Initial Environmental Examination Report (Draft)
Project Number: 51152-001 December 2018
BAN: Second PRAN Agribusiness Project Part 4
Prepared by Sylvan Agriculture Limited
The initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.
In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area. Initial Environmental Examination (IEE) of PRAN potato chips, Pasta and Flakes project
ANNEX-A: ATTENDANCE SHEET OF PUBLIC CONSULTATION MEETING
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Attendance sheet of the Public Consultation Meeting
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Public Consultation Meeting at Olipur City Park, Olipur
Rashel Kabir Public consultation Meeting Senior Manager-QMS HRM, PRAN
Md. Giash Uddind Md. Ishar Ali Businessman, Suraboi Retired Police Officer
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ANNEX-B: FOCUS GROUP DISCUSSION MEETING ATTENDANCE SHEET
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Attendance sheet of FGD with the land seller group
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Attendance sheet of FGD with the Business community
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Attendance sheet of FGD with the Ethnic community
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Attendance sheet of FGD with the Local people
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Focus Group Discussion (FGD) at Olipur and adjacent to Lalchand Tea Estate
Local Participants’ participation Ethnic Participants sharing their perceptions
Businessmen Participants’ Participation Land Seller Participants’ Participation
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ANNEX-C: LAYOUT PLAN OF THE POTATO CHIPS, Pasta and Flakes PROJECT
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ANNEX-D: FLORA AND FAUNA SPECIES IN THE STUDY AREA
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Table-1: Checklist of Flora (Block survey) Common Local IUCN SL# Scientific Name Family Use Types* Name Status** Status*** 1 Eucalyptus Eucalyptus obliqua Myrtaceae Timber T C NA 2 Teak tectona grandis Lamiaceae Timber T R NA Artocarpus 3 Jackfruit Moraceae Fruits T VC NA heterophyllus clerodendrum Fuel 4 Vat Lamiaceae S VC NA infortunatum wood 5 Dumur Ficus carica Moraceae Fruit T C NA Acacia 6 Acacia Fabaceae Timber T C NA auriculiformis 7 Sal Shorea robusta Dipterocarpaceae Timber T C NA Areca 8 Areca catechu Arecaceae Fruits T VC NA palm/Supari Neolamarckia 9 Kadam Rubiaceae Timber T C NA cadamba 10 Coconut Cocos nucifera Arecaceae Fruits T VC NA 11 Peyara /Guava Psidium guajava Myrtaceae Fruits T VC NA 12 Mango Mangifera indica Anacardiaceae Fruits T VC NA 13 Bamboo Bamboo spp. Poaceae Timber T VC NA 14 Banana Musa sapientum Musaceae Fruits H VC NA 15 Date palm Phoenix dactylifera Arecaceae Fruits T VC NA Artocarpus 16 Chapalish Magnoliopsida Fruits T R NA chaplasha 17 Bokua Neem Melia spp Meliaceae Timber T C NA 18 Dumur Ficus carica Moraceae Fruits T C NA Swietenia 19 Mahagoni Meliaceae Timber T VC NA mahagoni 20 Fern Adiantum obliquum Pteridaceae Weed H VC NA 21 Zambura/pomelo Citrus maxima Rutaceae Fruits T VC NA 22 Mango Mangifera indica Anacardiaceae Fruits T VC NA Boroi/ Indian Zizyphus 23 Rhamnaceae Fruits T VC NA Jujube mauritiana 24 Mangium Acacia mangium Fabaceae Timber T C NA 25 Jam Syzygium cumini Myrtaceae Fruits T C NA Cinnamomum 26 Tejpata Lauraceae Medicinal T R NA tamala 27 Sada koroi Albizia procera Fabaceae Timber T C NA Swietenia 28 Macrophylla Meliaceae Timber T C NA macrophylla
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Common Local IUCN SL# Scientific Name Family Use Types* Name Status** Status*** Patabahar/ Codiaeum 29 Euphorbiaceae Aesthetic S C NA garden croton variegatum 30 Lemon Citrus spp. Rutaceae Fruit S VC NA 31 Rain tree Samanea saman Fabaceae Timber T C NA *Types: S-Shrubs, T-Trees, H-Herbs **Local Status: C-Common, R-Rare, VC- Very Common ***IUCN status: NA=Not Available Table-2: Checklist of Vegetation according to the Block study Plot#1 (15m*15m area of block study) Common Number of Types of SL. Scientific Name Family Name Species Species* 1 Eucalyptus Eucalyptus obliqua Myrtaceae 15 T 2 Teak Tectona grandis Lamiaceae 2 T 3 Jackfruit Artocarpus heterophyllus Moraceae 2 T 4 Vat clerodendrum infortunatum Lamiaceae 10 S *Types of species: S-Shrubs, T-Trees Plot#2
Common Number of Types of SL. Scientific name Family name species species* 1 Eucalyptus Eucalyptus obliqua Myrtaceae 10 T 2 Teak tectona grandis Lamiaceae 3 T 3 Dumur Ficus carica Moraceae 2 S 4 Acacia Acacia auriculiformis Fabaceae 2 T 5 Vat clerodendrum infortunatum Lamiaceae 120 S *Types of species: S-Shrubs, T-Trees Plot#3
Common Number of Types of SL. Scientific Name Family Name species species* 1 Eucalyptus Eucalyptus obliqua Myrtaceae 15 T 2 Teak tectona grandis Lamiaceae 2 T 3 Acacia Acacia auriculiformis Fabaceae 2 T 4 Vat clerodendrum infortunatum Lamiaceae 30 S *Types of species: S-Shrubs, T-Trees Plot#4
Common Number of Types of SL. Scientific name Family name species species* 1 Sal Shorea robusta Dipterocarpaceae 30 T
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2 Accacia Acacia auriculiformis Fabaceae 2 T *Types of species: S-Shrubs, T-Trees Homestead Forest Block survey (10 blocks each size 15m*15m) Plot#1
Number of Types of SL. Common name Scientific name Family species species* 1 Areca palm/Supari Areca catechu Arecaceae 7 T Artocarpus 2 Jackfruit Moraceae 4 T heterophyllus 3 Coconut Cocos nucifera Arecaceae 2 T 4 Peyara /Guava Psidium guajava Myrtaceae 2 T 5 Mango Mangifera indica Anacardiaceae 6 T 6 Bamboo Bamboo spp. Poaceae 110 (1 bush) T 7 Banana Musa sapientum Musaceae 2 T *Types of species: T-Trees Plot#2
Scientific Number of Types of SL. Common Name Family Name Species Species* 1 Banana Musa sapientum Musaceae 20 T 2 Mango Mangifera indica Anacardiaceae 6 T
3 Kadam Neolamarckia cadamba Rubiaceae 5 T
4 Areca palm/Supari Areca catechu Arecaceae 5 T
Artocarpus 5 Jackfruit Moraceae 3 T heterophyllus 6 Date palm Phoenix dactylifera Arecaceae 2 T 7 Eucalyptus Eucalyptus obliqua Myrtaceae 1 T 8 Acacia Acacia auriculiformis Fabaceae 1 T *Types of species: T-Trees Plot#3
Common Number of Types of SL. Scientific Name Family Name species species* 1 Teak tectona grandis Lamiaceae 3 T Areca 2 Areca catechu Arecaceae 4 T palm/Supari 3 Bamboo Bamboo spp. Poaceae 325(5 bush) T 4 Chapalish Artocarpus chaplasha Magnoliopsida 1 T 5 Mango Mangifera indica Anacardiaceae 1 T 6 Bokua Neem Melia spp Meliaceae 1 T
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7 Dumur Ficus carica Moraceae 1 S 8 Mahagoni Swietenia mahagoni Meliaceae 1 T clerodendrum Lamiaceae 9 Vat 70 S infortunatum 10 Fern Adiantum obliquum Pteridaceae 50 S *Types of species: S-Shrubs, T-Trees Plot#4
Number of Types of SL. Common name Scientific name Family species species* 1 Zambura/pomelo Citrus maxima Rutaceae 2 T 2 Mango Mangifera indica Anacardiaceae 6 T Boroi/ Indian 3 Zizyphus mauritiana Rhamnaceae 1 T Jujube 4 Acacia Acacia auriculiformis Fabaceae 3 T 5 Mangium Acacia mangium Fabaceae 3 T 6 Bamboo Bamboo spp. Poaceae 370 (4 bush) T 7 Coconut Cocos nucifera Arecaceae 2 T *Types of species: T-Trees Plot#5
Number of Types of SL. Common name Scientific name Family species species* 1 Mango Mangifera indica Anacardiaceae 6 T 2 Areca palm/Supari Areca catechu Arecaceae 4 T 3 Bamboo Bamboo spp. Poaceae 310(1 bush) T 4 Jam Syzygium cumini Myrtaceae 2 T 5 Peyara /Guava Psidium guajava Myrtaceae 3 T 6 Eucalyptus Eucalyptus obliqua Myrtaceae 4 T 7 Banana Musa sapientum Musaceae 10 T *Types of species: T-Trees Plot#6
Number of Types of SL. Common name Scientific name Family species species* 1 Mango Mangifera indica Anacardiaceae 10 T 2 Peyara /Guava Psidium guajava Myrtaceae 3 T Cinnamomum 3 Tejpata Lauraceae 2 T tamala 4 Coconut Cocos nucifera Arecaceae 2 T 5 Zambura/pomelo Citrus maxima Rutaceae 4 T
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Zizyphus 6 Boroi/ Indian Jujube Rhamnaceae 2 T mauritiana clerodendrum 7 Vat Lamiaceae 110 S infortunatum *Types of species: S-Shrubs, T-Trees Plot#7
Number Types of SL. Common name Scientific name Family of species species*
1 Mango Mangifera indica Anacardiaceae 10 T 2 Acacia Acacia auriculiformis Fabaceae 15 T 3 Mangium Acacia mangium Fabaceae 5 T 4 Areca palm/Supari Areca catechu Arecaceae 5 T 5 Peyara /Guava Psidium guajava Myrtaceae 3 T 6 Sada koroi Albizia procera Fabaceae 2 T Neolamarckia 7 Kadam Rubiaceae 5 T cadamba 8 Fern Adiantum obliquum Pteridaceae 30 S *Types of species: S-Shrubs, T-Trees Plot#8
Number Types of SL. Common Name Scientific Name Family of Species Species*
1 Areca palm/Supari Areca catechu Arecaceae 5 T 2 Mango Mangifera indica Anacardiaceae 3 T 3 Jam Syzygium cumini Myrtaceae 5 T Swietenia 4 Macrophylla Meliaceae 2 T macrophylla Fabaceae 5 Acacia Acacia auriculiformis 2 T
6 Bamboo Bamboo spp. Poaceae 50(1 bush) T Patabahar/ garden Codiaeum 7 Euphorbiaceae 1 S croton variegatum *Types of species: S-Shrubs, T-Trees Plot#9
Number Types of SL. Common Name Scientific Name Family of Species Species*
1 Acacia Acacia auriculiformis Fabaceae 2 T 2 Mangium Acacia mangium Fabaceae 2 T 3 Mahagoni Swietenia mahagoni Meliaceae 3 T 4 Mango Mangifera indica Anacardiaceae 2 T
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5 Jackfruit Artocarpus heterophyllus Moraceae 5 T 200 (4 6 Bamboo Bamboo spp. Poaceae T bush) 7 Peyara /Guava Psidium guajava Myrtaceae 5 T 8 Lemon Citrus spp. Rutaceae 3 S 9 Zambura/pomelo Citrus maxima Rutaceae 2 T *Types of species: S-Shrubs, T-Trees Plot#10
Number of Types of SL. Common Name Scientific Name Family Species Species* 1 Bamboo Bamboo spp. Poaceae 870 (10 bush) T 2 Mango Mangifera indica Anacardiaceae 2 T Artocarpus 3 Jackfruit Moraceae 5 T heterophyllus 4 Rain tree Samanea saman Fabaceae 2 T 5 Teak tectona grandis Lamiaceae 2 T *Types of species: T-Trees Table-3: Photographs of Flora
Pitraj- Aphanamixis polystachya Segun(Teak)- Tectona grandis Sal- Shorea robusta
Akondo- Calotropis gigantea Banana -Musa sapientum Kadam- Neolamarckia cadamba
Mahagoni - Swietenia Mahagoni Arjun-Terminalia arjuna Ghoraneem-Melia azedarach
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Acacia (Akashmoni)- Acacia Supari-Areca catechu Guava-Psidium guajava auriculiformis
Fern- Adiantum obliquum Mangium-Acacia mangium Desi Neem-Azadirachta indica
Vati- clerodendrum Mikania cordata Boroi- Zizyphus mauritiana infortunatum
Kathal- Artocarpus Zambura- Citrus maxima Dumur-Ficus carica heterophyllus
Mango-Mangifera indica Sensative tree-Mimosa Pudica Alaci Lemon(Feronia limon)
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Neem (Bokna, Hybride) Melia Boroi - Zizyphus mauritiana Khuksa- ficus hispida spp.
