SUMMARY ENVIRONMENTAL IMPACT ASSESSMENT

JAMUNA-MEGHNA RIVER EROSION MITIGATION PROJECT IN THE

PEOPLE’S REPUBLIC OF BANGLADESH

July 2002

CURRENCY EQUIVALENTS (As of 30 June 2002)

Currency Unit – Taka (Tk) Tk1.00 – $0.0175 $1.00 – Tk57.2

The exchange rate of the taka is determined by the Bank of the People’s Republic of Bangladesh. In this report, the rate of $1.00 = Tk57.5 was used. This was the rate prevailing during the preparation of the draft paper.

ABBREVIATION ADB Asian Development Bank BIWTA Bangladesh Inland Water Transport Authority BWDB Bangladesh Water Development Board CADP Command Area Development Project DOE Department of Environment EIA environmental impact assessment EMP environmental management plan FCD&I flood control, drainage and irrigation FGD focus group discussion GRC grievance redress committee HYV high-yielding variety JMC joint management committee JMREMP Jamuna-Meghna River Erosion Mitigation Project M&E monitoring and evaluation MDIP Meghna-Dhonagoda Irrigation Project NGO nongovernment organization PIRDP Pabna Irrigation and Rural Development Project PMO project management office RF resettlement framework RP resettlement plan RPG Resettlement Procedural Guidelines SDL secondary defense line SEIA summary environmental impact assessment SMO subproject management office WMA water management association

Weights, Measures and Currency ha – hectare mm – millimeter km – kilometer mt – metric ton L – liter µg – micro gram m3 – cubic meter yr – year

m – meter

NOTES (1) The fiscal year (FY) of the Government ends on 30 June. FY before a calendar

year denotes the year in which the fiscal year ends, e.g., FY2002 ends on 30 June 2002.

(2) In this report, “$” refers to US dollars.

CONTENTS

MAP ii I. INTRODUCTION 1

II. DESCRIPTION OF THE PROJECT 1

III. DESCRIPTION OF THE ENVIRONMENT 2

A. Physical Environment 2 B. Biological Environment 5 C. Human and Economic Development 6

IV. ALTERNATIVES 9

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

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A. Physical Environment 10 B. Biological Environment 13

C. Human and Economic Development 14 D. Impact Identification and Assessment Matrix 17

VI. ECONOMIC ASSESSMENT 18

VII. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MONITORING PROGRAM

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VIII. PUBLIC INVOLVEMENT 20

IX. CONCLUSION 22

APPENDIXES

1 Morphological Trends 24

2 Multicriteria Analysis of Options 26

3 Summary of Resettlement Framework and Short Resettlement Plan 27

4 Impact Evaluation Matrix Showing the Project Impact on Important

Environmental Components 31

5 Project Investment in Environmental and Social Measures 32

6 Environmental Management Plan 33

7 Overall Institutional Framework for Implementation of the Project and

Environmental Management Plan 36

8 Environmental Impacts and Mitigation Measures 37

I. INTRODUCTION

1. The Bangladesh Water Development Board (BWDB) engaged consultants to undertake an environmental impact assessment (EIA) of the Jamuna-Meghna River Erosion Mitigation Project (JMREMP). The Project aims to mitigate the impacts of riverbank erosion threatening certain sections of flood embankments in the Pabna Irrigation and Rural Development Project (PIRDP) along the Jamuna River and in the Meghna-Dhonagoda Irrigation Project (MDIP) along the Meghna River through comprehensive and adaptive structural and nonstructural measures.1 This summary of environmental impact assessment (SEIA) of the JMREMP discusses the likely significant environmental changes as a result of the implementation of river erosion protection works. If these changes are found negative, mitigating measures that should be taken to lessen their impact both during construction and afterwards are identified, where possible. The implementation of these measures is included in an environmental management plan (EMP).

2. The EIA was carried out in accordance with the Asian Development Bank’s (ADB) Environmental Assessment Requirements of the Asian Development Bank2 and the guidelines of the Government of Bangladesh, including Guidelines for Environmental Impact Assessment (EIA),3 the accompanying manual, Environmental Impact Assessment4 and Guidelines for Environmental Assessment of Flood Control, Drainage and Irrigation Projects.5 It was of special relevance to assess the important environmental components in a “without Project” situation and compare this to a “with Project” situation. The comparison determines the negative and positive impacts of preserving the present benefits of the flood control, drainage and irrigation (FCDI) facilities provided by the PIRDP and MDIP. The JMREMP is classified as “Category A” by ADB and as “Category Red” by the Government. Under both classifications, an EIA is mandatory. A multidisciplinary team of consultants conducted the EIA during the project preparatory technical assistance from October 2001 to March 2002 with the utilization of a range of available data including those on flood flows and morphological changes measured from July to October 2001. This SEIA was prepared by the Government for review by ADB and other concerned stakeholders. The EIA will be forwarded to the Department of Environment (DOE) of the Government of Bangladesh for its approval.

II. DESCRIPTION OF THE PROJECT

3. The Project consists of structural and nonstructural measures for protection of the two vital irrigation subprojects, the PIRDP in Pabna District and the MDIP in Chandpur District, where riverbank erosion is threatening the embankments. The two schemes provide flood protection for a total area of 201,400 hectares (ha), within which irrigation command areas of 18,680 ha in PIRDP and 13,360 ha in MDIP were developed to benefit a total population of about 440,000. Failure of the embankments would have severe social, economic and environmental impacts on both the subprojects. Thus, there is a rationale to institute both

1 These project areas are covered under the ongoing Loan No.1399-BAN: Command Area Development Project, for

$30 million, approved on 7 November 1995 for the provision of irrigation canals and other support services. ADB also assisted the construction of flood control and drainage facilities in these two projects through Loans No. 378-BAN: PIRDP, for $38.0 million, approved on 12 December 1978, No.833-BAN: MDIP, for $24.0 million, approved on 15 December 1977, and No. 883-BAN: MDIP (Supplementary), for $8.4 million, approved on 4 February 1988.

2 ADB.1998. Environmental Assessment Requirements of the Asian Development Bank. Manila. 3 Flood Plan Coordination Organisation (FPCO). 1992. Guidelines for Environmental Impact Assessment. Dhaka. 4 FPCO. 1995. Environmental Impact Assessment. Dhaka. 5 Water Resources Planning Organization. 2001. Assessment of Flood Control, Drainage and Irrigation. Dhaka.

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structural and nonstructural measures to offset the severe socioeconomic and environmental impacts that would visit the two subprojects if erosion were to proceed unabated.

4. The structural river protection works have been designed in accordance with an “adaptive approach” to stabilize the two rivers along flat, smooth alignments that are natural to the respective river systems. Under this approach, the Project will protect a total of 7.0 kilometers (km) and 4.4 km reach of riverbank along the existing bank line of the PIRDP and the MDIP respectively. The protection works will comprise (i) riverbed revetment aprons using sand-filled graded geo-bags that launch and cover the eroding bank as they develop, (ii) upper bank line revetment with concrete blocks, and (iii) grass turfing along a strip of the bank at the crest of the revetment. The placement of protection works will follow a gradual, phased, and process-type approach, with the initial 2 years of works undertaken as pilot-cum-implementation phase to reconfirm the design criteria and implementation approach. This will provide structures based on the prevailing morphological conditions and opportunities for reducing the cost. The Project will be implemented over a 6-year period.6 Further to the above protection works, the Government will construct 1.2 km of secondary defense line of embankment in the PIRDP, which will be placed behind the critical reach of the embankments and will protect the project area from inundation in the event of possible breach of the existing embankments. 5. In addition to the structural measures, the Project will further encompass the following nonstructural measures: (i) riverbank erosion information management including monitoring, forecasting, and warning through procurement and analysis of satellite imaginary and mathematical modeling; (ii) disaster preparedness and management support; (iii) social development support to the vulnerable settlers on and around the embankments displaced by ongoing river erosion; and (iv) capacity development of institutions related to the Project. 6. During implementation of the Project, land will be required for structural work. A resettlement plan (RP) is included in the Project following ADB’s involuntary resettlement and other safeguard policies. The main principles are to (i) minimize negative impacts as much as possible; (ii) carry out resettlement and social development activities to improve or at least restore the preproject standards of living of the affected persons; (iii) fully inform and closely consult the affected people on compensation policy, options, and social development/poverty reduction designs; (iv) provide compensation for acquired assets at replacement rates; and (v) pay compensation for acquired lands, structures/immovable properties, and other eligible benefits prior to ground leveling and demolition of structures.

III. DESCRIPTION OF THE ENVIRONMENT

A. Physical Environment

1. Climate, Hydrometeorology, and Air

7. The monsoon climate that affects the project areas is part of a system that affects the whole of the Indian subcontinent. There are four more or less distinct seasons. The monsoon and the dry season are the main seasons, separated by transition seasons. The southwest

6 From the perspective of a project life of 30 years, additional structural measures were assessed for the medium- to

long-term future as stage II and stage III. The necessity to implement these stages will depend on the morphological development acting to safeguard the structures implemented under stage I. Stages II and III are included in the environmental assessment, especially in relation to morphological impacts, and incorporated in the economic analysis, although they are not considered for implementation under the current Project.

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monsoon lasts approximately from June to September, and produces the main rainy season. More than 90% of the annual rainfall (average 1,700 millimeters per year [mm/yr] in the PIRDP and 2,100 mm/yr in the MDIP) occurs during this period, when both temperature and relative humidity are high. In an average year the potential evapotranspiration exceeds rainfall between the months of October and April. Rainfall in the early and late monsoon periods is highly variable, however, and irrigation water requirements vary year by year. Basically there is a requirement for irrigation between the months of November and April, even under average rainfall conditions. No measurements exist of the air quality at the project sites. However, being in rural areas away from industry and heavy traffic, the general air quality is considered to be acceptable according to the Government’s ambient air quality standards.

2. Geology and Soils

8. The Bengal Basin is in the northeastern part of the Indian subcontinent, between the Indian Shield and the Indo-Burman Range, comprising three geotectonic provinces. The PIRDP and MDIP are situated in the Central Deep Basin. The area is actively subsiding and impacted by tectonic movements. With the development of the major river system of the Bengal Basin dominated by the Ganges-Brahmaputra-Meghna rivers, sedimentation and erosion processes of these rivers now dominate the project areas. In the MDIP the soils have developed from Meghna alluvial sediments, and in the PIRDP from young alluvial sediments deposited by the Ganges and Jamuna rivers and their tributaries in the Holocene Age. With proper drainage and irrigation the soil of the areas is very suitable for agricultural development.

