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Environmental Impact Assessment Report Narayanganj

Submitted to Economic Zone Bangladesh Economic Zones Authority June 2016

Bangladesh Economic Zones Authority (BEZA) EIA Report- Narayanganj Economic Zone

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The report has been prepared by PricewaterhouseCoopers Pvt Ltd (PwC) for Bangladesh Economic Zones Authority (BEZA). This is pursuant to the Scope of Work under the contract document "Consulting Services for Social and Environmental Site Assessment of Five EZ Sites at Bangladesh" issued by BEZA. PricewaterhouseCoopers Pvt. Ltd. (PwC) has been appointed by BEZA to undertake an initial site assessment for nine selected economic zones in Bangladesh. PwC would be undertaking the commercial aspects of the scope of work, the technical aspects have been sub contracted to Mahindra Consulting Engineers Ltd. (MACE). Any third party should obtain prior consent of PwC before copying or reproducing, in whole or in part, the contents of this report. PwC disclaims any responsibility for any loss or damage suffered by any third party by taking reliance of this report. Furthermore, PwC will not be bound to discuss, explain or reply to queries raised by any agency other than the intended recipients of this report. All information in the report is intellectual property of BEZA.

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Table of Contents

1. Executive Summary 14

1.1. Baseline and Social Environment 14 1.1.1 Temperature 14 1.1.2 Relative Humidity 14 1.1.3 Rainfall 15 1.1.4 Wind speed and direction 15 1.1.5NaturalHazards 15 1.1.6 Biological Environment 15 1.1.7 Agricultural Resources 16 1.1.8 Livestock and poultry 16 1.1.9 Fisheries 16 1.1.10 Socio-economic 16

1.2. Environment and Social Impacts of the Proposed Project 17 1.3. Conclusion and Recommendations 23

2. Introduction 25

2.1. Project Background 25 2.2. Rationale for the Proposed Project 27 2.3.ScopeandMethodologyoftheStudy 28 2.4. Limitation of the Study 29 2.5. ToR Compliance Matrix 29 2.6. EIA Team 32 2.7.StructureoftheReport 33 2.8. References 34

3. Legislative, Regulation and Policy Consideration 36

3.1. Regulatory Requirements for the Proposed Project 36 3.2. Procedure for Obtaining Environmental Clearance from DoE, Bangladesh 39

4. Project Description 41

4.1. Project Introduction 41 4.2. Project Objectives and Options (Alternate Analysis) 43 4.3. Interventions under selected options and activities 46 4.4. Project Area of Influence 46 4.5. Existing Infrastructure in and around the Project Site/Project Activities 47

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4.5.1. Power Supply for the proposed Site 48 4.5.2. Water Availability for the proposed Site 49 4.5.3.GasSupplytotheproposedSite 50 4.5.4. Telecom/ Internet connectivity to the proposed Site 50 4.5.5. Connectivity 51

4.5.6 ProposedInfrastructure 52 4.6. Project Schedule 33 4.7. Resources and Utilities Demand 33 4.7.1 Water 40 4.7.2 Power Requirement 40 4.8. Estimated Project Cost 40 4.9. Maps and Survey information 40 4.8.1 Project Location 40

4.10. Eco Sensitivity 44 4.11. Geology 44 4.12. Master Plan of Narayanganj Economic Zone 48 4.12.1 Zoning Plan 48 Zone Spotting 48 4.12.2 Detailed Design 50

5. Description of Environment (Environment and Social Baseline) 54

5.1. Methodology 54 5.2. Baseline data Collection 54 5.2.1. Meteorology 55 5.2.2. Water Resources 63 5.2.3. Land Resources 77 5.2.4. Ambient Air Quality 83 5.2.5. Ambient Noise Quality 84 5.2.6. Water Environment 85 5.2.7. Agricultural Resources 90 5.2.8. Livestock and poultry 90 5.2.9. Fisheries 90 5.2.10. Ecological Resources 90 5.2.11. Socio-economic Conditions 93 5.2.12. Traffic Survey 104

6. Identification and Analysis of Key Environmental Issues 105

6.1 Environmental Sensitivity Investigation 105

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6.2 Environmental Asset 105 6.3 Environmental Hotspot 106 6.4 Likely Beneficial Impacts 106 6.5 Community Recommendations and Alternative Analysis 106

7. Impacts Assessment 107

7.1. Introduction 107 7.2. Impact Identification 107 7.3. Impacts on Air Environment 109 7.3.1. Pre-construction phase 109 7.3.2. Construction Phase 109 7.3.3. Operation Phase 110

7.4. Impact on Noise Environment 111 7.4.1. Pre-construction and Construction Phase 111 7.4.2. Operation Phase 113

7.5. Impact on Water Environment 113 7.5.1. Pre-Construction and Construction Phase 113 7.5.2OperationPhase 116

7.6. Impact on Land Environment 118 7.6.1. Pre-construction and Construction Phase 118 7.6.2 Operation Phase 121

7.7. Impact on Biodiversity 122 7.8.ImpactsonAgricultureresources 122 7.9. Impacts on Fisheries 123 7.9.1 Impacts on fisheries during pre-construction and construction phase 123

7.10. Impacts on Occupation Health and Safety 123 7.11. Flood Risk 124 7.12. Sanitation and Disease Vectors 125 7.13. Impacts due to Climate Change 125 7.14. Cumulative Impacts 125 7.15. Impacts on socio-economy 126

8. Public Consultations and Disclosure 127

8.1 Introduction and Objectives 127 8.2 Methodology of Stakeholder Consultations 127 8.3 Levels of Consultations 128 8.4Methodology 128

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8.5 Specific Consultations 129 8.6 Stakeholder Analysis Matrix 129 8.7 Details of Consultations 130 8.8 Consultation Outcomes 135

9. Environmental Management and Monitoring Indicators 140

9.1. Introduction 140 9.2. Mitigation Plan 140 9.2.1 Preconstruction Operations 140 9.2.2 Construction Activity 141 9.2.2.1 Air Environment 141 9.2.2.2 Noise Environment 141 9.2.3 Mitigation Plan for Power Supply 145 9.2.4 Biological Environment/ Greenbelt Development 146 9.2.5 Emergency Preparedness Plan (Contingency Plan) 146 9.2.6 Post Project Monitoring Plan 147 9.2.6.1 Micrometerology 147 9.2.6.2 Air Quality 147 9.2.6.3 Noice Quality 147 9.2.6.4 Surface Water 147 9.2.6.5 Groundwater 148 9.2.6.6 Soil Quality 148 9.2.6.7 Flora and Fauna: 148

9.3. Mitigation Plan for EZ 149 9.4. Monitoring Plan 151 9.5. Monitoring Indicators 152 9.6. Institutional Arrangement 152 9.7. Community development plan 153 9.8. Post Project Monitoring Plan 154 9.9. Environment Management Cell 154 9.10. Compensation Plan 155

10. Cost of EMP 156 11. Conclusion and Recommendation 157

11.1Conclusions 157 11.2 Recommendations 157 11.1. Mitigation Plan for EZ 158 11.2. Emergency Preparedness Plan 160

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11.3. Monitoring Plan 160 11.4. Monitoring Indicators 162 11.5. Institutional Arrangement 162

12. Conclusion and Recommendation 163

12.1. Conclusions 163 12.2. Recommendations 163 Annexure A: Primary monitoring results 164 A) Groundwater Results 164 B) Noise Monitoring Results 165 C) Air Monitoring Results 166 D) Surface Water Analysis Results 167 Annexure B: Land Tranfer Documents 168 Annexure C: Approved ToR from DoE, Bangladesh 174 Annexure D: Land Use Plan of Narayanganj EZ 178 Annexure E: Zone Map of Narayanganj EZ 179 Annexure F: Detail Master Plan of Narayanganj EZ 180 Annexure G: Utility Map of Narayanganj EZ 181 Annexure H: Compliance Matrix as per DoE 182

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List of Figures

Figure 1: Photographs of the project site...... 26 Figure 2: Location Map of Narayanganj EZ...... 27 Figure 3: Steps for Obtaining Environment Clearance from DoE ...... 40 Figure 4: Location of Economic Zone...... 41 Figure 5: Mouza map of proposed site ...... 41 Figure 6: Site Surrounding Features...... 42 Figure 7: Project Area of Influence...... 47 Figure 8: Contour map of the proposed EZ for 5 kmradius (Bandar-Narayanganj) ...... 47 Figure 9: Location of power plants in the vicinity of proposed EZ ...... 48 Figure 10: Sources of drinking water in Bandar and Sonargaon upzila...... 49 Figure 11: Utility map for the proposed site location...... 50 Figure 12: Connectivity of the proposed Economic Zones via Road, Rail and Airport ...... 52 Figure 13: Embankment Details ...... 54 Figure 14: Embankment cross-section details ...... 55 Figure 15: Structural Details for Pile, Plinth beam and Fencing...... 56 Figure 16: EZ location on Upzila Map...... 41 Figure 17: Project site and surroundings ...... 42 Figure 18: Mouza Map with the project site...... 42 Figure 19: Contour Map of the Proposed EZ ...... 42 Figure 20: Topography of the Site...... 43 Figure 21: Geological log for Narayanganj District ...... 45 Figure 22: Geological Map of Bangladesh ...... 46 Figure 23: Geological Map of Narayanganj ...... 47 Figure 24: Proposed zoning map of Narayanganj Economic Zone ...... 48 Figure 25: Zoning map of designated Narayanganj Economic Zone ...... 49 Figure 26: Detailed Master Plan of Narayangonj Economic Zone ...... 51 Figure 27: Detailed Utility Map of Narayangonj Economic Zone...... 52 Figure 28: Wind Rose Diagrams ...... 57 Figure 29: Average monthly sunshine hours in Narayanganj, 2015 ...... 62 Figure 30: Drainage Pattern of the Project Site...... 63 Figure 31: Riverbank Erosion Pattern in Bangladesh ...... 64 Figure 32: Changes in River Morphology, Sitalakhya River ...... 65 Figure 33: Flow Regime of Sitalakhya River, 2003...... 66 Figure 34: Flow Regime of Sitalakhya River, 2005 ...... 66 Figure 35: Flow Regime of Sitalakhya River, 2008...... 67 Figure 36: Flow Regime of Sitalakhya River, 2010 ...... 67 Figure 37: Flow Regime of Sitalakhya River, 2014...... 68 Figure 38: Flow Regime of Sitalakhya River, 2016 ...... 68 Figure 39: Groundwater Zoning Map in Bangladesh, 2010 ...... 70 Figure 40: Groundwater setting of Narayanganj, Bangladesh ...... 71 Figure 41: Seismicity Map of Bangladesh ...... 72 Figure 42: Cyclone affected area map of Bangladesh ...... 73 Figure 43: Cyclone tracking map of Bangladesh...... 74 Figure 44: Flood affected area map of Bangladesh...... 75 Figure 45. Agroecological Regions of Bangladesh...... 77

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Figure 46: General Soil map of Bangladesh ...... 79 Figure 47: Geological log for Narayanganj District...... 81 Figure 48. Land Use Pattern around the subject Site, Narayanganj ...... 82 Figure 49: Monthly variation in pH, DO, BOD, COD, TDS and Chloride in Sitalakhya river samples in 2014, monitored by DoE, Bangladesh...... 87 Figure 50: Mouza Map indicating the project area as provided by the District Commissioner (DC) ...... 93 Figure 51: Age wise PAP distribution ...... 94 Figure 52: Literacy Level of the surveyed PAPs...... 95 Figure 53: Marital status of the surveyed PAPs...... 96 Figure 54: Employment status of PAPs...... 98 Figure 55: Income Level of the PAPs ...... 99 Figure 56: Livestock belonging to the PAPs ...... 102 Figure 57: Embankment cross-section details ...... 124

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List of Tables

Table 1: Environmental Impacts and Mitigation Plan for site preparation and construction of Administration Building ...... 17 Table 2: Mitigation Measures Suggested for Developer...... 21 Table 3: Site Details of the proposed site...... 25 Table 4: Compliance of TOR Points...... 29 Table 5: EIA Team...... 32 Table 6: Reference Used for EIA Study ...... 34 Table 7: Applicability of Key Environmental Legislation at a Glance ...... 36 Table 8: Strength and Weakness of Site ...... 44 Table 9: Frequency of passanger trains from Narayanganj to Dhaka...... 51 Table 10: Implementation Schedule of Off-site Infrastructural Details...... 33 Table 11: Estimated Project Cost...... 40 Table 12: Zoning of Narayanganj Economic Zone...... 49 Table 13: Design phases ...... 53 Table 14: Primary Baseline Data Collection ...... 54 Table 15: Monthly minimum and average minimum temperature during Jan 2005 to Dec 2014...... 55 Table 16: Monthly maximum and average maximum temperature during Jan 2005 to Dec 2014...... 55 Table 17: Monthly average relative humidity during Jan 2005 to Dec 2014...... 56 Table 18: Monthly total and 10 years average monthly rainfall during Jan 2005 to Dec 2014...... 56 Table 19: List of Major Earthquakes in Bangladesh...... 73 Table 20: List of Tornadoes had hit the Bangladesh...... 76 Table 21: Land Type Classification...... 79 Table 22: Representative K values for Unconsolidated Geology...... 82 Table 23: Ambient Air Monitoring conducted within the project site premises ...... 83 Table 24: Air quality at Narayanganj (adjacent to site) in 2015 (µg/m3) (EIA of Basundhara Industrial Complex) ...... 84 Table 25: Ambient noise levels at the EZ site, 2016...... 84 Table 26: Ambient noise levels at the proposed site and surrounding areas (EIA of Basundhara Industrial Complex) ...... 85 Table 27: Comparitive Analysis of the data analysed presently in 2016, from DoE in 2014 and from Basundhara Cement Plant in 2013...... 85 Table 28: Electrical Conductivity in Sitalakhya River during 2014 (µs/cm)...... 87 Table 29: Total Alkalinity in Sitalakhya River during 2014 (mg/L)...... 87 Table 30: Comparitive Analysis of the groundwater quality data analysed presently in 2016 and from Basundhara Cement Plant in 2013...... 89 Table 31: Arsenic contamination in Groundwater in Narayanganj ...... 90 Table 32: Fauna Species in the project area...... 91 Table 33: Floral Species in the project area ...... 91 Table 34: Fish Species in the Study Area ...... 92 Table 35: Demographic Data...... 94 Table 36: PAPs categorized based on their age...... 94 Table 37: Literacy level of PAPs...... 95

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Table 38: Marital Status of PAPs...... 96 Table 39: Health Status of affected households...... 97 Table 40: Availability of Health Facilities at Bandar and Sonargaon Upazila ...... 97 Table 41: Employment Status of PAPs...... 98 Table 42: Income Level...... 99 Table 43: Economic Status- loan and Indebtedness...... 99 Table 44: Range of loan amount...... 100 Table 45: Source of loan...... 100 Table 46: Consumption/ Expenditure Pattern: List of items as per Expenditure...... 100 Table 47: Details of assets owned by PAH’s ...... 101 Table 48: Details of Possession of Vehicles...... 101 Table 49: Livestock...... 101 Table 50: Decision making and participation by women...... 102 Table 51: Traffic Survey Locations ...... 104 Table 52: Environmental Assets of the project area ...... 105 Table 53: Classification of Social and Environmental Components ...... 107 Table 54: Impact Matrix for Proposed Off-site Infrastructure...... 107 Table 55: Noise levels generated by construction equipments (measured at 1 m distance) 112 Table 56: Typical Debris ...... 118 Table 57: Types of Consultations ...... 128 Table 58: Stakeholder Analysis ...... 129 Table 59: Details of Consultation...... 130 Table 60: Positive Impacts perceived by the Stakeholders...... 135 Table 61: Negative Impacts perceived by the Stakeholders...... 136 Table 62: Stakeholder Consultations...... 136 Table 63: Environmental Impacts and Mitigation Plan for constructiomn of access road, Boundary Wall, embankment and Administration Building ...... 142 Table 64: Mitigation Measures Suggested for Developer...... 149 Table 65: Environmental Monitoring Plan...... 151 Table 66: Cost for EMP Implementation...... 156 Table 67: Mitigation Measures Suggested for Developer...... 158 Table 68: Environmental Monitoring Plan...... 160

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Abbreviation & Glossary

EZ Economic Zone BEZA Bangladesh Economic Zone Authority EIA Environment Impact Assessment DoE Department of Environment ISA Initial Site Assessment ToR Terms of Reference WB World Bank HFL Highest Flood Level Ft. Feet KV Kilo Volts BOD Biological Oxygen Demand MVA Mega Volts Ampere BTCL Bangladesh Telecom Company Limited STP Sewage Treatment Plant ETP Effluent Treatment Plant MSW Municipal Solid Waste TPD Tonnes Per Day ECA Environment Conservation Act ECR Environment Conservation Rules O.P. Operational Policy DPHE Department of Public Health and Engineering TDS Total Dissolved Solids ECC Environment Clearance Certificate HT High Tension °C Degree Celsius BRRI Bangladesh Rice Research Institute BMD Bangladesh Meteorological Department IFC International Finance Corporation MLD Million Liters Per Day COD Chemical Oxygen Demand PwC PricewaterhouseCoppers Private Limited

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dB(A) Audible Decibel EMP Environmental Management Plan KLD Kilo Liter per Day VOC Volatile Organic Compounds kmph Kilometer per Hour HDPE high-density polyethylene m/s meter / second H&S Health and Safety mg/kg microgram per kilogram mg/l microgram per liter NOx Oxides of Nitrogen

PM10 Particulate Matter less than 10 micron size

PM2.5 Particulate matter less than 2.5 micron size PUC Pollution Under Control Certificate

SO2 Sulphur Dioxide µg/m3 microgram per cubic meter MACE Mahindra Consulting Engineers Ltd. ToR Terms of Reference RMG Readymade Garments PSDSP Private Sector Development and Support Project FDI Foreign Direct Investment BIWTA Bangladesh Inland Water Transport Authority BWDB Bangladesh Water Development Board SPM Suspended Particulate Matter TBT tributyltin

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1. Executive Summary

The Government of Bangladesh has embarked on the program to develop new Economic Zones (EZs) in the country to promote inclusive economic growth and job creation through the developments of industries. Under the same objective they have conceptualized the Private Sector Development and Support Project (PSDSP) which is supported by the World Bank.

Under PSDSP, PricewaterhouseCoopers Private Limited (PwC) has been appointed by Bangladesh Economic Zone Authority (BEZA) to undertake the Environment Impact Assessment for the Narayanganj (Sonargaon/Bandar) Economic Zone.

The total proposed project area comprises of 340 acres. The land ownership of the 340 acers demarcated for the project is as follows:

 166.09 acres has been allocated to the local stakeholders by DC categorized as “Bandobastho Land”. The land cateogirzed as “Bandobastho Land” has been considered as Private Owned Land.

 124.38 acres of land is categorized as Khas Land.

 49.5 acres of Khas land has been transferred to BEZA by DC and is presently owned by BEZA. The major roads which connect Narayanganj with the rest of the country are: a) Narayanganj-Munshiganj Highway (R812); b) Bandor-Madonpur Highway (R113); and c) Dhaka-Narayanganj Link Road (R111).

The proposed EZ site is linked by the Bandor-Madonpur Highway (R113). The site is about 7 Kms from Narayanganj Railway Station and around 48 Kms from Dhaka International Airport. The site is abutted by Sitalkhya River on the southern side, Meghna Bridge on the eastern side, Sitalakhya Bridge and highway, Mukhtapur-Dhaka Road on the western side and river and residential settlements on the northern side.

1.1. Baseline and Social Environment 1.1.1 Temperature

The monthly minimum (average) temperature at Dhaka varies between 13.50C and 26.60C and maximum temperature varies between 24.46C and 34.50C. The minimum and maximum temperature data indicates that December to February months are relatively cooler and April and May are the relatively hotter months. 1.1.2 Relative Humidity

The average relative humidity at Dhaka varies between 57.30 % in the month of March and 80.20 % in the month of August. The average humidity does not vary much with the change in seasons and is relatively high.

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1.1.3 Rainfall

Rainy season in Dhaka mainly prevails from May to October. The average monthly rainfall in Dhaka for the period Jan 2005 to Dec 2014 varied between 3.5 mm in the month of January and 412.8 mm in the month of July. The rainfall follows the general climate pattern with the highest rainfall in the summer from April to October and minimum rainfall in the winter from November to March. 1.1.4 Wind speed and direction

The monthly wind roses indicate the following trend: NW and northerly winds prevail in January, November and December; wind flows multi-directional in February and October; the predominant wind direction is south followed by SW in March; in April the wind direction is south, the predominant wind direction is south followed by SE from May to July; and in August and September the predominant wind direction is SE followed by south.

The area experiences wind speeds lower than 5 m/s for 98% of time. Of this half the time (44.4%of the time) is calm condition throughout the year (wind speeds in the range of 1-2.5 m/s). This indicates the weather conditions are not favorable for dispersion of pollutants released in the air. Month wise prevailing wind speeds are as follows: predominantly calm conditions prevail during January to March and September to December periods with the area experiencing wind speeds in the range of 1-2.5 m/s. The remaining five months experience lesser calm conditions and wind speeds in the range of 2.5 – 5 m/s. 1.1.5 Natural Hazards

The seismicity map of Bangladesh shows that Narayanganj lies in Zone-2 which shows intermediate level of seismic activity. As per tectonic classification, the area falls under Faridpur trough of Western platform flank which is adjacent to the hinge line.Tectonically this area is inactive and no apparent major structure like fault or fold exists in the region that might be geologically significant (Sir William Halcrow and Partners ltd., 1993).

Narayanganj lies in central Bangladesh it does not lie in risk area and high wind area.

Narayanganj lies in river/monsoon flood affected area. Since, Sitalakhya River is the main surface water body in that area, the proposed site is exposed to high flood risk. Consultations with local people during site visit indicated that there is regular flooding of the project site area during monsoon season. The approximate flooding is about 5 to 6 feet at certain places. 1.1.6 Biological Environment

Flora Due to the plantations along the project site and homestead trees, the area is rich with floral diversities. Different fruit, fuel wood trees along with various shrubs are abundant. Among the trees, the most widely available ones are Shilkoroi, Mehagani, Eucalyptus, Sliimul, etc. but there are some fruit trees also such as mango, coconut, jackfruit, bettlenut, guava etc.

Aquatic Fauna The fishes include catfishes (magura and shing), major carps (katla, rui, and mrigal), minor carps (puti), other (Tengra, Boal, Mola, Shol). Also prawn, particularly the popular small prawns, locally known as lchha are available.

Reptile

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The common types of reptiles are found in the study area includes, water snake, house lizard, soft-shell, turtle etc.

Amphibians Mostly Toads and frogs-two species are prominent.

Mammals These include fruit bat, Squirrel, field and house mousses, and flying box. No major mammal species of national significance are present in this area.

Birds The commonly spotted birds in the project area include kingfishers, house crow, house sparrow, little fern etc.

1.1.7 Agricultural Resources

The proposed site area is used for agriculture purposes. The project site consists of 340 acres of land consisting of Khas land, land owned by BEZA and “Private Bondobostho Land”. Of the 340 acres proposed for the project site, the Khas land constitutes 124.38 acres, 49.5 acres of land has been transferred to BEZA and 166.09 acres of land is “Private Bondobostho Land”. The proposed site is immediately abutted by Sitalakhya River and considering the loamy tyoe of soil, the crop fertility of the proposed site is relatively high. Crops are grown on a biannual cycle basis. Summers and winters are the two distict seasons for the crop production. Paddy, Corn and Bitterguard are the dominant variety during the summer season while Potato, Sweet Potato, Pui Shak and Lau Shak are in the winter season.

1.1.8 Livestock and poultry

There are two poultry farm reported to be there within the project site. Boilers and domestic varieties of chicken are being kept there. The owners use to sell the chicken in local market to earn their livelihood. The loss of livelihood has been enumerated and the owners shall be compensated for their loss of livelihood. 1.1.9 Fisheries

No pisciculture or fish culture are being practiced within the proposed site area. Fishing is a common practice at the project site and people catch fish from the Sitalakhya River and sell it in the local market.

1.1.10Socio-economic

In the project area of influence, most of the affected people were found to be within the age bracket of 18-30 which constituted 35.71% of the total affected PAPs. Considering the age group ranging from 18- 40 as the youth age bracket, a total of 120 within that age group were found to be impacted. So 57.14% of the total affected people are in the age group of 18-40 which is considered as the youth bracket age group. 100% project affected persons are Muslims.

Of the total affected population, 13.33% of the men have achieved secondary level of education where as 10.47% of the women population has achieved secondary level of education. Illiterate populations comprise of 9.52% of the total PAPs whereas illiterate population in women was 8.57% of the total PAP’s. 0.95% males and 0.47% of females of the total population were found to have some kind of vocational and technical trainings. The low education levels emphasize the need for stress on technical

16 EIA Report- Narayanganj Economic Zone education and skill enhancement programs in the region for employment in the industries proposed in the Economic Zone.

Data on health status of affected households indicate that nearly 42.00% of the families have suffered from illness during the last year. Kidney ailment at one household and cardiac ailment at three households were reported which could be categorized as major chronic ailments. Apart from that, the disease reported in the area were respiratory diseases, gastric issues, arthritis.

As per the findings of the social survey a total of 2 Upazilla Health Complex are there in Bandar and Sonargaon Upazila. A total of 16 Community Health Centre are there in Bandar and Sonargaon Upazila. A total of 15 private hospital and dispensaries are there in both the upazilas.

18.09% of PAPs are fishermen. All of them are males. These people catch fish from the Sitalakhya River and sell them at the local market. 38.09% of the PAPs are housewives and 9.04% of the total PAPs are farmers. All the farmers are males.

Out of the 210 of the total surveyed PAPs, 18 males (8.57%) and 81 females (38.57%) falls under the no income group. 2 males (0.95%) and 5 females (2.38%) of the total 210 PAPs, falls within income range of BDT 2000-3000 (per person). 49 males (23.33%) and just 3 females (1.42%) of the total 210 PAPs, do earn above BDT 10,000 per month. People earning more than BDT 10,00o are majorly fishermen while few were found to be working at shops at Dhaka. These people who are mostly dependent on agricultural lands, fishing etc have low to medium level of income. Most of the houses which falls within the affected area doesn’t have basic amenities like electricity.

Women in the region primarily are involved in household work. They are also involved in decision making involving decisions like education of children, decisions before social functions etc. Development of an economic zone will further benefit the socio-economic levels of women and also of the society.

1.2. Environment and Social Impacts of the Proposed Project

The proposed project involves development of following facilities to make site appropriate for development of economic zone:

 Site development  Administrative building  Land filling  External power supply system and substation at project site  External water supply arrangement The following table gives general mitigation measures: Table 1: Environmental Impacts and Mitigation Plan for site preparation and construction of Administration Building

Impact Mitigation Measures

Removal of  When clearing the site, care shall be taken to keep vegetation clearing at a minimum Vegetation  Removal of as little vegetation as possible during the development and re-vegetation of bare areas after the project.

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Setting up of  The construction camps should be at least 500 m distance from habitations from the construction nearest settlements to avoid conflicts and stress over the infrastructure facilities with camps/labour the local community. camps  Location for stockyards for construction materials will be identified at least 1 km from water sources  The living accommodation and ancillary facilities for labour shall be erected and maintained to standards and scales approved by the resident engineer  All sites used for camps will be adequately drained. There should not be any risk of periodic flooding, nor located within 300 feet of pools, sink holes or other surface collections of water  The camps will be located such that the drainage from and through the camps will not endanger any domestic or public water supply  All sites will be graded, ditched and rendered free from depressions such that water may get stagnant and become a nuisance  Construction camps shall be provided with sanitary latrines (1 per 25 pax), bathing facility and urinals.  Sanitary latrines shall be under cover and so partitioned off as to secure privacy, and shall have a proper door and fastenings  Adequate and suitable facilities for washing clothes and utensils shall be provided and maintained for the use of contract labour employed therein.  Sewerage drains will be provided for the flow of used water outside the camp.  Drains and ditches will be treated with bleaching powder on a regular basis.  The sewage system for the camp will be properly designed, built and operated so that no health hazard occurs and no pollution to the air, ground or adjacent watercourses takes place.  Appropriate care should be taken to ensure that the soak pits/ toilets will not penetrate the aquifer to minimize the contamination of the ground water  Clean potable drinking water facility should be provided at the site and the water quality should be monitored regularly  Crèche facility should be provided for children if female workers are employed  First aid facilities should be made available at construction camp. First aid box should contain small, medium and large sized sterilized dressings, sterilized burns dressings, 2 % alcoholic solution of iodine, bottle containing salvolatile, snakebite lancet, , bottle of potassium permanganate crystals, scissors, Ointment for burns & surgical antiseptic solution  1 first aid box should be available for every 50 labour  A person trained in first-aid treatment should be made in charge who will always be readily available during emergency  A suitable motor transport shall be kept readily available to carry injured or ill person to the nearest hospital.  The beach area should be restricted for the workers after sunset  There should not be lighting at the beach area during night time Landfilling  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in downwind direction of the identified sites for getting landfilling material.  The soil used for landfilling should have similar characterisctis to the native soil and free of any type of contamination.

In case of dredging activity for landfilling purposes:

 Dredging should not impact natural drainage courses  Dredging sites should be located away from sensitive locations  Permission from concerned local body should be taken before finalizing the location  Magnitude and frequency of dredging activity should be monitored to avoid impacts on the natural drainage  Prior to dredging activity, analyse the soil sample to prevent impacts on the receiving environment as a result of mismatch in soil characteristics;  During dredging activity, physical barriers such as silt screen/ curtains should be employed to prevent the spread of suspended sediments;  Maintain the extent of the turbidity plumes close to the dredging and disposal areas to minimise impacts on marine fauna habitat;  Visually inspect for any marine life and terrestrial organisms and stop dredging activity in case of any organism in the vicinity;  Monitoring should be done continuously during dredging to observe impacts on the marine life and in case of visible impacts, stop the dredging activity;

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 Dredging should be carried out during day time to minimize impacts on marine life.

Soil Erosion and  Contractor should plan the activities so that no loose earth surface is left out before the Sedimentation onset of monsoon. control  Top soil from debris disposal sites & along the road side should be stripped and kept under covered shed for plantation  After the construction activity is over, top soil will be utilized for landscaping activity.  To avoid soil compaction along the transportation routes, only identified haul roads would be used for transportation.  Turfing of low embankments and plantation of grasses and shrubs should be done in slope stabilization.  Soil erosion checking measures as the formation of sediment basins, slope drains, etc, should be carried out.  Minimize tree felling and vegetation removal  Stockpiling should be done in the opposite of wind direction Disposal of  Waste from construction camp should be segregated at site. Food/wet waste should be Debris and any composted in pit at the site, recyclable should be send to authorized recyclers and waste generated rejected waste should be disposed regularly through responsible agency in the area  Dustbins should be provided at the site and construction camps to prevent littering of waste  Storage area of minimum 2 days should be provided at construction camp for storage of the waste generated from labour camps  Construction debris should also be segregated at the site. This debris should be used for filling to the extent possible. Recyclable waste should be sold through authorized dealers and reject waste should be sent to the identified debris disposal site  All arrangement for transportation during construction including provision, maintenance, dismantling and clearing debris, where necessary will be considered incidental.  Construction debris should be stored under covered sheds on paved surfaces to prevent leaching  Any hazardous waste generated during construction activity shall be stored at designated place and then disposed through the TSDF using high temperation incenaration or any other chemical, thermal, biological, and physical methods. Chemical methods include ion exchange, precipitation, oxidation and reduction, and neutralization.  Utmost care shall be taken to ensure safe collection, transport and disposal of construction waste and debris. Dust Generation  Vehicles delivering materials should be covered with tarpaulin to reduce spills and dust blowing off the load.  Compaction of prepared site to re-strain the fugitive emissions.  Water should be sprayed in the cement and earth mixing sites as well as after compaction.  In high dust areas, workers should be provided and encouraged to use masks.  Regular maintenance, servicing of the vehicles and periodic emission check for equipment and machinery would be carried out in conformity with Schedule 6 – ‘Standards for Emission from Motor’ of The Environment Conservation Rules 1997 (Amended 2002);  Water will be sprayed on the haul road.  All the vehicles entering the project site will be checked for Pollution-Under-Control Certificates.  Air quality monitoring to be carried out during construction phase to check the pollutants level in the air Procurement &  Specifications of crushers, hot mix plants and batching plants, other Construction Setting up of Vehicles, Equipment and Machinery to be procured should comply to the DoE Crushers, Hot- Standards/ norms mix plants, other  Aadequate stack height and emission control devices such as bag house filters, cyclone Vehicles, separators, water scrubbers etc., should be attached Equipment and  Impervious platform for storage of bituminous and other liquid hazardous chemical Machinery  Pollution control measures for Diesel Generator (DG) set i.e. stack height (calculated by H = h+ 0.2 * Sqrt(kVA) where h = height of building where generator set is installed and kVA is total generator capacity), acoustic enclosure etc. should be ensured

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 Provision of readily available first aid kit, fire fighting equipments at the plant site at appropriate location to respond in case of accident.  Periodical monitoring of air quality and noise levels as per conditions stipulated under the statutory clearance from DoE. Whenever the emission exceeds the permissible level the plants should be stopped and necessary repairing works of faults should be done to bring down the emission levels Contamination of  Impervious platform and oil and grease trap for collection of spillage from construction soil equipment vehicle maintenance platform will be appropriately provided at construction camp, servicing area and liquid fuel and lubes at storage areas.  Proper management of waste from labour camps and construction site  Proper disposal of wastewater generated from labour camp and construction site Contamination of  Car washing / workshops near water bodies will be avoided. surface & ground  Avoid excavation during monsoon season water  Loosened soil will be stabilized by Contractor through landscaping and developing vegetation, wherever possible, once construction activity is completed at any site.  Sanitation facility with septic tank followed by soak pit will be developed. Common toilets will be constructed on site during construction phase and the waste water would be channelized to the septic tanks and soak pits in order to prevent waste water to enter into the water bodies.  Provision of oil & grease traps upstream of storm water drains  Surface run off due to construction activity will not be discharged in open without treatment. Loss of water  No excavation from the bund of the water bodies. bodies/ surface /  No earth will be excavated for development of any off-site facility ground  No debris disposal near any water body.  Prior written permission from authorities is required for use of water for construction activity.  Construction labours to be restricted from polluting the source or misusing the source.  Labour camps will be located away from water bodies. Drainage and  The Contractor will always clear all the cross drainage structures and natural drainage runoff before onset of monsoon in order to keep all drainage unblocked Earth, stones, wastes and spoils will be properly disposed off, to avoid blockage of any drainage channel.  All necessary precautions will be taken to construct temporary or permanent devices to prevent inundation Noise from  Construction activities would be carried out in the daytime only. Vehicles, Plants  The construction equipment would be provided with adequate noise control measures and Equipment and should comply with the noise standards as prescribed by DoE  Regular maintenance of vehicles and equipment would be carried out and corrective action taken in case of any deviation.  Ear muff/ear plug shall be given to the workers working around or operating plant and machinery emitting high noise levels.  DG sets if installed should be provided with acoustic enclosures  Labour working in noise prone area should be provided with ear plugs and job rotation should be practiced to prevent the prolonged exposure of any workers to high noise levels Loss or damage to  Vegetation will be removed from the construction zone before commencement of vegetation construction. All works will be carried out such that the damage or disruption to flora other that those identified for cutting is minimum.  Only ground cover/shrubs that impinge directly on the permanent works or necessary temporary works will be removed with prior approval from the Environmental Expert.  Trees identified under the project will be cut only after receiving clearance from the Forest Department  Vegetation only with girth of over 30 cm measured at a height of 1.0 m above the ground will be considered as trees and shall be compensated.  Compensatory plantation should be carried out in the ratio of 1:2

Loss, damage or  Construction workers will be directed not to disrupt or damage the fauna. disruption to  Construction vehicles will run along specified access to avoid disturbing the habitats fauna of flora and fauna.  EZ development should be planned in such a way to avoid or minimize tree cutting  Twice the nos. of trees to be fell should be planted as compensatory plantation in affected areas to minimize the impact on the eco-system  No waste shall be discharged in water bodies

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 Green buffer all around the project site will include most of the native plant species, which will significantly improve the ecology of the area.  Periodic monitoring shall be carried out as per the monitoring plan for air, water, noise and soil and ensure that no impact  Tree survival rate shall be monitored  Accidents  Safety officer should be appointed at site to ensure all the safety guidelines are being followed at site  Cautionary guidance should be provided at site to aware people about the associated risk with the area. Entry to the fuel storage room or machinery operation room should be restricted only to authorized trainer personnel  All Accidents shall be reported immediately and incident analysis, preventive measures shall be implemented. Clearing of  Contractors shall prepare site restoration plans. The plans shall be implemented prior Construction of to demobilization. Camps &  On completion of works, all temporary structures shall be cleared, all rubbish burnt, Restoration excreta or other disposal pits or trenches filled in and sealed and the site left clean and tidy. Occupational  All construction worker should wear PPEs including safety jacket, helmet, gloves, gum Health & Safety boots, ear plugs, mask while working at the site Plan  Workers should be made aware about the health issues related with open defecation  Training to workers should be provided for handling the construction equipment and machinery  Training to the workers should be provided to handle the emergency situations like fire, floods etc.  First aid facility and sufficient nos. of trained personnel should be available at all the time at construction camp  Cautionary signage and notice should be displayed in local language and English at the required places like fuel storage area so that hazards can be avoided. A security guard should be deputed in these areas and entry should be restricted  A register of all toxic chemicals delivered to the site shall be kept and maintained up to date. The register shall include the trade name, physical properties and characteristics, chemical ingredients, health and safety hazard information, safe handling and storage procedures, and emergency and first aid procedures for the product.  A register of Materials Safety Data Sheets (MSDS) relating to all hazardous substances on board, will be maintained Disaster Precaution will be taken to prevent danger of the workers and the public from fire, flood, Management drowning, etc. All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

Table 2: Mitigation Measures Suggested for Developer

Impact Mitigation Measures

Identification of Site for  Site identified should be 1.0 km away from settlement, sensitive Disposal of construction Debris, locations, like school, hospital, religious structures, reseve forest construction labour camp and and any other eco-sensitive zone etc. plant site  Site identified should be approved by BEZA and PMC  Site should be located in downwind direction from settlement area  Fertile agricultural land and community land should be avoided for setting of these facilities Air Pollution  Sprinkling of water during construction phase on all unpaved roads, site and haul roads  Avoiding excess pilling of raw material and debris at site  Storage & transportation of raw material and debris in covered conditions  Cutting of only identified trees after obtaining permission of forest department  Regular cleaning of site  Guiding signage should be provided at the site for vehicles

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 Timings of the construction material vehicles should be fixed and should be during non-peak hours to prevent traffic congestion and traffic jams  Usage of low energy intensive building material like fly ash mic cement and bricks  Usage of low sulphur diesel for running DG sets, construction vehicles and equipments  Obtaining temporary electricity connection during construction phase and operating DG sets only during power failure  Open burning of wood or any other material should be prohibited at site and all the workers should be made aware about the same Water Pollution & water  Minimizing the run-off from the site by construction of sediment Conservation basins  Maintaining the flow of water sprinklers so as to avoid wastage of water  No debris should be thrown or disposed off in any water body like river, pond, canal etc or ground water source like functional or abandoned well  Excavation should not be carried out during monsoon  Provision of temporary storm water drainage system during construction phase to drain the storm water  Excavated pits should be provided with garland drains to prevent enterance of water inside the pit  Provision of oil & grease traps wih the storm water drains draining the parking and fuel storage area  Provision of septic tanks and soak pits at the site & labour camps for disposal of sewage generated by construction labour  Waste generated by construction camps should be disposed off regularly at the identified site for debris disposal  Provision of cross drainage structures like balancing for maintaining the drainage pattern  Stone & bricks should be purchased only from licenced vendors  Keeping provision of land for development of STP for each industry  Tank alarms should be installed so as to prevent overflow of water  Leakage detection should be carried out quarterly so as to detect any leakages in the gas pipeline Soil Quality  Top soil, if excavated from the project site should be stored in covered condition and should be used later for landscaping purpose  Storage of raw materials, debris and fuel on paved surfaces  Training the workers to handle the material so as to minimize spillage of material on soil  Provision of cross drainage structures to prevent water logging and soil erosion  Stone pitching with grass turfing should be done for the high embankment close to water body  Disposal of construction debris, municipal waste from labour camps and hazardous waste from site should be disposed off at the identified site  Keeping provision of land for development of soild waste management facility within the EZ site  No open area should be left without the vegetation to protect the soil.  Mulching of soil should be done regularly to prevent direct exposure of soil to wind and water Noise Pollution  Construction vehicles, machinery and equipment used for construction purpose should meet the standards prescribed by DoE  Upkeeping and regular maintenance of all the construction vehicles, machinery and equipment used for construction purpose  Provision of acoustic enclosures, noise mufflers, silencers etc with the DG sets and any noise generating machinery

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 Provision of temporary noise shield/barrier in areas where more noise will be generated

Ecology  Only identified trees should be fell down after obtaining permission from forest department  Comensatory plantation should be carried out in ratio of min 1:2 under guidance of forest department  Development of thick green buffer all along the periphery of EZ  Boundary should be constructed around the EZ site to prevent trespassing of the animals  Native plant species requiring should be considered for plantation  No waterbody should be filled outside the EZ site  Disaster and Risk Management  Provision of first aid kit and first aid room and well trained first aid practioner at the site all the time  Ambulance facility should be provided at the site  Tie-ups with local hospital should be made to handly emergency case, if any  Availability of safety officers and supervisiors at all the time on the site  Workers should be given training for handling construction vehicles, equipment and handling emergency situations like fire, floods, earthquake and cyclone  Cautionary signage should be provided in the areas associated with risks like storage of explosives, fuels, heavy construction material etc. Entry for only trained authorized personnel should be allowed in such areas with adequate safery measures  Emergency handling cell & room should be developed at the site and should be headed by project & safety manager  Contact no. of nearest fire-station and hospitals should be displayed within the emergency handling room

1.3. Conclusion and Recommendations

Overall the impacts from both construction and operation phase have limited adverse environmental impacts, and can be readily addressed through mitigation measures as provided in EMP. BEZA, formed under EZ Act, 2010 is overall agency for implementation of EZ projects for rapid ecomonic development of Bangladesh. The EZ will be developed following PPP approach. BEZA will invest in land and related off-site infrastructure development so as to make zone accessible and resourceful. Thereafter economic zone development will be responsibility of private developers. The off-site facilities proposed to be developed by BEZA include development of administration building, boundary wall, electrical supply, and access road. The project falls under Red category as per ECA, 1995 and requires prior environment clearance from DoE, Bangladesh. The recommendations made for the project development on the basis of EIA study are given below:

 Construction activities for the development of project should be started after obtaining environment clearance certificate from DoE, Bangladesh

 Proposed environment management plan should be implemented strictly both during operation and construction phase of the project.

