Initial Environmental Examination BAN: Power System Expansion And

Power System Expansion and Efficiency Improvement Investment Program (RRP BAN 42378)

Initial Environmental Examination

September 2012

BAN: Power System Expansion and Energy Efficiency Improvement Investment Program Tranche 1

Prepared by the Ministry of Power, Energy and Mineral Resources for the Asian Development Bank

The initial environmental examination report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature.

CURRENCY EQUIVALENTS

(As of 30 June 2012)

Currency Unit – Taka (Tk) Tk 1.00 = $0.0121 $1.00 = Tk 83

ABBREVIATIONS

ADB - Asian Development Bank AFD - l’Agence Française de Développement AP - Affected People BPDB - Bangladesh Power Development Board CCGT - Combined-cycle gas turbine CITES - Convention on International Trade in Endangered Species of Wild Fauna and Flora DC - Double circuit DESCO - Dhaka Electric Supply Company DIA - Direct Impact Area DOE - Department of Environment DPDC - Dhaka Power Distribution Company Limited DS - Distribution system EA - Executing Agency ECA - Environment Conservation Act ECC - Environmental Clearance Certificate ECR - Environment Conservation Rules EIA - Environmental Impact Assessment EIB - European Investment Bank EMP - Environmental Management Plan FFA - Framework Financing Agreement GIA - General Impact Area GIS - Gas insulated switchgear GOB - Government of Bangladesh GRC - Grievance Redress Committee IDB - Islamic Development Bank IEE - Initial Environmental Examination IPCC - Investment Program Coordinating Committee MFF - Multitranche Financing Facility MOEF - Ministry of Environment and Forests MPEMR - Ministry of Power, Energy and Mineral Resources NGO - Non-government Organization NOC - No Objection Certificate NWPGCL - North-West Power Generation Company Limited OCGT - Open cycle gas turbine PGCB - Power Grid Company of Bangladesh Limited PV - Photovoltaic PMU - Project Management Unit REB - Rural Electrification Board RP - Resettlement Plan ROW - Right-of-Way SPS - Safeguard Policy Statement SS - Substation TA - Technical Assistance T/L - Transmission Line

WEIGHTS AND MEASURES m - meter km - kilometer ha - hectare MVA - megavolt-ampere kV - kilovolt (1,000 volts) mG - milliGauss MW - megawatt C - degree Celsius lahk - 100,000 Taka

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY

1.0 INTRODUCTION 8

1.1 Overview of the Investment Program 8 1.2 Environmental Requirements for Tranche 1 12 1.3 Structure of the Report 14

2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK 14

2.1 National Environmental Requirements 14 2.2 Environmental Requirements of Asian Development Bank and Cofinancing Institutions 17

3.0 COMPONENT 1 – EFFICIENCY IMPROVEMENT OF POWER PLANTS 23

3.1 Introduction 23 3.2 Description of the Existing Facilities 25 3.3 Audit and Site Investigation Procedure 31 3.4 Findings and Areas of Concern 31 3.5 Anticipated Environmental Impacts and Corrective Action Plan 34 3.6 Information Disclosure, Consultation, and Participation 45 3.7 Grievance Redress Mechanism 45 3.8 Implementation Arrangements 46 3.9 Conclusion and Recommendation 47

4.0 COMPONENT 2 - TRANSMISSION SYSTEM STRENGTHENING 48

4.1 Objectives and Benefits 48 4.2 Location and Components 48 4.3 Description of the Environment 50 4.4 Anticipated Environmental Impacts and Mitigation Measures 60 4.5 Analysis of Alternatives 66 4.6 Information Disclosure, Consultation, and Participation 67 4.7 Grievance Redress Mechanism 69 4.8 Environmental Management Plan 70 4.9 Conclusion and Recommendation 71

List of Tables

Table 1.1 Financing Plan of the Investment Program Table 1.2 Cofinancing Plan of the Investment Program Table 1.3 Project Details of the Tranches by Executing Agency Table 2.1 Brief Comparison of Environmental Requirements Table 3.1 Summary of Component 1 Table 3.2 Summary of Findings and Areas of Concern Table 3.3 Environmental Management Plan Table 3.4 Environmental Monitoring Plan Table 3.5 Carbon Dioxide Emissions Table 3.6 Estimated Water Requirements for Conversion into CCGT Power Plant Table 4.1 Components of Transmission Line Facilities Table 4.2 Administrative Units Traversed by the Transmission Line Routes Table 4.3 Trees within the GIA of MT Line Table 4.4 Trees within the GIA of BN Line Table 4.5 Trees within the GIA of CRK Line Table 4.6 Compensation for Affected Trees and Crops along the T/L Route ROW Table 4.7 Summary of Land Affected by Component 2 Table 4.8 Summary of Alternative Sites for Transmission Line Table 4.9 Environmental Management Plan Table 4.10 Environmental Monitoring Plan

List of Figures

Figure 1.1 Implementation Structure of the Investment Program Figure 1.2 Location Map of Tranche 1 Figure 2.1 DOE Application Process for Securing ECC Figure 3.1 Process Flow of Combined-Cycle Power Plant Figure 3.2 Component 1 Location Map Figure 3.3 General Layout of Shahjibazar Power Plant Figure 3.4 General Layout of Sylhet Power Plant Figure 3.5 Location Map of Khulna Power Plant Figure 3.6 Grievance Redress Committee of Component 1 Figure 4.1 Component 2 Location Map Figure 4.2 Seismic Map of Bangladesh Figure 4.3 Grievance Redress Committee of Component 2

List of Appendixes

Appendix 1 DOE Classification of industrial units or projects based on its location and impact on environment Appendix 2 Relevant Environmental Standards from Bangladesh ECR 1997 Appendix 3 Relevant Environmental Laws and Regulations in Bangladesh Appendix 4 Details of Audit and Site Investigations for Component 1 Appendix 5 Consultation Meetings Held from May 8-28, 2012 Appendix 6 List of Persons who Attended the Consultation Meetings Appendix 7 List of Participants, Safeguards and Capability Strengthening Planning Workshop for Executing Agencies, 28 May 2012

EXECUTIVE SUMMARY

1.0 Project Description

The Power System Expansion and Efficiency Improvement Investment Program will be financed under the multitranche financing facility and is designed to cover investments in three tranches for power generation, transmission and distribution to be implemented within 2012-2015 in order to meet the current severe energy shortfall in Bangladesh. The total amount of the Investment Program is estimated at $1.6 billion to be financed by Asian Development Bank (ADB), the European Investment Bank (EIB), Islamic Development Bank (IDB) and l’Agence Française de Développement (AFD).

This Tranche 1 is $400 M and has three components: (i) efficiency improvement of power plants through the conversion of existing open cycle gas turbine (OCGT) power plant in Shahjibazar (70 MW to 105 MW), Baghabari (100 MW to 150 MW), Sylhet (150 MW to 225 MW) and Khulna (150 MW to 225 MW) into combined-cycle gas turbine (CCGT); (ii) transmission system strengthening through the construction of three 132 kV double circuit (DC) transmission line from Mymensingh to Tangail (100 km), Brahmanbaria to Narshingdi (57 km), and Chandraghona to Khagrachari through Rangamati (80 km); and, (iii) capacity building for the Executing Agency(s) in the preparation of succeeding tranches, and better systems management. The Executing Agency (EA) for Component 1 is the Bangladesh Power Development Board (BPDB) and the North-West Power Generation Corporation Limited (NWPGCL), the Power Grid Corporation of Bangladesh (PGCB) for Component 2, and the Ministry of Power, Energy and Mineral Resources (MPER) for Component 3.

2.0 Environmental Requirements for Tranche 1

This initial environmental examination (IEE) was prepared following ADB's Safeguard Policy Statement 2009 (SPS 2009) as the unified environmental assessment and planning process for consultation, disclosure requirements, and safeguard documentation to meet the safeguard principles and requirements of both ADB and the cofinanciers.

The Environment Conservation Act of 1995 and the Environment Conservation Rules of 1997 of Bangladesh require that power projects also prepare an IEE and an environmental impact assessment (EIA) in obtaining the site clearance from the Department of Environment and the environmental clearance certificate.

3.0 Anticipated Environmental Impacts and Mitigation Measures

Component 1 involves the conversion of the existing open-cycle gas turbine power plants into combined-cycle power plants. The conversion will be limited to within the existing premises of the power plants and is not expected to cause significant adverse environmental impacts but will increase the generating capacity for the same amount of fuel. Heat from the exhaust gas of the existing power plants will be used to run the additional steam turbine. This will also result to reduction in CO2 and an improvement in the energy efficiency. Groundwater will be mainly used for cooling purposes. Ground elevation, groundwater level and pumping rates will be monitored to ensure that groundwater utilization will not cause adverse environmental impacts. An environmental management plan (EMP) was prepared to ensure that residual impacts are mitigated.

Component 2 consists of the installation of new transmission lines from Mymensingh to Tangail (MT Line), Brahmanbaria to Narshingdi (BN Line), Chandraghona to Khagrachari through Rangamati (CRK Line) with construction of new substation at Khagrachari and Rangamati, and improvements at the existing Narshingdi substation. Impacts will be

mainly during construction with about 16,418 trees affected by the right-of-way for MT Line, 47 trees for BN Line, and 7,860 trees for the CRK Line. Seven shops will be displaced by the MT Line and one unused building affected by the BN Line. Compensation of about Taka 2,175,000 is included in the project costs. Transmission towers will be used for MT Line and BN Line but CRK Line will use poles and the existing road easement to minimize the impacts in the hilly areas of Chittagong. An EMP with budget allocation was prepared for Component 2.

Component 3 is expected to have beneficial impacts in terms of improved performance in the operation and maintenance of the power systems and in addressing environmental concerns.

4.0 Information Disclosure, Consultation, and Participation

Component 1 will conduct formal consultations during the detailed design stage and in the preparation of IEE and EIA required by the DOE. The environmental assessment will be updated by BPDB and NWPGCL to include the results of consultations to comply with ADB's SPS 2009 and Public Communications Policy 2011. The revised/updated environmental assessment will be submitted to ADB.

For Component 2, there were 17 consultation meetings held from 8-28 May 2012 attended by a total of 267 people represented by 44% women. Additional seven meetings were held with women stakeholders and four ethnic minorities.

No major issues were raised during the consultations for Component 2. Affected people are supportive of the project in anticipation of potential employment opportunities and improvement in the reliability of power supply.

5.0 Implementation Arrangements and Grievance Redress Mechanism

A Project Management Unit (PMU) will be set up in each EA headed by a PMU Manager who will be responsible for reporting all subproject-related issues to the Chairman and Managing Director of each EA. The PMU will consist of technical, financial, and procurement staff while safeguards support will be hired, as and when required. The safeguards staff will be responsible in preparing the environmental monitoring reports to be submitted to ADB twice a year.

A grievance redress mechanism will be set up in each EA. Affected people can seek redress of their grievance at three levels: the PMU at each EA, the grievance redress committee, and the appropriate courts of law. A grievance redress committee (GRC) is set up through a gazette notification from the Ministry of Power, Energy and Mineral Resources as soon as the project commence. The GRC for Component 1 and Component 2 consists of PMU Manager as the Convenor, Contractor's representative as Secretary, and members are neighbor of the complainant, female representative of affected people, school teacher or Imam (church leader), and chair of the union.

1.0 INTRODUCTION

1. For more than two decades, Bangladesh has been faced with severe power shortfall as a result of several factors such as (i) the inability to build new generation capacity through timely investments, (ii) poor maintenance and performance of the existing generating capacity, (iii) gas shortages to operate some of the power plants, and (iv) rapid growth in the demand for electricity.

