste generation rates of industries and other areas vary to such an extent that exact quantification of solid waste generation is not feasible at this point. However, an attempt has been made to quantify & qualify the solid waste that may be generated from various components of the EZ.

The total quantity of solid waste to be generated from the EZ depends on various factors such as:

Type of occupants and their occupancy ratio

Processing methods, efficiency & capacity

Preparatory losses of each type of industries

Critical process requirements

Type & quality of raw materials to be processed & the consumables

Total manpower required for the industries and the likely domestic waste generated.

The total population as per the assumptions considered earlier is taken into consideration for the waste generation estimation. Further, as quantification of solid waste is not an exact science and no data is available for municipal solid waste generation within an EZ, estimation of solid waste generation was carried out based on norms. The following exhibit captures a snapshot of the norms adopted for solid waste generation estimation

Project component

Project component

Rationale

Industries 150 kg / acre/day Considered including packing materials, street

& floor sweepings, part of industrial waste etc

will contribute to this higher generation rate

All other areas 100 kg / acre/day Considered including food waste & others

Roads

25 kg / acre/day Considered as sweeping waste, foliage waste etc.

Greenery, utilities 150 kg / acre/day Considered including packing materials, street & floor sweepings, part of industrial waste etc will contribute to this higher generation rate

Exhibit 24 Solid Waste Generation Assumptions Based on the above, the solid waste quantity estimation has been carried out, the snapshot of which is depicted in the following exhibit

45

A. Industries Total Area

Faction

Solid waste Generation

Acre/day

Total solid waste

Generation Tons/day

Knitting 500.00 44.02 150.00 75.00

Spinning 300.00 26.41 150.00 45.00

RMG 97.94 8.62 150.00 14.69

B. Utilities -


25.00 2.20 75.00 1.88

Essential staff quarters 15.00 1.32 100.00 1.50

Road 70.00 6.16 100.00 7.00

Greenery 103.00 9.07 25.00 2.58

WareHouse 10.00 0.88 75.00 0.75

Gas Power Plant 15.00 1.32 75.00 1.13

Total 1,136 100 900 150 Figure 25 Solid Waste Generation Estimation 4 . 5 M A N P O W ER 4 . 5 . 1 CO N S T RU CT I O N S T A GE

It is estimated that almost 6970 gross person-years of employment could be created during the construction phase

4 . 5 . 2 O P E RA T I O N S T A GE The total man Power requirement for administrative level and maintenance of various environmental infrastructures during operation stages are presented in the following two figure

Employee Level Staff Employed

Top management 5

Senior Management 4

Middle Management 10

Lower Level 16

Secretarial 15

Total 50

Figure 26 Man Power for Administrative Level

46

Designation Tim

e Nos/ Sirajganj

shift STP 1

STP 2

WDS / WTP

WDS / WTP

CETP-1 CETP-2 SWM Total

Plant in charege G Shift 1 1 1 1 1

4

Shift Operators 3 shift 21 1 3 3 3 3 3 3 3

21

Relievers 4 1 1 1 1 1 4

Helpers 3shifts 1 3 3 3 3 3 3 3 21

Relievers 1 1 1 1 4

Mechanic G shift 1 1 1 1 1 1 1 2 8

Electrician G shift 1 1 1 1 1 4

Misc. labour for cleaning

2 2 1 1 2 2 15 25

Lab Chemist G shift 1 1 1 1 4

Plumber 3 3 6

Reliever 2 2

Bill collectors 4 4

Tractor driver 4 4

Front end loader driver

4 4

SWM collection team

10 10

Watch & Ward 3 3 3 3 3 3 3 21

Watch & Ward – reliever

1 1 1 1 4

Exhibit 27 Man power Requirement for maintenance of Various Environmental Infrastructure

47

CHAPTER # 5 ENVIRONMENTAL BASELINE DATA ON PHYSICAL, ECOLOGICAL AND

SOCIOECONOMIC PARAMETERS

5 D E SC RI P T I O N O F T H E E N V I RO N M E N T

5. 1 G E N E RA L

The primary objective of the study of existing environmental parameters is to provide an environmental baseline with which potential impacts from the construction and operation phases of the proposed project can be compared.

Identification of environmental parameters, data collection and impact predictions form the core of Environmental Impact Assessment exercise. A scoping matrix has been formulated to identify the attributes likely to be affected due to the proposed project and presented in the exhibit below.

Baseline data includes inventory of physical, ecological and socio-economic parameters. Covering these aspects, data has been compiled for:

Land Environment (physiography, geology, seismology and soils); Water

Environment (water resources, water quality);

Air Environment (meteorology, air quality);

Noise Environment (noise levels); Ecological Environment

Socio-economic Environment

Baseline data for the study area was collected using the following methods:

Previous studies and literature review Site Reconnaissance and Field Visits Organizational Visit

Public

Consultations Field Studies Laboratory

Analyses Preparation of Maps

SN

Important Environmental Components (IECs)

Likely Impacts

Natural Environment 1 Hydrology/Flo

oding Hydrological impacts include sedimentation, submergence of structures, bank erosion, and damage in the surrounding area

2 River erosion and siltation

Because of the construction activities in the site and possible obstacles to the flow of river, there could be impacts on the flow of river and sediment carrying capacity of the river.

3 Drainage Congestion

The approach road may have negative impact on local drainage pattern especially since the proposed site is located in a flood plain.

Ecological Environment 1 Aquatic Ecology Fish spawning, Fish Nursery, Cage Culture fishing and Pen

Culture (Katha fishing) are dominant in the region. Project development may lead to disrupt fish migration, fish

48

spawning and nursing ground and also the aquaculture activities by the local people.

2 Agriculture Agricultural land will be converted to industrial land cause agricultural production loss and soil quality degradation

3 Tree Cutting/plantation

In order to implement project components, trees have to be cut. On the other hand, opportunity for tree plantation arises due to the project and associated green belt and open

spaces 4 Wild Life Construction activities may create disturbance for aquatic

and terrestrial wildlife. However, terrestrial wild animals are rare in the region.

Environmental Pollution

1 Water Quality During construction: Surface run off from project site, Oil/fuel and waste spills, sewage discharge from labour camps and site office

During Operation: Waste Water Discharge, Discharge of Sewage, Oil/fuel and waste spills.

2 Noise Pollution During Construction: Noise due to operation of various equipment/generators and due to increased vehicular movement, pile driving During Operation: Noise from the industries, vehicle movement and generators.

3 Air Pollution During Construction: Dust generation from construction activities, air pollution due to increased vehicular movement, fugitive emissions from various construction equipment During Operation:

Air emissions occurring from the industrial units engaged in the production of manufacturing goods

4 Soil Pollution Accidental spillages of toxic chemicals such as fuel, lubricants and solvents may pollute soil

5 Socioeconomics Pre-Construction Stage

Loss of Land

Loss of structures

Loss of income

Construction Stage

Increased Job Opportunity

Increased Commercial activities

Operation Stage

Multiproduct sector enhancement

Increased commercial activities

Increased Job opportunities

Exhibit 28 Scoping Matrix

49

The methodology adopted for data collection is highlighted wherever necessary and the frequency adopted for data collection for environmental attributes is summarized in the following exhibit. SL No Attribute Parameters Freq

uency

Source

LAND ENVIRONMENT

1 Soil Soil Characteristics

- Literature review

2 Geology Geological Status

- Literature review

3 Seismology Seismic Hazard

- Literature review

WATER ENVIRONMENT 4 Water Quality Chemical

parameters One season

Field studies and Laboratory Analysis

AIR and NOISE 5 Ambient Air Quality SPM,SO2, NOX One

Season Field studies and Laboratory Analysis

6 Metrology Temperature , Rainfall, Wind Speed

Data BMD/Literature review

7 Noise Noise levels in db

One Season

Field Studies

Ecological Environment 8 Ecological Aspects Flora,Fauna, Threaten

Species Socio Economic Aspects

Socio Economic Aspects

9 Socio economic Aspects Socio economic characteristics of the affected area

Field Literature Studies and review

Figure : 29 Environmental Attributes and Frequency of Monitoring

50

5 . 2 P RO J E CT I N F L U E N CE A R E A

For the purpose of the EIA study, the Project Influence Area (impact zone) for the proposed Sirajganj Economic Zone confines within a radius of 2 km from the proposed project boundary since the nature of the project is such that most of the potential impacts are most likely to occur within this area as shown in the following exhibit.

The baseline information is collected for the identified influence area, where proposed project area is considered as the core zone with respect to the peripheral zone. Information for most of the environmental parameters and features was collected for this zone. However, general information of a larger area has been gathered from the secondary sources to compare the zone with on a broader scale.

SL No.

Attributes Direction Distance Features/

Remarks

1 Bangobandu Multripurpose Bridge North east Adjacent Major Bridge

2 Sidarbad Power Plant North east Adjacent Power Plant

3 Dhaka Rajshashi Highway North Adjacent Major Road

4 Belkuchi-Shragjang Approach Road West 1 KM Major Road

5 Jamuna River East Adjacent River

6 Shomeshpur Bazar North 2 Km Market

7 Randounipur Bazar North 3 Km Market

At a glance Rajapur UP of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila

Rajapur Number Belkuchi Number

Name 2 No Rajapur Union Number of HHs 7426

Area 6945 Number of voters 31460

Population 47596 Number of Mouza 23

Number of Village 33 Number of Village 37

Number of Mouza 5 Number of Bazar 05

Bazar 2 Number of High School 02

Transformation from

Sodor Upzila

CNG/Rickshaw/Bus Number of Gils High School 01

Literacy Rate 40.99% Number of Government Primary

School

11

Government Primary

School

12 Number of Non-Government

Primary School

10

Non-Government

Primary School

05 Number of Public Health

Primary School

01

High School 03 Public Library 02

Madrasa 14 Kinder Garden 02

Chairman Md. Ataur Rahman Lillah Boarding 05

Important religious

places

02 Ebtedaiyee Madrasa 04

RAJAPUR UP SAIDABAD UP

Figure : 30 At a glance Rajapur UP of Belkuchi Upazila and Saidabad Union of Sirajganj Sadar Upazila

51

5 . 2 . 1 D E T E RM I N I N G F A CT O RS F O R T HE P RO J E CT I N F L U E N C E AREA

Factors that were considered in determining the project influence area-

Construction Stage

Noise Pollution

Nuisance dust – PM10, ,SPM, Dust etc.

T raffic congestion

Operation Stage

Environmental Pollutant- liquid discharge/effluent outlet/ discharge outlet/ point

Air Emission dispersion Noise and Vibration Others

Load on infrastructure/ utilizes facilities- road, building, gas , electricity, water

Location of affected communities those who are using water body as source of drinking water

Location of ultimate recipients of above issues (surrounding villagers)

The methodology adopted for determining the influence area was:

Impact prediction

Physical observation of surrounding settings

General information on the site and surrounding collection

Mapping/overlay the project influential area over base map

Further information was gathered on the existing physical environment including meteorology, geology, topography, soils, hydrology and drainage, surface water quality, air quality and noise levels. The following sub-sections elaborate the findings in this regard.

5 . 3 P HY S I CA L E N V I RO N M ENT Following sub-sections detail out the current status of various environmental parameters in the study area 5 . 3 . 1 A T M O S P HE RE & C L I M A TE

The climate of Belkuchi and Sirajganj Sadar Upazila follows the sub-tropical monsoon climate of Bangladesh. North- west monsoon dominates the rainy/summer season and north-east monsoon drives the dry/winter season. Rainfall in the project area varies considerably depending on the season. The annual rainfall measured at Sirajganj averaged 1610 mm over the period 1990-2014. On an average, 60 to 70% of the annual rainfall of the project area occurs in the months of May, June, July and August. The post-monsoon or transitional season, October to November, is warm and humid with unstable atmospheric conditions that induce local thunderstorms due to the influence of cyclones from the Bay of Bengal. The cool dry season during December-March, is sunny with infrequent rainfall that is normally within three percent of the total annual rainfall. The pre-monsoon season between April-May is hot and is characterized by thunderstorms called

‘Nor-westers’, with heavy rainfall. The most important climatic events of the project area are the onset and withdrawal of the monsoon. The Bangladesh Meteorological Department (BMD) was contacted to obtain specific

meteorological data pertaining to the project area and its surroundings. The nearest meteorological observation

station is based at Sirajganj, about 20 km away from the proposed area. The meteorological data have been

considered in the engineering and design aspects such as the zoning & relative positioning of industrial clusters

within the area.

52

5.3.1.1 TEMPERATE

The exhibit below shows the average maximum and minimum temperature for the year 2005 to 2007. average maximum temperature is 34.6 °C in April and the average minimum temperature for three years was 11.9 °C in January .

5.3.1.2 RAINFALL

Rainfall varies considerably with a peak of 987 mm achieved during September 2007. The minimum rainfall recorded was zero mm in December 2005 and January 2006.

5.3.1.3 HUM IDITY AND WIND

Humidity levels are consistently very high during the monsoon season,

and drop significantly for a relatively short period at the end of the

dry season. Sunshine levels are low during the monsoon, but are

consistently high from November to May. It is reported that wind

speeds are at a maximum level in the early part of the monsoons, but drop substantially by the beginning of the dry season.

Wind direction is mainly from north to north-west during the dry season and from south to south-east during wet season.

5.3.1.4 AIR QUALIT Y

The Department of Environment (Rajshahi Division) does not have any record on regular air quality monitoring program for ambient condition or emission for the project area. Ambient air quality measurements are essential to provide a description of the existing conditions, to provide a baseline against which changes can be measured and to assist in the determination of potential impacts of the proposed EZ on air quality. In order to establish baseline air quality, air quality analysis was performed. The air quality assessment involved the

determination of ambient levels of Suspended Particulate Matter (SPM), Oxides of Sulphur (SOx) and Nitrogen (NOx).

Air samples were collected from the site for a standard continuous 8-hour run using pre-calibrated High Volume Sampler.

The following exhibit presents the air quality sampling locations

Parameter Testing Procedures

SPM Gravimetric method using High Volume Sampler NOx Absorption in dilute Sodium Arsenite Solution

SO2 Absorption in Potassium tetrachloromercurate solution

Figure 31 Procedures for Determining Various Air Quality Parameters

53

Test results are presented below and were observed to be within acceptable ambient standards (except the value of SPM which is slightly higher) as specified in Environmental Quality Standards for Bangladesh as well as WHO standards. The value of SPM exceeded the allowable limits probably due to the presence of dustiness adjacent to the bank of river.

SPM

(µg/m3)

SO2

(µg/m3)

NOx

(µg/m3)

BD Guidelines2(µg/m3)

WHO

Guidelines3 (µg/m3)

215.9 Not Detected 20.5 SPM- 200 (8 hrs) _

SO2- 365 (24 hrs)

SO2- 80 (annual)

20 (24 hr mean)

NOx – 100 (annual) 40 (annual)

Figure 32 : Air Quality Results around SEZ Area Note: Air Quality tests performed at Department of Environment Laboratory, Dhaka Division 5 . 3 . 2 L A N D CO N D I T I O NS

Following sub-sections describe the existing land condition in the study region.

5. 3.2.1 GEOLOGY

5.3.2.1 PHYSIOGRAPHY

Sirajganj site is located on the flood plain of the Jamuna. Sirajganj Sadar and Belkuchi Upazlia is located in Sirajganj district . On the eastern side is the Jamuna river and on the western side is the Belkuchi-Sirajganj access road. The Northern side is the Dhaka –Sirajganj highway and Southern side of project is Belkuchi Upazila. Sirajganj town is located north-west side of the proposed project site. The project is located western side of Bangabondu Multipurpose Bridge.

5.3.2.2 SOIL T YPE AND QUALITY

The soils of the project area have been deposited by the Jamuna River on its flood plain, or on the river channel as channel bar deposits during the Holocene and Quaternary Periods. Frequent shifting of channels resulted in the formation of lenses and inter–tonguing in both surface and subsurface sediments. At present, surface sediment of the proposed project site is mostly sandy clay with considerable amount of sand just below the surface. Soil of the area is grey loam on the ridges and grey to dark grey clays in the basins. The dominant general soil type is non-calcareous grey flood plain soil. Top soils are strongly acidic and sub-soils slightly acidic to slightly alkaline. General fertility level is medium with low nitrogen and organic matter

54

Figure 33 Physiographical Map of Bangladesh

5 . 3 . 3 W A T E R RE S O U R CES 5.3.3.1 BASIC HYDOLOGY

The Brahmaputra-Jamuna is the second largest river in Bangladesh and one of the largest rivers in the world, flowing through T ibet, China, India and Bangladesh. Actually Jamuna is the downstream course of the BRAHMAPUTRA which took place after the EARTHQUAKE and catastrophic FLOOD between 1782-1787. Presently the Brahmaputra continues southeast from Bahadurabad (Dewanganj upazila of Jamalpur district) as the OLD

BRAHMAPUTRA and the river between Bahadurabad and Aricha is the Jamuna, not Brahmaputra. The Hydrology Directorate of the BANGLADESH WATER DEVELOPMENT BOARD (BWDB) refers to the whole stretch as the Brahmaputra-Jamuna.

Average annual flow at Bahadurabad is estimated to be 501 million acre-feet. August has always been the month when widespread flooding has been most likely. Floods from May to July are usually due to the Brahmaputra -Jamuna and Meghna. From August to October due to the combined flows of those river and the Ganges. As a rule, the flow of the Brahmaputra-Jamuna is more erratic than that of the Ganges. The gradient of the Jamuna averages 1:11,850 which is slightly more than that of the Ganges. The Jamuna discharges a large volume of water and at the same time brings in huge amounts of SEDIMENTs. During the rainy season it brings down something like 1.2 million tons of sediment daily, and the annual silt runoff at Bahadurabad is estimated at 735 million tons.

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Recently a 4.8-km long bridge has been constructed over the Jamuna for linking the eastern and western parts of Bangladesh. The eastern edge of BANGABANDHU JAMUNA MULTIPURPOSE BRIDGE lies in Bhuapur upazila of Tangail district and the western end in Sirajganj Sadar upazila of Sirajganj district. Apart from quick movement of goods and passenger traffic by road and rail, it has facilitated transmission of electricity and NATURAL GAS, and integration of telecommunication links. The bridge was opened for traffic on 23 June 1998. A considerable volume of river training work was done to keep the river within the bridge instead of a flood-width of 14 km at the bridge site. During the dry season, water levels can be as low as 0.52 m above sea level, while during the monsoon season water levels can be much higher causing the Jamuna to overflow onto the low-lying floodplains.

The highest flood levels were recorded at the Jamuna hard point (about 11 km north –west of the project site) during the monsoon of 1998, 1988 and 1974 when flood elevations of +27m , +6.55 m and + 6.19 m PWD were noted respectively. At the same gauging station, the lowest elevations of 0.0 m PWD in the year 1994 and 0.2 m PWD in the year 1982 were recorded .

Source : http://

www.weatherforecastmap.com/bangladesh/tangail/

Average Weather in Tangail for July

Sunlight 10 hours a day

Coldest July temperature 22°C

Coldest daily temperature 23°C

Warmest daily temperature 28°C

Warmest July temperature 34°C

Discomfort* High

Morning Humidity 76%

Evening Humidity 68%

Rain in July 1262 mm

Wet days for July 14 days

Average Weather in Tangail for August

Sunlight 7 hours a day

Coldest August temperature 24°C

Coldest daily temperature 24°C

Warmest daily temperature 28°C

Warmest August temperature 37°C

Discomfort* High

Morning Humidity 79%

Evening Humidity 71%

Rain in August 758 mm

Wet days for August 17 days


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Figure 34. Flood level map of Bangladesh

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5.3.3.2 RIVER NET WORK The study area possesses the following sections of the rivers and adjacent floodplains: Jamuna

River (West)

5.3.3.2.1 JAM UNA RIVER

The Jamuna River is one of the three main rivers of Bangladesh. It is the main distributary channel of the Brahmaputra River as it flows from India to Bangladesh , Length: 205 km, Basin area: 47,000 km², Source: Chemayung-Dung glacier, Country: Bangladesh, Bridges: Jamuna Bridge, Cities: Mymensingh, Pabna, Tangail. This river drains the northern and a part of the southern slope of the Himalayas. Its basin area is nearly 570,000 km2 , and it is the highest contributor of fresh water into the estuary – more than 60% annually. Compared to the Ganges River, human interventions are insignificant in the Brahmaputra/Jamuna basin. The flow hydrograph for the Jamuna shows that the average peak (70,000 m3/s) of the river occurs in July/August and the average minimum flow (4,200 m3/s) occurs in February/March. Long-term observation of discharges suggests an apparent (although not significant) trend of increase in the flow volume. Since the seventies, very high variability has been apparent in the annual peak discharges, though the reasons for this trend are not

yet clear. This has an impact on the Meghna Estuary, especially in terms of increasing fresh water flows during the wet season. Brahmaputra/Jamuna is the largest source of sediment in the Meghna Estuary. The Bhadurabad station, situated about 240 km upstream of Chandpur in the northern limit of the Meghna Estuary, is the only sediment gauging station in the Brahmaputra/Jamuna River in Bangladesh. T ime-series (although not continuous) sediment measurements since 1964 are available at this gauging station. The bed materials in the Brahmaputra/Jamuna River comprise fine sand of an average grain size of 0.20 mm, which become gradually finer downstream. The suspended mode of sediment transport is the dominant process in the river. 1/3 of this sediment consists of fine sand and the rest silt and clay. Nearly 500 to 600 Mtons of sediment input is found at Bahadurabad. It has been found that the sand fraction of the sediment has decreased considerably over time, which indicates that there is variation in sediment input in the estuary with time. This is assumed to be the result of the Assam Earthquake in 1950, during which a huge amount of sediment was produced and transported to the estuary through the Brahmaputra/Jamuna River. The high accretion rate in the Meghna Estuary during the last 50 years is probably related to the extra sediment produced by the earthquake

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5.3.3.2.4 FLOOD PLAINS

Jamuna (Young Brahmaputra) Floodplain an alternative name used for the mighty Brahmaputra river, because the Jamuna channel is comparatively new and this course must be clearly distinguished from that of the older one. Before 1787, the Brahmaputra's course swung east to follow the course of the present Old Brahmaputra. In that year, apparently, a severe flood had the effect of turning the course southward along the Jenai and Konai rivers to form the broad, braided Jamuna channel. The change in course seems to have been completed by 1830. Due to the upliftment of the two large Pleistocene blocks of the Barind and Madhupur, the zone of subsidence between them was turned in to a rift valley and became the new course of the Brahmaputra as the great Jamuna. Both the left and right banks of the river are included in this sub-region. The Brahmaputra-Jamuna floodplain again could be subdivided into the Bangali-Karatoya floodplain, the Jamuna-Dhaleshwari floodplain, and diyaras and chars.