 Trees cutting should be minimum and compensatory plantation should be carried out in ratio of 2:1 (i.e. 2 trees planted for every tree cut)

 Proper training of maintaining environment, health and safety should be given to Project management unit in both construction and operation phase  Provision of garland drain, thick green belt, STP, segregated storm water shall be adhered to.

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 Environmental monitoring should be conducted as proposed in environment management plan.

 Before development, seperate environment impact assessment study should be carried out by individual units proposed to be developed in the EZ.  Ecological assessment should be carried out for the proposed EZ before commencement of the project.

 While commencement of the project, care should be taken to minimize impacts on biodiversity.

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2. Introduction

The Government of Bangladesh has embarked on the program to develop new Economic Zones (EZ) in the country, with the objective of inclusive economic growth and job creation through developments of industries. The new EZ regime provides for a new approach both in management and investment.

Bangladesh Economic Zone Authority (BEZA) has been promulgated under the Bangladesh Economic Zones Act, 2010 to develop the Economic Zones across the country. BEZA, after the initial site assessment, finalized to develop an Economic Zone housing Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials Agro, Food and Fish processing, light engineering industries in the Bandar and Sonargaon upazila under Narayanganj district.

As part of the Private Sector Development and Support Project (PSDSP), supported by the World Bank, PricewaterhouseCoopers Private Limited (PwC) was appointed by BEZA to undertake the Environmental Impact Assessment for the Narayanganj economic zone.

2.1. Project Background

The proposed Economic Zone site falls in both Bandar and Sonargaon upzila. The project involves development of EZ and off-site facilities for Naryanganj Economic Zone by BEZA. The site is surrounded by several cement plants such as Shah Cement, Bashundhara Cement etc and power plant. The site details are provided in table 1. The total proposed project area comprises of 350 acres. The major roads which connect Narayanganj with the rest of the country are:  Narayanganj-Munshiganj Highway (R812);  Bandor-Madonpur Highway (R113); and  Dhaka-Narayanganj Link Road (R111). The project site is abuted by Dhaleshwari River- South to North-West, confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna) - North East to South, Industrial and residential, facilities- North-West to North-East. The site photographs are shown in figure 1. The proposed project involves development of following offsite facilities to make site appropriate for development of economic zone:

 Administrative building  Land filling  External power supply system and substation at project site  Water supply arrangement at project site from borewells

Table 3: Site Details of the proposed site

Parameters Details Site co-ordinates 23° 34' 26.41"N to 23° 35' 35.06"N latitude, 90° 30' 48.88"E to 90° 33'25.28"E longitude Site boundaries on East Meghna bridge Site boundaries onWest Shitalkhya Bridge and Highway, Mukthapar-Dhaka Road Site boundaries on North River & Residential houses Site boundaries on South Shitalkhya River Total area of the site 340 acres Land tenure details Private Land and Government owned Vicinity of proposed site Proposed EZ area is surrounded by:  Dhaleshwari River- South to North-West

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 confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna)- North East to South  Industrial and residential facilities- North-West to North- East Existing land use Agriculture

Figure 1: Photographs of the project site

Dredging at the River Agricultural Fields

Agricultural Fields Green vegetations at the site area

Tributary of Brahmaputra River on the northern Cement Plant on the opposite side of the river Side of the Site

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Figure 2: Location Map of Narayanganj EZ

Source: http://1.bp.blogspot.com/-h-64leOs7E/Tnevk6J4w_I/AAAAAAAAAEA/o_USBFVktMU/s1600/ Narayanganj+District+Map.gif

2.2. Rationale for the Proposed Project

Bangladesh is primarily an agricultural economy with close to 50% of the labor force employed in agriculture. Industry sector contribution to Gross Domestic Product (GDP) has hovered around 25-30% only for past few years. Manufacturing sector of Industry shows predominance of export led garments and textile industries and comprise of 52% share of total exports in Bangladesh making it the world’s second largest garment manufacturer. Bangladesh also needs to bolster exports of other indigenous products, which will happen through enhanced industrial infrastructure, capacity building, and policy initiatives. Similarly, the country may choose to substitute imports of capital goods and other items of domestic consumption, provided there is adequate investment in industrial infrastructure to enable domestic manufacturing.

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The Government of Bangladesh has, in the past, successfully provided tailored infrastructure services and business environment conditions through EPZs. EPZs were used as a strategic instrument for attracting Foreign Direct Investment (FDI) and dealing with the shortcomings of the overall investment climate, business registration, licensing, etc. which were restricting investments in the Domestic Tariff Area (DTA). To overcome the limitations of EPZ model, new EZ regime has been adopted by the Government of Bangladesh so as more spill-over can be harnessed by local firms from FDI , additional investments can be encouraged within value chains, more local produce can be procured and better linkages can be established between manufacturing firms and educational institutions. The EZ development, a zoned industrialization, is required in Bangladesh to maximize the growth benefits of agglomeration and ease the increasing urban congestion. More importantly, the project will enable new sources of growth, where investor will show their interest. 2.3. Scope and Methodology of the Study

The scope and methodology for the EIA of the proposed site are:

 Identification and review of applicable local, state, national and international environmental and social regulatory and institutional frameworks;  Establishment of environmental baseline conditions of the site and surrounding area through the following:  Detailed surveys to observe environmental and social characteristics of the project area;  Discussions with the stakeholders and identification key issues during planning, construction and operation phase of the project;  Baseline data collection of the site and project area with respect to water and soil quality, ambient air and noise quality, environmental hazards and  Ecological assessment on flora and fauna of the site and project area through secondary data collection.  Assessment of the socio-economic environment through collation of secondary information of the site, supplemented by consultations with the local communities to understand community perception with regard to the project and its activities;  Preparation of the EIA report which includes:  Project Description describing the proposed project and its geographic, ecological, social, health and temporal context, including any related facilities that may be required;  Applicable Environmental Regulatory Framework including host country regulations, obligations for implementing relevant international social and environmental treaties, agreements, and conventions and WB Operational policies;  Environmental Baseline Conditions on the basis of the above identified parameters to understand the profile of the area and describe relevant physical, biological, health and labour conditions in the project area of influence;  Impact Assessment and Mitigation Measures for environmental and social components for pre-construction/construction and operation phases. To minimize the adverse impacts mitigations measures will also be suggested; and  Preparation of Environmental Management Plan (EMP) and Management System which includes the following: o Mitigations for adverse environmental impacts and associated risks; o Institutional arrangement - management tools and techniques for the implementation of environmental impacts and risk mitigations; o Monitoring and reporting of requirements and mechanisms for the effective implementation of the suggested mitigations; o Monitoring arrangements for effective implementation of suggested mitigations for the proposed project; and

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o Preparation of EMP accordance with the Performance Standards of IFC.

2.4. Limitation of the Study

The present EIA Report has been prepared based on the field investigations / assessment, and secondary data from data collected from Department of Public Health and Engineering (DPHE), Department of Environment (DoE), Bangladesh Meteorological Department (BMD), Bangladesh Water Development Board (BWDB), 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 judgement and subjective interpretation of facts and observations has been applied for the preparation of the EIA Report. Since offsite facilities are proposed to be developed by BEZA, required information essential for EA are available. The onsite (industrial area detailed planning will be carried out by prospective private developer) information are available limited to feasibility assessment.

2.5. ToR Compliance Matrix

The EIA study has been conducted in accordance with the ToR issued submitted to DOE. Below Table presents the point-wise compliance of the issued ToR. Table 4: Compliance of TOR Points

S. No. ToR Point Compliance

I The project authority shall conduct a comprehensive EIA study has been carried out in Environmental Impact Assessment (EIA) study line with the ToR Approved by considering the overall activity of the said project in DoE and WB guidelines accordance with this ToR and following additional suggestions II The EIA Report should be prepared in accordance Agreed with following indicative outlines: 1 Executive Summary Refer Chapter 1 2 Introduction: (background, brief description, Refer Chapter 2 rationale of the project, scope of study, methodology, limitation, EIA team, references) 3 Legislative, regulation and policy consideration Refer Chapter 3 (covering the potential legal, administrative, planning and policy framework within which the EIA will be prepared) 4 Project Description Refer Chapter 4 i. Introduction Section 4.1 ii. Project objective Section 4.2 iii. Project options Section 4.2 iv. Interventions under selected options Section 4.3 v. Project activities: A list of the main project activities Section 4.5 to be undertaken during site clearing, construction as well as operation vi. Project schedule: The phase and timing for Section 4.6 development of the project vii. Resources and utilities demand: Resources required Section 4.7 to develop the project, such as soil and construction material and demand for utilities (water, electricity, sewerage, waste disposal and others), as well as infrastructure (road, drains, and others) to support the project viii. Map and survey information Section 4.8

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Location map, cadastral map showing land plots (project and adjacent area), geological map showing geological units, fault zone, and other natural features 5 Environmental and Social Baseline Refer Chapter 5 5.1 Meteorology Section 5.2.1 5.1.1 Temperature Section 5.2.1.1 5.1.2 Humidity Section 5.2.1.2 5.1.3 Rainfall Section 5.2.1.3 5.1.4 Wind Speed Section 5.2.1.4 5.1.6 Sunshine hours Section 5.2.1.5 5.2 Water Resources Section 5.2.2 5.2.1 Surface Water System Section 5.2.2.1 5.2.2 Tropical cyclones and Tidal Flooding Section 5.2.2.8 & 5.2.2.9 5.2.3 Salinity Section 5.2.2.2 5.2.4 Drainage Congestion and Water Logging Section 5.2.2.1 5.2.5 Erosion and Sedimentation Section 5.2.2.3 5.2.6 River Morphology Section 5.2.2.4 5.2.7 Navigation Section 5.2.2.5 5.2.8 Ground Water System Section 5.2.2.6 5.3 Land Resources Section 5.2.3 5.3.1 Agroecological Regions Section 5.2.3.1 5.3.2 Land Types Section 5.2.3.2 5.3.3 Soil Texture Section 5.2.3.3 5.3.4 Land Use Section 5.2.3.4 5.4 Agriculture Resources Section 5.2.7 5.4.1 Farming Practice Section 5.2.7 5.4.2 Cropping Pattern and Intensity Section 5.2.3.1 and 5.2.7 5.4.3 Cropped Area Section 5.2.7 5.4.4 Crop Production Section 5.2.7 5.5 Livestock and Poultry Section 5.2.8 5.5.2 Livestock/Poultry Diseases Section 5.2.8 5.6 Fisheries Section 5.2.9 5.6.1 Introduction Section 5.2.9 5.6.2 Problem and Issues Section 5.2.9 5.6.3 Habitat Description Section 5.2.9 5.6.4 Fish Production and Effort Section 5.2.9 5.6.5 Fish Migration Section 5.2.9 5.6.6 Fish Biodiversity Section 5.2.10.2 5.7 Ecological Resources Section 5.2.10 5.7.1 Bio-ecological Zone/Protected Areas Section 5.2.10 5.7.2 Common Flora and Fauna Section 5.2.10 5.7.3 Ecosystem Services and Function Section 5.2.10 5.8 Socio Economic Condition Section 5.2.11 5.8.1 Socio Economic Condition Section 5.2.11 5.8.2 Quality of Life Indicators Section 5.2.11 5.8.3 Income and Poverty Section 5.2.11 5.8.4 Gender and Women Section 5.2.11 5.8.5 Common Property Resources Section 5.2.11 5.8.6 Conflict of Interest and Law and Order Situation Section 5.2.11 6 Identification and Analysis of Key Environmental Refer Chapter 6 Issues (Analysis shall be presented with Scenarios, Maps, Graphics, etc. for the Case of Anticipated Impacts on Baseline) 6.1 Environmental Sensitivity Investigation Section 6.1 6.2 Environmental Aspect/Valued Environmental Section 6.2 Components 6.1 Environmental Hot Spots Section 6.3

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6.1 Likely Beneficial Impacts Section 6.4 6.1 Community Recommendations Section 6.5 6.1 Alternate Analysis Section 6.5 7 Environmental and Social Impacts/Impact Refer Chapter 7 Assessment 7.1 Introduction Section 7.1 7.2 Impact on Water Resources Section 7.5 7.2.1 Pre-construction Phase Section 7.5.1 7.2.2 Construction Phase Section 7.5.1 7.2.3 Post-construction Phase Section 7.5.2 7.3 Impact on Land Resources Section 7.6 7.3.1 Pre-construction Phase Section 7.6.1 7.3.2 Construction Phase Section 7.6.1 7.3.3 Post-construction Phase/Operation Section 7.6.2 7.4 Impact on Agriculture Resources Section 7.8 7.4.1 Pre-construction Phase Section 7.8 7.4.2 Construction Phase Section 7.8 7.4.3 Post-construction Phase Section 7.8 7.5 Impact on Fisheries Section 7.9 7.5.1 Pre-construction Phase Section 7.9 7.5.2 Construction Phase Section 7.9 7.5.3 Post-construction Phase Section 7.9 7.6 Impact on Ecosystem/Biodiversity Section 7.7 7.6.1 Pre-construction Phase Section 7.7 7.6.2 Construction Phase Section 7.7 7.6.3 Post-construction Phase Section 7.7 7.7 Socio Economic Impact Section 7.15 and Section 7.12 and Section 7.10 7.7.1 Pre-construction Phase Section 7.15 and Section 7.12 and Section 7.10 7.7.2 Construction Phase Section 7.15 and Section 7.12 and Section 7.10 7.7.3 Post-construction Phase Section 7.15 and Section 7.12 and Section 7.10 8. Public Consultation and Disclosure Refer Chapter 8 8.1 Introduction Section 8.1 8.2 Objectives of Public Consultation and Disclosure Section 8.1 Meeting 8.3 Approach and Methodology of Public Consultation Section 8.2 and Disclosure Meeting 8.4 Public Consultation Meetings (PCMs) Section 8.3 8.5 Public Disclosure Meetings Section 8.4 (PDMs)/Methodology/Details of Consultations 9. Environmental Management Plan and Monitoring Refer Chapter 9 Indicators 9.1 Introduction Section 9.1 9.2 Mitigation Plan Section 9.2 9.3 Enhancement Plan/Institutional Arrangements Section 9.6 9.4 Contingency Plan/Emergency Preparedness Section 9.3 Plan/Mitigation Plan for EZ 9.5 Compensation Plan Section 9.10 9.6 Monitoring Plan Section 9.4 9.7 Monitoring Indicators Section 9.5 10 Cost Estimation for Environmental Mitigation Refer Chapter 10 Measures and Monitoring 11. Conclusions and Recommendations Refer Chapter 11 III Without obtaining approval of EIA report by the Agreed Department of Environment, the Project authority

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shall not be allowed to conduct earth filling or any kind of physical intervention in the proposed project site and also not be able to start the physical activity of the project. IV This approval of the Terms of Reference (ToR) Agreed would not mean any acceptance or site clearance of the Project. V The proposed EIA study would not establish any Agreed claim, right in favour of the proponent for getting site clearance or environmental clearance. VI. Without obtaining Environmental Clearance, the Agreed project authority shall not be able to start the operation of the project. VII. The project authority shall submit the EIA along Agreed with the No Objection Certificate (NOC) from the local authority, NOC from Forest Department (if it is required in case of cutting any forested plant, private or public) and NOC from other relevant agencies for operational activity etc. to the Bagerhat District Office of DOE with a copy to the Head Office of DOE in Dhaka.

2.6. EIA Team

BEZA has appointed M/s PricewaterhouseCoopers Pvt. Ltd. For carrying out environmental and social impact assessment studies for development of five upcoming EZs in Bangladesh. As per the procedure, proposed Terms of Reference (ToR) was submitted to DOE in May 2016. Approved ToR was granted by DoE vide Memo No. DoE/Clearance/5457/2016/228, dated 13 June, 2016. Copy of the approved ToR by DoEB is attached as Annexure II. The EIA study for the development of proposed Sabrang EZ has been carried out as per the ToR issued by DoEB, World Bank’s requirements and Environmental Management Framework of BEZA. The PwC team appointed for carrying out the ESIA studies is mentioned below: Table 5: EIA Team

Team Member Position Experience Yasir Ahmad Team Leader and More than 12 years of experience in Environmental Environmental Specialist and Social policy development, Social/Environmental audits, Environmental and Social impact assessment (ESIA) reviews, Environmental Due-diligence, Responsible investment related engagements for various industrial sectors including infrastructure, retail etc. Dr. D.J Rao Environmental and Tourism Doctrate with more than 28 years of experience in Specialist Environmental and Social Impact Assessment (ESIA) for diverse sectors, Community /Stakeholders’ Consultation, Risk Management, Environment and Social Mitigation Plan, carbon and sustainability strategy, etc. Mr. Sandeep Kota Project Manager More than 8 years of experience in Environment and Social impact assessment, Environmental management plan, Health and Safety compliance audits, Environmental Due-diligence, Responsible investment related engagements for various industrial sectors. Ms. Anjali Yadav Environmental Expert Five years of experience in Environment and social impact assessment, Environmental and social

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reviews, Environment and social policy development, Environment health and safety audits, Site investigation & characterization, Environmental site assessments (phase I & phase II ESA) and Remediation of soil and groundwater. Mr. Dhiman Environmental Expert Five years of experience in Environment and social Chakraborty impact assessment, Environmental and social reviews, Environment and social policy development, Environment health and safety audits, Site investigation & characterization, Environmental site assessments (phase I & phase II ESA) and Remediation of soil and groundwater

2.7. Structure of the Report

This EIA report has been prepared strictly following the report structure as per TOR. The EIA report contains project features, baseline environmental conditions, assessment of environmental impacts, and formulation of mitigation measures along with environmental management and monitoring plan. The report includes the following chapters: Chapter 1: Executive Summary The chapter provides the brief summary of the EIA report.

Chapter 2: Introduction This chapter provides background information of the project proponent, need for the EIA study as per prevailing legislation, Location and brief description of the project, methodology adopted for EIA study and structure of the report.

Chapter 3: Legislative, regulation and policy consideration This chapter deals with the details of the potential legal, administrative, planning and policy framework which have beed used in the preparation of the EIA Report.

Chapter 4: Project Description This chapter presents the details of the proposed EZ such as location, connectivity, project requirements, Infrastructure development, environmental consideration, etc.

Chapter 5: Environmental and Social Baseline This Chapter describes the baseline environmental conditions around the project site for various environmental attributes, in the project area of influence which is termed as the study area. Topography, soil, water, meteorology, air, noise, and land constitute the physical environment, whereas flora and fauna constitute the biological environment.

Chapter65: Identification and Analysis of Key Environmental Issues This chapter details the analysis of the key environmental impacts

Chapter 7: Impact assessment This chapter details the impacts due to the project activities and suggestive mitigation measures

Chapter 8: Public consultations and disclosure This Chapter provides details for the public consultation meetings in study area and the outcomes of public consultations

Chapter 9: Environmental Management Plan and Monitoring Indicators

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This Chapter provides mitigation and control measures to attenuate and/or eliminate environmental impacts, which are likely to be caused by the proposed project. An Environmental Management Plan (EMP) has been developed to mitigate the potential adverse impacts and to strengthen the beneficial impacts. This chapter also provides the environmental monitoring plan proposed for the project.

Chapter 10: Cost of EMP This chapter provides the tentative cost for the implementation of EMP

Chapter 11: Conclusions and Recommendations This chapter concludes on the findings that emerged from the environmental assessment study and summarizes the key points to be addressed to ensure the environmental sustainability of the project during the construction and operation phases.

2.8. References

List of secondary data used for carrying out EIA study and preparation of EIA report is given at the following table.

Table 6: Reference Used for EIA Study

S. No. Reference Government Departments 1. Bangladesh Economic Zone Authority 2. Department of Public Health and Engineering 3. Department of Environment 4. Bangladesh Meteorological Department 5. Bangladesh Forest Research Institute 6. Bangladesh Bureau of Statistics 7. Geological survey of Bangladesh 8. Bangladesh Water Development Board 9. Department of Disaster Management 10. Bangladesh Inland Water Terminal Authority (BIWTA) 11. Keraniganj Upazila Office 12. Keraniganj Union Office 13. District Forest Department, Cox Bazar Journals & Books 1. Population and Housing Census-2011, Community Report: Munshiganj, Bangladesh Bureau of Statistics, Statistics and Informatics Division, Ministry of Planning 2. Sirajur Rahman Khan, Revised by Michiel Damen, ITC, Cyclone Hazard in Bangladesh, 2013 3. Banani Mandal, Arunava Mukherjee, Subrata Sarkar & Samir Banerjee, Study on the Ornamental Fin Fish of Indian Sundarbans with Special Reference to Few Floral Sources for Carotenoid Pigmentation, 2012 4. Community Report Dhaka Zila June 2012, Population and Housing Census 2011, Bangladesh Bureau of Statistics, Statistics and Informatics Division, Ministry of Planning 5. District Dhaka 2011 Dhaka, Bangladesh Bureau of Statistics (BBS), Statistics and Infrmation Division (SID), Ministry of Planning, Government of the People’s Republic of Bangladesh 6. Sample Baseline and Preliminary Estimation by Baangladesh University of Engineering and Technology (BUET), 2012. 7. Keraniganj Upazila Health Complex, Ministry of Health and Family Welfare (MOHFW), Health Bulletin 2014 8. Tonmoy Sarker, Sedimentation process at Navigation Channel of Mongla Port on the Pasur Sibsa river system in Bangladesh, UNESCO IHE Institute of Water Education The Netherlands 9. “Consequences of Climate Change on Fish Biodiversity in the River Turag, Bangladesh: A Community Perception Studies” by B.Paul, Md. Hasan Faruque and Dewan Ali Ahsan; World Journal of Fish and Marine Sciences 6 (2): 136 – 141; Department of Fisheries, University of Dhaka 10. Adhikary, S.K., Gupta A. D. & Babel M.S., Modelling Groundwater Fow and Salinity Intrusion by Advective Transport in the Regional Unconfined Aquifer of SouthWest Bangladesh 11. Bangladesh Delta Plan 2100 Formulation Project, River System Management, 2015 12. Assessing Risk to Groundwater from On-Site Sanitation: Scientific Review and Case Studies, British Geological Survey 13. Land Use Change Detection of the Buriganga River using GIS tools and its Water Management for Promoting a Sustainable Environment, Syed Mahmud-ul-Islam, May 2011

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14. “Investigation of Vertical Distribution of Soil Elements at Central Part of Bangladesh Using Neutron Activation Analysis” by Md. Saifur Rahman, Syed Md. Hossain, Md. Jamal Uddin; International Journal of Environmental Protection: Feb 2013, Vol. 3 (5 – 13) 15. Final Report on Development of Deep Aquifer Database and Preliminary Deep Aquifer (First Phase), March 2006, Local Government Division, Ministry of LGRD. 16. “Urban Groundwater Protection and Management: Lessons from 2 Developing City Case Studies in Bangladesh and Kyrghyzstan” by B.L Morris, R.G Litvak and K.M Ahmed 17. “Preparation of Detailed Area Plan for Dhaka Metropolitan Development Planning (DMDP) Area” by Rajdhani Unnayan Kartripakkha (RAJUK); Ministry of Housing and Public Works, Government of Bangladesh Existing Studies 1. Md. Golam Mahabub Sarwar, Impacts of Sea Level Rise on the Coastal Zone of Bangladesh, Land University International Masters, Programmes in Environmental Sciences, 2005 2. Lubna Seal, Mohammed Abdul Baten, Salinity Intrusion in Interior Coast: A New Challenge to Agriculture in South Central part of Bangladesh, Unnayan Onneshan-The Innivators 3. Fisheries Statistical Yearbook of Bangladesh, 2012-2013, department of Fisheries, Bangladesh, Ministry of Fisheries and Livestock 4. Final Report, Prepraration of Detailed Area Plan (DAP) for DMPD area: Location 3, RAJUK 5. Research Report on State of Bangladesh’s Water by Hamidur Rahman Khan with the support of Nippon Foundation, 2004 6. “Bangladesh Delta Plan 2100 Formulation Project”: River Systems Management ; Baseline Study, August 2015: General Economics Division, Planning Commission, Government of Bangladesh 7. “Effects of Climate Change on River Morphology in Bangladesh and a Morphological Assessment of Sitalakhya River” by S.Hossain, M.Rahman, F. Nusrat, R. Rahman and N.F.Anisha: Journal of River Research Institute (RRI) 8. “Assessing effect of climate change on the water quality of Sitalakhya River using WASP model” by Md. Akramul Alam, A.B.M Badruzzamman and M.Ashraf Ali; Journal of Cibil Engineering (IEB); Vol. 41 (1) (2013): Page 21-30 9. “Risk and Water Quality Assessment overview of River Sitalkhya in Bangladeh” by Mohammad Naushad Alam, Professor Dr. Fazle Elahi, Professor Dr. Md. Didar-Ul-Alam; Academic Open Internet Journal, ISSN 1311-4360; Vol 19 (2006) 10. “Qualitive Assessment of Toxicity in the Sitalakhya River, Bangladesh” by Jahida B. Islam, Mammon Sarkar, A.K.M. Luftor Rahman, K.Shahin Ahmed; National Institute of Oceanography and Fisheries (2015); Vol. 41; Page 25-30 Website 1. Wikipedia 2. Google maps 3. http://www.bangladeshtourismdirectory.com/bangladesh-archaeological-sites-list.html 4. Google earth imageries 5. http://www.saarc-sadkn.org/countries/bangladesh/disaster_mgt.aspx (Bangladesh Disaster Knowledge Network) 6. http://www.bangladeshdeltaplan2100.org/wp-content/uploads/2016/02/Sustainable-Transportation-3- IWTFinal-June-2016.pdf 7. http://en.banglapedia.org/index.php?title=Agroecological_Zone 8. http://www.timeanddate.com/sun/bangladesh/dhaka?month=12&year=2015 Others 1. Site visits 2. Initial Site Assessment Reports 3. WB General EHS Guidelines 4. WB Performance Standards 2012 5. BEZA EMF

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3. Legislative, Regulation and Policy Consideration

3.1. Regulatory Requirements for the Proposed Project

This section highlights the regulatory requirements set out by Government of Bangladesh (GoB) and World Bank (WB) in relation to protection of environment and its resources as well as protection of the social environment from adverse impacts associated with the project development. These requirements are summarized below. Table 7: Applicability of Key Environmental Legislation at a Glance

Name Key Requirement Applicability Remarks Acts/Rules The Mandatory requirement of prior Applicable. The Site approval certificate is to Environment environment clearance for project is classified be obtained from DoE Conservation certain category of project for under red category Act, 1995 and conservation and improvement EIA study required subsequent of environment and control and to be undertaken amendments in mitigation of pollution of the 2000 and 2002 environment. and 2010 To ascertain responsibility for compensation in case of damage to ecosystem Environment Conservation Restriction on polluting Rules, 1997 automobiles, sale and production (Subsequent of environmental harmful items. Amendments in 2002 and 2003) Promulgation of standards for quality of air, water, noise and soil for different areas for different purposes.

Declaration of ecologically critical areas

Promulgation of standard limit for discharging and emitting waste.

Formulation and declaration of environmental guidelines.

Categorization of industries, development projects and other activities on the basis of pollution activities of the existing or proposed industries/ development projects/ activities.

Environment To give high priority to Applicable as the All the developments to be Court Act, 2000 environment pollution project shall have carried out as per ECA, 1995 and subsequent prevention environmental & ECR, 1997 and amendments in impacts amendments. 2002 The Private Conservation of private forests Applicable as the Tree cutting to be carried out Forests and for the afforestation on tree cutting is after taking permission from wastelands. involved in

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Ordinance Act, development of off- Regional Forest Officer, 1959 site facilities Forest Department The Protection Prohibit or regulate the Applicable. The Necessary permission would and construction, temporary or project involves need to be taken for Conservation of permanent of weirs, dams, construction of construction of embankment. Fish Act, 1950 bunds, embankment and other embankment and and subsequent structures other structures. amendments in 1982 Water Pollution Prevention of water pollution Applicable from the Applicable during both Control prospective of construction stage ( e.g. Ordinance 1970 prevention of sewage and equipment pollution washing and maintenance liquid waste discharges at construction camps) and operation phase (tourism activities) The ground Management of Ground Water Applicable. Three Permission should be taken Water Resources. nos. tube wells will before digging tube wells Management be dug to develop Ordinance 1985 Tube well shall not be dug in any water supply system place without permission from during operation Upzilla parishad. phase The An Act to consolidate the laws Applicable. The Regulatoy authority Ministry Embankment relating to embankment and project involves of Water Resources and FCD and Drainage drainage and to make better construction of Act 1952 provision for the construction, embankment. maintenance, management, removal and control of embankments and water courses for the better drainage of lands and for their protection from floods, erosion and other damage by water. Wetland Adhere to a formal Applicable. The Permission to be taken from Protection Act environmental impact proposed site the Ministry of Water 2000 assessment (EIA) process, as set location has low Resources and DOE out in EIA guidelines and lying area. manuals for water sector projects or related to alteration of natural drainage.

No construction of roads if likely to effect the flow of navigable water ways without clearance from concerned authorities

Upland flow in water channels to preserve eco-system

Protection against degradation and resuscitation of natural water-bodies such as lakes, ponds, beels, khals, tanks, etc. affected by man-made interventions or other causes.

Completely stop the filling of publicly-owned water bodies and depressions in urban areas for preservation of the natural aquifers and environment.

Stop unplanned construction on riverbanks and indiscriminate clearance of vegetation on newly accreted land.

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The Building An Act to provide for the Applicable as the Regulatory authority is Construction Act prevention of haphazard project involves Ministry of Works 1952 (with latest construction of building and development of amendment excavation of tanks which are infrastructure 2006) likely to interfere with the planning of certain areas in Bangladesh The Vehicle Act, To regulate vehicular exhaust Applicable as heavy Regular maintenance and 1927 emissions vehicle movement is upkeeping of the vehicles The Motor involved both should be carried out. Vehicles during construction Regulatory authority is Ordinance, 1983 and operation phase Bangladesh Road Transport The Bengal Authority Motor Vehicle Rules, 1940 The Factories This Act pertains to the Applicable as the Regulatory authority is Act, 1965 occupational rights and safety of workers will be Ministry of labour Bangladesh factory workers and the employed during Labour Law provision of a comfortable work construction and 2006, environment and reasonable operation phase of amendment working conditions. EZ 2013 Bangladesh Labour Rules 2015 Policies National For sustainable development Applicable for all Usage of energy efficient Environment development building material, fuel etc. Policy, 1992 projects should be encouraged National Conservation of natural habitats, Applicable for all Usage of energy efficient Environment bio-diversity, energy, development material, green building Management sustainable development and projects techniques, reduction of Action Plan 1995 improvement of life of people carbon foot prints etc. National Sustainable development of Applicable for all Usage of energy efficient Conservation Industrial Sector development material, green building Stratergy projects techniques, reduction of carbon foot prints etc. The National Protecting the environment by Applicable. EIA Energy efficient materials Energy Policy, requiring an EIA for any new study is to be and techniques should be 1995 energy development project, carried out explored introduction of economically viable and environment friendly technology. The National To ensure efficient and equitable Applicable. Ground Conjunctive use of water Water Policy, management of water resources, water is required to should be explored 2000 proper harnessing and be withdrawn for development of surface and fulfilling water ground water, availability of requirement during water to all concerned and operation phase institutional capacity building for water resource management The National Addresses options for water Applicable as it is Installation of sewage Water quality, considerations behind tourism sector reatment facility within the Management measures to clean up industrial project and will premises Plan, 2001 pollution, where effluent involve generation discharge monitoring and zoning of sewage regulations for new industries are emphasized World Bank’s Safeguards OP 4.01 Ensures sustainability and Triggered Project classified as Category Environmental environmental feasibility of the A considering impacts of Assessment project. Projects are classified project into A, B & C category depending on the nature and extent of the impact.

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OP 4.04 Ensures conservation of natural Triggered The project is likely to affect Natural habitats habitats and discourages the natural habitat of the disturbance of any natural marine ecosystem. Hence the habitat due to project OP 4.04 is trigerred. development by recommending adoption of alternative method/route/approach or adopting management measures OP 4.12 Ensures safeguards to address Triggered The proposed land is devoid Involuntary and mitigate risks due to of any structures. Small Resettlement involuntary resettlement such as temporary kaccha huts have economic, social and been constructed to house environmental risks. the workers employed in the salt farming and are used for a period of 6 months during the phase of salt farming. Also, there is private land of 60.5 acres in the proposed project area. Private Sector Development Support Project Environment Describes all the mandatory Triggered EIA report is prepared referring to Management environmental and social the guidelines mentioned in Framework clearances and purpose of the BEZA’s EMF. (EMF) same required to be taken before development of the project The framework sets out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the project activities to eliminate adverse environmental impacts, offset them, or reduce them to acceptable levels.