2. To respond to these issues, the Government of Bangladesh (GOB) developed a policy which aims to (i) increase energy supply through additional generation capacity and increased development of fuel sources, (ii) increase the efficiency of the energy supply and demand side, and (iii) diversify fuel resources to avoid dependency to natural gas and to increase renewable energy use.

3. Aside from power generation, the existing transmission network also needs strengthening to reliably evacuate power to the load centres. Gas-fired generation power plants are mostly outside the load centres in Dhaka and much of the power generated has to be transferred through long routes of more than 200 km.

1.1 Overview of the Investment Program

4. To achieve its objectives of addressing the current severe shortage in power supply, GOB requested the Asian Development Bank (ADB) to finance the Power System Expansion and Efficiency Improvement Investment Program under the multitranche financing facility (MFF).1 The Investment Program is designed to cover investments in three tranches for power generation, transmission and distribution to be implemented within 2012-2015 in order to meet the current energy shortfall in Bangladesh. The total amount of the Investment Program is estimated at $1.6B (see Table 1.1). ADB will finance $700 milllion for the three tranches, while the European Investment Bank (EIB), Islamic Development Bank (IDB) and l’Agence Française de Développement (AFD) will invest a total of $680 million to the whole Investment Program (see Table 1.2).

Table 1.1 Financing Plan of the Investment Program

Amount Share of Source ($ million) Total (%) Power System Expansion and Efficiency Improvement Asian Development Bank 700 44 Co-financing 680 42 Government 220 14 Total (Investment Program) 1600 100 Tranche 1 Asian Development Bank 185 46 Co-financing 183 46 Government 32 8 Subtotal (Tranche 1) 400 100 Tranche 2 Asian Development Bank 310 44 Co-financing 295 41

1 MFF is a flexible financing instrument of ADB which provides financing that is aligned to project readiness and long-term needs of the client. MFF is a modality consists of tranches that can finance multiple projects under an investment program in a sector or in several sectors, or large stand-alone projects with substantial and related individual components with long-term implementation plans. A tranche may comprise a loan, grant, guarantee, or ADB-administered cofinancing to finance a project or a component under the facility. (ADB Operations Manual, Multitranche Financing Facility, OM Section D14/BP, 18 May 2010)

Government 105 15 Subtotal (Tranche 2) 710 100 Tranche 3 Asian Development Bank 205 42 Co-financing 200 41 Government 85 17 Subtotal (Tranche 3) 490 100

Amount Share of Source ($ million) Total (%) Power System Expansion and Efficiency Improvement Asian Development Bank 700 44 Co-financing 680 42 Government 220 14

Total (Investment Program) 1600 100 Tranche 1 Asian Development Bank 185 46 Co-financing 180 45 Government 35 9 Subtotal (Tranche 1) 400 100 Tranche 2 Asian Development Bank 310 44 Co-financing 300 42 Government 100 14 Subtotal (Tranche 2) 710 100 Tranche 3 Asian Development Bank 205 42 Co-financing 200 41 Government 85 17 Subtotal (Tranche 3) 490 100

5. Tranche 1 has three components: (i) efficiency improvement of power plants through the conversion of existing open cycle gas turbine (OCGT) power plant in Shahjibazar (70 MW to 105 MW), Baghabari (100 MW to 150 MW), Sylhet (150 MW to 225 MW) and Khulna (150 MW to 225 MW) into combined-cycle gas turbine (CCGT); (ii) transmission system strengthening through the construction of three 132 kV double circuit (DC) transmission line from Mymensingh to Tangail (100 km), Brahmanbaria to Narshingdi (57 km), and Chandraghona to Khagrachari through Rangamati (80 km); and, (iii) capacity building for the Executing Agency(s) in the preparation of succeeding tranches, and in better systems management. An additional generation capacity of 235 MW will result from the conversion of existing OCGT into CCGT in Component 1.

6. Tranche 2 proposes to build essential 467 km of transmission lines and 14 transmission substations. The upstream improvements in the 33kV network include 500 km of distribution lines, 200 distribution substations, 39 new or upgraded 33/11kV substations and additions/upgrading of transformers to existing substations. These physical investments will ease overloading of existing transmission and distribution lines, achieve higher reliability and reduce technical losses and provides 450,000 new power connections.

7. Similar to Tranche 1, the components of Tranche 3 will include conversion of existing OCGT power plants or replacing retiring OCGT power plant with CCPP to improve energy efficiency and to install additional generation capacity.

8. The Ministry of Power, Energy and Mineral Resources (MPEMR) will be the Coordinating Agency for the MFF and will oversee the implementation of the Investment Program. Table 1.3 presents the project details of the tranches by Executing Agency (EA).

Table 1.3 Project Details of the Tranches by Executing Agency

Tranche Project Description Executing Agency Component 1 Conversion of OCGT in Baghabari Bangladesh Power (100 MW to 150 MW), Sylhet (150 MW Development Board (BPDB) to 225 MW), and Shahjibazar (70 MW to 105 MW) into CCGT Conversion of OCGT in Khulna (150 North-West Power MW to 225 MW) into CCGT Generation Company Limited (NWPGCL) Component 2 Installation of three new transmission Power Grid Company of line at Mymensingh to Tangail (100 Bangladesh Limited (PGCB) km), Brahmanbaria to Narshingdi (57 km), and Chandraghona to Khagrachari through Rangamati (80 km) 1 New substations at Rangamati and Khagrachari Improvements to existing substations in Tangail, Mymensingh, Brahmanbaria, Narshingdi, and Chandraghona Component 3 Capacity building on two main Ministry of Power, Energy activities: (i) provision of resources and Mineral Resources for the preparation of subsequent (MPEMR) tranches (Tranche 2 and Tranche 3); and, (ii) strengthen the institutional capacity of Executing Agencies for better systems management.

9. A Project Management Unit (PMU) will be set up in each EA headed by a PMU Manager who will be responsible for reporting all subproject-related issues to the Chairman and Managing Director of each EA. The PMU will consist of technical, financial, and procurement staff while safeguards support will be hired, as and when required.

10. An Investment Program Coordinating Committee (IPCC), chaired by the Secretary, MPEMR, will be established who will be responsible for coordinating the overall implementation of the Investment Program. Members of IPCC will be the Chairman and Managing Directors of the EAs, and the Additional Secretary of the Power Division, MPEMR. The MPEMR will conduct the review and due diligence of new project proposals submitted by the EAs prior to approval, and will monitor the performance and improvement in service delivery of the EAs. If necessary, consulting services will be provided to the PMU as support to supervision of technical due diligence process, safeguards due diligence, monitoring, and reporting. Figure 1.1 shows the overall implementation structure of the Investment Program.

Figure 1.1 Implementation Structure of the Investment Program

1.2 Environmental Requirements for Tranche 1

11. ADB and the cofinancing institutions have agreed that the Investment Program will adopt ADB's Safeguard Policy Statement 2009 (SPS 2009) as the unified environmental assessment and planning process for consultation, disclosure requirements and safeguard documentation to meet the safeguard principles and requirements of both ADB and the cofinanciers. Thus, the environmental policies and review procedures of ADB and the GOB will apply to all projects funded by the MFF which includes this Tranche 1.

12. According to SPS 2009, Tranche 1 is classified as Category B on environmental safeguard requiring the preparation of an initial environmental examination (IEE). 2 However, for existing facilities as in Component 1, an environmental audit is required (para. 10, Appendix 1, p32).

13. In the national environmental regulations set forth by the Environment Conservation Act (ECA) of 1995 and Environment Conservation Rules (ECR) of 1997, power projects are within the red category requiring both an IEE to secure the site clearance from the Department of Environment (DOE) and an environmental impact assessment (EIA) to get the environmental clearance certificate (ECC) after obtaining the site clearance.

14. PGCB contracted the Center for Environmental and Geographic Information Services (CEGIS) to prepare the IEE of Component 2 following the requirements of DOE in obtaining the site clearance certificate.

2 ADB, Safeguard Policy Statement, June 2009, para. 50, p.19.

15. The environmental audit for Component 1 and the IEE for Component 2 were prepared to meet the requirements of SPS 2009 with technical support from eGen Consultants Ltd.3 The IEE prepared by CEGIS for DOE was referred to in the preparation of the IEE for Component 2. Figure 1.2 shows the location map of Tranche 1.

Figure 1.2 Location Map of Tranche 1

3 ADB, TA 7889-BAN: Power System Efficiency Improvement Project II approved on 17 October 2011 for $700,000.

1.3 Structure of the Report

16. Section 2.0 presents the policy, legal, and administrative framework applicable to Tranche 1, Section 3.0 discusses the environmental due diligence for Component 1 and Section 4.0 presents the IEE for Component 2.

2.0 POLICY, LEGAL, AND ADMINISTRATIVE FRAMEWORK

2.1 National Environmental Requirements

17. The following presents the regulatory agency, process, regulations and international environmental agreements relevant to the Investment Program.

2.1.1 Environmental Authority

18. The Ministry of Environment and Forests (MOEF) is the agency of the GOB in planning, promotion, coordination and overseeing the implementation of environmental and forestry programs. MOEF oversees all national environmental matters and is responsible for activities such as prevention and control of pollution, forestation and regeneration of degraded areas and protection of the environment, and in the framework of legislations. MOEF also conducts surveys, impact assessment, control of pollution, research, and collection and dissemination of environmental information and creation of environmental awareness among all sectors in Bangladesh.

19. The DOE, created in 1989 under the MOEF, is the primary government authority mandated to regulate and enforce environmental management regulations to ensure sustainable development and to conserve and manage the environment of Bangladesh. DOE executes MOEF duties on-the-ground through the consistent application of environmental rules and regulations, and provide guidance, training and promotional campaign on improving the awareness of environmental issues.

2.1.2 Applicable Environmental Regulations

20. The Bangladesh Environment Conservation Act (ECA) of 1995 (amended in 2000 and 2002) provides for the protection of the environment, improvement of environmental standards, and the control and abatement of environmental pollution. This Act authorizes the DOE to undertake any activity needed to conserve and enhance the quality of environment and to control, prevent and mitigate pollution. The Environment Conservation Rules (ECR) of 1997 (adopted under the provision of ECA 1995 and amended in 2002 and 2003) provides rules related to the declaration of ecologically-critical areas, obtaining environmental clearance certificate, environmental quality standards, acceptable limits for discharges of waste, and environmental guidelines on pollution prevention. ECA 1995 and ECR 1997 outline the regulatory mechanism to protect the environment in Bangladesh.

21. Environmental Clearance Section 12 of ECA 1995 provides that no industrial unit or project can be established or undertaken without obtaining an environmental clearance certificate (ECC) from the Director General, DOE. Following the ECR 1997, DOE has classified development interventions based on potential adverse environmental impacts for the purpose of issuing the ECC as (i) green, (ii) orange A, (iii) orange-B, and (iv) red.

22. Securing the ECC from the DOE has two steps: (1) site clearance certificate is obtained at the initial stage and (2) the ECC at the advanced stage. ECC is required for all the categories (i.e., green, orange A, orange B, and red). A site clearance and ECC

7 are required for industries/projects in the categories: orange A, orange B, and red. Appendix 1 gives the complete list of industries according to category. The DOE will issue the ECC for green projects within 15 days upon receipt of application while the site clearance for orange A projects will be issued within 30 days upon receipt of application and 60 days for orange B and red categories. The ECC of green projects is valid for three years. Once the site clearance is obtained for orange A, orange B, and red projects, the ECC can be applied. DOE will issue or disapprove the ECC for orange A projects within 15 days and within 30 days for orange B projects while for red category, it will be within 60 working days. The ECC is valid for one year subject to compliance of the conditions and must be renewed 30 days prior to the expiry date.