Tela kochu-Eoccinia cordifolia Jam- Syzygium cumini Dumur- Ficus racemosa
Bamboo- Bambusa spp Eucalyptus -Eucalyptus obliqua Cotton tree -Bombax ceiba
Raintree-S. Saman Palm tree-Borassus flabellifer Sil Koroi- Albizia procera
Tea indicator tree-Melastoma Ruber-Hevea brasiliensis Chalta- Dillenia indica malabatricum
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Patabahar- Codiaeum Fishtail Palm tree- caryota Pineapple- Ananas comosus variegatum obtusa
Papaya -Carica papaya Banyan tree- Ficus benghalensis
Table-4: Checklist of homestead vegetation of 5 Km radius Global Type Local SL Common Scientific IUCN Family Name of Uses Status # Name Name Status* tree * * Timber & 1. Aromita Fabaceae Acacia aroma Tree C NA fuelwood Aegle Fruit & 2. Stone apple Rutaceae Tree R NA marmelos Medicine Albizia Timber and 3. White siris Leguminosae Tree C NA procera fuel wood Blackboard Alstonia 4. Apocynaceae Tree Timber R LC tree scholaris Anthocephalu Timber and 5. Kadam Rubiaceae Tree C NA s chinensis fuel wood Betel nut Fruit and 6. Palmae Areca catechu Tree R NA palm Timber Fruit, Artocarpus 7. Jackfruit Moraceae Tree Timber and C NA heterophyllus fuel wood Averrhoa 8. Starfruit Averrhoaceae Tree Fruit C NA carambola Azadirachta Timber and 9. Neem Meliaceae Tree C NA indica medicine 10. Bamboo Gramineae Bambusa sp. Tree Thatching VC NA Freshwater Barringtoniacea Barringtonia 11. Shrub Fuel wood C NA Mangrove e acutangula Cotton and 12. Cotton tree Bombacaceae Bombax ceiba Tree C NA Fuel wood Calamus Calamus 13. Palmae Shrub Thatching R LC palm tenuis www.eqmsbd.com Sylvan Agriculture Limited 180 Ref: # 0017820106 October 2017
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Global Type Local SL Common Scientific IUCN Family Name of Uses Status # Name Name Status* tree * * 14. Papaya Caricaceae Carica papaya Shrub Fruit C NA Medicine Centella 15. Kola Umbelliferae Herb and C NA asitica Vegetables Queen of Cestrum 16. Compositae Shrub Ornamental R NA the night nocturnum 17. Pomelo Rutaceae Citrus grandis Tree Fruit C NA Cocos Fruit and 18. Coconut Palmae Tree VC NA nucifera Fuel wood Indian Dalbergia Timber and 19. Fabaceae Tree R NA Rosewood sissoo fuel wood Angel's Datura 20. Solanaceae Herb Medicine R NA trumpet meteloides Elephant 21. Dilleniaceae Dillenia indica Tree Fruit R NA apple Diospyros 22. Velvet Apple Ebanaceae Tree Fruit C NA discolor Diospyros 23. Gaabh Herb Ebanaceae Tree Fruit C NA peregrina Erythrina 24. Coral bean Leguminosae Tree Fuel wood C NA ovalifolia Ficus 25. Bengal fig Moraceae Tree Fuel wood C NA benghalensis Fruit and 26. Hairy Fig Moraceae Ficus hispida Tree VC NA Fuel wood Giant Crape- Lagerstromia Ornamental 27. Lythraceae Tree R NA myrtle speciosa and Timber Litchi 28. Lychee Sapindaceae Tree Fruit C NA chinensis Mangifera Fruit and 29. Mango Anacardiaceae Tree VC NA indica Timber Moringa 30. Miracle Tree Moringaceae Tree Vegetable C NA oleifera Musa paradisiaca 31. Banana Musaceae Herb Fruit VC NA var. sapientum Ocimum 32. Hoary basil Labiatae Herb Medicine R NA americanum Pandanus 33. Screwpine Pandanaceae Shrub Ornamental R NA utilis Psidium 34. Guava Myrtaceae Shrub Fruit C NA guajava Golden Spondias 35. Anacardiaceae Tree Fruit R NA apple dulcis
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Global Type Local SL Common Scientific IUCN Family Name of Uses Status # Name Name Status* tree * * Siamese 36. Urticaceae Streblus asper Shrub Fuel wood C NA rough bush EN Swietenia Timber and 37. Mahogany Meliaceae Tree C (Locally mahagoni medicine available) Syzygium 38. Java plum Myrtaceae Tree Fruit R NA cumini Tamarindus 39. Tamarind Leguminosae Tree Fruit C NA indica Tectona 40. Teak Verbenaceae Tree Timber C NA grandis Terminalia Timber and 41. Arjun Combretaceae Tree C NA arjuna medicine Fruit, Tropical Terminalia 42. Combretaceae Tree Timber & R NA almond catappa fuel wood Chinese Vitex 43. Verbenaceae Shrub Medicine R NA chastetree negundo Indian Zizyphus 44. Rhamnaceae Tree Fruit VC NA jujube mauritiana Carissa 45. Karanda Apocynaceae Shrub Fruit C NA carandas Night- Nyctanthes 46. flowering Oleaceae Shrub Ornamental C NA arbortristis Jasmine Passiflora Climb Fruit & 47. Passion fruit Passifloraceae VR NA edulis er Ornamental Ananas Fruit & 48. Pineapple Bromeliaceae Shrub C NA comosus medicine Sweet Ipomoea 49. Convolvulaceae Herb Fruit C NA potato batatas Gmelina 50. Beechwood Lamiaceae Tree Timber C NA arborea Averrhoa 51. Tree sorrel Oxalidaceae Tree Fruit C NA bilimbi Ixora 52. Rangan Rubiaceae Shrub Ornamental C NA Coccinea Hibiscus rosa- 53. Hibiscus Malvaceae Shrub Ornamental VC NA sinensis VU (Locally it Royal 54. Fabaceae Delonix regia Tree Ornamental R has good Poinciana number of tree) Baccaurea 55. Latkan Euphorbiaceae Tree Fruit R NA sapida
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Global Type Local SL Common Scientific IUCN Family Name of Uses Status # Name Name Status* tree * * Sugar- Annona 56. Annonaceae Tree Fruit C NA pineapple squamosa 57. lemon Rutaceae Citrus limon Shrub Fruit VC NA Eucalyptus 58. Eucalyptus Myrtaceae Tree Timber C NA obliqua Pachyrhizus Climb 59. Yam Bean Fabaceae Vegetable VC NA erosus er Samanea 60. Rain Tree Fabaceae Tree Timber C NA saman Indian Acalypha 61. Euphorbiaceae Herb Medicinal C NA acalypha indica Prickly Chaff Achyranthes 62. Amaranthaceae Herb Medicinal C NA Flower aspera Spiny Amaranthus 63. Amaranthaceae Herb Medicinal VC NA amaranth spinosus Crown Calotropis 64. Asclepiadaceae Shrub Medicinal C NA flower gigantea Chenopodium 65. Epazote Chenopodiaceae Herb Medicinal C NA ambrosioides Cotula Buttonweed 66. Compositae hemisphaeric Herb Medicinal VC NA s a Australian Cuscuta 67. Convolvulaceae Herb Medicinal C NA Dodder australis Creeping Dentella 68. Rubiaceae Herb Medicinal C NA lickstoop repens Sesbania 69. Sesbania Leguminosae Shrub fuelwood VC NA rostrata 70. Rorippa Cruciferae Rorippa indica Herb Medicinal C NA *Local Status: C-Common, R-Rare, VC-Very Common, VR-Very Rare **Global IUCN Status: NA-Not Available, LC- Least concern, EN-Endangered, VU-Vulnerable Table-5: Checklist of Agricultural land Species Local SL# Common Name Scientific Name Family IUCN Status status*
1 Paddy /dhan Oryza sativa Poaceae VC Not Available
2 Topa pana Pistia stratioites Araceae C Not Available 3 Khudi pana Lemna minor Lemnaceae VC Not Available 4 yellow sawah lettuce Limnocharis flava Araceae C Not Available 5 Oxalis oxalis spp. oxalidaceae C Not Available Abelmoschus 6 Okra Malvaceae VC Not Available esculantus 7 Chili Capsicum frutescens Solanaceae VC Not Available
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Amaranthus 8 Helencha convolvulaceae VC Not Available philoveroides 9 Field Mustard Brassica rapa Brassica VC Not Available 10 Mutha Cyperus rotundus Cyperaceae C Not Available *Local status: C-Common, R-Rare, VC-Very Common Table-6: Checklist of Fallow land Species Local SL# Common name Scientific name Family IUCN status status* 1 Kochu colocasia esculenta Araceae VC Not available 2 Shame plant Mimusa pudica Mimosaceae C Not available 3 Durba Cynodon doctylon Poaceae VC Not available 4 Black nightshade Solanum nigrum solanaceae C Not available 5 Amaranthus spinosus Amaranthus spinosa Amaranthaceae VC Not available Nicotiana 6 Tobacco plant Solanaceae R Not available plumbaginifolia 7 Goma flower/Dron Leucas indica Lamiaceae C Not available Aleroden 8 Vat Verbenaceae VC Not available dronviscosum 9 Native Gooseberry physalis minima Solanaceae C Not available 10 Mutha Cyperus rotundus Cyperaceae VC Not available 11 Ironweed Vernonia cinerea Asteraceae C Not available Kontikori/ Yellow-fruit Solanum 12 Solanaceae C Not available nightshade xanthocarpum 13 Urena Urena lobata Malvaceae C Not available 14 Jhonjhoni ful Crotalaria pallida Fabaceae R Not available Triumfetta 15 diamond burbark Malvaceae C Not available rhomboidea 16 Choto dhutora Xanthium indicum Asteraceae R Not available 17 Hati sur Heliotropium indicum Boraginaceae R Not available 18 Frog fruits Phyla nodiflora Verbenaceae C Not available *Local status: C-Common, R-Rare, VC-Very Common Table-7: Checklist of Grassland Local SL# Common name Scientific name Family IUCN status status* 1 Mutha Cyperus rotundus Cyperaceae C Not Available 2 Durba Cynodon doctylon Poaceae VC Not Available 3 Helencha Enhydra fluctuans Asteraceae C Not Available 4 Alternanthera Alternanthera caracasana Amaranthaceae R Not Available 5 Caesarweed Urena lobata Malvaceae - Not Available 6 Acrachne Acrachne racemosa Poaceae C Not Available
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7 Common grass Oplismenus compositus Poaceae C Not Available 8 Common grass Paspalum scrobiculatum Poaceae C Not Available 9 Common grass Chrysopogon aciculatus Poaceae VC Not Available 10 Common grass Eleusine indica Poaceae C Not Available 11 Water Spinach Ipomoea reptans Convolvulaceae VC Not Available 12 Vhadale Kyllinga nemoralis Cyperaceae VC Not Available *Local status: C-Common, R-Rare, VC-Very Common Table-8: Checklist of Aquatic vegetation Local SL. Common Name Family Name Scientific Name IUCN Status status* Alternanthera 1 Alligator weed Amaranthaceae C Not available philoxeroides Feathered 2 Salviniaceae Azolla pinnata C Not available mosquito fern 3 Water Sprite Pteridaceae Ceratopteris thalictroides C Not available 4 Coco yam Araceae Colocasia esculenta VC Not available 5 Flatsedge Cyperaceae Cyperus sp. VC Not available Common water 6 Pontaderiaceae Eichhornia crassipes VC Not available hyacinth 7 Helencha Cyperaceae Enhydra fluctuans VC Not available Swamp morning- 8 Convolvulaceae Ipomoea aquatica VC Not available glory 9 Minute duckweed Lemnaceae Lemna perpusilla C Not available
10 Four Leaf Clover Mersileaceae Marsilea quadrifolia C Not available Arrow Leaf 11 Pontaderiaceae Monochoria hatata C Not available Pondweed 12 Water Lily Nymphaeaceae Nymphaea nouchali VC Not available
13 Tall reed Gramineae Phragmites karka VC Not available
14 Vetivergrass Gramineae Vetiveria zizanioides C Not available
15 Jointweed Polygonaceae Polygonum barbatum C Not available Denseflower 16 Polygonaceae Polygonum glabrum C Not available knotweed 17 Bishkatali Polygonaceae Polygonum lanatum C Not available 18 Asian Watermoss Salviniaceae Salvina cucullata C Not available Common 19 Lemnaceae Spirodela polyrhiza C Not available duckweed 20 Watermeal Lemnaceae Wolffia microscopica C Not available Sticky 21 Solanaceae Solanum sisymbriifolium C Not available Nightshade
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Local SL. Common Name Family Name Scientific Name IUCN Status status*
22 Water lettuce Araceae Pistia stratiotes C Not available *Local status: C-Common, VC-Very Common Table-9: Checklist of Birds Species IUCN Red SL List Status Local Name English Name Scientific Name Family # (Regional) * Tila Ghughu, Telia Eastern Spilopelia 1 Columbidae LC Ghughu Spotted Dove chinensis Boro Kubo, Centropus 2 Greater Coucal Cuculidae LC Kanakukhra, Kukka sinensis Little Phalacrocoracidae 3 Chhoto pankouri Microcarbo niger LC Cormorant Shonkho Chil, Lal Accipitridae 4 Brahminy Kite Haliastur Indus LC Chil 5 Bhubon Chil Black Kite Milvus migrans Accipitridae LC Common 6 Pati Hoodhood Upupa epops Upupidae LC Hoopoe Shobuj Shuichora, Green Bee- 7 Merops orientalis Meropidae LC Banspati eater Coracias 8 Indian Roller Indian Roller Coraciidae LC benghalensis Common 9 Pati Maachranga Alcedo atthis Alcedinidae LC Kingfiher DholagolaMaachran White-throated Halcyon 10 Alcedinidae LC ga Kingfiher smyrnensis Psilopogon 11 Dagi Boshonto Lineated Barbet Megalaimidae LC lineatus Common Dinopium Picidae 12 Pati Kaththokra LC Flameback javanense Fulvous- Dendrocopos Picidae 13 Batabi Kathkurali breasted LC macei Woodpecker Streak-throated Picus 14 Dagigola Kathkurali Picidae LC Woodpecker xanthopygaeus Metematha Black-naped 15 Picus guerini Picidae LC Kathkurali Woodpecker 16 Pati Fotikjol, Towfi Common Iora egithina tiphia Aegithinidae LC 17 Khoira Latora Brown Shrike Lanius cristatus Laniidae LC 18 Lenja Latora, Long-tailed Lanius schach Laniidae LC
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IUCN Red SL List Status Local Name English Name Scientific Name Family # (Regional) * Baghatiki Shrike Black-hooded Oriolus 19 Kalamatha Benebou Oriolidae LC Oriole xanthornus Dicrurus 20 Kala Fingey Black Drongo Dicruridae LC macrocercus Dendrocitta Corvidae 21 Hari Chacha Rufous Treepie LC vagabunda 22 Pati Kak House Crow Corvus splendens Corvidae LC Red-vented 23 Bangla Bulbul Pycnonotus cafer Pycnonotidae LC Bulbul Common Orthotomus 24 Pati Tuntuni Cisticolidae LC Tailorbird sutorius Striated Megalurus 25 Dagi Ghaspakhi Locustellidae LC Grassbird palustris Leiothrichidae 26 Bon Satarey Jungle Babbler Turdoides striata LC
Asian Pied 27 Pakra Shalik Sturnus contra Sturnidae LC Starling Chestnut-tailed Sturnus Sturnidae 28 Khoiralej Kathshalik LC Starling malabaricus Acridotheres Sturnidae 29 Bhat Shalik Common Myna LC tristis Oriental Magpie Copsychus 30 Doel Muscicapidae LC Robin saularis Nectarinia Nectariniidae 31 Beguni Moutushi Purple Sunbird LC asiatica Passer Passeridae 32 Pati Chorui, House Sparrow LC domesticus 33 Gang salik Pied myna Gracupica contra Sturnidae LC 34 Dhar kak Common raven Corvus corax Corvidae LC Streptopelia 35 Ghugu Ring neck dove Chordata LC capicola 36 Sada bok Great egret Ardea alba Ardeidae LC Coppersmith Megalaima 37 barbet Megalaimidae LC barbet haemacephala *IUCN Red List Status (Regional): LC-Least Concern
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Table-10: Photographs of Birds species
Red-vented Bulbul Brown Shrike Green Bee-eater
Brahmini Kite Long tailed shrike Eastern Spotted Dove
Lineated barbet Brahmini Kite Striated Grassbird
Purple-rumped Sunbird- female Little Cormorant White Breasted Kingfisher
Common Iora Common Myna Greater Coucal
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Jungle Babbler Cuckoo Oriantal Magpie Robin
Common Kingfisher Purple-rumped Sunbird- male Black Drongo
Jungle Mayna Asian Stonechat chestnut-tailed starling
Common Tailorbird Streak-throated Woodpecker Black hooded oriole
Fulvous-breasted Woodpecker Coppersmith barbet House Sparrow
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Pond heron White pond egret Pied myna
Common raven Black Jungle Babbler Ring neck dove
Red-whiskered bulbul Female house sparrow Table-11: Checklist of Amphibian and Reptiles IUCN Red Local SL. English Name Scientific Name Family List Status Name (Regional)* Common House 1 Tiktiki Hemidactylus frenatus Gekkonidae LC Gecko Common Garden Lampropholis 2 Anjoni Scincidae DD Skink guichenoti 3 Bezi Mongoose Varanus flavescens Varanidae NT Kono Duttaphrynus 4 Asian Common Toad Bufonidae LC bang melanostictus Dhura 5 Checkered keel back Xenochrophis piscator Colubridae LC sap Geso Two-striped 6 Rana taipehensis Ranidae LC bang grassfrog