3.2. Procedure for Obtaining Environmental Clearance from DoE, Bangladesh

Bangladesh has very simple administrative framework regarding environmental aspect. It has strong interface between local government and federal Government. Department of Environment is responsible for grant of environmental clearance to a project. In addition to three are other ministries to deal with specific area of importance to the country like Forests, Water.

According to the Section 12 of the Environment Conservation Act 1995 no project will be established or undertaken without obtaining permission, in the manner prescribed by the Environment Conservation Rules 1997, an Environmental Clearance Certificate from the Director General. Therefore, every development projects/industries which are specified under the Schedule – 1 of the Environment Conservation Rules 1997 require obtaining site and environmental clearance from the Department of Environment. According to the Rule 7 (1) of the Environment Conservation Rules 1997; for the purpose of issuance of Environmental Clearance Certificate (ECC), every projects, in consideration of their site and impact on the environment and will be classified into the four categories, i.e. green, orange A, orange B and red. Development of off-site facilities for economic zone will fall under red category. Thus EIA study is required to be carried out for the project. The present EIA study has been conducted for the proposed project complying with the ToR and applicable World Bank guidelines. A schematic representation of the various steps involved in obtaining the Environment Clearance certificate from DoE for red category projects is given in Figure 3.

39 EIA Report- Narayanganj Economic Zone

Figure 3: Steps for Obtaining Environment Clearance from DoE

40 EIA Report- Narayanganj Economic Zone

4. Project Description

4.1. Project Introduction

The proposed project involves development of EZ and off-site facilities for Naryanganj Economic Zone proposed to be developed by BEZA. The total proposed project area comprises of 340 acres. The major roads which connect Narayanganj with the rest of the country are:  Narayanganj-Munshiganj Highway (R812);  Bandor-Madonpur Highway (R113); and  Dhaka-Narayanganj Link Road (R111). The project site is abetting Shitalakhya River- South to North-West, confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna) - North East to South, Industrial and residential, facilities- towards North. The location of project site is shown in figure 4 and figure 5. The proposed project involves development of following offsite facilities to make site appropriate for development of economic zone:

 Development of boundary wall  Construction of administrative buildings  Land filling  External power supply system and substation at project site  Water supply system for project site Following development of offsite facilities, economic zone shall be developed under Public Private Partnership Model and a separate Environmental Clearance shall be obtained on a later date. Refer the below figure for the site location map.

Figure 4: Location of Economic Zone

It is proposed to have textile (is it textile processing or garment making), warehousing, shipbuilding, construction material (construction material like making of flooring tiles, ceramic material, etc), Agro, food and fish processing and light engineering industries in the economic zone. Figure below shows the Maouza map of the site. Figure 5: Mouza map of proposed site

41 EIA Report- Narayanganj Economic Zone

Figure 6: Site Surrounding Features

42 EIA Report- Narayanganj Economic Zone

4.2. Project Objectives and Options (Alternate Analysis)

The region is blessed with the presence of Sitalakhya River at its immediate south. The presence of the river body will ensure free waterway transport to different parts of Bangladesh. The water body will also ensure a shallow level of groundwater and quick recharge. A detailed analysis of the strengths, weakness, opportunities and weakness of the proposed site location are provided in the table below

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Table 8: Strength and Weakness of Site

Parameters Strengths Weaknesses Approach Road Access to the other land parcel (of the proposed EZ) located on the south east side of the Bashundhara cement plant is restricted owing to the presence of berth facility of Bashundhara cement plant on the river.

Potable  As per the stakeholder consultations, groundwater the ground water is available at a depth availability of 60 feet from ground level.  The proposed EZ is located adjacent to the confluence of three rivers viz. Meghna, Dhaleswari and Shitalakhya.  The water requirement is anticipated to be met through the borewells proposed to be constructed at the site. Landfilling  The proposed site is located on the Requirements bank of Sitalakhya River and the depth of waterlogging in the proposed EZ is around 4-5 ft during monsoon season.  Landfilling of depth 6-8 feet need to be undertaken, which means some initial cost has to be borne before the commencement of the development works. Resettlement issues The total proposed project area comprises of 340 acres. Out of the 340 acres, 166.09 acres is “private bondobostho land”, 124.38 acres of land is catagorized as Khas Land and is under DC while the remaining 49.5 acres of land has been transferred to BEZA by DC. Resettlement for 59 households needs to be considered. An alternative location for resettlement has already been provided in the SIA report. The selected location falls within the proposed site. Keeping in mind their present practices, the proposed location is adjacent to the river. This reduces the adverse impact on the livelihood of the fishermen. . Loss of The proposed site comprises of private income/livelihood Bondobostho Land, land under BEZA and also land under the jurisdiction of DC. Approximately 107 acres of land is under agriculture. The proposed site has also 2 chicken farms. Land acquisition will inevitably cause loss of livelihood. Road connectivity  The proposed site is well connected by road to the capital city and other major cities of Bangladesh. It is around 32 km away from Dhaka City.  The road distance between the centre of the town Bandar and proposed site is about 5 km.  There are three major roads which connect Narayanganj to the rest of the country. These roads are: (1) Narayanganj-Munsiganj Highway 44 EIA Report- Narayanganj Economic Zone

(R812); (2) Bondor-Modonpur Highway (R113); and (3) Dhaka- Narayanganj Link Road (R111).  Naryanganj is easily accessible from Dhaka city by bus service (frequent bus service available by Ashian, Bandhan, Utsav, Ananda, Setu and BRTC etc.).  The road condition is also favourable for passage of goods carrying trucks and vehicular movement is smooth. Rail connectivity  There are two major railway stations in the Narayanganj district viz. Narayanganj and Chashara.  Narayanganj railway station is located about 7 km from proposed site. Bangabandhu Sarak connects the proposed site to the railway station and traffic congestion is minimal throughout in the stretch. Port connectivity  The proposed site is located at a distance of about 254 km from Chittagong port & 304 km Mongla Port.  The site lies on the bank of inland water way connecting from Chittagong port to Mongla port.  Narayangunj river port, one of the oldest in Bangladesh is located within 3.5 km (Water way) / 28 Km (Road way) from the proposed EZ. Air connectivity  The proposed site is located about 48 km from Hazrat Shah Jalal International Airport at Dhaka. The travel time by road to Dhaka International Airport is 2.5-3 hours (approx.).  The proposed new international airport Bangabandhu Sheikh Mujib International Airport will be located in close proximity to Dhaka and within 50 km radius of the proposed site. Power connection  Bandar substation is located at 2 km  24×7 uninterrupted electricity (approx.) from the proposed site. supply is a prerequisite for  Preliminary assessment suggests that a development of any manufacturing new 132/33 kV substation could be facility. established or the existing substation  24×7 uninterrupted electricity could be upgraded for meeting the supply could be a possibility when requirement of power at the proposed either the existing substation is EZ. upgraded to a larger capacity or a new substation is established at the proposed site. Existing industrial  Narayanganj is the pioneer in ecosystem merchandising and manufacturing of Knitwear, jute, yarn, and dying items.  International trading, import and export business, garments industries, knitwear garments, cold storage, shipbuilding, brickfield, cement etc. are some other major industries present in this region.  These factors may provide backward linkages for development of industries such as shipbuilding, textile, construction materials and light engineering etc.

45 EIA Report- Narayanganj Economic Zone

Availability of  Narayanganj upzilla has 2 govt. medical facilities hospital, 4 upzilla health complex, 12 union health centre, 101 community clinics and 60 private clinics.  There are several medical facilities available within 10 km radius of the proposed EZ to cater to the healthcare requirements of the workforce. Availability of good The proposed site located near Narayanganj residential facility town, has no international standard and quality lifestyle residential facility in the nearby areas. in the nearby areas However such facilities are available near to Dhaka city (within 20 km radius of proposed EZ).

Since this region is an industrial centre, there are several dwelling units and residential facility available for labours in the area.

4.3. Interventions under selected options and activities

Narayanganj EZ has been selected for development of economic zone. Scope of the proposed project is to develop EZ and off-site facilities for upcoming EZ zone. These EZ facilities will be developed by BEZA. The EZ area will be developed by prospective developer who will also undertake detailed planning for the same. Proposed off-site facilities will help in improving the infrastructure of the area. Proposed interventions at the selected site are given below:

 Site development  Administrative building  Land filling  External power supply system and substation at project site  Construction of Embankments

It is proposed to develop an Economic Zone housing Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials Agro, Food and Fish processing, light engineering industries.. Following development of offsite facilities, economic zone shall be developed under Public Private Partnership Model and a separate Environmental Clearance shall be obtained on a later date.

4.4. Project Area of Influence

The project area of influence encompasses, as appropriate:

The area likely to be affected by: (i) the project and the client’s activities and facilities that are directly owned, operated or managed (including by contractors) and that are a component of the project; (ii) impacts from unplanned but predictable developments caused by the project that may occur later or at a different location; or (iii) indirect project impacts on biodiversity or on ecosystem services upon which Affected Communities’ livelihoods are dependent.

 Associated facilities, which are facilities that are not funded as part of the project and that would not have been constructed or expanded if the project did not exist and without which the project would not be viable.  Cumulative impacts that result from the incremental impact, on areas or resources used or directly impacted by the project, from other existing, planned or reasonably defined developments at the time the risks and impacts identification process is conducted.

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Hence the area of influence for the project is the project site and the immediate air-shed including the approach road to the site. Figure below shows the area of influce along with the site area highlighted.

Figure 7: Project Area of Influence

4.5. Existing Infrastructure in and around the Project Site/Project Activities

The proposed site falls under agriculture zone of Narayanganj district. As observed during site visit, the proposed EZ has a level difference of 5 to 6 m (approx.) with a gentle slope towards North East to South west direction. According to the contour variation, the depth of landfilling across the project area shall vary. The natural slope of ground is advantageous for gravity network of water supply, sewer and storm water drains. The contour maps of the proposed EZ for 5 km and 10 km radius are presented respectively figures below. The project site consists of a total of 340 acres of land. Out of that, 124.38 acres is Khas land, 49.5 acres of khas land has been transferred to BEZA and the remaining 166.09 acres of land is privately owned Bondobostho land. Based on the interaction with the UNO officials and local inhabitants, flood level during monsoon season varies from 5 feet to 6 feet depth inside the proposed EZ area. To avoid inundation during monsoon season, minimum land filling above the flood level is considered. Thus an average depth of 6 feet to 10 feet of land filling has been envisaged for the proposed EZ area.

Figure 8: Contour map of the proposed EZ for 5 kmradius (Bandar-Narayanganj)

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Source: ISA report

Based on the interaction with the UNO officials and local inhabitants, flood level during monsoon season varies from 4 feet to 5 feet depth inside the proposed EZ area. To avoid inundation during monsoon season, minimum land filling of 0.6 m above the flood level is considered. Thus an average depth of 6 feet to 8 feet of land filling has been envisaged for the proposed EZ area.

4.5.1. Power Supply for the proposed Site

There are several power plants located in Narayanganj district. Some of the prominent power plants include:  Shiddhirgonj power plant  Horipur Gas turbine power plant  Meghna power plant  Summit power plant

The power plants in the close proximity of the proposed site location are shown in the figure below.

Figure 9: Location of power plants in the vicinity of proposed EZ

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Source: ISA report

Bandar grid substation is located at 2 km (approx.) from the proposed site location. As per the discussions with UNO officials, this substation has a total capacity of 2 x 50 MW and an excess capacity of 65 MW is also available. A 33/11 KV substation is also located near the Summit power plant adjacent to the project boundary. The 33/11 KV substation has a total capacity of 20 MW and an excess capacity of 5 MVA. Preliminary assessment suggests that a new 132/33 kV substation could be established or the existing substation could be upgraded for meeting the requirement of power at the proposed EZ.

4.5.2. Water Availability for the proposed Site

There is no existing water supply system at the proposed site. The local inhabitants are dependent on tube wells for the purpose of drinking water. The sources of drinking water in Bandar and Sonargaon upzila are captured in figure 9.

Figure 10: Sources of drinking water in Bandar and Sonargaon upzila

Source: ISA report

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Based on the interaction with the local inhabitants, the ground water is available at a depth of 60 feet from natural ground level. The proposed EZ is located adjacent to the confluence of three rivers viz. Meghna, Dhaleswari and Shitalakhya. The water requirement for EZ will be met through borewells proposed to be installed at the site location.

4.5.3. Gas Supply to the proposed Site

An 8” diameter gas distribution line is located near basundara cement factory in close proximity from the proposed EZ (within 2 km.). Preliminary assessment suggests that gas could be tapped from the existing line to the proposed EZ by obtaining necessary clearances from Titas Gas.

4.5.4. Telecom/ Internet connectivity to the proposed Site

The capacity of Narayanganj Telephone Exchange has been extended with the installation of 16000 new digital telephone lines. Several Sub Exchange Offices have been setup at different locations resulting in improved service by Telephone Company Limited (erstwhile BTTB). At present, the internet and telecom services are provided by mobile companies such as Grameen Phone, Bharti Airtel, Banglalink, Teletalk in this region. Service by private operators has significantly improved the telecom connectivity in the district. At present there is no area around Narayanganj which is not covered by cellular phone network by private operators. The utility map for the proposed EZ is illustrated in figure 10.

Figure 11: Utility map for the proposed site location

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4.5.5. Connectivity

The proposed site location is easily accessible by road. The distance between Bandar town and the proposed site is approx. 5 km. Narayanganj is well-connected to Dhaka city and other major cities of Bangladesh by all modes of transportation.

4.5.5.1. Road

Narayanganj is 32 km (approx.) away from the Dhaka city. There are three major roads which connect Narayanganj to the rest of the country. These roads are:  Narayanganj-Munsiganj Highway (R812);  Bondor-Modonpur Highway (R113); and  Dhaka-Narayanganj Link Road (R111).

Naryanganj is easily accessible from Dhaka city by bus service (frequent bus service available by Ashian, Bandhan, Utsav, Ananda, Setu and BRTC etc.).

4.5.5.2. Rail

There are two major railway stations in the Narayanganj district viz. Narayanganj and Chashara. The Narayanganj railway station is located about 7 km from proposed EZ. Bangabandhu Sarak connects the proposed EZ to the railway station and the traffic congestion is minimal throughout the stretch.

Travel time of passenger trains from Narayanganj to Dhaka is approx. 40-45 minutes. Apart from Dhaka, Narayanganj is connected to Bahadurabad Ghat via Narayanganj–Bahadurabad Ghat line. There are branch lines to Jagannathganj Ghat and Netrakona-Mohanganj. This MG rail track opened up the connectivity prospect of places such as Gouripur, Kishoreganj, Bhairab Bazar and Mohanganj through branch lines. The frequency of passanger train from Narayanganj to Dhaka is shown in table below.

Table 9: Frequency of passanger trains from Narayanganj to Dhaka

Details of Train Service Frequency (number of trains per day) Dhaka to Narayanganj (Saturday to 13 Thursday) Dhaka to Narayanganj (Friday and 5 Govt. Holidays) Narayanganj to Dhaka (Saturday to 13 Thursday) Narayanganj to Dhaka (Friday and 5 Govt. Holidays)

4.5.5.3. Airport

Narayanganj EZ is located about 48 km from Hazrat Shah Jalal International Airport at Dhaka. The travel time by road to Dhaka International Airport is 2.5-3 hours (approx.). The Govt. of Bangladesh has proposed to construct a new international airport (Bangabandhu Sheikh Mujib International Airport) in close proximity to Dhaka to meet the demand of future growth in aviation sector. The Civil Aviation and Tourism Ministry is in the process to finalise the location of the proposed international airport. Some of the locations which are being considered as prospective locations for the development of new airport are: (1) Char Janajat under Shibchar Upazila in Madaripur district, (2) Keyain and Latobdi under Shirajdikhan Upazila in Munshiganj district and (3) Char Bilashpur under Dohar Upazila of Dhaka district. All these locations are located within 50 km radius of the proposed EZ. Figure below illustrates the connectivity of the proposed Economic Zones via Road, Rail and Airport mode of transportation.

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Figure 12: Connectivity of the proposed Economic Zones via Road, Rail and Airport

4.5.5.4. Port

The proposed site location is approx. 254 km from Chittagong port and 304 km from Mongla port. The Narayanganj river port, one of the oldest in Bangladesh is located within 3.5 km (Water way) / 28 Km (Road way) from the proposed EZ.

Narayanganj river port is situated on the banks of the Shitalakhya River and has four warehouses of 700 square metres each in addition to open storage area. Presently the river port consists of 5 berths and 8 anchorages. Most of the bulk cargos handled in this port consist of sand, stone, cement clinker and fly ash whereas food grains are handled in bagged form. In addition an inland container terminal is being planned at this location.

Various types of cargos are transported through Narayanganj Port. But there is no regular cargocservice for carrying commodities. Commodities are generally carried by private arrangements and berthing facilities provided by the BIWTA are used for loading and unloading purposes. Many business houses or industries use private berthing facilities. Regular cargo service is operated between Kolkata and Narayanganj under Protocol arrangement. Vessels traveling to Chattack from Kolkata also call at Narayanganj.

A substantial amount of cargos are transported through Engine Boats popularly known as Trawller or Cargo or Bulkhead. A large number of such boats ply in the Sitalakhya River and carries construction materials, mostly, fill materials. Country boats with sail, at present, are rarely found. 4.5.6 Proposed Infrastructure

Some of the major project activities will involve:

 Site Development – It is proposed to develop the entire area of site for land filling work. An embankment adjacent to the river is proposed to protect the site from flooding upto +3 m from NGL and

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minimum site filling of average 1 m from the existing NGL for the entire site area. The proposed site plan and site development works are shown in figures 12.

 Construction of Access Road - The construction of the access road connecting the site from the existing Bandar-Madanpur HIghway (R113)

 Construction of Boundary Wall - Based on site visit and Mouza map, it is proposed to construct boundary where ever the embankment is not envisaged wall for a length of approx 1.00 km. The height of boundary wall shall be +2.1 m from NGL.

 Construction of Admin Building - G+2 building considered as typical design

 External water supply system - Based on the type of EZ and the site visit, the water demand was revisited and total demand working out to 7.5 MLD Based on discussion with BEZA it is decided to construct 2 bore wells within the site to meet the initial demand of 1 MLD. The bore well of depth shall be around 200 to 225 meter. In addition river intake system can be envisaged near Meghna River for meeting the future demand at later stage

 External power supply system - Based on the type of EZ and the site visit, the power demand was revisited and total demand working out to 110 MVA. Based on discussion with BEZA it is decided to construct 33 kV substation within the site to meet the initial demand of 20 MVA with the provision for 132 kV substation for meeting the future demand.

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Figure 13: Embankment Details

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Figure 14: Embankment cross-section details

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Figure 15: Structural Details for Pile, Plinth beam and Fencing

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4.6. Project Schedule

The tentative schedule for the off-site infrastructure development is provided in table below:

Table 10: Implementation Schedule of Off-site Infrastructural Details

S.No Offsite infrastructure Duration in months from start 1 Site development 12 2 Access road 9 3 Embankment 6 4 Admin building 12 5 Water supply network 6 6 Power distribution 9

4.7. Resources and Utilities Demand

The details of Bills of Quantities for bund and fencing works is provided in below. The details of the resources and utilities demand shall be covered under the feasibility study.

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Details for BOQ of Bund and Fencing Work (1/7)

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Details for BOQ of Bund and Fencing Work (2/7)

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Details for BOQ of Bund and Fencing Work (3/7)

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Details for BOQ of Bund and Fencing Work (4/7)

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Details for BOQ of Bund and Fencing Work (5/7)

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Details for BOQ of Bund and Fencing Work (6/7)

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Details for BOQ of Bund and Fencing Work (7/7)

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4.7.1 Water

Water requirement during construction phase is estimated to be app. 5.16 MLD, which includes Domestic water requirement of construction workers. For storing rain water during construction phase, temporary rain water harvesting ponds can be constructed at the site. Water for construction shall be sourced from rain water harvesting ponds & Ground water. The water requirement for initial phase is proposed to be met through the bore wells (2 bore wells within the site to meet the initial demand of 1 MLD) to be constructed at the project site. 4.7.2 Power Requirement

Power demand during construction phase is quite significant. Power required has been estimated to be 44.83 MVA. Power supply system will be developed at later stage by developer. The nearest sub-station to the proposed EZ is Bandar grid substation has a total capacity of 2X50 MW and around excess capacity of 65 MW. The 33/11 Bandar grid substation is located approximately 2 Kms from the proposed EZ. A 33/11 KV substation is also located near the Summit Power Plant adjacent to the project boundary. The 33/11 KV substation has a total capacity of 20 MW and around excess capacity of 5 MVA is available. These existing substations could be upgraded fro meeting the requirement of power at the proposed EZ.

4.8. Estimated Project Cost

The project cost as envasised for this project includes the major infrastructure which are a) Site Development; b) Embankment and Fencing; c) Access Road; d) Boundary Wall; e) Administrative Building; f) External Water Supply; g) Pumping main; and h) External power supply. The estimated project cost is summarised in the table below.

Table 11: Estimated Project Cost

Infrastructure BDT USD Site Dvelopment 382,508,560.00 4,781,357.00 Embankment & fencing 411,282,333.75 5,141,029.17 Access Road 55,478,841.16 693,485.51 Boundary Wall 35,850,588.45 448,132.36 Administrative Building 130,476,579.00 1,630,957.24 External Water Supply (PTW) 160,279,000.00 2,003,487.50 Pumping Main 7,668,000.00 95,850.00 External Power Supply 115,583,659.00 1,444,795.74 Total 1,299,127,561.36 16,239,094.52 4.9. Maps and Survey information 4.8.1Project Location

The project site is located at approximately 6 kms from Narayanganj district. The major roads which connects Narayanganj with rest of the country are a) Narayanganj-Munshiganj Highway (R812); b) Bandor-Madonpur Highway (R113); and c) Dhaka-Narayanganj Link Road (R111). The proposed EZ site is linked by the Bandor-Madonpur Highway (R113). The site is abutted by Sitalkhya River on the southern side, Meghna Bridge on the eastern side, Sitalakhya Bridge and highway, Mukhtapur-Dhaka Road on the western side and river and residential settlements on the northern side. It is envisaged that the Economic Zone will comprise of knitting based industries, textile and RMGs, ship building, food and process industries and light engineering industries. The proposed site is well connected by rail network with the nearest railway station being Narayanganj Railway Station which is located at a distance of 7 Kms from the proposed site. The proposed site is located about 48 km from Hazrat Shahjalal International Airport in Dhaka. Travel time by road to this airport is 2.5-3 hrs. The below figure depicts the site location, features in the vicinity and the road connectivity options to the site.

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Figure 16: EZ location on Upzila Map

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Figure 17: Project site and surroundings

Figure 18: Mouza Map with the project site

Figure 19: Contour Map of the Proposed EZ

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Figure 20: Topography of the Site

Dredging at the River Agricultural Fields

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Agricultural Fields Green vegetations at the site area

Tributary of Brahmaputra River on the northern Cement Plant on the other side of the river Side of the Site

4.10. Eco Sensitivity

The project area is abutting Sitalakhya River. The river has been declared as Ecologicallly Crtical Zone (ECZ) by Department of Environemnt, Bangladesh. To minimize impacts due to the upcoming EZ starting from the construction phase, DoE has given a mandate to keep a buffer of 100m from the river shore line. No developmental activities shall be permited within the buffer zone of 100m from the river shore line. It has been proposed to develop green zone in that 100m strech though apart from that, the zone is least likely to have any infrastructure developments.

4.11. Geology

Geologically Narayanganj District lies on the edge of the Madhupur Tract and the Holocene floodplain deposits from the aquifers. Geologically it is a terrace from one to ten meters above the adjacent floodplains. Though in its present form it is of Pleistocene age, its origin may be in the late Miocene, when the Bengal Basin was being filled in rapidly. Unlike the Barind Tract it is largely in one piece, with seven small outliers. The main section stretches from just south of Jamalpur in the north, to Fatullah of Narayanganj, in the south. Two characteristic geological units cover the project area, viz Madhupur Clay of the Pleistocene age and alluvial deposits of recent age. The Madhupur Clay is the oldest sediment exposed in the area having characteristic topography and drainage. The major geographic units of the city are: the high land or terrace, the low land or floodplain, depressions and abandoned channels. Low lying swamps and marshes located in and around the area are other major topographic features.

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The Dupi Tila sands aquifer is the main source of water of the area. Madhupur Clay overlies the aquifer with a thickness of 8 to 45 m (avg.10 m). The aquifer varies in thickness from 100 to 200 m (avg.140 m). Ground water table lies at the depth of 15 to 20 m. Under the present condition the peripheral rivers act as sources of recharge as the Dupi Tila sands are exposed along the riverbeds. Other sources of recharge are vertical percolation of rain and flood water, leakage from water mains and the sewer system and seepage from the standing water bodies within the area.

The soils of the Tract have developed largely on Madhupur Clay; which are nutrient poor and somewhat acidic. They are red or brown in colour. In most places the changes from the floodplains to the Tract is quite sharp, but in some places the floodplain soils overlie the gently inclining edges. The Madhupur Tract is extensively dissected, with narrow or broad valleys extending deep into the level landscape and the Drainage pattern is clearly dendrites. The higher level lands are known as Chala and the valleys are called Baid. The valleys are cultivated with boro rice in the dry season by impounding the streams for irrigation.

Figure below shows one of the borelog developed by WASA in their study at Narayanganj district.

Figure 21: Geological log for Narayanganj District

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As shown in the above figure, loamy soil dominates the geological pattern of Narayanganj. Fine to medium grained sand with trace silt dominates for the first 15m. The silty sand layer is followed by hard clay which is plastic in nature. The layer of stiff clay extends till a depth of 26m below ground level. Presence of 11m thick fat clay indicates the presence of an aquitard. The top 15m could constitute the top few meters as Vadose Zone while the rest rich sand layer could served as the first aquifer or unconfined aquifer. Medium grained sand is there beyond 26m which clearly indicates the presence of confined aquifer. As mentioned, the water level from ground level was recorded at 5.5m.

Figure 22: Geological Map of Bangladesh

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Figure 23: Geological Map of Narayanganj

Narayanganj

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4.12. Master Plan of Narayanganj Economic Zone 4.12.1 Zoning Plan Zone Spotting

The whole area is divided into various zones. The zoning design is done in order to have a wider main road following the sufficient feeder road and required service road facilities to allow the inter- zone movement. Parking is planned at strategic locations. A filling station shall be established in a distinct place as per requirement of the Petroleum Act. Following site parameters are considered while positioning the zones:  Boundary Shape  Physical site features  Area availability  Environmental considerations  Micro climatic conditions  Compatibility issues  Surrounding areas  Accessibility  Transportation issues  Visibility

Zoning is a device for regulating or controlling both present and future development and constitutes a vital player for designing facilities. Firstly, a broad zoning of the facilities is laid out where the major zones are frequented by external and internal traffic. As the proposed EZ is surrounded by water on three sides, functions were solved to serve the best results. Detailed master planning is done cluster wise covering the following components:  Micro level zoning  Land use plan  Detailing the locations and sizes of various land uses  Land parcel plan  Showing the subdivision of industrial land  Phasing  Utilities mapping  Greenery and open space plan  Road category

As the Government has given much emphasis on industrial facilities, the Project aims at achieving the same objective. The Consultants carried out their planning activities within the presented pre-feasibility study originally considering 340 acres. Space required for small feeder roads (perpendicular to the main access road) needs to be earmarked; actual plot sizes will thus be decreased. Garment17 and textile zones should be in separate places. Spinning factories require clean air and no dyeing/printing can take place too close a garn spinning unit. A distance of 500 meter is recommended. As a result, the Consultants drew up a zoning plan:

Figure 24: Proposed zoning map of Narayanganj Economic Zone

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Source: Feasibility Consultants

The zoning percentage for the Narayanganj Economic Zone site would be as follows:

Table 12: Zoning of Narayanganj Economic Zone

Zoning Area (acre) % Load Unload Areas 20.10 6.4% EZ Plot 212.33 67.2% Administrative 7.64 2.4% Road 47.94 15.2% Custom & Guard 1.48 0.5% Green 19.53 6.2% Utilities 7.11 2.2% Total 316.13 100.0%

The Consultants conducted a careful measuring of the land area – based on Google Maps – and came up with a difference of 24 acres - between the 340 acres as declared by BEZA, and 316 acres as calculated by themselve. Confident of their exact own measures, the Consultants continue calculating with 316.1 acreas.

Figure 25: Zoning map of designated Narayanganj Economic Zone

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Source: Feasibility Consultants

Function, product mix and facility configuration of the EZ parcels are as follows:  Industrial Zone: The following facilities are proposed for the EZ areas:  Dyeing  Finishing  Knitting  Knitwear  Packaging  Printing  Spinning  Washing  Weaving  Logistic Zone: Loading and unloading yards, jetty, transportation hubs, cargo-handling centers, raw-material collection and storage halls, finished-goods storage, etc.  Multi-facility complex and utilities: ETP, STP, WTP, SWM, sewer network, communication network, street ligting, wastewater network, electrical substation, etc.  Customs Zone: Guard room, entry and exit, etc.  Greenery and walkway: Green belt along the boundary, lawns, tree plantation along the proposed roads, internal walkways, etc

4.12.2 Detailed Design

Detailed master planning is done cluster-wise covering the following components:

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 Micro-level zoning  Land use plan  Detailing the locations and sizes of various land uses  Land parcel plan  Phasing  Utilities mapping  Greenery and open-space plan  Road category

Design Requirement

The following are the parameters which the Consultants applied for their detailed design:

 Public green space per capita must be more than 1.5 acres  North south plot orientation  Architectural designs and control  Adequate water supply: Underground water and surface river water is available in this location. Municipal water supply is not avialabale here.  Waste disposal system: Central sewage system is not available here. Where there is no STP, normally soak well and septic tank is used for waste-water management. Due to the contamination of water observed when using soak well and septic tank, a STP is recommended here.  Solid-waste management: Proper solid-waste management shall be established  Natural environment: To manage the natural environment, BEZA and Bangladesh government has formulated and implemented environment standards, controls and established carrying capacity. These measures include guidelines for building construction such as control over tree cutting and restriction on construction buildings above tree tops or more than two stories.

Figures below shows the detail master plan and the utility map of Narayanganj Economic Zone

Figure 26: Detailed Master Plan of Narayangonj Economic Zone

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Source: Feasibility Consultants

Figure 27: Detailed Utility Map of Narayangonj Economic Zone

Source: Feasibility Consultants

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In a next and final step, the Consultants intend to draw up the detailed design phases. Table below shows the design phases.

Table 13: Design phases

Phase-1 Phase-2 Phase-3 Phase-4 Site analysis Total program Function Detail Function Gross program Concept development Detailed Master plan Detail Master plan Literature review Zoning Detail infrastructure analysis Concept formulation and sketches Function analysis Zoning analysis Master plan analysis

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5. Description of Environment (Environment and Social Baseline)

This section establishes the baseline environmental and socio economic status of the proposed economic zone and surrounding area to determine the project influence area within which the impacts of the Project are to be assessed.

Establishing baseline helps in understanding the prevailing environmental and socio economic status of the study area. It provides the background environmental and social conditions for anticipating of the future environmental characteristics of the area based on the operation of the new/ expansion activity of the project during its life cycle. It also helps in environmental and social management planning and strategy to minimize any potential impact due to the Project activities on surrounding environment. Field surveys were conducted at the project site to collect the requisite baseline information through discussions with project proponents, and local people. The baseline information was gathered pertaining to:

 The physical environment (air, water, land, noise, flora, fauna, etc.)  The socio-economic data of the area in which project site is located  Disadvantaged or vulnerable groups in the project area of influence  Presence of any indigenous people in the project area of influence  Presence of any cultural heritage sites in the project area of influence.

5.1. Methodology

The environmental and social baseline has been assessed and a survey of the project area was conducted to identify environmental and social sensitive receptors located within and around the project area. Environmental and social baseline data was collected through primary surveys as well as secondary sources by literature survey and discussions with the concerned stakeholders.

5.2. Baseline data Collection

Primary baseline data collection involved environmental monitoring and stakeholder consultations to collect the information related to the physical environmental conditions in the vicinity of the proposed site. Stakeholder consultations were carried out to collect information on socio-economic status of the project area. The primary baseline data collected for various social and environmental parameters is detailed out in table below.

Table 14: Primary Baseline Data Collection

S.No Environmental No. of Frequency Remarks Attribute Locations 1. Socio- economic Status Project affected Twice during the Primary communities study period consultation was carried out in the affected villages/ communities to understand the history and socioeconomic

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aspects of the site and surrounding areas. 2. Monitoring of groundwater Proposed project Once during Survey was quality site and in its study period undertaken by Monitoring of surfacewater vicinity DoE, Chittagong quality lab to assess the Monitoring of ambient air parameters. quality Monitoring of ambient noise

Secondary baseline data collection involved identifying and collecting available published material and documents. Information on various environmental aspects (like soil, geology, hydrogeology, hydrology, drainage pattern, ecology etc.) meteorology, and socio-economic aspects was collected from different government departments, institutions, literatures etc. 5.2.1. Meteorology

Meteorological data is used to anticipate the dispersion and diffusion of pollutants, once discharged into the atmosphere. The baseline conditions of physical parameters are provided in subsequent sections:

5.2.1.1 Temperature

Seasonal variation of temperature is not significant. Monthly minimum and maximum temperatures and average minimum and maximum temperatures for the period 2005-2014 for Dhaka are given in below Tables 6 and 7 (data obtained from Bangladesh Meteorological Department).

Table 15: Monthly minimum and average minimum temperature during Jan 2005 to Dec 2014

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 14.20 13.50 12.50 14.50 14.80 12.80 12.20 14.50 12.30 13.70 13.50 Feb 18.30 19.40 16.80 15.20 17.20 16.20 16.90 16.00 17.50 15.80 16.93 Mar 22.40 21.90 19.60 22.00 21.40 23.30 21.50 22.10 22.10 20.60 21.69 Apr 24.10 23.80 23.70 24.50 25.90 26.40 23.20 23.70 24.40 25.10 24.48 May 24.20 25.00 25.90 24.90 25.20 25.90 24.60 25.80 24.80 26.70 25.30 Jun 26.80 26.10 25.50 26.30 26.70 26.70 26.30 26.90 27.20 26.50 26.50 Jul 25.80 26.70 25.80 26.30 26.70 27.40 26.70 26.70 27.00 26.90 26.60 Aug 26.70 26.50 26.40 26.50 26.30 27.10 26.50 26.60 26.20 26.30 26.51 Sep 26.00 25.80 26.50 26.20 26.30 26.60 26.40 26.80 26.30 26.50 26.34 Oct 24.40 24.70 23.80 23.80 24.20 25.10 24.70 24.30 24.20 24.00 24.32 Nov 19.80 19.90 19.90 19.00 20.20 20.90 19.20 19.10 18.50 19.70 19.62 Dec 15.70 15.80 15.00 16.90 15.40 15.50 15.00 14.50 15.60 15.10 15.45

Table 16: Monthly maximum and average maximum temperature during Jan 2005 to Dec 2014

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 24.50 25.30 24.60 24.50 25.90 23.80 23.40 24.10 24.20 24.30 24.46 Feb 29.10 31.30 27.10 26.10 29.70 28.90 28.70 28.50 28.90 27.20 28.55 Mar 32.20 33.20 31.50 31.70 33.30 34.10 32.10 33.00 33.40 32.40 32.69 Apr 34.40 33.70 33.70 34.50 35.60 35.50 33.50 33.50 34.20 36.40 34.50 May 33.20 33.80 34.80 34.70 34.60 34.30 33.40 34.60 31.70 35.20 34.03

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Jun 33.40 32.40 32.50 32.50 34.50 33.10 32.60 33.20 33.70 33.20 33.11 Jul 31.50 32.40 31.50 31.80 32.30 33.00 32.30 32.60 32.70 32.90 32.30 Aug 32.10 32.50 32.50 32.10 32.50 33.10 31.10 32.60 32.00 32.20 32.27 Sep 32.80 31.90 32.00 32.60 32.50 32.50 32.40 32.90 32.60 32.90 32.51 Oct 30.60 32.30 31.50 31.40 32.20 32.40 32.70 32.30 31.50 32.20 31.91 Nov 29.10 29.70 29.00 29.70 30.20 30.10 29.70 28.70 30.20 30.20 29.66 Dec 27.10 26.90 25.80 25.60 26.00 26.10 25.00 24.00 26.30 24.50 25.73

The data shows that the monthly minimum (average) temperature at Dhaka varies between 13.50C and 26.60C and maximum temperature varies between 24.46C and 34.50C. The minimum and maximum temperature data indicates that December to February months are relatively cooler and April and May are the relatively hotter months.

5.2.1.2 RelativeHumidi ty

The average relative humidity at Dhaka varies between 57.30 % in the month of March and 80.20 % in the month of August. The average relative humidity for the last 10 years for Dhaka is provided in Table 8. The data shows that average humidity does not vary much with the change in seasons and is relatively high.