23. Green industries or projects are considered to be relatively pollution-free, thus, no environmental study will be required. However, a no objection certificate (NOC), normally taken from the local authorities, are required to be submitted to the DOE including a general information about the project/industry, and a description of the raw materials and finished products.

24. To obtain the site clearance, projects or industries within the orange A category are required to submit general information, NOC, feasibility report, description of raw materials and finished products, process flow diagram, lay out plan, and effluent disposal system.

25. For orange B category, the application for site clearance and ECC includes the feasibility report, IEE, environmental management plan (EMP) for existing industry, a NOC, pollution minimization plan, and an outline of relocation plan.

26. Red category are industries/projects which may cause significant adverse environmental impacts and therefore, require an environmental impact assessment (EIA). Power projects fall within the red category. The documents required for site clearance are feasibility report, IEE (the TOR for conducting the EIA is included in the IEE), EMP for existing industry, NOC, a pollution minimization plan including emergency plan for mitigation of adverse environmental impacts, and an outline of relocation plan (where applicable). After the issuance of the site clearance, the EIA is submitted in applying for the ECC. Figure 2.1 shows the process of environmental clearance application to DOE and the documents required.

Figure 2.1 DOE Application Process for Securing ECC

27. Other environmental regulations are as follows:

(i) Environment Court Act 2000 (amended in 2002) is under the Judiciary and MOEF to ensure the completion of environment-related legal proceedings effectively. (ii) Vehicle Act 1927, the Motor Vehicles Ordinance 1983, and Bengal Motor Vehicle Rules 1940 are under the Bangladesh Road Transport Authority which regulates vehicular emissions and noise including road safety. (iii) Factories Act 1965 and Bangladesh Labour 2006 are under the Ministry of Labour which provides for the occupational rights and safety of factory workers and the provision of comfortable work environment and reasonable working conditions. (iv) The Forest Act 1927 (amended in 1982 and 1989) is under the MOEF to protect forest resources. (v) Energy Policy 1996 is under the MPEMR which underscores the environmental protection by requiring an EIA for any new energy development project. (vi) Telegraph Act 1885 is under the Ministry of Posts and Telecommunication which provides that the GOB can build towers on public land without giving any land compensation (vii) Electricity Act 1910 is the law relating to the supply and use of electrical energy, and which allows any person to secure a license to supply energy and to put down or place electrical supply lines for the transmission of energy. Sect 19(1) of the Act provides that the licensee, in the exercise of any of the powers conferred by or under this Act, will cause as little damage, detriment and inconvenience as

may be, and will make full compensation for any damage, detriment or inconvenience caused by him or by any one employed by him.

28. Appendix 2 and Appendix 3 present the relevant environmental regulations and environmental quality standards in Bangladesh, respectively.

2.1.3 Relevant International Environmental Agreements

29. The following is a list of applicable international environmental agreements that can provide guidance during the implementation of Tranche 1:

Convention Concerning the Protection of the World Cultural and Natural Heritage (Paris 1972) – this convention was accepted in Bangladesh on 3 August 1983 and ratified on 3 November 1983. This Convention defines and provides for the conservation of the world`s heritage by listing the natural and cultural sites whose value should be preserved. Existing list can referred to, if available, to avoid impacts in areas with cultural and natural heritage value. Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar 1971) – ratified on 20 April 1992 and which provides a framework for national action and international cooperation for the conservation and sustainable use of wetlands and their resources. Bangladesh has two Ramsar sites, the Tangauar Haor (Northeast of Bangladesh) and parts of Sundarban Reserved Forest (Southwest of Bangladesh). Tranche 1 will avoid these two identified Ramsar sites. Convention on International Trade in Endangered Species of Wild Fauna and Flora (Washington 1973) – also known as CITES was signed on 20 November 1981. This Convention provides a framework for addressing the overharvesting and exploitation patterns that threaten species of flora and fauna. Under the Convention, the governments agree to restrict or regulate trade in species that are threatened by unsustainable patterns. Tranche 1 will ensure that it will not cause any harvesting and exploitation of wild flora and fauna during construction and operation. Convention on Biological Diversity (1992) – entered into force on 29 December 1993 and ratified on 20 March 1994. This provides for a framework for biodiversity and requires signatories to develop a National Biodiversity Strategy and Action Plan. Tranche 1 will refer to the applicable National Biodiversity Strategy and Action Plan to ensure that any replacement to cleared vegetation resulting from the project will be consistent with the objectives and priorities of the Action Plan. Convention on the Conservation of Migratory Species of Wild Animals (Bonn 1979) – this sets the framework for agreements between countries important to the migration of threatened species. Tranche 1 will avoid areas known to be habitat of migratory species of wild animals.

2.2 Environmental Requirements of Asian Development Bank and Cofinancing Institutions

30. This section provides the salient points of the environmental requirements of ADB and the cofinanciers.

2.2.1 Asian Development Bank

31. The environmental requirements are embodied in SPS 2009 which applies to all projects funded by ADB. SPS 2009 covers three key safeguard areas: environment, involuntary resettlement, and indigenous peoples, and aims to avoid adverse project impacts to both the environment and affected people; minimize, mitigate and/or

10 compensate for adverse project impacts, and help Borrowers to strengthen their safeguard systems and to develop their capacity in managing the environmental and social risks. The environment assessment and review procedures require for analysis of alternatives, meaningful consultation, timely information disclosure, environmental management plan and monitoring, setting up of grievance redress mechanism, biodiversity conservation and sustainable natural resource management, pollution prevention and abatement, inclusion of occupational and community health and safety, and avoiding damage to physical cultural resources.

32. During the identification and screening of projects, ADB uses a categorization system to indicate the significance of potential environmental impacts and is determined by the category of its most environmentally-sensitive component, including direct, indirect, cumulative, and induced impacts within the project's area of influence. The project categorization system is given below:

Category A – an environmental impact assessment (EIA) is required for a project that is likely to have significant adverse environmental impacts that are irreversible, diverse, or unprecedented, and may affect an area larger than the sites or facilities subject to physical works.

Category B – an initial environmental examination (IEE) is required for a project that is likely to have adverse environmental impacts that are less adverse than those of Category A which are site-specific, few if any of them irreversible and in most cases mitigation measures can be designed more readily than Category A.

Category C – no environmental assessment is required but environmental implications will be reviewed for a project that is likely to have minimal or no adverse environmental impacts.

Category FI – if a project involves investment of ADB funds to or through a financial intermediary.

2.2.2 European Investment Bank

33. In 1996, the European Investment Bank (EIB) adopted an Environmental Statement (revised in 2002 and 2004) to underscore its commitment to protecting and improving the natural and built environment according to the policy of the European Union (EU). From the Environmental Statement in 1996, it was further developed into the Statement of Environmental and Social Principles and Standards 20094 ("the Statement"), approved on 3 February 2009 which presents the environmental and social requirements of EIB to projects it finances giving greater emphasis than before to its social requirements. Following these principles, EIB screens and classifies project according to their potential environmental impacts.

34. Based on desktop review of available documents such as technical documentation related to pollution control and criteria, planning documents, previously prepared assessment reports, project-related environmental studies, etc., a checklist is used to initially screen the environmental issues. Project classification is as follows:

4 EIB. The EIB Statement of Environmental and Social Principles and Standards 2009. http://www.eib.org/about/news/eib-statement-of-environmental-and-social-principles-and-standards.htm. (Accessed 28 June 2012)

Categorization Definition A Minimal or no adverse impacts - Low risk Local and short-term negative environmental and associated social impacts and for which B effective mitigation measures are readily available - Low to moderate risk C Significant adverse environmental and social impacts which are complex, sensitive and diverse, have a wide area of influence or are long-term - Moderate to high risk D Not acceptable in EIB terms

35. The EIB aims at high level of environmental protection based on precautionary principle, preventative action that environmental damage be rectified at source taken at an early stage, and on polluter pays principle. Meaningful consultation is required to be conducted as early as possible in the project assessment with transparency and culturally- appropriate to the affected communities. For projects outside of the EU, the national law sets the minimum disclosure, consultation and participation requirements of EIB (para. 63, p20 of Statement). A person affected (or perceived to be affected) by any decision of EIB can file a complaint to its Secretary General, either in writing or through internet and whose complaint(s) is centrally-handled and registered by its Complaints Office.

36. EIB has environmental standards intended to protect and enhance natural environment, economic development and social well-being resulting from environmental sustainability. The environmental standards include emission, ambient, and procedural standards. The requirements for environmental assessment is governed by EU EIA Directive 85/337/EEC where

37. Aside from the Statement, the Environmental and Social Practices Handbook 2010 of EIB provides advice on planning and managing the environmental and social appraisal and monitoring.5 The Handbook describes the steps to determine the scope of the environmental and social review process throughout the project cycle and the overall internal processes and practices of EIB to ensure that its financing activities are consistent with its environmental policy.

38. For projects that involve cofinancing, the Statement provides that EIB can agree to apply the standards of other international financial institutions if deemed equivalent to their requirements (para. 23, p.9 of the Statement)

2.4.2 Islamic Development Bank

39. Established in December 1973, the Islamic Development Bank (IDB) is an international financial institution which aims to foster economic development and social progress of member countries and Muslim communities.6 The operations manual of the IDB provides guidance in addressing the environmental issues of the projects it finances. The guide emphasizes that the effects of the project on the environment and ecology in the area need to be assessed in all Projects Appraisal together with the measures to minimize any resulting adverse impacts.

5 EIB. Environmental and Social Practices Handbook 2010. http://www.eib.org/infocentre/publications/all/environmental-and-social-practices-handbook.htm. (Accessed 28 June 2012) 6 IDB. About IDB. http://www.isdb.org/irj/portal/anonymous?NavigationTarget=navurl://24de0d5f10da906da85e96ac356b7af0. (Accessed on 28 June 2012)

IDB is still in the process of preparing its Statement on Environmental and Social Safeguards Principles, and Commitments to Environmental and Social Responsibility.7

2.4.3 l’Agence Française de Développement

40. l’Agence Française de Développement (AFD) is a bilateral development financial institution established in 1941 to fund development projects on behalf of the French government based on its policies for overseas development assistance.

41. In January 2007, AFD formally adopted the following as reference framework for its social and environmental responsibility procedures:8

1. Universal Declaration of Human Rights 2. Conventions of the International Labour Organization 3. Three Rio Conventions 4. Anti-corruption conventions of the OECD and the United Nations including the international anti-money laundering rules

42. AFD subscribes to the principle of continuous assessment and monitoring of environmental and social impacts from processing to ex post evaluation in its financing operations.