The right bank of the Jamuna was once a part of the T ista floodplain, and now through the Bangali distributary of the Jamuna is a part of the bigger floodplain. Several distributaries of the Jamuna flow through the left bank floodplain, of which the dhaleshwari is by far the largest; this floodplain is sub-classed as the Jamuna-Dhaleshwari floodplain. The southern part of this sub-region was once a part of the Ganges floodplain. Along the Brahmaputra-Jamuna, as along the ganges, there are many diyaras and chars. In fact, there are more of them along this channel than in any other river in Bangladesh. There is a continuous line of chars from where this river enters Bangladesh to the off-take point of the Dhaleshwari. Both banks are punctuated by a profusion of diyaras. The soil and topography of chars and diyaras vary considerably. Some of the largest ones have point bars and swales. The elevation between the lowest and the highest points of these accretions may be as much as 5m. The difference between them and the higher levees on either bank can be up to 6m. Some of the ridges are shallowly flooded but most of the ridges and all the basins of this floodplain region are flooded more than 0.91m deep for about four months (mid-June to mid-October) during the monsoon.

The project area falls under the Jamuna flood plain system. All floodplains of the project area are extremely seasonal. These floodplains are fringing type i.e. plain upon which alluvium is deposited in relatively narrow discrete strips bordering the main river channel.

The schematic diagram of the entire river network system including associated flood plains of the study area is presented in the exhibit overleaf.

5.3.3.3 DRAINAGE SYSTEM

Jamuna river and its tributaries form the natural drainage system for the site . The recorded highest peak flow of Brahmaputra-Jamuna is 98,000 cusec in 1988; the maximum velocity ranges from 3-4 m/sec with a depth of 21-22m. The average discharge of the river is about 20,000 cusec with average annual silt load of 1,370-tons/sq km. The average slope of the Jamuna is about 1:11,400; however, the local gradient differs quite considerably from the average picture.

Although, Jamuna River provides the major drainage outlet of

the proposed project site, because the site adjacent with the Jamuna river Sirajganj point

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5.3.3.4 FLOODS AND WAT ER LOGGING According to the local inhabitants, the proposed project site is frequently affected by floodwater. However, at present, there is a road cum embankment that provides partial flood protection for the area. Other dynamics like topography and landform indicate that the area is affected by flood. It is to be noted that the formation level for the Dhaka-Sirajganj Highway (Highway N1) was raised to make it flood proof.

Maximum recorded water level at Sirajganj Hard Point is 6.17 m and estimated water level for 100 years return period at Bangobondu Bridge is 6.36 m, whereas ground elevation of the area varies between 8 to 10 m. This data may suggest that flooding in the project area is either due to local drainage congestion or river flooding. There is also a possibility that what the local people consider as flooding from the major river could, in reality, be local water logging. 5.3.3.5 RIVER EROSION As we know that Sirajganj is one of the river erosion affected area in Bangladesh and proposed site is closed with Jamuna river . So, planning stage need to prepared a protection dam for proposed EZ. Last 10 years the river erosion beside Jamuna river has been improved due to Jamuna Multipurpose bridge project. 5.3.3.6 SURFACE WAT ER QUALITY Two major centers of economic activities are located on the river Jamuna: Jamuna Multripupose Bridge and Bagabari River Port. Bangobondu Multripurpose Bridge is upstream to the proposed EZ site and Bagabari Reiver Port Authority is downstream to the proposed site. The river receives effluent from major industrial units as well as domestic and commercial wastes from sirajganj and other smaller economic/commercial centers and from the rural area, located on its banks. Run off from agricultural fields containing pesticide and chemical fertilizer residues are also drained into the river.

However, from the river monitoring data available with the DoE, Jamuna River appears to be relatively non-polluted. The river is in good condition aerobically and there is no problem with septic nature of the river. Given the large discharge of the river and limited number of industries, the septic nature is not a major concern for Jamuna.

For the determination of surface water quality, water samples were taken from Jamuna River. Water samples were collected by using Rutner sampler. The samples were preserved after collection and were analyzed for the parameters shown in the exhibit below.

Water samples were collected for the analysis of the following parameters:

pH: Measured by a digital PH meter

BOD: Measured by Incubation bottles (250-300 ml) & water Bath (thermostatically controlled at 200

C±10 C), (unit: mg/l (5 days))

DO: Measured by Portable Luminescent Dissolved Oxygen Meter

COD Measured with titration against 0.1250N ferrous ammonium sulphate using ferrous indicator.

Oil Measured by Partition Gravimetric methods (unit: mg/l) TSS Measured by Suspended

Solids Meter

TDS Measured by conductivity/TDS meter

5.3.3.7 GROUND WATER

Groundwater is the major source of drinking water in the region. It is also an important source of irrigation water for the area. The project area has good groundwater potential, as groundwater recharge is not a

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problem, due to the presence of highly permeable sandy soil. There are sandy aquifers at relatively low depths. The National Hydrochemical Survey found that the young (Holocene) alluvial and deltaic deposits are most affected whereas the older alluvial sediments in the north-west and the Pleistocene sediments of the uplifted Madhupur and Barind tracts normally provide water with low arsenic content. However, arsenic contamination in groundwater aquifers of the Bengal Basin is not uniformly distributed, because of lenticular nature of alluvial and deltaic deposits. Some of the wells may show high concentration of arsenic, whereas some may show very low concentration.

The National Hydro chemical survey found that arsenic concentration in groundwater of Siraganj District varies from 6-50 µg/l. Samples from Sirajganj Sadar and Belkuchi Upazila show a considerable amount of variation in arsenic concentration levels. Groundwater samples collected from a tubewell (13 m deep) of Upazila DPHE of Sirajganj Sadar Upazila showed a value of 31µg/l. However, groundwater samples collected from a tubewell (24 m deep) at Rajapur had arsenic concentration of 47.9 µg/l. Bangladesh standard for acceptable limit of arsenic concentration in drinking water is 50µg/l and as per WHO guidelines, it should be nil. During consultations in the Rajapur area (adjacent to the proposed Sirajganj EZ site), it was reported by the villagers that out of 65 tube-wells, only two wells are arsenic affected. Ground water samples were collected from one tube well at Bangobondu Bridge, about 1.5 km away from the proposed Sirajganj EZ area. The arsenic level in this sample was found to be nil. One of the reasons for that can be that the sample was taken from a 380m deep tube well. Low arsenic level in the sample suggests that the ground water at lower depths is arsenic free and suitable for potable use.

5 . 4 BI O L O G I CA L E N V I RO N M E NT The biological component generally refers to flora and fauna, their present status, description and habitats. The status of the flora and fauna of the study area (both terrestrial and aquatic environments) was determined by:

Transit walks

Interviews, and

Review of literature relevant to the area

5 . 4 . 1 E CO L O GY

Rajapur and Saydabad Union constitute a part of the Jamuna flood plain ecosystem and are inhabited by many freshwater plants and animal species. The channels of Jamuna River and wetlands of Jamuna flood plain are habitat to many species of commercial freshwater fishes, native waterfowl and migratory birds. Jamuna River is also a major route for fish migration and the surrounding canals and floodplains area are spawning grounds for some commercial fishes

5 . 4 . 2 A QU A T I C F LORA

The proposed EZ may have an impact on the aquatic plant species of the area, if appropriate mitigation measures are not enforced. Although many varieties of aquatic plants can be found in and around the project area, their diversity and abundance have been reduced and are now mostly restricted to river systems and wetland regions. Most of the aquatic plant species of the project area and the Jamuna Basin are sensitive to seasonal water level fluctuations, and regeneration and growth are governed by these parameters. In the permanent water bodies (‘beels’ - small ponds/lakes; and parts of river channels), plants can survive and reproduce for the whole year. Five different types of aquatic flora are found in and around the project area. They are:

Submerged plants;

Free floating plants;

Rooted floating plants;

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Sedges meadows; and.

Plants on margins (surrounding higher ground)

Submerged plants are present in the project area, both in ‘beels’ and seasonally flooded areas. Almost all of these plants are monocotyledons and belong to families like ‘Aponogetonaceae’ and ‘Hydrocharitaceae’. These plants start growing with the rise of water level and sustain as long as water is present.

Free floating plants are common throughout the project area although they are not among the most dominant plant communities of ‘beels’ and relatively stagnant parts of the river channels. They are related to families like ‘Eichhornia’, ‘Azolla’ and ‘Kachuripana’. Many fish ponds are also covered by this type of vegetation. Rooted floating plants present in the project area include species with dominant families of ‘Nymphaeaceae’ and ‘Menyanthaceae’. They are most common in ‘beels’, old ponds and deeply flooded floodplain portions of the project area. They are found in shallow parts of ‘beels’ or depressed areas due to inadequate time for growth. ‘Shapla’ is one of the common plants of this type. Reed and grasses cover high and medium high land and are not frequently affected by floods. This type of vegetation consists of plant families like ‘Phrgmites’, ‘Gramineae’. This group of plants consists of both grass and woody shrubs. ‘Durba’ (Cynodon aciculatus), ‘Kash’ (Saccharum spontaneum), ‘Gagra’ (Xanthium strumarium), ‘Binna ghash’ (Vetiveria zizaniodies) belong to this group of plants and they are quite common in the project area. Some of the most common aquatic plants of the project area include ‘Kachuripana’ (Eichhorina crassipes), ‘Makhna’ (Euryale ferox), ‘Shapla’ (Nymphaea nouchali), ‘Janglidhan’ (Hygrohiza aristrata), ‘Boronukha’ (Monochoria hastata) and ‘Binna’ (Vetivera Zizanoides).

A list of common plants including aquatic plants of the project area is presented in the annexure to the report

(Annex 5)

5 . 4 . 3 A QU A T I C F A U NA Fish is the most common aquatic fauna in the project area, in addition to other aquatic animals like crabs and mollusks. There are also a number of species of reptiles and amphibians like Bibron's softshell turtle (Pelochelys bibroni), Gangetic gharial (Gavialis gangeticus), Ganges softshell turtle (Aspideretes gangeticus), Median roofed turtle (Kachuga tentoria) Jerdon's bull frog (Hoplobatrachus crassus), Skipper frog (Euphlystis cyanophyctis) etc.

Jamuna and its floodplains provide very important habitat for many commercial species of fish. The river is also a major route of fish migration. In general, there are two groups of freshwater fish species in and around the project area. The chief are those that spawn and breed locally in local drainage systems and floodplains. Their spawning migration start when early flash floods or rain water inundates areas rich in nutrients creating favorable environmental conditions including expanded areas of aquatic habitat. This group of fish include Koi (Anabas testudineus), Khalisha (Colisa fasatus), Punti (Puntis ticto), Shol (Channa striatus), Taki (Channa punctatus) Shingi (Heterpneustes fossilis) etc. Towards the end of the monsoon, the fish start to return to rivers, streams and other aquatic parts of the project area. A list of common fish species is enclosed as annexure to the report (Annex 4). It may be noted here that the zero discharge concept proposed in the engineering & design study along with appropriate environmental mitigation measures enforced successfully would ensure minimization of the impact of the proposed project on various environmental components encompassing the fauna.

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5 . 4 . 4 T E RRE S T RI A L F L ORA There is no natural hardwood or freshwater swamp forest in the proposed project area. In general, most of the terrestrial vegetation of the project area is found along roadside and homesteads. Terrestrial vegetation is also found on the high ground of agricultural land and on the side of flood protection embankments. Common terrestrial plants of the project area include: Narikel (Cocos nucifera), Supari (Areca catechu), Kala (Musa spp), Ata (Annona squamosa), Kathal (Artocarpus heterophyllus), Aam (Mangifera indica), Tal (Borassus flabellifer), Simul (Bombax ceiba) Khejur (Phoenix sylvesetris), Debdaru (Polyalthia lonfifolia), Rain tree (Samanea saman), Koroi (Albizia sp), Gura neem (Melia sempervirence), Bel (Aegle marmelos), Bansh (Bambusa sp), Pitali (T rewia nudiflora), Painna dumur (Ficus heterophyllus) etc. A list of common plants, including homestead vegetation is annexed to this report (Annex 5).

5 . 4 . 5 T E RRE S T RI A L F A UNA There are very few wild mammals in the project area. The species that are present include small mammals such as Bengal Fox (Vulpes bengalensis), Common Mongoose (Herpestes edwardsi), Indian Porcupine (Hystrix indica), etc. Ud Biral (English Name: Indian Otter, Scientific Name: Lutra pespicillata). Other terrestrial animals like lizard, mouse, rats and bats are also found in the project area. The chars and the rivers of the project area are visited by different kinds of migratory birds. They normally use these areas as a temporary habitat. A list of wildlife species of the project area is also annexed to this report (Annex 4 ).

5 . 4 . 6 P RO T E CT E D A RE AS ’Protected Areas’ of Bangladesh covers an area of 2, 43,435 hectare, which accounts for 16% of the total area managed by the Forest Department and almost 2% of total area of Bangladesh. It includes 8 National Parks, 7 Wildlife Sanctuaries, 1 Game Reserve and 5 other conservation sites.

THE PROPOSED PROJECT DOES NOT FALL UNDER THE JURISDICTION OF ANY OF THE PROTECTED OR SENSITIVE AREAS OF BANGLADESH.

5 . 5 N A T U RA L HA Z A RD S A N D RI S KS

Because of the physiography, geography and other natural conditions of Bangladesh, the country is susceptible towards certain natural hazards and calamities like floods etc. The following sub-sections describe these in greater detail.

5 . 5 . 1 S E I S M I C E F F E CTS The project site is located in Seismic Zone II, an area classified as having potential for intermediate intensity earthquakes. This intensity can be up to VII on the Modified Mercalli Scale (MMS) (i.e. approximately 6.2 on the Richter scale). The basic horizontal seismic coefficient for the zone 2 is 0.15.

However, no major earthquake has been reported in the proposed project site in the recent past. The project area is not located at the margin of any major plate or at the basin boundary. It is understood that seismic risk at the project site is moderate and would not pose a major constraint to the development of the project. The following exhibit shows the earthquakes and seismic risk zoning of Bangladesh.

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Figure 35 Earthquake zones & flood prone areas of Bangladesh

5 . 5 . 2 CY CL O N E S A N D S T ORMS Cyclones (Kal-Boishakhi) may occur at any time of the year but are most probable and severe around April - May and October – November.

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CHAPTER # 6 POTENTIAL POSITIVE AND ADVERSE ENVIRONMENTAL IMPACTS OF THE

PROJECT

6 . I D E N T I F I C A T I O N A N D E V A L I UA T I O N O F P O T E N T I A L I M P A C T S The process of identification of potential environmental impacts was initiated by identifying the development and operational activities resulting from the proposed project as presented in the earlier sections of the report. This chapter discusses the potential impacts on environment. As far as possible, attempts have been made to quantitatively predict the impacts due to the proposed project. For non-quantitative impacts, qualitative assessment has been done.

This section identifies and appraises the negative as well as positive impacts on various aspects of the environment likely to result from the proposed development. Potential significant environmental impacts from the development of the project have been identified with respect to the major activities to be carried out which include:

Land development Infrastructure development

Operational phase of the project

It is pertinent to mention that the negative environmental impacts listed below are based on the assumption that no negative impact mitigation measures or benefit enhancement are adopted.

Land

Environment

Water Environment

Air Environment

Noise Environment

Biological Environment

Socio-Economic Environment

The impacts of the above components have been further assessed during various phases of the project cycle namely pre-construction (planning and design), construction and operation.

6 . 1 P RE - CO N S T RU CT I O N S T A G E E N V I R O N M E N T A L I M P ACTS

6 . 1 . 1 N A T U RA L F L O W S T O P P E D D U E T O F I L L I N G O F W A T E R BODIES

As per the survey drawing, a canal is entering into the project site on west corner. The rain water and m onsoon season will flow only through this canal. As per the Master Plan, realignment of the canal along the western

boundary to the existing discharge point (river) has been suggested. Due to this, no flooding is expected within the proposed site or outside the project boundary. Also, the main river course has been retained in order to maintain the normal water flow during all the seasons. Therefore, the natural water flow is not expected to be restricted due

to the filling.

6 . 1 . 2 L O S S O F T RE ES The Sirajganj Economic Zone will require removal of 3638 trees of various sizes and about 20 species. The affected people have planted fruit bearing and timber trees beside their houses or on other high lands.

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Types of trees Large Middle Small Sapling

Fruit tree 564 480 150 299

Timber 221 524 108 552

Banana 420 400 100 20

Total 1205 1204 358 871

As per DoE requirement, any tree required to be cut will have to be compensated by provision of 3 saplings for each tree cut.

Figure 35 : Loss of trees 6 . 1 . 3 R I S K D U E T O E A RT H Q U AKE

The project area falls in zone 2, i.e. moderate seismic zones (Z= 0.15) as per the Bangladesh National Building Code (BNBC). Necessary seismic factors suggested by BNBC shall be incorporated suitably while designing the structures to safeguard against earthquake risks. 6 . 2 CO N S T RU CT I O N S T A G E E N V I O N M E N T A L I M P ACTS

Generally, construction impacts are expected to last for a relatively short time period and are expected to cease soon after the completion of construction. CONSTRUCTION IMPACTS ARE CONSIDERED TO BE MINIMAL as all the construction works will be carried out within the site boundary on the acquired land and will be controlled via the mitigation measures defined in this EIA. If the developer does not comply with the environmental specifications, serious long term environmental problems could emerge.

6 . 2 . 1 D I S RU P T I O N O F E A RT H S U RF ACE

According to the preliminary design, the estimated quantities of earth works requirements for 3 m The Consultants recommend that the developer will take fill material from the designated land and will be carried by trucks, The developer will be required to submit specific proposals for borrow sources to the Project Director (Sirajganj EZ) who will check the acceptability of each proposal with advice/assistance from the environment authority. The developer will be responsible for obtaining all other necessary approvals for the borrow works such as may be required from landowners, local Government agencies and Government Departments. It is preliminarily identified that this land can be procured from various areas near Jamuna. All fill material should be free from roots, sods or other deleterious materials. If all the earth material is brought from an authorized place, NO MAJOR IMPACT IS EXPECTED TO BE ASSOCIATED WITH THE DISRUPTION OF THE EARTH SURFACE. Guidelines of Borrow Area development and operation have been annexed to this report.

6 . 2 . 2 S O I L E RO S I O N A N D S I L T A T ION

Soil erosion and siltation of water bodies from clearing and grubbing, storage of filled material, stripping of road surfaces etc. can have a negative impact on the flow regime and water quality within the Jamuna River adjacent to the construction site. This could lead to negative impacts such as flow impairment and localized upstream or downstream flooding (arising from the overtopping of the river bank). However, these IMPACTS CAN BE CONTROLLED THROUGH GOOD CONSTRUCTION PRACTICES.

6 . 2 . 3 S U RF A CE W A T E R A N D G R O U N D W A T E R P O L L U TION

Loose stockpiles of earth materials and bare top soil can be washed away into the water bodies during heavy rainfall events. During the construction phase, storm water runoff can carry large sediment loads which increase turbidity in the adjacent water bodies. This CAN BE AN IRREVERSIBLE IMPACT, if not mitigated properly. During construction, oil and grease and hazardous material should be managed properly in designated areas, and disposed of appropriately. These are, however, MINOR SHORT TERM, REVERSIBLE IMPACTS. The integrity of ground water quality must be maintained to ensure the long term yield of water suitable for potable supply.

6 . 2 . 4 T RA F F I C F L O W CO N G E S T I ON

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The transportation and use of heavy equipment and trucks would be required during construction. Trucks will transport construction materials and heavy equipment. This could directly impact traffic flow and aggravate accidental risk along the Dhaka-Sirajganj and village roads, especially at the entrance to the construction site. This can be a significant impact if not properly managed.

It is recommended that the construction impact mitigation plan of the developer quantify and forecast the impact on

the traffic volumes in Dhaka-Sirajganj road during the construction period. The plan should be approved by the Bangladesh Road Transport Authority.

6 . 2 . 5 A I R QU A L I TY During construction phase, SPM IS EXPECTED TO BE THE MAIN POLLUTANT ASSOCIATED WITH EARTHWORK activities and material handling.

SPM generation due to handling of earth and movement of vehicles would be another source of air pollution. It is, however, dependent on the moisture content of earth, and the same can be optimized by sprinkling water in requisite quantity. Impact on air quality is envisaged due to the emission of construction plant, machinery and transportation.

Due to the above mentioned emissions during construction, it is inferred that minor negative impact on ambient air quality within a few meters from the source and within the site would occur.

However, appropriate mitigation measures, in the form of good construction practices have been annexed to this report and the ESMF for the project would need to be followed in order to keep these impacts to a minimum.

6 . 2 . 6 N O I S E P O L L U T I ON

Noise at a construction site varies relative to the particular operation in progress. An operation can be divided into three consecutive phases:

Ground Clearing

Excavation and Foundation

Erection and Finishing

Construction activities are expected to produce noise levels at source in the range of 75-90 dB (A). It would be intermittent and decreasing with increasing distance. The impact of noise produced during the construction will, however, be limited to a distance of about 75 meters at which, the noise level of various equipment will come down below 55 dB(A). The CONSTRUCTION ACTIVIT IES WOULD THUS NOT HAVE A SIGNIFICANT IM PACT ON AMBIENT NOISE LEVELS, but the personnel operating the machines and the workers stationed close to the machines may get exposed to high levels of noise and therefore proper mitigation measures should be adopted to avoid any harmful consequences. 6 . 2 . 7 W A T E R RE S O U R CES Water requirement for the construction of the proposed EZ shall be met from tube wells within the premises of the EZ area. A large number of workers, depending upon the speed and type of construction, would be required during the peak period of the construction stage. Average estimated requirement of water for various construction activities would be about 180 kl every day.

The ground water condition is mainly influenced by soil cover, which controls the local vertical rainfall recharge. The infiltered water has to be stored in the interstitial spaces inside the sandy layer, which again depends on the primary porosity in sand. The thickness of the sand layer decides the total ground water storage while the open pore spaces controls the movement of water in the sub surface.

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The well inventory and hydrogeological studies in and around the study site indicate that the ground water potential of Sirajganj EZ is good. Ground water is present in shallow unconfined aquifers as well as deeper confined acquifers. The subsurface formations comprising semi- consolidated and unconsolidated alluvial sands form a multi-layered aquifer system which further contributes to the ground water sources of the study site. The occurrence and movement of ground water is mainly controlled by inter-granular pore spaces in the unconsolidated to moderately consolidated formations. The general study of the lithology of these areas reveals that there are alternating layers of sand and clay. At deeper horizons, there is occurrence of fine to medium grained sand and the thickness of the aquifer is also appreciable

The quality of surface water is acceptable and it is noted that the local villagers use the water from Jomuna River

for domestic purposes.