7 frog Common Indian Polypedates maculatus Rhacophoridae LC
*IUCN Red List Status (Regional): LC= Least concern, DD=Data deficient, NT= Near Threaten
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Table-12: Photographs of Amphibian and reptiles
Common House Gecko Garden Lizard Giu sanke
Asian Common Toad Table-13: Checklist of Mammals IUCN Red SL. English Name Scientific Name Family List Status (Regional)* 1 Small Asian mongoose Herpestes javanicus Herpestidae LC 2 Mongoose Varanus flavescens Varanidae LC 3 Golden Jackal Canis aureus Canidae LC 4 Assam Rabbit caprolagus hispidus Leporidae DD 5 small Indian civet Viverricula indica Viverridae NT 6 Rhesus macaque Macaca mulatta Cercopithecidae VU 7 Irrawardy Squirrel Callosciurus pygerythrus Sciuridae LC 8 Greater short-nosed fruit bat Cynopterus sphinx Pteropodidae LC 9 Little Indian field mouse Mus booduga Muridae LC 10 House mouse Mus musculus Muridae LC 11 Roof Rat Rattus rattus Muridae LC *IUCN Red List Status (Regional): LC= Least concern, DD=Data deficient, NT= Near Threaten, VU- Vulnerable Table-14: Photographs of Mammals
Wild Animal identification by Small Asian mongoose Greater short-nosed fruit bat Feces at the project area
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Small Indian civet (source Assam Rabbit House mouse internet)
Wild Animal identification by Rhesus macaque Irrawardy Squirrel Feces at the project area Table-15: Checklists of Butterflies IUCN Red SL. English Name Scientific Name Family List Status (Regional)*
1 Common Grass Yellow Eurema hecabe Pieridae LC 2 Psyche Leptosia nina Pieridae LC 3 Tiny Grass Blue Zizula hylax Lycaenidae LC 4 Lime Blue Chilades laius Lycaenidae LC 5 Grey Pansy Junonia atlites Nymphalidae LC 6 Dark Grass Blue Zizeeria karsandra Lycaenidae LC 7 punchinello Zemeros flegyas Riodinidae LC 8 Redbase Jezebel Delias pasithoe Pieridae LC
9 Common evening brown Melanitis leda Nymphalidae LC
10 Common Sailer Neptis hylas Nymphalidae LC 11 Bengal large swift Pelopidas subochracea Hesperiidae LC 12 peacock pansy Junonia almana Nymphalidae LC 13 Mottled emigrant Catopsilia pyranthe Pieridae LC *IUCN Red List Status (Regional): LC- Least Concerned
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Table-16: Photographs of Butterflies
Psyche Tiny Grass Blue Lime Blue
Dark Grass Blue Common Grass Yellow Grey Pansy
Common evening brown Punchinello Common evening brown
Bengal large swift peacock pansy Common Sailer
Mottled emigrant Redbase Jezebel
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Table-17: Checklist of Dragonflies and Damselflies SL. English Name Scientific Name Family Local Status* 1 Scarlet Marsh Hawk Aethriamanta brevipennis Libellulidae C 2 Ditch Jewels Brachythemis contaminata Libellulidae C 3 Ruddy Marsh Skimmer Crocothemis servilia Libellulidae C 4 Pied Paddy Skimmer Neurothemis tullia Libellulidae C 5 Fulvous Forest Skimmer Neurothemis fulvia Libellulidae C 6 Coromandel Marsh Dart Ceriagrion coromandelianum Coenagrionidae C *Local Status: C-Common, by local expert assessment Table-18: Pictures of Dragonflies and Damselflies
Scarlet Marsh Hawk Ditch Jewel Pied Paddy Skimmer
Fulvous Forest Skimmer Coromandel Marsh Ruddy Marsh Skimmer Table-19: Checklist of Fish species consider 5km Radius IUCN Red Local List Status SL# English Name Scientific Name Family Name Bangladesh 2015* Macrognathus 1 Tara balm One stripe spiny eel Mastacembelidae NT aculeatus Macrognathus 2 Guchi Baim Striped spiny eel Mastacembelidae LC pancalus Mastacembelus 3 Sal Balm Tire-track spiny Eel Mastacembelidae EN armatus 4 Khailsha Giant gourami Colisa fasciata Osphronemidae LC Lal 5 Red gourami Colisa lalia Osphronemidae LC Khalisha 6 Koi Climbing perch Anabas testudineus Anabantidae LC Dermogenus 7 Ek Thuita Wrestling hal fbeak Hemiramphidae LC pusillus
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IUCN Red Local List Status SL# English Name Scientific Name Family Name Bangladesh 2015* 8 Bele Tank goby Glossogobius giuris Gobiidae LC 9 Bheda Mud perch Nandus nandus Nandidae NT 10 Chanda Glass-Perchlet Pseudambassis lala Ambassidae LC Lomba Elongate glass 11 Chanda nama Ambassidae LC Chanda perchlet Ranga 12 Indian glassy Fish Parambassis ranga Ambassidae NT Chanda 13 Kuicha Freshwater eel Monopterus cuchia Synbranchidae VU 14 Shol Striped snakehead Channa striatus Channidae LC 15 Gajar Giant Snakehead Channa marulius Channidae EN 16 Taki Spotted Snakehead Channa punctatus Channidae LC 17 Telo taki Asiatic Snakehead Channa orientalis Channidae LC 18 Ragha Walking Snakehead Channa gachua Channidae LC 19 Kaikka Needle fish Xenentodon cancila Belonidae LC Heteropneustes 20 Shing Stinging catfish Heteropneustidae LC fossilis 21 Magur Air breathing Catfish Clarias batrachus Clariidae LC Pangasius 22 Pangas Yellowtail Catfish Pangasiidae EN hypophthalmus 23 Gharua Garu bacha Clupisoma garua Schilbeidae EN 24 Kikjuji Gangetic alilia Ailia colia Schilbeidae LC 25 Banspata River catfish Ailia punctata Schilbeidae LC 26 Bacha Bacha Eutropiicthys vacha Schilbeidae LC Eutropiicthys 27 Muri bacha Indus Garua Schilbeidae LC murius Pseudeutropius 28 Batasi Indian potasi Schilbeidae LC alherinoides 29 Pabda Indian butter Catfish Ompok pabda Siluridae EN 30 Boal Freshwater shark Wallago attu Siluridae VU Madhu 31 Patio catfish Ompok pabo Siluridae CR pabda Boali 32 Butter catfish Ompok bimaculatus LC pabda Scincidae 33 Tengra Striped dwarf Catfish Mystus vittatus Bagridae LC Golsha 34 Gangetic Mystus Mystus bleekeri Bagridae LC tengra 35 Bujuri- Tengra Mystus tengara Bagridae EN
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IUCN Red Local List Status SL# English Name Scientific Name Family Name Bangladesh 2015* tengra Long-whiskered 36 Ayre Sperata aor Bagridae VU Catfish Lepidocephalichthys 37 Gutum Cross fish Cobitidae LC guntea Lepidocephalicithys 38 Puiya Annandalle loach Cobitidae LC annandalei 39 Rani Bengal loach Botia Dario Cobitidae EN 40 Rui Rohu Labeo rohita Cprinidae LC 41 Catla Catla Catla catla Cyprinidae LC 42 Mrigel Mrigal Cirrhinus mrigala Cyprinidae NT 43 Kalibaus Orange fin labeo Labeo calbasu Cyprinidae LC Bhangon 44 Bata labeo Labeo bata Cyprinidae LC Bata Bhangna, 45 Reba Cirrhinus reba Cyprinidae NT Bata 46 Sarpunti Olive barb Puntius sarana Cyprinidae NT 47 Chola Punti Swamp barb Puntius chola Cyprinidae LC Ghora 48 Securicula gora Cyprinidae NT Chela 49 Tit punti Ticto barb Puntius ticto Cyprinidae VU 50 Jat punti Pool barb Puntius stigma Cyprinidae LC 51 Mola Punti Glass barb Puntius guganio Cyprinidae LC 52 Bashpata Bengal danio Devario devario Cyprinidae LC 53 Bhangon Bogalabeo Labeo boga Cyprinidae CR Amblypharyngodon 54 Mola Mola carplet Cyprinidae LC mola Amblypharyngodon 55 Mola Indian carplet Cyprinidae LC microlepis 56 Dhela Cotio Osteobrama cotio Cyprinidae NT 57 Khoira Indian grassBarb Chela laubuca Cyprinidae LC 58 Tatkini Kala bata Crosocheilus latius Cyprinidae EN 59 Dankina RasboraFinescale Rasbora rasbora Cyprinidae NT 60 Fulchela RazorbellyMinnow Salmostoma phulo Cyprinidae NT 61 Chela Silverrazorbellyminnow Salmostoma bacaila Cyprinidae LC Devario 62 Chebli Gaint danio Cyprinidae DD aequipinnatus
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IUCN Red Local List Status SL# English Name Scientific Name Family Name Bangladesh 2015* 63 Teri punti Onespot barb Puntius terio Cyprinidae LC 64 Ghonia Boggut labeo Labeo boggut Cyprinidae VU 65 Chital HumpedFeatherback Chitala chitala Notopteridae EN Notopterus 66 Foil GreyFeatherback Notopteridae VU notopterus Gangetic hair fin 67 Phasa Setipinna phasa Engraulidae LC Anchovy 68 Chapila Indian rivershad Gudusia chapra Clupeidae VU 69 Choukka Indian pellona Pellona ditchela Pristigasteridae LC Chandana 70 Toil shad Tenualosa toli Clupeidae LC ilish 71 Kachki Ganges river spart Corica soborna Clupeidae LC 72 Tepa Gangetic puffer Fish Chelonodon patoca Tetraodontidae DD 73 Khorsula Corsula mullet Rhinomugil corsula Mugilidae LC Anguilla 74 Bao Baim Giant Mottled Eel Anguillidae VU bengalensis
75 Baghair Gangetic goonch Bagarius bagarius Sisoridae CR * IUCN Red List Status Bangladesh 2015: LC- Least Concern, DD- data Deficient, VU-Vulnerable, CR-Critical, EN- Endanger, NT-Near Threaten
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ANNEX-E: SCREENING AND SCOPING REPORT
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SCOPING REPORT FOR INITIAL ENVIRONMENTAL EXAMINATION (IEE) OF PRAN POTATO CHIPS PROJECT
Prepared for: Sylvan Agriculture Limited (SAL)
Prepared by: EQMS Consulting Limited
January 2017
www.eqmsbd.com www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017
Scoping Report
Initial Environmental Examination (IEE) of PRAN Potato Chips Project
January 2017
Reviewed & Approved by:
Kazi FarhedIqubal Executive Director
This report has been prepared and reviewed by EQMS company, with all responsible skill, care and diligence within the terms of the Contact with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 i TABLE OF CONTENTS TABLE OF CONTENTS ...... ii LIST OF TABLES ...... iii LIST OF FIGURES ...... iii LIST OF ABBRVIATION ...... iv 1. INTRODUCTION ...... 1 1.1 Introduction ...... 1 1.2 Background ...... 1 1.3 EQMS Purpose and Objectives ...... 1 1.4 EQMS Approach and Methodology ...... 2 1.4.1 Screening ...... 2 1.4.2 Categorization ...... 2 1.4.3 Scoping ...... 2 1.4.4 Reporting ...... 3 1.5 Limitation ...... 3 1.6 Layout of this report ...... 3 2. PROJECT DESCRIPTION ...... 4 2.1 Location of the Project ...... 4 2.2 Key features of the project site and surroundings...... 4 2.3 Access Road ...... 5 2.4 Description about the project ...... 5 2.4.1 Product description ...... 5 2.4.2 Production Capacity ...... 6 2.4.3 Process flowchart ...... 6 3. ADMINISTRATIVE FRAMEWORK ...... 8 A. Bangladesh Environmental Policy, Regulations, and Guidelines ...... 8 3.1 Government Environmental Policy, Regulations, and Guidelines ...... 8 3.1.1 National Environmental Policy, 1992 ...... 8 3.1.2 National Environment Management Action Plan (NEMAP), 1995 ...... 8 3.1.3 The Environment Conservation Act, 1995 and subsequent amendments ...... 9 3.1.4 Environment Conservation Rules, 1997 and subsequent amendments ...... 9 3.1.5 The EIA Guidelines for Industry, 1997 ...... 10 3.2 Relevant National Polices ...... 10 3.3 Environmental Clearance ...... 11 3.3.1 Requirement of the DoE, Bangladesh ...... 11 3.3.2 Environmental and Social Requirements of the Asian Development Bank ...... 12 3.3.3 International Finance Corporation (IFC)’ World Bank Group; Environmental, Health, and Safety (EHS) Guidelines (Food and Beverage Processing) ...... 14 4. ENVIRONMENTAL SCREENING AND CATEGORIZATION ...... 16 4.1 Project classification as per DOE, MoEF, Bangladesh...... 16 4.2 Project classification as per ADB Safeguard Policy Statement ...... 16 5. PRELIMINARY STAKEHOLDERS MAPPING ...... 19 6. KEY ENVIRONMENTAL AND SOCIAL RISK ...... 21 6.1 Key Environmental Risks ...... 21 www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 ii 6.2 Social Risks ...... 23 7. APPROACH AND METHODOLOGY ...... 25 7.1 Introduction ...... 25 7.2 Establishment of Environmental and Social Baseline ...... 26 7.2.1 Study Area ...... 26 7.2.2 Environmental and Social Baseline Data Collection ...... 26 7.2.3 Stakeholder Engagement & Analysis...... 28 7.2.4 Impact Assessment ...... 28 7.2.5 Risk Assessment ...... 29 7.2.6 Environmental Management Plan (EMP) ...... 29 7.2.7 IEE report Format ...... 30 8. Work Plan...... 31 Annex-A: Rapid Environmental Assessment (REA) Checklist ...... 32 Annex-B: Involuntary Resettlement (IR) Assessment Checklist ...... 35 Annex-C: Indigenous People (IP) Assessment Checklist ...... 36 Annex-D: Photographs during screening study ...... 38
LIST OF TABLES Table 2-1: Salient features of the site and surroundings ...... 4 Table 2-2: Product Description ...... 5 Table 2-3: Product ingredients information ...... 6 Table 3-1: National Legal Instruments ...... 10 Table 3-2: Effluent Standard level for food and beverage processing project ...... 15 Table 4-1: Project Categorization as per ADB Safeguards ...... 16 Table 5-1: Stakeholder Mapping ...... 19 Table 7-1: Primary Baseline Data to be collected ...... 26 Table 8-1: Work plan for conducting the IEE study ...... 31
LIST OF FIGURES Figure 2-1: Location Map of Project Site ...... 4 Figure 2-2: Process Flow Chart ...... 7 Figure 3-1: Process of getting ECC at DoE for different categorized project ...... 12 Figure 7-1: Approach for the proposed project IEE Study ...... 25 Figure 7-2: Impact Assessment Process ...... 29
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 iii LIST OF ABBRVIATION ADB Asian Development Bank BBS Bangladesh Bureau of Statistics BD Bangladesh BDS Bangladesh Standard BIWTA Bangladesh Inland Water Transport Authority BMD Bangladesh Meteorological Department BOD Biochemical Oxygen Demand BSTI Bangladesh Standards and Testing Institution BWDB Bangladesh Water Development Board COD Chemical Oxygen Demand CO2 Carbon Dioxide CO Carbon Monoxide DoE Department of Environment DG Director General ECC Environmental Clearance Certificate ECR Environment Conservation Rules EHS Environment, Health and Safety EIA Environmental Impact Assessment EMP Environmental Management Plan EQS Environmental Quality Standards FGD Focus Group Discussion GoB Government of Bangladesh GHG Greenhouse Gas HDPE High-density polyethylene HIP Habiganj Industrial Park IECs Important Environmental Components IEE Initial Environmental Examination IFC International Financial Corporation IP Indigenous People IR Involuntary Resettlement KM Kilometer LDPE Low-density polyethylene LGED Local Government Engineering Department MoEF Ministry of Environment and Forest MPN Most Probable Number NEMAP National Environment Management Action Plan NOC No Objection Certificate NOx Oxides of Nitrogen pH Potential of Hydrogen REA Rapid Environmental Assessment RHD Roads and Highways Department SAL Sylvan Agriculture Limited SO2 Sulphur Dioxide www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 iv SPS Safeguard Policy Statement
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1. INTRODUCTION
1.1 Introduction
The PRAN agribusiness project is going to establish a new PRAN Potato Chips Project in Habiganj Industrial Park (HIP) under its company name Sylvan Agriculture Limited (SAL). The proposed project will be established in the HIP of Olipur, Habiganj District. The Project is interested in taking project finance from the Asian Development Bank (ADB), which requires an environmental and social assessment in line with the environmental and social requirements of these lenders as well as the national regulatory requirements in Bangladesh.