43. Table 2.1 presents a comparison of the environmental requirements focusing on ADB, EIB, and GOB.

Table 2.1 Brief Comparison of Environmental Requirements

Project Stage ADB EIB GOB Screening and Uses sector-specific rapid Uses environmental ECA 1995 and ECR Categorization environmental assessment eligibility criteria for 1997 set screening checklist for screening financing criteria to classify assigns categories based Uses Checklist of industries/projects on potential impacts: Environmental and Social based on potential A - EIA required Issues for Screening environmental impacts (irreversible, diverse or Project categorization as follows: unprecedented adverse based on potential Green, Orange A, environmental impacts) environmental impacts as Orange B and Red. B - IEE required follows: These screening criteria C - no environmental A - minimal or no are based on project or assessment required but a adverse impacts (Low industry type and do not review of environmental risk) consider the scale and implications B - local and short-term location. The category FI - ESMS required negative environmental determines the level of and associated social environmental impacts and for which assessment. effective mitigation measures are readily available (Low to moderate risk) C - significant adverse environmental and social

7 IDB. Statement by Dr. Ahmad Mohamed Ali, President, IDB. United Nationas Conference on Sustainable Development (Rio +20), 20-22 June 2012. http://www.isdb.org/irj/go/km/docs/documents/IDBDevelopments/Internet/English/IDB/CM/About%20IDB/Pre sident%20IDB%20Group/PS_UN_ConferenceSustainableDevelopment_20June2012.pdf. (Accessed on 28 June 2012) 8 AFD. Social and environmental responsibility. http://www.afd.fr/lang/en/home/AFD/L-AFD-s- engage/responsabilite-sociale-environnementale-afd. (Accessed on 28 June 2012)

Project Stage ADB EIB GOB impacts which are complex, sensitive and diverse, have a wide area of influence or are long- term (Moderate to high risk) D - not acceptable in EIB terms Environmental Identify potential impacts Strategic Environmental Industry/project category Assessment on physical, biological, Assessment (SEA) Green - no physical cultural resources, required for plans and environmental and socioeconomic aspects programmes which are assessment required in the context of project's likely to have significant Orange A - no IEE or EIA area of influence (i.e., effects on environment required but must primary project site and provide process flow, facilities, and associated Requirement for lay-out showing effluent facilities) environmental assessment treatment plant, etc. is guided by EU EIA Orange B - IEE required Directive 85/337/EEC Red - both IEE and EIA (amended by Directives are required 97/11/EC and 2003/35/EC) Assess the direct and indirect effects of a project on the following factors:  human beings, fauna and flora,  soil, water, air, climate and the landscape,  the inter-action between the factors mentioned in the first and second indents,  material assets and the cultural heritage. Assessment to include cumulative direct and indirect impacts Identify and address significant transboundary impacts Analysis of For projects with potential Requires assessment of Regulations (i.e., ECA Alternatives significant impacts (i.e., project alternatives 1995 and ECR 1997) do Category A) not require specifically Examine alternatives to the identification and the project's location, analysis of alternatives design, and technology Document rationale for selecting the particular project location, design, and technology Consider "no project" alternative Meaningful Starts early and continues Nature and magnitude of Public consultation Consultation during implementation stakeholder interests and participation are not Undertaken in an should be established mandatory based on atmosphere free of Include how the main ECA 1995 and ECR intimidation concerns of stakeholders 1997 Gender inclusive and will be dealt with in terms responsive of mitigation or Tailored to the needs of compensation measures vulnerable groups and how these will be Allows for the monitored during incorporation of all implementation relevant views of Clarify if any legal

Project Stage ADB EIB GOB stakeholders proceedings are ongoing against the project as part of EIA Negative campaign on the project should be noted in the Overall Environmental and Social Assessment Form D1 and the Environmental and Data Sheet Information ADB will post in its website Makes Non-technical No requirement for Disclosure the following: Summary (NTS) of EIA disclosure but DOE Draft EIA report posted available to public through posts the Minutes of the on ADB website at least electronic links in Project Meeting on the 120 days prior to Board List to the Borrower's application for consideration website at a minimum of environmental clearance Draft EA/EARF prior to 30 days prior to Board certificate to its website, appraisal consideration http://www.doe- Final or updated EIA/IEE Borrower responsible for bd.org/minutes.php upon receipt making the EIA and NTS Environmental monitoring publicly available in a report submitted by language appropriate for borrowers upon receipt consultation Grievance Redress Establish a mechanism to Complaints from affected Grievance redress Mechanism receive and facilitate people are lodged to the mechanism is not resolution of grievances or Secretary General and mentioned in the complaints dealt with by the regulations Complaints Office that ensures a centralized handling and registration of complaints. Use of Refers to Environmental Includes emission, Ambient and emission Environmental Health and Safety ambient and procedural standards included in Standards Guidelines 2007 standards from the ECA 1995 and ECR If national regulations Integrated Pollution 1997 differ, more stringent will be Prevention and Control, Occupational health followed European Union (EU) and safety standards If less stringent levels are directives, and sector included in the Factories appropriate in view of Framework Directions Act 1965 and specific project Bangladesh Labour Law circumstances, provide full 2006 and detailed justification Monitoring and Prepare monitoring reports Regular progress reports ECC is subject to Reporting on the progress of EMP containing results of annual renewal based Retain qualified and environmental on compliance of the experienced external monitoring, conditions set in the experts or NGOs to verify implementation of ECC. monitoring information for mitigation measures, Category A projects record of complaints Prepare and implement Completion Report on corrective action plan if compliance to non-compliance is identified environmental Requires submission of regulations and quarterly, semiannual, and implementation of annual reports to ADB for mitigation measures, and review environmental monitoring

3.0 COMPONENT 1 – EFFICIENCY IMPROVEMENT OF POWER PLANTS

3.1 Introduction

44. Component 1 will involve the conversion of existing 470 MW open-cycle gas turbine (OCGT) power plants in Khulna (150 MW), Baghabari (100 MW), Sylhet (150 MW) and Shahjibazar (Units 8 and 9, 2x35 MW) into combined-cycle gas turbine (CCGT) system increasing the total installed capacity to 705 MW. Without additional natural gas inputs, the conversion from OCGT to CCGT will result to an increase of 235 MW power generation capacity. Table 3.1 presents the component summary.

45. Heat from the exhaust gas (with temperature ranging from 550oC to 565oC) of the existing OCGT power plants will be used to produce steam through a heat recovery steam generator to run a steam turbine generating additional electricity. Cooling system will be provided by cooling towers with cooling water taken from groundwater and river water. After heat is extracted from the exhaust gas, the final exit gas temperature will vary from 160oC to 165oC. Figure 3.1 shows the process flow of a combined-cycle power plant while Figure 3.2 shows the location map of Component 1.

Table 3.1 Summary of Component 1

Additional Capacity Present Power Capacity after Power Status of Power Capacity Owner Plant with Heat conversion Plant Plant as OGCT Unit Recovery into CCGT (MW) (MW) (MW) Under construction and expected for Unit 1 Khulna NWPGCL 150 75 225 commissioning in (1x150) June 2013 Commissioned in BPDB 100 Unit 2 150 Baghabari 50 2001 Commissioned on BPDB 150 Unit 1 225 Sylhet 75 24 March 2012 (1x150) Commissioned in BPDB 2x35 Unit 8 and 105 Shahjibazar 35 2000 Unit 9

Source: IEE of 225 MW Khulna Power Plant, March 2012, NWPGCL

Figure 3.1 Process Flow of Combined-Cycle Power Plant

46. The primary objectives of converting the existing OCGT power plants into CCGT power plants are:

(i) to increase power generation through the use of exhaust gas from the existing power plants; (ii) to increase the efficiency from about 36% to 51%; and, (iii) to overcome present generation shortage, minimize load shedding, and catalyze economic development through the availability of adequate and reliable power.

47. BPDB is responsible for power generation, transmission, and distribution in Bangladesh. Due to Power Sector Reform Program in 2007, BPDB was restructured resulting to the creation of North-West Power Generation Company Ltd (NWPGCL), as an enterprise of BPDB, to construct, operate, and maintain the power generation facilities in the North-Western Zone of Bangladesh.9 The 150 MW Khulna Power Plant is one of the power generation facilities in the North-Western Zone and is part of the ongoing Asian Development Bank (ADB) Loan 2333/2332-BAN: Sustainable Power Sector Development Program approved on 26 June 2007.

48. As required by para. 10, Appendix 1 (p32) of SPS 2009, an environmental audit of the existing power plants was conducted as part of the environmental assessment (see Appendix 4).

9 ADB Loan 2333/2332-BAN: Sustainable Power Sector Development Program approved on 26 June 2007.

Figure 3.2 Component 1 Location Map

3.2 Description of the Existing Facilities

3.2.1 Shajibazar Power Plant (2x35 MW)

49. The Shahjibazar Power Plant is located in Madabpur Upazila, Hobiganj District, Sylhet about 140 km northeast of Dhaka City within a property of about 24.3 hectares (has) owned by BPDB. Of the 24.3 has, about 20.6 has is plain land and approx. 3.6 has is hilly area. The power station, office building, residential areas for staff, school and other amenities are located within the plain land while the residential areas of management staff and a rest house are in the hilly section of the property.

50. Shahjibazar Power Plant consists of a total of nine gas turbine units with varying capacity. The first unit (Unit 1, 14.8 MW) was commissioned in 1968 and six more gas turbine units (Unit 2 to Unit 7) were commissioned in 1969. In 2000, additional two gas turbine units (Unit 8 and Unit 9 at 35 MW each) started operating. The total capacity of Shahjibazar Power Plant is 174.4 MW but since August 2011, only Unit 8 and Unit 9 are operating.

51. Unit 1 (14.8 MW), Unit 3 (14.8 MW), and Unit 7 (15 MW) with a total capacity of 44.6 MW were retired in 1996. Rehabilitation and overhauling are required for Unit 2 (14.8 MW) and Unit 4 (15 MW). In August 2011, Unit 5 (15 MW) and Unit 6 (15 MW) stopped operating due to rotor grounding. Exhaust gas from each unit is discharged through a 15- m stack height.

52. The natural gas fuel is supplied from the Hobiganj Gas field located about 2 km from the power plant and the transmission of power generated from Shahjibazar Power Plant is through the 132/33 kV grid substation located within the property. Given the climate in Bangladesh, the power station was designed to withstand wind loadings of up to 62.6 m/s.

53. Other power plants within the BPDB property where Shahjibazar Power Plant is located include rental power plant units of 86 MW (with 15 year tenure) and 50 MW (with 3-year tenure but extended until 5 years). These power plants are rented by BPDB to generate power to meet the increasing demand but are privately owned and operated. Part of the Dhaka-Sylhet Railway passes through Shahjibazar Power Plant at the east side section and a branch line is connected to a railway carrier within the power station with a capacity of 70 tons. Figure 3.3 shows the general layout of Shahjibazar Power Plant.

Source: Shahjibazar Power Plant Technical Office, April 2012

Figure 3.3 General Layout of Shahjibazar Power Plant

54. Existing Environment The region has two marked seasons: rainy from May to October, and dry from November to April. November to February is the coolest and driest period; March to May is the hottest with periodic severe thunderstorms; June to mid- September is the most rainy and humid period, and mid-September until November is the transition with decreasing rainfall. Based on the meteorological data collected by Bangladesh Meteorological Department (1980-2010), the average annual rainfall is 242 cm. The highest average monthly rainfall occurs in May and June at about 450 mm while the driest month is January at only 5 mm.

55. Average monthly relative humidity varies from 77% to 84% while average monthly temperature ranges from about 6.5oC in January to 35.8oC in April. There are no major water bodies adjacent to Shahjibazar Power Plant and there were no records of flooding events. The nearest is Sutang River which is 4 km away and flowing at the eastern side of Shahjibazar Power Plant.

56. Bangladesh is divided into three seismic zones: Zone I – severe or major damage (seismic factor is 0.08g), Zone II – moderate damage (seismic factor is 0.05g), Zone III – minor damage (seismic factor is 0.04g). The Shahjibazar area falls within Zone III (minor damage).

57. Shahjibazar Power Plant is not located near or adjacent to forests or protected areas. Land use is a mix of agricultural, industrial, and residential. Industries include cotton mill, soap factory, candle factory, etc. Main crops are paddy rice, potato, jute, mustard, and pulse. Employment is primarily agriculture.