Table 17: Monthly average relative humidity during Jan 2005 to Dec 2014

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 68.00 69.00 68.00 69.00 72.00 71.00 69.00 66.00 65.00 72.00 68.90 Feb 60.00 65.00 68.00 61.00 55.00 56.00 54.00 52.00 55.00 62.00 58.80 Mar 66.00 53.00 54.00 67.00 53.00 59.00 57.00 57.00 55.00 52.00 57.30 Apr 66.00 67.00 69.00 64.00 66.00 67.00 64.00 69.00 63.00 56.00 65.10 May 73.00 72.00 70.00 70.00 72.00 71.00 76.00 70.00 78.00 68.00 72.00 Jun 79.00 81.00 81.00 80.00 74.00 79.00 80.00 77.00 76.00 78.00 78.50 Jul 81.00 80.00 84.00 83.00 80.00 77.00 79.00 79.00 77.00 77.00 79.70 Aug 82.00 77.00 80.00 81.00 82.00 78.00 82.00 78.00 80.00 82.00 80.20 Sep 81.00 80.00 80.00 81.00 81.00 79.00 77.00 79.00 81.00 76.00 79.50 Oct 80.00 76.00 78.00 77.00 73.00 74.00 73.00 71.00 78.00 72.00 75.20 Nov 72.00 68.00 77.00 69.00 66.00 68.00 67.00 68.00 66.00 66.00 68.70 Dec 66.00 69.00 69.00 79.00 69.00 66.00 73.00 77.00 72.00 77.00 71.70

5.2.1.3 Rainfall

The average monthly rainfall data for Dhaka (obtained from BMD) is provided in table 9 below. The data shows that rainy season in Dhaka mainly prevails from May to October. The average monthly rainfall in Dhaka for the period Jan 2005 to Dec 2014 varied between 3.5 mm in the month of January and 412.8 mm in the month of July. The rainfall follows the general climate pattern with the highest rainfall in the summer from April to October and minimum rainfall in the winter from November to March.

Table 18: Monthly total and 10 years average monthly rainfall during Jan 2005 to Dec 2014

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 1 0 0 23 1 0 0 10 0 0 3.5 Feb 3 0 30 56 1 48 0 1 8 12 15.9 Mar 155 0 11 45 43 22 20 37 26 10 36.9 Apr 91 181 163 91 14 37 123 269 32 80 108.1 May 291 185 185 205 168 177 235 137 378 147 210.8 Jun 259 326 628 577 170 308 314 175 325 342 342.4 Jul 542 331 753 563 676 167 356 226 302 212 412.8

56 EIA Report- Narayanganj Economic Zone

Aug 361 167 505 319 482 340 409 282 212 391 346.8 Sep 514 663 179 279 298 169 207 81 172 156 271.8 Oct 417 61 320 227 74 174 112 38 131 49 160.3 Nov 3 5 111 0 4 0 0 68 0 0 19.1 Dec 0 0 0 0 0 81 0 5 4 0 9.0

5.2.1.4 Wind Speed and Direction

The wind speed and direction of Dhaka district are depicted by wind rose diagrams. A wind rose gives a very succinct but information-laden view of how wind speed and direction are typically distributed at a particular location. Presented in a circular format, the wind rose shows the frequency of winds blowing from particular directions. The length of each "spoke" around the circle is related to the frequency of time that the wind blows from a particular direction. Each concentric circle represents a different frequency, emanating from zero at the center to increasing frequencies at the outer circles.

January to December wind rose and monthly wind roses, and wind classes for Dhaka (collected from BMD) are presented below. These wind roses and wind classes are average of last 30 years. These wind class and wind rose diagrams show that at Dhaka, dominant wind speed is in the calm condition followed by 1 to 2.5 m/sec. The predominant wind direction from Jan to Dec is south followed by south-east.

The monthly wind roses indicate the following trend: NW and northerly winds prevail in January, November and December; wind flows multi-directional in February and October; the predominant wind direction is south followed by SW in March; in April the wind direction is south, the predominant wind direction is south followed by SE from May to July; and in August and September the predominant wind direction is SE followed by south.

As indicated in the below wind rose diagram, the area experiences wind speeds lower than 5 m/s for 98% of time. Of this half the time (44.4%of the time) is calm condition throughout the year (wind speeds in the range of 1-2.5 m/s). This indicates the weather conditions are not favorable for dispersion of pollutants released in the air. Month wise prevailing wind speeds are as follows: predominantly calm conditions prevail during January to March and September to December periods with the area experiencing wind speeds in the range of 1-2.5 m/s. The remaining five months experience lesser calm conditions and wind speeds in the range of 2.5 – 5 m/s.

Figure 28: Wind Rose Diagrams

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5.2.1.5 Sunshine Hours

The monthly average sun-shine hour in Narayanganj varies from 10-13.5 hour/day in a year. Highest sunshine hurs are recorded in month May, June, July and August. In general, maximum average sun-shine hour of 13.5 hour in a day is found in June and July. Figure below shows the average monthly sunshine hours in the year 2015, Narayanganj.

Figure 29: Average monthly sunshine hours in Narayanganj, 2015

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13.5 13.5 13 13 12.5 12.5 12 11.5 11 11 11 10.5

Source: http://www.sunrise-and-sunset.com/en/sun/bangladesh/narayanganj/2015/december

5.2.2. Water Resources 5.2.2.1 Surface Water systems and Drainage

The major water body abutting the site on its southern side and eastern side is the Sitalakhya River. There are no other surface water systems within the project influence area. The Sitalakhya river having a length of 113 km originates from the Old Brahmaputra and falls into the river Dhaleswari. It flows by the eastern side of Dhaka district. The river joins the river Balu at Demra, a small tributary flowing from the north of greater Dhaka. About 20 km downstream of Demra, the Sitalakhya river joins the Dhaleswari river. It is navigable by the country boats throughout the year. The river hardly spills over the banks and follows more or less a straight course. There are several different types of industries like textiles and dyeing, paper and pulp, jute, pharmaceuticals, fertilizers, etc of moderate to big size and several urban developments along the entire stretch of the river. These establishments contribute to the pollution load to the Sitalakhya river directly or through a number of wastewater khals (canals) like DND drainage khal, Majheepara khal, Killarpul khal, Kalibazar khal, Tanbazar khal, etc. Domestic and industrial wastewater from Dhaka city through Norai khal and from the Tongi industrial area through Tongi khal is disposed of in the river Balu. This also contributes to the pollution load to the river Sitalakhya. The water quality of this river is of particular importance not only for ecological and commercial reasons but also for concerns regarding safe drinking water supply as the largest surface water treatment plant in Bangladesh located at Saidabad draws water from it through the intake at Sarulia about 400 m downstream of its confluence with the Balu river.

Figure below shows the drainage map of the subject site.

Figure 30: Drainage Pattern of the Project Site

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5.2.2.2 Salinity

Salinity levels of Sitalakhya River was determined from secondary sources. The salinity levels of the Sitalakhya River range between 57-582 PPM (“Quantitative assessment of toxicity in the Sitalakhya River, Bangladesh” by Jahida B. Islam, Mammon Sarkar, A.K.M Lutfor Rahman, K. Shahin Ahmed; Egyptian Journal of Aquatic Research (2015). Vol: 41; 25-30) 5.2.2.3 Erosion and Sedimentation

No erosion site at EZ site and at river bank is observed. Map showing areas prone to river bank erosion is given below in the below figure.

Figure 31: Riverbank Erosion Pattern in Bangladesh

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5.2.2.4 River Morphology

The Sitalakhya River is a distributary of the Brahmaputra River. In its initial stages it flows in a southwest direction and then east of the city of Narayanganj in central Bangladesh until it merges with the Dhaleswari nearKalagachhiya.A portionof its uppercourseis knownas Banar River. Theriver is about 110 kilometres long and at it widest, near Narayanganj, it is 300 metres across. Presently, the river has become a mere flood spill channel due to vulnerability of its off-take to sedimentation and thus, has also has become a low-energy river. JICA conducted studies on Sitalakhya River on the morphological changes in the river bed of Sitalakhya River. The parameters were recorded from the year 1985 to 2009. The study reflects that in these 24 years, the elevation in the river bed has varied from -0.4m to -14.1m. The width of the river bed observed from the top changed between 3.3m to 9.67m. The observations from JICA reflects that there has been a considerable though gradual change in the river morphology. Establishments of industries along the banks of this river, global warming could be some of the possible reasons behing this gradual differences. Figure below shows the change in the flow regime of the river from 1989 to 2010.

Figure 32: Changes in River Morphology, Sitalakhya River

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Change in Flow Regime

Source: “Effects of Climate Change on River Morphology in Bangladesh and a Morphological Assessment of Sitalakhya River” by S.Hossain, M.Rahman, F. Nusrat, R. Rahman and N.F. Anisha; Journal of River Research Institute

The flow regime of the Sitalakhya River since 2003 is presented in the following figure:

Figure 33: Flow Regime of Sitalakhya River, 2003

Figure 34: Flow Regime of Sitalakhya River, 2005

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Figure 35: Flow Regime of Sitalakhya River, 2008

Figure 36: Flow Regime of Sitalakhya River, 2010

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Figure 37: Flow Regime of Sitalakhya River, 2014

Figure 38: Flow Regime of Sitalakhya River, 2016

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Source: Google Earth 5.2.2.5 Navigation

The greater Dhaka city has got a natural advantage of circular waterways of 110.50 km length consisting of the rivers Buriganga, Turag, Balu, Sitalakhya and a small stretch of Dhaleswari. These rivers flow around Dhaka city through the districts of Dhaka, Narayanganj, Gazipur and Munshiganj. The circular waterways around Dhaka had the significant potentials to contribute the urban transport in and around Dhaka. But due to lack of required and perennial navigability in about 50 percent of the waterways, it could not be utilized for the movement of passengers and freight. The IWT operations were limited mainly to the movement of passengers and cargo between Dhaka/Narayanganj and other parts of the country. Mechanized country boats of small sizes could only navigate during monsoon from Sadarghat, Dhaka to Mirpur area and from Demra (Narayanganj) to Tongi area. Such contribution to urban transport was insignificant and may be termed as no contribution.

To enhance the navigable waterways and to contribute to the urban transport in Dhaka through IWT services BIWTA undertook a project called “Development of Circular Waterways around Dhaka- 1 st Phase” in 2000. The Project was completed in 2004 and a length of 29.50 km of waterways in Buriganga and Turag rivers was made navigable through dredging, including development of 10 landing stations along the waterways at a cost of BDT 360 million. The first phase included the waterways in the south- western, western and north-western parts of the city.

Currently, container feeder service is available from Chittagong Port to Port Klang (daily); Port of Singapore (daily); and Colombo Port (every 2-3 days) and with Bay of Bengal for connecting the mother vessels serving international destinations. More than 5 feeder vessel operators with vessels capacity of 1,000 -1,500 boxes (containers) have deputed their feeder vessels in this circuit. The transit time is about 3-4 days from /to Chittagong Port to the hub ports. All international Shipping Lines have their presence in Bangladesh and some even operate their own feeder vessels.

Meanwhile, the Ministry of Shipping, GoB, is finalising a draft of guidelines for establishing ICTs under private sector investment. A deep sea port is also proposed to be constructed at Sonadia, Cox Bazar. To develop inland waterway transportation, a jetty is also required to be proposed for the project.

5.2.2.6 Groundwater Systems

The study of the groundwater demand from different parts of the country shows that northwest and north central region depend on groundwater a lot for the supply of the water. Groundwater resources are

69 EIA Report- Narayanganj Economic Zone determined by properties of groundwater storage reservoir and volume of annual recharge. Mainly rainfall, flooding and stream flow in rivers penetrate earth surface and recharge groundwater reservoirs. Although Bangladesh has been considered rich in groundwater resources, the total groundwater storage data is absent. National Water Plan Phase-II estimated average groundwater as 21 cubic kilometres (cu km) in 1991. However, with the increased trend of urbanisation and irregular rainfall behaviour, surface run-off has increased in recent times, which reduces groundwater recharge considerably. Figure below is the groundwater zoning map in Bangladesh, 2010. From the map it could be seen that the groundwater level in and around the subject site is shallow. The groundwater level as reported by the figure below is somewhere between 0.5m-3m below ground level (bgl).

Figure 39: Groundwater Zoning Map in Bangladesh, 2010

Source: “A Briefing Paper on the State of Groundwater Management in Bangladesh” by Sengupta et al., September 2012

Groundwater storage reservoirs are composed of three aquifers in Bangladesh: 1. Upper aquifer or composite aquifer 2. Main aquifer (it is at depths six meters in north-west and to 83 m in the South) and 3. Deep aquifer

The transmission property of the main aquifer is good to excellent over most of the country but it is deteriorating towards the south and the east. Underlying the main aquifer, there is a deeper water bearing unit separated by one or more clay layers of varied thickness referred as the deep aquifer that has been exploited by tube wells in Dhaka and in the coastal areas. In the areas near the coast the water table is descending due to over extraction or salinity contamination of upper or main aquifer7. Strong declining trends (0.5–1 metre/year) in dry-period groundwater levels are observed in the central part of the country surrounding the Dhaka city. Moderately declining trends (0.1–0.5 metre/year) occur in western, northwestern, and northeastern areas. In the northern table land areas and floodplains of the major rivers, magnitudes of declining trends are low (0.01–0.05 m/yr). Stable or slightly rising trends (0–0.1 metre/year) are generally observed from the Meghna estuary to the southern coastal areas in the country.

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A similar overall pattern is seen during wet periods except in the northern table land areas, southwestern delta plains and southern coastal areas where wet period trends are slightly rising or stable.

Narayanganj is underlain by an unconsolidated alluvial aquifer system of Quaternary age which is many hundreds of metres thick across the entire project area but in which only the top 250 m (and principally the top 150 m) is utilised for groundwater supply purposes. Complex lateral interdigitation of medium grain-size clastics (medium to coarse sands) occurs with finer-grained clastics (fine sands, silts, clays). As a first approximation the system is considered to comprise an upper aquitard covering a shallow aquifer which is separated from a deeper more productive aquifer by a lower much thicker aquitard as shown in the figure below.

Figure 40: Groundwater setting of Narayanganj, Bangladesh

Source: “Urban Groundwater Protection and Management: Lessons from 2 developing city case studies in Bangladesh and Kyrghyzstan” by B L Morris, P G Litvak and K M Ahmed

With a monsoonal tropical climate, there are extensive opportunities for recharge not only directly from local rainfall but also from the Sitalakhya River and numerous khals and rainfed ponds. Annual monsoonal floods inundate much of the periurban area while the urban area can be affected on average about once every decade by abnormally high floods. Unconsolidated sediments provide intergranular flow conditions, and it is probable that there is hydraulic connection with the Sitalakhya River whose channel is deep enough to incise into the upper aquifer sequence.

Vertical connectivity is likely to be variable, depending on thickness and frequency of occurrence of fine- grained strata at any given location.

5.2.2.7 Seismicity

Bangladesh and the north eastern Indian states have long been one of the seismically active regions of the world, and have experienced numerous large earthquakes during the past 200 years. A seismicity map of Bangladesh and its adjoining areas has also been prepared by BMD and GSB. Bangladesh has been classified into three seismic zones with zone-3 the most and zone-1 the least vulnerable to seismic risks as indicated in figure below. Narayanganj which is approximately 20 Kms from Dhaka city, lies in Zone-2 which shows intermediate level of seismic activity.

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Figure 41: Seismicity Map of Bangladesh

Source: BMD

In the earthquake zoning map of 1993, 26 percent of Bangladesh falls in high risk, 38 percent moderate and 36 percent in low risk zone in terms of earthquake vulnerability. The distribution of recorded earthquakes indicate a major clustering of seismicity around the Dauki Fault and scattering of other events along other major fault systems of Bangladesh. The magnitude of the earthquakes are moderate (4-6) and majority of them are shallow depth.

Tectonically, Bangladesh lies on the northeastern Indian plate, near the edge of the Indian craton and at the junction of three tectonic plates - the Indian plate, the Eurasian plate and the Burmese microplate. These form two boundaries where plates converge- the India Eurasia plate boundary to the north forming the Himalaya Arc, and the India Burma plate boundary to the east forming the Burma Arc. The Indian plate is moving at a rate of 6 cm per year in a northeast direction, and subducting under the Eurasian and the Burmese plates in the north and east, at a rate of 45 mm per year and 35 mm per year, respectively (Sella et al., 2002; Bilham, 2004; Akhter, 2010).

The other major active tectonic belt of Bangladesh is at the eastern side. The Arakan subduction-collision system involves oblique convergence of the Indian and Burma plates. It has produced the N-S trending Indoburman range and a broad belt of folds along the western edge of the Bay of Bengal (Curray, 2005; Wang and Sieh, 2013). These lie above a mega thrust that dips moderately eastward beneath the Indoburman range but is nearly flat-lying beneath the folds. Beneath the 500-km long fold belt the mega thrust is also referred to as a decollement, because it is parallel or nearly parallel to sediment bedding within the Canges Brahmaputra delta. Many of the folds within the western 100 to 200 km of the fold belt appear to be actively growing, which implies that the underlying decollement is relaying slip onto thrust faults beneath these folds as it dies out westward toward a poorly defined deformation front. The proposed

72 EIA Report- Narayanganj Economic Zone site location is also on the eastern side of Bangladesh. Hence, there is risk of earthquake due to the Arakan fault.

List of the major earthquake that hit Bangladesh are listed in following table below.

Table 19: List of Major Earthquakes in Bangladesh

Date Name Magnitude (Ritcher) 10th January 1869 Cacher Earthquake 7.5 14 July 1885 Bengal Earthquake 7.0 12 June 1897 Great Indian Earthquake 8.7 8 July 1918 Srimongal Earthquake 7.6 2 July 1930 Dhubri Earthquake 7.1 15 January 1934 Bihar-Nepal Earthquake 8.3 15 August 1950 Assam Earthquake 8.5 Source: Department of Disaster Management 5.2.2.8 Tropical Cyclones

Devastating cyclones hit the coastal areas of Bangladesh almost every year usually accompanied by high- speed winds, sometimes reaching 250 km/hr or more and 3-10 m high waves, causing extensive damage to life, property and livestock. Cyclones in the Bay of Bengal occur in two seasons, April-May and October- November – i.e. before and after the monsoon. Cyclones enter the Bay as the remnants that originate in the South China Sea. They gain moisture and latent heat from the Bay of Bengal, and consequently rejuvenate into full-blown phenomenon. Following a curvilinear path, they reach the coast of Myanmar, Bangladesh or East Coast of India. Because of the funnel shaped coast, Bangladesh repeatedly becomes the landing ground of cyclones formed in the Bay of Bengal. The Bay cyclones also move towards the eastern coast of India, towards Myanmar and occasionally into Sri Lanka. But they cause the maximum damage when they come into Bangladesh and West Bengal of India. This is because of the low flat terrain, high density of population and poorly built houses. Most of the damage occur in the coastal regions of Khulna, Patuakhali, Barisal, Noakhali and Chittagong and the offshore islands of Bhola, Hatiya, Sandwip, Manpura, Kutubdia, Maheshkhali, Nijhum Dwip, Urir Char and other newly formed islands. The cyclone affected area map of Bangladesh is shown in Figure below. Narayanganj lies in no risk area.

Figure 42: Cyclone affected area map of Bangladesh

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Source: Department of Disaster Management

The tracks of few major cyclones that hit Bangladesh are shown in figure below.

Figure 43: Cyclone tracking map of Bangladesh

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Source: Department of Disaster Management

5.2.2.9 Tidal Floods

Floods are the most significant natural hazard in the country causing extensive damage to human life and property. The country lies on the downstream part of three major river basins: Brahmaputra, Ganges and Meghna and thus is frequently flooded. There have been many destructive floods in Bangladesh, including very severe floods of 1987, 1988 and 1998. The flood damage potential in Bangladesh is increasing due to the possible causes of climate change, urban concentration in the three river basins, encroaching of settlements into flood prone areas, and overreliance on the safety provided by flood control works such as levees, reservoirs.

There are two types of floods which occur in Bangladesh: annual floods (barsha) that inundate up to 20% of the land area; and low frequency floods of high magnitude that inundate more than 35% of the area (bonna). The major floods that occurred in 1954, 1955, 1974, 1984, 1987, 1988, 1993, 1998, 1999, 2000 and 2007 have been very destructive and caused serious threat to lives and economy. In the context of human exposure in flood hazard zones, nearly 19,279,960 people are present in these zones and Bangladesh ranks 1st among 162 nations. Similarly, the modelled amount of GDP in seismically hazardous zones puts Bangladesh 3rd among 162 countries. The flood affected area map of Bangladesh is provided in the figure below. The map shows that Narayanganj, lies in River/Monsoon flood area. Because of the close proximity with the Sitalakhya River, floods to the chor area or low land area are common which was also confirmed by local residential people inhabiting at the proposed site area.

Figure 44: Flood affected area map of Bangladesh

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Source: Department of Disaster Management

5.2.2.10 Tornado

It is the pre-monsoon period when most of the abnormal rainfall or drought conditions frequently occur in different parts of Bangladesh. Also there are severe local seasonal storms, popularly known as nor’westers (kalbaishakhi). Severe nor’westers is generally associated with tornadoes. Tornadoes are embedded within a mother thundercloud, and moves along the direction of the squall of the mother storm. The frequency of devastating nor’westers usually reaches the maximum in April, while a few occur in May, and the minimum in March. Nor’westers and tornadoes are more frequent in the afternoon. Nor’westers may occur in late February due to early withdrawal of winter from Bangladesh. The occasional occurrence of nor’westers in early June is due to the delay in the onset of the southwest monsoon over the region (Karmakar, 1989). List of the nor’westers and tornadoes is given in table below. Narayanganj was hit by Tornado way back in 1976.

Table 20: List of Tornadoes had hit the Bangladesh

Date Location 14th April, 1969 Demra (Dhaka) 17th April, 1973 Manikganj (Dhaka) 10th April, 1974 Faridpur 11th April, 1974 Bogra

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09 May, 1976 Narayanganj 1st April, 1977 Faridpur 26th April, 1989 Saturia (Manikganj) 14th May, 1993 Southern Bangladesh 13th May, 1996 Tangail 4th May, 2003 Brahmanbaria 21st March, 2005 Gaibandha Source: http://old.ddm.gov.bd/tornado.php

5.2.3. Land Resources 5.2.3.1 Agroecological Regions

An Agroecological Region is a zone which has unique combination of physiographic, soil, hydrological and agroclimatic charecteristics. Thirty agroecological regions and 88 subregions and 535 units have been identified by adding successive layers of information on the physical environment which are relevant for land use and for accesing agricultural potential. These layers are:

1. Physiography 2. Soils 3. Depth and suration of seasonal flooding 4. Length of rainfed kharif and rabi growing periods 5. Length of pre-kharif period of unreliable rainfall 6. Length of cool winter period 7. Frequency of occurrence of extremely high (> 40 degrees) summer temperature.

The physiographic unit of the project is: Young Brahmaputra and Jamuna Floodplain (AEZ# 29) (shown in figure below). The region comprises the area of Brahmaputra sediments. It has a complex relief of broad and narrow ridges, inter-ridge depressions, partially in filled cut-off channels and basin. This area is occupied by permeable silt loam to silty clay loam soils on the ridges and impermeable clays in the basins, neutral to slightly acid in reaction. General soil types include predominantly grey floodplain soils. Organic matter content is low in ridges and moderate in basins. Soils are deficient in N, P, and S but the status of K and Zn are reasonable. General fertility level is medium.

Figure 45. Agroecological Regions of Bangladesh

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5.2.3.2 Land Types

The landforms of Bangladesh can be divided into three major classes:  The northern and eastern hills  The Holocene floodplains  The Pliestocene terraces

The sediments deposits of Bangladesh mainly consists of those laid down by the Ganges, Brahmaputra and Meghna (GBM) river systems. Holocene floodplain deposits cover most of the surface area of present-day Bangladesh. According to geographic and geomorphic distribution, the Holocene floodplains are divided in four classes:  Piedmont plains  Meander floodplains  Tidal floodplains  Estuarine floodplains

Land types are classified depending upon the depth of inundation during monsoon season due to normal flooding in an average year. SRDI has made the land type classification into five types, i.e. High land (Above flood level), Medium highland (Flooding depth 0-90 cm), Medium lowland (Flooding depth 90- 180 cm), Lowland (Flooding depth 90-270 cm) and very lowland (Flooding depth >270 cm). Land type classification based on flooding during Monson Season by SRDI is given below in table.

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Table 21: Land Type Classification

Land Type Description Flooding Depth Flooding Charecteristics F0 Highland 0-30 cms Non Flooded to Intermittent F1 Medium Highland 30-90 cms Seasonal F2 Medium Lowland 90-180 cms Seasonal F3 Lowland 180-270 cms Seasonal but remains wet in early dry season F4 Very Lowland >270 cms Seasonal but remains wet in most of the dry seasons Source: SRDI

As per the classification, project site will be covered under medium lowland.

5.2.3.3 Geomorphology/ Soil Texture

As per the geological map of Bangladesh, the Keraniganj area mainly consists of mainly loamy with which is a mixture of fine sand, silt and trace clay. The geological map of Bangaldesh is provided in the below figure and geological log of Keraniganj upazila is shown in figure.

Figure 46: General Soil map of Bangladesh

79 EIA Report- Narayanganj Economic Zone

Source: Soil Resources and Development Institution (SRDI), Dhaka, Bangladesh

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Extensive areas throughout the flood plain are occupied by broad ridges on which rather yellowish, friable, silt loams and silty clay loams predominate. Some of those have dark grey topsoils which are acid when dry, but slightly alkaline when flooded; subsoils are moderately alkaline, but non-calcareous. In the southern half of Narayanganj district there are extensive deep basins which have dark grey compact clays with moderately alkaline subsoils usually overlying a yellowish and loamy substratum.

Figure 47: Geological log for Narayanganj District

As shown in the above figure, loamy soil dominates the geological pattern of Narayanganj. Fine to medium grained sand with trace silt dominates for the first 15m. The silty sand layer is followed by hard clay which is plastic in nature. The layer of stiff clay extends till a depth of 26m below ground level. Presence of 11m thick fat clay indicates the presence of an aquitard. The top 15m could constitute the top few meters as Vadose Zone while the rest rich sand layer could served as the first aquifer or unconfined aquifer. Medium grained sand is there beyond 26m which clearly indicates the presence of confined aquifer. As mentioned, the water level from ground level was recorded at 5.5m. The groundwater water level is majorly shallow at Narayanganj region. The Narayanganj region is abutted by rivers (Sitalakhya, Meghna, tributaries of Bramhaputra) which results in quick recharge of the aquifer.

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WASA in its following study also conducted Slug Test (Rising and Falling Head Aquifer Test). The Hydraullic Conductivity (K) as enumerated by them came to be in the range of 3.8 x 10-6 m/sec to 2.84 x 10-5 m/sec. The enumerated K value depicts that the specific geology is unconsolidated geology with a high degree of conductivity. The values as enumerated also falls within the prescribed values of K for specific strata. Below table shows the general range of K value for a particular type of unconsolidated strata.

Table 22: Representative K values for Unconsolidated Geology

Material Hydraullic Conductivity (m/sec) Gravel 3×10-4 to 3×10-2 Coarse sand 9×10-7 to 6×10-3 Medium sand 9×10-7 to 5×10-4 Fine sand 2×10-7 to 2×10-4 Silt 1×10-9 to 2×10-5 Clay 1×10-11 to 4.7×10-9 Source: Domenico and Schwartz 1990; http://www.aqtesolv.com/aquifer-tests/aquifer_properties.htm 5.2.3.4 Land Use

Land Use pattern at Narayanganj proposed site:

The proposed EZ is planned on an area of 340 acres. Out of the total 340 acres, 49.5 acres was with DC which has been transferred to BEZA at present, 124.38 acres is khas land which is under the jurisdiction of DC and the remaining 166.09 acres is private Bondobostho land. There are 59 households presently inhabiting within the subject area. Approximately 102.71 acres of land is under agriculture. Cultivation of crops are practiced in 2 seasons at the site with paddy and potato being the prime crop being grown. The area also has one CPR which is a Mosque. Agriculture is majorly practiced in the low lands which in the monsoon season suffers from floods or water logging.

Land use pattern around the vicinity of the subject site at Narayanganj:

The proposed EZ is abutted by Sitalakhya River on its Southern side. Agricultural land followed by Meghna River is there towards its eastern side. Towards the western side of the site lies residential pockets followed by agricultural pockets which are followed by industries like Basundhara Cement Plant and Sumit Power Plant. Towards the north the site is immediately abutted by a tributary of Brahmaputra followed by dense residential settlements.

Figure below shows the landuse pattern of the area surrounding the subject site.

Figure 48. Land Use Pattern around the subject Site, Narayanganj

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5.2.4. Ambient Air Quality

PwC conducted the analysis of ambient air quality parameters within the subject site premises. The laboratorical analysis was done by experts of MIST. The rationale behind undertaking the ambient air quality analysis was to understand the baseline air quality. The particular set of analysed data will provide a standard baseline for comparison later, before and after the EZ development, the deviations in the air quality standards. The reported concentrations were compared against the recent National Ambient Air Quality Standards (NAAQS) as proposed by DoE in 2005. Refer Annexure C for the reported results of MIST, Bangladesh.

Table 23: Ambient Air Monitoring conducted within the project site premises

Parameters Units Ambient Air World Bank Results Quality Standards EHS (The Environment Guidelines , WHO Conservation guidelines Rules, 1997) Volatile Organic ppm --- 1.21 Carbon (VOC) Carbon dioxide ppm --- 356.0 (CO2) Carbon monoxide ppm 35.0 ppm (1 hour) 0.75 (CO)

Oxygen (O2) % --- 21.0 Relative Humidity % --- 79.3 Sulfur Dioxide ppm 0.14 ppm (24 hours) 20 PPM (24 0.10 (SO2) hours) Nitrogen Oxide Ppm 0.053 ppm (Yearly) 40 ppm (Yearly) 0.011 (NOx)

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Ozone (O3) Ppm 0.12 ppm (1 hour) BDL* Hydrogen Sulfide Ppm --- 3.23 (H2S) Suspended µg/m3 200 µg/m3 (8 hours) Particulate Matter 84.3 (SPM) Particulate Matter µg/m3 --- 50 µg/m3 (24 40.2 (PM 10) hours) Particulate Matter µg/m3 --- 25 µg/m3 (24 41.4 (PM 2.5) hours)

As shown in the above table, none of the reported concentrations were found to exceed NAAQS (DoE, 2005). Though the weighted average concentrations of PM2.5 was found to exceed the World Bank EHS standards. The baseline analysis of the selected parameters of air suggests that the quality of ambient air meets the standard criteria and at present none of the reported concentrations of the key parameter exceeds the standards as per the NAAQS (DoE, 2005).

Basundhara Cement Plant which falls within the close proximity of the subject site conducted an EIA study in 2013. Table below reports the ambient air parameter concentrations.

Table 24: Air quality at Narayanganj (adjacent to site) in 2015 (µg/m3) (EIA of Basundhara Industrial Complex)

Sample Location PM2.5 PM10 SPM SO2 NO2 West Side (river side) 22.47 69.42 322.65 6.10 24.85 East Side 61.29 129 380.75 7.24 26.56 National ambient air quality 65 150 200 365 100 standard, Bangladesh WHO guideline values 25 50 20

As reported in the table above, reported concentration of SPM was found to exceed at both the locations, the Standards of Air (Schedule-2) ECR-1997. Comparison was also done with WHO standards which are much more conservative than the DoE standards. Reported concentrations of PM10 was found to exceed the WHO standards at both the locations while reported concentration of PM2.5 was found to exceed the WHO standard at the East Side location. 5.2.5. Ambient Noise Quality

Ambient Noise Monitoring were also consucted within the project site. Table below tabulates the reported decibel value of the noise monitored on site premises on 5th August, 2016. The onsite assessment of the noise was done by experts from MIST. The rationale behind analysing the ambient noise intensity within the subject site was to understand the baseline noise intensity of the proposed site before the developmental site activities happens. With the initiation of the construction and operational activities at the subject site, the noise assessment can be made with respect to the baseline assessed value. Table below tabulates the reported noise intensity levels in decibels conducted on 5th August, 2016. Refer Annexure B for the Noise Monitoring Report.

Table 25: Ambient noise levels at the EZ site, 2016

Sample Location Date Time Sound Level (dBa) At the Mohanpur 05th August, 2016 1620 hrs to 1745 hrs 75.93 Moza (extreme east of the site area) Sound Standards (ECR, 1997) (for mixed area) 60

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Bangladesh Stadnard at day time for Residential Area as per Noise 55.0 Pollution (control), Rules, 2006

The analysed reported noise intensity suggests that the measured decibal value exceeds the Bangladesh Sound Standard (ECR,1997) for mixed area. The project area stands on an island. Due to the movement of engine boat, trawlers and other water transport in the river and noise from mike and other sound system, the measured average value in the time range between 1620 hrs and 1745 hrs was found to exceed the sound standards of Bangladesh.

Secondary data was also collected from Basundhara Cement Plant which lies within close proximity of the subject site. Table below tabulates the ambient noise levels as monitored by Basundhara Cement Plant in the year 2013.

Table 26: Ambient noise levels at the proposed site and surrounding areas (EIA of Basundhara Industrial Complex)

Location Equivalent noise (dBA) West Side 61 East Side 62 North Side 65 South Side 69 DoE (Bangladesh) Standard for Industrial zone 75 (day time) as per ECR 1997 in Bangladesh

As reported in the table above, the noise levels monitored at four locations were reported to be below the prescribed standard for Industrial Zone as per ECR, 1997 of Bangladesh. 5.2.6. Water Environment

Water environment includes surface water and groundwater. The Project site is located on the banks of Shitalakhya River.

The project site is located to adjacentShitalakhya River- South to North-West, confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna) - North East to South, Industrial and residential, facilities- North-West to North-East. The river leads to the route of the communication with Chandpur, Chittagong as the port of cargo. Besides these, the people live on and around the Sitalakhya River utilize its water for their household washing, bathing and other necessary daily works. 5.2.6.1 Surface Water Quality

The site location is abutted by Sitalakhya River on its immediate south. Surface water from the Sitalakhya River was collected on 27th June, 2016. The test was conducted by experts from Military Institute of Science and Technology (MIST). Surface water from Sitalakhya River was also analysed by Basundhara Cement in 2013. The data form Basundhara Cement Plant has been presented in order to have a comparative analysis of the surface water quality in the last 3 years. Surface water quality monitoring data was also collected from DoE. The data provided was of the annual monitoring of the surface water quality of the year 2014. The data gathered from DoE was also presented as a comparative tool with the present evaluated surface water quality. Table below tabulates the reported concentrations of the parameters as obtained recently from MIST from the primary testing, Basundhara Cement Plant and DoE. Refer Annexure D for the Surface Water Quality Assessment Report from MIST.

Table 27: Comparitive Analysis of the data analysed presently in 2016, from DoE in 2014 and from Basundhara Cement Plant in 2013.

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Sources Bangladesh Standard for Primary data Data obtained Data Obtained Parameters Units Inland during the from DoE from Water (ECR, study period, (Averaged), Basundhara 1997) 2016 2014 Cement Plant, 2013

pH - 6-9 7.20 7.292917 7.4

TDS mg/L 2100 71 218.5083 85

DO mg/L 4.5-8 3.78 2.73055 5.6

EC µS/cm 1200 149.8 437.2917 169

TSS mg/L 150 08 34.79167 NA

BOD5 mg/L 50 4.38 9.008333 NA

COD mg/L 200 37 37.77778 89.6

Iron mg/L 2 0.17 NA 0

Ammonia mg/L 50 0.28 NA NA

Chromium mg/L 0.5 0.0001 NA NA

Cadmium mg/L 0.05 00 NA NA

Lead mg/L 0.1 0.0002 NA NA

Total Coliform Cfu/100ml - >200 NA NA

Feacal Cfu/100ml NA NA Coliform

Chloride mg/L 600 15.56042

Alkalinity mg/L 150 57.07

The above table of comparison reports none of the parameter exceeding the prescribed standards as per ECR, 1997. The relatively high concentration of TDS and EC for the averaged out data from DoE indicates that the data could have been recorded during the monsoon season. The above table compares the data across 4 years (2013 to 2016) collected from the EIA report of Basundhara Cement Plant, DoE Bangladesh and from the primary monitoring conducted by PwC in June 2016. Bansundhara Cement Plant is downstream of the proposed site and the sample collected by Bansundhara Cement Plant could be considered as a downstream sample w.r.t the site. The sample collected by PwC in that context could be considered as the upstream sample of Sitalkhya River stream immediately abutting the subject site. The data suggest that analytical properties of the river immediately abutting the site, is well below the standards prescribed according to the ECR, 1997. In 2012, DoE has updated 12 areas/locations as an Ecological Critical Area (ECA). Sitalakhya River is also an ECA and it was declared as an ECA on 1st September, 2009. Environmental parameters shall be regulated and controlled so that the presence of an EZ shall not, under any condition, have further adverse impacts on the river water quality. Strict mitigation measures will be in place which will ensure that the industries are nor discharging waste water to the river directly further detoriote the river water quality. The strict mitigation measures are mentioned in section below.

Sitalakhya river water quality is being monitored by Department of Environment at three locations: Demra Ghat, Ghorashal Fertilizer factory and ACI factory at Narayanganj. The electrical conductivity and alkalinity of Sitalakhya river in 2013 are provided in tables below. The below table shows monthly variation in pH, DO, BOD, COD, TDS and Chloride in Sitalakhya river samples monitored by DoE, Bangladesh.

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Details of the reported results of the surface water quality assessment of Sitalakhya River of the year 2014 by DoE has been elaborated in tables and figures below.

Table 28: Electrical Conductivity in Sitalakhya River during 2014 (µs/cm)

Sampling Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Locations Near ACI, - - - 1044 598 ------Narayanganj Demra Ghat - 798 933 1064 514 519 - 127.4 - - - - Fhorashal 376 - 622 - 469 136.4 - 139.1 139.1 - - - Fertilizer Factory

Table 29: Total Alkalinity in Sitalakhya River during 2014 (mg/L)

Sampling Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Locations Near ACI, - - - 220 142 ------Narayanganj Demra Ghat - 190 650 285 200 39 - 0 - - - - Fhorashal 100 - 250 - 130 29 - - 60 - - - Fertilizer Factory

Figure 49: Monthly variation in pH, DO, BOD, COD, TDS and Chloride in Sitalakhya river samples in 2014, monitored by DoE, Bangladesh.