PRAN-RFL Group has therefore initiated the Initial Environmental Examination (IEE) study to comply with the IEE guidelines of the GOB and the Safeguard Policy Statement (SPS) of the ADB. PRAN-RFL group engaged EQMS Consulting Limited to conduct the IEE study of the proposed project.
1.2 Background
“PRAN” is the largest business group in Bangladesh, established in 1981. Currently “PRAN” is one of the most admired foods and beverages brand among the millions of people of Bangladesh and other countries of the world where PRAN Products are regularly being exported to different countries of the world. PRAN is currently producing Juices, Drinks, Mineral Water, Bakery, Carbonated beverages, Snacks, Culinary, Confectionery, Biscuits, and Dairy. The proposed project will produce real potato chips. This project will be located in the Olipur site of Shayastaganj, Habiganj Sadar, Habiganj.
1.3 EQMS Purpose and Objectives
The objectives of this Initial Environmental Examination (IEE) will be to ensure that the project compiles with ADB Safeguard Policy Statement (2009) and other social dimension requirements as well as with that of the GoB, which may serve as input in the design of the Project being prepared for possible financing by the ADB.
The reference framework for IEE study willtherefore follow the following standards/ guidelines: Applicable Bangladesh national, regional & local regulatory requirements; ADB’s Safeguard Policy Statement (SPS); ADB Social Protection Strategy; ADB’s Public Communications Policy; The IFC Performance Standards for Environmental & Social Sustainability; and The IFC General EHS Guidelines.
The key tasks were undertaken for screening and scoping for IEE study of the project include: Site assessment (Based on site reconnaissance);
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 1 Categorization of the project as per the GOB regulations and potential lenders' guidelines/standards; Review of administrative framework applicable for the Project; Identification of primary stakeholders; Identification of key environmental and social issues and risks pertaining to the Project; and The scope of the IEE study with proposed approach and methodology.
1.4 EQMS Approach and Methodology
The approach and methodology adopted for the screening and scoping of the Project comprise of:
1.4.1 Screening
EQMS reviewed the existing available data of the project with the client and secondary information available in public domain with regard to the project, project location, and its surroundings. The screening process was undertaken to identify environmental, social and other sensitivities associated with the project. A review of the applicability of the reference framework with respect to the proposed project was also undertaken as part of this screening phase.
The EQMS team had a brief introduction meeting with the PRAN-RFL officials on 07/01/2017 at Habiganj Industrial Park (HIP) prior to site reconnaissance visit. EQMS undertook 3 days (07/01/2017 to 09/01/2017) site visit to understand the site setting, environmental and social sensitivities and to identify the relevant local stakeholders.
The site visit included an inspection of all the individual factories in the HIP and associated facilities with PRAN-RFL officials. A consultation with the local community and previous land owners was also conducted to understand the local environmental and social issues in the area and to receive feedback from stakeholder on these issues.
1.4.2 Categorization
EQMS has categorized the project by following the DOE and ADB categorization criteria based on the screening assessment, site visit, environmental and social sensitivities and limited consultation. The project categorization with respect to ADB classification criteria will now become a basis for the impact assessment, planning and implementation of mitigation, monitoring and reporting mechanisms for the project to meet the potential lenders' requirement. A preliminary stakeholder mapping exercise was also undertaken to identify the key stakeholders from Government/Community/at the local/regional level, who would be required to be consulted during different stages of the Project.
1.4.3 Scoping
As an outcome of the screening and categorization exercise, EQMS has defined scope for the www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 2 IEE study, which includes a detailed approach and methodology including field plan for Environmental and Social baseline data collection, impact identification, impact assessment/cumulative impact assessment and management plan.
1.4.4 Reporting
The outcome of the screening and scoping exercise is this report, which includes: Site profile; Overview of local legal requirements; Overview of potential lenders' requirements; Categorization of the project; Key environmental and social issues/risks; Preliminary stakeholder mapping; Approach and methodology for IEE study; Field plan for environmental and socio-economic survey including stakeholder consultation; Schedule for IEE study; and Way forward.
1.5 Limitation
The scope of this review was limited to the desk-based study of available information in the public domain and rapid site reconnaissance survey. Uses of this Report The present IEE Report has been prepared based on the primary field investigations/assessment and secondary data collected from BMD, DoE, and published journals, and books, public consultation, and site observations. The environmental and social assessment is based on the information collected from the various agencies, community consultations and observations. Professional judgment and subjective interpretation of facts and observations have been applied for the preparation of this report. Additionally, assessment is made on the basis of preliminary information available from PRAN-RFL authority.
1.6 Layout of this report
The layout of the report is as follows: Section 1: Introduction Section 2: Project Description Section 3: Administrative Framework Section 4: Environmental Screening and Categorization Section 5: Preliminary Stakeholder Mapping Section 6: Key Environmental and Social Risks Section 7: Approach and Methodology for IEE study Section 8: Deliverables, report format &work Plan
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 3 2. PROJECT DESCRIPTION
2.1 Location of the Project
The proposed project will be located inside of the Habiganj Industrial Park (HIP). The HIP is administratively situated in the Nurpur Union under Habiganj Sadar Upazila of Habiganj District, Bangladesh. The absolute location of the proposed PRAN potato chips project is 24°16'28.60"N latitude and 91°23'3.94"E longitude. The northern site of HIP is covered by Surabahi, Shailjura and Gayerpur village; industries of the Square group on the South; Sachiura, Noagaon, Dushashan village on the West and Olipur village, Dhaka-Sylhet Highway, Dhaka-Sylhet Railway and Hilly areas are located on the East side. A location Map of the proposed project site is presented in Figure 2-1. This project is situated about 120 KM far from the Dhaka.
Source: EQMS Figure 2-1: Location Map of Project Site
2.2 Key features of the project site and surroundings
The salient features of the projects are described in Table 2-1. Table 2-1: Salient features of the site and surroundings
1. Geographical Details Latitude: 24°16 28.60 N; Longitude: 91°23 3.94 E 2. Land use of Plant site 100% area under Habiganj Industrial Park (HIP) 3. Minimum Distances From Project Site
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 4 a) City: Dhaka @ 120 km, Habiganj @ 12 km; Sylhet @ 85 km b) Village: Surabahi, Shailjura, Gayerpur, Sachiura, Noagaon, Dushashan, Olipur village @ around 2 km c) Railway Station: Sutang @ 2.22 km; Sylhet @ 83 km d) Railway Line: Dhaka-Sylhet @ 400 m from the project location e) Highway: Dhaka-Sylhet @ 60 m, from the HIP entrance f) River: Sutang @ 3 km g) Khal: Inside the HIP and connected with Sutang river h) International Airport: Osmani International Airport, Sylhet @ 91 km I) River Port: Ashuganj @ 47 km J) Market/Bazar: Olipur Bazar @ close with HIP entrance 4. Displacement of Population None (project will be established inside of the HIP) 5. Seismic/Earthquake Zone: As per the Bangladesh Earthquake Zone the project is situated in Zone-I (Basic seismic coefficient is 0.08 g)
2.3 Access Road
The project site is well connected by the Dhaka-Sylhet Highway. The Dhaka-Sylhet railway line is very close to the proposed project site. It’s around 400 m far from the project location. The distance from the HIP to Dhaka is approximately 120 km and Sylhet is 91 km. The access road is suitable for transportation of equipment and material for setting up the industry. Inside of the HIP road network developed in a planned way and a wonderful traffic system are exist. It is mandatory to collect NOC from Roads & Highway Department (RHD) and Local Government Engineering Department (LGED) to access the government road.
2.4 Description about the project
2.4.1 Product description
Detailed product description of the PRAN potato chips is given below: Table 2-2: Product Description
1 Process Name Frying process 2 Product Name Real Potato Chips 3 Ingredients Real Potato & Seasoning (Red Chilli, Turmeric, Blackpepper, Cinnamon, Cumin Seed, Citric Acid, common salt) 4 Important product Crispy & spicy in nature Characteristics 5 Labeling instruction Name and address of manufacturer, Logo (BSTI, Keep Your Country Clean & Non-Veg) Allergen Information, Nutrition Facts, MFG & Expire Date, MRP (Including All Of Taxes). 6 Primary Packaging Foil Pack (Pet +PE+ MPET+LDPE) 7 Secondary packaging HDPE Bag
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 5 8 Shelf life 05 months from Date of Production at ambient Temperature 9 Storage condition At ambient Temperature 10 Distribution Method Through PRAN distribution mechanism as a multiple packaging of 22 gm 11 Who will consume General People 12 Sensitive Customer Yes; Immune-compromised 13 Intended Use Ready for consumption 14 Applicable legal BSTI, BDS No - 1556 regulation Source: Feasibility Study 2.4.2 Production Capacity The following ingredients will be use in the PRAN potato chips production. Production capacity of the proposed project will be about 500 kg/hours:
Table 2-3: Product ingredients information SI Name of the ingredient Unit Qty 1 Raw potato Kg/Hour 2500 2 Palm Oil Kg/Hour 1000 3 Seasoning Kg/Hour 25 4 Packaging materials (Foil) Kg/Hour 164 Source: Feasibility Study 2.4.3 Process flowchart The process flow chart of real potato chips is given below:
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Source: Feasibility Study Figure 2-2: Process Flow Chart
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 7 3. ADMINISTRATIVE FRAMEWORK
To address the environmental and social risks of any proposed project and its associated components and to protect and conserve the environment from any adverse impacts, the GOB has specified regulations, policy, and guidelines. Potential lenders also have their own set of requirements (such as the ADB’s Safeguard Policy and IFC’s Performance Standards) to which any project funded to them must operate.
This section focuses on the administrative framework under the purview of which the proposed project will fall and the IEE study will be governed, namely: Bangladesh national and local, legal and institutional framework; ADB policies and framework; and IFC performance standards and EHS Guidelines. A. Bangladesh Environmental Policy, Regulations, and Guidelines 3.1 Government Environmental Policy, Regulations, and Guidelines
3.1.1 National Environmental Policy, 1992 The Bangladesh National Environmental Policy, approved in May 1992, sets out the basic framework for environmental action together with a set of broad sectoral action guidelines. Key elements of the Policy are: Maintaining ecological balance and ensuring sustainable development of the country through protection and conservation of the environment; Protecting the country from natural disasters; Identifying and regulating all activities that pollute and destroy the environment; Ensuring environment-friendly development in all sectors; Ensuring sustainable and environmentally sound management of the natural resources; Maintaining active association, as far as possible, with all international initiatives related to the environment.
The Environmental Policy of 1992, which amongst other policies, seeks to ensure that transport systems, including roads and inland waterways, do not pollute the environment or degrade resources. The Policy states that IEE should be conducted before projects are undertaken.
3.1.2 National Environment Management Action Plan (NEMAP), 1995 The NEMAP is a wide-ranging and multi- faceted plan, which builds on and extends the statements, set out in the National Environmental Policy. NEMAP was developed to address issues and management requirements during the period 1995 to 2005 and set out of the framework within which the recommendations of the National Conservation Strategy are to be implemented. NEMAP was developed based on the following broad objectives: Identification of key environmental issues affecting Bangladesh; Identification of actions necessary to halt or reduce the rate of environmental degradation; Improvement of the natural environment; www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 8 Conservation of habitats and bio-diversity; Promotion of sustainable development; Improvement of the quality of life of the people. To this end, it has grouped all the relevant necessary actions under four heads: a) institutional, b) sectoral, c) location-specific and d) long-term issues. The institutional aspects reflect the need of inter-sectoral cooperation to tackle environmental problems those need new and appropriate institutional mechanisms at national and local levels. The sectoral aspects reflect the way the ministries and agencies are organized and make it easier to identify the agency to carry out the recommended actions. The location-specific aspect focuses on particularly acute environmental problems at local levels that need to be addressed on a priority basis. The long-term issues include environmental degradation of such degree that it might become more serious and threatening than they seem to be if their cognizance is not immediately taken.