Groundwater is the major source of drinking water in the region and also an important source of irrigation water for the area. The study site is blessed with good surface and groundwater sources, as groundwater recharge is adequate enough due to the presence of sandy soil.

The proposed project site is on the South Eastern side of Dhaka and surrounded by areas with high arsenic contaminated groundwater aquifers. THERE IS A HIGH PROBABILIT Y OF THE PRESENCE OF ARSENIC CONTAMINATED GROUNDWATER AT SHALLOW DEPTH IN THE STUDY SITE.

Drinking water requirement during the construction period is expected to 100 lpcd (Liters per capita per day), which will be arranged by the developer. Requirement of water for water closets and urinals for the workers would be met from the tube well at site. Wastewater generation during construction is assessed to about 80 lpcd, which could cause water pollution, if not treated. NO SIGNIFICANT IMPACT ON THE QUALITY OF WATER RESOURCES IS ANTICIPATED due to disposal of treated wastewater. 6 . 2 . 8 S O L I D W A S T E D I S P O SAL Inorganic solid waste generated during the construction phase like waste concrete, and mortar, left over aggregate and debris etc. shall be recycled. Municipal waste from labour camps can lead to land pollution. Pollution risks may also arise from accidental leakage and spillage of oil or fuel, which may contaminate soil. The overall IMPACT OF WASTE DISPOSAL DURING CONSTRUCTION PHASE CAN BE SIGNIFICANT AND HENCE PROPER MIT IGATION MEASURES WOULD BE REQUIRED TO BE FOLLOWED. 6 . 2 . 9 BR I D G E S T R U CT URES Construction of bridge can have serious effects on the area particularly on its hydrology and drainage, leading to the risk of flooding. THEREFORE, THE DESIGN OF THE BRIDGE WILL HAVE TO TAKE INTO ACCOUNT ANY POSSIBLE MODIFICATION OR RIVER REGIM E BOTH UPSTREAM AND DOWNSTREAM AND M INIMIZE SUCH MODIFICATIONS AND CONSEQUENT IMPACTS. 6 . 2 . 1 0 F L O RA A N D F A U NA The clearing of vegetation will result in the modification or removal of existing habitats for fauna. No impact on or encroachment of nature reserves is anticipated, as the project area and its surroundings do not come under any notified natural reserve.

During the baseline study, some species were found in the project area that are designated as threatened animals by the IUCN. These include Siberian Duck, Ganges River Dolphin etc. 6 . 2 . 1 1 HI S T O R I CA L A N D CU L T U RA L M O N U M ENTS

NO HISTORICAL OR CULTURAL MONUMENTS WILL BE AFFECTED/ LOST due to the construction of the project. 6 . 3 O P E RA T I O N S T A G E E N V I RO N M E N T A L I M P ACTS

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Operational impacts continue during the life of the project after the completion of construction phase and these

impacts are relatively longer lasting and in some cases permanent. 6 . 3 . 1 A I R QU A L I TY

As part of the manufacturing processes of the multi-product industries shortlisted for the project, the following air emissions are to be generated from the manufacturing operations.

Dust emission from blending of raw cotton/spinning/weaving/knitting manufacturing process

Dust particle may be emitted from formulation and packing material of the pharmaceutical plant

VOC emission from dye and paint mixing

Exhaust emission from boiler

Diesel Generator

Emission due to Gas based Power Plant 6 . 3 . 2 D U ST Dust emissions would occur during natural fiber and synthetic staple processing and yarn manufacturing. Fiber (especially cotton) handling and storage are sources of dust, particularly within work areas. Invisible micro dust particles of fibers escape from the factory, which deteriorate the ambient air quality in terms of Suspended Particulate Matter (SPM). The pollution of atmosphere by SPM may have the following effects:

Increased dustiness of the area Retarding the growth of the vegetation Increased nuisance to the inhabitants Increased health hazards to the workers and inhabitants

However, the nature and extent of the effects depend on concentration of particulates and the length of exposure. 6 . 3 . 3 V O CS

Emissions of VOCs are related to the use of organic solvents in activities such as printing processes, fabric cleaning, and wool scouring (e, g. thermo fixation, drying and curing). Another source of emissions is the evaporation or thermal degradation of chemicals used. THIS CAN HAVE A SIGNIFICANT IMPACT AS WELL.

6 . 3 . 4 E X HA U S T G A S ES

Another source of air pollution is the exhaust from the boiler operation. Since the boiler will be operated by natural gas as fuel, limited air pollution is expected except some effects on the ambient air quality in terms of thermal pollution through stack effect of the boiler.

All the above IMPACTS WOULD BE CONTAINED WITHIN THE WORKING ENVIRONMENT within the plant area and would not affect the area outside the EZ, provided standard mitigation measures have been applied to control the potential environmental impacts.

Moreover, vehicular emissions will be the major source of air pollution from the Sirajganj EZ area. The

pollutants from vehicular emission would include SPM, RSPM, CO2, NOx and CO. However, AS MOST

OF THE VEHICLES WOULD BE USING CNG, POLLUTION FROM VEHICULAR SOURCES IS

EXPECTED TO BE LOW. It is recommended that the traffic within the EZ is phased as much as possible

to minimize traffic jams. The proposed master plan for the development of the EZ considers traffic

movement within the area and has been developed to minimize congestion. During the baseline survey, NO APPARENT PROBLEM WITH THE AIR QUALITY WAS NOTICED.

Satisfactory results were obtained which revealed that the ambient air quality (in terms of PM10,

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SPM, SO2, NOX) is within the acceptable levels as prescribed by the Department of Environment and internationally accepted guidelines

6 . 3 . 5 G A S - BA S E D P O W E R P L A NT

It is proposed to install combined cycle GAS BASED POWER PLANT of 54 MW capacity which is integrated by two or more thermodynamic cycles of energy to transform the feed energy more efficiently into work or power. Capacity of the power plant is arrived considering the power requirement as follows:

Electrical Demand Requir 39 MW (assuming with Unity Power Factor)

In the process mentioned above the following units are required for operation of the power plant with closed cooling water system. AN AREA OF 14.84 ACRES IS EARMARKED WITHIN THE SIRAJGANJ EZ BOUNDARY FOR POWER PLANT .

Compressor Gas turbine Steam

turbine

HRSG (Heat Recovery Steam Generator)

Condensation stage (exchanger and a tank)

Energy generator

6 . 3 . 6 N O I S E P O L L U T I ON

Major sources of noise pollution expected are:

Yarn processing (texturizing, twisting and

doubling) Woven fabric production Vehicular traffic

Generator sets during emergency

Gas Based Power Plant

From past experience, it is found that during yarn processing, maximum noise level generated from the

machines is about 99-105 dB(A)9. Therefore, high noise level, causing inconvenience and certain health impacts related to hearing impairment and other problems for the workers, are expected if no monitoring, mitigation and enforcement measures are in place. The respective agencies responsible for such noise generation are envisaged to be monitored by the proposed environmental and social cell at the site.

The modeling of impacts of noise from generators considering the worst case when all the sets are

running together indicated that the noise level at source would be about 75 dB (A)10. The impact in this case, without any attenuation at the receptor, is given in the following exhibit. As seen from the exhibit, noise during operation phase will be less than 55 dB (A) within a distance

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of 20 m from the source. It can be concluded that noise in the operation phase of the project would have moderate impact. To keep the noise within allowable limit will be the most challenging issue during operation period of the proposed power plant project. As per Engine specification, project will generate noise at a level of 101 dB (A) within 1 meter from aggregate source and 123 dB (A) from Gas exhaust source. Generated noise from Gas exhaust source shall be minimized at level of 75 dBA in 10 meter measured at the chimney escape by installing ‘Exhaust Gas Silencer’. EPC Developer must ensure allowable noise level at boundary wall through proper layout and setting design of machineries. 6 . 3 . 7 T RA F F I C F L O W / CO N G E S TION

Preliminary traffic flow estimated at the site is about 12,326 PCU/day. Operation of the proposed EZ and other establishments will result in an increase of traffic at the access and Dhaka-Sirajganj road. Therefore, there would be a CONSIDERABLE NEGATIVE IMPACT ON THE TRAFFIC MOVEMENT . Within the zone, the traffic estimations have been utilized to arrive at the road configuration required in terms of number of lanes to carry the traffic volume.

6 . 3 . 8 W A T E R P O L L U T I ON

In the Sirajganj EZ, only yarn and fabrics are water polluting units. Other industries are assumed to be only formulation (pharmaceutical), apparel making (leather and jute) etc. and not producing any effluents. Yarn and Fabrics, in general consume large volumes of water. Consequently, these plants discharge large quantities of effluents and these effluents normally exhibit polluting characteristics, unless treated appropriately. The production process of Composite textiles (Yarn and fabrics) is depicted in the exhibit below:

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Exhibit 48 Garment Process flow chart

Exhibit 36 Flow chart for composite textiles

6.3.8.1 PROCESS OF WASTEWATER Wastewater effluents are related to wet operations, which are integral to the textile manufacturing process. Process wastewater from textile manufacturing is typically alkaline and has high BOD (from 700 to 2000 mg/l) and COD loads. Pollutants in textile effluents include suspended solids, mineral oils and other organic compounds, including phenols from wet finishing processes (e.g. dyeing) and halogenated organics from solvents used in bleaching. Effluent streams from dyeing processes are typically hot and colored and may contain significant concentrations of heavy metals (e.g. chromium, copper, zinc, lead or nickel). In a COTTON TEXTILE DYEING/PRINTING INDUSTRY EFFLUENTS NORMALLY HAVE HIGH BOD5 AND SOLIDS CONCENTRATION. If it is a composite/integrated textile mill involving

various processes of desizing, scouring, bleaching, mercerizing and causticizing, dyeing and printing, about 50 % of the total waste water flow, about 20% of the total BOD, and about 15% of the total suspended solids would come from the dyeing process alone. For the printing process, corresponding figures are about 5%, 5% and 2.5% respectively.

No waterborne pollutants originate from the process of weaving since all the operations are mechanical processes requiring almost no water. Almost, all wastewater generation takes place during the finishing processes. The following exhibit presents the snapshot of the estimated effluent generation, from the yarn and fabric industry units in the Zone. Effluents may be generated from the following production steps:

Scouring: Fiber (especially wool) scouring involves the use of hot water and detergents to

remove soil, vegetable impurities, grease, and other contaminants from fibers. The scouring

effluent is strongly alkaline, and a significant portion of BOD5 and COD loads from textile

manufacturing arises from scouring processes.

Desizing: Desizing operations may generate effluents with significant concentrations of organic matters

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and solids. BOD5 and COD loads from desizing may be significant (35 to 50 percent of the total load), and COD concentrations up to 20,000 mg/L may be generated.

Bleaching: Common bleaching reagents include hydrogen peroxide, sodium

hypochlorite, sodium chlorite and sulfur dioxide. Wastewater let out from this process has high BOD, pH and temperature.

Mercerizing: Wastewater from this process is highly alkaline. Since this wastewater is normally reused after recovery of caustic soda there is no constant liquid let out from this process.

Dyeing: The process varies with the choice of dye, desired color and depth. Reactive dyeing solution consists of an alkaline solution of the dye. Reactive dyes also react with water in alkaline solution at elevated temperatures. Depending on the color and depth, generally 10 - 50 gm/liter of common salt and 5 - 20 gm/liter of soda ash is used in the dyeing process. Following the dyeing process the fabric is washed once with detergent and twice with plain water. Dyeing process effluents are characterized by relatively high BOD and COD value, the latter commonly above 5,000 mg/l. Salt concentration may range between 2,000 and 3,000 ppm

Printing: The wastewater coming out from this process is colored and contains high suspended solids and BOD5

Finishing: The quantity of WASTEWATER LET OUT FROM THIS PROCESS IS ABOUT 5 % OF TOTAL WASTEWATER. The untreated effluent if discharged into surface water bodies causes rapid depletion of the dissolved oxygen of the receiving streams. The condition is aggravated due to the settlement of Suspended Solids (SS) and subsequent decomposition of the deposited sludge in an anaerobic condition. The alkalinity and the toxic substances like sulphide and chromium affect aquatic life; and also interfere with the biological treatment process. The color often renders the water unfit to use for some industrial purposes. Only properly treated effluents may be discharged into any water body or even land; otherwise it may pose a threat to the water quality and aquatic life. Effluent from Dyeing & Finishing plants may contain heavy metals like Chromium, Copper, Cobalt etc. when mordant azo dyes are used in the process. The individual units within the EPZ are not expected to use any Azo dyes, so it is expected that the effluent will not contain any heavy metals.

Process Cooling Water: In addition to the process liquid waste, certain volumes of liquid wastes mainly comprising boiler wash water, boiler blow down, jacket water (cooling water) and other occasional releases are discharged from the individual plant. Generally, this wastewater does not contain any harmful or toxic elements and requires no special treatment. However, a routine monitoring will be required for effluents particularly for cooling water (temperature and pH) and for boiler blow down (concentration factor and pH) before discharging into the environment.

6.3.8.2 SEWAGE

The average DAILY SEWAGE GENERATION FROM THE PROJECT HAS BEEN ESTIMATED TO BE ABOUT

6570 M3

/DAY, which is proposed to be treated through the proposed Fluidized Aerobic Bio Reactor (FABR) or active sludge process based sewage treatment plant. The treated effluent from the sewage treatment plant will be

used for watering of plants and greenery, in addition to usages that do not involve manual contact with the water. No significant adverse impact due to this is anticipated.

6.3.8.3 POWER PLANT

The power plant is not expected to generate any process wastewater, particularly cooling water. Because the main power block is designed with Closed Cooling Water system. ‘Engine Jacket Water Cooling Circuit’ shall be

replaced when necessary.

6 . 3 . 9 S O L I D W A S TE Wastes specific to the textile industry include trials, edge trimmings, cuttings of fabrics, and yarns and sludge from process wastewater treatment containing mainly fibers and grease. Solid waste generated in textile industries should be effectively recycled or reused within the process.

It is estimated that about 69 TPD would be generated during the operation phase, which need to be

disposed off effectively.

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NO NEGATIVE IMPACTS ARE PREDICTED DUE TO SOLID WASTES DURING PLANT OPERATION since handling and disposal of solid wastes will be carried out in accordance with the solid waste management plan as detailed in the Engineering Design. 6 . 3 . 1 0 O D O UR Odour may be generated, particularly in the dyeing and other finishing processes, and use of oils, solvent vapors, formaldehyde, sulphur compounds etc.

It may also be a problem in the waste disposal area and the area surrounding it. Proper mitigation measures need to be designed to minimize the impact. 6 . 3 . 1 1 F L O O D I NG Flooding impacts relate to both flooding of the site by adjacent properties, and flooding of adjacent properties by the proposed development at the site.

Major portion of the site mainly constitutes low-lying areas due to the Jamuna River crossing the site from east. The entire site area is well below the Maximum Flood Level of 6.3 m. It is recommended to have the finished ground level of the EZ above the maximum flood level i.e. 7.3 m to ensure prevention of water logging/inundation at the site. Also, the river leg flowing through the site has been designed to be retained.

6.4 E V A L U A T I O N O F I M P ACTS Identification and evaluation of potential/significant impacts due to project location, site preparation, construction and operation of the Sirajganj EZ has been done using an ‘IM PACT ASSESSM ENT M AT RIX ’ for environmental impact assessment by identifying all stages of activities (construction to operation and maintenance phase) and assessing the potential impact of each operation upon individual environmental components.

The impact assessment matrix was developed to quantify the impacts and understand their significance in detail. Impacts have been rated across five parameters:

Scale of Impact (Rated on a scale from -3 to 3, with -3 being the most negative and 3 being

the most positive)

Probability (Rated on a scale from 0 to 4 with 0 being no probability and 4 being highly probable) Cumulative Impact (Rated on a scale from 1 to 3) Permanence (Rated on a scale from 1 to 3) Reversibility (Rated on a scale from 1 to 3)

It is to be noted that the identification as indicated in the ‘Matrix Rating’ relates to the significance level of impact, assuring that no negative impacts mitigation or beneficial enhancement are adopted.

Since the proposed EZ is expected to house predominantly textile (Yarn and fabrics manufacturing) industries, major environmental components that will be adversely affected by activities of the project are water quality and ambient noise conditions. Other industries are not producing any effluents or noise problems. The EZ has been planned in such a way as to consider these impacts and reduce them to a minimum. For waste disposal, a separate area has been identified where a CETP has been proposed to treat the untreated effluent to meet ‘zero discharge’ standards i.e. no treated/ non- treated water and solid waste generated from the CETP will be let out to areas/ environmental components surrounding the EPZ. It can be seen from the IMPACT MATRIX THAT T HREE PARAMETERS (SURFACE WATER, NOISE, AND ODOUR) REACH SCORES IN THE RANGE OF -72 TO -96 WHICH INDICATES MAJOR AND IRREVERSIBLE IMPACT

Also, NO CUMULATIVE IMPACT IS EXPECTED to be created, although there are a few industrial settlements in the nearby region.

During the CONSTRUCTION PHASE, THE MAJOR IMPACT IS ENVISAGED TO BE ON FAUNA is which cannot be reversed. Other major estimated impacts during construction are NOISE, AIR AND WATER POLLUTION that will need to be mitigated properly through good construction practices.

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CHAPTER # 7 ANALYSIS OF THE ALTERNATIVES

7 . 1 T HE N O B U I L D S CE N A RIO From a purely physical environmental point of view, the ‘do-nothing’ scenario is preferable to any project implementation, since it would avoid creation of any of the adverse impacts associated with the project. However, the potential socio-economic benefits to the nation would be foregone and industrial growth would be hampered.

It is, therefore, concluded that the ‘No build’ alternative is not acceptable, and the potential socio- economic benefits of implementation of such project far outweigh the adverse impacts, all of which can be controlled and minimized to an allowable level.

7 . 2 CO N S I D E RA T I O N O F A L T E RN A T IVES 7 . 2 . 1 A L T E RN A T I V E S I TE S

Due to land scarcity in the country, seeking an alternative site for establishing an industrial zone is quite difficult. Also, land acquisition is a lengthy and complex procedure under the existing Land Acquisition Law of Bangladesh. Not only that, the project conceptual development over alternative sites is quite difficult because delay in overall land acquisition process might create social conflicts and risks for the project.

This site has been selected by BEZA and it has done some initial planning for land acquisition and general layout planning. Part of this land is Government ‘khas’ land and the remaining needs to be acquired from public. As per the plot schedule provided by BEZA, the total amount of land to be acquired for the project is 1035.93 acres.

To avoid and minimize the impacts resulting from the activities of the project, Sirajganj Economic Zone project is expected to be designed to adopt appropriate technological design, improvements or adjustments, policy including good site operational practices and applicable ESMF etc.

The overall strategy shall follow the following sequence:

Impact avoidance & minimization

Adequate Compensation where impacts are unavoidable

Enhancement Measures – Employment benefit enhancement

measures proposed by consultant

7 . 2 . 2 S I T E A N A L YSIS

The proposed site was assessed based on industrial, locational and infrastructure dynamics in the region. The key aspects were as follows:

Industrial positioning: The success of an EZ depends on its acceptability by the

potential industries. Considering the same, we assessed the benefits/challenges that industries may perceive in locating at the proposed site.

Social considerations: The potential of site for industrial development was weighed vis- à-vis

the social impact of the same to develop a holistic perspective of the proposed development.

Infrastructure availability: Considering that infrastructure is one of the key requirements for industrial development, we assessed the infrastructure scenario in the region to identify the critical bottlenecks that could be potential hindrances for industrial development.

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The parameters highlighted above lay the foundation for assessing the potential for industrial development in the

Northern region. The constraints posed by the site conditions and the corresponding design aspects have been summarized in the following figure Figure 37 Summary of Site Constraints and Corresponding Design Aspects

7 . 2 . 3 S O C I O - E N V I RO N M E N T A L CO N S I D E RA T IONS The baseline study of the socio-environmental aspects with regards to the project site helped in identifying a set of

parameters that would require due consideration while planning the project. The following exhibit captures a snapshot of these parameters and the corresponding design aspects incorporated in the basic planning study

Further, the environmental quality standards envisaged to be adhered to by the on-site infrastructure, based on the

environmental study are summarized in Figure 38.

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Day Night Day Night Silent - - Silent 50 40 Residential 55 45 Residential 55 45 Commercial 70 70 Commercial 70 60 Industrial 70 70 Industrial 75 70

Parameter World Standards Bangladesh Standards Comment

Ambient Air Quality

Parameter WHO guidelines (µg/m3)

Parameter BD guidelines (µg/m3)

No diesel generation sets are envisaged to be established at the project site. Further, air quality monitoring is envisaged to be carried out by respective agencies responsible for operation of captive power generation units & other air polluting components etc.

Sulphur Dioxide 20 (24 hr mean) Nitrogen Oxides 40 (annual mean) Suspended 50 (24 hr mean) Particulate matter (SPM10)

Suspended 25 (24 hr mean) Particulate matter (SPM2.5)

Carbon Monoxide - Ozone 100 Lead 0.5

Sulphur Dioxide 365 (24 hour) 80 (Annual)

Nitrogen Oxides 100 (Annual) Suspended Particulate matter 150(24 hour) (SPM10) 50 (Annual)

Suspended Particulate matter 65(24 hour) (SPM2.5) 15 (Annual)

Carbon Monoxide 1000 (8 hour) Ozone - Lead 0.5

Ambient Noise Standards

Location WBG guidelines dB(A) Location BD guidelines dB(A) No ambient noise polluting project components are envisaged as a part of the site infrastructure. The respective agencies responsible for such noise generation are envisaged to be monitored by the proposed environmental monitoring agency at

the site

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Effluent Parameter WB Guidelines (mg/l) Parameter BD Guidelines (mg/l) The effluent treatment network and

pH 6-9 pH 6.5-9 system has been designed considering Suspended Solids 50 Suspended Solids 100 the applicable standards.

BOD5 30 BOD5 150 Total dissolved solids - Total dissolved solids 2100 Waste water flow - Waste water flow 100 l /kg of fabric processed Total Chromium 0.5 Total Chromium 2 Sulfide 1 Sulfide 2 Phenolic Compounds 0.5 Phenolic Compounds 5 Oil & Grease 10 Oil & Grease 10 Cobalt, Nickel, Copper 0.5 each Cobalt, Nickel, Copper -

Parameter World Standards Bangladesh Standards Comment

Potable Water Guidelines

Parameter WHO Guidelines (mg/l) Parameter BD Guidelines (mg/l) The water treatment infrastructure at the site has been designed considering the applicable standards.