3. Physiography

9. The PIRDP lies within the floodplain of the Padma-Jamuna rivers, and before the construction of the embankment most of the area was flooded annually. Under the present conditions the area is generally flood free. However, the drainage system is managed to maintain water bodies such as beels during the dry season. Under pre-PIRDP conditions, the Isamoti River used to flow through the area. At present the Isamoti River is closed and forms an irrigation and drainage channel. The Hurashagar River flows through the northern part and the Jamuna River through the eastern side of the PIRDP area. Both these rivers are causing erosion of flood protection structures. However, it is the erosion by the Jamuna River that has taken a serious turn in recent years.

10. The MDIP area is situated in the Meghna River and Meghna floodplain, which was previously flooded annually. The land of the project impact area within the embankment is almost flat, with some local depressions and has a general mild slope, mainly from the north to south. It has also a gentle cross slope in the west direction. In the pre-MDIP period, the Meghna River and the Dhonagoda River, with their numerous tributaries, used to drain the area. However, the MDIP flood protection embankment and irrigation and drainage channels have substantially altered the natural drainage pattern of the area, and very few natural water bodies remain inside the embankment.

4. River Hydrology and Morphology

11. The Jamuna at the PIRDP has a braided river channel pattern, with the river flowing in multiple channels that divide around chars and sandbars. The river is highly dynamic, being characterized by rapid changes in channel locations. Analysis of the right bank positions over the 27-year period for which satellite images are available, reveals that, except for a single location, all locations along the right bank have been exposed to erosion a number of times. The

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channel is characterized by having rapid scour and deposition, and by bed material transport of more than 150 million metric tons (mt)/yr. The present bank erosion attack at the project site started in the last half of the 1980s. The average annual erosion rate at the attacked area was up to 130 meters over 1992-2000. 12. A number of new chars are close to the project site. These chars/sand bars have been deposited recently, have hardly any vegetation and are uninhabited. After the 2000 flood, the bank line at the PIRDP was attacked by the flow of three separate channels. Since the 2001 flood, the northern of these channels has become clearly dominant, and the erosion area has shifted further north. This northern channel is not believed to be stable, considering it is a close to perpendicular offtake from the main channel. At present the morphological situation at the PIRDP is very complex and unpredictable, both in the short and long term. In the long term (decades), the erosion/accretion pattern along the PIRDP is expected to be similar to that experienced in previous decades and in other locations along the right bank. Based on the experience from previous bank erosion attacks, such attacks are likely to last for a number of years and subsequently ease off for a number of years till a new attack takes place. (See Appendix 1 for recent morphological changes around the PIRDP.) 13. After the confluence of the Jamuna and the Ganges, the Padma River is formed, which flows in a southeasterly course for approximately 100 km until it reaches the junction with the Upper Meghna River. At this confluence, near the MDIP, the river makes an abrupt turn to the south. The Padma River has an anabranched7 channel pattern, with two or more prominent channels dividing around large vegetated chars. The active channel width varies between 13 km in wide sections where the river divides around the chars to a minimum of about 4 km in narrow, single channel reaches. Large sandbars appear during the dry season. The bed material transported is estimated at approximately 200 million tons/yr. Whereas the sediment-laden Padma flow stays along the right bank, away from the MDIP, it pushes the flow of the Upper Meghna with its low sediment content, against the right bank at the MDIP. In the early 1970s, the Padma joined the Meghna as a single channel, and the MDIP was situated along the bank of the Upper Meghna. In the late 1970s, the Padma developed two channels at the confluence, which have remained since then. The two channels vary in strength in a cyclic manner, with the two channels being intermittently dominant. The erosion attack at the MDIP is closely related to the strength of the north Padma channel. If the north Padma channel flow reduces, the erosion pressure at the MDIP will be reduced. The balance between the north and the south Padma channels is governed by strong controls, including major developments in the Padma far upstream; erosion deposition of very large sediment volumes; and finally, but not least, the strong influence of natural hardpoints. In other words, the processes controlling the balance between the north and the south Padma channels are very strong and are not likely to be affected by any minor interventions in the river system. The morphological conditions at the MDIP are at least as complex as the conditions at the PIRDP, but very different. (See Appendix 1 for recent morphological changes in the MDIP.)

5. Surface Water Quality

14. Measurements of water quality parameters carried out by the Department of Environment (DOE) until 1990 and subsequent data show that the oxygen concentrations in the Meghna and Jamuna are acceptable and will sustain normal aquatic life in the rivers. Due to the large size of both rivers and the considerable base flow even during the dry season, it is expected that the oxygen levels are still acceptable. The measurements of coliform bacteria 7 An effluent of a stream that rejoins the main stream, forming an island between the two water sources.

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indicate a relatively high impact from human and animal excreta. This would primarily be from the discharge of untreated sewage and fecal matter from livestock. Based on available measurements, no problems are identified with respect to the nutrient levels in the Meghna and Jamuna rivers. Given the size and baseflow of the rivers during the dry season, the situation is not expected to have changed drastically.

6. Groundwater

15. The groundwater resources of the PIRDP area are reasonably plentiful. There is enough rainfall in the area, and seepage from irrigation canals and rivers adds to the recharge of good aquifers created by sandy sediments deposited by the Jamuna and the Ganges rivers. Groundwater is used in the PIRDP area for irrigation and drinking purposes. Toxicity of groundwater for irrigation has been noted in the area mainly due to the presence of iron, boron, molybdenum, and bromide. Arsenic contamination in shallow aquifers has contaminated about 17% of the wells of Pabna District by more than 50 micrograms per liter (µg/L), and about 6% of the wells show arsenic contamination at more than 200 µg/L.

16. The groundwater resources potential is not uniformly distributed in the MDIP area. Recharge of groundwater is not considered to be a major problem for a large part of the project area, as there is sufficient rainfall and the area is inundated for a considerable part of the year. However, aquifer characteristics and water quality are a major constraint of groundwater development. It has been found that deeper aquifers contain fresh water and shallow aquifers above are brackish or saline. The occurrence of fresh water beneath the saline water aquifers means that the groundwater-based irrigation may not be sustainable in the area. Arsenic contamination of groundwater is another major constraint for the use of groundwater use in the MDIP area; 90% of the tubewells in the district are contaminated by more than 50 µg/L arsenic, and 80% of the wells contain more than 200 µg/L arsenic.

B. Biological Environment

1. Aquatic Ecosystem

17. The PIRDP area within the floodplain of the Padma and Jamuna rivers is a freshwater- dominated environment inhabited by freshwater plant and animal species. Agricultural and water resources development has already altered the biological environment of the area. Most of the former low-lying floodplain wetland areas and beels have been converted into rice fields. At present there is no wetland in its virgin natural condition within the PIRDP area, and it is heavily impacted by human activities. The added security provided by the embankment has encouraged a rapid increase in population and in agricultural activities in the area. These activities in return have changed the ecology of the area, leaving very little land where the natural ecosystem could flourish. However, there is some wetland in seminatural condition on the floodplain of the Hurashagar River and the Jamuna River close to the PIRDP site. A number of beels remain within the PIRDP area, providing shelter to aquatic species during the dry season.

18. The Meghna Flood Plain is a dominant freshwater environment inhabited by freshwater plant and animal species. Before the implementation of the MDIP, the low-lying area with a saucer- shaped depression used to remain submerged under floodwater for about 9 months in a year. The project area consisting of the Meghna and Dhonagoda rivers, and their floodplain once formed a special freshwater ecosystem supporting high fish production, and many species are now endangered. Native waterfowl and migratory birds depended on this system, and the

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area was rich in biodiversity. The construction of embankments entirely changed the ecosystem. The free migration patterns of fish from the floodplain to the Meghna River and vice versa was disrupted, and fish production in the MDIP area fell after the implementation of the project. Intensive agriculture and reduction in wetland areas have affected the habitat of migratory birds. The pressure from the increasing human population on the natural resources has affected the ecosystem. Very few areas are left, and only outside the embankments, where the natural ecosystem remains. At present there is no natural wetland remaining within the MDIP area.

2. Terrestrial Ecosystem

19. The area covered by natural vegetation in the project areas is marginal and consists only of some small patches covered by mostly grass and bushes. The major terrestrial vegetation of the area includes human-influenced vegetation that grows in homestead gardens, orchards, plantations, cropland, at roadsides, and on other cultivated land. In fact, homestead vegetation is the most important group of vegetation present in the project areas. Selected species of homestead vegetation are also planted on the roadside and grown in very small orchards. Homestead vegetation includes two types of plants; those cultivated for economic value and those that are self-propagating.

20. Wild mammals are relatively scarce in the project area; all bigger wild mammals have disappeared. Small mammals such as Bengal fox, common mongoose, and fishing cat remain along with smaller animals like lizards, mice, rats and bats. In addition, a number of terrestrial birds and waterfowl are found.

3. Endangered Species

21. Several species attributable to the project area appear on the World Conservation Union’s (IUCN) Red List of Threatened Animals,8 including the Ganges river dolphin, Bengal fox, fishing cat, jungle cat, Bengal monitor, ring lizard, Pallas's fish eagles, brown fish owl, and Asian fairy bluebird.

C. Human and Economic Development

1. Land Use and Settlement

22. The estimated population of the PIRDP irrigation command area is about 233,000, with approximately 50,000 households. About 2,500 households are located between the present embankment and the river and are directly exposed to flooding and erosion. The total land area between the embankment and the bank line under erosion is estimated to be 550 ha, of which about 110 ha is used for settlement, roads, etc. Hundreds of erosion-affected people in recent years have shifted their households in and around the embankment. An estimated 1,400 squatter families live on the embankment near the erosion-prone area. The estimated population of the MDIP area is 210,000, who live in about 45,000 households.

2. Water Supply and Sanitation

23. In the PIRDP and the MDIP, 98% and 95% of the people, respectively, depend on tube wells for drinking water. The remaining population uses river water and ponds. The high content of arsenic, especially in the MDIP area, constitutes a massive drinking water quality and health

8 IUCN. 1990. Red List of Threatened Animals.

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problem. Sanitation facilities in the PIRDP area are poor. About 25% of households have sanitary latrines, 65% use katcha9 latrines and about 10% use open places. People living in squatter areas have even more problems with latrine facilities. The sanitation facilities of the MDIP area are relatively better in the PIRDP area: About 45% households have sanitary latrines, about 50% use katcha latrines, and about 5% use open places. Sanitation and the living conditions of people in squatter areas are generally very poor.

3. Agricultural Productivity

24. The net cultivatable area of the PIRDP is 21,850 ha. Prior to the PIRDP/Command Area Development Project (CADP), most of the land was non-irrigated, and the cropping intensity was about 128%. At present 13,720 ha land is irrigated and the cropping intensity has reached 177%. Major crops grown are aman, boro and aus rice10; wheat; oilseeds; and pulses. Total rice production from the PIRDP area in 2001 was 85,295 mt, which includes 39,024 mt of high-yielding variety (HYV) boro, 6,550 mt of HYV aman, 5,965 mt of HYV aus, and 33,756 mt of other rice. For comparison total rice production in the PIRDP was 47,065 mt in 1996.