3.1.3 The Environment Conservation Act, 1995 and subsequent amendments The provisions of the act authorize the Director General (DG) of Department of Environment to undertake any activity he deems fit and necessary to conserve and enhance the quality of the environment and to control, prevent and mitigate pollution. The main highlights of the act are: Declaration of Ecologically Critical Areas; Obtaining Environmental Clearance Certificate; Regulation with respect to vehicles emitting smoke harmful for the environment; Regulation of development activities from environmental perspective; Promulgation of standards for quality of air, water, noise and soils for different areas and for different purposes; Promulgation of acceptable limits for discharging and emitting waste; Formulation of environmental guidelines relating to control and mitigation of environmental pollution, conservation, and improvement of the environment.
3.1.4 Environment Conservation Rules, 1997 and subsequent amendments The Environment Conservation Rules, 1997 are the first set of rules promulgated under the Environment Conservation Act, 1995. These Rules provide for, inter alia, the following: The national Environmental Quality Standards (EQS) for ambient air, surface water, groundwater, drinking water, industrial effluents, emissions, noise and vehicular exhaust; Categorization of industries, development projects and other activities on the basis of actual (for existing industries/development projects/activities) and anticipated (for proposed industries/development projects/activities) pollution load; Procedure for obtaining environmental clearance; Requirement for undertaking IEE and EIA as well as formulating EMP according to categories of industries/development projects/activities; Procedure for damageclaim by persons affected or likely to be affected due to polluting activities or activities causing hindrance to normal civic life. Depending upon location, size, and severity of pollution loads, projects/activities have been classified in ECR, 1997 into four categories: Green, Orange-A, Orange-B and Red
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 9 respectively, to nil, minor, medium and severe impacts on important environmental components (IECs).
3.1.5 The EIA Guidelines for Industry, 1997 The EIA Guidelines is a handbook for procedures for preparing the EIAs and for reviewing them for the benefit of the development partners, EIA Consultants, reviewers, and academicians. While preparing these guidelines, the present environmental status as well as the need for rapid economic development of Bangladesh has been kept in view. These considerations have essentially resulted in simpler procedures to be followed for preparing the EIAs and their review. 3.2 Relevant National Polices Table 3-1presents an outline of the other national legal instruments that will have relevance to development project with respect to the social and environment considerations. The IEE will be prepared in compliance with these national policies. Table 3-1: National Legal Instruments
Act/ Rule/ Law/ Responsible Agency- Key Features-Potential Applicability Ordinance Ministry/ Authority Environment Court Act, Ministry of GOB has given highest priority to 2000 and subsequent Environment and environment pollution and passed amendments in 2002 Forest ‘Environment Court Act, 2000 for completing environment related legal proceedings effectively The National Water Ministry of Water Protection, restoration, and Policy, Resources enhancement of water resources; 1999 Protection of water quality, including strengthening regulations concerning agrochemicals and industrial effluent; Sanitation and potable water; Fish and fisheries; and Participation of local communities in all water sector development. The Brick Burning Ministry of Control of brick burning; (Control) Act, 1989 Environment Requires a license from the MoEF for The Brick Burning and Forest operation; (Control) Amendment Restricts brick burning with Act, 1992 and 2001 fuelwood; Water Supply and Ministry of Local Management and Control of water Sanitation Act, 1996 Government, Rural supply and sanitation in urban areas. Development and Cooperatives The Ground Water Upazila Parishad Management of groundwater Management Ordinance resources; 1985 Tube well shall not be installed in
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 10 Act/ Rule/ Law/ Responsible Agency- Key Features-Potential Applicability Ordinance Ministry/ Authority any place without the license granted by Upazila Parishad. The Protection and Ministry of Fisheries Protection and Conservation of Conservation of Fish Act and Livestock fishes in Government owned water 1950subsequent bodies amendments in1982 National Fisheries Policy, Ministry of Fisheries Preservation, management, and 1998 and Livestock exploitation of fisheries resources in inland open water; Fish cultivation and management in inland closed water; Prawn and fish cultivation in coastal areas; and Preservation, management, and exploitation of sea fishery resources. The Acquisition and Ministry of Land Current GoB Act and Guidelines, Requisition of relating to acquisition and Immovable requisition of land. Property Ordinance 1982 and subsequent amendments in 1994, 1995 and 2004 The Factories Act, 1965 Ministry of Labor This Act pertains to the occupational Bangladesh Labour Law, rights and safety of factory workers 2006 and the provision of a comfortable work environment and reasonable working conditions. National Agriculture Ministry of The act deals with the programs Policy,1999 Agriculture related to make the nation self- sufficient in food through increasing production of all crops, including cereals, and ensure a dependable food security system for all
3.3 Environmental Clearance
3.3.1 Requirement of the DoE, Bangladesh The Department of Environment (DoE), the technical arm of the Ministry of Environment and Forest (MoEF) is the regulatory body and the enforcement agency of all environmental related activities. As per ECR, 1997, for obtaining the environmental clearance from DoE for different category projects required to follow some specified steps. The steps for obtaining Environmental Clearance Certificate (ECC) are given in Figure 3-1.
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Figure 3-1: Process of getting ECC at DoE for different categorized project 3.3.2 Environmental and Social Requirements of the Asian Development Bank The Asian Development Bank (ADB) Safeguard Policy Statement (‘the SPS’) 2009 sets out the requirements for ADB's operations to undertake an environmental assessment for projects funded by the bank. The goal of the SPS is to promote the sustainability of project outcomes www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 12 through protecting the environment and people from potential adverse impacts. The overall objectives of the SPS are to: i) Avoid adverse impacts of projects on the environment and affected people, where possible; ii) Minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is impossible; and iii) Help borrowers/clients strengthen their safeguard systems and develop the capacity to manage environmental and social risks. The SPS sets out the ADB policy objectives, scope and triggers and principles for following three key safeguard areas: i) Environmental Safeguards; ii) Involuntary Resettlement Safeguards along with those vis-à-vis Land Acquisition; and iii) Indigenous Peoples Safeguards. ADB Safeguard Categories 1. Environment Proposed projects will be screened according to type, location, scale, and sensitivity and the magnitude of their potential environmental impacts, including direct, indirect, induced, and cumulative impacts. Projects are classified into the following four categories: Category A. A proposed project is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or facilities subject to physical works. An environmental impact assessment (EIA), including an environmental management plan (EMP), is required. Category B. The proposed project’s potential adverse environmental impacts are site- specific, few if any of them are irreversible, and in most cases mitigation measures can be designed more readily than for category A projects. An initial environmental examination (IEE), including an EMP, is required. Category C. A proposed project is likely to have minimal or no adverse environmental impacts. An EIA or IEE is not required, although environmental implications need to be reviewed. Category FI. A proposed project involves the investment of ADB funds to or through a financial intermediary. The financial intermediary must apply and maintain an environmental and social management system, unless all of the financial intermediary's business activities have minimal or no environmental impacts or risks.
2. Involuntary Resettlement The involuntary resettlement impacts of an ADB-supported project are considered significant if 200 or more persons will be physically displaced from home or lose 10% or more of their productive or income-generating assets. Projects are classified into the following four categories: Category A. A proposed project is likely to have significant involuntary resettlement impacts. A resettlement plan, which includes assessment of social impacts, is required. www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 13 Category B. A proposed project includes involuntary resettlement impacts that are not deemed significant. A resettlement plan, which includes assessment of social impacts, is required. Category C. A proposed project has no involuntary resettlement impacts. No further action is required. Category FI. A proposed project involves the investment of ADB funds to or through a financial intermediary. The financial intermediary must apply and maintain an environmental and social management system, unless all of the financial intermediary's business activities are unlikely to generate involuntary impacts.
3. Indigenous Peoples The impacts of an ADB-supported project on indigenous peoples is determined by assessing
the magnitude of impact in terms of . customary rights of use and access to land and natural resources; . socioeconomic status; . cultural and communal integrity; . health, education, livelihood, and social security status; and . the recognition of indigenous knowledge; and the level of vulnerability of the affected Indigenous Peoples community. Projects are classified into the following four categories: Category A. A proposed project is likely to have significant impacts on indigenous peoples. An indigenous peoples plan (IPP), including assessment of social impacts, is required. Category B. A proposed project is likely to have limited impacts on indigenous peoples. An IPP, including assessment of social impacts, is required. Category C. A proposed project is not expected to have impacts on indigenous peoples. No further action is required. Category FI. A proposed project involves the investment of ADB funds to or through a financial intermediary. The financial intermediary must apply and maintain an environmental and social management system, unless all of the financial intermediary's business activities unlikely to have impacts on indigenous peoples.
3.3.3 International Finance Corporation (IFC)’ World Bank Group; Environmental, Health, and Safety (EHS) Guidelines (Food and Beverage Processing) This guideline covers the processing of meat, vegetable, and fruit raw materials into value- added food and beverage products for human consumption. Environmental issues in food and beverage processing facilities primarily include the following: i) Solid waste ii) Wastewater iii) Energy consumption iv) Emissions to air
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Table 3-2: Effluent Standard level for food and beverage processing project
Guideline Value Pollutants Units DoE standard for (Inland IFC Standard Surface Water) pH - 6 – 9 6 – 9 BOD5 mg/l 50 150 COD mg/l 250 200 Total nitrogen mg/l 10 50 Total phosphorus mg/l 2 8 Oil and grease mg/l 10 10 Total suspended solids mg/l 50 150 Temperature increase °C <3b - Total coliform bacteria MPNa / 100 ml 400 - Active Ingredients / To be determined on a case- - Antibiotics specific basis Notes: (a) MPN = Most Probable Number; (b) At the edge of a scientifically established mixing zone which takes into account ambient water Inland Surface Water means drains/ponds/tanks/waterbodies/ditches, canals, rivers, springs and estuaries.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 15 4. ENVIRONMENTAL SCREENING AND CATEGORIZATION
4.1 Project classification as per DOE, MoEF, Bangladesh Depending upon location, size, and severity of pollution loads, projects/activities have been classified in ECR, 1997 into four categories: Green, Orange-A, Orange-B and Red respectively, to nil, minor, medium and severe impacts on important environmental components (IECs).
As per the Schedule-1 of ECR 1997, corresponding category related to PRAN Potato Chips fall under ORANGE-B Category for the following components:
Item 21: Processing fish, meat, food
An initial environmental examination (IEE), including an EMP, is required for the proposed project. 4.2 Project classification as per ADB Safeguard Policy Statement
Categorization for the proposed project was undertaken by using ADB’S Rapid Environmental Assessment (REA), Involuntary Resettlement (IR) and Indigenous people (IP) assessment checklist during the screening and scoping exercise. The REA checklists for the potato chips are given in Annex-A. The Involuntary Resettlement (IR) assessment checklist and Indigenous People (IP) assessment checklist are presented in Annex-B and Annex-C, respectively. The findings of the assessment are presented in Table 4-1.
Table 4-1: Project Categorization as per ADB Safeguards
SL Criteria Relevance Remarks Category No. 1. Environmental Categorization A. Irreversible Environmental issues and impacts Irreversible impacts Based on of the project are anticipated due to the project irreversible, during the construction and include: diverse and operation of the PRAN potato Increase noise cumulative chips project and development of and vibration impacts, it associated infrastructures during should be categorize as construction of “B” potato chips plant and operation; Changes in air quality due to existing, proposed and future projects; Affected aquatic ecology and surface water quality water discharge from
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 16 SL Criteria Relevance Remarks Category No. the plant; Occupational health and safety; Community health and safety; Associated development in the area B. Cumulative The PRAN-RFL group has already Cumulative impacts established more than 15 different on physical, types of industries in the HIP area. biological and This new project will be effect on socioeconomic the local environment along with environmental other industries that’s why a conditions cumulative impact assessment is required to assess the impacts on the environment of the new project. C. Diverse Nature of activities The nature of activities is not diverse for the area, as there is already an operational of similar different industries of PRAN-RFL in the HIP. However, the new plant will be able to supply new type of product (Real potato chips). They have already a potato crackers plant in the HIP. D. Unprecedented Changes in land use Previously the land was used for agricultural activities. However, HIP changes the land use. Current land use of the project site is industrial. 2. Involuntary Resettlement Categorization A. Mode of Purchased land by PRAN –RFL The land purchased In case of no Acquisition Group from the local people foreseen adverse B. Precedence The land for the proposed project During the land impact, project site was obtain to establish an purchase PRAN-RFL shall be industrial park in 2012 group paid actual categorized as amount of this land “C” comparing the market price
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 17 SL Criteria Relevance Remarks Category No. C. Irreversible Project affected households Previously the land area was under agricultural land (only Boro paddy cultivated). The industrialization of the area has helped in providing them non-agricultural livelihoods. 3. Indigenous People Categorization A. Presence Existence of indigenous people The Population In case of no census (2011) has foreseen shown that only 7 adverse households with 34 impact, project persons in Nurpur shall be UP categorized as “C” B. Impact Impact on No adverse impact indigenous/ethnic/schedules on the Ethnic tribes minority is unforeseen
According to ADB guidelines, the Sylvan Agricultural Project can be categorized as environment “Category-B” that’s why an initial environmental examination (IEE), including an EMP, is required for the proposed project.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 18 5. PRELIMINARY STAKEHOLDERS MAPPING A key component of the IEE process is project related information disclosure, communication and stakeholder consultation. Legislation/ guidelines such as the ECR1997 of GOB; Safeguard Policy Statement of ADB and IFC Performance Standards prioritize this even further. PRAN-RFL group recognizes the benefits of information disclosure and stakeholder consultation to ensure that all relevant concerns and opinions regarding this particular project are integrated into the project decision making process and are adequately addressed in the IEE process. Taking this into consideration, the key stakeholders for the proposed project have been identified during the scoping process and these include: Government Agencies - Regulatory as well as local government (including District, Upazila and Union Parishad level); Community and Union Parishad level stakeholders; Research Institutions - Government and Independent; Sub-contractors; and Internal stakeholders – PRAN-RFL Group, local partner, employees. List of key identified stakeholders which emerged from the site visit and preliminary discussions have been presented in Table 5-1. Table 5-1: Stakeholder Mapping
Institutions SL Particular Government Local Office Locals 1. Environmental Policy Director, Department of Environment, - and Law Sylhet Divisional Office 2. Air Quality Director, Department of Environment, Local Sylhet Divisional Office community/residents 3. Water Quality Director, Department of Environment, Local Sylhet Divisional Office community/residents, District/Upazila Department of Public Fisherman, Farmers Health and Engineering Officer-Habiganj 4. Soil District/Upazila Agicultural Officer- Local farmers Habiganj Union Parishad- Nurpur 5. Geology and Ground - Local farmers subsidence 6. Biota and ecosystem District/Upazila Forest Officer-Habiganj Local farmers District/Upazila Fisheries Officer- Local fishermen Habiganj Union Parishad- Nurpur 7. Road traffic and Roads and HighwayDepartment, Local community accident records Ministryof Communications – Habiganj those who are using Upazila LGED officer-Habiganj the local roads 8. Global warming Upazila Parishad - Habiganj Union Parishad- Nurpur 9. PRAN Potato chips PRAN-RFL Group Villagers project related decision
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 19 Institutions SL Particular Government Local Office Locals 10. Socio-economic Union Parishad-Nurpur Local people, women census data and vulnerable group 11. Natural hazards and Red crescent villagers, women and disaster (Flood, Upazila Disaster Management vulnerable groups Cyclone, Tornadoes, Committee-Habiganj Earthquake) Union Disaster Management Committee- Nurpur 12. River and waterway BWDB-Habiganj Users, Fisherman BIWTA-Habiganj 13. Agriculture and Upazila Parishad-Habiganj Farmers, villagers irrigation Union Parishad-Nurpur 14. Meteorological data BMD-Sylhet Station - 15. Topographical LGED-Habiganj - information 16. Community Union Parishad-Nurpur - 17. Labor related Inspector of Factory and Establishment Local people, office-Habiganj villagers, labor (local and migrant)
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 20 6. KEY ENVIRONMENTAL AND SOCIAL RISK Potential environmental and social impacts have been identified through a systematic process whereby the activities (both planned and unplanned) associated with the construction and operation of the project have been considered with respect to their potential to interaction with sensitive environmental and social resources or receptors. Scoping of potential impacts has been undertaken in two stages:
Stage 1: Identification of potential interactions between project activities and environmental receptors; and Stage 2: Prioritization of these interactions in terms of their potential to cause significant impacts taking into consideration the current knowledge of project activities and the existing condition/sensitivities of environmental and social baseline.