3.2.2 Baghabari Power Plant (100 MW)

58. The 100 MW Baghabari Power Plant (Unit 2) is located within the existing premises of the Baghabari Power Plant complex in Shelachapri Mouza, Shahzadpur Upazila, Serajganj. Baghabari Power Plant is about 100 km northwest of Dhaka City.

59. Prior to commissioning of Unit 2 in 2001, the Baghabari Power Plant complex has the existing 71 MW Baghabari Power Plant (Unit 1) and the 90 MW barge-mounted power plant owned by Westmont Power (Bangladesh) Ltd. (WPBL). In September 2011, another 50 MW (6x8.52 MW) was commissioned by BPDB to operate during peak load and has the capability for dual firing using heavy fuel oil and natural gas as fuel. The total generating capacity within the Baghabari Power Plant complex is 311 MW.

60. The Baghabari Power Plant complex is close to Boral River and northwest of Karotoa River. Karotoa River is a tributary of Jamuna River. These rivers are not used to supply the water requirements of Baghabari Power Plant (Unit 2) as it uses closed loop cooling system with demineralized water supplied by the Westmont Power (Bangladesh) Ltd. Fuel is natural gas supplied through the Jamuna Bridge but the power plant was designed to have dual firing. Power transmission is through the 132 kV substation and another 230 kV substation of PGCB is adjacent to the Baghabari property. There is an oil- water separation system to deal with oily wastes generated by the operation of the power plant and is equipped with fire fighting system in case of emergency.

61. Other structures within the property but separated from the power stations are residential areas, officers building, conference hall, guest house, primary school (until 5th Grade), a mosque, open space that serves as park, and a medical clinic. The total area is about 19.3 ha which consists of the existing power plant (Unit 1 and Unit 2) and amenities (12.1 ha), the new 50 MW (2.2 ha), and the proposed area for conversion to CCGT (5 ha).

62. Existing Environment Mean annual rainfall in the area reaches up to 1800 mm occurring in July and August and a relative humidity varying from 71% to 86% which normally occurs in July and February, respectively. Mean annual temperature ranges from 18oC to 29oC. Wind speed varies from 1.4 m/s to 3.2 m/s coming from the south during monsoon and northwest during the winter season.

63. There are no forests or any protected areas near the existing Baghabari Power Plant complex. Existing land use within the area is a mixed of industrial, commercial and residential uses. There is no record of wild animals and endangered species found within the area as it is now generally a modified habitat. The Karotoa River and the Boral River are generally used for navigation, general purpose washing, watering of plants and other crops, and subsistence fishing. It provides habitat for a variety of fish such as carp (Rui, Katal, Mrigel, Ghania, Kalibaus, etc). Unit 2 of the Baghabari Power Plant does not use the rivers for its operation.

3.2.3 Sylhet Power Station (150 MW)

64. The Sylhet Power Plant is located in Sylhet City and about 270 km from Dhaka City. It started commercial operation on 26 March 2012. Sylhet Power Plant is within the 7.3 ha Kumargaon Power Station complex owned by BPDB. Figure 3.4 shows the general layout of Sylhet Power Plant.

65. The Sylhet Power Plant has no capability for dual firing and uses natural gas for fuel with low NOx combustion system. It is also equipped with continuous emissions monitor system that records parameters such as temperature, gas flow, gas pressure, CO, O2 and CO2. The exhaust gas is discharged from a 42-m stack height. The air intake system and stack are equipped with silencer to suppress noise level. There is an existing 132 kV substation within the power complex for power transmission.

66. The drainage system consists of sewage water system, rainwater system, and oily wastewater. All drains or channels are concrete-lined. There is an emergency oil collection system to serve as emergency oil pit in the transformer area to drain in the emergency oil basin for storage. The closed cooling water system (CCWS) is provided by two draft cooling towers with make-up water supplied by two deep wells. The CCWS is also equipped with a chemical dosing to prevent corrosion, material deposition, and the growth of algae and fungus. The dosing system consists of NaClO dosing complete with a set for disinfection, scale inhibitor, and sulphuric acid dosing for deposition control.

Source: IEE for 150 MW Sylhet Power Plant, January 2010, BPDB

Figure 3.4 General Layout of Sylhet Power Plant

67. Aside from the 150 MW Sylhet Power Plant, there are other power plant units within the Kumargaon Power Station complex. These are the 20 MW gas turbine operated by BPDB and two rental power plant units with a capacity of 50 MW and 10 MW, respectively. Amenities within the power station include mosque, playground, and residential areas.

68. Existing Environment The existing land use within the Sylhet Power Plant is a mix of residential, commercial and industrial uses. Temperature varies from 5.7oC to 38.8oC with annual average relative humidity of 77.8%. Average annual rainfall is about 3,334 mm occurring between May and September. There are no forests or protected areas near the Sylhet Power Plant.

69. The nearest surface water to Sylhet Power Plant is Surma River which is mainly used by local people for agricultural purposes and navigation but is not used for power plant operation.

3.2.4 Khulna Power Station (150 MW)

70. The Khulna Power Plant is still under construction within the premises of the existing Goalpara Power Station Complex in Goalpara, Khalispur Upazila, Khulna. Goalpara Power Station is one of the oldest power complex in Bangladesh which started operation in 1954. It is about 170 km southwest of Dhaka City and is expected to be commissioned in June 2013. Goalpara Power Station complex is bounded on the west by residential areas, on the north by the Padma Oil depot, on the east by a graveyard, and on the south by commercial areas. The total land area is about 24.3 ha. Figure 3.5 presents the location map of Khulna Power PLant.

71. The Khulna Power Plant has dual firing capability (i.e., natural gas and high speed diesel) and will use the Bhairab River as source of cooling water which runs along the east side of the Goalpara Power Station complex. Two diesel storage tanks will be built on-site. Natural gas will be supplied through the Ishurdi-Khulna gas pipe line system from the City Gate Station. It will use low NOx burner to minimize formation of NO2 and will be equipped with a 60-m smokestack. Power transmission will be through underground cable connection from the Khulna Power Plant to the Khulna Central Substation which is about 4 km.

Source: EIA Final Report, 150 MW Khulna Power Plant, March 2010, NWPGCL

Figure 3.5 Location Map of Khulna Power Plant

72. The fire fighting system is equipped with a two-hour fire water supply and fuel oil tanks are furnished with foam fire fighting systems. There are other power plants within the Goalpara Power Station complex as follows:

1) 40 MW rental power plant owned by Aggreko Ltd which started operation in September 2008 and uses diesel as fuel 2) 110 MW power plant owned by BPDB which started operating in 1984 and uses heavy fuel oil (also referred to as furnace oil) for fuel 3) 60 MW power plant owned by BPDB which started operating in 1973 and uses heavy fuel oil for fuel 4) 115 MW power plant owned by Khulna Power Company Ltd and Summit & United Group which started operating in June 2011 and uses heavy fuel oil as fuel 5) 110 MW power plant owned by Khulna Power Company Ltd and Summit & United Group which started operating in October 1998 using heavy fuel oil as fuel

73. Other amenities within the power station complex are primary school and a high school, a 5-bed hospital with ambulance facilities, an employee club, and an officer’s club.

74. Existing Environment Land use within the area is a mix of heavy industrial area, commercial and residential. There are no forests or protected areas near the power complex. The average monthly maximum temperature ranges from 25.1oC to 35.9oC with highest occurring in April and the coldest in January. Monthly average relative humidity is from 68.7% (April) to as high as 85.3% occurring in July, August and September. Annual average rainfall is about 1,414 mm with a highest monthly rainfall in September 2008 (379 mm) and the month without rainfall is November.

75. Wind direction during the monsoon season (June to September) is from the south-southwest and changes in November until February towards the north-northwest direction. Maximum windspeed was recorded in October 2008 at 5.3 knots. Bangladesh is divided into three seismic zones: Zone I – severe or major damage (seismic factor is 0.08g), Zone II – moderate damage (seismic factor is 0.05g), Zone III – minor damage (seismic factor is 0.04g). The Goalpara Power Station complex falls under Zone III.

3.3 Audit and Site Investigation Procedure

76. The audit and site investigation for the conversion of the existing OGCT power plants was conducted through review of available relevant project documents, site visits to the power plants, and meetings and interviews with key management and technical staff of BPDB and NWPGCL at the Corporate Offices in Dhaka and in the power plants. The site visits and persons met during the site investigations are given in Appendix 4.

3.4 Findings and Areas of Concern

77. All the existing OCGT power plants are located within a power plant complex with several other power plants currently operating and some power plant units non-operating. Table 3.2 presents a summary of findings and areas of concern while the details of site investigations are given in Appendix 4.

Table 3.2 Summary of Findings and Areas of Concern

Shahjibazar Power Baghabari Power Sylhet Power Khulna Power Description Plant Plant Plant Plant Compliance to national unclear unclear IEE prepared in IEE was environmental compliance to compliance to January 2010 and prepared and regulations environmental environmental site clearance

Shahjibazar Power Baghabari Power Sylhet Power Khulna Power Description Plant Plant Plant Plant regulations regulations site clearance issued by DOE started operation started operation issued by DOE on on 23 May in 2000 but no IEE in September 2001 16 February 2010 2007 or EIA provided but no IEE; EIA no EIA and EIA prepared no site clearance provided ECC provided in March 2010 or ECC provided no site clearance and approved or ECC provided by DOE on 31 May 2010 Environmental no environmental no environmental started monthly monitoring and monitoring reports monitoring reports operation on 26 progress report submission of reports March 2012 submitted by to DOE no EPC to environmental NWPGCL but monitoring reports does not yet include environmental aspects Designated no environmental no environmental no two environmental staff staff staff environmental environmental staff staff (one in the Head Office in Dhaka and one at the project site in Khulna) Safety and security good safety and power plant power plant safety security complex secured separated from posters at the premises well- by high concrete other existing construction fenced wall and barbed power plants at site power station wires Kumargaon with first aid separated from power plant Power Station treatment other amenities separated by fence complex with a center and such as residential from other concrete wall and health areas, mosque, amenities gate personnel school, etc a military entire property onsite contingent secures is secured by high hard hats and the power plant concrete wall and vests provided complex and PGCB metal bars to construction property particularly on the staff technical staff side of Surma labor shed operating the power River and washing plant not wearing there are visible area provided safety gear such as safety posters to workers safety shoes and signs but some posters are not in Bangla but in Chinese some areas have poor drainage with waters accumulated for days Asthetics and solid trees planted at good landscaping there are drainage in waste management and around the with designated construction good condition premises of power areas planted to debris that need storage of plant complex fruit-bearing trees; to be removed as construction uses composting fruits are harvested this may pose materials and and burning of solid are divided among safety risks to waste wastes staff staff management four open considered dumpsites of up to good 10 ft depth to accommodate solid waste

Shahjibazar Power Baghabari Power Sylhet Power Khulna Power Description Plant Plant Plant Plant solid wastes are covered by soil before another layer of garbage is dumped Use of groundwater uses groundwater uses groundwater uses will use for cooling water for domestic groundwater for groundwater for and domestic purposes only cooling water and domestic purposes demineralized domestic purposes (i.e., uses closed water for cooling purposes drinking water cooling water tower provided by a uses closed and sanitation) system private company, cooling water Westmont Power system (Bangladesh) Ltd. Abstraction of fresh does not use does not use river does not use will use the surface water fresh surface water water for power river water for Bhairab River in power plant plant operation due power plant as source of operation to poor quality operation cooling water in the closed system Amenities and/or small hospital, residences for residences for primary school services within the school, mosque, staff and their staff and their and a high power plant complex playground, multi- families, families, mosque, school, a 5-bed purpose conference hall, hospital (under hospital with hall/community guest house, construction), ambulance center, commercial primary school, playground facilities, an area, residences for mosque, open employee club, staff and their space as park, and and an officer’s families, open medical clinic club. space filtration system provides potable water to staff and their families Other structures within Unit 1 to Unit 7 new 50 MW 20 MW 40 MW rental the power plant are non-operating peaking power Kumargaon power plant complex since August 2011 plant near OCGT operated owned by and some units residences which by BPDB Aggreko Ltd since 1968 operates at night, two private (started noise level may rental power plant operation in need monitoring to units of 50 MW September ensure that it is owned by Energy 2008) within the healthy Prima and 10 MW 110 MW and safe level owned by owned by Deshbondu BPDB (started Power operation in 1984) 60 MWowned by BPDB (started operation in 1973) 115 MW owned by Khulna Power Company Ltd and Summit & United Group (stated operation in June 2011) 110 MW owned by Khulna Power Company Ltd