25. FCD&I facilities provided by MDIP/CADP helped to increase agricultural production in the area. There was very little irrigated land during the pre- MDIP period. As of June 2001, there was about 12,300 ha of irrigated land in the project area. Irrigation water is mainly used to cultivate boro crops in the dry season. Aman and late aus crops are cultivated using rainwater. The net cultivatable land of the project area is 14,500 ha, and the cropping intensity is 214%. Total rice production increased from 83,408 mt in 1996 to 118,060 mt in 2001. Major varities of rice produced in the area are HYV aman, HYV boro, HYV aus. Other crops include oilseeds, pulses, wheat, jute, sugarcane, and vegetables.

4. Fish Culture

26. Although there has been a decrease in capture fisheries resources, there has been an increase in production from fish culture that in both the PIRDP and MDIP areas is estimated to more or less make up for the loss of capture fisheries at present. The potential for culture fish production is still not fully developed in both schemes.

5. Navigation

27. Water transport is an important means of travel for the people living in the PIRDP and MDIP areas. Motorized and manually operated boats carry agricultural goods, including livestock, to other markets and bring commodities for the local population. There are relatively important river ports at both project sites. The oil terminal area in the Hurashagar River north of the PIRDP area is an important ship terminal. The navigability of the river is hampered during the dry season due to sedimentation at the confluence with the Jamuna and narrowing of the western main channel in the Jamuna. The Bangladesh Inland Water Transport Authority (BIWTA) carries out dredging regularly during the dry season to maintain the access to and navigability of the Hurashagar River. The planned volume of dredging in 2002 is 100,000 cubic meters.

9 Earthen. 10 Aman, boro, and aus rice means rice grown in the monsoon, dry season, and pre-monsoon seasons respectively.

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6. Quality of Life Values

a. Way of Life and Equity

28. The people of the two areas generally live in small towns and villages. In comparison to the MIDP area, the PIRDP area is less densely populated. However, the area threatened by river erosion at PIRDP is more densely populated than that of MIDP. People of the project area are mostly engaged in agriculture, fishing, and weaving. Some of them are also engaged in trading and transportation. Some are involved in both agriculture and fishing, the latter especially during the monsoon. Some of the farmers have also fishponds. Cattle ranching is fairly common among the people living in villages. Especially the PIRDP area is famous for its milk and milk products. Members of households often work and live in the major cities, or overseas, supporting their families, especially in the MDIP area.

b. Income and Poverty

29. People in both project sites are generally poor, and large populations live below the poverty line. According to the World Health Organization/United Nations International Children’s Fund standard for Bangladesh, the absolute poor (below the poverty line) are defined as those who cannot afford an intake of 2,122 calories per day, and the hardcore poor are those who cannot afford a daily intake of 1,805 calories. The most hardcore poor are found in the areas outside the embankment and affected by river erosion at both project sites, as shown in Table 1.

Table 1: Income and Poverty Status

Item Annual Income Population below Poverty Line

Hardcore Poor

PRIDP MDIP PIRDP MDIP PIRDP MDIP Outside Embankment Tk 44,200 Tk 43,600 67.0% 53.0% 46.7% 40.0% Inside Embankment Tk 70,500 Tk 55,600 45.0% 43.3% 28.3% 28.3% Outside Project Area Tk 55,800 Tk 55,100 57.0% 45.8% 34.5% 33.2%

MDIP = Meghna-Dhonagoda Irrigation Project, PIRDP = Pabna Irrigation and Rural Development Project.

c. Health and Education

30. In the PIRDP and MDIP areas, waterborne diseases are relatively common. However, the situation has improved compared with the period before the provision of the FCD&I facilities, when diarrhea was widespread, especially during the flood season. Another health factor is the increasing number of people affected by arsenic. In addition, malaria is fairly common in both areas. Health care facilities are slightly better in the MDIP area than in the PIRDP area. In both areas thana (upazila) health complexes provide basic health care facilities. Family planning and immunization programs are also carried out through these health complexes. For the PIRDP area, the overall literacy rate is about 52%, and for the MDIP area about 50%.

d. Cultural and Heritage Sites

31. There are no archaeological sites of national interest in the project areas. The mosques, temples, and bazars of historical interest are situated far from the Project sites and are not likely to be affected by project activities.

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IV. ALTERNATIVES

32. The River Erosion Prevention and Morphology Study (REPMS),11 prepared in November 2000, comprised a prefeasibility study for several bank protection and mitigation measures. Under the current study, a further options assessment was undertaken. Conventional structures such as revetments with deep setting level with hard and/or interconnected materials and high spurs were found to be far more expensive than other options and had low economic return and high maintenance costs. While low permeable spurs were identified as a potential alternative, the piling alone would cost three times more than the low solid spurs and was consequently dropped. The following options were taken forward for the feasibility study:

(i) without project,

(ii) embankment retirement,

(iii) riverbank protection by revetment, and

(iv) riverbank protection by low solid spurs

33. In the without project scenario, river erosion will continue. The estimated loss of land by river erosion over the last 10 years is 1,430 ha at PIRDP and 222 ha at MDIP. With the expected average erosion rate over the next 30 years it is estimated that 3,000 ha will be eroded at PIRDP and 2,300 ha at MDIP. It is expected that some of the erosion of land at the project sites will cause sediment deposition and generation of new land elsewhere. However, the newly accreted land is of low value, and it generally takes up to 20 years before such land has good productive capacity.

34. Further, in the without project condition, the embankment would be breached to inundate the project area, creating a considerable impact on the terrestrial and aquatic environment. Parts of the agricultural land in the PIRDP and MDIP would be flooded annually, causing a reduction in agricultural production of approximately 11% in the PIRDP and 39% in the MDIP. In addition, flooding would a have a negative impact on water supply, sanitation, and health during the flood season. The floodplains would reverse to their former function, supporting aquatic life during the flood season. This would have a significant impact on fisheries and culture fish production. A considerable part of the production capacity in the pond culture would be lost, while the capture fishery could be reinstated. However, on the whole the increase in fisheries production in the project area would be minimal.

35. Under an embankment retirement scenario (as well as the without project scenario) continued river erosion will have a significant impact on the terrestrial environment. It will accelerate the present negative cycle of environmental degradation in the project area where people displaced by erosion move to remaining marginal land. This will cause a further deterioration of the existing natural resources and further reduction in the terrestrial biodiversity in the MDIP and PIRDP areas.

36. At PIRDP, it is estimated that over the past 15 years at least 2,500 households have lost their homestead lands to river erosion. These households have therefore been forced to relocate their homes to an alternative location including along the embankment. The number of

11 BWDB. 2000. River Erosion and Morphology Study. Dhaka

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households that could be lost in the retirement scenario at PIRDP as a result of erosion attacks in the next 30 years is estimated at 7,000, which includes the 2,500 now existing outside the embankment and others just on and behind it. In MDIP it is estimated that about 4,000 households have lost their homesteads over the past 15 years, of which, about 300 are at present squatting on and along the embankment. Another 2,900 households (approximately) have migrated inside the project area, and the remaining households have migrated to the opposite side of the rivers. The number of households that could be lost due to bank retreat at MDIP as a result of erosion attacks in the next 30 years is estimated at 5,400.

37. The alternative without project and embankment retirement scenarios were evaluated and compared with the recommended protection and alternative approach works using multicriteria analysis that summarized economic, social, and environmental consequences. (See summary analysis in Appendix 2.) The overall economic analysis shows that embankment retirement costs less and has a higher economic viability than riverbank protection by revetment selected under the Project. However, the severe environmental impacts and significant social disruption under the embankment retirement scenario, associated with continued loss of agriculture and homestead land and dislocation of 28,000 people in the next 10 years, made this choice highly unattractive, and opposed by the stakeholders. There was a consensus among the stakeholders and the Government that embankment retirement should be avoided as long as there is an economically feasible alternative, given its highly disruptive social impacts. Nevertheless, the retirement option would need to be considered if other appropriate cost effective and sustainable measures are not found to be feasible.

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

A. Physical Environment

1. Air

38. During construction, 80-100 boatloads of sand need to be transported to each of the sites daily. This may cause dust, noise, and air pollution. Storage of sand and sand-filled geo-bags at the project site may generate dust emission. Impacts during the transportation and storage of sand will be minimized by covering the sand or by keeping the surface wet. Work will be restricted to the daytime, reducing nuisance from noise. Boat owners will be required to keep their engines properly maintained to reduce air pollution from exhausts. Vehicles will be similarly maintained to minimize exhaust.

2. Soils

39. Establishment of working areas and storage of sand and sand-filled geo-bags at the project site may cause damage to local vegetation and degrade the topsoil. During these activities topsoil may be covered by sand, seriously affecting its productivity. Removing the topsoil from the storage site and storing it in a secure place for later use will mitigate these impacts. After the completion of the construction, the topsoil will be returned to its original place. In areas with no topsoil (sandy areas), sand can be stored directly on the ground. However, after the construction, the area will be turfed and trees planted.

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3. Physiography

40. The general physiography of the project areas will not be altered by the Project, and in general the existing situation will be maintained. Works will be carried out in limited areas, and the structures will be situated at the river embankments with no apparent changes.

4. River Hydrology and Morphology a. Design Impacts

41. The riverbank protection works will have significant positive impacts by protecting the productive agricultural and homestead land from progressive river erosion, without which about 5,300 ha of land would be eroded, displacing about 12,400 households over the next 30 years. However, structures built on the riverbank will also cause morphological impacts. The morphological impact will occur when the structure becomes effective. It will affect the river flow and thereby to a certain extent affect the shaping of the riverbed and the river course. A structure will become effective when it is being attacked by the flow, protecting the riverbank against erosion. There are two main categories of structures: active structures built into the river, intended to influence the river flow (groins, spurs, guide bunds, etc.); and passive structures that are well aligned with the existing flow and ideally are intended to remain like that (bank protection structures, revetments, etc.).

42. The bank protection structures planned for the PIRDP and MDIP are passive structures, intended to stay out of attack as long as possible. Being well aligned with the direction of the flow, they may not be exposed to any significant attack for some time. In the attempt to erode its banks, it is likely that the Jamuna will attack the structures. Based on the experience from previous bank erosion attacks, such attacks are likely to last for a number of years and subsequently ease off for a number of years until a new attack takes place. The structures will not prevent these attacks from taking place, but they are designed to stand up against the river attack and will prevent bank erosion at the location where they have been built. In this situation, when under erosion attack, the structures will cause morphological impacts.