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The secondary surface water quality data of Sitalakhya River, as provided by Department of Environment, Bangladesh in 2014 indicates the following:

 In 2013, pH value of Sitalakhya River at all locations was within the standards for inland surface waters (6.5-8.5) for the reported period.  DO was below standard (5 mg/L) at all locations, except at Ghorasha (approximately 40 km from proposed site) in June, August and September.  BOD was high or very high compared to standard (6 mg/L for fisheries) during dry period (February, March and April). In wet season BOD is either within the limits or marginally higher. At Ghorashal FF, BOD was very high 47 mg/L in March.  COD was within standard limits (200 mg/L for waste water after treatment) at all locations  TDS varied from 5.0 to 523 mg/L as against the standard (2100 mg/L for wastewater after treatment)  Chloride was much below the standard (600 mg/L for waste water after treatment) at all locations for the reported period.  Suspended solids concentrations were much higher at Demra Ghat and Ghorashal FF during dry period. It was within limits (150 mg/L for waste water after treatment) in all other reported months at all locations.  Electrical Conductivity was within the standard limits (1200 mg/L for waste water after treatment) at all locations in all reported months. At ACI Narayanganj, the EC is very close to the standard in April.  Total alkalinity was reported higher values during dry season at Demra Ghat and ACI compared to standards (150 mg/L for waste water after treatment). At ACI the alkalinity was 220 mg/L in April.

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5.2.6.2 Groundwater

Groundwater from the site area was collected on 27th June, 2016. The test was conducted by experts from Military Institute of Science and Technology (MIST). The analysed data from MIST has been compared with the data obtained from the groundwater analysis data by Basundhara Cement in 2013. The data form Basundhara Cement Plant has been presented in order to have a comparative analysis of the groundwater quality in the last 3 years. Table below tabulates the reported concentrations of the parameters as obtained recently from MIST from the primary testing, Basundhara Cement Plant and DoE. Refer Annexure A for the Groundwater Quality Assessment Report from MIST.

Table 30: Comparitive Analysis of the groundwater quality data analysed presently in 2016 and from Basundhara Cement Plant in 2013. Sources WHO Bangladesh Guidelines Standard for Primary data Data Obtained Parameters Units Values - Inland Water monitoring from Basundhara 2004 (ECR, 1997 during the study Cement Plant, period, 2016 2013 pH 6.5 – 8.5 6.5 – 8.5 6.90 7.2 TDS mg/L 1000 1000 611 228 TSS mg/L 10 10 72 EC µS/cm - - 1280 448 DO mg/L 6 6 3.25 0.6 BOD5 mg/L 0.2 0.2 0.42 COD mg/L 04 04 08 Iron (Fe) mg/L 0.3 – 1 0.3 – 1 9.4 0.66 Total mg/L 200 – 500 200 – 500 4.32 NA Hardness Sulfate mg/L 400 400 0 NA Fluoride mg/L 1.5 01 0.47 NA Arsenic mg/L 0.01 0.05 0.0396 NA Chromium mg/L 0.05 0.05 0.0001 NA Cadmium mg/L 0.005 0.005 0 NA Lead mg/L 0.05 0.05 0.0031 NA Total cfu/100ml 0 0 65 NA Coliform Feacal cfu/100ml 0 0 0 NA Coliform

The above table of comparison shows that reported concentration by MIST of TSS, BOD5, COD and iron were found to be exceeding the ECR, 1997 and WHO standards while the reported concentration by Basundhara Cement Plant of iron was found to exceed both the standards of comparison. Upon comparison of the groundwater quality of Narayanganj in the last 3 years (2013 to 2016), it could be interpreted that the quality has deteriorated. Reported concentrations of TDS, EC and iron has shown a 3 times increase in the last 3 years. The presence of BOD5 could be geogenic. Presence of fulvic acid and humic acid in soil could be a potential reason for the BOD presence.

Groundwater was collected from a handpump which generally is tapped at a shallow aquifer. The locality from where the water was collected has around 59 households and most of them have kaccha toilets. The area or the locality doesn’t have septic tanks also for safe disposal of human wastes. All these condictions could result in impacting the groundwater with biodegradable wastes. As reported, the concentration of sulfate is zero. It could be hypothesised that the groundwater is under anoxic conditions which could possibly provide a favourable environment for anoxic microbes to flourish. This could be a possible reason behind the presence of total coliform. The absence of sulfate could also indicate that the groundwater is under negative potential (reducing conditions). Under a reducing environment and pH around neutral

89 EIA Report- Narayanganj Economic Zone range, probability of chromium to be present in the form of hexavalent chromium (the harmful form of chromium) are low. Hexavalent chromium requires an oxidative environment or positive Eh to get oxidised to hexavalent chromium.

TDS could be geogenic. Presence of ions in water do contribute towards the concentrations of TDS. Bangladesh generally have the problems with the presence of arsenic in groundwater. Secondary data from the research paper “Status of groundwater arsenic contamination in Bangladesh: A 14-year study report”, Water Research - November 2010 indicates that there is a substantial concentration of arsenic in groundwater from Narayanganj and Dhaka district. The primary monitoring during the study period indicates that the concentration of arsenic are below the presecribed standards. Table below shows the concentration of arsenic in groundwater collected from Dhaka and Narayanganj district. Factors like the depth from where the groundwater was collected could also impact the concentrations of arsenic. Considering that the concentration of arsenic in groundwater is due to geogenic reasons, sample collected from greater depth could probably have higher concentrations of arsenic.

Table 31: Arsenic contamination in Groundwater in Narayanganj

Division District Area Population Total no No of No of No of Distribution of total samples in different As Max (km2) of thana surveyed thana samples concentrations (µg/l) ranges Conc thana As >50 analyzed <10 10-50 51-99 100- 300- 500- 700- >1000 detected µg/l 299 499 699 1000 (µg/l) Dhaka Dhaka 1459.56 8511228 27(6) 6 3 574 449 29 26 63 7 - - - 352 Narayan 687.76 2173948 5 3 2 412 54 42 34 147 68 36 26 5 1750 ganj

5.2.7. Agricultural Resources

The proposed aite area is used for agriculture purposes. The project site consists of 340 acres of land consisting of Khas land, land owned by BEZA and “Private Bondobostho Land”. Of the 340 acres proposed for the project site, the Khas land constitutes 124.38 acres, 49.5 acres of land has been transferred to BEZA and 166.09 acres of land is “Private Bondobostho Land”. The proposed site is immediately abutted by Sitalakhya River and considering the loamy tyoe of soil, the crop fertility of the proposed site is relatively on the higher end. Crops are grown on a biannual cycle basis. Summers and winters are the two distict seasons for the crop production. Paddy, Corn and Bitterguard are the dominant variety during the summer season while Potato, Sweet Potato, Pui Shak and Lau Shak are in the winter season.

5.2.8. Livestock and poultry

There are two poultry farm reported to be there within the project site. Boilers and domestic varieties of chicken are being reared and sold in local market to earn their livelihood. The loss of livelihood has been enumerated and the owners shall be compensated for their loss of livelihood. 5.2.9. Fisheries

No pisciculture or fish culture are being practiced within the proposed site area. Fishing is a common practice at the subject site and people catch fish from the Sitalakhya River and sell it in the local market.

5.2.10. Ecological Resources

The flora fauna information provided in this section is collected through secondary sources. The project area is mostly low lying and rich in biodiversity. As per the ecological survey findings presented in EIA of Basundhara Industrial Complex (adjacent to proposed site), the flora and fauna species are presented in tables below.

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Table 32: Fauna Species in the project area Scientific Name English Name Local Name Reptiles _ Enhudris enhydris Smooth Water Snake Painnya Shap/ Huriha Hem idactylus House Lizard Goda Tik Tiki Naja naja Kaouthia Narrwo headed Softsheel Chitra indicated Turtee Chitra katchap

Amphibians Bafo melanostictus Common Toad Bang Rana Cyanophyctis Skipper Frog Bang

Mammals Callosciurus sp. Squirrel Kat Biral Cynopterus spinex Short nosed fruit Bat Badur Funumbalus pennanti Squirrel Kat Biral Herpestes Mongoose Bheji Auropuncatus Mus booduga Field Mouse ldure Mus musculus House Mouse Nengti ldur Pteropus Giganteus Gaint Flying Fox Boro Badur

Bird Alcedo atthis Common Kingfisher Machranga Copsychus saularis Robin Doel Corvus splendens House Crow Kak Egretta albe Great Egret Boro Bak Egretta gazetta Small Egret Shoto Bak Dirrurus adsimilies Black Drongo Fingry Passer domesticus House Sparrow Choroi Source: EIA of Basundhara Industrial Complex

Table 33: Floral Species in the project area English Name Scientific name Local name Main name

Grass Grass Spontaneum Khar Ful/Covering Saccharum Gash (kaichi Kash, Dubla etc.) Cynondon dactylon Soil Binder Trees Bettie nut Areca Catechu Supari Lichi Lichi chinensis Lichu Fruit Mango Mangifera indica Aam Fruit, Timber Date Palm Phoenix sylvestris Khejur Fruit, Timber Black Berry Syzygium cumini Jam Brown sugar Jackfruit Heterophyllus Khatal Fruit, Timber Coconut Cocos nucifera Narikle Fruit, Timber Papaya Carica Papaya Pape Fruit, Fuel Guava Psidium guajva Piara Fruit, Banana Musa Sepientum Kala Fruit Fuel

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Wood Tree (Timber/Fuel wood) Mehagani, Shilkoroi, Shorea Robusta Shil kiroi Fuel, Timber Shimul Albizia procea Salmalia Silk cotton Fuel, Timber Fuel, Pillow malabaricum Source: EIA of Basundhara Industrial Complex

Table 34: Fish Species in the Study Area Fish Group Scientific Name Local Name Prawn Macrobrachium malcolmsoni Icha Cat Fish Mystus vittatus Tengra Mystus vittatus Golisha Tengra Wallago attu Boal Pangash Major Carps Labeo rohita Rui - Catla catla Catla Carrhinus mrigala Mrigel Minor Carps Puntius sophere Puti Snakehead Channa punctatus Taki Eel Mastacembelus armatus Bain Others Amblypharyngodon mola Mola Pscudeutropicus atberinoides Batasi Source: EIA of Basundhara Industrial Complex

The industrial activity and open discharge, without appropriate measures, shall have impact on the biodiversity of the project area.

5.2.10.1 Flora

Due to the roadside plantations and certain homestead forests, the area is rich with floral diversities. Different fruit, fuel wood trees along with various shrubs are abundant. Among the trees, the most widely available ones are Shilkoroi, Mehagani, Eucalyptus, Sliimul, etc. but there are some fruit trees also such as mango, coconut, jackfruit, bettlenut, guava etc.

5.2.10.2 Aquatic Fauna

The fishes include catfishes (magura and shing), major carps (katla, rui, and mrigal), minor carps (puti), other (Tengra, Boal, Mola, Shol). Also prawn, particularly the popular small prawns, locally known as lchha are available.

5.2.10.3 Terristrial Fauna

Reptile The common types of reptiles are found in the study area includes, water snake, house lizard, soft-shell, turtle etc.

Amphibians Mostly Toads and frogs-two species are prominent.

Mammals

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These include fruit bat, Squirrel, field and house mousses, and flying box. No major mammal species of national significance are present in this area.

Birds The commonly spotted birds in the project area include kingfishers, house crow, house sparrow, little fern etc.

5.2.11. Socio-economic Conditions 5.2.11.1 Demographic Characteristics

Demographic characteristics are obtained for the people whose house or privately owned land is impacted because of proposed EZ development. The Sonakanda mouza map which was used as a reference to identify the land details is given below. Please note that the redefined area for the EZ development is being marked as blocks named as 1 to 5.

Figure 50: Mouza Map indicating the project area as provided by the District Commissioner (DC)

5.2.11.2 Distribution on the basis of gender composition

 Homesteads impacted by project

The development of the Economic Zone will involve physical displacement of 59 homesteads. The physical displacement of the homesteads will impact 210 people categorized as Project Affected Person (PAP’s).

 Households impacted by project

The area which has been highlighted in the map attached above, depicts the revised area that has been presently proposed for the EZ developmental purposes. The private “Bondobostho Land” demarcated for

93 EIA Report- Narayanganj Economic Zone the proposed Economic Zone comprises of 59 households. 56 households were surveyed while 3 were locked which couldn’t be surveyed.

The census survey was administered through structured questionnaire for a total of 56 land owners comprising of 210 PAP’s constituting the families of the affected homesteads. Of the 210 PAP’s, 115 were males and remaining 95 were females. The primary source of livelihood for majority of the PAP’s is from the fishing and agriculture especially of potato in the project affected area. The overview of the demographic characteristics of the project affected landowners to whom the census survey was administered is provided in the below table.

The demographic data as tabulated in table below indicate that the females constitutes 44.76% of the total project affected landowners populations while the males constituted 57.14%.

Table 35: Demographic Data S. No. Scenario No. of PAPs No. of PAPs Sex Ratio Average PAH‘s* (%) Total Male Femal (Numbe rof Househol e Males/Fem d Size ales)*100 1 Project 60 100 210 115 95 121 3.5 Affected Persons Total 60 100 210 116 94 121 3.5 Source: Census survey March-April 2016

Below table shows the age wise distribution of the PAPs that were surveyed. Most of the affected people were found to be within the age bracket of 18-30 which constituted 35.71% of the total affected PAPs. Considering the age group ranging from 18-40 as the youth age bracket, a total of 120 within that age group were found to be impacted. So 57.14% of the total affected people are in the age group of 18-40 which is considered as the youth bracket age group.

Table 36: PAPs categorized based on their age Age Group Number of PAPs Percentage of the total PAPs (%) 14-17 21 10.0 18-30 75 35.71 31-40 45 21.42 41-60 57 27.14 61 and above 12 5.71 TOTAL 210 100 Source: Census survey March-April 2016

Figure below represents the graphical analysis of the age wise distribution of the PAPs.

Figure 51: Age wise PAP distribution

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6% 10% 14-17

27% 18-30 31-40 36% 41-60

21% 61 and above

5.2.11.3 Religion

As per the findings of the socio-economic survey, 100% project affected households are Muslims. 5.2.11.4 Literacy Level

Of the total affected population, 13.33% of the men have achieved secondary level of education where as 10.47% of the women population has achieved secondary level of education. Illiterate populations comprise of 9.52% of the total PAPs whereas illiterate population in women was 8.57% of the total PAP’s. 0.95% males and 0.47% of females of the total population were found to have some kind of vocational and technical trainings. The low education levels emphasize the need for stress on technical education and skill enhancement programs in the region for employment in the industries proposed in the Economic Zone. Below table illustrates the literacy level percentage.

Table 37: Literacy level of PAPs S. No Literacy Level of Number Percentage of Number of Percentage of PAPs Males males Females females 1 Illiterate 20 9.52 18 8.57 2 Can read and write 45 21.90 41 19.04

3 Primary Schooling 13 6.19 9 4.28 (class 1-5) 4 Class 6th to 8th 22 10.47 14 6.66

5 Class 9th to 10th 6 2.85 8 3.80

6 SSC/HSC 7 3.33 4 1.90 Equivalent 7 Vocational or 2 0.95 1 0.47 Technical Diploma Total 115 55.23 95 44.76 Source: Census survey March-April 2016

Figure below represents the graphical analysis of the literacy levels of the PAPs.

Figure 52: Literacy Level of the surveyed PAPs

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Illiterate

Can read and write 5%1% 7% 18% Primary Schooling (class 1- 5) 17% Class 6th to 8th

Class 9th to 10th 11% 41% SSC/HSC Equivalent

Vocational or Technical Diploma

5.2.11.5 Marital Status

As per socio-economic survey, 155 (73.80%) persons are married while 29 (13.80%) persons are unmarried. Widows comprises 12.38% of the total PAPs. Refer below table for the marital status of the PAPs.

Table 38: Marital Status of PAPs S. No Marital Status of PAPs Number %

1 Married 155 73.80 2 Widow/Widower 26 12.38 3 Divorced/Seperated 0 0.00 4 Unmarried 29 13.80 Total 210 100.00

Source: Census survey March-April 2016

Figure below represents the graphical analysis of the marital status of the PAPs.

Figure 53: Marital status of the surveyed PAPs

96 EIA Report- Narayanganj Economic Zone

14% Married 0% 12% Widow/Widower

Divorced/Seperated 74% Unmarried

5.2.11.6 Health Status

Data on health status of affected households indicate that nearly 42.00% of the families have suffered from illness during the last year. Refer below table for the health status of the PAHs and project affected landowners in the project area. Kidney ailment at one household and cardiac ailment at three households were reported which could be categorized as major chronic ailments. Apart from that, the disease reported in the area were respiratory diseases, gastric issues, arthritis.

Table 39: Health Status of affected households S. No Health Status of PAHs Number %

1 Illness 35 41.46

2 No Illness 20 58.53

3 Don’t Know 1

Total 56 100

Source: Census survey April 2016

As per the findings of the social survey a total of 2 Upazilla Health Complex are there in Bandar and Sonargaon Upazila. A total of 16 Community Health Centre are there in Bandar and Sonargaon Upazila. A total of 15 private hospital and dispensaries are there in both the upazilas. Details of availability of health facilities as per census survey of March-April 2016 are mentioned in below table.

Table 40: Availability of Health Facilities at Bandar and Sonargaon Upazila

S. No Health Facilities Number

1 Upazila Health Complex 2

2 Community Health Centre 16

3 Private Clinic 15

Total 33 5.2.11.7 Employment Status of PAPs

97 EIA Report- Narayanganj Economic Zone

Gender segregated employment status of the PAPs is mentioned in table below

Table 41: Employment Status of PAPs S. No Employment Number Percentage Number of Percentage Status/Occupation of Males Females 1 Wage Labour 11 5.23 1 0.47 2 Factory Worker 19 9.04 2 0.95 3 Farmer 19 9.04 1 0.47 4 Tailor 3 1.42 1 0.47 5 Carpentor 1 0.47 0 0.0 6 Fishing 38 18.09 9 4.28 7 Unemployed 2 0.95 80 38.09 8 Rickshaw Puller 1 0.47 0 0.0 9 Milk Seller 1 0.47 0 0.0 10 Migrant Worker 1 0.47 0 0.0 11 Student 1 0.47 1 0.47 12 Government Service 1 0.47 0 0.0 13 Private Service 11 5.23 0 0.0 14 Business/Shops 6 2.85 0 0.0 Total 115 54.76 95 45.23

Source: Census survey March-April 2016

Figure below represents the graphical analysis of the employment status of the PAPs.

Figure 54: Employment status of PAPs

Wage Labour

Factory Worker

Farmer 5%3%6% 1%0%0%1%0% 10% Tailor

10% Carpentor 2%1% Fishing 39% Unemployed 22% Rickshaw Puller

Milk Seller

Migrant Worker

5.2.11.8 Income Level

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Out of the 210 of the total surveyed PAPs, 18 males (8.57%) and 81 females (38.57%) falls under the no income group. 2 males (0.95%) and 5 females (2.38%) of the total 210 PAPs, falls within income range of BDT 2000-3000 (per person). 49 males (23.33%) and just 3 females (1.42%) of the total 210 PAPs, do earn above BDT 10,000 per month. People earning more than BDT 10,00o are majorly fishermen while few were found to be working at shops at Dhaka. Refer the below table for the income levels of the PAPs of the surveyed area. These people who are mostly dependent on agricultural lands, fishing etc have low to medium level of income. Most of the houses which falls within the affected area doesn’t have basic amenities like electricity. Please note that row where “No income” has been mentioned encompasses students and housewives. Men from their family earn the livelihood for the entire family.

Table 42: Income Level S. No Income Level Number Percentage Number Percentage (Males) (Females) 1 No Income 18 8.57 81 38.57 2 Below BDT 2000 2 0.95 5 2.38 2 Rs. 2000-3000 1 0.47 1 0.47 3 Rs.3000 – 10000 45 21.4 5 2.38 4 Above 10,000 49 23.33 3 1.42 Total 115 54.76 95 45.23

Source: Census survey March-April 2016

Figure below represents the graphical analysis of the Income levels of the PAPs.

Figure 55: Income Level of the PAPs

25% No Income Below BDT 2000 47% Rs. 2000-3000 Rs.3000 – 10000 24% Above 10,000 1%3%

Table 43: Economic Status- loan and Indebtedness Economic Status-Loan and Indebtedness Yes % No % Total

20 35.71 36 64.28 56

Source: Census survey March-April 2016 As per socio-economic survey, 20 PAH’s have borrowed loans (refer the table above), with 4 (20%) PAH’s have taken loan from some bank, 1 (5.0%) PAH each have borrowed loan from some money lender or from some relative or friend. 14 PAHs (70%) have borrowed loans from some NGOs. Construction or

99 EIA Report- Narayanganj Economic Zone mainanence of their home, increased monetary requirements during festive seasons are some of the reasons for borrowing loan. PAPs whose monthly income is relatively on the higher end and who have borrowed loans more than BDT 1,00,00 are paying somewhere around BDT 25,000 per year. Details of sources of loan are mentioned in table below. Loan amount varies between BDT 20,000 to BDT 1,50,000. Refer the below tables for the range of loan amount and the sources of loan borrowed by the PAHs.

Table 44: Range of loan amount S. No Income Level Number % 1 Less than equal to BDT 20,000 3 15.0 2 BDT 21,000 – BDT 50,000 12 60.0 3 BDT 51,000 – BDT 1,00,000 2 10.0 4 Above 1,00,000 3 15.0 Total 20 100

Source: Census survey March-April 2016

Table 45: Source of loan S. No. Source of loan Number % 1 Bank 4 20 2 NGO 14 70 3 Money Lender 1 5 4 Relative/Friend 1 5 Total 20 100

Source: Census survey March-April 2016

5.2.11.9 Expenditure/ Consumption Pattern

The following table indicates that 7.14% PAHs spend less than Rs. 2000/- on food. As the households surveyed constitute non-titleholders residing on the private “Bondobostho Land”, thus the rental expenditure is zilch. Significant proportion of the expenditure is on food and beverages. The negligible expenditure on the education further collaborates the low literacy rate in the project area. The expenditure patterns indicate that the PAP’s comprise of low income groups. Refer the below table for the details of Consumption/ Expenditure Pattern of the PAPs surveyed.

Table 46: Consumption/ Expenditure Pattern: List of items as per Expenditure Items of Below BDT 2000 BDT 3000 – Above Total Grand Expenditure BDT 2000 -3000 10,000 10,000 Total

Food and Beverages 4 1 28 23 56 56 clothing and Footwear 32 14 9 1 56 56 Fuel and Lighting 50 2 4 0 56 56 Health and Medical 42 8 6 0 56 56 Care Education 45 8 3 0 56 56 Transport 47 9 0 0 56 56 Social 31 16 9 0 56 56 Functions/Festivals House Maintenance 47 3 6 0 56 56 Agriculture 48 3 3 2 56 56 Monthly Rent 56 0 0 0 56 56 Others 56 0 0 0 56 56

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Source: Census survey March-April 2016 5.2.11.10 Material assets

37 PAHs (66.07%) of the 56 PAPs surveyed have a mobile connection. 17 (30.358%) PAHs out of 56 PAHs have a color television in their homes. While 10 of them (17.85%) have a Dish Antenna with their color TV. Most of the houses are not equipped with electrical connections. PAPs generally take a walk to avail food, markets and even to local doctors. The table below indicates the assets owned by the PAH’s. The traffic survey analysis was also done for the PAHs. Considering that the market, hospital, school etc are quite nearby, PAPs staying at these PAHs are not quite verse with using vehicles like scooters, bicycle for local usesandneeds. 13ofthePAHs(23.21%) outof56 havecountryboats(manual) while2 ofthePAHs(3.57%) have mechanized boats. Since they have to cross a river every time they have to go to the market or for any other reasons hence few of them have boats. In exigencies PAPs use public services to travel to Dhaka. Refer the table below for the traffic survey analysis result for the PAHs.

Table 47: Details of assets owned by PAH’s S.N Area Color CD/D Dish Radi Mobile Refri Sewing Electric Washing o Televis VD Anten o/Ta gerat Machine Fan Machine ion Playe na pe or r Rec orde r 1 PAPs 17 7 10 5 37 9 1 16 2 Total 17 7 10 5 37 9 1 16 2 Source: Census survey March-April 2016

Table 48: Details of Possession of Vehicles S.No Area Bicyle Rikshaw Scooter Car Truck Country Mechanised /Motorc /Bus Boat Boat ycle 1 PAPs 6 0 1 0 0 13 2 Total 6 0 1 0 0 13 2

Source: Census survey March-April 2016 5.2.11.11 Livestock data

Livestock data was collected during the survey of 56 PAHs. Majority of the household rear livestock. 23 of the PAHs (41%) have cow/ox in their homes. 17 of the total PAHs surveyed (30.35%) have chicken or poultry in their homes. They breed Boilers and Local Chicken breeds and sell them at appropriate time. Animal and animal products serves as one of the major source of earnings for these PAPs. Refer the table below for the breakup of livestock.

Table 49: Livestock

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S. No. Livestock Number %

1 Cow 23 41.07 2 Buffaloes 0 0.00 3 Goats 2 3.57 4 Sheeps 1 1.78 5 Poultry (chickens) 17 30.35 6 Pigeons 3 5.35 7 None of the above 10 17.85 Total 56 100 Source: Census survey March-April 2016

Figure below represents the graphical analysis of the livestock belonging to the PAPs.

Figure 56: Livestock belonging to the PAPs

Cow

18% Buffaloes Goats 5% 41% Sheeps

Poultry 30% 0% (chickens) 2%4% Pigeons

5.2.11.12 Gender assessment

Women in the region primarily are involved in household work, cultivation and other agriculture activities. They are also involved in decision making involving decisions like education of children, decisions before social functions etc. However, data collected from household survey reveals lower participation of women in financial decisions which indicate the need for the women empowerment in the region.

Table 50: Decision making and participation by women Decision Making Households No. % Financial matters Male 2 3.57 Female 0 0.0 Combined 54 96.42 Education of children Male 3 5.35 Female 0 0.0 Combined 53 94.64 Health care of children Male 2 3.57

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Female 0 0.0 Combined 54 96.42 Purchase of assets Male 11 19.64 Female 0 0.0 Combined 45 80.35 Day to day household activities Male 3 5.35 Female 0 0.0 Combined 53 94.64 Social function and marriages Male 11 19.64 Female 0 0.0 Combined 45 80.35 Women to earn for family Male 56 100.0 Female 0 0.0 Combined 0 0.0 Land and property Male 42 100.0 Female 0 0.0 Combined 0 0.0 Source: Census survey march-April, 2016

Evidence based on the census survey points to persistent gender disparities in access to and control of a wide range of assets: human capital assets (education and health); directly productive assets (labor, land, and financial services); and social capital assets (e.g., gender differences in participation at various levels, and in legal rights and protections).

As indicated in the census survey, close to 99% of the women surveyed are not a part of the active work force participation. The absence of the women in the active work force participation also reflects on the lack of access to the monetary benefits for women. Further, the census survey has also indicated that more than half of the women population have not enrolled in the formal primary education.

Further, the census survey has indicated the need for the skill development initiatives for the women in the project area of influence to gain access to employment in the proposed industries. The proposed industries in the EZ vis-à-vis knitting, textile and agro based industries, require advanced trainings for employment

Gender assessment on the social capital is considered in terms of the ability to effectively forge ties in the society, communicate freely and without coercion for exchanging of the information. The concept of social capital, is broadly understood as a social resource ‘‘upon which people draw when pursuing different livelihood strategies requiring coordination and collective action’’. Social capital builds when groups (men and women) are brought into a dialogue or otherwise work on activities which benefit everyone in the society.

The census survey has indicated the presence of gender biases of social capital, which can be dissected as collective action that (re)produces gender discrimination, that is, reinforces male dominated power structures and excludes women from participation and decision making.

As indicated in the census survey, women’s responsibility for family provision of household resources such as water and fuel wood makes women both more dependent on common property or open access to natural resources and at the same time more vulnerable to the negative effects on rural livelihoods of resource degradation.

The site reconnaissance survey has indicated the presence of strong ability for women to forge informal relationship in the society. The other socio-economic factors such as unemployment, responsibility towards children factor towards greater interdependency and altruism exhibited by women.

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However, this also alludes to the lack of participation of women in formal organizations, which limits the ability communicate freely and without coercion for information exchange.

The lack of avenues for accumulating economic resources and the women’s immobility as evidenced through census survey indicate a greater need for women to sustain the informal networks. 5.2.11.13 Inference

Survey of demographic profile, material assets, occupation and income level of the project affected households indicates the presence of poor to medium social and economic condition. Lower women participation in the financial decision and lack of women participation in the active work force indicate the need for women empowerment in the area.

5.2.12. Traffic Survey

The construction and operation of EZ will involve transportation of materials. The proposed site is located near the Sitalakhya River. Sitalakhya River is extensively used for goods and human transportation. Fishing activities are carried out extensively. The secondary data has been collected from EIA of Summit Narayanganj power, on traffic survey for the below mentioned locations.

Table 51: Traffic Survey Locations

Traffic Survey Type Location GPD Readings River Sitalakshaya River 22° 18’ 59.27”N 91° 49’ 21.24”E Road Modonganj Main Road 23° 35’ 26.8”N 90° 30’ 57.8”E

The survey results reveal that the supplies of food grain, consumer goods, grocery items, edible oil, clothing and garments, cement and other construction materials, petroleum products, electronics, medicine, machinery and equipment etc received by Modonganj in 122 trucks. Other vehicles include car, micro bus, bus, rickshaw, van, motorcycle, baby taxi which were 13, 12, 7, 51, 36, 23 and 14 respectively during the observation. And around 47 units of river vehicles were moved through the Sitalakhya river during the observation.

The existing vessel traffic in Shitalakhya River is as follows (Source: Narayanganj Port 2015):

- 60 passenger launches every day cross the river from one side to other carrying the passengers - Movement of oil tankers which are 150 feet long and 50 feet wide along the river – 100 per month (Three to four per day) - Cargo vessels of same size carrying fly ash, cement material, clinker, etc – 200 per month (6 to 7 vessels per day) - Bulk cargo (sand) vessels of size 80 feet x 25 feet – 50 vessels per day

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6. Identification and Analysis of Key Environmental Issues

6.1 Environmental Sensitivity Investigation

Environmental impact assessment has been carried out considering the impacts of proposed interventions with associated activities on important components of the environment and society. Firstly, all of the environmental components sensitive to proposed activities were identified during reconnaissance field visit based on expert observation, local people’s perception and worldwide practice of EIA. The scoping process, followed to identify the environment and social sensitive features included professional judgments of the multi-disciplinary EIA team members and public consultation. The preliminarily identified environmental and social sensitive components are listed in sections below. 6.2 Environmental Asset

Environmental assets identified in the study area are listed below: 1. Air Quality of the area 2. Noise level of the area 3. Water Quality of the area 4. Transportation system of the area 5. Ecosystem of study area Identified environmental assets of the project are likely to be impacted due to development of the off-site facilities at all the pre-construction, construction and operation stages of the project. Project activities which may have an impact on the environmental assets and the associated impacts are listed below. The detailed impact identification and mitigation measures are given at Chapter 7. Table 52: Environmental Assets of the project area

S. Environmental Assets Impact Related No. Project Activity Pre-Construction & Construction Phase 1 Air Quality of Study Area Degradation Site clearance/ preparation Construction activities Excavation Exhaust from construction vehicles/machinery 2 Noise Level of Study Area Increase in Noise levels Construction activities Movement of construction vehicles/machinery 3 Transportation System Traffic congestion Increased nos. of vehicles carrying construction raw material and construction debris 4 Fisheries of Study Area Filing up of the aquaculture Construction of borewells ponds/small water bodies Increase in run-off from Increased sedimentation of construction/excavated site water body 5 Biodiversity study of project Increased sedimentation of Increase in run-off from area water body construction/excavated site Vehicular movement Hogher noise levels Disposal of treated and untreated waste

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Operation Phase (For Off-site Developments Only) 1 Noise Level of Study Area Increase in Noise levels Increased traffic movement and tourism activities 2 Transportation System Traffic congestion Increased nos. of vehicles 3 Fisheries of Study Area Degradation of fisheries The construction activities may impact fisheries in the project area of influence.

4 Eco-system of Study area Degradation of Water Discharge of untreated solid Quality & Aquatic ecology and liquid waste Higher noise levels Tourist activities Vehicular movement

6.3 Environmental Hotspot

The project area is abutting Sitalakhya River. The river has been declared as Ecologicallly Crtical Zone (ECZ) by Department of Environemnt, Bangladesh. To minimize impacts due to the upcoming EZ starting from the construction phase, DoE has given a mandate to keep a buffer of 100m from the river shore line. No developmental activities shall be permited within the buffer zone of 100m from the river shore line. It has been proposed to develop green zone in that 100m strech though apart from that, the zone is least likely to have any infrastructure developments. 6.4 Likely Beneficial Impacts

The project involves development of EZ and off-site facilities. It is proposed to develop Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials Agro, Food and Fish processing, light engineering industries at the proposed EZ. The likely benefits from the proposed development are listed as below: 1. Rapid Economic development 2. Large scale direct and indirect employment generation 3. Development of infrastructure facilities 4. Technological enhancement for management of environmental management ( like water treatment, waste management, environmental monitoring ) 5. Permanent source of employment, fixed monthly income; 6. Better living standards

6.5 Community Recommendations and Alternative Analysis

The details of the community recommendations and alternative analysis options are covered in SIA report and snapshot is provided in chapter 8.

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7. Impacts Assessment

7.1. Introduction

The environmental impacts assessment was carried out considering present environmental setting of the project area, and nature and extent of the proposed activities. The proposed project involves development of EZ and off-site facilities for upcoming EZ at Narayanganj. Potential environmental impacts associated with EZ and each of the proposed off-site facility are classified as:  impacts during design and construction phase and  impacts during operation phase.

Sensitive environmental components were identified during the site visits and qualitative and quantitative techniques have been applied for direct and indirect assessment of impacts on these components. The classification of environmental components is provided in Table below.

Table 53: Classification of Social and Environmental Components Components Sub-component Parameters PHYSICAL Water Surface water Hydrology, water quality Air Ground water Land Air, noise Air quality, noise level Soil Erosion, soil quality ECOLOGICAL Fisheries/ Aquatic species Species, diversity, economic value Aquatic Aquatic Biology Density, species Terrestrial Vegetation Species, population Wildlife Species, population INFRASTRUCTURE Water Supply Surface/ground water Frequency, quality Electricity — Generation, Transmission, requirement, Transport Highways/Roads Access, availability, type, utility of each Land use Rail mode Drainage Air Water — Flooding, drainage

7.2. Impact Identification

During the site visit, various environmental sensitive features were identified which may potentially be impacted by the project at various stages. Identified impacts of the project activities on the environment components are given below along with the associated activities.

Table 54: Impact Matrix for Proposed Off-site Infrastructure

S. Activities Impacts Negative Positive Not No. Impact Impact Applicable Short Long Short Long Term Term Term Term A Pre-Construction Phase

i Land Acquisition for  Change in land use  access road and water pattern of existing supply system

107 EIA Report- Narayanganj Economic Zone

agricultural land   Impact on livelihood  Shifting of Utilities



ii Site Preparation Demolition of buildings,  Removal of Vegetation.  Loss of tree cover and Impact on aesthetic aspects B Construction Phase i Development of EZ and Loss of Top soil  Construction of Soil contamination due  Boundary wall, to spillage of material embankment, Access Surface water  Road, electrical & water contamination supply system and Air pollution  administration building Noise pollution  Increase in traffic  Un pleasant view  Impact on Health &  safety Social impact   Felling of Trees  C Operational Phase i Development of Off-site Impact on the ambient  Infrastructure, i.e. Air Quality Boundary wall, Noise Pollution  embankment, access Potential for surface  road, water supply water pollution due to system, electrical supply industrial waste line and administration discharge building and operation Impact on river of industries hydrology due to  construction of long embankment along the river Economic Development  Accessibility  Groundwater depletion  Potential for land  contamination due to industrial activities Improved drainage  Electrification of the   area Improved health and  sanitation facilities Increased Run-off  Generation of  Employment Natural drainage pattern  Ii Green Buffer  Improved Ecology  development around  Air Quality  each industrial plot Improvement  Aesthetics 

108 EIA Report- Narayanganj Economic Zone

7.3. Impacts on Air Environment 7.3.1. Pre-construction phase

The pre-construction phase will involve site clearance activity for development of EZ, access road and water supply system which will lead to fugitive emissions. But these emissions will be localized and have impact for short duration only during clearance activity.

During pre-construction phase 59 houses and other structures will be demolished. This activity would generate fugitive dust emissions, though it is for short duration.

To minimize the dust generation, water should be sprinkled regularly at the site and low sulphur diesel should be used in land levelling equipments to control the SO2 emissions.

7.3.2. Construction Phase

The proposed project involves construction activities which includes:

 site development (land filling, earth work);  construction of embankment along the river  civil construction;  construction material handling and stockpiling; and  Vehicular movement which will generate fugitive dust and vehicular emissions.

Air quality will be impacted from the following sources during the construction phase:

 Fugitive dust emissions from site clearing, excavation work, cutting and levelling work at sites and access/ internal roads, stacking of soils, handling of construction material, transportation of material, emission due to movements of vehicles, plying of heavy construction machinery etc.;  Vehicular emissions due to traffic movement on site and on the connecting roads;  Exhaust emissions from construction machineries, other heavy equipment as bull dozers, excavators, compactors; and  Emissions from diesel generator required for emergency power during construction period.