6.1 Key Environmental Risks Cumulative Impacts Different types of industries (more than 15) are operational close to the proposed project site in the Habiganj Industrial Park (HIP). As a result, the project impacts cannot be assessed in isolation and the cumulative impacts are anticipated and also need to be assessed.
Climate Change Climate Change is now a global concern and considered Bangladesh as the most climate vulnerable country in the world. But it argues that Bangladesh has play only a very small role in contributing to climate change and has very small GHG emissions per person compared to larger developing countries. Bangladesh is not highly industrialized or urbanized, and these are two of the main sectors that emit greenhouse gases.
The proposed project will use different goods and raw materials for its every day production. The project will emit greenhouse gasses in two ways, from direct emissions (emissions that are produced at the facility itself) and indirect emissions (associated with the facility's use of energy).Detailed study on GHG emission will be conducted during the baseline survey and impact assessment.
Natural Hazards Bangladesh is positioned at the juncture of several active tectonic plate boundaries. On the basis of the distribution of earthquake epicenters and morphotectonic behavior of different tectonic blocks Bangladesh has been divided into three generalized seismic zones. The northeastern folded regions of Bangladesh (Sylhet region) are the most active zones and belong to the zone-I. The Bask seismic coefficient of this zone is 0.08. The proposed PRAN potato chips fall in the seismic zone-I.
Severe flood, tornado, lightning, earthquake etc. may occur at any time during the operation and maintenance of the project. An Emergency Response Plan is required to be prepared and actions to be taken by the implementing agency to cope with any emergency period.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 21 Construction Period As Bangladesh has a long monsoon period from mid-May to early October months, the scheduling of the construction period will be an important issue in terms of construction management and safety of the workers from construction schedule as well as safety and health related concerns.
Population Influx The proposed project will result in an influx of workers to the area because of construction activities, plant operation activities and hence potential employment and contract opportunities. This may result in stress on the local resources in absence of proper planning for the drinking water and sanitation facilities of the workers.
Emission to Air/Air Pollution During construction and operations of the project, it will be required to movement of vehicles and heavy equipment’s that may create a small amount of dust and SOx, NOx and CO2. But this small amount of pollution will be no significant impact on the overall pollution of the ambient air quality.
During Construction stage building construction, pumping station, transportation of the pipeline, construction of earth road, welding, cleaning and coating/wrapping of the pipeline etc. could cause low atmosphere pollution in the air, which may create less health problem on workers and surroundings inhabitants. The emission of dust, gaseous pollutants (SOx, NOx and CO2) and suspended particulates will be also low and also of short duration.
The primary fuel for the plant will be natural gas, which is considered as a cleaner fuel, however, these plants can pollute the area during plant operation stage with NOx and CO emissions and can impact air quality of the area in absence of proper pollution control measures.
Noise and Vibration During construction period producing so much noise and vibration cause of movement of vehicles, heavy equipment’s and Lorries will impact on workers, health as well as surrounding people. For this reason, it will impact on bio-diversity of the project area.
Impact on Sutang River The Sutang River is almost 3 km far from the project site and well connected with a khal that flows inside the HIP. If any hazardous waste, solid waste or others harmful materials are through to the khal it can contaminate the surface water of the khal as well as the Sutang river. There will be a possibility to impact on the aquatic flora and fauna in the project area and its surrounding area. Detailed study will be conducted during the baseline survey and impact assessment.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 22 Waste Water During the operation stage, fresh water will be required to cleaning the raw potato at the primary stage. At this stage, waste water will be produced. It will be required to collect waste water in a proper way and take them to the treatment plant for further use and reduce the environmental effect. A detailed study on wastewater management will be conducted in further.
Solid Waste During the construction and operation stage of the project, a large number of workers/employees will be engaged with the proposed PRAN potato chips plant. At the same time, a significant amount of solid waste will be produced from the domestic waste, garbage, sludge from a wastewater treatment plant, water supply treatment plant, food waste, by-product material etc. Solid waste can effect on the local environment if it is not treatment properly. A proper solid waste management system is essential for maintaining a healthy and sustainable environment in the project site.
Health and safety issues Probability of occurrence of worker accidents is anticipated to be high in all construction works. Concentration of labor force in the work area is anticipated to create unhygienic conditions. Storage of flammable materials at site in large quantities may pose risk of fire and explosion.
Fire and Explosion Fire is considered as one of the important hazards for any industry. It can happen due to any natural and manmade causes. To prevent the occurrence of fire and explosion an emergency response/management system and capacity building of the workers are essential.
6.2 Social Risks The project will be setup in the HIP area so it does not involve with land acquisition activities. Previously the area was a low agricultural land and only single crop (Boro rice) was produced here. Hence, there is no risk of involuntary resettlement and rehabilitation issue linked to this project. However, there is a range of other social risks which emerged from the scoping exercise are listed as follows:
Impact on Livelihood/Employment Generation The project is expected to provide an opportunity to unskilled wage labor in the locality. The wage earning will supplement their earnings from agriculture, fishing and household industries. The impact of the project activities on the livelihood of these people requires to be studied in detail.
Population Influx The project will facilitate the influx of labor, skilled workers and staff (national and expatriates) who would live or stay in the locality for varied length of time. The impact of the population influx thus needs to be studied further. www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 23
Labor Issue The project in construction and operation phase will employ labor that would give rise to a range of labor issues including protecting their rights, providing them requisite facilities, protecting their health and providing a safe working condition to them. Hence, a detailed examination is required to assess the risks to the labor engaged during the project work.
Community Health and Safety The population influx, transportation, and storage of construction related materials are expected to expose the local population to an increase risk accident, communicable and vector borne diseases in the locality. Hence, a close assessment of the health care facilities available in the project area and community health and safety is necessary.
Occupational Health and Safety In addition to the labor employed for the construction, there will be a sizable number of skilled and supervisory staff engaged during the project construction and operation. The assessment of risk to their health and safety of their workplace will also be undertaken during impact assessment.
Impact of indigenous or ethnic communities/groups, if any The preliminary social screening of the area based on census 2011 data of the project influence area and its surroundings shows that there is no ethnic community in the project area.
Impact of Cultural Resources The project site does not have any structure with cultural and heritage significance. However, there are mosques and other religious places inside and around the project site at various distances. The likely impact on these cultural resources will be studied during impact assessment.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 24 7. APPROACH AND METHODOLOGY
7.1 Introduction Based on the site reconnaissance survey, understanding of the type of data/information required, the time period required for the monitoring, focus areas during IEE study, etc. EQMS proposes the following approach and methodology for the IEE study.
Source: EQMS, R&D Figure 7-1: Approach for the proposed project IEE Study
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 25 7.2 Establishment of Environmental and Social Baseline As outcome of scoping and reconnaissance survey of the site, following data/documents requires being collected during IEE study for the proposed project.
7.2.1 Study Area The study area considered for IEE will include an area within 2 km radius from the center of the project site. The area of 2 km has been selected based on the location of project site and its footprint, nature and spatial distribution of potential social and environmental impacts (based on the experience of the similar type of projects).
7.2.2 Environmental and Social Baseline Data Collection Environmental and social baseline data will be collected through primary monitoring and baseline surveys and also based on information available through secondary sources. Literature surveys will be done and relevant information will be collected for environmental baseline. The baseline study included the following: Reconnaissance survey of the Project site and surrounding area within 2 km radius from center of the proposed project site to establish dominant features of the biophysical and social environments; The primary environmental baseline data will be collected with respect to ambient air quality, water (surface and groundwater) quality, soil characteristics, noise level and ecology; Information on geology, meteorological conditions, water and ecological resources, socio-economic status etc. will be collected from secondary sources. A. Primary Baseline Data Collection
With the assistance of Client, EQMS will identify an accredited environmental laboratory of repute, which will be engaged for collection of baseline information on micrometeorology, ambient air quality, water quality (surface and ground water), ambient noise quality as per aspects detailed in the following Table 7-1:
Table 7-1: Primary Baseline Data to be collected
No. of SL# Environmental Attribute Frequency Remarks Locations 1. Ambient Air Quality 4 24 hrs / 2 AAQ monitoring covering SPM, PM10 and PM2.5 weeks, 2 times upwind, downwind and Oxides of Nitrogen (NOx) in a week Crosswind directions and Carbon Monoxide (CO) at Project site. Existing and Sulphur Dioxide (SO2) proposed new industries within the air shed shall be identified. 2. Surface and Groundwater 2 Once during Surface and ground water Quality: Physical parameters: the Baseline samples will be collected pH, Temp ., DO, conductivity, survey from the study area. Total Dissolved Solids, BOD, COD, NO3, Cl, Na, K, total coliform and fecal coliform
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 26 No. of SL# Environmental Attribute Frequency Remarks Locations 3. Ambient Noise Quality 6 24 hrs / Once Noise levels will be Leqday, Leqnight, Legmax, during the monitored on BD standard Leqmin, Leqavg Baseline survey 4. Flora and Fauna Study Once during Ecological survey will be Survey of the study area Area The baseline undertaken to assess the Identifying endangered or survey biodiversity aspects. protected species or period endemic floral species prevailing in the study area. Identifying any endemic fauna in the study area. Identifying vegetation cover and current status of natural habitats or species. Identifying and assessing ecological resources within the study area. Terrestrial ecology and fisheries 5. Land use and GIS mapping of Representing Based on available satellite the study area the period of imageries of the recent PIA and monitoring past year within 2 6. Socio-economics One time Mostly assessed through km radius survey FGD and available secondary information For the socio-economic aspects typically required within the IEE, EQMS will undertake the following activities: Undertaking consultation, interviews and FGD’s in the surrounding villages; Discussions with Government Departments, local authorities etc, as required; Discussions with marginal farmers, vulnerable groups, indigenous people etc.
B. Secondary Baseline Data Collection Readily available secondary information would be collected for following aspects: a) Physical Environment Regional setting o Geography and geomorphology o Land use o Geology and soil Climate and meteorology o Climatic pattern o Ambient temperature o Relative humidity o Rainfall o Regional wind patterns (wind speed & direction) Hydrology and water use o Natural Hazards
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 27 o Seismic activities o Seasonal storms & cyclones
b) Socio-economic Environment: Demographic profile Education & literacy Economic activities & livelihood pattern Socio-economic Infrastructure & Indicators o Health care facilities o Education facilities o Drinking water & sanitation o Agriculture o Transportation facilities o Sites of cultural/archaeological importance
Few of the identified sources for collecting secondary data include the following: Bangladesh Meteorological Department (BMD) at Dhaka; Department of Environment (DoE); Bangladesh Bureau of Statistics (BBS); and Published technical journals and books.
7.2.3 Stakeholder Engagement & Analysis Stakeholder engagement is the fundamental element of the approach to an IEE process. Certain stakeholders are likely to be consulted in the course of the engagement process for the IEE and have been identified based on the reconnaissance visit and presented in section 5 of this report.
Stakeholder Consultation Consultation will be conducted with key stakeholders including the local population, government department/agencies, farmers and fishermen; Stakeholder consultation will be conducted with the intent of collecting baseline information on the environmental and social conditions and sensitivities, developing a better understanding of the potential impacts, informing the public of the proposed project and to gain an understanding of the concern of the stakeholders; Collected information will be used for formulating mitigation measures and environmental and social management plan.
7.2.4 Impact Assessment Analysis of the baseline data and incremental impacts of the project will be assessed in accordance with the national guidelines for air, water and noise emissions; standards are mentioned in ECR 1997, ADB guidelines and IFC’s performance standard and EHS guidelines, including the general guidelines and those for Food and Beverage Processing.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 28 The impact assessment will involve the prediction, evaluation, and mitigation of impacts and will report on impacts including residual impacts and cumulative impacts (Figure 7-2). Impact prediction will take into account control measures that are part of the project design. Additional mitigation measures aimed at further reducing predicted impacts will be proposed where necessary or appropriate.
Figure 7-2: Impact Assessment Process
Mitigation/ Residual Predict Evaluate Enhance Impacts
What could Is it Important? What can be done Is there still a happen as a (Significance) about it? significant consequence of impact? doing what is proposed
Aspects which will be considered in the impact assessment for both the construction and operation phase of the project including air quality, greenhouse gases, water quality, noise, ecology, waste, landscape and visual, traffic, soil, and groundwater, socio-economic and health.
The IEE study will evaluate the significance of all the environmental and social impacts associated with the proposed project under impact categories including positive or negative, short term or long term, direct or indirect. The effectiveness of mitigation measures shall also be assessed through environmental impact predictions on the different sensitive receptors within any environmental component.
7.2.5 Risk Assessment Risk assessment study will cover the following: Hazards identification to determine the incident scenarios, hazard and hazardous events, their causes and mechanism; Consequence analysis to determine extent of the consequence of identified hazardous events; Frequency estimation to determine the frequency of occurrence of identified hazardous events and various consequences; Risk summary to determine risk level and their significance, and recommendation for risk mitigation.
7.2.6 Environmental Management Plan (EMP) An Environmental Management Plan (EMP) would be prepared covering mitigation measures, environmental control technologies and best available practices with defined www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 29 Environmental Management System. The mitigation measures would be targeted at reducing impacts to as low as reasonably practical. The EMP will comprise of (and not limited to): Feasible control technologies and mitigation measures to minimize adverse impacts of proposed activities such as: . Pollution control measures proposed to meet the emission, effluent and noise standards etc.; . Effluent treatment; . Solid waste management; . Environmental monitoring programme; . Occupational health and safety related mitigation measures. Management of social impacts through mitigation measures at community as well as household levels; Mitigation and management plans for implementation with definite timeline and responsibilities; Organization required for implementation of management program during different phases of the project; Training the EMP implementation team; and Monitoring and reporting mechanism both for regulatory compliance.