43. River reaches upstream and downstream of the structure may, if they remain unprotected, continue to erode, and the protected riverbank will then represent a protrusion into the river. This will cause local scouring of the riverbed adjacent to the structure, and it may increase erosion along the opposite side of the channel. This erosion is, however, expected to be considerably less than the prevented erosion along the protected bank. A number of factors will tend to delay and limit the morphological impacts at the PIRDP and further to limit any consequences of these impacts:

(i) Protection work will be along the alignment natural to the river channel (at least initially and during the coming years, as long as there is no major morphological change at that location).

(ii) Large areas of uneroded land exist upstream of the Hurashagar River. This will prevent the protected riverbank from protruding into the river at least over the short to medium term.

(iii) The impacts further downstream from the protection structure will be reduced due to joining of the major anabranch (footnote 7).

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(iv) If any erosion occurs, this will be on the sandbars and the char closest to the protected portion. These are uninhabited and largely without vegetation.

44. At the MDIP, the naturally occurring erosion rates are smaller than the corresponding erosion rates at the PIRDP. Thus, the morphological impacts due to prevented erosion will be even less. It is expected that this effect will not be significant, but rather that impacts will be minimal and occur mainly locally, close to the intervention. A number of factors will tend to delay and limit the morphological impacts and further limit any consequences of these impacts:

(i) The existence of erosion-resistant clay deposits along the left bank of the north Padma channel will prevent further northwards shifts of this channel, thereby limiting the risk of erosion attack from upstream of the structure.

(ii) The south Padma channel is hydraulically more efficient than the north Padma channel, and there are signs that this difference will be further enhanced in the coming years according to recent flow measurements, bathymetric surveys, and satellite images. This will reduce the erosion attack in the MDIP.

(iii) The impacts further downstream will be further reduced and made insignificant due to the joining of the South Padma channel just below the protected sections.

(iv) The morphological impact, if any, will initially be in the form of prevented deposition rather than erosion. Should erosion occur, it will be at sandbars opposite the protected bank. These are uninhabited.

45. Monitoring of the morphological situation is essential so that mitigation measures can be planned and implemented in time. The Project will collect all necessary data relating to hydrology, morphology, hydrodynamics, sedimentation, and other aspects of behavior of the rivers. The information will be collected, collated, interpreted, and analyzed for the purpose of making the necessary and timely interventions, if and when erosion upstream of the existing structures will start to threaten these. In case unexpected morphological changes are detected that affect areas away from the project sites, these will be analyzed as part of the permanent monitoring program. If such morphological changes are significant and can be prescribed to originate from the structures implemented by the Project, a compensation program will be implemented.

b. Construction Impacts

46. Large-scale sand mining may have some negative impact on the environment. The present plan is to extract sand by dredging from boats at Gazaria for the MDIP site and from the confluence of the Hurashagar River and the Jamuna and from chars in the Jamuna River for the PIRDP site. The amount of sand required for the construction is about 600,000 cubic meters, equivalent to approximately 1 million mt for both sites together. Construction will take place in phases over a 6-year period. Compared with the annual bed load transport of the Jamuna and Ganges of 150 million mt and more than 200 million mt in the Padma, the dredged volume of sand will be very small, and no impact is expected on river morphology and erosion.

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5. Surface Water Quality

a. Design Impacts

47. The Project will protect the pump-operated surface water irrigation and drainage system to draw in river water for irrigation and drain out any polluted or stagnant water from the project area. This in turn will reduce local water pollution problems. The overall impact of the project on water pollution is expected to be positive.

b. Construction Impacts

48. During the implementation phase there may be some water pollution from the construction site, labor camps, etc. There may be up to 3,000 laborers at each construction site during peak construction period. To mitigate this, the following measures will be taken:

(i) Maintain all construction sites in a clean and safe condition, and provide and maintain appropriate facilities for temporary storage of all wastes before transportation and disposal.

(ii) Organize disposal of all wastes generated during construction in an environmentally acceptable manner. This will include consideration of the nature and location of disposal sites, so as to cause least environmental impact.

(iii) Take all precautionary measures when handling and storing fuels and lubricants,

to avoid causing environmental pollution. This is to include establishment of contingency plans for cleanup in the event of spillage.

(iv) During site inspections a trial sand dredging was observed. No direct impacts were identified except the overflow from the barge where the sand is separated. The silt and clay contents in the overflow were found to increase the turbidity of the water in the vicinity of the operation.

49. As part of the EMP, the dredging operations will be monitored to ensure that water quality standards are not violated with respect to turbidity. If this is observed, the site of dredging will be shifted to places where the clay and silt content is low enough to maintain the turbidity within the water quality standards.

6. Groundwater

50. Continued supply of irrigation water is considered to improve the recharge and availability of groundwater in the project areas during the dry season. The Project is not foreseen to have any impact on the groundwater resource during construction.

B. Biological Environment

1. Aquatic Ecosystem

51. The Project is foreseen to have a limited positive impact on the aquatic ecosystem by providing shelter for aquatic organisms at the revetment. During construction, sediments may reach the aquatic habitat from sand mining, transport, storing, filling of sandbags, and dumping. Slope preparation at some stretches, especially at the PIRDP, may be necessary, which would

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create spreading of sediment. However, the expected increase in sediment concentration is not considered to be higher than generated at present by river erosion, and the effect is considered negligible.

2. Terrestrial Ecosystem

52. The Project will not encroach into any terrestrial habitats of any significance. It will prevent the ongoing erosion of the present terrestrial habitats, however human-impacted these may be, thereby having an overall positive impact. During construction, noise may disturb the (scarce) wildlife and birds in the vicinity of the project sites, thereby having a slight negative impact. Sand mining close to existing uninhabited areas such as sandbars used by birds for resting will be avoided. Boat owners will be required to keep their engines properly maintained to reduce noise. Vehicles will also be maintained to minimize noise.

3. Endangered Species

53. Disturbances during construction may have a temporary effect on endangered species. However, no permanent negative impact is foreseen.

C. Human and Economic Development

1. Resettlement

54. The Project will involve a total of (i) 11.4 km of revetment works in the PIRDP and MDIP and (ii) 1.2 km of secondary defense line (SDL) of embankments in the PIRDP, which will require the acquisition of land, removal of buildings, and resettlement of affected people. The total amount of land acquired for revetment is estimated at 35 hectare (ha) in PIRDP and 22 ha in the MDIP. This will displace 89 households including 9 small business enterprises. These have to be further reviewed during the final design stage, when the alignments for the protection works will be decided upon based on the morphological development at that time. On the other hand, the SDL will require the acquisition of 10 ha of land, for which 3 households (18 people) will be relocated and an additional 30 households will experience some loss of agricultural lands. This does not include land for construction camps or storage areas, as the number, size, and location of these have yet to be determined. The land taken for these facilities will be kept to a minimum and will be leased temporarily.

55. The resettlement activities will be implemented in accordance with ADB’s involuntary resettlement and other social safeguard policies. In the context of the Project, a resettlement framework (RF) was prepared for the PIRDP and MDIP to cover the riverbank protection work, for which specific sites will be finalized at the final design stage in response to the shifting of the riverine environment. The established RF requires the following procedures: (i) BWDB will carry out impact assessment surveys once the scope of each year’s work is identified, based on preliminary technical designs; (ii) if impacts are found to be “significant,” BWDB will prepare full RPs for each subproject; and (iii) if subproject impacts are less than significant, short RPs will be sufficient for project preparation. Experienced consultants and NGOs will be recruited to assist the process. The short RPs must, however, comply with ADB’s policy on involuntary resettlement and other social safeguard guidelines. In addition to the above, a short RP was prepared for the SDL. The summary of RF and short RP are given in Appendix 3.

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2. Land Use and Settlement

a. Design Impacts

56. It is expected that 12,400 households in the project areas will be protected from losing their land over the 30-year lifetime of the Project. An additional 91,000 will be protected from annual flooding of the project areas. This will have a large positive impact on households and settlement.

b. Construction Impacts

57. Apart from the resettlement impacts described in para. 54, during construction the presence of construction camps may stress the existing settlement resources and infrastructure. This may lead to antagonism between locals and migrant workers. To prevent this, the contractor will be required to prioritize the use of local labor. In addition, the contractor will provide camps with facilities such as health care clinics and places of worship, and a mechanism will be established that allows local people to raise grievances arising from the construction process.

3. Water Supply and Sanitation

a. Design Impacts

58. Implementation of the Project will protect the present infrastructure of the area including tubewells, dugwells, and latrines from flooding. This will have very positive impact on securing a hygienic drinking water supply and maintaining sanitation facilities in the areas inside the embankments during the wet season.

b. Construction Impacts

59. During the construction phase some tubewells may have to be relocated and some people using the river as their source of drinking water may face inconvenience. This may have a minor local negative impact. To mitigate any such impact the contractor will be required to establish an alternative water supply.

4. Agricultural Productivity

Design Impacts

60. A small amount of agricultural land may be permanently needed for sloping of the revetment, especially in the PIRDP. However, the Project will prevent the further erosion of much larger areas of agricultural land. In addition, the Project will preserve the FCD&I facilities. Without these it is estimated that cropping intensity in the PIRDP area will be reduced from the present 177% to 167% and in the MIDP area from 214% to 169%. Not only will the Project preserve the present, increased agricultural production, but it will also provide the potential for further increase in both schemes. The project will have a long-term, very positive impact on agricultural productivity.

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b. Construction Impacts 61. Agricultural production may be slightly reduced during the implementation of the Project because of construction of labor camps, approach roads, storage sites for construction materials, sites for preparation of geo-bags and concrete blocks, transportation of construction material, etc. It is expected that the contractor will establish camps for laborers and permanent staff supervising, directing, and controlling the works. These camps are anticipated to house up to around 1,300 people during construction work, which will typically last about 4-6 months. The area needed for each camp is from 2-3 ha. The land for these camps will be hired, owners compensated, and the land restored after demobilization. After construction the agricultural land will be reinstated to its former state, wherever possible. Any longer term damage to the productivity of rented land will be compensated for through the RP.

5. Fish Culture

62. The Project will preserve the existing flood protection facilities. Fish production from ponds protected against flooding is generally more than double the productivity in unprotected ponds. The Project will ensure the basis for the present, high fish culture productivity, with even the potential for further increase in the future. During construction, the project will be implemented along the riverbank, where there are no fishponds or other water bodies.