Parameter WHO Guidelines (mg/l)

pH 6.5-8.5 TDS 500

BOD Nearly 0 Turbidity 5 NTU Fluoride 1.5

Nitrite 0.91 Sulphide 0 Ammonia 1.5 Chloride 250 Iron 0.3 Phosphorus - Arsenic 0

Parameter BD Guidelines (mg/l)

pH 6.5-8.5 TDS 1000 BOD 0.2 Turbidity 10 NTU Fluoride 1

Nitrite <1 Sulphide 0 Ammonia 0.5 Chloride 150-600 Iron 0.3-1 Phosphorus 0 Arsenic 0.05

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7.2.4 A L T E RN A T E P R O D U CT I O N T E C HN I QU E S F O R T E X T I L E D YING The focus here would be on assessing the main sources of pollution within the industry and suggesting mitigation measures. To assess the pollution within the industries, a cleaner production audit process will be carried out with the cooperation of the industries.

A Cleaner Production Audit is a management tool comprising a systematic, documented, periodic and objective review of a company’s processes, products and operations, designed to identify and provide information about opportunities to reduce environmental hazard, by reducing the use of hazardous substances in the product life cycle.

This would focus on the raw materials coming on to the premises, the processes to be undertaken and the materials (products, by-products and waste) that would leave each factory site. In addition water quality analysis would be undertaken in the effluent and in the different stages of production, to support the cleaner production audit process.

In order to reduce waste, many alternative production trials will be carried out to optimize the production processes. These will include improved housekeeping, training of factory staff, and optimization of dyeing conditions (changing dyeing parameters and introducing alternative inputs or processes).

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CHAPTER # 8 MITIGATION AND ENHANCEMENT MEASURES

8 . 1 M I T I G A T I O N M E A S U R ES

This chapter includes the principles, procedures and mitigation measures that are necessary for ensuring the most appropriate environmental mitigation and enhancement plans are applied during different stages of project implementation. To avoid and minimize the impacts resulting from the activities of the project, measures/management plans are based on appropriate technological design, improvements or adjustments, noise policy including good site operational practices etc.

The overall strategy has the following sequence:

IMPACT AVOIDANCE: Changing project location, design and construction methods to avoid impacts.

IMPACT MINIMIZATION: Where impacts cannot be avoided, implementing mitigation measures to reduce

the impact to acceptable levels.

COMPENSATION: Arranging compensation where impacts cannot be avoided or sufficiently mitigated.

ENHANCEMENT: Measures, which, at insignificant cost to the project, give appreciable social or

developmental benefits. The mitigation plan has been recommended to highlight the action procedures to avoid/minimize / control the impacts arising out of different project phases i.e. pre-construction, construction and operation. NO RESIDUAL

IMPACT OF THE PROPOSED MIT IGATION MEASURES IS ANTICIPATED

8 . 2 E N HA N CE M E N T M E A S URES

The total construction time frame envisaged for the project is 2 years for Phase 1 with commercial operations starting in the year 2015. During construction, the project will create some temporary job opportunities. However, the impact is expected to be of relatively short duration, being restricted locally to the construction period. Although labour recruitment is the affair of the construction Developer who has the right to determine the selection procedures, but priority could be given to hire local people/PAPs as far as possible.

The proposed Sirajganj EZ is expected to provide foreign exchange earnings by promoting traditional exports, provide jobs to alleviate unemployment or under employment problems in the country and assist in income creation, attract foreign direct investment (FDI) that would act as catalysts for domestic entrepreneurs to engage in production of textile goods and other products.

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Environmental Impact / Issue

Mitigation Measures Location/Source Time Frame Responsibility Implementation

Responsibility Supervision

Design and Planning Stage Loss of Trees As per ESMF Prior to land clearance Resettlement

Unit

External

Consultant

Loss of Water bodies- a. As per Master plan, the associate canal has realigned along the northern and western boundary to the existing river. The main river course also retained in order to maintain the normal flow of water during all the season.

b. Alternate water route would be proposed in the detailed engineering and design study phase for overcome affected water bodies being utilized transportation by the surrounding communities

Detailed Design Design Consultant

BEZA

Bridge Structure Design related issue: Provision of adequate waterway such that no afflux is created upstream after construction of bridge Provision of adequate vertical clearance for navigation

Control of possible bank erosion with proper

river training works Need of higher embankment for bridge approaches due to navigational requirements

Construction Stage

a.The hydraulic design will be considered 50 years design flood for Sirajganj, including bridge openings, to accommodate flash floods and catastrophic events, which typify the area. b.Scour protection will be provided where necessary. c. Make sure that the regime waterway width is not reduced, thus avoiding additional rise of water level upstream of bridge because of constricted water way (afflux creation) d.Hydraulic Model studies may be necessary

Detailed Design Design Consultant

BEZA BEZA

Land Clearance a. Any debris generated will be disposed of only at designated sites.

Construction site During Construction Developer ESC

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b. Adequate protection will be provided to prevent the dispersal of loose material.

Preservation of Top Soil The filling material will be brought by truck from designated land.


Transport of construction material to site

a. All vehicles delivering material to the site will be covered to avoid spillage of material

b. All haul roads will be kept clean and clear of all dust / mud or other extraneous material dropped by such vehicles

c. All vehicles used on site for this purpose will carry currently valid fitness certificates issued by the BRTA at all times and copies of the same should be submitted to the Project Director

d. All vehicles used on site for this purpose should comply with the pollution norms of ECR 1997.

Construction site

During Construction

Developer ESC

Storage of Construction Material On site

Stockpiles of all construction material will be at least 100m from watercourses along the expansion area.


Slope Protection All slope protection measures will be carried out as detailed in the engineering design with prior approval of the Project Director.


Erosion Control Measures Suitable erosion protection

measures will be carried out as detailed in the engineering design with prior approval of the Project Director.

Construction site

During Construction

Developer ESC

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Hot-mix Plants and Batching Plants All hot-mix plants and batching plants will comply with requirements of ECR emission control norms (Schedule –11, ECR).


Contamination of Soils by fuel and lubricants

a. Vehicle/ machinery and equipment operation, maintenance and refueling will be carried out in such a fashion that spillage of fuels and lubricants does not contaminate the ground

b. Fuel storage and refilling areas will be located at least 300 m from all cross drainage structures and water bodies or as directed by the site engineer.


Contamination from fuel and Lubricants

a. The work will be carried out in

such a manner that pollution of natural watercourses, ponds and tanks is avoided.

b. Vehicles, machinery & equipment maintenance and refueling will be done in a manner as specified to prevent pollution of water.

At Brick fields/Brick crushing yards

During Construction Developer ESC

Impacts of bricks material a) Give preference to local brickworks that have

DOE’s approval. (b) Procure bricks only from brick kiln using natural gas as fuel. (c) All bricks delivered to site to

At Brick fields/Brick crushing yards


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be accompanied by a certificate showing that the kiln concerned has not used fuel wood in their production. (d) Developer to use kerosene, gas or other non fuel wood materials for heating bitumen and for domestic purposes

Construction Camp (a) Sufficient measures will be taken in the construction camps, i.e. provision of garbage tanks and sanitary facilities. Waste in septic tanks will be cleared periodically. (b) Drinking water will meet

Environment Quality Standards. (c) Garbage will be collected in a tank and disposed of periodically. (d) Special attention will be paid to the sanitary condition of camps. (e) Location of temporary sanitation facilities must avoid settlements which are adjacent to the EPZ boundary.

All Construction Worker’s Camps including areas in immediate vicinity

During establishment, operation and dismantling of Camps

Developer ESC

Construction site During Construction Developer ESC Dust/Air Pollution a. Locating Hot Mix Plant/s

(HMP) away from habitat. Construction plants, equipment and vehicles

During Construction Developer/ Construction Firm

ESC

84




b. Locating Concrete batching plant (CBP) away from human habitation and water bodies.

c. Locating HMP and CBP in downwind direction (predominant) to the nearby settlement as far as possible

d. Adequate dust control devices for HMP and CBP

e. Carrying out routine maintenance and/ or replacement of dust control devices.

f. Carrying out regular maintenance of plant, equipment and vehicles

g. Maintaining adequate moisture in aggregates before loading and unloading to feeder bins of HMP to prevent dust emission.

h. Defining vehicle movement path inside plant site and maintaining the movement path for control of dust emission.

i. All tippers / dumpers carrying earth, sand or stone will be always fitted with tailboards to prevent spilling.

j. Materials will not be loaded to a level higher than the side and tail boards and will be covered

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with a clean tarpaulin in good condition. The tarpaulin will be properly secured.

Noise Pollution (a) All vehicles, equipment and machinery used for the project will comply with the relevant ECR norms and the relevant BRTA rules. (b) Using enclosure for all diesel generator sets. (c) Source control through proper maintenance of all equipment. (d) Use of properly designed engine enclosures and intake silencers. (e) Construction workers operating equipment that generates noise should be equipped with noise protection. It is recommended that workers operating equipment generating noise of ≥80 dB (A) continuously for 8 hours or more should use ear muffs. Workers experiencing prolonged noise level 70 -80 dB (A) should wear ear plugs.

Vehicles, Plant and machinery

During Construction

Developer ESC

Water Pollution a. Storage of construction material and excavated soil above high flood level.

b. Strictly avoiding cleaning/washing of construction vehicle in any water body.

Earthwork and marginal spillage of construction material causing temporary turbidity and suspended solids


86




c. Proper planning of site clearing and grubbing so as not to keep the cleared site before working for long duration

d. Providing temporary side drains, sedimentation basin, as necessary to avoid or minimize erosion and prevent sedimentation to receiving water bodies.

Ground Water Pollution (a) Providing septic tanks for treating sewage from toilets before discharging through soak pits.

(b) Locating soak pits at least 50 m from any ground water sources.

Human wastes and waste water at construction camp


Land Pollution (a) Collecting kitchen waste in

separate bins and disposing of in a pit at designated

areas.

(b) Collecting plastics in separate bins and

disposing as specified

Domestic solid waste and liquid waste generated at

workers’ Camp


Loss of Damage of Vegetation (a) All work will be carried out in such a fashion that the damage or disruption to the flora is minimal. Only the trees or shrubs that impinge directly on the permanent works or necessary temporary works will be removed with prior approval from the Site Engineer.

Site Clearance During Construction Developer ESC

87




Loss, Damage or Disruption to Fauna (a) All works are to be carried out in such a fashion that the damage and disruption to fauna is minimal. b) Construction workers will be instructed to protect natural resources and fauna, including wild animals and aquatic life. Hunting and unauthorized fishing would be prohibited

Throughout the construction site


Traffic Control and Safety The Developer will take all necessary measures for the safety of traffic during construction and provide, erect and maintain such barricades, including signs, markings, flags, lights and flagmen as may be required by the Engineer for the information and protection of traffic approaching or passing through the section of the EPZ area under improvement.

All along the EZ area During Construction Developer ESC

Occupational health and safety of worker

(a) Water supply, sanitation, drainage and medical health facilities at campsite.

(b) Providing and using PPEs (c) Using working reverse horn for all construction equipment and construction vehicles i.e. tippers, dumpers, roller, etc. (d) Providing earth link circuit breaker (ELCB) for all electrical connections. (e) Maintaining first aid at construction sites.

Construction camp and work site


88




(f) Maintaining emergency response system.

(g) Conducting induction and periodic training for all workers

and supervisors. e) Conducting periodic training for all personnel working at plant site.

Bridge Construction

Disruption of Navigation and Water Transport

(a)To avoid the navigational disruption and accidental risk, adequate navigation lights, and markings are to be provided in the navigation route and adequate navigational clearance should be allowed in the design of bridge

Degradation of Water Quality if bentonite mud is allowed to enter water course

(a)Developer will made provision for disposal of bentonite enriched material from site in an appropriate manner and in accordance with the regulations of the appropriate regulatory authorities.


Construction of circular cofferdam for the foundation of bridge is an issue of

(a) The work shall be scheduled and planned to avoid creating


89




major concerns as it may block the waterway creating obstruction to free movement of aquaculture including migratory fish

obstruction and disturbance to migration and spawning of fish

Noise from pile driving ESC (a) Piles will be designed as cast in place


Impact on aquatic ecosystem (a) Mitigation measures will include appropriate engineering design to minimize increases in suspended solids. This is particularly important during the Feb.-March and August to October fish migration periods.


Post Construction/Operation Stage


Bridge Structure of BEZA Hydrology and Flood Pattern

a. Adequate waterway opening shall be provided in the design of bridge and approach roads for defusing impacts on regional hydrology

(b) Proper maintenance and monitoring of bridges/ culverts are to be ensured during post construction


Industrial Effluent (a) Effluent from individual industry should be collected and transported through concealed pipes to CETP which will ensure zero discharge treated effluent by way of recycling

(b) No treated/non treated water and solid waste generated from the CETP should be let

Individual Plant Throughout Operation stage

Developer ESC

90




out to land/drain/existing water sources or discharged to other areas (Refer: Basic

Planning Study –Sirajganj EZ (c) The Design Consultant should include the main mitigation measures in the treatment process, to ensure that effluent standards meet National/ international standards

Air Pollution (a) Suitable dust collectors (bag filters)

will be provided at all major emission sources. Use of masks should be made compulsory for the workers. (b) Gas based generator will be used (c) Boiler/generator will be regularly inspected to ensure that they are operating efficiently and emission standards are met (d) For well dispersion of the hot air from boiler stack, it is recommended that the height of the stack chimney should be at least 15.0 m (e) Installing and modifying equipment to reduce solvent use (f) Adopting water based methods for removing oil and grease from fabric instead of using volatile solvents

Noise Pollution (a) The workers and employees working at the factory premises should use ear plugs and ear muffs for protection against the noise

Individual Plant Throughout stage Operation Unit

ESC

91




(b) The individual plant should carryout regular maintenance of the equipment to minimize the noise level

(c) Using enclosure for all generator sets

Traffic Control and Safety

(a) Traffic management plan will be implemented (b) Traffic control measures to be enforced strictly.

All along the Sirajganj EZ

area and surrounding

Throughout Stage

ESC Supervision Consultant

Domestic Sewage Discharge

a. Suitable STP with tertiary treatment will be established and treated waste water will be used as non potable water.

b. The Design Consultant should include the main mitigation measures in the treatment process, to ensure that effluent standards meet National/international standards.

c. Location of STP should avoid settlements which are adjacent to the boundary.

STP Throughout stage

ESC

Supervision Consultant

Drinking Water (a) Water Treatment System selected will ensure that the quality of water is within the drinking water standards.

WTP Operation Throughout stage ESC Supervision


Solid waste Management

(a) Elaborate Solid Waste collection/ management mechanism will be implemented

(b) Biocomposting facility, sanitary land filling will be implemented within the MEPZ area . c) Observe good housekeeping and periodic maintenance

MSW, Industrial Waste (Hazardous/Non Hazardous)

Throughout Operation Stage


Odour a.Installing and modifying equipment to Individual plant (Dyeing and Throughout Operation ESC Supervision

92




reduce use of odorous chemicals (b) Routing of stack emissions through boilers to reduce odour emissions

Finishing process)

Stage

Consultant

ETP The designers should have included the main mitigation measures in the treatment process (CETP, STP, Sanitary landfill) to ensure that odour standards meet National/ international standards

Sludge of CETP, STP and Sanitary landfill area

Throughout Operation Stage


Figure : 39 Mitigation Measures

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CHAPTER # 9 ENVIRONMENTAL MANAGEMENT PLAN ( EMP) OF THIS PROJECT

9.1 O BJ E CT I V E

The Environmental Management Plan (EMP) aims to ensure the compliance of all activities undertaken during the implementation and the operation of the Sirajganj EZ with the environmental safeguard requirements of the World Bank and Government of Bangladesh. Furthermore, it aims at integrating the environmental components of the project with existing initiatives and programs in these fields. The plan consists of mitigation, monitoring and institutional measures to be taken during implementation and operation to eliminate adverse environmental impacts, offset them, or reduce them to acceptable levels. The plan also includes the actions needed to implement these measures. The EMP is based on five major principles:

The POLLUTER PAYS for pollution and prevention of pollution.

The DEPARTMENT OF ENVIRONMENT (DOE) IS TO PLAY A CENTRAL

ROLE in the environmental safeguarding of the project - regulation, supervision and enforcement.

Environmental SAFEGUARDS TO BE INCORPORATED FROM THE INCEPTION of all activities.

PRIVATE SECTOR DEVELOPMENT FOR EXECUTION AND IMPLEMENTATION of environmental safeguard related activities.

All activities undertaken within the framework of the PSDSP or subsequent developments are to be reviewed for their environmental impacts, and, when required, they need to be included in relevant EFFECTIVE ENVIRONMENTAL MANAGEMENT PLANS aimed at off-setting, preventing, or mitigating any such negative impacts. Satisfying the environmental safeguard requirements is a condition for the proposed activities to be implemented.

9 . 2 E N V I RO N M E N T A L M A N A G E M E N T M E A S U RE S PROPOSED

Exhibit 54 summarizes the potential impacts which are to be controlled, the mitigation measures which are to be adopted, and the indicated time frame for implementation and responsibility for ensuring the management plans are efficiently implemented.

9 . 3 S P E CI F I C M A N A G E M E N T PLAN Certain important and specific management plans with their respective action procedures for carrying out the overall

EMP effectively are enumerated as follows

9 . 3 . 1 S T O RM W A T E R M A N A G E M E N T P LAN The proposed drainage system is designed to cater to the surface runoff within the project area by gravity flow. Drainage system is designed in order to meet the stream invert level at the corresponding location. The different types of drainage systems are:

Open drain with brick wall - trapezoidal, rectangular, semi-circular

Open drain with RCC wall - rectangular, semi-circular

Closed drain with RCC wall - rectangular Closed rectangular drains are adopted for the surface run off collection for easy maintenance and land optimization. The entire zone area is designed to be covered under this collection system. Drainage system is designed on both sides of the road. Foot path is planned on top of the drain slab. RCC box culverts of suitable sizes are designed for road crossings. Rainwater harvesting structures are envisaged along the drain.

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The storm network with discharge point is shown in the exhibit below.

9. 3 . 2 W A S T E W A T E R M A N A G E M E N T P L A N

9.3.2.1 SEWAGE T REATMENT SYSTEM

The objective of the sewerage & sullage treatment system is to cater to the anticipated peak discharge requirements and to treat the waste as per the required discharge standards. Although grey water (sullage) is potentially different from the sewage and requires different treatment system if it is to be used in an optimal manner, the sullage quantity estimated at the project site is insignificant. In light of this, it is recommended that sewage and sullage be treated together at the Sirajganj EZ STP (sewage treatment plant) facility. Based on the estimation of sewage generation at the project site, this section concentrates on the qualitative aspects of the sewage treatment system and alternatives recommended for the same.

The total capacity of the sewage treatment plant is 6.57 MLD of sewage per day. 9.3.2.2 SEWAGE COLLECT ION NE T WORK DESIGN

The design criteria considered for the design of the sewage treatment system are summarized in the following figure.

Demand 6.57

Working hours per day 24

Pipe material NP2 RCC for all areas except road crossing

NP3 RCC for road crossing

Pipe roughness coefficient 140

Peak Flow Factor 2.00 for contributory population up to 50,000

Formula used to calculate friction loss Hazen Williams

Infiltration 10%

Minimum self cleansing velocity 0.6 m/s Figure 40 Sewage Collection & Transport Network Design Criteria

The raw effluent characteristics taken for design basis are as follows:

Parameters Unit Value

Ph - 6.0-7.5

Suspended Solids mg/l 150

Biological Oxygen Demand mg/l 300

Chemical Oxygen Demand mg/l 900

Oil and Grease mg/l <50

Bacteriological Count mpn/ 100ml 107

-108

Figure 41 Raw Effluent Characteristics T reated effluent characteristics taken for setting objectives of design are given in the following exhibit below.


Ph - 6.0-7.5

Suspended Solids mg/l Less than or Equal to 20

Biological Oxygen Demand mg/l Less than or Equal to 20

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Chemical Oxygen Demand mg/l Less than or Equal to 100

Oil and Grease mg/l Tarces

Bacteriological Count mpn/ 100ml Less than 103

Figure 42 Treated Effluent Characteristics The treatment system for the proposed STP is as

follows:

Primary Treatment

Bar Screening: Large debris entering into the system prevented with a bar screen installed

Collection sump: The effluent from the bar screen chamber is let out into the

collection sump

Secondary Treatment

Fluidized Aerobic Bio Reactors (Phase I & II): The reactor is filled with high quality self-supporting cylindrical shaped poly-Propylene. Bacterial growth is generated by providing compressed air in the reactor and gets attached on the PP media to form fixed film. Here the BOD, COD, organic pollutants get digested easily

Clarifier (Phase I, II): T reated water and sludge gets separated

Tertiary System

Disinfection: Sodium Hypo Chlorite is dosed before filtration for disinfection

Dual media filtration: It is used as polishing unit for the removal of

suspended solids, color, odour, chlorine etc.

9.3.2.3 RECOMMENDED SEWAGE T R EATMENT PLANT

Since the sewage generated is of domestic nature and the cost of land is very high, fluidized aerobic bio reactor

system is considered as the primary and secondary treatment systems in order to optimize land usage at the site. It is also proposed that the tertiary treatment system consist of lagooning followed by filtration with chlorination for disinfection. Sludge handling system can consist of thickener and centrifuge. The thickened/ dried

sludge is recommended to be handled by the secured landfill/ composting facility.

9.3.2.4 EFFLUENT COLLECT ION AND T REAT M ENT SYSTEM

It is proposed to collect the industrial effluent from the polluting industry sub zones of the EZ through suitable effluent networks and discharge into one location within the earmarked area for common effluent treatment plant (CETP). The tentative quality of the raw effluent is given below based on the available data from the industry. It is expected that the treatment of the effluent shall meet “zero discharge” concept. The zero discharge concept means no treated / non treated water and solid waste generated from the CETP should be let out to land / drain / existing water sources or discharged to other areas. It is also envisaged that at least 85% recovery of the waste water for recycling usage for the process industry will be achieved. The tentative raw effluent and

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treated effluent characteristics are given below.

Parameters Influent

pH 10-11 Total Dissolved Solids (TDS), mg/l 6000-9000 Suspended Solids (SS), mg/l 150-300 Biochemical Oxygen Demand (BOD), mg/l 300-600 Chemical Oxygen Demand (COD), mg/l 1200-1700

Figure: 43 Raw Effluent Characteristics

The estimated quantity for yarn manufacturing industries is approx. 0.97 MLD and for fabric manufacturing industries is approx. 0.88 MLD. Central effluent treatment plants of appropriate capacities are therefore recommended for the corresponding industrial sub zones.