Shahjibazar Power Baghabari Power Sylhet Power Khulna Power Description Plant Plant Plant Plant and Summit & United Group (started operation in 1998) Future plans of existing proposed proposed proposed proposed power plant complex conversion into conversion into conversion into conversion into CCGT to generate CCGT to generate CCGT to CCGT to additional 35 MW additional 50 MW generate generate additional 300 additional 75 MW additional 75 MW CCGT is MW planned to be dismantling of constructed in the 40 MW rental power plant power plant of complex Aggreko Ltd in September 2012 to provide space for the conversion of 150 MW Khulna Power Plant into CCGT

3.5 Anticipated Environmental Impacts and Corrective Action Plan

78. The following section describes the anticipated environmental impacts of converting the OCGT power plants into CCGT power plants and the corrective action plan. Table 3.3 presents the environmental management plan while Table 3.4 presents the environmental monitoring program.

3.5.1 Pre-Construction Phase

Dismantling of 40 MW rental power at Khulna Power Plant

79. The rental contract agreement between Aggreko Ltd and BPDB will expire in September 2012. The space that will be vacated will be the site for the conversion of Khulna Power Plant into CCGT power plant. Dismantling activities may potentially cause temporary disturbance and safety risks within the Goalpara Power Station complex and the residents living near the complex.

80. BPDB will require the Aggreko Ltd to submit a dismantling plan prior to start of any dismantling works describing the activities and measures to ensure public safety. The dismantling plan should cover toxic and hazardous waste management. The dismantling plan will be made available to ADB for review and clearance.

Compliance to national environmental regulations

81. The compliance of existing power plants in Shahjibazar, Baghabari, and Sylhet to the environmental requirements of DOE is unclear. BPDB will ensure that the conversion of power plants in Shahjibazar, Baghabari, and Sylhet comply with environmental requirements of DOE by obtaining the site clearance and ECC prior to any construction works. Both BPDB and NWPGCL will submit the site clearance and ECC to ADB.

Existing non-operational gas turbine units in Shahjibazar

82. Unit 1 to Unit 7 of Shahjibazar Power Plant have been non-operational since August 2011. Some of the units were retired more than 15 years ago. BPDB should determine the best and highest usage of the remaining gas turbine units, if any, including the space where these units are located. A decommissioning plan should be developed by BPDB following international best practices and in compliance to relevant national regulations before any dismantling works commence. Presence of asbestos and asbestos-containing materials (if any) should be dealt with properly to avoid exposure of workers.

3.5.2 Construction Phase

83. Each PMU of BPDB and NWPGCL will ensure that the Contractor's contract will include the obligation to compensate for any temporary damage, loss or inconvenience as result of the project during the construction phase (Sect. 19 of Electricity Act 1910, 1982 Acquisition and Requisition of Immovable Properties, SPS 2009).

84. During the construction phase of power plant conversion, associated civil works include earthworks (excavation, filling and backfilling); foundation for heat recovery steam generator, steam turbine, buildings and other equipment; concrete pavement and gravel surfacing; landscaping and turfing; site protection works for flood and erosion protection; deep well and pump installation; drainage and sewage works; and fencing. Building works may include electrical, plumbing and sanitation installation, floor laying, painting, air conditioning and ventilation system, roofing and brickworks, etc. These project activities may result to the following environmental impacts:

Risk to occupational health and safety from the outbreak of diseases and poor working conditions

85. Contractor(s) will be required to provide sanitary facilities, safe drinking water supply, garbage bins for construction workers, and good drainage system at the constructions camps. An orientation about good hygiene, occupational health and safety, HIV and other diseases will be conducted prior to the start of construction. Drills on emergency such as fire and earthquake will be conducted regularly to develop preparedness among workers in dealing with emergency situations. Workers will be required to wear safety gear and personal protective equipment. Workers failing to comply with this requirement will be given disciplinary action.

86. The temporary sanitary facilities will be located away from settlements and good housekeeping will be imposed. A medical treatment unit will be provided by the Contractor(s) with medical staff (at least a nurse) available at all times. The Contractor (or its designated staff) will ensure that all electrical connections will earth link circuit breaker to prevent electrocution and other accidents. The PMUs will ensure that the Contractor(s) strictly comply with this requirement.

Influx of migrant workers

87. To avoid the influx of migrant workers, priority for hiring will be given to local people for construction works and eligible individuals for technical and non-technical positions.

Public safety risks from transport of construction materials to the site

88. Vehicles transporting construction materials to the site will be covered to avoid spillage. Shahjibazar can use the railway connected to the power plant property as an alternative way of transporting heavy equipment such as turbine while Khulna, Sylhet and

Baghabari can use river transport. Haul roads used that will pass through the residential areas within the power plant complex will be sprayed with water to suppress dust level.

Increased noise and dust levels

89. Vehicles transporting dusty construction materials will be covered to minimize fugitive dusts while concrete batching and mixing plant will be located away from settlements, water bodies, and in downwind direction. Where needed, water will be sprayed to minimize the increase in dust level.

90. To minimize the contribution of construction activities to noise level, works that generate noise (e.g., hammering, piling, etc) will be done during daytime and enclosures will be provided to diesel generator sets (if used due to load shedding in Bangladesh). Workers operating elevated noise-generating equipment and machine will be provided with noise protection such as ear muffs.

Degradation of nearby water bodies

91. otential degradation of nearby water bodies such as Boral River and Kaotoa River in Baghabari, Surma River in Sylhet, and Bhairab River in Khulna may occur due to negligent construction workers. Contractor(s) will ensure that throwing of garbage by workers into the rivers and cleaning/washing of vehicles near these water bodies will not be allowed. Construction materials and excavated soils will be located above the high flood level to ensure that these will not go into the nearby rivers.

Potential contamination from lubricants and fuel oil

92. Works that require the use of lubricants and fuel oil will be done in a concrete workshop area or lined with impermeable material to minimize soil contamination in case of spillage. Fuel storage and refuelling areas will be located away from Surma River, Boral, River, Bhairab River, and Karotoa River to prevent contamination in the event of oil spill.

3.5.3 Operation Phase

Lack of environmental monitoring to serve as baseline environmental data

93. Prior to conversion into CCGT, the existing power plants lack environmental monitoring which could serve as baseline environmental quality data for the CCGT power plants. As a corrective action, BPDB and NWPGC will ensure that environmental quality measurements will be conducted prior to the commissioning of the CCGT power plants.

94. Environmental quality parameters such as suspended particulate matter, NO2, noise level, groundwater level, groundwater elevation, oil & grease for groundwater, critical heavy metals such as arsenic and lead should be measured. Secondary data on community public health (e.g., mortality and morbidity rates) should also be collected to determine the public health profile of the project's area of influence. These environmental data can serve as baseline in comparing the environmental monitoring results during implementation.

95. The results of baseline measurements will be submitted to ADB.

Generation of noise from the CCGT power plants

96. Gas and steam turbine together with generators will increase the ambient noise level within the power plants. Equipment will be designed to have guaranteed noise level not exceeding the ECR 1997 noise limits of 75 dB(A) during daytime and 70 dB(A) at night within the power plant boundary.

97. Turbine and generators will be provided with adequate enclosures and baffle-type silencers at the inlet and exhaust ducts to minimize the noise generated. Routine power plant maintenance will be conducted to ensure that equipment are tuned up and avoid unnecessary noise. As in other BPDB existing power plants, trees will be planted at and around the CCGT power plants to serve as noise buffer. Noise level will be monitored at sensitive receptor areas such as school, mosque, residences and hospital to check if the DOE limits are exceeded. Operators of noise-generating equipment will be provided with ear plugs/muffs.

Use of water for cooling system

98. The existing power plants in Shahjibazar and Sylhet and converted Khulna use groundwater for closed-cycle cooling system while the Baghabari power plant is supplied by demineralized water by Westmont Power (Bangladesh) Ltd. for its closed-cycle cooling system. Westmont Power (Bangladesh) Ltd. has their own demineralization plant within the Baghabari Power Plant complex.

99. The conversion of the existing power plants into CCGT power plant will also use closed-cycle cooling system and will require additional water for cooling purposes. Water supply will come mainly from groundwater due to poor water quality of rivers near the power plants. Table 3.6 shows the estimated water requirements for conversion of existing power plants.

Table 3.6 Estimated Water Requirements for Conversion into CCGT Power Plant

Power Plant Capacity Water Requirement* Source of Water Shahjibazar 105 MW 325 tons/hr Groundwater Sylhet 225 MW 700 tons/hr Groundwater Baghabari 150 MW 475 tons/hr Boral River Khulna 225 MW 700 tons/hr Groundwater *major part of water requirement is for cooling purposes

100. Closed-cycle cooling system is widely used (53%) by electric power plants in the United States particularly by natural gas combined-cycle power plants and in March 2011, the U. S. Environmental Protection Agency issued proposed standards for cooling systems supporting closed-cycle systems.10

101. Groundwater is abundant in Bangladesh and its aquifer are highly productive. Water table is generally shallow at around 1-10 m below the ground surface. 11 Groundwater recharge is estimated at 21 km3 (based on 1977-2001 data).12 The detailed engineering design will determine the water requirement for cooling purposes and the make-up water needed to compensate the evaporation in the cooling towers including the hydrological features of Surma River and Boral River. Sustained availability of groundwater will also be considered in the detailed engineering design. To ensure that the use of groundwater will not result to adverse environmental impact such as land

10 U. S. Energy Information Administration, Annual Electric Generator Report, 17 November 2011. http://www.eia.gov/todayinenergy/detail.cfm?id=3950. (Accessed 5 July 2012) 11 British Geological Survey, Groundwater Quality: Bangladesh, January 2001. 12 Earth Trends 2003 Country Profile, Bangladesh, Water Resources and Freshwater Ecosystems. http://www.earthtrends.wri.org

30 subsidence, groundwater level, ground elevation, and pumping rates will be monitored quarterly.

Generation of employment

102. A total of 74 positions will be required to operate the CCGT power plants (Sylhet- 20 positions, Shahjibazar - 14 positions, Baghabari - 13 positions, and Khulna - 27 positions). These new positions will be an opportunity for eligible local people.

Wastes from the power plant

103. Operation of the power plant will generate wastewater such as laboratory drains, oily washings, etc. An oil-water separator will be used before oily wastes are collected in drums for reuse or resale to approved re-users. Domestic wastes will be treated through septic tanks and soak pit system and wastewater from the power plant will be treated prior to discharge to ensure compliance with the DOE limits. Segregation and recycling of solid waste will be imposed.