6. Navigation a. Design Impacts

63. One of the major navigation routes maintained by BIWTA is the channel outside the PIRDP leading into the Hurashagar River. Especially at the confluence with the Jamuna, sedimentation occurs. Dredging is carried out to ensure navigability and access to the oil terminal in the Hurashagar River. The dredging works may have to consider the safety of the riverbank protection and not be carried out in the immediate vicinity. Coordination between BWDB and BIWTA on this issue has to be effected in the joint management committee (JMC) formed in the project area and the project steering committee formed at the central level. River ports and ghats (boat landing facilities) and access roads should be incorporated in the revetment design to ensure people's mobility.

b. Construction Impacts

64. Easy access to the river may be somewhat obstructed during construction. In many places the river is a major means of transportation of goods and people. During implementation of the works, proper planning should ensure that the inconvenience to people is minimized by leaving access to the river at given, required sites along the riverbank.

7. Quality of Life Values

a. Way of Life and Equity

65. All strata of the population will benefit from the Project protecting agricultural land, homesteads, markets, hospitals, schools, roads, irrigation systems, etc. Increased agricultural production and the construction works of the Project will generate more employment opportunities for the poor and landless, including destitute women. To maximize these benefits, contractors will be required to recruit laborers among the poor and landless with a preference for destitute women.

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b. Income and Poverty

66. The Project will have a very positive impact in preventing a substantial part of the people in the project area from becoming landless and thereby from being thrown directly into poverty. In addition the Project will preserve the potential for further improvement in agricultural production. Especially in the PIRDP there is potential for further increase, as the present production is substantially lower than in the MDIP. It is expected that all levels of society will benefit from increased agricultural production, although large landowners will be relatively more benefited than others.

Health and Education

(i) Design Impacts

67. As the bank protection measure will help increase the agricultural productivity of the area, this will create employment opportunities for the poor. An increase in household income will directly contribute to overall improvement in living conditions, particularly through better health and nutritional status of people. It is likely that per capita expenditure on food, sanitation, and health care will increase, which will have positive impacts on health.

68. The Project will provide improved income opportunities, which in turn will encourage people to send their children to school more regularly. This will be a positive impact on education. The bank protection measures will prevent erosion of schools and colleges in the area and provide flood-free areas for normal economic, social, and academic activities. Infrastructure protected by the bank protection measures will provide easy access to schools and colleges.

(ii) Construction Impacts

69. It is anticipated that around 3,000 workers will be employed at each project site, of whom more than half would be hired locally. Any impacts on the health of workers employed on the Project will be mitigated by provision of adequate water supply and sanitation facilities, proper waste collection and disposal systems, health clinics, etc. at both sites.

70. There is a general risk of accidental injury to workers. Implementation of adequate safety procedures and provision of first aid facilities will mitigate this to the extent possible. The risk of possible health hazards from handling of geotextiles will be small. Following appropriate construction techniques and safety procedures will mitigate or reduce these negative impacts on workers. High-grade geotextiles will be used in the construction, and manufacturers’ instructions for the handling and use of geotextiles will be followed.

71, During the implementation phase, schools in the vicinity may experience temporary disturbance due to noise and dust. The timing and placing of construction activities should seek to avoid any unnecessary disturbances during school hours.

D. Impact Identification and Assessment Matrix

72. The important environmental components and their potential interaction with the major project activities are presented in a matrix (Appendix 4) following the methodology described in the full EIA report. National guidelines require this matrix be considered in order to be able to evaluate the impact of the Project in a rational manner.

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VI. ECONOMIC ASSESSMENT

73. The total cost of the Project is estimated at $61.3 million for the 6-year project period. The foreign exchange component is calculated at $19.5 million (32%) and the local component at $41.8 million (68%). Taxes and duties account for $9.7 million of the local component.

74. The economic assessment of the Project shows an economic internal rate of return of 17% and 31% for the PIRDP and MDIP areas, respectively. The analysis indicates that there is no significant difference in the economic viability indicators between geo-bag revetment and low spurs. Geo-bag revetment was selected in consideration of technical and managerial criteria including the prospects of economizing the costs by providing the structures adaptively in response to prevailing morphological conditions.

75. The costs associated with the environmental mitigation measures identified relate to the resettlement, environmental costs to be covered under the civil works contract, disaster preparedness, riverbank management monitoring and information, environmental monitoring and capacity development. The total costs, amounting to $5.22 million, are outlined in Appendix 5. Resettlement amounts to $2.00 million, detailed in the RF.

76. For the PIRDP, the likely morphological impacts are slightly increased erosion of nearby chars. These chars are newly developed, uninhabited, and unutilized. For the MDIP, the likely morphological impact would be a reduction of the deposition at the inner bend of the Padma north channel, opposite the project area. The costs of these morphological impacts cannot be quantified at present. The information management subcomponent of the Project will be designed and implemented to detect any such identifiable impacts. Contingencies in the environmental cost budget will cover unforeseen morphological impacts and ensuing compensation, if required.

77. Other nonquantifiable costs include effects from air pollution; disturbances to wildlife, birds, and fish; and water pollution during construction work. Such effects, though minimized through mitigation efforts, are non-avoidable, and are considered small. By protecting land from further erosion and preserving the FCD&I facilities in the PIRDP and MDIP, the project is expected to have nonquantifiable positive effects on income generation, poverty, equity, health and education for the total population of 440,000 in the irrigation command area.

78. The Project will preserve the PIRDP and MDIP areas and reverse the negative impact these schemes have had on capture fisheries through increased culture fisheries. It is not possible to accurately estimate the present day costs of the reduction in capture fisheries, as this has declined all over Bangladesh during the last decade. However, the increase in culture fisheries has, since the implementation of the PIRDP and MDIP, made up for the loss in capture fisheries. Total fish production today is considered to be at more or less the same level of 3,000 tons per year in the MDIP and 1,500 tons in the PIRDP.

VII. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MONITORING PROGRAM

79. The institutional requirements for mitigation of the adverse effects of the Project and the associated environmental monitoring program have been incorporated into the EMP (Appendix 6). The EMP outlines the environmental management system that will be implemented during the detailed design and protection works of the Project to minimize deleterious effects and implement enhancement measures. The EMP also embraces environmental management

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issues following the implementation of the riverbank protection measures, to maximize the beneficial effects of the Project, and to detect and ameliorate adverse long-term effects. Environmental management of the Project will involve the following national level agencies:

(i) BWDB, under the control of the Ministry of Water Resources with the guidance and supervision of the Governing Council of the Board, as the executing agency of the project; and

(ii) Department of the Environment (DOE), under the Ministry of Environment and

Forest, responsible for environmental clearance of the Project and enforcement of other environmental legislation.

80. At the BWDB headquarters levels, a project management office (PMO) will be set up with a senior director or additional chief engineer as full-time project director. Overall responsibility for the environmental management of the Project and liaison with DOE will lie with the PMO, with the engagement of an executive engineer having environmental management experience and assisted by consultants. At the level of the PIRDP and MDIP, subproject management offices (SMOs) will be established, each with a superintending engineer as subproject director, under the newly established JMC comprising representatives of line agencies, local governments, and stakeholder institutions. The PMO in association with the Hydrology Department of BWDB will be responsible for morphological information management at the national level. These organizations will form and operate a riverbank management system focusing on the project area and relevant reaches of the Jamuna and the Meghna rivers.

81. For proper monitoring and evaluation (M&E) of the proposed interventions including environmental management, an M&E subdivision will be created in each SMO. An environmental specialist will be placed to carry out environmental monitoring and reporting with the assistance of the PMO and consultants. (See Appendix 7 for the organizational setup for environmental management.) A section officer experienced in resettlement and social development will be posted in the construction subdivision of each SMO to undertake concerned activities with the assistance of consultants and engagement of nongovernment organizations (NGOs). Training programs in these disciplines for BWDB professionals will also be provided to enhance their capacity.

82. The responsibilities for undertaking specific required activities at the design, construction, and operational stages are listed in Table 2.

83. The contractor’s environmental responsibilities will be prescribed in the tender documents and later on in the contract. They will include the need to adhere to environmental clauses in the contract and the guidelines provided. The contractor’s responsibilities will include ensuring occupational health and security for workers, minimizing disturbances, and adhering to existing environmental legislation, including avoiding water pollution and following proper waste handling and deposition procedures. 84. The M&E subdivisions, with the assistance of the PMO, will supervise and enforce contractual requirements and monitor compliance. The M&E subdivisions will be supplied with necessary equipment for sampling and measurement of dissolved oxygen, turbidity, and other relevant parameters. The M&E subdivisions will submit quarterly and annual reports to the PMO and JMC. All reports will be forwarded to DOE for review. See Appendix 8 for a summary of environmental impacts and mitigation measures.

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Table 2: Institutional Responsibilities for Environmental Management

Project Stage

Responsible Organization

Responsibilities

Detailed Design

DOE Review project EIA and provide environmental clearance for Project.

PMO/ Consultants Minimize non-avoidable losses; incorporate mitigation measures and enhancement activities into engineering design and specifications.

PMO/ Consultants

Review and approve environmental mitigation measures Review and forward EMP for DOE approval. Review and forward RP for ADB approval.

SMO/ NGOs/ Consultants

Implement RP.

Construction Contractor Implement required environmental measures. SMO – M&E/ SC Supervise contractor's implementation of environmental measures.

Enforce contractual requirements. SC Audit construction activities through inspections and environmental

monitoring. Submit quarterly/annual reports. DOE Monitor compliance with legal requirements during construction. Operational BWDB Provide budget to undertake environmental monitoring. Operational SMO – M&E Carry out environmental monitoring and submission of quarterly/annual

reports. Operational PMO/JMC/DOE Review monitoring reports. ADB=Asian Development Bank, BWDB=Bangladesh Water Development Board, DOE=Department of Environment, EIA=environmental impact assessment, EMP=environmental management plan, JMC=joint mamangement committee, NGOs=nongovernment organizations, M&E=monitoring and evaluation, PMO=project management office, RP=resettlement plan, SC=supervision consultant, SMO=subproject management office.

VIII. PUBLIC INVOLVEMENT

85. Public involvement has been a substantial part of the process. During the study phase the people’s consultation process was initiated to obtain stakeholders’ views on the consumptive and nonconsumptive use of natural resources, and their demands for protecting and enhancing the environment. The process was carried out in two rounds, the first one through focus group discussions (FGDs) with smaller groups of homogeneous stakeholders in selected (i) areas inside and outside the embankments directly threatened by riverbank erosion, (ii) areas outside the embankment not threatened by riverbank erosion, and (iii) areas inside the embankment benefiting from FCD&I facilities. In total, 42 FGDs were held. On the basis of FGD consultations, the second round of consultations was held in the form of local workshops involving local and regional officials, union parishad12 chairpersons, elected people in the water management associations (WMAs), civil society representatives, as well as representatives from the FGDs to discuss potential options and stakeholder views, which are summarized as follows:

(i) The consulted people pointed at traditional river erosion protection designs as construction of hardpoints, e.g., groins at Eklaspur, and revetments.