T reated effluent characteristics taken for setting objectives of design are given in the following

Figure.

Parameter Treatment

pH 7-7.5

Total Dissolved Solids (TDS), mg/l Less than 200

Suspended Solids (SS), mg/l Nil

Biochemical Oxygen Demand (BOD), mg/l Nil

Chemical Oxygen Demand (COD), mg/l Less than 10

Hardness, mg/l Less than 5

Turbidity, NTU Less Than 1

Oil & Grease, mg/l Nil Figure 44 Treated Effluent Characteristics

The design criteria considered for the design of the effluent collection network have been summarized in the following exhibit.

Demand 6.57

Working hours per day 24

Pipe material NP2 RCC for all areas except road crossing

NP3 RCC for road crossing

Pipe roughness coefficient 140

Peak Flow Factor 2.00 for contributory population up to 50,000

Formula used to calculate friction loss Hazen Williams

Infiltration 10%

Minimum self cleansing velocity 0.6 m/s Figure 45 Effluent Collection & Transport Network Design Criteria

9.3.2.5 T REAT M ENT AND RECYCL ING SCHEM E

The treatment scheme depends upon the raw water quality and also the technology provider. One of the treatment scheme followed in the textile industry is pre-treatment followed by membrane treatment process. The tertiary treated water is recommended be used as non- potable water. Excess treated water is planned to be disposed to the water body passing through the site, only after ensuring that the treated water meets the required norms.

Since the treatment scheme depends on the treatment technology, it is proposed that a suitable party is

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brought on board for design, detailing, fabrication, erection, testing, commissioning, operating and maintaining of effluent treatment system for obtaining the treated water effluent quality from the raw effluent quality with zero discharge concept.

9 . 3 . 3 S O L I D W A S T E M A N A G E M E N T PLAN

Solid waste management system at the Sirajganj EZ site has been recommended so as to reduce/recycle to the maximum extent and effectively manage/treat the solid waste at the site. The role of integrated solid waste management is to reduce the quantity of solid waste disposed of to land by recovering materials and energy from solid waste as depicted in Exhibit 63.

In order to maximize the utility of the solid waste management system, source segregation should be made mandatory and due care should be taken while planning the collection, transportation of waste within the EPZ area. Users should be asked to segregate their waste in the following categories and put in color coded bins

Bio-degradable waste

Non-biodegradable waste other than industrial / hazardous

Construction debris, street sweepings etc.

From the above, only bio-degradable waste & construction debris etc. can be treated with the integrated solid waste treatment facility.

The entire solid waste at the Zone is planned to be collected and disposed off to the composting plant and landfill site identified within the EZ. An area is earmarked for development of STP (sewage treatment plant), composting plant and secured landfill within the EZ to handle the solid waste generated by the zone operations. Since the non hazardous industrial waste and non biodegradable municipal waste are expected to be relatively limited, it is proposed to dispose both the non hazardous industrial waste and non biodegradable municipal waste in the secured landfill

Figure 46 Integrated Solid Waste Management Methodology

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9 . 3 . 4 T RA F F I C M A N A G E M E NT

Based on the traffic flow estimation carried out for the project site, the road design was developed. Further, in the detailed design phase, the following practical operational aspects of traffic management were considered:

Avoidance of direct intersection of major on site roads. For added safety;

Incorporation of adequate green buffer along the roads, to ensure effective

usage of the sidewalks by the employees of the zone.

It is also recommended that ingress / egress points be set back at least 30 m from the road junction. The Sirajganj EZ Authority should consider enforcing on street parking of containers and trailers along the major roads. All design elements relating to landscape and signage are coordinated to reinforce a sense of harmony for the Sirajganj EZ.

Large billboards for advertising should be discouraged. Reasonable dimensions for logo and / or company name signs range between 3.0 m to a maximum of 6.0 m in length. The EZ Authority should establish a colour scheme and a set of predetermined standard signage design guidelines, along with a set of street name signboards, which will set the pace for the Sirajganj EZ.

9 . 3 . 5 L A N D S CA P I N G / G RE E N E RY Extensive landscaping shall be one of the most important features of this EZ. A total of 100.35 acres of land is designated for green space which meets the minimum requirement of 10%. Essentially, the public open spaces within Sirajganj EZ are centered in the following locations:

Green landscaped zone at the entrance plaza

Green belts on the edge of the boundary

Green belts at selected pockets

Green belts around the water bodies

Green buffer all along the HT (high tension) power line

In order to create a high-quality built environment for people to work, in addition to the public parks and open spaces, guidelines are recommended to be developed to ensure that there is sufficient greenery within the individual factory plots in the respective industrial zone. Mandatory areas for landscaping and greenery within the factory plots, facing the road are proposed. In the exhibit below, we present the proposed Greenery of the Sirajganj Economic Zones area.

The greenbelt development/plantation in the Sirajganj EZ area will not only function as landscape features resulting in harmonizing and amalgamating the physical structures of proposed buildings with surrounding environment but will also acts as pollution sink/noise barrier. It will check soil erosion, make the ecosystem more diversified and functionally more stable, make the climate more conducive and restore balance. 9 . 3 . 6 O C CU P A T I O N A L HE A L T H & S A F E T Y M A N A G E M E N T PLAN

Sirajganj EZ Authority would be committed to protect the existing conditions of the surrounding environment, health, safety and hygiene of employees, workers, Developers, and sub- Developers within the project area during construction and operational phase on the basis of IFC/World Bank Guidelines as well as code of practices will also be in compliance with GOB guidelines/requirements.

These guidelines apply to intermittent, temporary and permanent places of work and activities undertaken by Developers’ workforce, suppliers’ people and employees of the Sirajganj EZ project.

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An Occupational Health, Safety and Hygiene Management Plan/ System shall be established, operated and maintained for overall project. It is the responsibility and duty of the employer to ensure healthy and safe working conditions. A fully transparent OHSMP is a powerful tool towards fulfilling the objectives. Meaningful participation by workers and employees is required for optimum results and these could be obtainable through efficient awareness building and training program among the workers and employees The initial system of assessment should include the needs for risk reduction and management related to HIV/AIDS at the place of work. The contents of the OHSMP manual is prepared from ILO-OHS 2001 and outlined in brief at below ;

1. Occupational Health, Safety and Hygiene Policy

Management’s supports and direction 2. Organizational Framework of the OHSMP (Safety Organization) Staffing of OHSMP

Operating procedures Training program on all topics of OHSMP System documentation

Communication 3. OHSMP Objectives

Realistic and achievable participation of all by supervision 4. Risk and Hazard Prevention

Prevention and control measures

Emergency preparedness/ awareness and response

Procurement (tools, equipment, services Developers, etc.)

5. Performance Monitoring, Investigation and Reporting Hazards and natural calamities prevention measures

Ambient working environment

Work related injuries, ill health, diseases and on-going incidents

On-going Medical and safety monitoring program for all workers and employees

6. Evaluation Feedback

Corrective measures

Action plan

In-line with the aforesaid salient features of management plan referred in IFC/WB guidelines, Sirajganj EZ Authority has prepared their Action Plan Manual on the above subject.

In fulfillment of Commitment on execution of this particular project and in response to EIA Study, Sirajganj EZ Authority will conduct its project activities in a manner so as to minimize environmental and human health and safety impacts and to provide project area free from recognized safety hazards and risk as far as practicable. In addition to cited action plan, provisions will be incorporated in the operation policy manual for protecting OHS, electric shock and hearing impairment to the workers/ employees, health and life insurance system to be introduced in contractual agreement as per procedure laid down in DOE’s Rules of GOB and WB.

In fact Sirajganj EZ Authority will comply with all applicable safety, health and environmental laws and regulation prescribed by Department of Environment (GOB) and IFC/World bank. The Authority will also monitor and assess performance in Health, safety and environmental protection from major impacts.

The EZ Authority will also impart training needed for human, environmental and physical resources and project protection.

The Authority always encourages timely communication of health, safety and environmental risks between employees/workers and their Developer.

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Subject matter statement within box-umbrella referred in Exhibit 65 reflects the expectation and requirement of all employees, workers and Developers of the proposed project and they adhere to the adopted principles/ guidelines of OHSMS compliance in their performance of their respective job responsibilities. 9 . 3 . 7 I N D U S T R I A L R I S K S A N D CO N T I N G E N CY PLAN Potential sources of risks and emergencies to be envisaged during the operation of the industries in the Sirajgain EZ are presented below. Risks Emergencies

Fire & Explosion

Emergency shutdown systems

Failure of key controls, of power sources or of services

Fire-fighting devices

Structural failures

Emergency evacuation procedures

Work site injuries

First aid equipment & personnel Specialist medical treatment

Spills and unplanned release of producer other materials

Systems and procedures for preventing, mitigating & monitoring environmental effects of emergency actions

Outbreaks of disease

Procedures for communicating with authorities relatives and other relevant parties

Impacts & collisions

Health risks from inhalation of dust and particulate matter

Noise, odour, dust and vibration

9 . 3 . 8 A P P RO P R I A T E C O N T I N G E N CY A N D E M E RG E N CY RE S P O N S E M E A S U RE S

The individual industrial concerns in the EZ should have the following:

Alarm systems (Flame arresters, smoke detectors);

Appropriate fire extinguishers (foam, water hydrants, dry chemical, sand, CO2 etc.);

Eye wash and showers, where appropriate; First aid equipment;

Emergency shutdown systems; Oil/chemical spill cleanup systems; Emergency evacuation procedures

A properly coordinated internal and external emergency

response teams;

A well maintained internal and external communication system;

Procedures for communicating with authorities relatives and other relevant parties;

Systems and procedures for mobilizing company equipment, facilities and personnel; Arrangements and procedures for mobilizing third party resources for

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emergency support.

For the Sirajganj EZ, it is imperative to have the following:

A well equipped clinic to be manned by doctor and nurses; An ambulance;

A fleet of firefighting equipment trucks including water hydrants, wheeled extinguishers and portable hand extinguishers;

Arrangements for training response teams and for testing the emergency systems

and procedures; Communications to other departments and agencies (Fire Brigade, local police

station etc.) with fire fighting and emergency response capabilities;

Strategic sitting of water hydrants

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CHAPTER # 10 ENVIRONMENTAL MONITORING AND INSTITUTIONAL DEVELOPMENT

10.1 M O N I T O R I N G P L A N

1 0 . 1 . 1 G E N E RA L F E A T U RES

Monitoring is a critical activity with respect to the implementation of the EMP for the Sirajganj EZ. The primary purpose of the monitoring plan is to ensure that the environmental objectives set during project preparation are consistently achieved during project implementation. The results of the monitoring plan will provide critical information to influence decision-making during the construction and operation stages. It is expected to provide information regarding the effectiveness of the mitigation and enhancement measures proposed within the EMP and suggest further actions that need to be taken to achieve the desired results. Monitoring would include:

Visual observations Selection of site specific environmental parameters;

Sampling and regular lab analysis of the above selected parameters.

The prime objectives of monitoring are:

To check whether mitigation and enhancement measures are actually being adopted, and are proving effective in practice.

To provide a method whereby impacts which were subjected to uncertainty at the time of preparation of the EMP, or which are unforeseen, can be identified and steps can be taken to adopt appropriate control measures.

To provide information on the actual nature and extent of key impacts and

the effectiveness of mitigation and enhancement measures used on the

project To satisfy legal, safeguard and community obligations.

10.1.1.1 C O M P O N E N T S TO BE M ONITORED

Monitoring has the following two components:

COMPLIANCE MONITORING, which checks whether prescribed actions have been carried out, usually by visual observation and by the use of checklists.

MONITORING OF EFFECT S, which records the beneficial and adverse consequences of activities on the biophysical environment. This is often by repeat measurements of a set of objectively verifiable indicators.

10.1.1.1.1 PRE-CONSTRUCTION STAGE C OMPLIANCE M ONITORING Compliance monitoring during the pre-construction stage has three components:

Checking that the project’s design incorporates appropriate measures to avoid or minimize negative impacts

Incorporation of appropriate protective clauses in the contract documents that are to be followed by the Developer

10.1.1.1.2 CONSTRUCTION STAGE COMPLIAN CE M ONITORING

Compliance monitoring during the construction stage comprises:

Developer’s compliance to the environmental clauses in their day-to-day activities.

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Implementation of site clearance activities after completion of work.

The environmental impacts during construction are highly dependent on:

INCORPORATION OF MIT IGATING MEASURES identified in the EMP into bid documents and specifications

The Developer’s WORK PRACTICES, especially those related to the storage of construction materials and cleanliness of the work sites;

CO-OPERATION BY THE LOCAL AUTHORITIES with the Developer in terms of traffic management and use of public space and utilities; and

Project management teams’ strict enforcement of the CORRECT CONSTRUCTION

PRACTICES and standards;

Direct monitoring during the construction phase will involve the following activities:

REVIEW OF DEVELOPER’S PROPOSED DESIGNS and working methods including a review at project start-up to ensure that the designs and working methods proposed by the Developers have taken account of the environmental constraints specified in the tender documents (geotechnical, ecological, safety etc).

SITE- SPECIFIC REVIEW OF DEVELOPER’S TEMPORARY FACILIT IES; involving the inspection of Developer’s worksites and work camps to ensure that the Developer’s arrangements regarding temporary facilities are satisfactory.

REGULAR SITE INSPECT ION during the construction period, involving scheduled and unannounced inspections to ensure that the stipulated procedures as defined in the ESMF and this EMP are being followed by the Developer(s). This monitoring will require the completion of systematic observations of site activities using checklists to be developed by Sirajganj EZ authority or the supervising consultants.

INSPECTION OF THE CERTIFICATE OF SITE CLEARANCE and restoration, to ensure that actual restoration has taken place, e.g., the temporary works have been adequately & appropriately disposed of etc.

The above monitoring system will be fully controlled by the EZ Authority.

10.1.1.1.3 OPERATION STAGE COMP LIANCE MONITORING

Operation compliance monitoring involves following

activities:

Periodic monitoring and checking of the environmental parameters within the EZ

Inspection of the individual units to check whether the units follow the prescribed environmental norms or not.

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1 0 . 2 I N S T I T U T I O N A L A RR A N G E M E NT

The implementation of the ESMP will be done by the project Developer in case of the project being

developed by a SPV. Otherwise, the present BEZA structure with an additional Environmental and Social

Cell and Resettlement Unit is recommended. The organization structure for both the above

alternatives is shown in the exhibit below ;

Figure 47 : EMP Implementation and Organization Structure

The following key entities will be involved in the EMP implementation:

Project Director/GM(Sirajganj EZ)

Environmental and Social Cell (ESC)

Resettlement Unit

The Supervision Consultant

Developer

BEZA/DEVELOPER

Environmental & Social Cell

Project Director /GM

Sirajganj EZ


Developer Resettlement Unit

Resettlement Specialist Environmental

Specialist

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1 0 . 2 . 1 RO L E S A N D RE S P O N S I BI L I T IES

The Project Director of the Sirajganj EZ with the assistance of ESC will be responsible for ensuring overall compliance of safeguard measures and will be reporting to the regulatory bodies and donor agencies certifying that relevant environmental safeguard measures have been complied with during the project implementation. The Project director will undertake implementation of the environment measures and will conduct a periodic self-audit. The roles of others involved in the implementation of the EMP will be as follows:

10.2.1.1 E N VI R O NM E N T AND SOCIA L CELL

The ESC of will be responsible for effective monitoring of the EMP. For this purpose, provisions have been made in the ESMF towards training for the capacity building of ESC staff. Its primary objectives would be as follows:

Ensuring implementation of the EMP throughout the project implementation period

Ensuring integration of the EMP into the project design and implementation plans through bid documents

Monitoring implementation of the mitigation measures Assisting the construction engineers at site by providing appropriate environmental and social

compliance advice and solutions

Preparing training materials and implementing program in collaboration with the supervision consultant

Preparing regular periodic progress reports on the implementation of the EMP

throughout the project implementation period. Preparing budget and maintaining records of expenditure

Maintaining a log of public complaints and the action taken

Coordinating the process of environmental clearance for units

10.2.1.2 SUPERVISION CONSULTANT

The supervision consultant will be appointed by the EZ authority and will liaise with ESC to ensure that the Developer complies with the requirements of various environmental safeguard measures through supervision, monitoring and reporting on the same. Efforts must be made by the consultant to ensure that environmental mitigation and good-construction-practices are not only considered but actually implemented as integral component of each civil activity. Implementation of environmental safeguard measures needs team effort and the team leader will delegate the responsibilities to each member of the supervision team with respect to their core responsibilities. Besides, the team leader of the supervision consultant will nominate a senior level engineer for being directly responsible for implementation of stipulated safeguard measures, to establish accountability. He will provide guidance to the field staff of the consultant and Developer for implementing each of the activities as per the EMP. He will review Developer’s EMP, traffic management plan and safety plan. He will be responsible for record keeping, providing instructions through the Engineer for corrective actions, ensuring compliance of various statutory and legislative requirements and assist Engineer for submitting reports to ESC. He will maintain a close coordination with the Developer and ESC for successful implementation with the environmental safeguard measures. 10.2.1.3 DEVELOPER To ensure that the EMP is properly implemented, Developer is required to nominate a Senior Engineer / Manager as Environmental and Safety Officer (ESO) from the commencement to completion of the project. It is recommended that the personnel to be nominated as ESO should have experience on implementation of environmental and safety measures. The responsibilities of ESO will include the following:

Discussing various environmental issues and environmental mitigation, enhancement and

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monitoring actions with all concerned directly or indirectly

Preparing EMP, traffic management plan and safety plan as part of their work Program

Ensuring compliance with the EMP stipulations and conditions of statutory bodies Ensuring timely procurement of materials that are included in the Bill of Quantities relating to

environmental mitigation and enhancement measures

Conducting periodic environmental and safety training for site engineers, supervisors and workers

Preparing registers for material sources, labour, pollution monitoring results, public complaints and other issues

Preparing monthly reports on the status of implementation of safeguard measures

1 0 . 2 . 2 T RA I N I NG

The training program should equip the members of the Environment and Social Cell (ESC) and Resettlement Unit, who will be directly involved in the planning, design and implementation of the project, to understand and appreciate the ESMF requirements and to monitor the implementation of the project EMP.

It is recommended that an environmental orientation workshop is conducted. The purpose of this workshop can be to discuss the environmental impact aspects as stipulated in contract, and the data collection, implementation, best practices, supervision and reporting & MIS mechanisms. A follow-up training program should be conducted for reviewing the implementation status, constraints, shortcomings etc. and to improve implementation. It is also suggested that Developers are required to conduct routine training program for their own staff to ensure that environmental and safety measures are complied with. A workshop for the tenant units describing various environmental aspects is also recommended

1 0 . 2 . 3 E N V I RO N M E N T A L S P E CI F I CA T IO N S

Environmental specifications to be included in the technical specification of bid documents are annexed to the report (Annex 5). 1 0 . 2 . 4 M O N I T O R I N G P R O G R AM The monitoring program for the various performance indicators of project stage wise is shown in the following Figure.

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Environmental Aspect Monitoring Parameter Frequency Location Responsibility

Implementation Supervision

Pre Construction Stage

Fisheries Study to

establish baseline

Fish monitoring(5 km upstream and

downstream)

Fish Catch monitoring

(surrounding area)

Katha ((pen Culture) fishing

Fish landing center (fortnightly)

Captive fisheries (Cage culture and

aquaculture

Limnobiological monitoring

Once External

Consultant

ESC

Tree Removal Monitoring all prescribed mitigation measures in Mitigation Table

During tree removal and site clearance operations

Developer ESC

Construction Stage

Surface Water Quality pH, Turbidity, Temperature, DO, BOD5, COD, TSS, TDS, oils and greases

Drinking Water Quality pH, fecal coliforms, Fe, Chloride, Arsenic

Pre monsoon and Post monsoon Jamuna river and associate

canal passing adjacent to the SEZ area, bridge site

Pre monsoon and Post monsoon Tube well near construction camp

Developer ESC

Developer ESC

Air Quality SPM, SOx, NOx Pre monsoon and Post monsoon (8

hours continuous for two days)

Near Hot Mix Plant, near settlement area

Developer ESC

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Noise Level Measurement of noise dB(A) Quarterly (during day time) and whenever any complain is received about disturbance due to construction noise

Near residential area, institutional area and , silent zone within 1 km from the EPZ boundary, bridge site

Developer ESC

River Erosion and Site Inspection Continuously Jamuna river and Developer ESC

siltation associate canal passing

adjacent to the SEZ

area, bridge site

Navigation Site inspection During monsoon Bridge site Developer ESC

Hydrology and flood Site inspection during flood Weekly during flood Jamuna river and Developer ESC

pattern associate canal passing

adjacent to the SEZ

area, bridge site

Occupational health Check of personal protective Weekly Construction Site Developer ESC/DoE

equipment (PPE) for workers at

the sites

Operation Stage

Post Fisheries Monitoring

Check if Health, First-Aid facility, and staff trained in First Aid

are available at the sites Check if

medical checkup of

workers is on going Same indicators as done during pre- constructions

During first year External

Consultant

ESC

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Industrial Effluent pH, Color, DO, BOD5, COD, TDS, TSS, Oil & grease, heavy metals

Samples of effluent to be collected before it is entered into

Raw effluent and Treated Effluent


(chromium, copper, cobalt, nickel, CETP and after treatment

zinc, cadmium etc.)

Domestic Waste Water pH, Turbidity, Temperature, DO, Before and after treated water Raw Sewage and Treated ESC Supervision

BOD5, COD, TSS, TDS, Coliform (Quarterly) sewage Consultant count

Drinking Water Quality pH, fecal coliforms, Fe, Chloride, Monthly Treated water from WTP ESC Supervision

Arsenic Consultant

Noise Level Measurement of noise dB(A) Quarterly (24 hours) and Four corners of the site ESC Supervision

whenever any complain is boundary, at 200 m and Consultant received about disturbance due 300 m from the following

to noise level locations: (i) residential, (ii)

institutional (school,

mosque), (iii) silent (hospital) area

Air Quality SPM, SOx, NOx Quarterly (8 hours continuous for Boundary of the Generator, ESC Supervision

two days) and at 200 m and 300 m Consultant from the following locations: (i) residential, (ii)

institutional (school,

mosque), (iii) silent

(hospital) area

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Environmental Aspect Monitoring Parameter Frequency Location

Responsibility Implementation Supervision

Odour Sludge Annually and whenever any CETP and STP ESC Supervision complain is received about Consultant disturbance due to odour

problem

Land fill monitoring Landfill gas, Leachate, Odour Annually Landfill Site/Composting ESC Supervision

plant Consultant

Stack Emission SPM, SOx, NOx Annually (24 hrs average ) Boiler, Power Plant ESC Supervision

Consultant

Re-vegetation Program

(Green Belt) Select healthy sapling to confirm

survival rate

Quarterly As per Master Plan MEPZ Authority

ESC

Monitoring plantation procedure

Growth

Figure : 48 Monitoring Program during Project Cycle

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10.2.4.1 EFFECTS M ONITORING

The effects and results (beneficial/ adverse), arising out of the establishment of the EZ, should be monitored based on the parameters described in the ‘Monitoring and Evaluation Framework’ in the ESMF. Parameters across seven components, based on the sustainability framework, have been identified – these would help in efficient monitoring of impacts and results.