A huge filling requirement [about 1.4 million cubic meters (MCM) filling material] is expected in this site. Dredged material from adjacent river is expected to be used for filling. To carry the dredged material about 1000 trucks are expected to move from port to inside the site. This truck movement will cause fugitive emissions and exhaust emissions. Additional numbers of trucks will be required to sand for backfilling from source to sink. Similarly, the dredging equipment involved in this dredgeing will also cause emissions.

Gaseous emissions containing PM10, PM2.5, SPM, CO, HC, NOx, SO2 and lead will be released from the vehicules, construction equipment and dredger exhaust. The vehicular movement on the unpaved roads will also result in the fugitive dust emissions. The movement of trucks carrying construction material to the site during the construction of boundary wall and embankment will lead to fugitive and exhaust emissions which would impact the people in the project area of influence. The movement of heavy trucks also increase the potential for road accidents.

Mitigation Measures to be implemented are:

To mitigate the construction impacts, BEZA should have contract agreements with contractors as well as sub-contractors to implement the measures provided in EMP.  Sprinkling of water at construction site and haul roads

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 Construction of barricades between the settlements and the site to minimize travel of fugitive emissions towards settlements  Tree Plantation on either side of the approach road to mitigate the fugitive dust emissions  Minimizing stockpiling by coordinating excavations, spreading, re-grading, compaction and importation activities  Cease or phase-down work if excess fugitive dust is observed, investigate source and take suppression measures such as water spray  Adequate parking space should be provided for the construction vehicles so as to prevent idling of the vehicles and the emissions generating from them  Vehicles carrying construction material and debris should be covered with tarpaulin cover  Raw materials, excavated soil and other debris should be stored under covered sheds or cover with tarpaulin  Green buffer should be developed all along the EZ boundary  Provision of face mask to workers to minimize inhalation of dust particles  Construction vehicles and machinery should be regularly serviced and check for pollution control  Low sulphur diesel should be used for running construction equipment and vehicles  Covering the scaffolding (in case of administration building) to reduce the dust emission in outside environment  Speed of vehicles on site is recommended to be 10-15 km/hr which will help in minimizing fugitive dust emissions due to vehicular movement

7.3.3. Operation Phase

Post development of the EZ & setting up of industries, there could be some impacts on the air quality of the area. Industrial development will involve generation of emissions, and increased vehicular movements. These altogether may have overall negative impact on the air quality of the site and the nearby areas. The industries proposed as per the pre-feasibility study are Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials, Agro, Food and Fish processing, Light engineering industries. It is envisaged that particulate matter, sulphur dioxide, metals and other criteria pollutants like ozone, oxides of nitrogen and carbon monoxide will be generated during industrial operations.

Air emissions from food processing industry contains some volatile organic compounds but do not contain any hazardous compounds. These industries emit low process-air emissions. Most of the processes uses electrical power and rarely emit harmful compounds to environment. But air emissions from effluent treatment plant of these industries are a major concern. No significant air emissions is generated from readymade garment industries.

The sources of air emissions in shipbuilding and repair operations include blasting, painting, metal plating and surface finishing, machining and metal working and solvent cleaning and degreasing. The probable sources of emissions to air are in the form of VOCs from the shipbuilding process operations; Particulate Matter, SO2 and NO2 from utilities like boilers; and SO2, NOx, HC and CO from vehicular traffic coming in and going out from the shipyard cum Port.

The major air pollutants generated from textile mills include Suspended Particulate Matter (SPM), sulphur dioxide gas, oxide of nitrogen gas, etc. The hydrocarbons are emitted from drying ovens and from mineral oils in high-temperature drying/curing. The residues from fibre preparation also emit pollutants during heat setting processes. Carriers and solvents may be emitted during dyeing operations depending on the types of dyeing processes used and from wastewater treatment plant operations. Carriers used in batch dyeing of disperse dyes may lead to volatilisation of aqueous chemical emulsions during heat setting, drying, or curing stages. Inhalation of the dust generated where cotton fibre is converted into yarn and

110 EIA Report- Narayanganj Economic Zone fabric significantly contributes to byssinosis (an occupational lung disease). So, periodic checkups shall be done for the workers. Rotating of workers shall be done to reduce exposure levels.

OSHA and the American Conference of Governmental Industrial Hygienists (ACGIH) standards set 0.2 mg/m3 respirable cotton dust as measured by the vertical elutriator as the limit for occupational exposure to cotton dust in textile yarn manufacturing. Monitoring units for air quality must be installed and periodically checked at upstream and downstream wind flow directions and the analysis results should be within the limits as provided by the DoE.

The air pollution in jute mills is mainly due to generation of solid wastes such as dust, dirt, and short fibre. As per the publication “Ecological and economic attributes of Jute and Natural fibre for sustainable Eco- Management” by Professor Dr. A. B. M. Abdullah, the waste generated during product manufacturing process is about 5% of total jute processed. The endotoxin analysis indicates that dust zone concentrated with fungi and gramenegative bacteria is responsible for frequent / prevalent occurrence of byssinosis in workers engaged in high dust zone.

Mitigation Measures

 Provision should be made for peripheral green belt all along the EZ boundary. Green belt should have minimum of three rows of local variety of tree.  Tree species should be selected such that first inside row is of smaller height, middle row of tree is of medium height and last row of tree is of higher height so that green belt formed appears like a canopy.  Development of thick green belt and organized greens within each industrial plotsPower Generators should be provided with stacks of adequate height (higher than nearest building) to allow enough dispersion of emission.  Process emission if any should be controlled with the installation of adequate air pollution control systems  All industries should obtain clearance from DoE, Bangladesh as applicable. Air pollution control measures shall be adopted by respective industries in line with DOE permission  Air pollution monitoring should be carried out quarterly by all industries to check the air pollution level.  Preference of usage of clean fuel like LPG, low sulphur diesel should be explored  Energy conservation should be adopted by opting the alternate energy options like solar power  Odour should be managed at the site using odour suppressant and planting fragnant flowering trees.  Periodic check ups should be conducted for the workers working in the textile and jule millsto reduce exposure levels, rotate the shifts of the workers.

7.4. Impact on Noise Environment 7.4.1. Pre-construction and Construction Phase

Pre-construction phase will involve site clearance activity for development of access road and utilities. The site clearance will involve removal of vegetation and land levelling activities. Operation of different machineries and equipments for construction activities, running of heavy load traffic for construction materials transportation, and regular traffic movement may generate noise during construction period. The heavy equipment, machineries, transportation and earthworks used for the construction activities are the major sources of noise. It is envisaged that there will be an increase in traffic and thereby in traffic noise impacts on the receptors near the approach road from the transportation of equipment, construction materials. As detailed in the earlier sections, the residents in the vicinity of the site would be impacted due to the noise emissions. Table below shows the typical noise levels generated by some of the construction equipment expected to be used during the construction phase. As seen from the Table 28, the local peak

111 EIA Report- Narayanganj Economic Zone noise level for non-continuous construction activity may reach to as high as 96 dB(A), depending on the type of equipment. The impact, however, is expected to be temporary and localised.

Table 55: Noise levels generated by construction equipments (measured at 1 m distance) Equipment Noise Level (dB(A) Earth Movers Front Loaders 72-84 Backhoes 72-93 Tractors 76-96 Scrapers, Graders 80-93 Pavers 86-88 Bull dozer 86-88 Excavator 84-86 Trucks 82-94 Material Handlers Concrete Mixers 75-88 Concrete Pumps 81-83 Cranes 75-86 Winch 85-88 Stationary Generators (in canopy) 71-82 Electric Saw 81-85 Wood Planer 81-85

Noise levels will have compounding effect when multiple equipments and trucks operate at the same time. Thus the actual noise level at the site and surroundings would be much more than given in the above table. However, due to the linear shape of site the large-scale concentration of construction equipment may not happen. Thus, compounding effect may not be very high.

Mitigation Measures

The following mitigation measures will be implemented to minimize potential noise impacts during the construction phase:

 Regular maintenance of equipment such as lubricating moving parts, tightening loose parts and replacing worn out components should be conducted;  Machinery and construction equipment that may be in intermittent use should be shut down or throttled down during idle time;  Acoustic enclosure will be provided for the DG set;  Equipment known to emit noise strongly in one direction should be orientated so that the noise is directed away from nearby sensitive receptors as far as practicable;  Honking should be avoided;  Construction work should be carried out only during day time (from 8.00am to 6 pm); and  Machinery to be used should comply with the noise standards prescribed by DoE.  To deal with noise exposure by construction workers in construction site, pocket guide by OSHA is helpful.

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The following noise reduction measures are suggested in the pocket guide.

Reduce It: Reduce the noise by using the quietest equipment available. For example, choose a smaller, quieter generator.

Move It: Move the equipment farther away with the use of extension cords, additional welding leads, and air hoses. Noise levels go down as we increase our distance from a noisy object. Move the generator (example) farther away or face it in a direction that is away from where most people are working. If you are not required to be in a high noise area, move to a quieter area.

Block It: Block the noise by building temporary barriers of plywood or other on-site materials to keep the noise from reaching workers. Place a five-sided, oversized wooden box over the generator. Add fire- resistant acoustical absorbing material (foam) inside the box. If the generator sits on soil or sand, that will help absorb some of the noise.

At individual worker level, the construction contractor should be insisted to provide earmuffs to the workers exposed to high noise levels. 7.4.2. Operation Phase

After development of offsite infrastructure and economic zone, the noise levels may rise due to vehicular movement, DG set, pump sets, and industrial operations, boilers operations. Auxilliary activities like operation of water pumps, booster pumps during operation phase of economic zone will also impact the noise environment. Operations of ventillations units and fans can also add up to the noise emissions. The following mitigation measures are proposed to mitigate the noise pollution during operation phase.

Mitigation Measures

 Pumps should be fitted in close room, preferably acoustic enclosure to reduce the noise generation  Green buffer should be developed all along the project boundary. Green buffer should compose of the 2-3 rows of plants of variable height and thick canopy so as to form continuous barrier. This will help in reducing the noise level significantly.  Noise regulators must put a strong mandate and fine on vehicle operators which are not properly maintained, produce noise (silencers not proper).  All industries should obtain clearance from DoE before establishing industrial unit and should comply with all the conditions mentioned in the letter of environment clearance  All industries should install the new machiney of modern make which complies with the noise standards prescribed by DoE.  Job rotations should be practiced for workers in working at noise intensive locations to prevent prolonged exposure to high noise level as it may lead to deafness, fatigue, head ache, nausea and drowsiness. Propose PPEs muct be made cumpolsory for workers working at locations where the intensity of noise is high.  Acoustic design with sound proof glass paneling will be provided for critical operator cabins / control rooms of individual modules as well as central control facilities.  Proper greasing, periodic checkups for frictionless movements.  Honking should be prohibited within the economic zone

7.5. Impact on Water Environment 7.5.1. Pre-Construction and Construction Phase

Impacts on Ground & Surface Water ResourcesSignificant quantity of water will be required for various construction activities & domestic purpose. The water requirement will be sourced from borewells of 200-

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225 m depth proposed to be contructed onsite. Excess withdrawal of ground water may lead to depletion of aquifers. Thus, measures should be taken to minimize the water extraction by reducing water consumption and wastage. Mitigation measures are given below.

Mitigation Measures

 Water for curing can be saved by carrying out curing in early morning or late evening and covering structures with gunny bag so as the moisture can be restored for longer time.  Regular inspections at site to monitor leakages in water storage tanks  Temporary storm water drains and rain water harvesting ponds should be constructed so as to store rain water for construction activities.  Creating awareness among construction workers about the importance of water conservation  Storing the curing run-off and waste from other construction activity and using the same for sprinkling.  Regular inspections at site to monitor leakages in water storage tanks. Care should be taken that construction of embankments will not alter tidal flow  Covering the water storage tanks at site to prevent evaporation losses.  Undertake Step-Test and Pump Test before abstracting groundwater to understand the sustainable rate of groundwater withdrawl. The rate of groundwater withdrawl shall nor exceed the sustainable flow rate which have minimum impact on the groundwater table.  Tapping should be made at a different aquifer from the aquifer from where the local people have tapped for water for drinking and domestic purposes

Impact on Surface Water and Groundwater Quality The major source of wastewater generation during construction phase is from the labour camp, which will be established for project construction activity. There is a potential for contamination of surface and groundwater resources resulting from improper management of sewage.

The quality of water bodies could also be affected due to surface runoff from contaminated soil (soil contamination due to oil/ fuel spillage and leakages), particularly during monsoon season. The surface runoff carrying the loose top soil will lead to increased sedimentation in the receiving water bodies. Contamination to water bodies may also result due to oil spilling during construction activities and/or surface runoff from the construction site to the adjaccent water body. Thus measures are required to be taken to minimize the surface water pollution

Mitigation Measures  To avoid excavation activities during rains  To prevent piling up of excavated soil, raw material and construction debris at site by proper management and disposal  Minimize run-off by using sprays for curing  Maintaining appropriate flow of water sprinklers at site  Construction of storm water drains along with sedimentation tanks with sand bags as partition as barrier for direct flow of run off to river.  Collection & Reusing of curing over flow, tyre wash water etc within the site  Construction of adequate nos. of toilets and proper sanitation system for workers to prevent open defecation along the river banks/water supply lines  Construction of soak pits/septic tanks to dispose-off the domestic wastewater generated from labour camps to prevent disposal of sewage in surface water bodies. Alternatively collect labour camp sewage and connect to nearby municipal sewers.  Proper collection, management and disposal of construction and municipal waste from site to prevent mixing of the waste in run-off and entering the water bodies

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 No debris/construction material should enter the waterbody in the area  Use of licensed contractors for management and disposal of waste and sludge;  Labourers should be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets. Open defecation and random disposal of sewage will be strictly restricted;  Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages.  There should be a containment tank installed of 1.5 times the HFO storage capacity in order to prevent accidental leakage of oil (source: fuel-oil piping and storage – ICC)

Impacts of dredging BEZA has proposed to carry out landfilling with dredged material from the adjacent rivers. Total dredged material requirement is 1.4 million cubic meter (360 acres x 4000 sq meters per acre) or 2.1 million tonnes (density of loose sand = 1.442 tonnes per m3) excluding requirement for embankment. The dredged material is mostly sand except thin top layer. During the site visit, at certain places sand extraction (dredging) has been observed from the river. This material is stored on the banks of the river, which will be ultimately used as construction material.

The statistics show that 50 ship loads (80 ft x 25 ft) of sand is being transported from the confluence area to the hinter land every day. This indicates there is marked demand for sand in the hinterland. If the huge quantities of dredged sand is used for landfilling, it will deprive the needs of construction industry as well as government may loose revenue during that period. The total quantity of dredged material transported daily by these 50 ships is 30,000 tonnes of sand which is dredged per day in this region. Additionally, about 20,000 tonnes of sand needs to be dredged daily considereing 100 days of cut and fill operation. Transportation of huge quantity of dredged material would require another 30 vessels per day of same size that of existing size, cause enormous congestion in Shitalakhya River which is already experiencing heavy traffic. The dredged material will be transported by ships to nearest port. From the port the material will be transported to site by trucks. Approximately 1000 trucks would be required per day to transport the material. This traffic is impossible to control and out of proportion.

Most of this dredging is expected in adjacent Shitalakhya River. If the dredged material is polluted, it may affect the ecosystem, and fisheries activities at both dredging and dumping locations.

The possible physical impacts due to dredging on water quality are as follows:

 Resuspension of bottom sediments, thereby increasing turbidity  Dispersion from and accumulation into bottom sediment of toxic substances  Depletion of oxygen due to oxidation of organic matter  Reduced primary productivity due to decrease in the depth of the euphotic zone  Temperature alteration  Increased nutrient levels

Earlier studies on effect of dredging in the estuarine environment indicate the following:

 Impact on fisheries, due to bottom disturbances and consequent increase in turbidity  Bottom sediment disturbance: release of toxicant due to resuspension  Increase in turbidity due to agitation in dredged sites is generally short-term, hence effects are localised and transient

Another Studiy indicates that there is a marked increase in metal concentrations in the sediments of downstream region of the dredging site in a water body, due to migration of suspended sediments along the water current. On the other hand, the build-up of metal concentrations in water due to resuspension of sediments is not reported to be appreciable, except for metals which form soluble sulphides.

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The extent of impacts due to dredging activity is highly varied and site specific, depending upon a number of factors shown below:

 Method of dredging and disposal  Channel size and depth  The size, density and quality of the material  Background levels of water and sediment quality, suspended sediment and turbidity  Current direction and speed  Rate of mixing  Presence and sensitivity of animal and plant communities (including birds, sensitive benthic communities, fish and shellfish)

Mitigation Measures

The project proponent is advised to find out alternative filling material to avoid impacts due to dredging and save economic value. 7.5.2 Operation Phase

It is envisaged to install abstraction wells within the subject site to meet the water demand. The development of economic zone shall lead to the generation of process and domestic effluent. Dyeing units which are an integral part of textile units are the main source of process waste water. The waste water generally has high TDS, high BOD, COD and the color quotient of the water is also high. Effluent Treatment Plant with primary and secondary modes of treatment shall be an integral part of all the textile units the other industrial units. Domestic and cleaning waste likely to be generated from kitchens, canteens, toilets and also from the residential set-ups within the EZ for staffs shall contribute to the domestic waste water. Conventional Sewage Treatment Plant with biological mode of treatment for a particular set of industries can be installed to treat domestic waste water having high BOD, TSS concentration.

The direct discharge of the untreated process and domestic effluent waste will lead to impacts in the surface water quality. Also, it is anticipated that surface run-off may significantly increase post development of economic zone which may impact surface water quality.

Following measures should be adopted during operation phase to minimize impacts of development of Economic zone on water quality:

Mitigation Measures  Each industry should obtain consent of DoE Bangladesh before construction and operation and should comply to the conditions laid by them  The Industry should also obtain the consent of the water abstraction limit from DoE, Bangladesh.  No leachate, waste water and waste material should be stored in pervious unlined area/pond.  Each industry should treat the effluent and sewage generated by them so as to achieve zero discharge and no untreated effluent should be discharged into any water body  ETP shall be mandatory for all the industries. Every unit shall have its own ETP unit.  A water balance between the abstracted water and the water diverted for process purposes and domestic purpose shall be developed and based on the volume of the process and domestic waste, ETP and STP shall be designed.  Baseline water quality assessment shall be done. Analysis of the process waste water shall also be done and based on that (peak hours and maximum load concept basis) the ETP and STP shall be designed.  The effluenct treated process waste water shall be analysed and the analysed parameter shall be well below the Bangladesh Standard (ECR, 1997).

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 Each and every industry shall start the operation of their ETP and STP even in case the CETP doesn’t get functional. The specific design criteries that the owner of each unit has to follow strictly are:  The STP and ETP shall be overdesigned. There could be every possibility for expansion in future which the unit has to consider while they set up the area for STP and ETP construction and the volume of waste water the STP and ETP each unit can treat;  There shall be strict check of certain vital parameters like DO, pH, COD, BOD, TSS, TDS, Temperature and the presence of any metals everyday for the influent water;  DoE shall have a strict vigilance over the performace of the ETP and STP. Every month officials from DoE shall have an unannounced visit and check the influent and effluent water quality from STP and ETP;  Any deviation from the standards suggested according to ECA, 1997 shall be penalized. The degree of penalization shall be set by DoE, Bangadesh;  DoE shall set a set limit of the volume of treated water for discharge for each and every unit operating. The unit should have an electronic flow-meter connected to their effluent channel. Readings shall be recorded diligently and forwarded to DoE on a regular basis;  DoE shall also put a limit on the volume of water each unit can extract;  Process of Recycling and Re-use shall be implemented. No units shall be permitted CTO without having a concrete plan of how they are going to recycle and reuse the treated water.  Limited water shall be diverted to CETP. Even provisions shall be there to reuse and recycle the treated water from CETP. There shall be hardly ant discharge of even treated water to the water system;  DoE engineers shall approve the ETP and STP design before the unit avails the CTO.  Each industry should practice rain water harvesting to minimize the water consumption and reduce run-off from the site  Proper management of waste should be done to prevent any contact between the waste and storm water  Storm water drains should be lined to separate from effluent drains  Storm water system should be inspected & cleaned before monsoon every year  Peripheral drain shall also be lined and shall not be connected to internal storm water drainage system.  The top soil shall be preserved and used for covering the sand layer at EZ site. Vegetation turffing shall be made at the side slops of the EZ areas to prevent erosion and siltation in the river.  River water quality shall be monitored periodically  Ground water quality shall be monitored periodically.  Sludge should be dried into cakes and used as manure for green belt.  The industries within the EZ shall comply with the “Zero Discharge” clause recently introduced by DoE, Bangladesh. Proper design and application methodology shall be determined before the industrial set-up  The abstraction of groundwater shall be done at a sustainable flow rate. Step-Test and Pump-Test shall be conducted before deciding the rate of groundwater abstraction and the volume to understand the target aquifer charecteristics.  As, the continuous abstraction of groundwater, could impact the groundwater level, rainwater harvesting units within the subject site shall be constructed to recharge the aquifer especially during the 3 to 4 months of monsoons.  Practices like reverse boring shall be strictly avoided.

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7.6. Impact on Land Environment 7.6.1. Pre-construction and Construction Phase

The impacts on soil due to the project are as follows:

 Dredging and landfilling activity  Soil erosion due to vegetation clearance and excavation activities;  Topsoil degradation  Generation of waste (hazardous and non-hazardous) from site clearance, excavations, civil works and activities of construction workers (general waste and sewage); and  Possible contamination of soil due to potential spills of lubricating oil, fuel oil, concrete etc. 7.6.1.1 Demolition of dwelling structures On the project site, there are 59 dwellings, wuich include residential single family and multiple families, religious structures, etc. Most of the structures are semi-permanent structures, constructed using tin sheets. Very fiew dwellings are permanent RCC strutures. All these dwellings will be evacuated and ultimately demolished. The demolition will cause debry generation. Table below lists down the typical debris.

Table 56: Typical Debris Components Examples Wood Forming and framing wood, plywood, laminates, scraps Wall Concrete, gypsum, tin sheet, plaster Metals Pipes, rebar, steel, aluminum, copper, brass, stainless steel Plastics doors, windows, pipes Ceramic Flooring tiles, sanitary ware Roofing Concrete, Asphalt & wood stands, tile, roofing sheets, roofing fittings Rubble Asphalt, concrete, residual blocks, rock, earth Brick Bricks and decorative blocks Glass Windows, mirrors, lights Miscellaneous Carpeting, fixtures, insulation, ceramic tile

When buildings are demolished, large quantities of waste may be produced in a relatively short period of time, depending on the demolition technique used. The demolition project duration can vary depending on the technique used. The techniques that can be used are use demolishing cranes, or deconstruct the structure. In actual practice, the vast majority of demolition projects use a combination of these two basic techniques depending on the materials used in the project, the physical size of the structure, and the time allocated for the project. All the weight of a building including the concrete foundations, may be generated as demolition debris when a building is demolished.

Demolitions may produce several types of materials bonded together or contaminated with hazardous materials, such as asbestos or lead paint. The resultant debries pose enormous problem for disposal.

An attempt is made to estimate approximate quantity of the debries in the project area during demolition.

Totalnumberofunitstobedemolished :59 Area assumed for each dwelling : 500 sft Thus, total area of demolition : 29,500 sft Single family and multifamily units are assumed Total quantity of debries generated : 500 Tonnes.

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The debris consiting of RCC material may be used for landfilling after proper sizing and removing of rebar material. This may also reduce the dredging material requirement for landfilling. Tin sheets which are not spoiled may be used in R&R colony.

After demolision, the residues if properly not disposed may find way into adjacent river causing high suspended solids.

Apart from demolition of buildings, huge number of trees will also be cut to during preconstruction phase. Disposal of these debris will also pose disposal problem.

The EZ authorities/ the contractor may identify the users of these tree debries for useful purposes such as timber wood, fire wood, or any other purpose.

7.6.1.1 Soil Erosion

During the pre-construction and construction phase, the site clearance activities including clearing of vegetation, construction of the earth structures, labour camps, storage area, toilets will involve removal of top soil which will result in slope destabilization and the land will be more susceptible to soil erosion.

The soil erosion will result in the run-off of the silt to surface water impacting aquatic ecosystem of receiving water bodies with increased suspended sediment load and associated nutrients.

Most important: After landfilling, if the land is be kept for long without further development, it leads to soil erosion due to loose top soil.

7.6.1.2 Soil Compaction

During construction activities, there will be compaction of soil in the project area due to construction of the internal access roads, movement of vehicles/ construction machinery and work force movement. The soil compaction would impact the soil physical properties such as reduction in pore spaces, water infiltration rate and soil strength etc. The extent of soil compaction is primarily limited to the Project foot print area and surroundings within 100 m distance. The impact is restricted to the construction phase of the project.

7.6.1.3 Landfilling with Dredged material

The project site is located in low lying area and landfilling will be done during site development activity. About 1.4 million cubic meter filling material is required for landfilling. Generally in Bangladesh, landfilling is done with dredged material. Dredging activity may be carried out near the site location or away from site. Dredging activity will have two fold impacts - firstly as a result of the dredging process itself and secondly as a result of the landfilling of the dredged material. Impacts during dredging are given in the earlier section.

The soil quality in the dumping site may be affected if the dredged material is deposited on the banks or on low-lying areas for land reclamation. Analysis of dredged material at the upper stretch of the River, however, showed that it did not contain appreciable quantities of heavy metals or radioactive elements, which can potentially have an adverse impact on the dumping site.

In case the soil quality at dumping sites is different from the sediment from the dredging sites, the ultimate soil quality of the disposal site can be affected.

The soil used for landfilling should be free of any type of contamination and have similar characteristics as that of native soil to avoid impacts on the soil quality.

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7.6.1.4 Waste Generation

The construction waste generated onsite comprises of materials such as excavated soil, rocks, concrete, wooden pallets, steel cuttings/filings, packaging paper or plastic, wood, metals etc. Municipal domestic wastes consisting of food waste, plastic, glass, aluminum cans and waste paper will also be generated by the construction workforce and labor camp site.

The waste generated during the construction phase will also include hazardous waste such as used oil, hydraulic fluids, waste fuel, grease and waste oil containing rags. If improperly managed, solid waste could create impacts not only to land but also to local air quality, water quality, and human health. It is expected that the generation of the waste oil will be insignificant as the DG sets will be used only during the construction phase and the waste oil will be generated only during the maintenance of DG sets.

7.6.1.5 Soil Contamination

Soil contamination during the construction phase may result from filling activity, leaks and spills of oil, lubricants, or fuel from heavy equipment and wastewater. Such spills could have a long-term impact on soil quality, but are expected to be localized. The soil at project site is sandy clay. The soil strata has higher permeability, thus allowing contamination at greater depth. Storm water run-off from the contaminated area can pollute the downstream soil and water quality of adjacent rivers.

Spill control measures such as the storage and handling of chemicals and fuel in concrete areas with secondary containment will be implemented to minimize impacts in the event of a spill.

The soil characteristics of the native soil may also be changed due to import of soil for filling and levelling purpose. It is envisaged that the filling activity may impact the native soil due to spillages during transportation of soil and run-off during filling and compaction. Apart from the embedded controls to be included in project design, the following mitigation measures will reduce the negative impacts of construction activities on soil environment:

Mitigation Measures

 Stripping of topsoil should be scheduled as the last mile activity (maintain vegetation cover for as long as possible) in order to prevent the erosion (wind and water) of soil;  Care should be taken to minimize percolation of soil used for filling to adjacent rivers during filling operations. Proper embankment may be provided in the downstream areas to minimize soil percolation to rivers.  Vegetation should be planned and maintained for slope stabilization and to prevent soil erosion after construction period;  The disturbed areas and soil stock piles should be maintained moist to avoid wind erosion of soil;  The routes for movement of heavy machinery should be designated to avoid the soil compaction in other areas;  Transport vehicles and equipment should undergo regular maintenance to avoid any oil leakages; designate routes for bringing construction material and outside soil;  Construction contractor should designate the sites to be used for disposal of hazardous wastes including waste oils, solvents, paint and batteries. The Contractor should ensure that no unauthorized dumping of hazardous waste is undertaken from the site;  Fuel and other hazardous substances should be stored in areas provided with roof, impervious flooring and bund/containment wall;  For landfilling, dredging should be carried out considering above mentioned factors in dredging section and cause least impact on the environment;  The soil used for landfilling should have similar characterisctis to the native soil and free of any type of contamination.

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 Prior to dredging activity, analyse the soil sample to prevent impacts on the receiving environment as a result of mismatch in soil characteristics;  During dredging activity, physical barriers such as silt screen/ curtains should be employed to prevent the spread of suspended sediments;  Maintain the extent of the turbidity plumes close to the dredging and disposal areas to minimise impacts on marine fauna habitat;  Visually inspect for any marine life and terrestrial organisms and stop dredging activity in case of any organism in the vicinity;  Monitoring should be done continuously during dredging to observe impacts on the marine life and in case of visible impacts, stop the dredging activity;  Dredging should be carried out during day time to minimize impacts on marine life.

7.6.2 Operation Phase 7.6.2.1 Impact on Soil Quality

After development of economic zone, disposal of industrial domestic and process waste may contaminate land and soil quality of the area. The impact can be significant and long term in case of uncontrolled discharges. Improper disposal of waste (hazardous and non-hazardous waste) may degrade soil, water, air quality and ecology of the area. As per the preliminary planning, textile Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials Agro, Food and Fish processing, light engineering industries are being envasised for this EZ. These industries are anticipated to be polluting and hence discharge of the generated sludge, e-waste shall be done in a structured manner. Process dry sludge, e-waste, domestic dry sludge could be envisased as the major source of hazardous waste. All these wastes shall be segregated depending upon the source of its generation. Sludge generated from STP shall be dried using a filter-press and the dried sludge could be used as manure. There are authorized vendor for recycling E-waste in Bangladesh. E-waste generating units shall disposed their e- waste to e-waste authorized vendors. General practice followed in Bangladesh regarding the process waste is storage in a dedicated room. As the country doesn’t have a concrete rules and regulations guiding the process waste disposal, practice to design and execute a localized landfill unit could be helpful.

Mitigation Measures

 Provision shall be made for proper storage and disposal of industrial waste by receptive industries.  Provisions shall be made to segregate e-waste with rest of the wastes generated.  Alliance shall be done with e-waste recycling vendor and the segregated e-waste shall be send to the vendor for recycling purposes  A Common waste storage areas shall be designated for industrial domestic waste.  The domestic waste shall be kept away from the industrial waste. Dried domestic waste could be used as manure.  Waste should be segregated at source into hazardous and non hazardous waste. Further the waste should be segregated into recyclable and rejected waste. Recyclable waste should be sent to authorize vendors for recycling and rejected waste should be disposed off as per the norms specified by DoE for the particular waste.  Industrial waste generated should be stored on sealed surfaces and should be disposed off as per guidelines of DoE, Bangladesh.  Local environmental bodies shall be consulted for the initiation for the designing and constructing localized landfill for the disposal of process waste.  No chemical/hazardous raw material should be allowed to spill over the land and should be operated in covered systems

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 Excessive packaging should be reduced and recyclable products such as aluminum, glass, and high-density polyethylene (HDPE) are being used where applicable.  Organic waste should be resold to value addition industries or can be feeded to live stock.  Use of advanced techniques to control specific portions of the manufacturing process to reduce wastes and increase productivity.  Sludge generated in effluent treatment plant should be sold to authorized recyclers.

7.7. Impact on Biodiversity

The proposed site location has trees and vegetation. For site development and construction of access road, it is required to fell some trees and bushes. These trees and bushes provide habitat to birds, insects, reptiles and small mammals like squirrel etc. The cutting of the trees shall disturb the eco-system and the natural habitat of the organisms. Also, discharge of solid and liquid waste in rivers, shall impact the aquatic life. Therefore, proper mitigation measures should be taken to minimize the impacts on biodiversity. No infrastructure development activities shall be encouraged close to the river shore line. Sitalakhya River has been declatred as an Ecological critical zone. To minimize the impacts during the construction and the operation phase, DoE has strictly proposed no developmental activities will be permitted or allowed within 100m of the river shore line. The proposed plan is to develop green buffer zone along the first 100m from the river shore line and not to undertake any sort of developmental or infrastructure (offsite or onsite) activities. Mitigation Measures  EZ development should be planned in such a way to avoid or minimize tree cutting  Twice the nos. of trees to be fell should be planted as compensatory plantation in affected areas to minimize the impact on the eco-system  No waste shall be discharged in water bodies  The 100m buffer from the river shore line shall be maintained diligently  Infrastructure related activities shall be strictly avoided in that buffer zone of 100m along the river shore line

7.8. Impacts on Agriculture resources

The development of the EZ is envasiged on land of 340 acres. Out of 340 acres, approximately 107 acres of land is under agricultural practice. Agriculture is majorly practiced in the low land area. All the agricultural lands falling within the site boundary shall be acquired by BEZA and proper compensation based on present market rates will be provided. There could be impacts that can be envisased during the construction phase to the nearby agricultural lands. Discharge of water, dumping of construction debris etc can impact the agricultural resources and invariably production. Mitigation Measures

 There shall be dedicated place to keep the construction debris and the specific place shall not be close to any of the agricultural fields;  Construction related waste water shall not be directed towards the agricultural fields. Often the waste water from construction activities contain heavy metals and contaminants which can impact the soil quality;  If the workers want to construct kaccha temporary shelters then in that case, the shelters shall be away from agricultural land;  During the operation phase, the treated water shall not be discharged on the agricultural fields.

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7.9. Impacts on Fisheries 7.9.1 Impacts on fisheries during pre-construction and construction phase

The proposed site for EZ development is not presently being used for pisciculture purposes or for fishing purposes. The proposed area doesn’t have any lakes or ponds where in past or in present times fishing or fish culture is practised. Thus no significant impact on fisheries is anticipated due to the project development. There are residential people who do fishing from the adjacent Sitalakhya River and sell those to the local maret to earn their daily livelihood. To minimize the impacts on those people, the proposed location for relocation has also been decided along the vicinity of Sitalkhya River, hardly 3 Kms from the present location. These people can continue with their fishing activity even at the new proposed location which is southeast of Basundhara Cement Plant.

7.10. Impacts on Occupation Health and Safety

The lack of adequate mitigation measures on the health and safety of the workers will result in accidents and injuries leading to loss of life or property. It is proposed to implement the following mitigation measures to ensure safe work place for the construction labor.

Mitigation measures to be implemented are:

 The EZ owner should ensure that the contractor (make part of contractors contract) to have and occupational health and safety plan. The contractor should provide for all the workers accidental insurance and medical insurance.  The contractor should conduct daily tool box meeting for all workers to discuss potential work related hazards and other safety aspects.  The contractor should conduct training for all workers on safety and environmental hygiene at no cost to the employees.  The contractor should maintain first aid facilities for the workers and will instruct and induct all workers in health and safety matters (induction course) including construction camp rules and site agents/foremen will follow up with toolbox talks on a weekly basis. Workforce training for all workers starting on site will include safety and environmental hygiene.  Fencing on all areas of excavation greater than 1m deep and sides of temporary works should be observed.  Workers should be provided with appropriate personnel safety equipment such as safety boots, helmets, gloves, protective clothes, dust mask, goggles, and ear protection at no cost to the workers.  Reversing signals (visual and audible) should be installed on all construction vehicles and plant.  Contractor should at all-time keep the first aid kit at the construction sites.  Contractor should be responsible for evacuation injured person to the nearest medical center  Pertinent H&S trainings should be provided to all the workers with respect to hazards linked to the activities. Additionally, the workers will be informed of precautions to be taken to avoid impacts to the local community;  Monitoring of the PPE usage can be strengthened, in that, a mechanism can be adopted whereby defaulters receive a warning on non-usage and stringent actions can be taken on subsequent offences;  Maintain H&S records of occupational H&S incidents, accidents, diseases and dangerous occurrences  Ensure that PPE is available at all times at site;

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 In event of accidents, the contractor will be responsible for immediate evacuation of injured person to the nearest medical center. The contractor should bear medical and other expenses of the injured person.  Undertake daily tool box talk and proper training of the workers regarding health and safety procedures related to solar projects, PPE usage, and regulatory provisions;  The contractors should ensure H&S standards of labour camps. The labour camps will be established in the proposed site area. Additionally, the PIU team should conduct random spot checks to determine any issues related to improper waste disposal or the living conditions in these camps (i.e. presence of secure shelter and flooring, number of persons per room, number of toilets for the manpower, water availability etc.);  Strong protocols should be built as part of contractual obligations around zero tolerance of child labour or harassment of women workers and even health and safety aspects. These should also be monitored by supervision and monitoring team.

7.11. Flood Risk

The project site is abated by Shitalakhya River- South to North-West, confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna) - North East to South, Industrial and residential, facilities- North-West to North-East. Based on the stakeholder interactions, the flood level during monsoon season varies from 4 feet to 5 feet depth inside the proposed EZ area. To avoid inundation during monsoon season, minimum land filling of 0.6 m above the flood level is considered. Thus an average depth of 6 feet to 8 feet of land filling has been envisaged for the proposed EZ area. An embankment adjacent to the river is proposed to protect the site from flooding upto +3 m from NGL and minimum site filling of average 1 m from the existing NGL for the entire site area as shown in figure below. Figure 57: Embankment cross-section details

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7.12. Sanitation and Disease Vectors

Potential sanitation and impacts from disease need to be controlled by maintaining hygienic conditions in the EZ area throughout the operational phase as well during construction by implementing appropriate social and health programs for the Project. BEZA should ensure that improvements are made to site sanitation and should implement the mitigation measure below for all operational activities and also that the contractor ensures that:

 Measures to prevent malaria should be implemented by installation of proper drainage to avoid water stagnation, etc.  Standing water should not be allowed to accumulate in the drainage facilities or along the warehouse sides to prevent proliferation of mosquitoes.  Temporary and permanent drainage facilities should be designed to facilitate the rapid removal of surface water from all areas and prevent the accumulation of surface water ponds.  Malaria controls should be implemented in line with social plans for the Project. HIV/AIDS awareness and HIV-AIDS education and prevention program should be implemented in line with social plans under the social development work stream.