(ii) Nonstructural measures such as planting of grass and trees for stabilizing the embankments were identified as beneficial.

12 Refers to village union assembly.

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(iii) For participation in the implementation of proposed mitigation measures against river erosion, the union parishads and BDWB were considered to have a role along with local committees formed with the involvement of NGOs.

(iv) People’s representation in WMA and union parishad, and involvement of NGOs was considered important as well.

(v) Collection of taxes on land supplied with irrigation was identified as a primary possible source of financial contribution to mitigate river erosion. Taxes on fishculture were seen as another funding possibility. Tolls on traffic and on marketplaces were identified as well.

(vi) Local people offered support in kind as physical labor, supply of food, shelter, and necessary materials (bamboo, sacks, etc.).

86. A national workshop was held in December 2001 with 120 participants focusing on the design options. Important feedback was provided, including that (i) the Project should be integrated with a comprehensive national strategy and plan for riverbank management; (ii) the feasibility and long-term sustainability of proposed cost-effective structural solutions needs to be confirmed in light of the highly dynamic morphological processes; (iii) their effectiveness should be verified in the context of the major rivers in Bangladesh; (iv) nonstructural measures for flood and erosion mitigation should also be explored and adopted, including floodplain management and support to existing erosion victims; (v) effective monitoring arrangements for the erosion process and the performance of protection works need to be established; (vi) environmental impacts on char lands and other river processes need assessment; and (vii) further options for institutional setup could be explored with a long-term vision for river management that requires a system-wide approach. It was remarked that the guidelines of ADB as well as the Government should be followed. These issues were consequently addressed in the design of structural and nonstructural measures, impact assessments, and the institutional and project implementation plans. 87. During February 2002, surveys on people’s perception of the environmental issues in the PIRDP and MDIP were carried out. A total of 10 FGDs were carried out in both the PIRDP and MDIP involving in all nearly 160 people. The FGDs revealed that there is little conflict between fishermen and farmers. Overall, people’s perception of the existing embankments is positive. If embankments were decommissioned or destroyed, the following problems would occur according to the people consulted: (i) Bera and Matlab upazilas would go under water; (ii) the total project area will be destroyed; (iii) crops, livestock, and homes would be damaged during floods; (iv) rice would be produced only once a year, which would result in a food shortage; (v) fish cultivation would be disrupted; (vi) out-migration problems would occur; (vii) acute sanitation, fuel wood, and drinking water problems would be created; (viii) people would become shelterless; (ix) communications would be disrupted; (x) income of people would be reduced; (xi) waterlogging might occur and remain a problem in the PIRDP; and (xii) fishermen during times of low catch opportunity would have to revert to other temporary occupations as day laborers, rickshaw pullers, etc.

88. As a part of the public involvement process, a consultative meeting was held in March 2002 to present and discuss the preliminary results of the EIA to 12 leading NGOs, and government institutions, and institutions active in the environment sector, as well as BWDB. The participants generally supported the choice of the geo-bag revetment against other alternatives such as retiring the embankments, in view of the extreme social and economic hardship of the

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large number of people who would have to be displaced as river erosion proceeds. However, its cost effectiveness and long-term sustainability against the highly dynamic morphological process in Bangladesh were pointed out as critical concerns. On this account, it was explained that the Project will take a passive and adaptive approach, under which the revetment will be designed and provided where the protected bank line can be aligned along lines natural to the river system cost effectively, and where such alignment can be expected to remain natural over a reasonable period. This will minimize the risk of structural failure and will contain high maintenance requirements. 89. Regarding the environmental impacts of the selected design option, it was generally noted that the impacts should be insignificant, and confined to the vicinity of the project areas. While morphological impacts on erosion and sand deposition in the nearby areas drew some attention, it was explained that (i) nearby char lands and sand bars on which the revetment may cause direct impacts are uninhabited and unutilized; and (ii) overall impacts should be small as long as the revetment remains passive and adaptive to the natural river course, with any morphological changes upstream and downstream regarded as statistically neutral.

IX. CONCLUSION

90. The proposed Project aims to mitigate the effects of riverbank erosion, which is currently threatening critical sections of the flood embankments in the PIRDP and MDIP, through cost-effective, sustainable, and comprehensive structural and nonstructural measures to cope with the highly dynamic morphological process of the Jamuna and the Meghna rivers. With the placement of revetments using sand-filled geo-bags following an adaptive approach along the alignments natural to the river system, it will protect and enhance the livelihoods of the beneficiary people totalling about 440,000 within its irrigation command, and about 2 million in the overall area protected by the flood embankments.

91. The major benefits from the Project therefore will come directly from the environmental and socioeconomic resources preserved by erosion protection, and indirectly from the losses prevented. Therefore, the impacts, benefits, and disbenefits of the Project have been assessed comparing the present situation with a without-project situation during its expected 30-year lifetime. The impacts during construction works have been addressed as well.

92. The major positive impacts resulting from the Project will be to

(i) arrest river bank erosion, thereby protecting existing homesteads, infrastructure, and agricultural land;

(ii) bring an end to people rendered landless in the project areas;

(iii) safeguard FCD&I facilities; and

(iv) maintain the present level of and the potential for future increases in agricultural production.

93. The EIA did not identify any environmentally sensitive areas that may require particular attention. The project area, including both the riverbank and the river itself, are heavily impacted by human activities. The project intervention will encourage limiting human activities within remaining sensitive areas outside the embankments and thus help to protect the environment and ecology.

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94. The potential morphological impacts of the structures and the risk of increased riverbank erosion elsewhere have been studied. For the PIRDP, the likely morphological impact will be slightly increased erosion of nearby chars. These chars are newly developed, uninhabited, and unutilized. For the MDIP, the likely morphological impact will be a reduction of the deposition at the inner bend of the north Padma channel, opposite the project area. These assessments, however conclusive, may be considered qualitative.

95. In general the planned implementation of mitigation measures during the design, construction, and maintenance periods of the Project will minimize negative environmental impacts to satisfactory low levels. The mitigation measures will be included as part of the project design. Monitoring of morphological and other environmental impacts is essential so that mitigation measures can be implemented in time. This monitoring will be carried out as an important element in the riverbank management system, which will continue for the lifetime of the Project.

96. In conclusion, the Project will have overall beneficial impacts preserving the existing and potential benefits of the existing PIRDP and MDIP schemes, as well as protecting the livelihood of the population living outside the embankments in the erosion prone Project areas. Negative impacts are expected to be insignificant, but nevertheless will be carefully monitored and mitigated.

26 Appendix 2

MULTICRITERIA ANALYSIS OF OPTIONS

Pabna Irrigation and Rural Development Project

Meghna Dhonagoda Irrigation Project

Riverbank Protection Embankment Retirement*

Riverbank Protection EmbankmentRetirement*

Do Nothing

Revetment Low Solid Spur

Do Nothing

Revetment Low Solid Spur

Financial Capital Cost Over 30 Years ($ million) - 47.6 48.2 23.7 - 31.3 34.7 20.4 Economic Net Present Value ($ million) -26.0 3.65 3.00 9.3 -44.9 13.2 10.7 15.4 Economic

Criteria EIRR - 16.7% 16.7% 30.9% - 31.4% 23.4% 72.0% Air 0 0 0 0 0 0 0 0 Soil 0 0 0 0 0 0 0 0 Physiography - 3 0 0 - 2 - 3 0 0 - 2 River Hydrology and Morphology 0 - 1 - 1 0 0 - 1 - 1 0 Surface Water Quality - 2 - 1 - 1 - 1 - 2 - 1 + 1 - 1

Physical Environment

Groundwater 0 0 0 0 0 0 0 0 Aquatic Ecosystem + 2 - 1 - 1 0 + 2 - 1 - 1 0 Terrestrial Ecosystem - 2 + 2 + 2 - 2 - 2 + 2 + 2 - 2

Biological Environment

Endangered Species 0 0 0 0 0 0 0 0 Land Use and Settlement - 3 + 2 + 2 - 2 - 3 + 2 + 2 - 2 Water Supply and Sanitation - 3 + 1 + 1 - 1 - 3 + 1 + 1 - 1 Agricultural Productivity - 3 + 2 + 2 - 1 - 3 + 2 + 2 - 1 Fish Culture - 3 + 2 + 2 - 1 - 3 + 2 + 2 - 1

Human and Economic Development

Navigation - 1 0 0 0 - 1 0 0 0 Way of Life and Equity - 3 + 2 + 2 - 1 - 3 + 2 + 2 - 1 Income and Poverty - 3 + 2 + 2 - 1 - 3 + 2 + 2 - 1

Quality of Life Values

Health and Education - 2 + 1 + 1 - 1 - 2 + 1 + 1 - 1 Cost of Land Acquisition ($ million) - 1.18 0.59 5.4 - 0.64 0.32 5.2 Relocation of Household (no.) 7,000 86 26 7,000 5,400 3 1 5,400 Market Price of Eroded Land ($ million) –excluded from financial/ economic cost

26.0 - - 26.0 26.7 - - 26.7

Resettlement Criteria

Erosion-and-flood Affected People (no.) 540,000 86 26 35,000 210,000 3 1 27,000 EIRR=economic internal rate of return. *Cost of embankment retirement option does not include the cost of safety net for those who will be displaced by river erosion. Note 0= not significant , -1= small negative impact,

+1= small benefit, +2= moderate benefit,

-2= moderate negative impact, -3 = major negative impact.