7.2.7 IEE report Format EQMS will prepare the IEE report as per the following structures but not limited: Executive Summary Introduction Description of the project Administrative and regulatory framework Baseline data Impact and mitigation measures Environmental and social monitoring program Information disclosure, consultation, and participation Grievance redress mechanism Environmental and Social Management Plan Conclusion
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 30 8. Work Plan The work schedule for conducting field survey, baseline data collection and preparation of IEE report in line with the potential Lenders' requirement for the proposed project is as given in following Table 8-1.
Table 8-1: Work plan for conducting the IEE study Time ( Weeks) Description Progress 1 2 3 4 5 6 7 8 Kick-off Meeting and Mobilization Completed Scoping for IEE/EMP Completed Project Description Analysis of Alternatives Preparation of IEE Checklist and Submission to DoE Environmental and Social Baseline Impact Assessment (Cumulative) including developing mitigation measures to minimize adverse impacts/risks Development of EMP Preparation of Draft IEE Preparation of Final IEE Report
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 31 Annex-A: Rapid Environmental Assessment (REA) Checklist
Country/Project Title: PRAN Potato Chips Project (Bangladesh)
Sector Division: Agribusiness/Fo od
Screening Questions Yes No Remarks A. Project Siting Is the Project area adjacent to or within any of the following environmentally sensitive areas? Cultural heritage site √ Legally protected Area (core zone or buffer zone √ Wetland A Khal is situated inside of the Habiganj √ Industrial Park (HIP) and connected with Sutang River Mangrove √ Estuarine √ Special area for protecting biodiversity √ B. Potential Environmental Impacts Will the Project cause… Impairment of historical/cultural areas; disfiguration of landscape or potential √ loss/damage to physical cultural resources? Disturbance to precious ecology (e.g. sensitive or protected areas)? √ Alteration of surface water hydrology of waterways resulting in increased sediment in √ streams affected by increased soil erosion at construction site? Deterioration of surface water quality due to silt runoff and sanitary wastes from worker-based √ camps and chemicals used in construction? Increased air pollution due to project construction Dust will be generate during the and operation? √ construction and also during operation phase of the project Noise and vibration due to project construction or Noise and vibration will be generate operation? during the construction activities and √ also during operation of the potato chips plant Involuntary resettlement of people? (physical Proposed PRAN potato chips will be displacement and/or economic displacement) √ establish inside of HIP
Disproportionate impacts on the poor, women and According to the population census 2011 children, Indigenous Peoples or other vulnerable √ there are only 7 households (male 18, groups? female 26, total 34) in Nurpur Union Poor sanitation and solid waste disposal in Impacts can occur during construction construction camps and work sites, and possible and operation phase of the proposed transmission of communicable diseases (such as √ project STI's and HIV/AIDS) from workers to local populations? Creation of temporary breeding habitats for If canals inside the HIP will not be diseases such as those transmitted by mosquitoes √ properly maintained, it can be breeding and rodents? habitats Social conflicts if workers from other regions or At present worker are working in HIP √ countries are hired? from different region and culture Large population influx during project Local available resources will be affected construction and operation that causes increased due to population influx for setup new √ burden on social infrastructure and services (such industries in HIP as water supply and sanitation systems)? Risks and vulnerabilities related to occupational Accidents may occur during
√ incautiousness www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 32 Screening Questions Yes No Remarks health and safety due to physical, chemical, biological, and radiological hazards during project construction and operation? Risks to community health and safety due to the If fuel and oil and grease are not transport, storage, and use and/or disposal of properly stored, transported and √ materials such as explosives, fuel and other disposed chemicals during construction and operation? Community safety risks due to both accidental and natural causes, especially where the structural elements or components of the project are accessible to members of the affected community √ or where their failure could result in injury to the community throughout project construction, operation and decommissioning? Generation of solid waste and/or hazardous Solid waste will be generate from the waste? √ workers during operation and washing of potato Use of chemicals? √ Citric Acid will be use Generation of wastewater during construction or Generally waste water will be generate operation? √ during washing the washing of raw potato
Climate Change and Disaster Risk Questions The following questions are not for environmental Yes No Remarks categorization. They are included in this checklist to help identify potential climate and disaster risks. . Is the Project area subject to hazards such as earthquakes, floods, landslides, tropical cyclone winds, storm surges, √ tsunami or volcanic eruptions and climate changes (see Appendix I)? . Could changes in precipitation, temperature, salinity, or extreme events over the Project lifespan affect its √ sustainability or cost? . Are there any demographic or socio-economic aspects of the Project area that are already vulnerable (e.g. high incidence of marginalized populations, rural-urban √ migrants, illegal settlements, ethnic minorities, women or children)? . Could the Project potentially increase the climate or disaster vulnerability of the surrounding area (e.g., increasing traffic or housing in areas that will be more √ prone to flooding, by encouraging settlement in earthquake zones)?
Appendix I: Environments, Hazards and Climate Change
Environment Natural Hazards and Climate Change Arid/Semi-arid Low erratic rainfall of up to 500 mm rainfall per annum with periodic droughts and high and desert rainfall variability. Low vegetative cover. Resilient ecosystems & complex pastoral and environments systems, but medium certainty that 10–20% of drylands degraded; 10-30% projected decrease in water availability in next 40 years; projected increase in drought duration and severity under climate change. Increased mobilization of sand dunes and other soils as vegetation cover declines; likely overall decrease in agricultural productivity, with rain-fed agriculture yield reduced by 30% or more by 2020. Earthquakes and other geophysical hazards may also occur in these environments. Humid and More than 500 mm precipitation/yr. Resilient ecosystems & complex human pastoral and sub-humid cropping systems. 10-30% projected decrease in water availability in next 40 years; projected plains, foothills increase in droughts, heatwaves and floods; increased erosion of loess-mantled landscapes by
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 33 and hill country wind and water; increased gully erosion; landslides likely on steeper slopes. Likely overall decrease in agricultural productivity & compromised food production from variability, with rain-fed agriculture yield reduced by 30% or more by 2020. Increased incidence of forest and agriculture-based insect infestations. Earthquakes and other geophysical hazards may also occur in these environments. River valleys/ River basins, deltas and estuaries in low-lying areas are vulnerable to riverine floods, storm deltas and surges associated with tropical cyclones/typhoons and sea level rise; natural (and human- estuaries and induced) subsidence resulting from sediment compaction and ground water extraction; other low-lying liquefaction of soft sediments as result of earthquake ground shaking. Tsunami coastal areas possible/likely on some coasts. Lowland agri-business and subsistence farming in these regions at significant risk. Small islands Small islands generally have land areas of less than 10,000km2 in area, though Papua New Guinea and Timor with much larger land areas are commonly included in lists of small island developing states. Low-lying islands are especially vulnerable to storm surge, tsunami and sea-level rise and, frequently, coastal erosion, with coral reefs threatened by ocean warming in some areas. Sea level rise is likely to threaten the limited ground water resources. High islands often experience high rainfall intensities, frequent landslides and tectonic environments in which landslides and earthquakes are not uncommon with (occasional) volcanic eruptions. Small islands may have low adaptive capacity and high adaptation costs relative to GDP. Mountain Accelerated glacial melting, rockfalls/landslides and glacial lake outburst floods, leading to ecosystems increased debris flows, river bank erosion and floods and more extensive outwash plains and, possibly, more frequent wind erosion in intermontane valleys. Enhanced snow melt and fluctuating stream flows may produce seasonal floods and droughts. Melting of permafrost in some environments. Faunal and floral species migration. Earthquakes, landslides and other geophysical hazards may also occur in these environments. Volcanic Recently active volcanoes (erupted in last 10,000 years – see www.volcano.si.edu). Often environments fertile soils with intensive agriculture and landslides on steep slopes. Subject to earthquakes and volcanic eruptions including pyroclastic flows and mudflows/lahars and/or gas emissions and occasionally widespread ashfall.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 34 Annex-B: Involuntary Resettlement (IR) Assessment Checklist Probable Involuntary Resettlement Effects Yes No Remarks Involuntary Acquisition of Land Will there be land acquisition? √ Project will be establish inside of Is the site for land acquisition known? √ Habiganj Industrial Park (HIP) Is the ownership status and current usage of Land inside of the Habiganj √ land to be acquired known? Industrial Park (HIP) Will there be loss of shelter and residential √ land due to land acquisition? Will there be loss of agricultural and other √ productive assets due to land acquisition? Will there be losses of crops, trees, and fixed √ assets due to land acquisition? Will there be loss of businesses or enterprises Business opportunities will be √ due to land acquisition? increase Will there be loss of income sources and Income and livelihoods √ means of livelihoods due to land acquisition? opportunities will be generate Involuntary restrictions on land use or on access to legally designated parks and protected areas Will people lose access to natural resources, √ communal facilities and services? If land use is changed, will it have an adverse √ impact on social and economic activities? Will access to land and resources owned √ communally or by the state be restricted? Information on Displaced Persons: Any estimate of the likely number of persons that will be displaced by the Project? [√] No [ ] Yes If Yes, approximately how many?...... Are any of them poor, female-heads of households, or vulnerable to poverty risks? [√] No [ ] Yes Are any displaced persons from indigenous or ethnic minority groups? [√] No [ ] Yes
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 35 Annex-C: Indigenous People (IP) Assessment Checklist KEY CONCERNS (Please provide elaborations on the Remarks Yes No Remarks column) A. Indigenous Peoples Identification Are there socio-cultural groups present in or Project site falls in Nurpur Union of use the project area who may be considered as Habiganj Sadar Upazila in Habiganj "tribes" (hill tribes, schedules tribes, tribal District of Bangladesh. As per peoples), "minorities"(ethnic or national Population Census of Bangladesh √ minorities), or "indigenous communities" in the 2011, there are only one 7 project area? households (male 18, female 26, total 34) in Nurpur UP. Detailed study will be conducted during IEE Are there national or local laws or policies as Not Applicable well as anthropological researches/studies that consider these groups present in or using √ the project area as belonging to "ethnic minorities", scheduled tribes, tribal peoples, national minorities, or cultural communities? Do such groups self-identify as being part of a Not Applicable √ distinct social and cultural group? Do such groups maintain collective Not Applicable attachments to distinct habitats or ancestral √ territories and/ or to the natural resources in these habitats and territories? Do such groups maintain cultural, economic, Not Applicable social, and political institutions distinct from √ the dominant society and culture? Do such groups speak a distinct language or Not Applicable √ dialect? Has such groups been historically, socially Not Applicable and economically marginalized, √ disempowered, excluded, and/ or discriminated against? Are such groups represented as "Indigenous Not Applicable Peoples" or as "ethnic minorities" or "scheduled tribes" or "tribal populations" in any formal √ decision making bodies at the national or local levels? B. Identification of Potential Impacts Will the project directly or indirectly benefit Not Applicable √ or target Indigenous Peoples? Will the project directly or indirectly affect Not Applicable Indigenous Peoples' traditional socio-cultural √ and belief practices? (e.g. child-rearing, health, education, arts, and governance) Will the project affect the livelihood systems Not Applicable of Indigenous Peoples? (e.g., food production √ system, natural resource management, crafts and trade, employment status) Will the project be in an area (land or territory) Not Applicable occupied, owned, or used by Indigenous Peoples, and/ or claimed as ancestral √ domain?
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 36 KEY CONCERNS (Please provide elaborations on the Remarks Yes No Remarks column) C. Identification of Special Requirements Will the project activities include: Commercial development of the cultural Not Applicable resources and knowledge of Indigenous √ Peoples? Physical displacement from traditional or Not Applicable √ customary lands? Commercial development of natural resources Not Applicable (such as minerals, hydrocarbons, forests, water, hunting or fishing grounds) within customary lands under use that would impact √ the livelihoods or the cultural, ceremonial, spiritual uses that define the identity and community of Indigenous Peoples? Establishing legal recognition of rights to Not Applicable lands and territories that are traditionally √ owned or customarily used, occupied or claimed by indigenous peoples? Acquisition of lands that are traditionally Not Applicable owned or customarily used, occupied or √ claimed by indigenous peoples?
D. Anticipated project impacts on Indigenous Peoples - Not Applicable Anticipated positive Anticipated negative Project component/activity/output effect effect 1. 2. 3. 4. 5. Note: The project team may attach additional information on the project, as necessary.
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 37 Annex-D: Photographs during screening study
Cake production line Bread production line
A floor of the biscuit production line Bread production line
Biscuit production line Consultation with the local community and taking feedback
Consultation with the local community and Consultation with the local community and taking feedback taking feedback
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 38
Consultation with the local community and Consultation with the local community and taking feedback taking feedback
Consultation with the local community and Consultation with the land sellers and taking taking feedback feedback
Existing ETP inside of the HIP Production line of beverage (PRAN-UP)
Production of Dry cake Mango Bar production line
www.eqmsbd.com Sylvan Agriculture Limited Ref: # 0017820106 January 2017 39 Initial Environmental Examination (IEE) of PRAN potato chips, Pasta and Flakes project
ANNEX-E: COMPLIANCE AUDIT REPORT (OPERATION PHASE)
www.eqmsbd.com Sylvan Agriculture Limited 199 Ref: # 0017820106 October 2017
Environmen tal Compliance Audit Report OF PRAN POTATO CHIPS, PASTA AND FLAKES PROJECT
Prepared for:
Sylvan Agriculture Limited
Prepared by: EQMS Consulting Limited Flat # C1, House # 76, Road # 5, Block # F Phone: +88-02-9873282 www.eqmsbd.com
October 2017 Environmental Compliance Audit Report
Environmental Compliance Audit of PRAN Potato Chips, PASTA AND FLAKES Project
Final Report
December 2017
Reviewed & Approved by:
Kazi Farhed Iqubal Executive Director
This report has been prepared and reviewed by EQMS company, with all responsible skill, care and diligence within the terms of the Contact with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.
We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk
Table of Contents
Executive Summary ...... 4 1. Introduction ...... 5 1.1. Introduction ...... 5 1.2. Project description ...... 5 1.3. Objective ...... 5 2. Summary of National, Local and any Other Applicable Environmental Laws, Regulations, and Standards ...... 6 2.1. Bangladesh Environmental Policy, Regulations and Guidelines ...... 6 2.1.1. Government Environmental Policy, Regulations and Guidelines ...... 6 2.1.2. Environmental Clearance ...... 6 3. Audit and Site Investigation Procedure ...... 7 3.1. Overview ...... 7 3.1.1. Desk Based overview ...... 7 3.1.2. Site Visit ...... 7 3.2. Compliance rating ...... 8 3.3. Information gaps and limitations ...... 8 4. Findings and Areas of Concern ...... 9 5. Corrective Action Plan ...... 15 5.1. Overview ...... 15 5.2. Corrective action plan ...... 15 ANNEX-Photographs ...... 17
Executive Summary
The PRAN agribusiness project is going to establish a new PRAN Potato Chips, Pasta and Flakes Project inside of the Habiganj Industrial Park (HIP) under Sylvan Agriculture Limited (SAL), a subsidiary of PRAN Group. Recently Potato project construction has been completed and initial operation is carried out from November 2017. Yet full swing operation hasn’t been started. On the other hand, Pasta and Flakes project operation hasn’t started yet. Still machine installation procedure is going on. Therefore, this operational period audit was conducted on solely Pran Potato Chips project.