Table 3.3 Environmental Management Plan

Responsibility Environmental Concern Mitigation Measures Estimated Cost (Lakh Taka) Implementation Supervision Pre-construction Phase Demolition of 40 MW rental (Aggreko Ltd) in Cost to be borne by Aggreko Ltd PMU-NWPGCL Investmentd Khulna Power Station to accommodate the ecommissioning the plant according to the Program conversion of 150 MW Khulna Power Plant Government of Bangladesh regulations Coordinating Committee (IPCC) Compliance to national environmental 510.84 PMU-NWPGCL, IPCCS regulations ecure site clearance and environmental clearance PMU-BPDB from DOE Construction Phase Transport of construction materials to the Included in Contractor's contract Contractor(s) PMUV - site ehicles will be covered to avoid spillage cost NWPGCL, PMUR -BPDB ailway can be used in Shahjibazar and Khulna while river transport can be used for Khulna also and Baghabari H aul roads used passing through the residential areas within the power station complex will be sprayed with water to suppress dust level Potential contamination from lubricants and Included in Contractor's contract Contractor(s) PMUW- fuel oil orkshop will be done in concrete area or lined with cost NWPGCL, impermeable material to minimize soil contamination PMU-BPDB in case of spillage F uel storage and refilling areas will be located away from Surma River, Boral River, Bairab River and Karotoa River Construction Camp Included in Contractor's contract Contractor(s) PMUP - rovision of garbage bins, sanitary facilities, and safe cost NWPGCL, drinking water PMU-BPDB I mpose good housekeeping and hygiene. L ocation of temporary sanitation facilities must avoid settlements

Responsibility Environmental Concern Mitigation Measures Estimated Cost (Lakh Taka) Implementation Supervision Orient workers on good hygiene and transmitted diseases such as HIV Potential increase in dust and noise levels Included in Contractor's contract Contractor(s) PMUC - oncrete batching and mixing plant will be located cost NWPGCL, away from settlements, water bodies, and downwind PMU-BPDB direction S pray water, where needed, to suppress dust V ehicles transporting dusty construction materials will be covered P rovide enclosures to diesel generator sets (if used) L imit noise-generating works during daytime W orkers operating elevated noise-generating equipment and machine will use noise protection such as ear plugs/muffs Potential further degradation of water quality Included in Contractor's contract Contractor(s) PMUC - in Boral River, Surma River, Bairab River onstruction materials and excavated soil will be cost NWPGCL, and Karotoa River located above high flood level PMU-BPDB C leaning/washing of construction vehicles near the water bodies will not be allowed T hrowing of garbage by workers into water bodies will be strictly prohibited Occupational health and safety risks Included in Contractor's contract Contractor(s) PMUP -BPDB, rovide safe water supply, sanitation and medical cost PMU- health facilities, drainage system at construction NWPGCL camps P rovide and impose wearing of safety gear and PPEs to workers A ll electrical connections will have earth link circuit breaker P

Responsibility Environmental Concern Mitigation Measures Estimated Cost (Lakh Taka) Implementation Supervision rovide orientation to workers on occupational health and safety C onduct drills on emergency such as fire and earthquake Recruitment of workers and staff --- Contractor(s) PMUP -BPDB, riority for local hiring for construction workers and PMU- eligible individuals as technical and non-technical NWPGCL staff Operation Phase Lack of environmental monitoring that could Included in the O & M costs Technical PMUC -BPDB, provide baseline environmental quality data onduct environmental quality measurements prior to Management PMU- operation of the CCGT Staff of power NWPGCL plants in Shahjibazar, Khulna, Baghabari, Sylhet Emissions from stack Included in the project costs Technical PMUL -BPDB, ow-NOx burner will be used Management PMU- Staff of power NWPGCL,U se of natural gas as fuel plants in DOE Shahjibazar, Khulna, Baghbari, Sylhet Generation of noise from the power plants Included in the project costs Technical PMUU -BPDB, se of enclosures in turbine and generators and Management PMU- baffle-type silencers to inlet and exhaust ducts Staff of power NWPGCL, plants in DOER outine maintenance of power plant Shahjibazar, Khulna, Baghbari, M onitor noise level if any sensitive receptor areas Sylhet such as school, mosque, hospital, residences, etc. are involved. O perators of noise-generating machine and equipment will use ear muffs/plugs P lant trees at and around the power plant to serve as buffer

Responsibility Environmental Concern Mitigation Measures Estimated Cost (Lakh Taka) Implementation Supervision Waste from the power plant Included in the project costs Technical PMUW-BPDB, astewater will be treated prior to discharge management PMU- staff of NWPGCL,A n oil-water separator will be used before wastes are Shahjibazar, DOE collected in drums for reuse or sale to approved re- Baghabari, users Sylhet, and Khulna Power D omestic waste will be treated using septic tanks and Plants soak pit system S egregation and recycling of solid waste will be imposed Occupational health and safety risks Included in the O & M costs Technical PMUP - rovide safety gear and conduct drills on fire and management NWPGCL, earthquake emergencies staff of PMU-BPDB Shahjibazar, Baghabari, Sylhet, and Khulna Power Plants Use of water for cooling systems d etailed engineering design will ensure that availability of water supply is sustained m onitoring of ground elevation, groundwater level, and pumping rate to determine if there is ground subsidence

Table 3.4 Environmental Monitoring Plan

Estimated Cost Responsibility per year Issue Parameter Recommended Location Monitoring Frequency (exclusive of Implementation Supervision transport) per power station13 Construction Phase Ambient air quality Total suspended If any sensitive receptor areas Quarterly Contractor(s) PMU- Included in particulates such as settlements, hospital, NWPGCL, Contractor’s school, mosque located Results included in the PMU-BPDB costs downwind of the construction quarterly reports will be sites summarized and sent to ADB for review as part of semiannual environmental monitoring report Groundwater quality pH, oil & grease, total Drinking water supply at Quarterly Contractor(s) PMU- Included in dissolved solids, Pb, As, construction camps NWPGCL, Contractor’s total coliform Results included in the PMU-BPDB costs quarterly reports will be summarized and sent to ADB for review as part of semiannual environmental monitoring report Noise Noise level, dB(A) Sensitive receptor areas such Quarterly Contractor(s) PMU- Included in as settlements, hospital, school, NWPGCL, Contractor’s mosque located downwind of Results included in the PMU-BPDB costs the construction sites quarterly reports will be summarized and sent to ADB for review as part of semiannual environmental monitoring report Waste generation Collection and disposal Weekly Contractor(s) PMU- Included in NWPGCL, Contractor’s PMU-BPDB costs Operation Phase

13 Price of BUET, 2007 and Adroit Environmental Monitoring Consultants Ltd.

Estimated Cost Responsibility per year Issue Parameter Recommended Location Monitoring Frequency (exclusive of Implementation Supervision transport) per power station13 * Emissions generated NO2, SO2 Downwind of the stack Semiannual Technical PMU- @ Tk. 30,000.00 by power plants management NWPGCL, per stack x 2 per *will be monitored only if Results will be summarized staff of PMU-BPDB year =Tk HSD will be used as fuel and sent to ADB for review Shahjibazar, 60,000.00 per in Khulna Power Plant as part of annual Baghabari, stack per year environmental monitoring Sylhet, and report Khulna Power Plants * Ambient air quality NO2, SO2 Sensitive receptor areas such Semiannual Technical PMU- @ Tk. 30,000.00 as settlements, hospital, school, management NWPGCL, per spot x 2 per *will be monitored only if mosque located downwind of Results will be summarized staff of PMU-BPDB year =Tk HSD will be used as fuel the construction sites and sent to ADB for review Shahjibazar, 60,000.00 per in Khulna Power Plant as part of annual Baghabari, spot per year At and around the cooling environmental monitoring Sylhet, and PM10 towers report Khulna Power Plants Groundwater quality Oil & grease, Pb, As, Drinking water supply Semiannual Technical PMU- @ Tk. 15,000.00 total coliform (for drinking management NWPGCL, per spot for 6 water), total dissolved Results will be summarized staff of PMU-BPDB parameters x 2 solids, suspended solids and sent to ADB for review Shahjibazar, per year =Tk as part of annual Baghabari, 30,000.00 per environmental monitoring Sylhet, and spot for 6 report Khulna Power parameters per Plants year Noise level Noise in dB(A) Sensitive receptor areas such Semiannual Technical PMU- @ Tk. 1,000.00 as settlements, hospital, school, management NWPGCL, per spot x 2 per mosque located downwind of Results will be summarized staff of PMU-BPDB year =Tk the construction sites and sent to ADB for review Shahjibazar, 2,000.00 per spot as part of annual Baghabari, per year environmental monitoring Sylhet, and report Khulna Power Plants Groundwater Ground elevation, Deepwell supplying water for Quarterly Technical PMU- groundwater level, cooling systems management NWPGCL, pumping rate, cracks at Results will be summarized staff of PMU-BPDB pavement casing of and sent to ADB for review Shahjibazar,

3.6 Information Disclosure, Consultation, and Participation

104. Component 1 involves existing power plants within the property of BPDB and NWPGCL. Formal consultations of key stakeholders like local authorities will be carried out during the detailed design stage and in the preparation of IEE and EIA required for securing the site clearance and environmental clearance certificate from the DOE. The consultations will provide information about the concept of the project, temporary problems or inconvenience associated with the construction phase, and the management measures that will be implemented to minimize the impacts. Consultation will continue throughout project implementation.

105. Project brief or flyers will be made available (both in English and Bangla) to interested individuals at the PMU office at the sites and in the Corporate Offices of BPDB and NWPGCL in Dhaka. Once accepted by ADB, the environmental assessment report will be posted to the website of BPDB and NWPGCL. BPDB and NWPGCL will revise/update the IEE to include the consultation done during the detailed design stage and the preparation of IEE and EIA required by DOE. BPDB and NWPGCL will submit the revised IEE to ADB and will post the same to their website.

106. Local authorities, youth organization, NGO or other project stakeholders may be invited to participate in the tree planting at the new CCGT power plants to improve landscaping and to provide noise buffer.

3.7 Grievance Redress Mechanism

107. BPDB and NWPGCL will ensure that local people will be given the chance to express their legitimate grievance or file a complaint about the project by establishing a process to address the issues raised. This can be achieved by careful implementation of the environmental management plan (EMP), continuing consultation and communication with stakeholders (as appropriate) during implementation by the Project Management Units (PMUs) of BPDB and NWPGCL, Contractor(s), and local government authorities. Contact details of the PMUs for filing complaints will be posted in the project areas.

108. A grievance redress committee (GRC) at the union level will be set up by BPDB and NWPGCL as soon as the project commence. The setting up of the GRC will be through a gazette information from the Ministry of Power, Energy and Mineral Resources (MPEMR). Members of the GRC will ensure equal representation of women. Figure 3.6 shows the organization of the GRC.

Figure 3.6 Grievance Redress Committee of Component 1

109. GRC will convene twice in a month and will keep a record of the grievances, classify, prioritize, and provide the solution(s) within 30 days from the date of the complaint. The record will include the contact details of the complainant, date the complaint was received and the nature of the complaint, agreement on corrective actions and the date it was enforced, and the final outcome. All complaint-related documentation such as minutes of the meeting and decisions will be summarized and become part of the semi-annual monitoring report submitted to ADB.

110. The GRC will report to the complainant(s) about the developments regarding their grievances and the decisions of the GRC. If the grievance is not addressed, the complainant can seek legal redress of the grievance in the appropriate Courts.

111. The grievance redress mechanism is generally integrated in the compensation process for temporary damages and land acquisition (if any) in the Resettlement Plan (RP). However, since Component 1 will not entail resettlement or land acquisition, the cost of implementing the grievance redress mechanism will be included in the total project cost. The GRC will continue to function during the life of the Project.