7.13. Impacts due to Climate Change

Bangladesh is one of the most vulnerable countries to Climate change. Dhaka, the capital city of Bangladesh is exposed to different types of climatic conditions, and climate change hazards such as cyclone, tidal surge, coastal inundation and salinity intrusion due to sea level rise, erratic rainfall, flood, river bank erosion, drought, landslide and negative impacts on agricultural production. The proposed site location is abatting Shitalakhya River and near the confluence of three rivers (Dhaleshwari, Shitalakhya and Meghna) which possess high flood risk.

Global warming as a consequent of the Climate change will most likely increase the precipitation levels in the region thereby heightening the flood risk at the proposed site location. A warmer atmosphere can hold more moisture, and globally water vapour increases by 7% for every degree centigrade of warming. The impact of these changes on global precipitation has not yet been correlated academically, but the total volume of precipitation is likely to increase by 1-2% per 0C of temperature increase.

To mitigate the risk of flooding it is proposed to provide an embankment along the periphery of the project site. 7.14. Cumulative Impacts

It is anticipated that the positive cumulative imapcts of the development of EZ will outweigh the negative impacts. After the development of proposed EZ housing Jute and Cotton mills, Textile and Readymade Garments (RMG), Warehousing, Shipbuilding, Construction materials Agro, Food and Fish processing, light engineering industries, the emissions and effluent discharge shall be within permissible. The cumulative effect of the effluent discharge of different industrial units might lead to the much deteriotation of overall air or/ and water quality in the region if the units doesn’t follow the stringent environmental norms and regulations. Most of these units are water intensive units. The permitting body from DoE shall regulate the abstraction of water very carefully. Industries shall strictly monitor their water intake and shall develop a comprehensive water balance sheet to keep a tab on the volume of water discharged from process units. The plant should have their own ETP and design of the ETP shall be based on the incoming volume of waste water and its charesteristics. The vehicular movement, boiler units, generator sets and any process associated stacks will impact the air quality of the region. Point source monitoring of the boilers and generator sets shall be periodically done and the parameters analysed shall be kept below the schedule-2 standard of ECR, 1997. If the parameter were found to exceed the standards then remedial measures like electro-precipitator, scrubber can be installed along the stacks.

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Vehichles in Bangladesh and especially in Dhaka use Compressed Natural gas as a driving fuel. CNG is a clean fuel and engines running with CNG have limited impacts on the ambient air quality. Following all the standards and protocols as forwarded by DoE, the development could have more positive cumulative impacts than weighted negative ones.

The cumulative impacts of the projects will be:

 Aid in the development of the human capital in the region as well as the infusion of the financial capital resulting in the increase in contribution to the overall growth of the GDP in the country.  Employment opportunities for the people thereby increase in standard of living of people  Economic integration of the area with the market and trade centers within and outside the districts  Upliftment of the socio-economic conditions of the local residents

7.15. Impacts on socio-economy

The project does have adverse impacts. The proposed area for EZ development have 166.01 acres of privately owned land and 59 households along with 1 CPR. The proposed site also have 2 poultry farms. Hence the development of the project does involve loss of livelihood.

Mitigation Measures

 Prior to the beginning of any construction activity the land shall be legally acquired by BEZA. All the corresponding land owners shall be compensated and the compensation shall be based on the present market rates.  The people who will suffer livelihood losses, shall be provided with a fixed amount per month based on the RSMF from BEZA.  Trainings shall be provided by BEZA delivered by experienced people so that these people get trained for the prospective opportunity during the different phases of the EZ development and even during the operational phase.

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8. Public Consultations and Disclosure

8.1 Introduction and Objectives

This section provides the stakeholder identification and analysis as well as a brief understanding of the engagement process for the project. “Stakeholder Analysis” is understood as the process of identifying the individuals or groups that are likely to affect or be affected by a proposed project, and sorting them according to their impact on the project and the impact the project will have on them. This information is then used to assess the manner in whichthe interests of the stakeholders should be addressed in the project plan, policy, program, or other action.

The stakeholders identified in the project comprise of project displaced / impacted people, project beneficiaries, government officials, especially the officials in BEZA and Upazilla office. 8.2 Methodology of Stakeholder Consultations

Different techniques of consultation with stakeholders were used during project preparation, viz., in-depth interviews, public meetings, group discussions, Individual Consultations etc. to understand the socio- economic profile of the community and the affected families, questionnaires were designed and information was collected from the individuals on one-to-one basis. The key informants during the project preparation phase included both individuals and groups vis-à-vis:  Heads and members of households likely to be affected  Groups/clusters of PAPs  Local voluntary organizations Government agencies and departments such as local revenue authority  Other project stakeholders with special focus on PAPs belonging to the vulnerable group

The strategy adopted for carrying out Focused Group Discussions was two prone i.e. to:  Disseminate information of the project and obtain the opinions and preferences of the PAPs  Involve the PAPs in decision-making.

The dissemination process and the type of information shared with the stakeholders during consultations are described below:  While undertaking inventory for the proposed area for EZ establishment, and census survey of PAHs, information dissemination focused on the proposed establishment of an EZ which could result in improved livelihood, better employment opportunities and development in the standard of living for the villagers.  Potential PAHs were consulted to inform them about the proposed development of the EZ, resultant impacts and possible socio-cultural conflict (if any) including loss of personally owned properties and relocation of CPRs.  People were requested to gather at common places which included a common point in village easily accessible by many or group of households. The FGDs were conducted at several locations within the village so as to maximize the ease of access to the local residents;. During these consultations phases, detailed discussions in local language and also in the form of pamphlets were also used to explain proposed improvement and possible social impacts in the concerned villages.

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8.3 Levels of Consultations

Public consultations in the form of local and focused group discussions were carried out during the period from 8th April till 9th May 2016. The extent of likely adverse impacts was one of the major criteria for deciding the locations of public consultations. Types of consultations done with various participants using various tools including, interviews with government officials, individual consultations, key informant interviews, focus group discussion, stakeholder consultations, etc, are presented in below table:

Table 57: Types of Consultations Level Type Key Participants Individual Local level Consultation People along the project area Individual Door to Door Personal interactions People along the project area including those that are not impacted directly Settlement Focus Group Discussion PAP, Women, marginalized people

8.4 Methodology

Different techniques of consultation with stakeholders were used during project preparation, viz., in-depth interviews, public meetings, group discussions, Individual Consultations etc. to understand the socio- economic profile of the community and the affected families, questionnaires were designed and information was collected from the individuals on one-to-one basis. The key informants during the project preparation phase included both individuals and groups vis-à-vis:  Heads and members of households likely to be affected  Groups/clusters of PAPs  Local voluntary organizations Government agencies and departments such as local revenue authority  Other project stakeholders with special focus on PAPs belonging to the vulnerable group

The strategy adopted for carrying out Focused Group Discussions was two prone i.e. to:  Disseminate information of the project and obtain the opinions and preferences of the PAPs  Involve the PAPs in decision-making.

The dissemination process and the type of information shared with the stakeholders during consultations are described below:  While undertaking inventory for the proposed area for EZ establishment, and census survey of PAHs, information dissemination focused on the proposed establishment of an EZ which could result in improved livelihood, better employment opportunities and development in the standard of living for the villagers.  Potential PAHs were consulted to inform them about the proposed development of the EZ, resultant impacts and possible socio-cultural conflict (if any) including loss of personally owned properties and relocation of CPRs.  People were requested to gather at common places which included a common point in village easily accessible by many or group of households. The FGDs were conducted at several locations within the village so as to maximize the ease of access to the local residents.  During these consultations phases, detailed discussions in local language and also in the form of pamphlets were also used to explain proposed improvement and possible social impacts in the concerned villages.

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8.5 Specific Consultations In addition to the local/village level meetings, consultations were organized at specific locations; - critical stretches along the proposed locations within and outside the proposed area for the EZ developments. At these locations, FGDs were also organized.

8.5.1 Discussions with Upazila and Union Level Officials

The officials of the Bandar Upazila office and Sonakanda Union office were also appraised about the details of the project, the location of the proposed area, Project Affected Persons (PAP), the source of their income including the challenges, the advantages and impacts the local stakeholders could face with the onset of the EZ development.

8.6 Stakeholder Analysis Matrix Analyses revealed that majority of stakeholders were supportive and showed positive interest in the project and promised to ensure good support during execution of the project. District, Upazila and Union level authorities were consulted. The details were found out during the extensive on-field survey. The stakeholder analysis for the project is presented in below table.

Table 58: Stakeholder Analysis Stakeholder Relevant Characteristics Interests in terms Influence Category Stakeholders (Social, location, of support / (H-High, M size, organizational opposition - Medium, capacity) L- Low) Government Representative of Bandar Largely positive with High Upazila office (Bandar) assurance of full and Union Office support. (Sonakanda)

Union Land Officer, Sonakanda, Bandar Positive with assurance High Sonakanda of full support. Stakeholders Nearby and adjacent Mixed social group, all Supportive Medium in the project residential settlements along the project area area of of influence influence women, elderly persons Dispersed across the Largely Supportive Medium project area of influence PAP's Residential settlements agricultural lands are Largely Supportive as High within the site area and maily towards the the project will provide eastern and the employment southern end of the opportunities. revised project site However the PAP’s also while the residential undermined their settlements are apprehensions of loss concentrated towards of livelihood, loss of the eastern side of the shelter and opinioned subject site for training needs to enable them to work in the Economic Zones

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Other External Workers working at On the approach road Largely positive as like Medium / internal Basundhara Cement which connects these the proposed EZ will stakeholders Plant, Summit Power plants and also the increase mobility, Plant and people future EZ employment staying close to these generation, and above plants all better economic integration of the area with the major market and trade centers within and outside the districts can open new employment opportunity. The integration of the area with larger major markets will also favor the existing industries.

8.7 Details of Consultations Detailed consultations in the form of Focused Group Discussions (FGDs) carried out at different locations of the project affected area, discussed issues on land acquisition, compensations for land and structures, alternative alignments, general perception about the project and suggestions from participants to mitigate adverse impacts from relocation and loss of livelihood, resettlement options CPR requirement, etc. The details of the Focused Group Discussions are presented in below table.

Information collected during consultation has been shared with environmental and technical team. Suggestion obtained from people and their representatives have been analyzed based on technical and economic feasibility. Wherever possible, PAPs suggestion have been incorporated in the final design.

Table 59: Details of Consultation Issues Raised Suggestion form BEZA’s response s t Participants n n a o e i p t t i a a c i c D t o r L a P

The people have built their Adequate livelihood 1- Project information houses on private support and income shall be shared “Bondobostho Land” and restoration to the regularly and e

g are practicing poultry, affected persons even if transparently a l

l agriculture etc which serves the person is a non- 2- Provision of income i

V as the source of income for titleholder restoration plan and

i 6 r

1 most of the households. Every person shall be skill development a 0 2 w Since the location is abutted eligible for training to the PAP’s. / 0 h 3 1 s

0 by Sitalakhya and Meghna compensation. The value 3. Payment of the e / l 6 a river, most of the people of the compensation compensation shall be 2 h catches fishes and earn their shall depend on many made before the D

r livelihood. These people factors and it will be commencement of the a

h have been practicing enumerated based on the pre-construction phase C agriculture, fishing etc and RSMF, 2015 by BEZA. of the project have not been imparted training in alternate domain.

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The development of the EZ over this Khas land and private “Bondobostho Land” will affect the source of livelihood and the income restoration will be challenging without skill development to work in alternate work streams. How much will be the compensation to each of these non-titleholders and how it will be evaluated?  Development of the EZ  Adequate relocation 1. Design shall be would also result in for affected families adjusted to minimize the physical displacement who are losing impact for 59 squatters. The residents structures 2. Payments of the alternate relocation  In most probable compensation shall be options for the situation, the area made on the basis of the homesteads needs to be for resettlement resettlement social in the near-by vicinity shall fall closer to the framework of BEZA  There shouldn’t be any location where (RSMF, 2015). delay in compensation presently they are 3. Provision of adequate for their lost assets staying. This will also notice period shall be  Social issues (Health, minimize the extent included in LAP sanitation, Employment of impacts as 4. Provision for activities like fishing, employment

i and Poverty and etc.) r opportunities for the a working in an

w agricultural field as a PAPs; h s 5. Relocation assistance e daily wage laborer l

a won’t get much shall be provided for h

D non-titleholders as well

affected . 6 r 1

a by identifying an 0  Expeditious h 2

/ alternate homesteads. C payment of the 4

3 1 f 0 The land that will be o

/ compensation

0 n allotted shall not be very 3 (before the o 2 i t beginning of the pre- far away from the place r o construction they are residing P

l presently.

a activities) r

t 6. As a measure to n

e reduce unethical C practices during the construction strong protocols will be built as part of contractual obligations around zero tolerance of child labour or harassment of women workers and even health and safety aspects. These will also be monitored by supervision and monitoring team.

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 People are sentimentally  It is well understood 1. The area demarcated attached with this area as that since people are for the EZ has been their forefathers have staying here from redesigned to minimize been staying here from ages, sentimental the resettlement and ages. So they requested attachment with this land acquisition. BEZA’s to initiate the area and the houses priority is to minimize developmental activities are expected. The the resettlement costs on pieces of land which planning shall be 2. Training shall be are under the made keeping in provided irrespective jurisdiction of mind minimum from the background the government or where adverse impact person comes from. All there are no residential  The local people as the members shall have settlements well as people from equal rights to enroll  They will show full adjacent villages themselves and to get support for this EZ if the shall be provided trained development does not with necessary 3. Safety and security demand their trainings. They shall will be ensured. Better j

n resettlement from that be enrolled into high luminosity lights all a

g area different training around and within the n

a camps in which they EZ developmental area y  The attendees enquired a 6

1 with male and female r how the EZ will utilize shall be made 0 a

2 patrolling police shall be

N competent enough to

/ the pool of local people 5

, 5 2 j ensured 0 as very few of them have be skillfull to work n / a 4 the desired and the for the EZ g 0

n required training development; a d

a  People seem to be  Safety and security a worried about the safety should be there on M and security especially the top most priority. for women with the onset Already it’s been of the EZ activities as the observed that the development shall also area has dense attract more people from population. With the adjacent districts and onset of upazilas development activities, migration or influx of people from adjacent villages, upazillas and districts will definitely go up. This will demand necessary and proactive safety and security measures.  Whether the industrial  Trainings which 1. Employment opportunities for the set-up at the Economic should include M

Zone proposed shall classroom lecture affected youths shall be j

n provide them with sessions from experts provided on a priority a

g employment and on-field hands on basis. a n e 6 o 1 r opportunities experience. The skill 2. Interest specific d 0 a

a 2 training should focus trainings shall be

o  Since the opportunities / 5 M 5 1 d provided to all the e 0 will require specific on soft skills n / h o 4 t development, youths affected by the trainings, will they be h 0 n K i community-oriented development of this provided with trainings h

t so that they become courses, project u

o competent polytechnical 3. The training modules Y  Will there be any courses, craftsman will vary based on the employment training (for semi- requirement and the

132 EIA Report- Narayanganj Economic Zone

opportunity during the skilled interest of the construction phase opportunities). The stakeholders.  Priority for local courses should also population be holistic.  The training system should lead to trained young people in employable skills who are open to immediate employment opportunities.  The project affected youths shall be prioritized for employment opportunities  PAPs shall get the first  The affected people 1. Lists of affected priority for any kind of shall be provided the people will be populated an opportunity first and the utmost during the RAP  The design for the EZ priority for providing implementation and the development shall be any kind of an affected people will be done in a way that should opportunity be its prioritized for minimize the adverse compensation, job employment social impacts etc opportunities.

r  Trainings shall be 2. Compensation for

e  The PAPs and the PAHs c

i open to all. Well non-titleholders will

f shall be compensated f also be provided for the O based on the current renowned experts

d market rates of the land shall be requested to relocation assistance. n a

6 and structures come for few days to L 1

0 C  Compensation shall be share their 2 A /

3

3 granted before the experience. The class a l 0 i / room lectures shall

z commencement of 2 a 2 be coupled with on- p construction U

field trainings r

a  Compensations for d

n trees, land, a

B structures for privately owners shall be provided based on the market rates and the same shall be reimbursed before any kind of an activity begins at the proposed land  Employment  People whose lands and 1. Employment

e opportunities within the houses are getting opportunities h t EZ affected should be commensurate with the n i  Provisions for the safety of provided with skill of the PAP’s will be o

p 6

l provided. 1 the residents during the employment o 0 k 2 e construction period opportunities 2. The safety standards t / 0 o i 1 4 r will be made part of the S  Provide

0  Provision of residential P /

4 contract of the agency n quarters for the workforce accommodations for 1 a

y  Possibility of sexual employees and their executing the a r harassment of women family members within construction work. h s employed in the EZ and walking distance of the A also of the women in the EZ.

133 EIA Report- Narayanganj Economic Zone

vicinity of the project due  Ensure that the 3. Labor camps will be to the influx of migrant residential areas in the provided for population vicinity don’t face construction workforce. safety issues during the 4. There will be zero construction. tolerance on the sexual  Ensure strict code of harassment and also conduct for the child abuse. The same contractor to prevent will be incorporated as sexual harassment and part of the contract of child abuse. the agency executing the works at the site. Further tightened security will be provided to mitigate the cases of sexual harassment.  The expected  The Union Office 1. The local government commencement of extended full support bodies and the PAPs operation of the EZ for this project. shall be timely informed  The access road for the  Priority for about the project proposed EZ employment should be developments  The EZ should be even for the people 2. Employment developed keeping in mind residing in the affected opportunities the opportunities for local unions. commensurate with the people staying in these  People who are affected skill of the local villagers a

d Union shall be well informed will be provided. n

a  As the construction work in advance about the 3. Provision of the k

a security will be of

6 might be undertaken next phases of the n 1 o 0 during the night, the developments. The outmost significance for S 2

, / the EZ. Round the clock 5 e 4 security measures for local government c 0

i security guard will be /

f women during night shift bodies and the PAPs 2 f

2 provided for the EZ. O should be ensured. shall be informed well

n before the o i

n commencement of the

U land acquisition.  The authorities should be updated on the status of the development of the EZ.  Specially appointed night guards should be ensured for the security .  What could be likely  Since the existing 1. As suggested, officials

t impacts on the current approach road will be from EZ shall keep a n

e industrial setup, if any used by the EZ, close tab on the extent of

m appropriate impacts on air and

e  Since the approach road C shall be shared by the EZ maintenance of the water. The EMP which a r and power plant like road should also be shall be developed with a h 6

1 Summit Power Plant and ensured the EIA, shall be d 0 t n

2 followed and n cement manufacturing  The training programs u / 7 a s 3 l implemented diligently

a plant like Basundhara should be open for all. 0 P / B 1 Cement Plant, will EZ Workers from local jute 2. Trainings programs 3 o t authorities look after the and rice mills and even shall be open to all. e s maintenance of the same from Summit Power Workers from the o l

c nearby area shall be  Will the workers working Plant, Basundhara a

e at Summit, Basundhara or Cement Plant, the provided equal r

A in some local jute and rice established firms opportunities for the mill get an equal nearby, should also get training programs

134 EIA Report- Narayanganj Economic Zone

opportunity in the training equal opportunity to programs organized by EZ enroll himself/herself  Will the EZ take sufficient under the training steps in minimizing the air programs and water impacts as these  EZ should have a well- plants are also within the documented and same area of 885 acres and applicable EMP for is immediately west of the them to minimize the presently proposed area impacts on air and for development. Any water impact on air or water can also adversely affect the working environment of of so many shops, restaurants and also for the cement plant and power plant towards the western corner of the site area of 885 acres

8.8 Consultation Outcomes

Although the stakeholders were enthusiastic for the proposed project, they also expressed apprehensions on the compensation that will be provided due to the private land acquisition and the timelines for the provision of the compensation. The stakeholders expressed that the development of the Economic Zone will bring social and economic development in the region providing permanent source of income for the PAPs and also to other nearby residential settlements. There is paucity of employment opportunities and health facilities in the region and villagers tend to travel long distances to Dhaka for better medical facilities which is affecting overall social and economic development. Agriculture is the main economic activity in the project area. The land owners were apprehensive regarding the acquisition of their owned property which will invariably cause loss of their source of livelihood. The owners of Bandobastho land were inquisitive of the proposed plan, land acquisition process, whether proper compensation will be provided and whether local residents whose agricultural lands will be impacted be provided any alternative means of employment. The stakeholders sought that the payment of compensation and other rehabilitation measures be completed before the start of any work. They also expressed their desire to hold consultations across the project lifecycle and not just at the initiation phase.

The community perceives that the project will help in increasing better connectivity, promote better and sustained employment opportunities, better service facilities, and better conveyance. Apprehensions raised by the community include loss of agricultural lands, loss of house and settlement options for few people putting up within the site area, amount and time for the compensations, factors which will determine the compensation, if resettlement happens what would be the likely location. The likely outcome from the FGDs related with the compensations came out to be compensation should be paid at market rate and before the beginning of the pre-construction phase of the project.

Further, the analysis of the key positive impacts, apprehensions and perceived negative impacts and the suggestions/recommendations as documented during stakeholder consultations are detailed in below table.

Table 60: Positive Impacts perceived by the Stakeholders Positive impacts perceived by the stakeholders

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 Increase in direct and indirect employment opportunities for both the genders  Provision of enhanced basic amenities  Facilitate improved access to market centers, educational institutions, healthcare facilities, and offices located in Narayanganj districts amd more especially in the Bandar and Sonargaon upazillas.  The cumulative positive impacts of the project will result in increased mobility, employment generation, and above all better economic integration of the area with the major market and trade centers within and outside the districts

The negative impacts perceived by the stakeholders are provided in below table.

Table 61: Negative Impacts perceived by the Stakeholders Negative impacts perceived by the stakeholders

 Loss of primary source of livelihood from the fishing and poultry business

 The industrial developments in the EZ might impact the quality of the Sitalakhya River water. Sitalakhya River is one of the Ecologically Critical Area (ECA). Hence, the stakeholders expressed their apprehensions regarding the degradation of the water qualities  They expressed their concerns regarding the water demand of a textile plant. Water demand of a textile unit is high. If they start to abstract water from groundwater, because of prolonged abstraction, the water table could fall down resulting in crisis of water requirement for drinking or for other less water intensive processes.

Table 62: Stakeholder Consultations Multiple stakeholder consultations and FGDs undertaken as part of the project

Focused Group Discussions (FGDs) being conducted with Char Dhaleshwari (the affected area)

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FGDs conducted with the youth at Madanganj, Narayanganj

FGDs conducted at centre part of Char Dhaleshwari (the affected area)

Focused Group Discussions being conducted with Women at Shanti Colony

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Stakeholder Discussion with Women Welfare Association member, social expert from BEZA and a local leader at Shanti Colony

Focused Group Discussions close to Basundhara Cement Plant gate

Foccused Group Discussions with project affected people

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Focused Group Discussions at Shanti Shanti Colony, Narayanganj

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9. Environmental Management and Monitoring Indicators

9.1. Introduction

This section outlines the suggestive mitigation measures, monitoring and management responsibilities during the construction, and operational phases of the project.

The purpose of EMP is to:

 List all suggested mitigation measures and control technologies, safeguards identified on generic understanding of the impacts;  Provide an institutional mechanism with well-defined roles and responsibilities for ensuring that measures identified in EIA designed to mitigate potentially adverse impacts, are implemented;  Provide project monitoring program for effective implementation of the mitigation measures and ascertain efficacy of the environmental management and risk control systems in place; and  Assist in ensuring compliance with all relevant legislations at local, state and national level for the Project.

The EMP will reduce adverse environmental impacts and help BEZA in complying with environmental standards and regulations of the Department of Environment, Bangladesh.

9.2. Mitigation Plan 9.2.1 Preconstruction Operations

Trees lost during land clearance: There are many trees in the site area. BEZA should make lay out plan such that cutting of maximum number of trees is avoided. To compensate the cutting of trees, plantation activity shall be planned. The plantation should be either equivalent or more than the number of trees cut in the site (BEZA needs to enumerate trees before land clearance activity). The types of trees to be planted should be similar trees which are existing on the site at present. The tree plantation should be followed by maintaining for at least 3 years.

Disposal of debries resulting from tree cutting will also pose problem. BEZA has to obtain permission to fell trees from appropriate authorities. The contractor has to auction the felled trees and clear the debris.

Cut and fill operations: As mentioned earlier BEZA has proposed to carry out landfilling with dredged material from the adjacent rivers. Since sand is used in construction industry and has economic value, BEZA should carry out a cost benefit analysis between dredged material and outside filling material before finalising on dredged material.

In case of the dredged material is used for filling, ships will carry the dredged material to the site area. In any case, the following general measures may be adopted:  In both cases, shortest possible route should be selected for transporting the material and densely populated settlements may be bypassed as far as practicable.  If the material is dusty the containers should be covered  The trucks used for transportation should meet exhaust (Schedule 6 – ‘Standards for Emission from Motor’ of The Environment Conservation Rules 1997 (Amended 2002); and noise emission standards

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as per Schedule 5 – ‘Standards for sound originating from Motor Vehicles or Mechanised Vessels’ of The Environment Conservation Rules 1997 (Amended 2002).  To avoid fugitive dust, water may be sprayed at the places where vehicles are moving

The exposed soil after cut and fill operation in the site may pose soil erosion danger. The run off through exposed soil may increase suspended solid levels in adjacent Naf River. The cut surface which is not covered with construction is expected to be naturally stabilised over time. However, to reduce short term impacts, hard grass may be grown on the cut surfaces.

9.2.2 Construction Activity

The following are the major construction activities:

 Construction of embankment along the sea  Construction of administrative building  Bore holes and pumping station  Construction of power lines and substation 9.2.2.1 Air Environment

Major sources of air and noise pollution are already mentioned in Impact Assessment Section. The above activities, vehicles transporting men and materials to and from construction sites, and movement of construction equipment will cause gaseous emissions which include PM10, PM2.5, CO, HC, NOx, and lead/ benzene.

To mitigate the foreseen impacts, BEZA will ensure through construction contractors, as well as sub- contractors, execute construction activities in accordance with environmental management plan. Furthermore, such impacts would be perceived during only construction period which is temporary. Having implemented the EMP during the project construction and being supervised by BEZA/ contractor personnel, would minimise the emissions.

These impacts can be minimised by proper planning and by adopting simple steps. The fugitive dust emission can be minimised by spraying water. BEZA should insist the construction contractor to use standard equipment which meet exhaust and noise standards (Schedule 5 and 6 of The Environment Conservation Rules 1997, amended 2002); generator (DG set) exhaust and noise standards; and other construction equipment standards such as US Federal Highway Administration Standards or any relevant standards. For trucks and other vehicles, insist truck operators who are operating on access roads and also entering EZ to carry out regular maintenance and engine tuning. Insist the drivers to show truck servicing records at the entry gate. Take appropriate action if the vehicle is not maintained reasonably long time. 9.2.2.2 Noise Environment

The potential for construction noise impact varies by location and land use. Rural and residential areas surround the present construction sites. Noise impact from nighttime construction would be much more extensive, which emphasizes the importance of avoiding nighttime construction which is noise generating near residential areas. Thus, noise generating operations should be planned only during day time.

To deal with noise exposure by construction workers in construction site, pocket guide by OSHA is helpful. The following noise reduction measures are suggested in the pocket guide. Reduce It: Reduce the noise by using the quietest equipment available. For example, choose a smaller, quieter generator.

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Move It: Move the equipment farther away with the use of extension cords, additional welding leads, and air hoses. Noise levels go down as we increase our distance from a noisy object. Move the generator (example) farther away or face it in a direction that is away from where most people are working. If you are not required to be in a high noise area, move to a quieter area. Block It: Block the noise by building temporary barriers of plywood or other on-site materials to keep the noise from reaching workers. Place a five-sided, oversized wooden box over the generator. Add fire- resistant acoustical absorbing material (foam) inside the box. If the generator sits on soil or sand, that will help absorb some of the noise.

The following are the Standards for Sound Originating from Motor vehicles or further measures to Mechanised Vessels – Schedule 5 of The Environment reduce noise exposure. Proper maintenance of Conservation Rules 1997 equipment and tools can result in lower noise Motor vehicles (all types) 85 dB(A) As measured at a distance of 7.5 mtrs from exhaust pipe levels. Changing seals, 100 dB (A) As measured at a distance of 0.5 mtrs lubricating parts, using from exhaust pipe sharp blades and bits, Mechanised Vessels 85 dB(A) As measured at a distance of 7.5 mtrs installing mufflers, and from vessel which is not in motion, not loaded and is at two thirds of its replacing faulty or worn maximum rotating speed equipment or parts can 100 dB (A) As measured at a distance of 7.5 mtrs reduce the noise levels from vessel which is in the same significantly on the job site.

At individual worker level, the construction contractor should be insisted to provide earmuffs to the workers exposed to high noise levels.

The construction of access road east of Basundhara Cement Plant has been proposed. The impacts associated with construction of access road, boundary wall and administration building along with proposed mitigation measures are given below. No impacts are anticipated during operation phase. The Contractor shall carry out all mitigation and enhancement measures (including those related to mitigation of air/noise/water pollution; drainage/traffic congestion) as specified in the EMP tabulated below.

Table 63: Environmental Impacts and Mitigation Plan for constructiomn of access road, Boundary Wall, embankment and Administration Building

Impact Mitigation Measures

Removal of  When clearing the site, care shall be taken to keep vegetation clearing at a minimum Vegetation  Removal of as little vegetation as possible during the development and re-vegetation of bare areas after the project. Setting up of  The construction camps should be at least 500 m distance from habitations from the construction nearest settlements to avoid conflicts and stress over the infrastructure facilities with the camps/labour local community. camps  Location for stockyards for construction materials will be identified at least 1 km from water sources  The living accommodation and ancillary facilities for labour shall be erected and maintained to standards and scales approved by the resident engineer  All sites used for camps will be adequately drained. There should not be any risk of periodic flooding, nor located within 300 feet of pools, sink holes or other surface collections of water  The camps will be located such that the drainage from and through the camps will not endanger any domestic or public water supply

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 All sites will be graded, ditched and rendered free from depressions such that water may get stagnant and become a nuisance  Construction camps shall be provided with sanitary latrines (1 per 25 pax), bathing facility and urinals.  Sanitary latrines shall be under cover and so partitioned off as to secure privacy, and shall have a proper door and fastenings  Adequate and suitable facilities for washing clothes and utensils shall be provided and maintained for the use of contract labour employed therein.  Sewerage drains will be provided for the flow of used water outside the camp.  Drains and ditches will be treated with bleaching powder on a regular basis.  The sewage system for the camp will be properly designed, built and operated so that no health hazard occurs and no pollution to the air, ground or adjacent watercourses takes place.  Clean potable drinking water facility should be provided at the site and the water quality should be monitored regularly  Crèche facility should be provided for children if female workers are employed  First aid facilities should be made available at construction camp. First aid box should contain small, medium and large sized sterilized dressings, sterilized burns dressings, 2 % alcoholic solution of iodine, bottle containing salvolatile, snakebite lancet, , bottle of potassium permanganate crystals, scissors, Ointment for burns & surgical antiseptic solution  1 first aid box should be available per 50 labour  A person trained in first-aid treatment should be made in charge who will always be readily available during emergency  A suitable motor transport shall be kept readily available to carry injured or ill person to the nearest hospital. Landfilling  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in downwind direction of the identified sites for getting landfilling material.  The soil used for landfilling should have similar characterisctis to the native soil and free of any type of contamination. In case of dredging activity for landfilling purposes:

 Dredging should not impact natural drainage courses  Dredging sites should be located away from sensitive locations  Permission from concerned local body should be taken before finalizing the location  Magnitude and frequency of dredging activity should be monitored to avoid impacts on the natural drainage 

Soil Erosion and  Contractor should plan the activities so that no naked / loose earth surface is left out before Sedimentation the onset of monsoon. control  Top soil along the road side should be stripped and kept under covered shed for plantation  After the construction activity is over, top soil will be utilized for landscaping activity.  To avoid soil compaction along the transportation routes, only identified haul roads would be used for transportation.  Turfing of low embankments and plantation of grasses and shrubs should be done in slope stabilization.  Soil erosion checking measures as the formation of sediment basins, slope drains, etc, should be carried out.  Disposal of Debris  Waste from construction camp should be segregated at site. Food/wet waste should be and any waste composted in pit at the site, recyclable should be send to recyclers if any and rejected waste generated should be disposed regularly through responsible agency in the area  Dustbins should be provided at the site and construction camps to prevent littering of waste  Storage area of minimum 2 days should be provided at construction camp for storage of the waste generated from labour camps  Construction debris should also be segregated at the site. This debris should be used for filling to the extent possible. Recyclable waste should be sold in the local markets and reject waste should be sent to the identified debris disposal site  All arrangement for transportation during construction including provision, maintenance, dismantling and clearing debris, where necessary will be considered incidental.  Construction debris should be stored under covered sheds on paved surfaces to prevent leaching

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 Utmost care shall be taken to ensure safe collection, transport and disposal of construction waste and debris. Dust Generation  Vehicles delivering materials should be covered with tarpaulin to reduce spills and dust blowing off the load.  Compaction of prepared site to re-strain the fugitive emissions.  Water should be sprayed in the cement and earth mixing sites as well as after compaction.  In high dust areas, workers should be provided and encouraged to use masks.  Regular maintenance, servicing of the vehicles and periodic emission check for equipment and machinery would be carried out in conformity with Schedule 6 – ‘Standards for Emission from Motor’ of The Environment Conservation Rules 1997 (Amended 2002);  Water will be sprayed on the haul road.  All the vehicles entering the project site will be checked for Pollution-Under-Control Certificates.  Air quality monitoring to be carried out during construction phase to check the pollutants level in the air Procurement &  Specifications of crushers, hot mix plants and batching plants, other Construction Setting up of Vehicles, Equipment and Machinery to be procured should comply to the DoE Standards/ Crushers, Hot- norms mix plants, other  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in Vehicles, downwind direction of the identified plant site Equipment and  Aadequate stack height and emission control devices such as bag house filters, cyclone Machinery separators, water scrubbers etc., should be attached  Impervious platform for storage of bituminous and other liquid hazardous chemical  Pollution control measures for Diesel Generator (DG) set i.e. stack height, acoustic enclosure etc.  Provision of readily available first aid kit, fire fighting equipments at the plant site at appropriate location to respond in case of accident.  Periodical monitoring of air quality and noise levels as per conditions stipulated under the statutory clearance from DoE. Whenever the emission exceeds the permissible level the plants should be stopped and necessary repairing works of faults should be done to bring down the emission levels Contamination of  Impervious platform and oil and grease trap for collection of spillage from construction soil equipment vehicle maintenance platform will be appropriately provided at construction camp, servicing area and liquid fuel and lubes at storage areas.  Proper management of waste from labour camps and construction site  Proper disposal of wastewater generated from labour camp and construction site Contamination of  Car washing / workshops near water bodies will be avoided. surface & ground  Avoid excavation during monsoon season water  Loosened soil will be stabilized by Contractor through landscaping and developing vegetation, wherever possible, once construction activity is completed at any site.  Sanitation facility with septic tank followed by soak pit will be developed. Common toilets will be constructed on site during construction phase and the waste water would be channelized to the septic tanks and soak pits in order to prevent waste water to enter into the water bodies.  Provision of oil & grease traps upstream of storm water drains  Surface run off due to construction activity will not be discharged in open without treatment. Loss of water  No excavation from the bund of the water bodies. bodies/ surface /  No earth will be excavated for development of any off-site facility ground  No debris disposal near any water body.  Prior written permission from authorities is required for use of water for construction activity.  Construction labours to be restricted from polluting the source or misusing the source.  Labour camps will be located away from water bodies. Drainage and  The Contractor will always clear all the cross drainage structures and natural drainage runoff before onset of monsoon in order to keep all drainage unblocked Earth, stones, wastes and spoils will be properly disposed off, to avoid blockage of any drainage channel.  All necessary precautions will be taken to construct temporary or permanent devices to prevent inundation or ponding. Noise from  Construction activities would be carried out in the daytime only. Vehicles, Plants  The construction equipment would be provided with adequate noise control measures and Equipment and should comply with the noise standards as prescribed by DoE

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 Regular maintenance of vehicles and equipment would be carried out and corrective action taken in case of any deviation.  Ear muff/ear plug shall be given to the workers working around or operating plant and machinery emitting high noise levels.  DG sets if installed should be provided with acoustic enclosures  Labour working in noise prone area should be provided with ear plugs and job rotation should be practiced to prevent the prolonged exposure of any workers to high noise levels Loss or damage to  Vegetation will be removed from the construction zone before commencement of vegetation construction. All works will be carried out such that the damage or disruption to flora other that those identified for cutting is minimum.  Only ground cover/shrubs that impinge directly on the permanent works or necessary temporary works will be removed with prior approval from the Environmental Expert.  Trees identified under the project will be cut only after receiving clearance from the Forest Department  Vegetation only with girth of over 30 cm measured at a height of 1.0 m above the ground will be considered as trees and shall be compensated.  Compensatory plantation should be carried out in the ratio of 1:2 minimum

Loss, damage or  Construction workers will be directed not to disrupt or damage the fauna. disruption to  Construction vehicles will run along specified access to avoid accidents to flora and fauna. fauna Accidents  Safety officer should be appointed at site to ensure all the safety guidelines are being followed at site  Cautionary guidance should be provided at site to aware people about the associated risk with the area. Entry to the fuel storage room or machinery operation room should be restricted only to authorized trainer personnel  All Accidents shall be reported immediately and incident analysis, preventive measures shall be implemented. Clearing of  Contractors shall prepare site restoration plans. The plans shall be implemented prior to Construction of demobilization. Camps &  On completion of works, all temporary structures shall be cleared, all rubbish burnt, Restoration excreta or other disposal pits or trenches filled in and sealed and the site left clean and tidy. Occupational  All construction worker should wear PPEs including safety jacket, helmet, gloves, gum Health & Safety boots, ear plugs, mask while working at the site Plan  Workers should be made aware about the health issues related with open defecation  Training to workers should be provided for handling the construction equipment and machinery  Training to the workers should be provided to handle the emergency situations like fire, floods etc.  First aid facility and sufficient nos. of trained personnel should be available at all the time at construction camp  Cautionary signage and notice should be displayed in local language and English at the required places like fuel storage area so that hazards can be avoided. A security guard should be deputed in these areas and entry should be restricted  A register of all toxic chemicals delivered to the site shall be kept and maintained up to date. The register shall include the trade name, physical properties and characteristics, chemical ingredients, health and safety hazard information, safe handling and storage procedures, and emergency and first aid procedures for the product. Disaster Precaution will be taken to prevent danger of the workers and the public from fire, flood, Management drowning, etc. All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

9.2.3 Mitigation Plan for Power Supply

Laying of electrical transmission may involve various environmental and social issues. Mitigation Plan has been prepared addressing all the potential issues. Transmission line construction impacts can be minimized by the following precautions to be taken during construction of transmission line:  Proper back filling of debris at the completed foundation locations to enable cultivation by farmers  Efforts to reduce/minimize tree cutting  Assessment of crop loss and proper crop loss compensation

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 Ensuring safety of workers while constructing towers, identifying nearby medical facilities for emergency situations Along with the above general mitigation methods mentioned above would help in minimising construction period impacts of power line. 9.2.4 Biological Environment/ Greenbelt Development

Development of a greenbelt/tree plantation in the buffer zone along the river shore line will be strictly mandatory and green coverings along the internal roads will be beneficial. The tree plantation will have the following objectives:  restoration of green cover lost due to tree felling and shrub cutting during land clearance activities  restoration/preservation of genetic diversity  attenuation of noise pollution from EZ to surroundings  creation of aesthetic environment

At least three rows of trees may be retained along the boundary. New trees can be planted to make up the gaps devoid of trees.