Appendix 3 27

SUMMARY OF RESETTLEMENT FRAMEWORK AND SHORT RESETTLEMENT PLAN A. Resettlement Framework for the Riverbank Protection Works 1. Scope: The resettlement framework (RF) includes the framework for the proposed 7.0 kilometer (km) and 4.4 km of protection work along the flood embankments of the Jamuna and the Meghna rivers in the Padma Irrigation and Rural Development Project (PIRDP) and Meghna-Dhonagoda Irrigation Project, respectively, to protect the project areas from progressive river erosion. The revetment works will be implemented over a 6-year period. During that time, an estimated 57 hectares (ha) of land will be acquired for revetment work. Implementation of the Project is expected to start in the first quarter of 2003. The Bangladesh Water Development Board (BWDB) is the executing agency of the Project. 2. Resettlement Policy Framework: The current legislation governing land acquisition for the Project includes: (i) Acquisition and Requisition of Immovable Property Ordinance of 1982, and (ii) East Bengal State Acquisition and Tenancy Act (1951, revised 1994). While the 1982 Ordinance is the only law that provides clearly defined compensation for land acquisition, it does not cover project-affected persons without titles or ownership records such as informal settlers/squatters. Further, the compensation paid does not constitute market or replacement value of the property acquired. The East Bengal State Acquisition and Tenancy Act (Section 7) defines the ownership and use right of alluvial (nadi sikosti) and diluvion land (payosti, reformation in situ or original site) in the country. Legally, the Government owns the bank lines and eroded land in the river. However, the “original” owner(s) can claim the land if it reappears as a natural process with the 30 years from the date of erosion. 3. In the absence of a policy consistent with the Asian Development Bank’s (ADB) policies on involuntary resettlement and poverty reduction, a project-specific resettlement policy framework (RPF) and resettlement procedural guidelines (RPGs) will be adopted. The RPF and RPG stipulations in line with ADB policy will apply to all riverbank protection works to be prepared and approved under the loan project. This will ensure that persons affected by land acquisition – whether it is floodplain, bank line, or eroded land – will be eligible for appropriate compensation in this Project. 4. The RPF stipulates eligibility and provisions for all types of losses (land, crops/trees, structures, business/employment, and workdays/wages). Since land-for-land would not be a feasible option due to the ongoing erosion in the floodplain, the owners of land acquired for protection work, including bank line/eroded land within the 50 meter right-of-way acquisition (from the revetment toe in the river to the floodplain on the bankline), will be compensated at full replacement cost. Affected households compensated by the deputy commissioner for lost assets will receive (i) an additional cash grant to match the replacement value; and (ii) other resettlement assistance, such as shifting allowance and compensation for loss of workdays/income due to dislocation. Female-headed households and other vulnerable households will be eligible for further cash assistance for relocation and house reconstruction. 5. Resettlement Procedural Guidelines: The established RPGs require the following procedures: (i) BWDB to carry out impact assessment surveys after the bank lines to be protected under each year’s work are defined, based on preliminary technical designs; (ii) if impacts are found to be “significant,” BWDB will prepare a full resettlement plan (RP) for each subproject; and (iii) if subproject impacts are less than significant, short RPs would be sufficient for project preparation. The short RPs must, however, comply with ADB’s policy on involuntary resettlement and other social safeguard guidelines.

28 Appendix 3

6. Disclosure, Consultation, and Grievances: Each RP will be prepared and implemented in close consultation with the stakeholders and will involve focus group discussions and meetings, particularly with the project-affected people. Copies of draft RPs will be distributed among nongovernment organizations (NGOs)/community groups. A grievance redress committee (GRC) will be established with representation from BWDB, affected persons, women/vulnerable groups, local government, and NGOs. The resettlement coordinator will chair the GRC. Other than disputes relating to ownership rights under the court of law, the GRC will review grievances involving all resettlement benefits, relocation, and other assistance. Any grievances submitted to the GRC will be resolved within a period of 2-3 weeks. 7. Institutional Responsibilities and Resettlement Cost: The Ministry of Water Resources through BWDB has overall coordination, planning, implementation, and financing responsibilities. BWDB fully recognizes the complexity of the resettlement and social development programs under the Project. Therefore, an experienced NGO will be hired for RP implementation. A senior BWDB staff member with the rank of executive engineer will be appointed as chief resettlement officer to supervise the implementation work. BWDB will further ensure that resettlement funds are delivered on time to the deputy commissioner’s office and the implementing NGOs for timely RP implementation. The cost of land acquisition and resettlement is estimated at Tk104.0 million ($1.81 million) including contingencies. The Government of Bangladesh will provide the entire fund for land acquisition and resettlement. 8. Monitoring and Evanluation: BWDB will establish a monthly monitoring system involving BWDB and implementing NGO staff, and will prepare progress reports on all aspects of land acquisition/resettlement and social development activities. External monitoring will be assigned to an independent local expert/agency. BWDB will report to ADB on land acquisition and resettlement/social development in the quarterly progress report. B Short Resettlement Plan for the Secondary Defense Line of Embankments 9. Scope: The short RP is associated with the construction of a 1.2 km secondary defense line (SDL) embankments to protect some critical sections of the existing embankments in the PIRDP. It will be implemented in 2003. 10. Impacts: The construction of the SDL will require acquisition of an estimated 10 ha of land. The proposed alignment consists largely of low-lying agricultural land. As a result, the project impact is limited to three households only (total affected persons, 18). In addition to this, an estimated 30 households will experience some loss of agricultural lands. However, the severity of impact will still be limited due to strip acquisition. The affected households requiring resettlement own their house plots as well as structures to be relocated; they typically combine agriculture with wage labor, fishing, and/or small businesses as sources of livelihood. Two of the three households reported incomes, that translate into less than a dollar per day per person. 11. Resettlement Plan Objectives and Policy Framework: This short RP is designed to deal with the limited impacts of the SDL. Major types of losses include loss of agricultural/homestead land, crops/trees, other immovable assets, residential structures, and work days/income due to dislocation and relocation. BWDB is keen to minimize land acquisition and will take all measures to reduce the amount of land acquisition to the absolute minimum, taking into account the need for the SDL.

Appendix 3 29

12. The current legislation governing land acquisition for public purposes is the 1982 Ordinance, in accordance with which the legal process is initiated by an application by the executing agency to the deputy commissioner of the district. In determining the amount of compensation, the deputy commissioner takes into consideration land transaction cases for the preceding 12 months to determine the average value, plus a 50% premium for compulsory acquisition. The 1982 Ordinance, however, does not cover project-affected persons without titles or ownership records such as squatters or roadside encroachers, nor indirectly affected people. At present there is no national policy for resettlement of project-affected people in Bangladesh. As a result, ADB’s policy on involuntary resettlement1 will be used as the framework for this RP. The framework has been designed to cover compensation for lost assets and to restore or enhance the livelihoods of all categories (direct, indirect, titleholders, and nontitleholders) of affected people. The entitlement matrix recognizes seven types of losses to cover all potential cases, including loss of access by tenants/sharecroppers due to acquisition of agricultural land (Table A3.1). 13. Consultation Meetings and Stakeholder Participation: During the project preparatory stage, consultation was held covering the SDL area. The feedback and observations made at the stakeholders’ meetings have been used in preparing the entitlement matrix and project benefits for the affected people. In addition, two local workshops were held in the project area, in which a strong support and positive public responses were observed towards the SDL and other protection work from riverbank erosion, because it will ensure the safety and security of the people and bring significant economic benefits to the local communities.

Table A3.1: Entitlement Matrix

Type of Loss Application Definition of

Affected Persons

Entitlements Expected Results

1. Loss of agricultural or any other type of land such as fishponds.

Land on the SDL ROW

Legal owners of land

����Cash compensation under law by DC ���� Additional cash grant to match market/replacement value to be determined by BWDB through independent valuation committee ����Refund of registration cost incurred for replacement land purchase

Replacement of agricultural land or the value to the affected persons

2. Loss of homestead land

Land on the SDL ROW

Legal owners of land

����Cash compensation under law by DC ����Replacement value of land ����Refund of registration cost incurred for replacement land

Replacement of homestead/ commercial land

3. Loss of residential structure by owners

Structure on the SDL ROW

Owner(s) of structures identified by DC and the SES

���� Cash compensation under law by DC ���� Additional cash grant to match replacement costs ����Tk2,000 as transfer grant for relocation ����Tk7,500 for homestead/ land development and reconstruction cost

Reconstruction of structure at a new site

4. Loss of trees, crops, perennials

Standing crops, trees on SDL ROW

Owners of land

����Compensation at the rate estimated by the Forest Department and the Agricultural Extension Department

Compensation for standing crops and trees

5. Loss of access by tenants/ sharecroppers

Agricultural plots on the SDL ROW

Tenants of the land as identified by the SES

����Tk200 per decimal (1/247 hectare) of agricultural land under tenant/ sharecropping contract farming

Compensation for loss of access to farmland

1 ADB. 1995. Involuntary Resettlement. Manila.

30 Appendix 3

Type of Loss Application Definition of

Affected Persons

Entitlements Expected Results

6. Loss of income and work days due to displacement

Households affected by SDL RoW

Head of households identified by the SES

����Tk2000 per household ����Tk3000 for households headed by women ����Employment in the project construction work

Subsistence and income in post-displaced period

7. Additional assistance to the poor and vulnerable

Vulnerable households on the SDL RoW

Households relocated to new site

����Lump sum poverty reduction assistance of Tk5,000 per household with incomes under the poverty line

Poverty reduction measures and development

BWDB=Bangladesh Water Development Board, DC=deputy commissioner, ROW=right of way, SDL=secondary defense line, SES= socio-economic study. 14. Disclosure, Consultation, and Grievances: The same arrangement as described in the RF will be followed.

15. Implementation Responsibilities and Cost Estimates: The same arrangement as described in the RF will be followed. The estimated land acquisition and resettlement cost for the SDL is Tk15 million ($260,000). The Government will provide the entire fund for land acquisition and resettlement. The affected people, including those affected by land acquisition, will receive compensation prior to the start of construction work. 16. Monitoring and Evaluation: During project implementation, BWDB will establish a monthly monitoring system involving BWDB and implementing NGO staff, and will prepare monthly progress reports on all aspects of land acquisition/resettlement operations. External monitoring will be assigned to a local independent agency/expert. BWDB will report to ADB on land acquisition and resettlement in its quarterly progress report.

31

IMPACT EVALUATION MATRIX SHOWING THE PROJECT IMPACT ON IMPORTANT ENVIRONMENTAL COMPONENTS

Project Phase Implementation O&M

Important Environmental Components Sand Mining and

Transportation of Sand

Preparation Geo-bags and Manufacture of Concrete

Blocks

Construction of Revetment and Low Solid

Spurs

Flood Protection

Protection of Infrastructure and Natural Resources

River Erosion 0 -1 -1 +8 +9 Land Use and Settlement

0 -1 -3 +6 +6

Agricultural Land 0 -1 -2 +6 +6 Agricultural Productivity

0 -1 -2 +7 +7

Terrestrial Habitat 0 -1 -2 +3 +4 Aquatic Habitat -1 -1 -2 +1 +1 Culture Fisheries 0 0 0 +7 +7 Captive Fisheries -1 -1 -2 -3 -5 Drainage 0 -2 -1 +5 +5 River Morphology 0 0 -1 +4 +4 Hydrology and Hydraulics

0 0 -1 0 -1

Navigation -1 0 -2 0 -2 Irrigation 0 0 0 +5 +6 Sedimentation -1 -1 -2 +2 +2 Open Water Areas(River, etc.)

0 -1 -2 0 0

Water Pollution -1 -1 -2 +3 +3 Groundwater Recharge

0 0 0 0 +2

Drinking Water Supply

0 0 -1 +1 +3

Education and Health

0 -1 -1 +2 +3

Employment and Economic Activities

+3 +3 +3 +3 +3

Poverty +1 +2 +3 +3 +7 Migration from the area

0 0 0 +4 +7

Status of Women +1 +1 +1 +2 +2 Equity +2 +2 +2 +2 +2

O&M=operation and maintenance.