It is understood that the Department of Environment (DoE) is under-staffed and is therefore not able to monitor and strictly enforce the regulations. It is recommended that the supervision consultant appointed by the SIrajganj EZ Authority to supervise/monitor the work of ESC on all the environmental aspects as detailed in the EMP.

10.2.4.2 LABORATORY SUPPORT SERVICES

The EZ authority would require a well-equipped and on-site analytical laboratory with modern instruments. The laboratory shall be used for routine physical and chemical analysis of liquid effluents and potable water. The laboratory shall also observe gaseous pollutant discharge in connection with stack emission and air quality, noise level monitoring, quality and quantity measurement and regular analysis of solid waste.

The EZ authority would require a well-equipped and on-site analytical laboratory with modern instruments. The laboratory shall be used for routine physical and chemical analysis of liquid effluents and potable water. The laboratory shall also observe gaseous pollutant discharge in connection with stack emission and air quality, noise level monitoring and regular analysis of solid waste.

1 0 . 2 . 5 RE P O RT I N G S Y S T E M A N D RE CO RD K E E P I NG

The rationale for the reporting system is based on accountability to ensure that the measures proposed as part of the Environmental Management Plan get implemented in the project.

Reporting system for the suggested monitoring program operates at two levels:

1) Reporting for environmental condition indicators and environmental management indicators

2) Reporting for operational performance indicators at the Project Director/GM ( Sirajganj EZ)/ESC level

Monitoring involves regular checking of the environmental management issues detailed in the ESMF and in this EMP and to ascertain whether the mitigation measures are achieving their objectives with the progress of the works. It provides the necessary feedback for project management to keep the program on schedule will still achieving the expected outcomes.

The Developer, Supervision Consultant and Project Director/GM (Sirajganj EZ)/ESC will operate the reporting system for environmental conditions and environmental management indicators. The reporting system is presented Exhibit 69 to ensure timely and effective implementation of the ESMP.

This reporting will be as follows:

Reporting by the Developer to the SC

Reporting by the SC to ESC

Reporting by ESC for the information of all interested parties

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ITEM Developer ESC and RU Unit


Donor BEZA

Implementation Supervision Reporting to Project Director/ GM (EPZ)

Oversee Compliance Monitoring

Report to donor(s)

Desired Supervision

Construction Stage

Initial Site Observation of construction site and camp

Before the start of work

Regular Quarterly Quarterly Half yearly

Pollution Monitoring

As required As required Quarterly Quarterly After Monitoring

Half yearly

Tree Cutting Weekly Weekly Monthly Quarterly Half Yearly Yearly

Operation stage

Pollution Monitoring

As per monitoring program

After Monitoring

Twice during operation phase

Green Belt Program

Quarterly Half

Yearly

Yearly

Figure 49 Reporting System

Record keeping is an important management tool for ensuring sustainable operation of the proposed project. Records should be maintained for regulatory, monitoring and operational issues. Typical record keeping requirements for the proposed facility is summarized in the following exhibit

Parameter Particulars

Waste Water Daily quantity of treated sewage received Daily quantity of treated effluent disposed

Quantity and point of usage of treated wastewater Result sheet of Treated Wastewater quality

Solid Waste Handling and Disposal

Daily quantity of waste received Daily quantity of treated and recycled waste

Daily quantity of waste sent for landfill

Regulatory Licenses (Environmental)

Site Clearance and Environmental Clearance Certificate from DoE

Monitoring and Survey Records of all monitoring carried out as per the finalized monitoring protocol

Accident reporting Date and time of the accident Sequence of events leading to accident

Chemical datasheet assessing effect of accident on health and

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environment

Step to prevent recurrence of such events

Emergency measures teken

Figure 50 Typical Record Keeping Requirements

1 0 . 2 . 6 E N V I RO N M E N T A L A U D IT

To assess whether the implemented EMP is adequate or not, annual third party environmental audits will be conducted. These audits will be followed by corrective action plan to correct various issues identified during the audits.

1 0 . 3 I M P L E M E N T A T I O N S C HE D UL E A N D C O S T E S T I M ATES

1 0 . 3 . 1 I M P L E M E N T A T I O N S C HE D U L E

The Following are the key activities, which are to be performed at different phases of the project, as per the requirement of this EMP.

Obtaining site clearance from DoE and approved ToR for Environmental Impact Assessment (EIA)

study

Allocating budget for environmental management

Engaging construction supervision monitoring consultants

Nominating environmental and safety officer of Developer

Review and approval of Developers’ EMP, traffic management and safety plan Finalizing site/s and layout plan for construction camp incorporating environmental requirements

T ree removal

Implementation of mitigation and enhancement measures

Environmental Pollution Monitoring

T raining

Re-vegetation (Green Belt) Program The EMP implementation schedule, along with the responsibilities for each of the above- mentioned activities is annexed with the report.

It is also recommended that environmental safeguard measures may be included as an item for pre-bid meeting so that

Developers can raise queries on the same, if any

1 0 . 3 . 2 CO S T E S T I M A T ES

The budget for implementing various activities and mitigation measures proposed in this EMP has been estimated and the details are given in Exhibit 71. The total budget for implementing the EMP has been estimated as USD 0.42 million. This EMP budget will form part of the total project budget. The cost of environmental infrastructure implementation such as traffic management, water treatment, sewage treatment, solid waste management, development of green belt area are considered to be a part of the project itself and their costs have been included in the project cost. Cost of environmental protection works, which will be implemented by the Developer, shall be considered incidental to the corresponding item of civil work for which Bill of Quantities will be given in the bid document and no separate payment shall be made.

Sl No

Budget Head Unit Amount (Million Taka)

Reference to Overall Project Budget Head

1 ESC Operational Budget

a. Staff Salary

Part of the Sirajganj EZ establishment budget

b. Transportation Cost

2 Baseline Fisheries Study

a. Preconstruction LS 10 Part of the Study

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b. Post Construction (during first year)

LS 8

3 Environmental Auditing consultant Fees

LS 1.00 Part of the Technical Audit Consultancy Budget. Estimated budget considered two audit program (one for construction period and one for operation)

4 Environmental Mitigation / Enhancement

Not considered. Will be Part of the Project Cost, Civil BOQ item cost,

5 Environmental Laboratory Set up including equipment procurement for Monitoring (including heavy metal) (Laboratory consumables, maintenance, vehicles and running cost for 1 year, other machineries for longer term)

LS 10.00 Part of the Environmental management budget

6 Environmental and social T raining LS 2.00 Part of the overall TA / T raining budget

7 Stakeholder Consultation LS 1.00 Part of the overall TA

Total 32.00

Contingencies @ 10% 3.200

Total (in million Taka ) 35.20

Total ( in million USD ) 0.50

Figure 51 : EMP Budget

Currency Conversion rate: USD 1 = BDT 70 (Other environmental infrastructure costs have been considered separately)

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11 P UB LI C C O N SU LT A T I ON

Public Consultation is a tool for managing two-way communication between the project sponsor and the public. Its goal is to improve decision-making and build understanding by actively involving individuals, groups and organizations with a stake in the project. This involvement will increase a project’s long-term viability and enhance its benefits to locally affected people and other stakeholders.

As per the requirements of World Bank guidelines this consultation process is undertaken to seek opinions and suggestions from various stakeholders that will provide inputs required to designing, construction and other implementation related issues of Sirajganj EZ Project.

1 1 . 1 O BJ E CT I V ES

Engaging with stakeholders from the very initial stage – as a part of core business strategy – enables a proactive cultivation of relationships that can serve as “capital” during challenging times and to confirm long term cooperation. Key objectives of stakeholder consultation and participation at this stage of the project cycle and considering the community situation were limited to:

Rapport Building

Understand the stakeholders attitude towards SEZ Project as well as perception and concerns

Disseminate information about proposed project interventions

Collect qualitative information on present livelihood system, extent of project affect and their views, expectations and suggestions on livelihood restoration Identify impacts issues that not been considered Develop

mitigation and design enhancement measures. Establish an

information discloser channel Perceive ‘How communities expect Project authority in developing relationship and maintaining throughout the project life’.

Priority and objectives also varied according to the stakeholders’ interest/stake with the Sirajganj EZ Project. 1 1 . 2 I D E N T I F I CA T I O N O F S T A K E HO L DERS

Through a systematic process the following stakeholders have been identified for consultation. Public Sector

Board of Investment (BOI) Bangladesh Economic Zones Project Bangladesh Export Processing Zone Authority (BEPZA) Department of Environment(Department of Environment) Deputy Commissioner, Sirajganj Upazila Nirbahi Officer (UNO), Belkuchi and Sirajganj Sadar District LA office , Sirajganj Chairman and Word Members of Rajapur Union of Belkuchi Upazila Chairman and Word Members of Saidabad Union of Sirajganj Sadar Upazila Department of Fisheries Department of Agriculture Extension

Private Sector

Word Commissioners, former Union Chairman and word members of the study area Farmers, landowners, fishermen, Katha Fishing ground owner, and pond owner of the study area PAPs of Saidabad and Rajapur Union

Non-Government Organizations

Local and national active NGOs of the study area ( MMS & NDP)

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1 1 . 3 CO M M U N I T Y CO N C E R N S O N P RO J E CT I N T E RV E N T I ON

The following exhibit summarizes only the environmental concerns/issues of surrounding communities that were raised and discussed.

Issues Participants Discussion Use of surface water

Villagers of Rajapur and Saidabad UP

The canal at the southern side of Dhaka-Sirajganj Highway ( West site of Bangobondu Multipurpose Bridge) the proposed area is being used as source of drinking, bathing, washing water for people of Saidabad Union .

The people of Rajapur Union using Jamuna river fresh water as bathing, washing and agriculture. They requested to keep the canal undisturbed for their use, if it is disturbed, piped water supply facilities to be provided though they are living beyond the project boundary.

Noise

Affected people of the villages surrounding the project

During construction and operation of the project people will have to face noise pollution. The project will try to minimize the thing.

Proposed Gas Pipeline interception of the site

Village of Masumpur

During consultation, participants informed that authority of Porchimpnchall Gas company planed to construct a high pressure gas pipeline from Sirajganj to proposed site which shall intersect the site at north-east. Sirajganj EZ authority should take necessary action to revise the alignment of the proposed gas pipe line immediately.

Compensation for fish, pond and open water bodies.

Pond owners, Katha fishing and Cage fishing owners, boat men, fishermen, laborers

Ponds are on private land and Katha or Cage fishing practices are in the river. People take lease space in the river from the GoB for Katha or Cage fishing. The pond owner will get compensation for land, digging cost, fish stock etc. The Katha fishing and Cage fishing will be paid compensation for the existing fish stock and lump sum as business restoration grant. The boatmen and wage laborers associated with the Katha fishing will duly be paid grants as per policy of RAP. People demanded open water bodies to be kept undisturbed so that fishermen can earn their livelihood.

Figure 52 : Environmental concerns/issues of surrounding communities

1 1 . 4 F U T U RE C O N S U L T A T I O N A N D D I S CL O S U RE P L AN. To encourage participation, regular consultations are planned with beneficiary communities to share project related information and to provide a feedback mechanism for these communities to voice their concerns and issues in all stages of the Sirajganj EZ project. BEZA will be responsible to carry out continued consultation with and information dissemination to the key stakeholders.

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12 C O N C LU SI O N S A N D R E C O M M E N D A T I O NS

1 2 . 1 K E Y CO N CL U S I O NS

Sirajganj EZ is located west site of Bangobondu Multipurpose Bridge , with an approximately distance of 130 km from Dhaka and 10 km from Sirajganj. A land parcel spanning approximately 1035.94 acres has been identified by BEZA for development of an EZ in the northern part of Bangladesh. The identified site is adjacent to the Dhaka-Sirajganj highway, at the western end of Bangobondu Multipurpose Bridge.

This EIA report is a legal requirement for obtaining Environmental Clearance Certificate from the Department of Environment (DoE) for implementation of Sirajganj EZ. The information and data presented in this EIA are based upon the field visit Report and specific data obtained and gathered from relevant organizations/institutions, field survey and public consultation meetings in the study area in line with the Environmental Guidelines for Industries published by DoE of the GoB as well as the guidelines embodied in WB’s Environmental and Social Safeguards Policies.

On critical review of the potential environmental, the specific mitigation and monitoring measures proposed and the benefits described, the project is not expected to lead to any long term irreversible adverse impacts on the adjacent environmental quality and resources. The findings further suggest that major IECs adversely affected during implementation of proposed EPZ would be: loss of water bodies, trees, hydrology/drainage, back water effect, erosion, industrial effluent, pollutant emissions to air, noise / vibration etc. The potential negative and long term problem could arise if the new bridge is incorrectly sized leading to periodic catastrophic flooding and erosion. This could be avoided by USING HYDRAULIC MODEL during the design process.

INDUSTRIAL EFFLUENTS FROM INDIVIDUAL PROCESSING UNITS COULD BE A MAJOR SOURCE OF ADVERSE IMPACT associated with the operational phase of the proposed Sirajganj EZ. This may create long term and irreversible effect to a certain degree on the receiving environment, if no mitigation measures are adopted. It is recommended that all industrial effluents be collected and transported through concealed pipes to the CETP which will ensure zero discharge treated effluent by way of recycling. Traffic congestion is also expected to increase in the region. Therefore, construction of new roads and proper traffic channeling and monitoring would be required to ease the congestion. The proposed EZ is also expected to provide foreign exchange earnings by promoting traditional exports; provide jobs to alleviate unemployment or under employment problems in the country and assist in income creation, attract foreign direct investment (FDI) that would act as catalysts for domestic entrepreneurs to engage in production of textile goods and Multi Products.

Most of the potential impacts are expected to be short-term and minor in nature. Therefore, the anticipated adverse effects could be controlled/minimized or eliminated through adoption of suggested mitigation measures and implementation of the Environmental Management Plan during construction, operation and maintenance phases of the project.

Since the Project sponsor, namely BEZA, shows a positive approach towards environmental management and safety standards in-line with their environmental policy and management plan, it is expected that Sirajganj EZ will provide necessary resources to the proposed Environmental and Social Cell (ESC) such as proper technical personnel to make the ESC an accountable and responsible institution for successful implementation of the recommended EMP.

In the view of keeping surroundings of the project environmentally friendly, the Sirajganj EZ authority should ensure the practice of proper implementation of an Operation and Maintenance Manual together with an Environmental Pollution Abatement and Mitigation Measures Plan, regular and effective monitoring of environmental quality parameters as indicated in this EIA report. The amount of residual environmental damage due to the project would be directly related to how well the EZ authority meets its environmental responsibility, and how it uses the EMP and enforces the Developers’ compliance with the EMP and the monitoring program.

However, no development project could be expected without any adverse impact on environment aspects. The beneficial impacts on the nation as well as human beings would only be meaningful and the development would only be sustainable if the impacts are minimized through proper management and taking appropriate control measures as proposed and recommended for this project. All this would need extreme care and

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subsequent monetary involvement, and EZ authority should take these into consideration.

Finally, having reviewed all the potential environmental impacts and following the recommended mitigation measures as per this EIA, it is expected that the proposed EZ with operate within the internationally accepted environmental norms. 1 2 . 2 RE C O M M E N D A T I O NS

Based on the above study, the following recommendations are made:

The open water bodies should be kept intact so that fishermen can earn their livelihood from the river as they are doing now

In light of the loss of water bodies currently being used by the surrounding communities for water consumption, it is proposed that alternate source of water be developed by the BEZA outside the project boundary for this purpose

Detailed baseline fisheries study will be necessary to evaluate exact impact on fish and fisheries resources within and adjacent demarcated area

Mathematical and physical modeling study to be conducted at the Sirajganj EZ site to confirm the hydrological and flood impact during the detail design stage

Immediately after commencement of acquisition process, the EZ authority should apply to the Department of Environment for a SITE CLEARANCE CERTIFICATE by submitting IEE report and approval of ToR for EIA Study

BEZA to facilitate design, detailing, fabrication, erection, testing, commissioning, operating and maintaining of EFFLUENT TREATMENT SYSTEM for obtaining the treated water effluent qual ity from the raw effluent quality with zero discharge concept

Sirajganj EZ authority and DoE should MONITOR THE ENVIRONMENTAL COMPLIANCE of

EPZ on a regular basis and in accordance with the ESMF & ESMP

Textile and dyeing industries should ADOPT ENVIRONMENTALLY RESPONSIBLE PRODUCTION TECHNIQUES

It is also recommended that environment compliance issues are INCORPORATED UPFRONT INTO THE CONTRACTUAL DOCUMENTATION while issuing licenses to operate within the zone

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CHAPTER # 11

Social, Gender and

Resettlement Issues

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1.1.1 INTRODUCTION

Social and gender aspects and resettlement issues are crucial in the planning and implementation of any development project. On the one hand, EZs require land acquisition which will cause loss of property, homestead and livelihood sources and on the other hand they will provide significant opportunities for economic activities, commerce and trade. These are likely to have an impact on landownership, poverty issues, food security, economic status, social status and gender relations. The social and gender aspects and the resettlement issues presented here, cover the impact of the proposed EZ on the EZ itself and on adjacent areas. These are based on the current socio-economic scenario of the locality and take into account whether the proposed project is going to affect lives, livelihoods, structures, institutions, historic sites, ethnic and religious minority people and resettlement matters of the displaced population for the proposed EZ.

1.1.2 METHODOLOGY

Review of relevant documents and data including World Bank policies related to social, gender and

resettlement aspects and the Bangladesh Government Acts.

Meeting with concerned agencies.

Reconnaissance field visit.

Public consultation within the project area and adjacent areas. Preparation of the review report including secondary and primary data and incorporation of feedback.

1.1.3 SECONDARY DATA COLLECTION AND LITERATURE REVIEW

The literature review is carried out to identify the current socio-economic scenario of the EZ and adjacent areas and the Project Affected People (PAP). This will provide the basis in formulation of the RAP (Resettlement Action Plan). However during the feasibility stage, a further review will be conducted on social, economic and legal issues relevant to the project.

The following activities have been undertaken:

Data were collected from secondary sources comprising demographic composition, occupational status and

sources of livelihood, educational status, household structures, and access to basic physical facilities.

An assessment of all legislation including World Bank Polic ies and those of the Bangladesh

Government was done.

A list of social, cultural, religious and academic institutions and sites was done.

An information gap analysis and identification of the areas where further field work was done.

1.1.4 DONOR POLICIES AND ACTS AND REGULATIONS OF BANGLADESH GOVERNMENT

The World Bank's environmental and social safeguard policies: The World Bank's environmental and social safeguard policies were analyzed. These are a cornerstone of its support to sustainable poverty reduction. The objective of these policies is to prevent and mitigate undue harm to people and their environment in the development process. These policies provide guidelines for World Bank and borrower staff in the identification, preparation and implementation of programs and projects.

Safeguard policies have often provided a platform for the participation of stakeholders in project design and have been an important instrument for building ownership among local populations. The following policies and legislation were reviewed:

World Bank OP 4.12 Requirements for Involuntary resettlement

World Bank Gender Policy: OP 4.20 - Gender and Development (Revised March 2012)

Specific Funding Requirement of the World Bank Policy OP 4.10.

World Bank policy on Physical and Cultural resources: OP4.11

Bangladesh Government Acquisition and Requisition of Immovable Property Ordinance, 1982

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1.1.5 PUBLIC CONSULTATION IN PROJECT AREA AND ADJACENT AREAS

A participatory approach is an essential part of projects dealing with development in order to ensure sustainable development. Participation of local people and other stakeholders enables different socio- economic interest groups in enhancing their capabilities to play an effective role in development initiatives. It also ensures commitment and a sense of ownership of various stakeholders beyond local people and direct project beneficiaries. Government agencies, people’s representatives, professional groups and voluntary groups including NGOs and community-based organizations, could be actively engaged to share responsibility in key decisions. It also enriches project planners with local/indigenous knowledge.

1.1.6 FIELD VISIT TO THE SIRAJGANJ EZ

Meetings were held with the DC at the Sirajganj District and Bulkuchi and Sirajganj Sadar UNO and other government officials, Upazila chairman of Sirajganj Sadar , Belkuchi in Sirajganj Sadar UNO office.

Consultations were conducted with local people including homestead owners, private land owners, fishermen, shopkeepers and restaurant owners and workers, women, school going children and local small traders.

Table 4.2.2.3-1: Consultations at site

Date Stakeholders Location No of persons 2th July 2013 Interviews with the DC and

ADC and other government officials

Sirajganj District

4 Person

25th July 2013 Youth, students, fishermen, van pullers, shop owners

Rajapur UP 26 fishermen, 3 van pullers, 9 shop owners, 18 youth

29th July 2013 Affected households. Nakkata Government Primary School

17 homestead owners’ place, 18 children in the adjacent area, 2 women

11-14 February, 2014

Youth, students, fishermen,

van pullers, shop owners, Affected households.

Saydabad Union Several spot discussions with many locals and to be affected people in their homestead and shops 11-14 February,

2014 Survey on population

composition, HH, & shops structures, institutions, ponds, trees

Affected area by DC office

Whole area covered

15-20 May, 2014

Survey on population composition, HH, & shops structures, institutions, ponds, trees

Affected area by DC office

Whole area covered

1.1.7 BACKGROUND, GEOGRAPHIC AREA AND LOCATION

Sirajganj district was formerly a sub-division of Pabna zila. It was made full-fledged zila as a part of up-gradation programme of Sub-divisions to zilas. During the reign of Nawab Alivardi Khan Sirajganj became the commercial centre of Bengal. He flourished this commercial centre further for steady supply of papers to different parts of the country by transferring a group of highly skilled people in making hand-made papers (generally known as Tulat kagas) from central Asia to this place. Their descendants are still in Kalia and Kandpara mauzas adjacent to Sirajganj town. He also gave the name of this place as “Sirajganj” after the name of his beloved grandson Sirajuddowla, the last independent Nawab of Bengal.