The selection of trees and plants for greenbelt/tree plantation should be those which could grow in the existing agro climatic conditions. They should be able to survive in the local soil conditions.

Based on the above considerations and also due to loss of trees on the site, the plant species should be native (especially those which are cut from the site and for road widening) in nature. The selected plant species would need minimum level of maintenance including fertilisation and other soil amelioration.

Apart from trees, the shrubs removed from the site, and other herbaceous species may also be planted in between the trees along the boundary wall. This will act as green cover, prevent soil erosion by increasing the binding capacity of the soil, and importantly act as noise barrier together with trees.

Tree plantation also need to be taken up along the roads such as approach road to the EZ, internal road reaching administration building, on the vacant land of administration building, etc. Care should be taken that mangroves adjacent to the site location should not be impacted or cut.

9.2.5 Emergency Preparedness Plan (Contingency Plan)

In order to be in a state of readiness to face adverse effects of accidents, an emergency preparedness plan is required to be prepared which includes on-site and off-site emergency plan by the individual industry and industrial estate. BEZA is committed to develop an emergency preparedness plan in consultation with district authorities and industry association. The Emergency Preparedness Plan will have the following minimal components:

 Accidents preventions procedures/ measures  Fire prevention planning and measures  Fire water storage and foam system  Accident/emergency response planning procedure  Grievance redressal mechanism  Emergency control centre  Emergency information system with role & responsibility and command structure  Recovery procedure  Assessment of damages and rectification  Evaluation of functioning of disaster management plan  Accident investigation

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 Clean-up and restoration

9.2.6 Post Project Monitoring Plan

To monitor the extent of environmental impact of the proposed EZ and proposed industries, it is advised to monitor the ambient environmental quality around the project location periodically. This section describes the environmental quality monitoring detailing number and location of sampling stations, parameters to be monitored, frequency of sampling, etc. The EZ authorities has to submit all the monitoring results to DOE, Bangladesh.

9.2.6.1 Micrometerology

The nearest meteorological station is located at Dhaka, thus, it is advised to monitor the alteration of meteorological conditions in the area around EZ location, an automatic weather station for monitoring wind speed and direction, temperature, rainfall, and relative humidity will be installed within EZ premises.

9.2.6.2 Air Quality

Air quality monitoring includes ambient air quality monitoring and truck exhaust emission monitoring. The following are the details.

Two ambient air quality monitoring stations will be established at and around EZ site depending on the predominant wind directions to assess the change in ambient air quality over the time. Out of these, one sampling place will be at EZ and one will be decided based on predominant wind direction. The EZ authorities will also interact with DOE while deciding the exact monitoring locations.

The parameters to be monitored are SPM, PM10, PM2.5, SO2, NOX, CO and hydrocarbons. The frequency of sampling is once a month, with 24 hours sampling. The EZ Authority is also advised to carry out monitoring of truck exhaust emissions of SPM, SO2, NOX, and CO in regular intervals.

9.2.6.3 Noice Quality

It is proposed to measure noise at 10 locations day and night. Noise monitoring could be done once a month. Portable noise meters could be used for the purpose. All the air quality monitoring locations will be covered for noise monitoring.

9.2.6.4 Surface Water

Water quality should be monitored once a month at upstream and downstream locations to the EZ in the sea.

Methods of analysis and parameters to be analysed would be according to standard methods. Parameters to be monitored should be based on Bangladesh standards for surface water quality. The main water quality parameters to be monitored are:Temperature, pH, colour, odour, DO, BOD, COD, EC, TDS, TSS, Total Coliform, Fecal Coliform, Oil and grease, ammonia, nitrates, alkalinity, sulphate, phosphate, TKN, Iron, and trace metals such as Chromium, Lead, Cadmium and Mercury.

The parameters, which could be analysed in the EZ laboratories, should be analysed there. Samples could be sent to other laboratories like DOE laboratory or any Research Laboratory for analysing remaining parameters.

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Parameters such as oil and grease, TSS, COD, BOD will be measured manually as per Standard Methods, whereas pH, and temperature will be monitored with appropriate meters. The results of the monitoring will be sent to DOE periodically.

9.2.6.5 Groundwater

One groundwater sample shall be analysed in the project area. Frequency of monitoring would be monthly and parameters to be monitored are as per Bangladesh drinking water quality standards. The main parameters are as follows: pH, DO, BOD, COD, EC, TDS, TSS, Total Hardness, Calcium, Magnecium, Total Coliform, Fecal Coliform, Sulphate, Fluoride, Iron, Arsenic, and trace metals such as Chromium, Lead, Cadmium and Mercury.

9.2.6.6 Soil Quality

Soil quality to be monitored at one locations in EZ. Both physical and chemical parameters need to be monitored at each location. The parameters should be compared with the soil sample of undisturbed location. The parameters to be analysed in soil sample are as follows:

 Textural class  Gravel (%)  Sand (%)  Silt (%)  Clay (%)  pH  Bulk density (g/cc)  Infiltration rate (cm/h)  Specific gravity  Porosity (%)  Moisture content (%)  Organic matter (%)

 Alkalinity (CaCO3 mg/L)  Sodium absorption ratio  Conductivity (micromhos)  Available nitrogen (%)  Available phosphorous (mg/kg)  Available potassium (%)  Available boron (mg/kg)  Available NaCl (%)

 Available Na2CO3 (%)  Available iron (mg/kg)  Available manganese (mg/kg)  Available copper (mg/kg)  Available zinc (mg/kg)

9.2.6.7 Flora and Fauna:

During the primary ambient environmental quality monitoring around the EZ location, flora and fauna on the site and surrounding the EZ has not been monitored to assess the flora and fauna before construction

148 EIA Report- Narayanganj Economic Zone of the project. Thus, it is recommended to carry out a one-time assessment of baseline flora and fauna surrounding the project location before completion of the project. There after terrestrial and aquatic flora and fauna should be monitored to observe any alteration in their species composition and replacement. This could be done in association with local universities and research institutions which carry out such studies frequently. Such monitoring would help in taking necessary steps at the appropriate stage to prevent further deterioration of the surrounding ecology and protect the flora-fauna. The frequency of sampling could be once in a year during post monsoon season (Oct to Dec).

In addition, the Environment Management Cell should collect studies on flora-fauna conducted by local universities and research institutions in the nearby areas.

9.3. Mitigation Plan for EZ

The detailed plan for EZ development will be prepared in later stages. However following measures shall mandatorily form part of EMP for EZ development and operation:

 Seperate environment clearance should be taken by developer before developing economic zone from DoE

 Industries should obtain environment clearance individually from DoE prior to establishment and commencement. Measures that should be taken by developer and individual industrial owners whicle development and operation phase is tabulated in table below Table 64: Mitigation Measures Suggested for Developer

Impact Mitigation Measures

Identification of Site for Disposal  Site identified should be 1.0 km away from settlement, sensitive of construction Debris, locations, like school, hospital, religious structures, reseve forest and construction labour camp and any other eco-sensitive zone etc. plant site  Site identified should be approved by BEZA and PMC  Site should be located in downwind direction from settlement area  Fertile agricultural land and community land should be avoided for setting of these facilities Air Pollution  Sprinkling of water during construction phase on all unpaved roads, site and haul roads  Avoiding excess pilling of raw material and debris at site  Storage & transportation of raw material and debris in covered conditions  Cutting of only identified trees after obtaining permission of forest department  Regular cleaning of site  Guiding signage should be provided at the site for vehicles  Timings of the construction material vehicles should be fixed and should be during non-peak hours to prevent traffic congestion and traffic jams  Usage of low energy intensive building material like fly ash mic cement and bricks  Usage of low sulphur diesel for running DG sets, construction vehicles and equipments  Obtaining temporary electricity connection during construction phase and operating DG sets only during power failure  Open burning of wood or any other material should be prohibited at site and all the workers should be made aware about the same Water Pollution & water  Minimizing the run-off from the site by construction of sediment Conservation basins  Maintaining the flow of water sprinklers so as to avoid wastage of water

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 No debris should be thrown or disposed off in any water body like river, pond, canal etc or ground water source like functional or abandoned well  Excavation should not be carried out during monsoon  Provision of temporary storm water drainage system during construction phase to drain the storm water  Excavated pits should be provided with garland drains to prevent enterance of water inside the pit  Provision of oil & grease traps wih the storm water drains draining the parking and fuel storage area  Provision of septic tanks and soak pits at the site & labour camps for disposal of sewage generated by construction labour  Waste generated by construction camps should be disposed off regularly at the identified site for debris disposal  Provision of cross drainage structures like balancing for maintaining the drainage pattern  Stone & bricks should be purchased only from licenced vendors  Keeping provision of land for development of STP for each industry  Tank alarms should be installed so as to prevent overflow of water  Leakage detection should be carried out quarterly so as to detect any leakages in the gas pipeline Soil Quality  Top soil, if excavated from the project site should be stored in covered condition and should be used later for landscaping purpose  Storage of raw materials, debris and fuel on paved surfaces  Training the workers to handle the material so as to minimize spillage of material on soil  Provision of cross drainage structures to prevent water logging and soil erosion  Stone pitching with grass turfing should be done for the high embankment close to water body  Disposal of construction debris, municipal waste from labour camps and hazardous waste from site should be disposed off at the identified site  Keeping provision of land for development of soild waste management facility within the EZ site  No open area should be left without the vegetation to protect the soil.  Mulching of soil should be done regularly to prevent direct exposure of soil to wind and water Noise Pollution  Construction vehicles, machinery and equipment used for construction purpose should meet the standards prescribed by DoE  Upkeeping and regular maintenance of all the construction vehicles, machinery and equipment used for construction purpose  Provision of acoustic enclosures, noise mufflers, silencers etc with the DG sets and any noise generating machinery  Provision of temporary noise shield/barrier in areas where more noise will be generated Ecology  Only identified trees should be fell down after obtaining permission from forest department  Comensatory plantation should be carried out in ratio of min 1:2 under guidance of forest department  Development of thick green buffer all along the periphery of EZ  Boundary should be constructed around the EZ site to prevent trespassing of the animals  Native plant species requiring should be considered for plantation  Timber should be purchased only from authorized vendors  No waterbody should be filled outside the EZ site  The mangroves adjacent to the site location should not be cut or impacted. Disaster and Risk Management  Provision of first aid kit and first aid room and well trained first aid practioner at the site all the time  Ambulance facility should be provided at the site  Tie-ups with local hospital should be made to handly emergency case, if any

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 Availability of safety officers and supervisiors at all the time on the site  Workers should be given training for handling construction vehicles, equipment and handling emergency situations like fire, floods, earthquake and cyclone  Cautionary signage should be provided in the areas associated with risks like storage of explosives, fuels, heavy construction material etc. Entry for only trained authorized personnel should be allowed in such areas with adequate safery measures  Emergency handling cell & room should be developed at the site and should be headed by project & safety manager  Contact no. of nearest fire-station and hospitals should be displayed within the emergency handling room

9.4. Monitoring Plan

The objective of environmental monitoring during the construction and operation phases is to compare the monitored data against the baseline condition collected during the study period to assess the effectiveness of the mitigation measures and the protection of the ambient environment based on national standards. A monitoring schedule has been sketched based on the environmental components that may be affected during the construction and operation of the project and is given below. Table 65: Environmental Monitoring Plan

S. Aspect Source of Monitoring Frequency Executing Enforceme No. Impact Methods and Agency nt Agency Parameters 1.0 Construction Phase 1.1 Local Manpower Construction Contractor’s Monthly Contractor BEZA & PMC Absorption Works report No. of people working in the project 1.2 Soil Erosion Excavation, Survey & Monthly Contractor BEZA & PMC disposal, cut & fill observation; and land clearing Extent and degree activities for site of erosion; levelling and Structures for internal roads, controlling soil disposal erosion 1.3 Greenbelt - Survival rate of Half Yearly Contractor/B BEZA & PMC Development species planted; EZA Density of vegetation 1.4 Air Quality Transportation of Survey & Once in each BEZA & PMC construction observations; season for materials, road Levels of PM10, two weeks at construction, PM2.5, SO2, NOx, 3 locations construction of CO utilities 1.5 Waste Restoration of Status of Quarterly Contractors BEZA & PMC Management disposal sites and protection construction areas measures 1.6 Noise Level Noise levels Ambient Daily Contractors BEZA & PMC compliance with Equivalent respect to continuous Sound industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations 1,7 Drinking Water Contamination All physio- Monthly Contractor BEZA & PMC chemical &

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biological parameters 2.0 Operation Phase 2.1 Noise Levels Noise levels Ambient Monthly Individual BEZA compliance with Equivalent Industrial respect to continuous Sound Units industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations Plant periphery Monthly Individual BEZA and near noise Industrial generation Units sources 2.2 Biological Horticulture/ Survival rate of Quarterly BEZA BEZA Environment Greenbelt plants and shrubs Development Survival rate of Quarterly Individual BEZA plants and shrubs unit at individual unit 2.3 Ambient air Ambient air Ambient air Quaterly Individual BEZA quality quality levels quality Industrial compliance with monitoring at Units respect to individual industrial industries – standards Monitor levels of PM10, PM2.5, SO2, NOx, CO 2.4 Ground water Ground water Borewells Quaterly Individual BEZA quality quality levels installed at site Industrial compliance with Units respect to industrial standards

9.5. Monitoring Indicators

The physical, biological and social components which are of particular significance to the proposed project are listed below:

 Air quality  Water quality  Noise levels  Solid & Hazardous Waste Management  Re-plantation success / survival rate  Soil Erosion These indicators will evaluated periodically based on the monitoring results, baseline conditions, predicted impacts and mitigation measures.

9.6. Institutional Arrangement

BEZA has developed Environmental Management Framework with the help of World Bank. The institutional arrangement is aligned as per this framework. BEZA will have an Environmental and social cell which will coordinate with site engineers and PMC. Overall Project Implementation Arrangements The overall management of the project will be carried out by BEZA which is the project implementing unit (PIU).

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Institutional Set Up For Environment Management The institutional arrangements for the implementation of various aspects of EMF and environment management of the proposed project envisaged to be implemented as part of the PSDSP comprise the following.

 Project Environment Cell (PEC) at PIU to ensure adequate integration of environment management measures in the design phase and supervise implementation of EMF and specific requirements of EMP  Environment Management Unit (EMU) at EZ to implement EMP and other regulatory requirements during construction & operation phase of EZ . Project Environment Management Cell (PEC) at PIU The Project Implementation Unit (PIU) will establish a Project Environmental Cell (PEC) headed by a ‘Manager – Environment’ and supported by environmental engineers. The PEC will function to:  Supervise implementation of EMF throughout project implementation period;  Ensure integration of the EA and the EMP measures into the sub-project design and implementation plans such as contract documents, maintenance contracts, tenant lease agreements, etc;  Supervise the implementation of the mitigation measures by the Master developers / Contractors;  Assist the engineering staff and other PIU staff in addressing environmental issues during planning, design and implementation of the sub-projects;  Prepare periodic progress reports on the implementation of the EMP throughout the project period. Environment Management Unit (EMU) In order to implement various environmental management measures at EZ, the master developer / contractor / operator will set up an Environment Management Unit (EMU). The EMU will consist of environmental engineers with relevant experience on environmental issues associated with the development of tourism based EZ. The details of the EMC has been elaborated in section 9.2.7. The EMU will function all through construction and operation phase of the EZ and perform the following functions.

 Identify regulatory requirements of the sub-project and initiate necessary actions / studies to ensure compliance to the same;  Co-ordinate with DoE and PIU and ensure securing SCC and ECC as applicable for the project(s);  Co-ordinate with the contractors / sub-contractors and all other agencies involved in the development and operation of EZ / EPZ and ensure that all the requirements of EMP are fully complied;  Ensure that all the common environmental infrastructure in EZ / EPZ is operated and maintained in compliance with the regulatory requirements of GoB;  Liaise with individual enterprise/tenants and ensure that all environmental management conditions of the tenant lease agreement are fully complied; Prepare regular reports on environment management and submit to PIU/GoB. 9.7. Community development plan

It is recommended the EZ owners to involve the local community during the project development. The EZ owner/its contractors may recruit local workforce to the extent possible during construction phase. The EZ owner would identify technically qualified unemployed youth around the project location and other nearby areas, and employ as far as practical. The EZ owner should form a forum/ association/ trust along with its industrial units to look after community development activities of EZ. All the industrial units should periodically contribute to this Trust. The Trust would represent EZ and its industries for all matters related to community and its development. This would act as interface between EZ and community. The Trust should encourage its industrial units to recruit local unemployed youth in the jobs during operational phase. For this if required arrange training for the local people to develop skilled manpower required if

153 EIA Report- Narayanganj Economic Zone sufficient skilled manpower is not available to carry out technical work in the industrial units during operational phase.

The Trust will organise a community advisory group involving local representatives, representatives from EZ industries and neighbouring industries; that would help them in finding ways to participate with its neighbours in addressing socio-economic concerns. With the advice of its community advisory panel, local officials, and other key individuals and groups, the Trust along with its constituent industries may sponsor appropriate programs and projects to benefit its community as a whole.

Some specific community development programs that could be considered by the Trust in coordination with other industries in the locality are suggested here:  Conducting awareness programs in surrounding villages on health impacts due to environmental pollution (air, noise, water, solid waste, etc), and precautions to be taken to minimise health impacts.  Conducting periodic health check-ups to the EZ (including industries) staff and in the surrounding villages to identify pollution related diseases.  Encouragement to residents in the nearby localities for self-employment ventures, such as by assisting them in arranging micro finances to develop them as artisans/ skilled personnel.  Periodic training programs on health and sanitary education, women and child development, and income generation schemes.  Participation in improving the existing medical and educational facilities of the area - for this purpose, it is suggested that the Trust provide funds for facilities improvement (providing toilets, furniture, additional space creation, any other needed) to the local hospitals and schools  Development of greenbelt/greenery or tree plantation in the nearby vacant government lands to build a green and clean environment in the surrounding areas and to reduce pollution impacts to some extent.  Sponsoring fellowships to students in surrounding villages to encourage them to go for higher education  Construction of a hospital in EZ area in collaboration with other industries to improve health status  Conduct or sponsor camps to clean up river ghats, jetties and terminals in the surrounding areas.

9.8. Post Project Monitoring Plan

To monitor the extent of environmental impact of the proposed EZ and proposed industries, it is advisable to periodically monitor the ambient environmental quality around the project location. This section describes the environmental quality monitoring detailing number and location of sampling stations, parameters to be monitored, frequency of sampling, etc. The EZ authorities has to submit all the monitoring results to DOE, Bangladesh.

9.9. Environment Management Cell

It is recommended that the EZ Authority set up an EMC (Environmental Management Cell) to address environmental management concerns. The cell should be manned by qualified persons who will be responsible for regular environmental quality monitoring, proper functioning of STP, implementation of community development plan, and liaison with regulatory bodies such as DOE.

The EMC will be responsible for the following:

 to implement the EHS policy of EZ  to coordinate with EZ Trust in relevant activities  to ensure that STP function properly and meet effluent discharge standards

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 to maintain environmental quality analysis laboratory and analyse air, noise, water and soil samples on a regular basis  to implement community development plan,  to coordinate and monitor EZ Trust to regularly check workers health and take appropriate steps  to coordinate and monitor EZ Trust on safety conditions at various work environments and take necessary steps to maintain high safety standards. To deal with emergency situations.  to liaison with regulatory bodies  to ensure systematic and routine housekeeping of the common areas of EZ  to maintain the proposed greenbelt along the boundary

The EMC may be headed by an Assistant Director – Environment, who should be a senior person, should have an overall knowledge of STP, hazardous waste TSDFs, and their maintenance, environmental laws and standards, and should be able to independently manage the Cell. The EMC in-charge may be supported by Environmental scientist/ engineer and a Social Analyst. The scientist will be responsible for environmental quality analysis and should be capable of preparing reports and data sheets. He/she should have sufficient knowledge in sampling and analysis of environmental parameters. The social analyst should have knowledge of community programs and should be able to plan and implement community programs. In addition a part time occupational health specialist and a safety specialist can be appointed.

In addition the following staff at laboratory are required:  One STP and TSDF In-charge  One Chemist cum laboratory incharge  Three Plant Operators (one per shift) and three TSDF operators  Laboratory/Field Assistants  Sampling assistants

9.10. Compensation Plan

BEZA and DC shall compensate the private land owners and the household owners whose land needs to be acquired and houses needs to be demolished for the development of the EZ. The Compensation Plan has been detailed in the Social Impact Assessment Report of Narayanganj Economic Zone. The compensation plan has been decided based on the entitlement matrix of RSMF, BEZA 2015. The basis of compensation has been calculated by strictly following the RSMF.

Compensation has also been enumenrated for the a) loss of agricultural crops; b) loss of 59 homesteads along with the c) compensation for acquiring 166.01 acres of private bondobostho land and d) loss of trees owned by the 59 homesteads. The total compensation that has been enumerated under the above headings comes out to be BDT 3,487,181,478.

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10. Cost of EMP

The cost of EMP given here includes only that for the CETP, TSDF, laboratory/analysis facilities, certain equipment for post project monitoring, and greenbelt development. The costs are approximate and need calibration at the time of detailed design and estimation stage.

Table 66: Cost for EMP Implementation

S. No Activity/ Equipment Cost (Tk.) 1 Weather Station 65,000 2 Ear Muffs (10 Nos only for sampling personnel who may go 40,000 to industries where high noice is experienced) 3 ETP construction 50,00,000 4 Solid waste bins for common areas (100 Nos) 10,000 5 Greenbelt along the boundary and plantation along the 20,00,000 roads 6 High Volume Air Samplers (2 Nos) 3,00,000 7 Digital Sound Level meter 8,000 8 First time flora and fauna study 5,00,000 9 Analytical Laboratory (equipment for water quality and air 15,00,000 quality analysis) 10 Laboratory and EHS department space and a small storage: Cost will be given by feasibility team total area 2000 sft as part of building construction 11 Manpower cost: This is recurring cost. 42,60,000 per year  Assistant Director – Environment  Environmental scientist/ engineer,  Social Analyst,  part time occupational health specialist and a safety specialist,  One ETP Incharge  One TSDF Incharge  One Chemist  Six Plant Operators (one per shift)  Laboratory/Field Assistants  Air quality sampling assistants 12 Fund for proposed community development activities 50,00,000

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11. Conclusion and Recommendation

11.1 Conclusions

Overall the impacts from both construction and operation phase have limited adverse environmental impacts, and can be readily addressed through mitigation measures as provided in EMP. BEZA, formed under EZ Act, 2010 is overall agency for implementation of EZ projects for rapid ecomonic development of Bangladesh. The EZ will be developed following PPP approach. BEZA will invest in land and related off- site infrastructure development so as to make zone accessible and resourceful. Thereafter economic zone development will be responsibility of private developers. The off-site facilities proposed to be developed by BEZA include development of administration building, boundary wall, electrical supply, and access road. The project falls under Red category as per ECA, 1995 and requires prior environment clearance from DoE, Bangladesh. 11.2 Recommendations

The recommendations made for the project development on the basis of EIA study are given below:

 Construction activities for the development of project should be started after obtaining environment clearance certificate from DoE, Bangladesh

 Proposed environment management plan should be implemented strictly both during operation and construction phase of the project.

 Proper training of maintaining environment, health and safety should be given to Project management unit in both construction and operation phase

 Provision of garland drain, thick green belt, ETP, STP, segregated storm water shall be adhered to.  Environmental monitoring should be conducted as proposed in environment management plan

 Seperate environment impact assessment study is to be carried out by individual industry before development.

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11.1. Mitigation Plan for EZ

The detailed plan for EZ development will be prepared in later stages. However following measures shall mandatorily form part of EMP for EZ development and operation:

 Seperate environment clearance should be taken by developer before developing economic zone from DoE

 Industries should obtain environment clearance individually from DoE prior to establishment and commencement. Measures that should be taken by developer and individual industrial owners whicle development and operation phase is tabulated in table below Table 67: Mitigation Measures Suggested for Developer

Impact Mitigation Measures

Identification of Site for Disposal  Site identified should be 1.0 km away from settlement, sensitive of construction Debris, locations, like school, hospital, religious structures, reseve forest and construction labour camp and any other eco-sensitive zone etc. plant site  Site identified should be approved by BEZA and PMC  Site should be located in downwind direction from settlement area  Fertile agricultural land and community land should be avoided for setting of these facilities Air Pollution  Sprinkling of water during construction phase on all unpaved roads, site and haul roads  Avoiding excess pilling of raw material and debris at site  Storage & transportation of raw material and debris in covered conditions  Cutting of only identified trees after obtaining permission of forest department  Regular cleaning of site  Provision of adequate parking space at site so as to prevent idling of vehicles during construction phase  Upkeeping and maintenance of all the construction vehicles, machinery and equipment used for construction purpose  All vehicles entering the EZ site should carry PUC  Guiding signage should be provided at the site for vehicles enetering the site to minimize the movement of vehicle within the site  Timings of the construction material vehicles should be fixed and should be during non-peak hours to prevent traffic congestion and traffic jams  Speed limits should be restricted within the site for all the construction vehicles  Usage of low energy intensive building material like fly ash mic cement and bricks  Usage of low sulphur diesel for running DG sets, construction vehicles and equipments  Obtaining temporary electricity connection during construction phase and operating DG sets only during power failure  Provision of wheel washing facility at exit point of site  Adequate air pollution control measures like provision of bag filters, stacks of adequate height should be provided with WMM, hot mix plant, batching plant etc.  Open burning of wood or any other material should be prohibited at site and all the workers should be made aware about the same  Zonation of EZ should be carried out such that high polluting industries should be located in downwind direction Water Pollution & water  Minimizing the run-off from the site by construction of sediment Conservation basins for collection of storm run-off and re-using that water for curing purpose and wheel washing  Maintaining the flow of water sprinklers so as to avoid wastage of water

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 No debris should be thrown or disposed off in any water body like river, pond, canal etc or ground water source like functional or abandoned well  Excavation should not be carried out during monsoon  Provision of temporary storm water drainage system during construction phase to drain the storm water and should be connected to nearest surface water body  Excavated pits should be provided with garland drains to prevent enterance of water inside the pit  Provision of oil & grease traps wih the storm water drains draining the parking and fuel storage area  Provision of septic tanks and soak pits at the site & labour camps for disposal of sewage generated by construction labour  Waste generated by construction camps should be disposed off regularly at the identified site for debris disposal  Provision of cross drainage structures like balancing for maintaining the drainage pattern  Stone & bricks should be purchased only from licenced vendors  Keeping provision of land for development of ETP for each industry  Provision of rain water harvesting should be made at the point of extraction of ground water. Recharge should be atleast equal the amount of water extracted  Rain water harvesting tank should be developed at the site so as that water can be used for meeting daily water demand  Tank alarms should be installed so as to prevent overflow of water  Leakage detection should be carried out quarterly so as to detect any leakages in the gas pipeline Soil Quality  Top soil, if excavated from the project site should be stored in covered condition and should be used later for landscaping purpose  Storage of raw materials, debris and fuel on paved surfaces  Training the workers to handle the material so as to minimize spillage of material on soil  Provision of cross drainage structures to prevent water logging and soil erosion  Stone pitching with grass turfing should be done for the high embankment close to water body  Disposal of construction debris, municipal waste from labour camps and hazardous waste from site should be disposed off at the identified site  Keeping provision of land for development of soild waste management facility within the EZ site  No open area should be left without the vegetation to protect the soil.  Mulching of soil should be done regularly to prevent direct exposure of soil to wind and water Noise Pollution  Construction vehicles, machinery and equipment used for construction purpose should meet the standards prescribed by DoE  Upkeeping and regular maintenance of all the construction vehicles, machinery and equipment used for construction purpose  Speed limits should be restricted for all construction vehicles and equipment  Honking should be prohibited at the site  Provision of acoustic enclosures, noise mufflers, silencers etc with the DG sets and any noise generating machinery  Provision of temporary noise shield/barrier in areas where more noise will be generated Ecology  Only identified trees should be fell down after obtaining permission from forest department  Comensatory plantation should be carried out in ratio of min 1:2 under guidance of forest department  Development of thick green buffer all along the periphery of EZ  Boundary should be constructed around the EZ site to prevent trespassing of the animals  Native plant species requiring should be considered for plantation  Timber should be purchased only from authorized vendors

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 No waterbody should be filled outside the EZ site

Disaster and Ris  Provision of first aid kit and first aid room and well trained first aid k Management practioner at the site all the time  Ambulance facility should be provided at the site  Tie-ups with local hospital should be made to handly emergency case, if any  Availability of safety officers and supervisiors at all the time on the site  Workers should be given training for handling construction vehicles, equipment and handling emergency situations like fire, floods, earthquake and cyclone  Cautionary signage should be provided in the areas associated with risks like storage of explosives, fuels, heavy construction material etc. Entry for only trained authorized personnel should be allowed in such areas with adequate safery measures  Emergency handling cell & room should be developed at the site and should be headed by project & safety manager  Contact no. of nearest fire-station and hospitals should be displayed within the emergency handling room

11.2. Emergency Preparedness Plan

In order to be in a state of readiness to face adverse effects of accidents, an emergency preparedness plan is required to be prepared which includes on-site and off-site emergency plan by the individual industry and industrial estate. BEZA is committed to develop an emergency preparedness plan in consultation with district authorities and industry association. The Emergency Preparedness Plan will have the following minimal components:

 Accidents preventions procedures/ measures  Fire prevention planning and measures  Fire water storage and foam system  Accident/emergency response planning procedure  Grievance redressal mechanism  Emergency control centre  Emergency information system with role & responsibility and command structure  Recovery procedure  Assessment of damages and rectification  Evaluation of functioning of disaster management plan  Accident investigation  Clean-up and restoration

11.3. Monitoring Plan

The objective of environmental monitoring during the construction and operation phases is to compare the monitored data against the baseline condition collected during the study period to assess the effectiveness of the mitigation measures and the protection of the ambient environment based on national standards. A monitoring schedule has been sketched based on the environmental components that may be affected during the construction and operation of the project and is given below. Table 68: Environmental Monitoring Plan

S. Aspect Source of Monitoring Frequency Executing Enforceme No. Impact Methods and Agency nt Agency Parameters

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1.0 Construction Phase 1.1 Local Manpower Construction Contractor’s Monthly Contractor BEZA & PMC Absorption Works report No. of people working in the project 1.2 Soil Erosion Excavation, Survey & Monthly Contractor BEZA & PMC disposal, cut & fill observation; and land clearing Extent and degree activities for site of erosion; levelling and Structures for internal roads, controlling soil disposal erosion 1.3 Greenbelt - Survival rate of Half Yearly Contractor/B BEZA & PMC Development species planted; EZA Density of vegetation 1.4 Air Quality Transportation of Survey & Once in each BEZA & PMC construction observations; season for materials, road Levels of PM10, two weeks at construction, PM2.5, SO2, NOx, 3 locations construction of CO utilities 1.5 Waste Restoration of Status of Quarterly Contractors BEZA & PMC Management disposal sites and protection construction areas measures 1.6 Noise Level Noise levels Ambient Daily Contractors BEZA & PMC compliance with Equivalent respect to continuous Sound industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations 1,7 Drinking Water Contamination All physio- Monthly Contractor BEZA & PMC chemical & biological parameters 2.0 Operation Phase 2.1 Noise Levels Noise levels Ambient Monthly Individual BEZA compliance with Equivalent Industrial respect to continuous Sound Units industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations Plant periphery Monthly Individual BEZA and near noise Industrial generation Units sources 2.2 Biological Horticulture/ Survival rate of Quarterly BEZA BEZA Environment Greenbelt plants and shrubs Development Survival rate of Quarterly Individual BEZA plants and shrubs unit at individual unit 2.3 Ambient air Ambient air Ambient air Monthly Individual BEZA quality quality levels quality Industrial compliance with monitoring at Units respect to individual industrial industries – standards Monitor levels of PM10, PM2.5, SO2, NOx, CO 2.4 Ground water Ground water Borewells Monthly BEZA BEZA quality quality levels installed at site compliance with respect to

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industrial standards

11.4. Monitoring Indicators

The physical, biological and social components which are of particular significance to the proposed project are listed below:

 Air quality  Water quality  Noise levels  Solid & Hazardous Waste Management  Re-plantation success / survival rate  Soil Erosion These indicators will evaluated periodically based on the monitoring results, baseline conditions, predicted impacts and mitigation measures.

11.5. Institutional Arrangement

BEZA has developed Environmental Management Framework with the help of World Bank. The institutional arrangement is aligned as per this framework. BEZA will have an Environmental and social cell which will coordinate with site engineers and PMC.

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12. Conclusion and Recommendation

12.1. Conclusions

Overall the impacts from both construction and operation phase have limited adverse environmental impacts, and can be readily addressed through mitigation measures as provided in EMP. BEZA, formed under EZ Act, 2010 is overall agency for implementation of EZ projects for rapid ecomonic development of Bangladesh. The EZ will be developed following PPP approach. BEZA will invest in land and related off- site infrastructure development so as to make zone accessible and resourceful. Thereafter economic zone development will be responsibility of private developers. The off-site facilities proposed to be developed by BEZA include development of administration building, boundary wall, electrical supply, and access road. The project falls under Red category as per ECA, 1995 and requires prior environment clearance from DoE, Bangladesh. 12.2. Recommendations

The recommendations made for the project development on the basis of EIA study are given below:

 Construction activities for the development of project should be started after obtaining environment clearance certificate from DoE, Bangladesh

 Proposed environment management plan should be implemented strictly both during operation and construction phase of the project.

 Trees cutting should be minimum and compensatory plantation should be carried out for trees to be fell for off-site development minimum in ratio of 1:2

 Proper training of maintaining environment, health and safety should be given to Project management unit in both construction and operation phase  Provision of garland drain, thick green belt, ETP, STP, segregated storm water shall be adhered to.

 Environmental monitoring should be conducted as proposed in environment management plan  Seperate environment impact assessment study is to be carried out by developer for whole zone before developing the EZ.

 Ecological survey should be conducted before developing the EZ.

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Annexure A: Primary monitoring results A) Groundwater Results

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B) Noise Monitoring Results

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C) Air Monitoring Results

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D) Surface Water Analysis Results

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Annexure B: Land Tranfer Documents

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Annexure C: Approved ToR from DoE, Bangladesh

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Annexure D: Land Use Plan of Narayanganj EZ

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Annexure E: Zone Map of Narayanganj EZ

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Annexure F: Detail Master Plan of Narayanganj EZ

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Annexure G: Utility Map of Narayanganj EZ

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Annexure H: Compliance Matrix as per DoE

S.No Comments PwC Response 1 The EIA report should explain the stringent mitigation Refer Section 7.5.2; Page Number-117 measures to prevent further impact on the river water which lists in details the stringent quality of Sitalakhya River measures developers and DoE shall take to prevent further impact on the water quality parameters of Sitalakhya River 2 The EIA report should have the master plan in the Annexure-D, E, F and G details the land annexure of the report use map, zone map, detail master plan and utility map of the subject site. Page number: 178, 179, 180 and 181 3 The EIA report shall explain the water quality upstream Refer section 5.2.6.1; Page Number-86 for and downstream of the subject site and explain the water the comparison of the water quality quality parameters of the water parameters upstream and downstream of the river s.r.t the river abutting the project site. 4 The report should also mention the need of installation of Refer Section 7.5.2; Page Number-116 ETP and STP for every unit islotalety which shall be apart which lists in highlight the requirement of from the CETP STP, ETP and CETP 5 EIA report shall highlight the water re-use and recycling Refer Section 7.5.2; Page Number-116 and concept 117 highlighting the introduction of water re-use and recycling and also water balance

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