Note : The Impact has been scored on a 1 to 10 scale. No impact is “0,” negative impacts from –1 to –10, and positive impacts from +1 to +10.

Appendix 4

32

PROJECT INVESTMENT IN ENVIRONMENTAL AND SOCIAL MEASURES (2001 prices)

Quantifiable Items

Cost ($)

A. Resettlement and Social Development

1. Resettlement and Compensation 2,000.0

2. Social Development 1,150.0

B. Environmental Costs – Civil Works Contract

1. Construction of Camp Requirements (e.g., clean drinking water, proper waste handling and disposal, drainage, training staff)

50.0

2. Compensation for Income Loss (crop loss, loss of fishermen from captive fishery, etc.)

100.0

3. Provision of Health Care, First Aid Facilities, Staff etc. 30.0

4. Rehabilitation and Slope Protection (grass and tree plantation)

170.0

5. Construction of Ghats and Access Roads 180.0

C. Disaster Preparedness

Awareness Campaigns and Training 104.5

D. Monitoring and Information Management

River Surveys, Remote Sensing Analysis, Modeling, Equipment.

906.0

E. Project Management Support

Monitoring and Evaluation, Environmental Monitoring 120.0

F. Capacity Development

Training, Environmental Monitoring 50.0

G. Contingencies

Physical Contingencies. 360.0

Total 5,220.5

Appendix 5

33

ENVIRONMENTAL MANAGEMENT PLAN

1. The Institutional Requirements for mitigation of the adverse effects of the Jamuna-Meghna River Erosion Mitigation Project (JMREMP) and the associated Environmental Monitoring Program have been incorporated into an environmental management plan (EMP). This entails the procedural framework to ensure that all mitigation measures and monitoring requirements specified in the assessment of environmental impacts will be carried out in the subsequent project stages. 2. The EMP outlines the environmental management system that will be implemented during the detailed design and protection works of the Project to minimize deleterious effects and implement enhancement measures. The EMP also embraces environmental management issues following the implementation of the riverbank protection measures, to maximize the beneficial effects of the Project, and detect and ameliorate adverse long-term effects. The EMP is based on the anticipated environmental impacts and mitigation measures identified in the environmental impact assessment, and will be further developed and updated when the contractor’s design are completed, together with the contractors’ subsequent environmental action plan. A. Objective of the Environmental Management Plan

3. The objective of the EMP is to provide a framework for the monitoring and management of the environmental aspects and issues of the Project during detailed design, construction, and operation and maintenance of the riverbank protection works, during its expected lifetime of 30 years. The basic objectives are to

(i) define a recommended plan of action and a means of testing this plan to meet existing and projected environmental needs and problems;

(ii) provide an organizational framework that assigns roles and responsibilities to all

parties involved for environmental monitoring and management; (iii) identify potential environmental impacts; (v) recommend mitigation measures for the negative impacts; (vi) identify opportunities for enhancement measures; and

(vii) establish a supervision, monitoring, auditing, and reporting framework.

The EMP will thus ensure implementation of recommended corrective actions aimed for environment protection, mitigation, and its enhancement.

B. Parties Responsible for EMP Implementation

4. Parties to be involved in environmental management of the Project are (i) Ministry of Water Resources,

(ii) Ministry of Environment and Forestry,

Appendix 6

34

(iii) Bangladesh Water Development Board (BWDB),

(iv) project management office

(v) joint management committee,

(vi) line agencies (Department of Environment, Department of Agricultural Extension, Department of Fisheries, Bangladesh Inland Water Transport Authority),

(vii) subproject management offices,

(viii) Construction Division,

(ix) Construction Subdivision,

(x) Monitoring and Evaluation Subdivision,

(xi) external design and project management consultants,

(xii) construction contractors,

(xiii) local governments, and

(xiv) water management associations and other stakeholder organizations.

5. The primary responsibility for environmental management lies with BWDB. However, the parties involved have important roles and responsibilities for the efficient implementation of the EMP in order to avoid, minimize, and mitigate adverse impacts and effectuate planned enhancements. The main roles of the different parties are summarized in Table 2 of the main text and the overall institutional framework is presented in Appendix 7.

C. Environmental Management and Monitoring during Different Phases of project Implementation

6. The environmental mitigation measures will be implemented progressively in the various stages of project implementation (design, construction, and operation and maintenance). The environmental impacts and mitigation measures are summarized in Appendix 8. The mitigation measures during design take into considerations environmental requirements to minimize land acquisition and disturbance to people, infrastructure, facilities, and services. In addition, provision is planned for means for rehabilitation, compensation, and enhancement into the design and incorporation of all relevant environmental protection requirements in the tender documents, risk and hazard assessment, and permit and approval. The contractor will describe the implementation of the required environmental mitigation measures in an environmental action plan to be approved by the project management office (PMO)/Department of Environment (DOE).

7. The construction phase mitigation measures include renting of land for temporary labor camps and working sites; compensation, resettlement, and rehabilitation to affected people prior to permanent acquisition of land for construction; site preparation; work area; and labor camp establishment; drainage; topsoil saving for reuse; waste and spoil management; job opportunities for local people; occupational health and safety, provision of safe drinking water,

Appendix 6

35

health care, and emergency facilities and first aid services; monitoring and control of air, water, and land pollution; survey of sand mining activities and loss and degradation of terrestrial and aquatic environment; subsequent demolition of facilities not required for further construction; and restoration of rented land, replacing of top soil, turfing, and planting.

8. The operation and maintenance phase will include monitoring of the general environment and especially developments in river morphology; implementation of supporting structures and repairs in the event of an erosion threat to protection work; and liaison with line agencies to avoid activities endangering riverbank protection structures, such as dredging in the vicinity of the sites by the Bangladesh Inland Water Transport Authority.

D. Records, Audits, and Corrective Actions

9. The construction contractor and the permanent M&E subdivision of SMO with the assistance of the supervision consultant will keep all records pertaining to project environmental management, mitigation measures, corrective actions, and monitoring during the construction phase. In the operation and maintenance phase, keeping and maintaining the records of the environmental monitoring and possible measures will be the responsibility of the M&E subdivision. 10. The monitoring and evaluation (M&E) subdivision of SMO with the assistance of the supervision consultant will carry out compliance auditing regarding the environmental performance during the periods of construction. Besides, the PMO and funding agencies will audit works carried out by the M&E subdivision and the supervision consultant. Quarterly and annual audit reports will be prepared by the M&E subdivision to be forwarded to the PMO for its consideration. DOE and the joint management committee will annually review the audit reports, and if required carry out site visits and provide recommendations for remediation activities. The PMO will prepare an integrated audit report on completion of each year’s construction work during project implementation. 11. BWDB will prepare an environmental audit report every year during the 6 years of project implementation. These project performance audit reports will include an assessment of the performance of the Project with respect to expected environmental impacts, including effects on the river morphology. In addition, the report will describe to what degree the Project satisfies the environmental requirements, the efficiency of mitigation and enhancement measures, and if any unforeseen effects have occurred, and how these were addressed and mitigated. E. Complaints and Grievances 12. Complaints and grievances from the public will be directed to the parties responsible for environmental management through the water management associations and stakeholder organizations to the construction subdivision or operation and maintenance subdivisions at each site. All complaints will be properly recorded and reported to the SMO for immediate consideration. Complaints on minor issues that need immediate attention will be handled by the SMO. Complaints on major issues will be reported to the PMO for its immediate consideration and direction. All complaints will be reported in the quarterly and annual audit reports forwarded to the PMO.

Appendix 6

OVERALL INSTITUTIONAL FRAMEWORK FOR IMPLEMENTATION OF THE PROJECT AND ENVIRONMENT MANAGEMENT PLAN

Organization Chart of the Project

Ministry of Water Resources

DG, BWDB

Additional DG, O&M, BWDB

Project Management Office Project Director: Director/ Additional CE

Chief Resettlement and Environmental Officer

Subproject Management Office Subproject Director: SE of concerned circle

Governing Council of BWDB

Joint Management Committee Representatives of line agencies, local governments, WMAs, etc.

O&M DivisionConstruction Division

O&M Sub-divisionsConstruction subdivision Resettlement and social development officer

M&E subdivision

Environmental management officer

WMAs and Other Stakeholder Institutions

ConsultantsNGOs

Zonal CE

CE=chief engineer, M&E=monitoring and evaluation, NGO=nongovernment organization, WMA=water management association

37

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

Possible Impact Mitigation during Design Mitigation during Construction

Mitigation during Maintenance

Air pollution - - Spray water regularly on dry surfaces creating dust problems

- Regulate vehicle emission

-

Noise pollution - - Regulate use of horns - Avoid unnecessary noise,

especially at night

-

Destruction of land and vegetation

- Minimize need for land for construction

- Remove and store topsoil for replacing after construction

- Afforestation and grass planting of work place after works

-

Morphological changes

- Careful alignment of river bank protection works

- Monitoring of function of constructed riverbank protection works and impact on river hydraulics

- Monitoring of morphological changes

- Construction of supporting structures

- Compensation if significant changes occur

Dredging spoils - - If clay and silt in outflow water exceeds water quality standards, change site for dredging for sand

-

Deterioration of water quality

- - Prevent discharge of wastewater from labor camps

- Prevent spills of oil and lubricants from vehicles, engines, etc.

-

Disturbance to water supply

- - Establish adequate alternative water supply

-

Disturbance of wildlife

- - Avoid sand mining close to sand bars

- Minimize noise

-

Disruption of agricultural activities

- Minimize need for use of agricultural land during construction

- Minimize need to disrupt irrigation

- Reinstate land after construction

- Provide adequate land rent and compensation

- Restore irrigation facilities immediately if affected

- Provide compensation

-

Disruption of irrigation

- - Avoid disruption of irrigation channels

- Provide compensation

-

Disruption of navigation

- Provide adequate river ports and ghats

- Maintain close liaison with BIWTA

- Provide buoys and navigational lights

- Avoid sand dredging in navigational routes

- Maintain close liaison with BIWTA concerning their dredging operations

Disruption of road traffic

- Minimize need for affecting existing roads

- Maintain access to ghats - Practice caution in use of

vehicles

-

Disruption to char dwellers

- - Avoid sand mining close to inhabited chars

-

Transmission of diseases among

- - Provide health inspection and vaccination

-

Appendix 8

38

Possible Impact Mitigation during Design Mitigation during Construction

Mitigation during Maintenance

workers - Organize proper collection of wastes

- Provide adequate sanitary facilities to personnel and workers

Safety of workers - - Adopt appropriate safety measures

- Provide first aid services - Make workers aware of

risks and how to avoid these

-

BIWTA=Bangladesh Inland Water Transport Authority

Appendix 8