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The zila is bounded on the notrth by Bogra zila, on the east by Tangail and Manikganj zilas, on the south by Manikganj and Pabna zilas and on the west by Natore and Bogra zilas. It lies between 24º01’ and 24º47’ north latitudes and between 89º15’ and 89º59’ east longitudes. The total area of the zila is 2,402.05 sq. km.

1.1.8 ANNUAL AVERAGE TEMPERATURE Maximum 34.6°C, minimum 11.9°C; annual rainfall 1610 mm.

1.1.9 MAIN RIVERS Jamuna, Baral, Ichamati, Karatoa and Phuljuri. About 10% area of the CHALAN BEEL is located in the TARASH upazila of this zila.

1.1.10 ARCHAEOLOGICAL HERITAGE AND RELICS

Tomb and mosque of Khawja Pir Saheb of Enayetpur (Chauhali), tomb of Hazrat Abdul Ali Baki Shah Shar if Jindani (R) of Naogaon (Tarash), homestead of Behula (Tarash), Shiva Mandir (Tarash), Rabindra Kuthi Bari (Shajadpur), Akhra of Sri Sri Maha Pravu, Gopinath Bigraha, Kalika Devi Bigraha, Joysagar (Raiganj), Protap Dighi (Raiganj), Elliot Bridge or Lohar Poll (iron bridge, built in 1893), Makkahaulia Mosque (fifteenth century, Ullahpara), Nabaratna Mandir (Ullahpara).

Historical Events: In 1922, many people were killed and wounded when police opened fire on an assemblage of people gathered at Salanga Hat (as a part of the Khelafat and non cooperation movement) under the leadership of Maulana Abdur Rashid Tarkabagish. This is known as Salanga Movement or 'Salanga Genocide'. In 1942 Mohammad Ali Jinnah came to Sirajganj to attend the All India Muslim League Conference; Mahatma Gandhi and Subas Basu came to Sirajganj to attend the convention of the Brahmo Samaj in 1928. The Hindu-Muslim Pact of the Swaraj Party, headed by Deshbandhu CHITTA RANJAN DAS, was adopted in the Conference of the All India Congress Party held in 1924 at Sirajganj. National Poet KAZI NAZRUL ISLAM came to Sirajganj in 1932 to preside over the Conference of the Tarun Muslim. AK FAZLUL HUQ laid the foundation stone of Sirajganj Degree College in 1940. During the War of Liberation a battle was fought between the freedom fighters and the Pak army at Naogaon of Tarash upazila in which the Pak army was defeated and about 150 members of the Pak army were killed. During 11 to 14 December a battle was fought between the Pak army and the freedom fighters at Shailabari in which Pak army was defeated. Sirajganj was liberated on 14 December 1971.

1.1.11 MAIN CROPS Paddy, jute, wheat, mustard seed, sugarcane, onion, garlic, potato, sweet potato, chilly and ground nut. Extinct or nearly extinct crops Indigo, tobacco, local varieties of aus paddy, china, kaun, varieties of dal (pulse).

1.1.12 MAIN FRUITS Mango, jackfruit, black berry, papaya, guava, coconut, palm, date, olive, bel, tetul and banana.

1.1.13 INFORMATION ON SIRAJGANJ AND THE EZ AREA

The following section provides the current socio-demographic and economic conditions of the people of the EZ area of Boyra Masum and Baro Beruakarua Mouza of Rajapur Union of Belkuchi Upazila and Khasbaroshimul, Chockboyra, Birhati, Saydabad and Ponchoshona Mouza of Saydabad Union of Sirajganjg Sadar Upazila

The EZ is a small part of the Boyra Masum and Baro Beruakarua Mouza , Khasbaroshimul, Chockboyra, Birhati, Saydabad and Ponchoshona Mouza and population density in this part is much less compared to the Mouza’s overall population. The EZ covers government land and part of the adjacent area Jamuna River. From the consultation with local people during the field visits, and the field survey it is found that 815 households (HH) will be affect and that the number of people living in the proposed EZ area is 4000 The survey covered a l l o f M o u za b u t some portion of these wards may not fall under the EZ as they live in fringe too, thus number of real affected households and people may be less. During the site visit, it appeared that they are among the most poverty stricken families, mostly fishermen or old aged people once were involved in agriculture in field and living in ‘kutcha’/ T in shed houses.

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Figure 4.2.3-1: Conceptual Diagram Showing EZ Location in Sirajganj District

The socio-demographic data in this section presents details of the EZ area to provide an idea of the locality and the people who will be effected by the proposed EZ.

Table 4.2.3-1: Land distribution of Sirajganj EZ

1. Existing land 1041.43 Acre 2. Private land 55.50 Acre 3. Public land 985.93 Acre

1.1.14 AT A GLANCE BELKUCHI UPAZILA BELKUCHI UPAZILA

CENSUS RESULTS AT A GLANCE Items Zila Upazila

2011 2001 2011 2001

Population (Enumerated)

Both Sex 30,97,489 26,93,814 3,52,835 3,02,678

Male 15,51,368 13,97,863 1,79,738 1,60,265

Female 15,46,121 12,95,951 1,73,097 1,42,413

Urban 3,76,432 2,29,106 75,364 0

Other Urban 60,145 92,147 0 20,328

Rural 26,60,912 23,72,561 2,77,471 2,82,350

Annual growth rate 1.38 1.76 1.52 2.13

Sex Ratio

Total 100 108 104 113

Urban 103 110 108 0

Other Urban 99 111 0 119

Rural 100 108 103 112

Households (HH)

Total 7,14,971 5,62,708 74,450 57,666

Urban 84,287 46,953 16,229 0

Sirajganj District

Belkuchi

Upazila Sirajganj

Sadar

Rajapur UP Saydabad

UP

Khasbaroshimul,

Chockboyra, Birhati,

Saydabad and

Ponchoshona Mouza

Boyra Masum and Baro

Beruakarua Mouza

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Other Urban 14,887 19,490 0 3,748

Rural 6,15,797 4,96,265 58,221 53,918

Average HH Size

Total 4.31 4.78 4.72 5.30

Urban 4.39 4.86 4.60 0

Other Urban 4.01 4.69 0.00 5.30

Rural 4.31 4.78 4.75 5.21

Area sq. km 2402.05 2497.92 158.87 164.29

Area sq. mile 927.43 964.45 61.34 63.43

Density per sq. km 1290 1842 2221 1842

Density per sq. mile 3340 4771 5752 4771

Urbanization (% ) 14.09 11.93 21.36 6.72

Literacy (%)

Both Sex 42.1 40.6 45.7 47.0

Male 45.1 45.5 48.2 51.5

Female 39.0 35.4 43.1 42.0

School Attendance (5 to 24 years) (%)

Both Sex 50.5 41.7 46.7 42.3

Male 53.5 45.1 47.5 43.2

Female 47.6 38.2 45.9 41.3

Population (Adjusted)

Both Sex 32,20,814 28,18,278 3,67,337 3,16,255

Male 16,13,173 14,62,455 1,87,137 1,67,452

Female 16,07,641 13,55,823 1,80,200 1,48,803

Geographic Unit

Upazila/Thana 9 9 - -

Union 82 79 6 6

Mauza 1,300 1,467 94 108

Village 2,016 2,024 131 143

Paurashava 6 4 1 0

Paura Ward 60 42 9 0

Paura Mahalla 160 117 14

Area and Location: The upazila occupies an area of 158.87 sq. km. It lies between 24°13' and 24°22' north latitudes and between 89°37' and 89°47' east longitudes. The upazila is bounded on the north by Kamarkanda upazila, on the east by Tangail Sadar and Kalihati upazilas of Tangail zila, on the south by Shahjadpur and Chowhali upazilas and on the west by Ullahpara and Kamarkhanda upazilas. 1.1.15 AT A GLANCE SIRAJGANJ SADAR UPAZILA Items Zila Upazila 2011 2001 2011 2001

Population (Enumerated) Both Sex 30,97,489 26,93,814 5,55,155 4,84,170

Male 15,51,368 13,97,863 2,79,113 2,53,050 Female 15,46,121 12,95,951 2,76,042 2,31,120

Urban 3,76,432 2,29,106 1,58,913 1,28,144 Other Urban 60,145 92,147 8,287 7,007

Rural 26,60,912 23,72,561 3,87,955 3,49,019 Annual growth rate 1.38 1.76 1.36 2.21 Sex Ratio

Total 100 108 101 109 Urban 103 110 102 109

Other Urban 99 111 105 113 Rural 100 108 101 109

Households (HH)

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Name of area Total

HH Total

population Village Mouza Bazar

Rajapur UP 6945 47596 33 5 2

Saydabad UP 7426 31460 37 05 2

Total 14371 79056 70 10 4

Total 7,14,971 5,62,708 1,25,485 99,769

Urban 84,287 46,953 35,556 26,525 Other Urban 14,887 19,490 1,886 1,423 Rural 6,15,797 4,96,265 88,043 71,821

Average HH Size Total 4.31 4.78 4.38 4.85

Urban 4.39 4.86 4.37 4.81 Other Urban 4.01 4.69 4.38 4.84

Rural 4.31 4.78 4.39 4.86 Area sq. km 2402.05 2497.92 320.15 325.78 Area sq. mile 927.43 964.45 123.61 125.78

Density per sq. km 1290 1842 1734 1486 Density per sq. mile 3340 4771 4491 3849

Urbanization (% ) 14.09 11.93 30.12 27.91 Literacy (%)

Both Sex 42.1 40.6 48.0 47.4 Male 45.1 45.5 50.1 51.0 Female 39.0 35.4 45.8 43.6

School Attendance (5 to 24 years) (%) Both Sex 50.5 41.7 54.3 41.6

Male 53.5 45.1 57.0 44.2 Female 47.6 38.2 51.7 38.9

Population (Adjusted) Both Sex 32,20,814 28,18,278 5,78,583 5,07,722

Male 16,13,173 14,62,455 2,90,897 2,65,355 Female 16,07,641 13,55,823 2,87,686 2,42,367 Geographic Unit

Upazila/Thana 9 9 - - Union 82 79 10 10

Mauza 1,300 1,467 187 217 Village 2,016 2,024 294 299

Paurashava 6 4 1 1 Paura Ward 60 42 15 15 Paura Mahalla 160 117 50 52

1.1.16 Total number of Household, population and structure of residence

1.1.17 TOTAL NUMBER OF INSTITUTIONS IN EZ AREAS

Institution type Educational Institutions Religious Institutions Social

Institute

Graveyard

Primary School

High school

Collage Madras a

Mosque s

Temple Church Pagoda

No 2 - - 1 2 1 2

1.1.18 TYPE OF OWNERSHIP OF LAND

(i) Water bodies, Baluchar (sandy islands): the major part of the water body belongs to the government and only a very small area of such land belongs is in private ownership

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(ii) All lands are compensated at double the current market price. Compensation for homesteads will be twice the current market price. Actual current market price of trees will be provided.

For livelihood loss, payment for sources of income and relocation costs will be provided

Due to the location of the Sirajganj EZ, the population of Sirajganj district will be benefit from the high number of industrial jobs created there

1.1.19 POPULATION OF RAJSHAHI DISTRICT AND DIVISION

Population in Sirajganj District: 7,616,352 (male-3,838,854, female-3,777,498) Population living in rural areas in Sirajganj : 4,463,723

Population in Rajshahi Division: 28,423,019 (Male: 1, 39, And 33,314, female: 14,489,705)

Population living in rural areas: 21,517,539

Due to the location of the Sirajganj EZ, the population of Sirajganj , Tangail, Pabna, Natore and Bogra districts will benefit from the high number of industrial jobs created there.

2.0 SOCIO-ECONOMIC BACKGROUND OF PROPOSED SITE

2.1 POPULATION DISTRIBUTION

For a better understanding of the Union and locality the following section provides information on Rajapur and Saydabad UP . In Rajapur of Belkuchi and Saydabad of Sirajganj Sadar Upazila, the total number of households is 14371 with a total population of 79056. Maximum number of people ara floating population in the proposed project area . The population density (per sq.km) in the Union is 2221.The following population composition and information on the households are based on the Union population.

2.2 POVERTY INFORMATION

There is no data directly indicating poverty in the latest Census. But the data on occupation, education and household types are presented to give an idea of the socio-economic condition of the locality. From these variables, the area seems impoverished and very few well-off families live in the proposed area. But in the Upazila there are several structures and buildings and institutions which are presented in the report.

2.3 THE NUMBER OF PEOPLE NOT ATTENDING SCHOOL

More than 20 % of the population aged 7 and above, which is not attending at school . Thus, employment of parents is expected to contribute to higher attendance of children, including girls, at schools and overall higher education for all.

2.4 EMPLOYMENT STATUS

There is a huge gap in male-female employment. In the job seeking category 93 are males and 44 are females. Most of the women are involved in household work.

2.5 WOM EN’ S EM POW ERM ENT

Since women are mostly in the household work category. Thus, employment opportunities for women

created by the proposed EZ, directly or indirectly, in Sirajganj is expected to provide them with a better socio-economic status and empowerment.

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2.6 OCCUPATION

Table 4.2.5-3: Field of Activity by the People Living in the EZ

Among the employed population, 474 males and 37 females work in agriculture. In fisheries 40 males and 23 females are employed. 37 males and 2 1 females work in the service sector. The employment status clearly shows that the majority are dependent on agriculture related activities. Fewer than 100 people are involved in industry, an insignificant percentage of the population.

During consultation with local people, it appears that as a whole, in terms of occupation, this is a predominantly fisheries based area.

2.7 HOUSEHOLD STRUCTURE

Most of the houses are kutcha (76.4%) followed by Jhupri/ straw-shed (16.3%). Only 3.2% are pucca and 4.1% semi-pucca.

2.8 SANITATION FACILITIES Sanitary water sealed toilets: 5.2%; Sanitary non water sealed toilets: 41.6%; non-sanitary toilets:

47%, no toilets: 6.1%.

The household pattern, sanitation facilities and behaviour show a grim picture of poverty in the proposed EZ area. The majority of the population (around 83%) live in kutcha and temporary straw- shed houses. People using sanitary toilets is only 5.2%. Due to the sea-side location, salinity is also a problem for pure drinking water.

2.9 TOTAL NUMBER OF STRUCTURES The socio-cultural institutions of Sirajganj Sadar and Belkuchi Upazila , Rajapur and Saydabd UP are presented below. Though the proposed EZ area is part of the Rajapur and Saydabd UP, not all of these institutions fall under the EZ proposed area, thus the number of affected institutions is less than these. Therefore, an inventory and population census is done in the area which is presented in earlier section.

a. Homestead: The number of total households in project area about 875, the total population is

4730. During consultation, we were informed that the proposed EZ area will be in the seaside area where the population concentration is very low and around 574 HH will fall under the EZ area. People living in these households will be affected and will need resettlement and compensation. The houses are scattered and mostly kutcha .

b. Business centres, bazaar, shops etc.: There are also a few shops and restaurants which are mostly small and

kutcha and tin-sheds. There are a few trees around the homestead and the roadside bust mostly small and newly planted. In the resettlement compensation package, all of these are included. Details of these are provided in the budget analysis section of this report.

c. Primary Schools: 2 d. Mosques: 2 e. Dakhil madrashas-1 f. Forkania madrashas-1

g. Health centres: None in project area k. Graveyards: 1 l. NGOs: MMS , NDP , Shushilan has micro-credit and awareness raising programs.

Although in the consultations during field visits, local people, mentioned no higher academic or social institutions within the EZ area, the UNO of Sirajganj Sadar and Belkuchi provided the list of institutions in Rajapur and Saydabd UP. If any academic or religious institutions fall under the EZ area, proper compensation and replacement cost will be provided after consultation of local authorities and local residents.

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2.11 OVERALL SOCIAL IMPACT

Regarding social indicators, the following are likely to have impact on the social lives of the local population due to EZ:

Table 4.2.8-1: Overall Social Impacts with Strategies for Mitigation

Issues Impact Strategies for Risk mitigation

Poverty Alleviation and Diversification in livelihood

Through industrialization and related trades, diversification of livelihood will occur for all strata of people. Diverse livelihood option for the locals and better wages for the employees of the industrial zone will reduce poverty for many poor households and will contribute to reducing the poverty level in the locality.

Skill training programs by relevant Government agencies and NGOs will be needed for efficient utilization of this huge manpower.

This EZ will have garments , spinning , and knitwear will create approximately 1,72,000 workers (374 workers per hectare).

Food security With increased income the families will be able to ensure food security for themselves. As current earnings are not enough for the small farmers and fishermen to ensure food security for their families or a standard livelihood, they prefer a better livelihood and secure earning options.

Better livelihood options and food security should be ensured for the 815 HH s who will be displaced and the most impoverished fishermen’s families. Preferences of the males and females of displaced HHs in job opportunities created by the EZ.

Issues Impact Strategies for Risk mitigation Awareness and accessibility regarding health:

Better access to health facilities and better communication and access to health services is expected. Housing patterns and WATSAN behaviour which is very poor at current stage are expected to be much better due to affordability of better housing, sanitary toilets and attitudinal change due to increased earning and industrial zone lead urban atmospheres.

Issue of health hazards caused by the EZ industries to be identified. If there is any, steps need to be taken to prevent and minimize such hazards.

Education for children including Girls’ Education

Due to the establishment of the EZ and better economic changes in the locality, the child education rate is likely to increase leading to a reduction in children’s informal or agriculture based labour.

During construction and until the EZ becomes operational, children’s safety needs to be ensured. Local community needs to be sensitized and NGOs can be engaged with them.

Access to civic amenities and communication

Civic life for the overall communities will be better due to the modern facilities and better communication. Industrialization will ensure better livelihood and increase ability to access better civic facilities. However, due to the EZ construction overall traffic may be congested over the years.

815 HHs will be displaced, compensation package should be ensured to be sufficient for a better livelihood and living.

Social mobility With improved employment opportunities and increased and secured income, impoverished people will be able to move up to the social ladder.

Special compensation package or priorities in job opportunities for the most impoverished needed so that they don’t become more vulnerable due to higher income level of others.

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Women’s empowerment

Women are mostly in household work category. Thus, employment opportunities for women created by the proposed EZ directly or indirectly are expected to provide them with better socio- economic status. Through employment; women will be empowered economically by being self- reliant and may become more socially aware. This could lead to their having more decision making power in their respective families and communities.

Measures should be taken to ensure women of the households who are losing livelihood opportunities do not face vulnerable situations of losing livelihood options of their HH head or themselves.

This will also encourage the parents to send their children to schools and withdraw them from wage earning activities. At the same time girl’s education due to parents’ better economic condition and awareness will prevent early and child marriage as girls’ education will automatically retain them in school increasing social awareness and reducing pressure marrying them off at an early age.

While dealing with land transfer and compensation, the gender issue should be taken care of sensibly as women in Bangladesh do not usually possess land in their names but in the male household members’ names. If cash compensation is given, it could be also in joint account transfer, so women are not deprived of any benefit and also do not bear the loss alone. With female headed households, a special package can be provided. Preferences of males and females in job opportunities created by the EZ.

At the macro-level, employment opportunities, social and economic commitment of development efforts and public-private partnership will be the outcomes of the project. More detailed consultation at the EZ site and adjacent areas may be needed to assess detailed socio- cultural effects.

2.12 RESETTLEMENT ISSUES AND PLAN

The policy objective conforms to that of the government, to reduce poverty and meet the Millennium Development Goals (MDGs). The basic policy is to avoid land acquisition as much as possible. The guiding principles are:

to minimize and mitigate adverse impacts;

to ensure compensation payment according to the World Bank OP 4.12 and GoB rules and regulations;

to establish a grievance redress mechanism with representatives from stakeholders to suggest institutional and monitoring arrangements for compensation payment.

2.13 PEOPLE LIKELY TO BE AFFECTED

The people who will be removed from their homesteads will have to be provided with financial compensation as there is no government fallen/khas land available near the site or in the Upazila. It is not possible to accommodate these people within the EZ site due to shortage of land.

All lands are compensated by double price of current market price. Compensation for homesteads will be 2 times current market price. Actual current market price of trees will be provided. For the livelihood loss, payment for sources of income and relocation costs will be provided. The private land owners will be compensated according to standard provisions.

The proposed industries here are Garments and Knitwear industries, requiring huge number of workers at different levels. This EZ will have garments , knitwear’s , spinning and textile and will create 172,000 workers (374 workers per hectare). As the EZ will provide job opportunities with standard wages, the overall population, including the poor population, will benefit from that immensely. The project can make provision the affected farmer, small businessman, labourers to be given priority in employment and recruitment in the EZ, so that a better livelihood is ensured for them. The most impoverished section of the population, women and vulnerable people,

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could be given priority and a special package of compensation to restore or initiate their sustainable livelihood in case they are not capable of taking jobs.

The fishermen and farmer in the EZ area and nearby locality will benefit from greater job opportunities. At the moment, they can only catch fish from the river for 4 months of the year and it is not plentiful. They often have to risk their lives. Many of them have lost heir investments through river errisoin . Thus, economic activities in the locality will bring more opportunities and diverse and secure livelihood options for them.

During the consultation with the local poorest people including farmar , labours , fishermen, shopkeepers, unemployed youth and students living inside and adjacent areas, all opined that the EZ will bring more economic benefits to the population of the EZ and adjacent areas as there are no industries established or income generating activities currently undertaken. The poorest strata of the population of the locality, fishermen and unemployed women will benefit from the EZ.

However while the construction activities go on, including the establishment of the EZ, widening roads and seaside dam improvement with dykes, outside workers are likely to be present in the locality for a long period. Thus, necessary measures needed to be taken to prevent any harassment or violence against women and public health related problems including HIV-AIDS.

Detailed survey and consultation on socio-economic conditions and land ownership and asset ownership patterns of PAPs at the EZ site needed for efficient and effective resettlement actions. Further consultation in EZ adjacent areas may be needed before and during implementation of resettlement and establishment of EZ for ensuring best possible socio-economic effects of the EZ.

2.14 ESTIMATED EMPLOYMENT CREATION

Employments of Sirajganj is estimated from an average employment of each industrial sector estimated from the existing industry in Bangladesh and some industries which doesn’t exist in Bangladesh was estimated from industries of Asian countries. Based on the planned land use of Sirajganj, the estimated employment created will be 1,72,000 workers. The total employment of direct and indirect employments may reach 1,72,000 workers within 7-10 years.