The site visit was undertaken from 17th to 18th December 2017 and was attended by two environmental and social safeguard specialists from EQMS Consulting Limited. Desk based study along with observational field visits and internal/external stakeholder interview were adopted in this study. Audit study has found in four major areas those are non-compliance to ADB Safeguard Requirement 1. Along with the overall findings, specific findings were also highlighted. Required corrective action plan, timeline and budget have been suggested as well.
1. Introduction
1.1. Introduction
“PRAN” is the largest business group in Bangladesh, established in 1981. Currently “PRAN” is one of the most admired foods and beverages brand among the millions of people of Bangladesh and other countries of the world where PRAN products are regularly being exported to different countries of the world. PRAN is currently producing Juices, Drinks, Mineral Water, Bakery, Carbonated Beverage, Snacks, Culinary, Confectionary, Biscuit, Dairy, Health Food Drink, Breakfast and Refreshment, Rehydration, Frozen Food and Kernel Sunflower Oil. All the PRAN products are produced as per international standard maintaining the highest level of quality during its production processes. PRAN started its successful journey to export market since 1996 and currently exports to over 118 countries.
The PRAN agribusiness project is going to establish a new PRAN Potato Chips, Pasta and Flakes Project inside of the Habiganj Industrial Park (HIP) under Sylvan Agriculture Limited (SAL), a subsidiary of PRAN Group. The proposed project will be established inside of the HIP of Olipur, Habiganj District, Bangladesh. The project is interested in taking project finance from the Asian Development Bank (ADB), which requires an environmental and social assessment in line with the environmental and social requirements of these lenders as well as the national regulatory requirements in Bangladesh. PRAN Group has therefore initiated the Initial Environmental Examination (IEE) study to comply with the IEE guidelines of the GOB and the Safeguard Policy Statement (SPS) of the ADB.
1.2. Project description
The proposed project is located inside of the Habiganj Industrial Park (HIP). The HIP is administratively situated in the Nurpur Union under Habiganj Sadar Upazila of Habiganj District, Bangladesh. The northern site of HIP is covered by Surabahi, Shailjura and Gayerpur village; industries of the Square group (Square denim and Shahjibazar power station) on the South; Sachiura, Noagaon, Dushashan village on the West and Olipur village, Dhaka-Sylhet Highway, Dhaka-Sylhet Railway and Hilly areas are located on the East side. Recently Potato project construction has been completed and initial operation is carried out from November 2017. Yet full swing operation hasn’t been started. Lack of row materials is the main reason behind this. Main row material is potato which will be available from February/March. Once potato supply will be available and stored, full swing production will be continued.
Pasta and Flakes project operation hasn’t started yet. Its infrastructural construction has been completed but still machine installation procedure is not started. Therefore, this operational period audit was conducted on solely Pran Potato Chips project.
1.3. Objective
The objectives of this audit are to:
Review environmental compliance of the existing assets against the requirements of ADB SR1: Environment, with consideration of international best practice Propose a corrective action plan (CAP) that sets out the actions that the Project needs to implement to achieve compliance with ADB SR1
2. Summary of National, Local and any Other Applicable Environmental Laws, Regulations, and Standards
2.1. Bangladesh Environmental Policy, Regulations and Guidelines
2.1.1. Government Environmental Policy, Regulations and Guidelines
National Environmental Policy, 1992 National Environment Management Action Plan (NEMAP), 1995 Environment Conservation Act (ECA), 1995 and subsequent amendments Environment Conservation Rules (ECR), 1997 & subsequent amendments National Conservation Strategy, 1992 The EIA Guidelines for Industry, 1997 Relevant others National Polices
2.1.2. Environmental Clearance
Requirement of the DoE, Bangladesh Environmental and Social Requirements of the ADB . Environment . Involuntary Resettlement . Indigenous Peoples Applicable EHS Standards Applicable Environmental Standards
3. Audit and Site Investigation Procedure
3.1. Overview
The audit approach has involved a desk based review and a site visit to obtain information. This report has been informed by the review of Project documentation and questions and answers with SAL. In addition, clarifications and additional information have been sought through meetings with local community and corporate social responsibility (CSR) beneficiaries. The information obtained has been compared against the individual requirements of SR1 to make informed, evidence-based judgments as to whether the Project is compliant or not. The findings of the compliance audit have been used to identify recommendations that form the basis of the corrective action plan, which is presented in Section 6.
3.1.1. Desk Based overview
The desk based review of project documentation included the following key documents:
Initial Environmental Examination (IEE), 2017;
Stakeholder Engagement Plan; Emergency response plan;
Quality plan; Others (policy and plan). 3.1.2. Site Visit
The site visit was undertaken from 17th to 18th December 2017 and was attended by two environmental and social safeguards specialist from EQMS Consulting Limited.
Internal stakeholder consultation The following SAL personnel with responsibilities relating to environmental and social safeguards compliance matters facilitated the EQMS environmental and social safeguard specialist during the site visit and provided responses to questions before, during and after the site visit:
Table 3-1: Internal Stakeholder Lists Designation Sl Name S.M 1. M. A Latif D&M 2. Md. Shahin Mahmud M 3. Md. Mohiuddin 4. A.B.M Eqram Hossain M-Qc SAM 5. Md. Abdullah Miah AM(HRM) 6. Mohammed Ali AM 7. Hasan Ahmed SH 8. Md. Rasel Kabir External stakeholder consultation A number of external stakeholders were consulted during the site visit.
3.2. Compliance rating
The compliance audit findings are presented in Section 5 alongside an overall compliance determination which has been assigned on the following basis: Compliance: Taking account of ADB’s policies and requirements, the Project’s practices, documents reviewed and field observations, specialists consider the Project, on the whole, to be compliant with SR1 Non-compliance: Taking account of ADB’s policies and requirements, the Project’s practices, documents reviewed and field observations, specialists consider the Project has at least one area that is not being performed to the required standard of SR1 and that this is of sufficient importance as to prevent compliance with SR1
3.3. Information gaps and limitations
The limitations of the audit approach are that of the duration of the site visit and, based on the timeframes inherent in the audit process, the audit only presents a snapshot of the Project’s performance during the review period.
4. Findings and Areas of Concern
Table 4-1: Audit findings and concern areas Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding Environmental Assessment: Overall Findings: Compliance No further action required Conduct environmental assessment IEE report has been prepared considering potential to identify potential direct, indirect, direct, indirect, cumulative, trans boundary and induced cumulative, trans boundary and impacts and risks. Analysis of alternatives was also induced impacts and risks. Include assessed in IEE report. analysis of alternatives Environmental Planning and Overall Findings: Compliance No further action required Management: Precise environmental planning and management was Avoid, minimize, mitigate, and/or adopted. Furthermore, impact assessment and specific offset adverse impacts and enhance EMP also were prepared and followed. positive impacts by means of Specific Findings: environmental planning and EMP covers following aspects to mitigate different range management. Prepare an of envisaged impacts; environmental management plan Land/Soil resources (EMP) Water Air Noise Waste (Non-hazardous solid) Waste (Hazardous) Occupational Health and Safety Community Health and Safety Risk (industrial accidents, fire accidents) Natural Hazards Information disclosure: Overall Findings: Non The following improvements Disclose a draft environmental Public consultation along with all the local stakeholders Compliance are recommended to ensure assessment (including the EMP). was undertaken before the draft environmental Full Compliance: Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding assessment. But draft environmental assessment report ● Draft environmental hasn’t disclosed to local people yet. assessment report along with the EMP should be disclosed to the local communities so that local people know whether all environmental and social issues were considered. Consultation and Participation: Overall Findings: Compliance No further action required Carry out meaningful consultation Periodical consultation is being done according to with affected people and facilitate Stakeholder Engagement Plan. Stakeholders are their informed participation. informed/discussed in different issues related to project activities those might impact negatively on the local villagers. Specific Findings: Stakeholder Engagement Plan (SEP) has been adopted. Local communities have been consulted twice/thrice in a year according to the SEP. Communities’ perceptions regarding project activities are discussed. Community grievances and suggestions are discussed as well. Communities are informed about the CSR plan and activities. Communities are encouraged by community meetings to take the benefits of CSR activities also. Currently, Pran RFL implementing different categories of CSR activities including Pran RFL Public School, road development etc. In Pran RFL public school, most of local children are getting better schooling opportunity along with all modern school facilities. Two separate roads are being constructed for the ease communication of the local community. Besides this, Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding sufficient numbers of lamp posts have been installed to enhance the security at night for the local people. Grievance Redress Mechanism: Overall findings: Compliance No further action required Establish a grievance redress Active external and internal GRM have been observed mechanism to receive and facilitate working in the project area. Since the operation started resolution of the affected people’s lately, no grievance has been recorded yet. concerns and grievances regarding Specific Findings: the project’s environmental Grievance boxes have been installed in different places performance. in the project area. Local people and employees/workers were found know about how to address grievance.
Monitoring and Reporting: Overall Findings: Non The following improvements Implement the EMP and monitor its Since the initial operational activities started from last complience are recommended to ensure effectiveness. Document monitoring November 2017, periodical external monitoring and Full Compliance: results, including the development reporting for the operation period hasn’t started yet. ● Periodical monitoring, and implementation of corrective However, internal monitoring in some aspects such as reporting must be continued actions, and disclose monitoring water, noise, air is being carried out periodically. during the operational period. reports ● Corrective measures should be taken if necessary and properly discussed with the relevant stakeholders.
Unanticipated Since operational period has been started lately, no Couldn’t Environmental Impacts: sufficient evidence has been found or available right assessed Update IEE and EMP or now to be observed. prepare new IEE and EMP to address unanticipated environmental impacts Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding that become apparent during project implementation Biodiversity Overall Findings: Non The following improvements Conservation and Afforestation and canal protection activities were Compliance are recommended to ensure Sustainable Natural observed. However, required 30000 sft afforestation is Full Compliance: Resource Management: still not achieved. ● Need to complete Ensure specific afforestation requirement. requirements are met for developments in critical habitats or areas of natural habitats. Apply a precautionary approach to the use of renewable natural resources. Pollution Prevention Overall Findings: Compliance No further action required and Abatement: Technologies and practices consistent with international Apply pollution prevention and good practices and technologies to prevent pollution control technologies and practices have been adopted. consistent with international good Specific Findings: practices. ETP plant Waste water is treated in ETP before disposing. Water quality is assessed and recorded periodically. Perishable waste management Perishable sludge is being transferred to fertilizer unit for producing organic fertilizer. Fertilizer quality is being tested periodically as well. Nonperishable waste management Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding Nonperishable waste is deposited separately in separate waste bin. Finally, waste is sold to local vendors. Health and Safety: Provide Overall Findings: Non The following improvements workers with safe and healthy Health and safety procedures are in place and complience are recommended to ensure working conditions and prevent effectively implemented for SAL. However, it remains to Full Compliance: accidents, injuries, and disease. be disclosed to the local community to ensure that any ● Local community specific Establish preventive and emergency risks can be successfully avoided or minimized. This will emergency response plan and preparedness and response be required for further consideration. disclosure is required. measures to avoid, and where Specific Findings: avoidance is not possible, to Safe and healthy working conditions: minimize, adverse impacts and risks Project activities specific HIRA and control mechanism to the health and safety of local have been developed and implemented successfully. communities. Workers have been found using appropriate PPE while working. Adequate numbers of fire extinguishers have been observed. Others firefighting equipment have been found also. In addition to this adequate number of staff/workers have been found who are trained in providing/assisting first aid and fire-fighting. Moreover, medical facilities and ambulance services for the workers have been observed. Preventive and Emergency Preparedness and Response Measures Threat specific emergency response plan for Ammonia Gas Leakage, Fire specific prevention, Spillage of hazardous chemical, flood, earthquake, Terrorist Attack & Bomb Threat have been taken and implemented. Beside all these, periodical fire evacuation drill, training plan and periodical successful training implementation practices have been observed. Additionally, fire license Compliance ADB Safeguard Requirements Audit Findings Recommendation Finding from fire service and civil defense was also available along with periodical renewal. 5. Corrective Action Plan 5.1. Overview
This section presents a corrective action plan (CAP) setting out the actions needed for the Project to comply with ADB Safeguard Requirement 1. 5.2. Corrective action plan
The CAP sets out: The corrective actions based on the findings of the compliance audit and recommendations to achieve compliance with SR1 The deliverable or key performance indicator (KPI) that demonstrates the corrective action has been completed Responsibility for implementing the corrective action Timeline to resolve the corrective action, usually referencing financial close, commencement of construction or operation Estimated budget to achieve the deliverable or KPI, stated as a range or estimated limit. Table 5-1: Corrective action plan (CAP) Sl Corrective Action Deliverable Responsibility Time to resolve Estimated budget
1. Draft Environmental assessment report IEE report (discloser SAL Before next audit BDT 100000 must be disclosed with the local section) stakeholders (Public consultation is required)
2. Monitoring and reporting Environmental and SAL or Before next audit BDT 2400000 (yearly) social monitoring External-internal monitoring and reporting Consultancy firm report are required to start immediately
3. 30000 sft afforestation is required to Environmental and SAL Before next audit BDT 100000 achieve social monitoring report
4. Emergency response plan is required to Community SAL Before next audit BDT 150000 disclose with the local community response plan and discloser
ANNEX-Photographs
Production Process
Storing in cold storage Gradual preheating
Feeder Elevator
Grader, Washing, Destoning, Peeler Conveyor, Slice feed elevator, CC feeder
Shaker, Blencher, Shaker
Fryer, de-oiling, vibrator inspection belt
Seasoning, Metal detector
Packaging Process
Step 1 Step 2
Step 3 Step 4
Stakeholder Meeting
Internal Stakeholder Meeting External Stakeholder Meeting
Internal Stakeholder Meeting (Workers)
Health and Safety in working place
Fire Extinguisher Emergency Exit
Electric shock: First aid and respiratory PPE instruction procedure
Awareness for respecting female workers Hose pipe using instruction
Smoking prohibition Traffic awareness
Grievance Mechanism
Awareness on GRM procedure Grievance Box
Waste Management
ETP Plant Fish culturing in water reservoir pond (treated water)
Organic fertilizer compost Organic fertilizer compost test report
CSR Activities
Public School Road under development