Table 4.2.7.2-1: Employment Estimate for Sirajganj Economic Zone

Industry & Com Land Area (Ha) Employment /Ha Employments

Knitting 202 500 101172

Spinning 121 300 36422

RMG 40 798 31629


10.1

25 253

Essential staff quarters 6.1 25 152

Road 28.3 2 57

Greenery 41.7 50 2084

Warehouse 4.0 20 81

Gas Power Plant 6.1 25 152

Total 460 1745

172000

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Sector wise % of Employment Generation: 2.15 RESETTLEMENT PLAN As there are various types of household, a detailed survey will be needed to assess the socioeconomic condition and land and asset ownership patterns before the compensation is provided. Proper consultation needed before displacing people from their households who need to be re-located, consultation with the local elite, UP chairman and members, teachers, religious leaders, local administration including UNO need to be included along with the representatives of the PAPs particularly the ones losing their homesteads needed in the grievance redress mechanism committees to ensure proper compensation is provided to the genuinely deserving ones and to reduce tensions and in order to motivate PAPs to move out of their current homesteads on time.

Affected households will be resettled in or adjacent to the EZ area in Sirajganj. The farmers, fishermen and people from other affected occupational groups will receive compensation for loss of livelihood options and income, with twice the current market value. Private tree owners will also be compensated.

2.16 COMPENSATION AND ENTITLEMENTS

The affected persons will be compensated for their affected structure, trees, cropping field, ponds and business. Compensation is based on entitlements including: (i) replacement value for structures, tree, etc. and (ii) other resettlement assistance as required such as transfer grants, re-installation grant (except replacement value) and compensation for loss of business/wage due to dislocation. Vulnerable households will be eligible for further cash assistance for relocation and resettlement to improve their living condition. The entitlements as per loss category are presented in table below;

2.17 RESETTLEMENT MATRIX AND COMPENSATION PACKAGE

Sl. No.

Type of loss Type of compensation suggested

1 Homestead Resettlement in EZ area (land for land) Cash compensation: twice the current market price and relocation costs who opt for cash instead of land Preference in the jobs created by the EZ Skill training for new livelihood options

2 Private land ownership Cash compensation x 1.5 times of current price Actual of loss of crops where applicable Preference in the jobs created by the EZ Legal owner(s), including mortgagors, as determined by DC during Compensation under law (CUL) payment, or by court in cases of legal disputes. Co-sharers/ to be determined by title deeds/records by DCs. T ransition allowance (TA) for income loss from productive lands.

3 Shop owners Actual cost of the shops & materials Relocation costs Compensation for two months earnings.

58.82

21.18 18.39

0.00 0.15 0.09 0.03 1.21 0.05 0.00

10.0020.0030.0040.0050.0060.0070.00

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Preference in the jobs created by the EZ 4 Ponds Cash compensation x 1.5 times of current price 5 Trees Cash compensation x 1.5 times of current price

In case of fruit tress one season of earnings from fruit sale 5 Livelihood loss Preference in the jobs created by the EZ

Compensation of 2 months of earnings and relocation costs 6 Vulnerable groups A special compensation for the most vulnerable people such as female headed

families, people with disability, orphans. 7 Training needs

assessment Government’s youth department, Women’s affairs department, NGOs can do needs assessment on training and provide technical training related to employment at EZ industries.

8 Temporary/short term hassle for construction period

Compensation to the affected people Employ their household members in construction works or other relevant works.

9 Social, educational and Economic organizations

The project is avoiding any destruction of such institutions and minimizing such loss, thus approach roads were carefully designed to avoid loss.

10 Public property In case any such public property is affected during the construction or operational phase, these services and facilities will be compensated and rehabilitated/relocated properly before implementing work.

11 Historical, cultural or religious sites

None fall in the project area. In case any such sites are affected, relocation cost should be paid.

12

Closing/obstructing to accessibility to natural resources

Sirajganj EZ is adjacent to the Jamuna River. But the EZ is not closing or obstructing access for communication or livelihood to the natural resources as a whole. The dyke for protection of the EZ will be constructed with a road on top of it. So accessibility to surroundings will be very good. The dyke will also protect the locality of the fishermen from flood. There is no possibility of destroying the access of fishermen to the sea. But, a sea channel is proposed to bring coal to the power plant inside the EZ. It will be a shipping line. So the mouth of river Sangu may have limited access for fishing activities.

Though BEZA is responsible for overall execution and coordination, ensuring GOB's support and timely financial

disbursements of the EZ but land acquisition and resettlement has to be done by the Ministry of Land through the

respective DC office. Thus, complexity of bureaucratic procedure and coordination may happen. Land replacement

costs, dislocation allowance, transfer grants, reconstruction grants, onetime special assistance, income and

livelihood restoration grants will be included in the compensation package so that the economic condition of PAPs

will be improved.

The Project construction activities will require many unskilled labourers and skilled staff for earthwork in the EZ development, approach roads, offices and management work. Provision should be made in the contract with the contractors for employment of qualified PAPs and their dependents in the recruitment of local labour, including affected women. Employment in the project construction will act as an added source of income and livelihood restoration of the PAPs.

Land replacement costs, dislocation allowance, transfer grants, reconstruction grants, onetime special assistance, income and livelihood restoration grants will be included in the compensation package so that the economic condition of PAPs will be improved. The Project construction activities will require many unskilled labourers and skilled staff for earthwork in the EZ development, approach roads, offices and management work. Provision should be made in the contract with the contractors for employment of qualified PAPs and their dependents in the recruitment of local labour, including affected women. Employment in the project construction will act as an added source of income and livelihood restoration of the PAPs.

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Related Activities and Responsibilities Responsibility

A. Preparation of Updated RAP Preparation of land acquisition plans BEZA/RU/Eng Firm LA process and land acquisition DC/BEZA Recruitment of ERS and NRS BEZA/RU/WB Recruitment of Implementing Agency BEZA/PIU Design and reproduction of RAP Information Brochures BEZA/RU/NRS Disclosure and public consultations BEZA/RU/IA Selection of members for resettlement advisory bodies BEZA/RU/IA Design and carry out census for joint inventory of losses RU/IA Market survey on prices of lands, structure, crops and trees. IA/PVAT Establishment of unit prices PVAT/RU Processing the Census and socioeconomic data of APs IA/NRS Assessing AHs to be relocated and any vulnerable APs IA/RU Determination of entitlements and consultations with individual APs RU/IA Consultation of Draft RAP to EA, APs and stakeholders ERS/RU Incorporate suggestions and finalizing the RAP ERS Review and concurrence of RAP SS(National)/WB

B. RAP Implementation Mobilization of GRC RU/IA Establishment of internal monitoring and hiring of EMA MOHW/DCs/PIU Budget approval for compensation and resettlement PIU Release of funds for compensation BEZA/RU Filing and resolution of complaints APs, RU/GRCs/IA Assess needs, identify sites and develop relocation sites RU/IA/APs Consultation with APs on schedule of clearing the lands RU/IA Clearing of lands APs Confirmation of “No Objection” for the award of civil works contract WB Relocation and livelihood restoration assistance IA/RU/LIRP C. Monitoring and Evaluation Internal monitoring RU/ERS/NRS/IA Independent external monitoring and evaluation EMA/WB

Table : Institutional Responsibilities in Resettlement Process

135

Figure: Procedure of Determining Valuation of Property

Identification of Alignment and Affected Property by RU

PVAT members RU (PIU,BEZA) IA Representative DC Representative

PVAT to Collect Information

Key Informants

Potential Buyer

Potential Seller

Deed Writer

Religious Leader Local Elites

Conduct PVS for Land, Structure, T rees

CRO for approval of Unit Rate

Implementing Agency for

Preparing Budget

Sub-Register Office for the then Recorded Value of Land

Prepare Mouja wise existing

Replacement Value/Unit Rate

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2.18 GRIEVANCE REDRESS

A grievance redress mechanism should be developed prior to the compensation provided and during the resettlement period.

The land acquisition and resettlement will be done during mid-2014 to early 2016. A local body incorporating the Local Governance (LG) representatives and the government administration at the local level, with a cell at central level, could be established to take care of this.

The aggrieved person will apply to GRC (Grievance Redress Committee). The grievance redressing mechanism is shown in the following figure. GRC will review the application and if the application is under arbitration then it will be referred to the DC. If the application is not under arbitration then the grievance will be settled by RAP policy. If the application is rejected then the person can apply to the district judge for legal settlement.

It should be remembered that grievance redress is a very time consuming matter and should be given priority so that the minimum possible time is required for it.

2.19 DISCLOSURE OF INFORMATION

According to WB OP 4.12, people’s participation in the project planning and implementation phase is essential. People have the right to information what is going to happen in their surroundings. They must be informed about the positive and negative impacts of the proposed project and their opinion, suggestions and feedback must be incorporated in the project design. People living in the EZ area, where embankment improvement with dykes and super dykes will be undertaken, must be informed so that they can take protective measures for their safety, or can get compensation for the loss of their structures. Consultation was done with various stakeholders in the EZ area and adjacent areas for initial assessment of the positive and negative effect of the EZ.

2.20 INSTITUTIONAL ARRANGEMENTS AND PROBLEMS RELATED TO IT

There may be problems regarding institutional arrangements among several government departments involved in the EZ implementation. Lack of manpower, lack of training, lack of coordination, administrative problem for transfers, trust building and rapport with local people are the major problems which may be faced during implementation of the project.

During consultation with the relevant stakeholder government agencies, it appeared that while the PPP agency had some considerable amount of money to undertake new ventures, due to lack of experience, in practise, the money could not be spent. Also the regulatory frameworks and coordination are mentioned as major obstacles.

Government Ministries and agencies likely to be the stakeholders are, among others : the Prime Minister’s Office, the Ministry of Finance (Finance Division and Economic Relations Division), the Ministry of Land, the Customs Authority, the Board of Investments (BOI), Bangladesh Economic Zone Authority (BEZA), Bangladesh Export Processing Zone Authority (BEPZA),the Ministry of Industries, the Ministry of Commerce, the Ministry of Power, Energy and Mineral Resources, the Ministry of Communications, the Ministry of Water Resources, the Ministry of Railways, the Ministry of Law, the Ministry of Environment and Forest. More consultations are needed in this regard.

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Resettlement Unit (RU) for BEZA

An INGO needs to be involved in the process of resettlement for transparency and effect land acquisition and resettlement and grievance redress process for timely completion of this phase to move on to construction of EZ and allocation of industrial plots.

2.21 CONSULTATION WITH LOCALS

A participatory approach is an essential part of projects dealing with development in order to ensures sustainability. Participation of local people and other stakeholders enables different socio-economic interest groups in enhancing their capabilities to play an effective role in development initiatives. It also ensures commitment and a sense of ownership of various stakeholders beyond the locals and direct project beneficiaries. Government agencies, people’s representatives, professional groups and voluntary groups including NGOs and community-based organizations, could be actively engaged to share responsibility in key decisions. It also enriches project planners with local/indigenous knowledge.

As part of the public consultation of social, gender, and resettlement issues, we carried out a series of consultations with people from a range of categories within the proposed EZ and the nearby areas including proposed approach roads. These meetings were heled from March 2011 to June 2014. Meetings were held with relevant government officials. Consolations took the forms of individual interviews, focus group discussions – mostly informal, in project area. Consultations were done with the locals including farmaer, fishermen and, labourers, youth and children. In the consultation, various stakeholders mentioned the positive impact of the EZ on the lives and livelihoods of the people of that area or adjacent areas. They consider that in the current scenario of the unemployment and low return from agriculture and fishing, low food security is a problem. They perceive that industrialization in the EZ will enhance job opportunities and income and will have positive impacts on poor people by various occupational and income generating opportunities even in addition to the EZ employment. The probable offshoots of the EZ would be tourism, small trading, suppliers of raw materials to the related small factories, better transportation and transportation related business, women’s entrepreneurship and children’s education.

Issues covered in Consultation:

During consultations, issues covered are current socio-economic conditions of the population living inside the EZ area and the locality, women’s employment, children’s education and health facilities; how EZ will affect the lives and livelihoods of the people living inside and adjacent areas, what are the expected prospects for socio-economic development in the area due to the EZ and if there is any probable negative problems related to the establishment of the EZ, what should be the resettlement compensation and grievance redress.

BEZA

Project

Director

Social/Resettle

ment

Specialist

Deputy

Commissioner

INGO/IA

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2.22 SWOT Analysis for Sirajganj Economic Zones

Strengths

Site is located by the side of the 60 ft. wide Dhaka- Sirajganj Highway , 130

KM to Dhaka international airport and 375 KM to Chittagong port .

Ra ilway s tation only 1 KM

Closest with Bangabandhu Multipurpose Bridge

Bagabari River port within 40 KM . In future have a chance to establish river

port with zone

Jamuna River within 1 KM . Large water body available southern part of

zone

Gross area 1041.43 acre (Khas land 985.93 acre and 55.50 private Land

Si te is especially suitable for knitwear , garments and pharmaceuticals

Employment creation is expected to be 80,000 workers

230 KV switching power station within 1 KM from the site

Gas supply source available within 1 KM

The land is plain and high. only 3m earth filling is required

Resource development -80000 workers employment opportunities.

Own River port will be developed for EZ in future

Garments , knitwear and RMG industries suitable for large no. of

employment.

Suitable for national investors as competitive and high demand of

knitwear and garments abroad

• Increased urban faci l i ties and connectivi ty to the ci ty of Si ra jganj

• Resettlement of 815 HHs

would be a challenge,

strong monitoring needed.

• Inadequate institutional

support and coordination

among the government

ministries and agencies.

• PPP is not well

practiced yet, needs

motivation and good

coordination.

• Local investors and traders

may like small scale risk free

industries, needs motivation.

• Political changes and red tape.

• Social bottlenecks-

resistance form sections of

communities & landowners

in developing EZ.

Threat Lack of co-ordination between

relevant government ministries and

agencies.

Land will be acquired by Land

ministry, other development activities

done by several other ministries

Lack of experience and success in PPP

may risk the project or slow it down.

Labour cost competitiveness but

conforming with more restrictive labour

laws.

Opportunities

To use EZ to catalyze

infrastructure development.

To increase investment in a demand

driven, labour intensive way in a

country experiencing unemployment in

rural areas.

To organize industrial zone for

best management and least health and

environmental hazards.

Sirajganj EZ

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World Bank Policy on Involuntary Resettlement, Gender and Indigenous/Tribal Population

2.23 WORLD BANK OP 4.12: REQUIREMENTS FOR INVOLUNTARY RESETTLEMENT

The primary objective of the World Bank policy on ‘Involuntary Resettlement’ is to explore all alternatives to avoid or at least minimize involuntary resettlement. Where resettlement is unavoidable, the resettlement activities should be conceived and executed as sustainable development programs, providing sufficient resources to enable affected persons to share in project benefits and assisted in their efforts to improve their livelihood and standard of living, or at least to restore them to pre-project level. The policy also requires that affected people are meaningfully consulted and should have opportunities to participate in planning and implementing resettlement programs. The policy applies to the taking of land and other assets when involuntary resettlement results in the loss of shelter, the loss of all or part of productive assets, or access to them and the loss of income sources or means of livelihood, with or without physical displacement.

Measures required ensuring that resettlement has a positive outcome include:

Providing Project-affected persons with options;

Permitting their participation in planning and selecting these options;

Prompt compensation at full replacement cost for losses;

Choosing relocation sites that provide, at a minimum, the same benefits as the sites they

replace;

Providing allowances and other assistance to make a smooth transition after displacement;

Identifying vulnerable groups and providing and special assistance to these groups; and, Implementing an institutional structure that supports the process to a successful and

World Bank policy on Involuntary Resettlement requires payment of compensation and other assistance to project affected people before they are displaced from their existing locations. Further, the policy requires income rehabilitation assistance to those affected severely due to the loss of their productive assets or loss of incomes and livelihood.

Absence of legal title does not exclude individuals from the eligibility to receive compensation and/or other assistance. The displaced or affected population eligible for compensation for losses include: those who have formal legal rights to land or other assets and those who initially do not have formal legal rights to land or other assets but have a claim to legal rights based upon the laws of the country. The policy also requires that those without legal title should be given assistance to meet the objectives of the policy. The genesis of these rights may come from continued possession of public land where the government has not sought their eviction. World Bank policy also recognizes that stakeholders who illegally occupy project-affected areas after established cut-off-date for any components are not eligible for compensation and other assistance provided that adequate measures are taken for information dissemination to people.

The gaps in the existing legal framework of Bangladesh and the objectives and requirements of the World Bank and other multilateral agencies are well recognized. Therefore, institutional or project specific policies are prepared to address these gaps and to meet the requirements of multilateral agencies in projects funded by them. The gaps in the existing legal framework of Bangladesh and the objectives and requirements of the World Bank and other multilateral agencies are well recognized. Therefore, institutional or project specific policies are prepared to address these gaps and to meet the requirements of multilateral agencies in projects funded by them. The following basic categories of issues/impacts are foreseen under this entitlement framework:

a. Loss of land;

b. Loss of structure; c. Loss of source of livelihood;

d. Loss of access to common resources and facilities;

e. Loss of standing crops, trees and perennial trees; and f. Loss of public infrastructure.

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Data on the various land patterns, structures and institutions are provided in the report showing the overall condition and probable impact of the proposed EZ. In the financial and economic plans, financial compensation is counted for all the affected households whoever is living inside the proposed EZ area. From the secondary data it seems there are mostly kuccha and khupri houses in the area of the EZ site, so the financial compensation along with job opportunities will benefit them compared to the amount of land they will lose from their possessions and their current livelihood loss. Though there are structures and institutions and buildings in adjacent areas, if extension or new constructions for transportation are needed, more consultation will be needed with relevant stakeholders.

2.24 WORLD BANK GENDER POLICY OP 4.20: GENDER AND DEVELOPMENT (REVISED MARCH 2012)

The objective of the World Bank Gender and Development policy is to assist member countries to reduce poverty and enhance economic growth, human well-being and development effectiveness by

addressing the gender disparities and inequalities that are barriers to development and by assisting member countries in formulating and implementing their gender and development goals.

No gender disparity will result from implementation of the proposed EZ. Rather, it will contribute to gender parity and women’s empowerment by their involvement in the income generation activities and employment in the industries, compared to the current situation where women are mostly unemployed. However, a special package should be provided for the female headed households.

While providing compensation money for the households, a joint back account should be opened and money should be transferred by banks for the purchase of property. If possible, property should be bought in the name of husbands and wives jointly. While moving to a new place, women may their kin, social networks and informal economic transactions. Therefore, for the displaced population, special care needs to be taken to ensure that women are not left vulnerable and without assets. In the case of women having some kind of income generating activities, livelihood restoration support must be provided.

Regarding poverty alleviation, as previously stated the project will contribute tremendously by creating jobs particularly for women and the impoverished population. By reducing poverty and contributing to the solvency of families within the area, it is also expected that education and health will improve. This project conforms to various MDGs and has no conflict with the World Bank’s aim of poverty alleviation and development. But the project needs to ensure that the affected people are given priority in employment and that the most vulnerable people including widows, the old age population, orphans and people with disability get priority in assistance packages.

2.25 SPECIFIC FUNDING REQUIREMENT OF THE WORLD BANK POLICY OP 4.10

Policy document OP4.10 of the World Bank contributes to the Bank's mission of poverty reduction and sustainable development by ensuring that any development activity and accompanying processes fully respects the dignity, human rights, economies and cultures of Indigenous Peoples. Hence, it is a requirement that all projects which are proposed for financing by the World Bank are assessed to see whether the policy needs to be triggered keeping in mind the geographic location, nature and scope of activities.

The policy requires client governments to seek broad community support of Indigenous Peoples through a process of free, prior and informed consultation before deciding on development projects affecting Indigenous Peoples. The policy requires that Indigenous Peoples benefit from the commercial development of natural resources. The Project must include measures to (a) avoid potentially adverse effects on the Indigenous Peoples’ communities; or (b) when avoidance is not feasible, minimize, mitigate, or compensate for such effects. World Bank-financed projects are also to be designed and structured in a manner to ensure that Indigenous Peoples receive social and economic benefits which are culturally appropriate and gender and inter-generationally inclusive.

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2.26 WORLD BANK OP/BP 4.11: PHYSICAL AND CULTURAL RESOURCES

The objective of OP/BP 4.11 on Physical Cultural Resources is to avoid, or mitigate, adverse impacts on cultural resources from development projects that the World Bank finances. Cultural resources are important as sources of valuable historical and scientific information, as assets for economic and social development and as integral parts of a people's cultural identity and practises. The loss of such resources is irreversible, but fortunately, it is often avoidable.

Taking OP 4.11 into consideration the project planning team endeavoured to avoid any such resources being affected by the project and proposed alternatives to avoid destruction of cultural resources and to minimise the displacement of physical resources

2.27 LEGAL CONTEXT OF LAND ACQUISITION IN BANGLADESH Currently the only legal framework that governs land acquisition in Bangladesh is the Acquisition and Requisition of Immovable Property Ordinance, 1982.However, its provisions are not adequate to address adverse impacts associated with land acquisition and involuntary displacement and do not fully satisfy the requirements of the Bank's Operational Policy (OP 4.12) on Involuntary Resettlement or that of the international practices. The project proposal follows the World Bank policy OP 4.12 Requirements for Involuntary Resettlement where there is a gap between the government’s and World Bank’s policy regarding the resettlement issues.

Due to the low lying land, the EZ area is at risk of flooding, during rainy season, for example the site was affected by the floods of 1988, 1998, 2004, 2011. Therefore, people living in the site area are willing to relocate a safer site with compensation. Although the site is currently waste land prone to flooding in the time of rainy season, the construction of a super dyke is planned (7 metres in height, which is 1 metre higher than the historical record flooding.) surrounding the Sirajganj EZ site. This, plus land-reclamation of 5 metres will turn the waste land into a safe and valuable water front industrial zone. Many ports and industrial zones in Asia, including Japan, Korea, China, Philippines and Vietnam were low waste land, but were turned into valuable industrial zones/ports. The Sirajganj EZ can convert the current waste land into a valuable water front industrial zone using the above technical solution. These would make the EZ safe and valuable and also ensure the safety of the entire community of Sirajganj (population of 259,022 in 49,966 HH living in the Upazila, with including 0000 HH living in rural areas .

2.28 Detailed Information of Land for proposed EZ Data on this section was collected from the DC, Sirajganj district records. There may be a small gap in these details and the land use pattern in the EZ. This is provided to help in identifying the land details during the land acquisition and compensation for resettlement.

Upazi la Name M ouza Name JL NO Khas Land (acre) Private Land (acre)

Sirajganj Sadar Khas Baro Shim ul

214 271.35 -

Chak Boayra 215 260.19 -

Birhati 216 13.47 -

Belkuc hi Boyra M asum 16 139.83 -

Baro Bera Kharua

17 295.59 -

T otal 980.13

Private land for approac h road = 55.50 ac re and

Bangobandu Bridge authori ty land = 5.50 ac re = 61.00

Total Land 1041.43

142

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