112. Briefly, the process is described below:

Step 1 Affected persons (APs) will file the complaint, queries or concerns to the PMU designated staff who will review and respond within five working days. If the AP is satisfied with the outcome and compensation is required, they can proceed to BPDB or NWPGCL to claim the payment.

Step 2 If the issue(s) remains unresolved, the APs can go to the GRC assisted by PMU designated staff who will refer the case with written documentation. The GRC will conduct hearing and resolve the issue within 30 days from the receipt of the complaint. The APs must be present during the hearing of the complaint and the Minutes will be documented and made available to the APs. BPDB or NWPGCL Manager approves the Minutes and the decision sent to the APs. If an agreement is reached and the APs are satisfied with the decision and compensation is required, payment can be claimed to BPDB or NWPGCL.

Step 3 If still the issue(s) remains unresolved, the case is referred by the GRC to the appropriate court of law for settlement.

3.8 Implementation Arrangements

113. Management and general supervision of project implementation will be done by the PMU headed by the Project Director from BPDB or NWPGCL. The overall implementation of the EMP will be carried out under the supervision of the Project Director, PMU. An environmental staff (or a firm that will be retained during implementation), who will be primarily responsible for ensuring that the EMP is properly implemented, will be recruited for the project prior to award of the civil works contract. Aside from this, he/she will coordinate and interact with Project Director, PMU on compliance to ADB requirements, relevant government agencies and local authorities on environmental issues and clearances, update and finalize the IEE, and will prepare environmental monitoring reports for submission to ADB at least twice a year during construction and annually during operation phase.

114. The Contractor(s) will be informed of their responsibility in complying with the EMP and the requirements of ADB. There are specific responsibilities for EMP compliance during construction phase that will rest with the Contractor who will be monitored by the environmental staff of the project.

3.9 Conclusion and Recommendation

115. The conversion of existing OGCT into CCGT power plants will increase the generation capacity of Bangladesh and thus, expected to help improve the current power shortage. Aside from the increase in generation capacity, the contribution to carbon dioxide emissions will be reduced as no additional fuel will be used but instead the heat from exhaust gases will be utilized to run a steam generator.

116. There are no significant adverse environmental impacts associated with the conversion and impacts identified can be readily mitigated by implementing the EMP and the environmental monitoring program.

117. The CCGT power plants will employ closed-cycle cooling systems to avoid the impacts of impingement and entrainment associated with once-through cooling systems. Groundwater will be mainly used as cooling water but will ensure that availability is sustained without undue environmental impacts such as ground subsidence.

118. The PMU of BPDB and NWPGCL will ensure that Contractor(s) complies with the EMP and will report of any unanticipated impacts during construction.

119. Information disclosure will take the form of flyers or project brief both in English and Bangla to be made available to interested individuals. Environmental assessment will be posted to the websites of BPDB and NWPGCL in compliance to ADB's SPS 2009 and Public Communications Policy 2011.

120. BPDB and NWPGCL will ensure that site clearance and environmental clearance certificate will be obtained from the DOE prior to construction works. Consultation will continue throughout project implementation.

4.0 COMPONENT 2 - TRANSMISSION SYSTEM STRENGTHENING

4.1 Objectives and Benefits

4.1.1 Mymensingh to Tangail 132 kV Double Circuit Transmission Line (MT Line)

121. The MT Line aims to (i) evacuate the power that will be generated by the upcoming 150 MW power plant in Mymensingh area to the national grid, (ii) relieve the Ashuganj 132 kV bus by transferring a considerable amount of power from Mymensingh to Tangail, (iii) increase the reliability of power supply at the Mymensingh area, and (iv) reduce transmission loss and relieve some overload at the 132/33 kV substation.

122. The joint venture of Bangladesh Power Development Board (BPDB) with Rural Power Corporation Ltd (RPCL) is planning to build another power plant within the premises of the RPCL’s 210 MW power plant in Mymensingh. The Mymensingh to Tangail 132 kV transmission line is planned to accommodate the evacuation of power from this power plant.

123. The MT Line will prevent blackout or severe load shedding in Mymensingh region in the event the existing 132 kV double circuit transmission line from Kishoreganj Grid Substation (S/S) to Ashuganj Power Station switchyard will fail or will incur problems.

4.1.2 Brahmanbaria to Narshingdi 132 kV Double Circuit Transmission Line (BN Line)

124. The BN Line is expected to: (i) minimize the accumulation of power from the Ashuganj 132 kV bus bar; (ii) allow the evacuation of power from the 70 MW Brahmanbaria Power Plant; (iii) minimize overloading of the existing Ashuganj-Ghorasal 132 kV transmission line; (iv) relieve Dhaka area through transfer of power to Brahmanbaria area to Narshingdi-Dhaka area; and, (v) increase the reliability of power transmission of Brahmanbaria from Sylhet.

4.1.3 Chandraghona to Khagrachhari through Rangamati 132 kV Double Circuit Transmission Line (CRK LIne)

125. The CRK Line will meet the growing demand in Chittagong Hill Tract area by providing reliable power from the Chandraghona Power Plant to Rangamati and Khagrachhari.

4.2 Location and Components

126. PGCB’s approach in the selection of the optimum route for their power transmission projects includes the following criteria:

(i) The route avoids settlements and urban areas to minimize displacement; (ii) The route does not affect public utilities, schools, or any monument of cultural and historical value; (iii) The route avoids infringement in the areas of natural resources such as water bodies; and, (iv) The route considers open agricultural areas where the distance to connecting road is not far away from rural and regional road crossings; and, (v) The route considers the shortest distance to the location of substations.

126. Based on load flow study, 132 kV double circuit transmission line will meet the evacuation of future additional power generation in Mymensingh toTangail (estimated at 100 km), Brahmanbaria to Narshingdi (estimated at 57 km), and Chandraghon to Khagrachhari through Rangamati (estimated at 80 km). Table 4.1 presents a summary of Component 2 while Figure 4.1 shows the location map.

Table 4.1 Components of Transmission Line Facilities

Component Alignment 132 kV Substation Transmission Line Mymensingh to Tangail (MT Line) 100 km Two 132 kV bay extension for existing Tangail Substation (SS) Two 132 kV bay extension for existing RPCL Mymensingh SS Brahmanbaria to Narshingdi (BN Line) 55 km and 2 km Two 132 kV bay extension for river crossing line existing Brahmanbaria SS Four 132 kV bay extension, one bus coupler bay, and one transformer bay for existing Narshingdi SS Chandraghona to Khagrachhari 80 km New construction of 132/33 through Rangamati (CRK Line) kV substation at Rangamati New construction of 132/33 kV substation at Khagrachhari Four 132 kV bay extension for existing Chandraghona SS Source: PGCB. Development Project Proposal 2012

Figure 4.1 Component 2 Location Map 4.3 Description of the Environment

128. The project area of influence considered in this IEE covers the 20 m right-of-way (ROW) as the direct impact area (DIA) and a 30 m buffer along each side of the power transmission line as the general impact area (GIA) for a total of 80 m.

129. The administrative boundaries that will be traversed by the transmission line routes are given in Table 4.2. A general socioeconomic profile was described at the union level.

Table 4.2 Administrative Units Traversed by the Transmission Line Routes

Transmission Line District Name Upazila Name Number of Union Fulbaria Gauripur Mymensingh 11 Mymensingh Sadar Mymensingh to Tangail Trishal (MT Line) Ghatail Tangail Kalihati 14 Madhupur Tangail Sadar Brahmanbaria to Banchharampur 5 Brahmanbaria Narshingdi (BN Line) Brahmanbaria Sadar Nabinagar 13 Narshingdi Narshingdi Sadar Khagrachhari Sadar Khagrachhari 6 Mahalchhari Chandraghona to Nanner Char 7 Khagrachhari through Rangamati Sadar Rangamati Rangamati (CRK Line) Kawkhali (Betbunia) Kaptai 2 Chittagong Rangunia Source: CEGIS Route Survey, 2012

4.3.1 Meteorology

130. Meteorological data collected by the Bangladesh Meteorological Department (BMD) at the Tangail station (2008-2011), Comilla station (2008-2011), and Rangamati station (2001-2011) were used to describe the meteorological conditions within the areas traversed by the transmission line routes.

131. Climate in Bangladesh is characterized by tropical monsoon significantly varying in rainfall and temperature throughout the country. There are three main seasons: summer (pre-monsoon) from March to May, rainy (monsoon) from June to October, and winter season from November to February.

132. MT Line is in the North Central region where monsoon season is experienced in July and recedes in late October. The average monthly rainfall varies from 65 mm (occurring in December) to 410 mm (occurring in October). Average relative humidity ranges from 50% to 85% with highest value in July until August and lowest in January until February. The hottest month is April based on average maximum temperature which ranges from 28.2oC to 41.8oC while coldest month is January with significant fluctuation in minimum temperature varying from 7.4oC to 25.1oC.

133. In the BN Line, rainfall varies from 50 mm to 400 mm occurring in December and in July, respectively, while temperature ranges from 23oC to 33oC with highest temperature in April and lowest in January. Average relative humidity ranges from 74% to 80% with lowest value occurring in November and February while the highest during the months of July to August.

134. At the CRK Line, average monthly rainfall varies from about 80 mm to 280 mm with the highest occurring in October and lowest in January. Mean maximum temperature ranges from 26.2oC to 38.7oC and June being the hottest month while average minimum temperature fluctuates from 8.9oC to 25.6oC and January being the coolest month. Average relative humidity ranges from 67% to 85%.

4.3.2 Natural Hazards

135. Seismicity Bangladesh has been divided into three seismic zones (Figure 4.2): Zone I – Severe (Seismic Factor, 0.08g), Zone II – Moderate (Seismic Factor, 0.05g), and Zone III – Minor (Seismic Factor, 0.04g). Both the MT Line and the BN Line routes lie within seismic Zone II and as such, the design of towers should withstand ground acceleration equivalent to 0.05g during earthquake. The CRK Line is within Zone III and design of poles should withstand a ground acceleration of 0.04g during earthquake.

136. Flooding The MT Line will not traverse flood-prone areas compared to the BN Line which will traverse flood-prone areas. There will be two river crossings for the BN Line, Titas River at Brahmanbaria and the Gumati River in Narshingdi. These are tidal rivers characterized by water flow decreasing during the dry season and increasing during high tide period in the monsoon season. CRK Line is mostly in the hilly areas of Bangladesh and does not run through flood-prone areas.

137. Cyclone Seasonal storms known as Nor’westers (Kalbaishakhi) usually reach the maximum in April, low in May and minimum in March. Nor’westers affect the entire country and are generally associated with tornadoes and its impacts to transmission towers should be incorporated in the detailed design.

Figure 4.2 Seismic Map of Bangladesh

4.3.3 Agricultural Resources

138. The lands traversed by all the transmission line routes are intensively used for agriculture planted to high yield variety (HYV) Boro rice, Aus and T. Aman rice variety, and other crops such as mustard, spinach, eggplant, bitter gourd, etc which are grown vastly in the area. The average yield rate of the HYV Boro and T. Aman crops are about 5-6 ton/ha and 3-4 ton/ha, respectively.

4.3.4 Terrestrial Ecology

4.3.4.1 Ecosystem

139. The terrestrial ecosystems in the areas where the transmission lines are located include the homestead and agricultural lands. Vegetation in the homestead are those cultivated for economic value and those that are self-propagating. Agricultural lands are used to cultivate rice, some vegetables, mustard, sugarcane, pineapple, turmeric, etc.

140. The most dominant species observed in homestead vegetation is bamboo (Bambusa tulda) while common species include Kanthal (Artocarpus heterophylla), Supari (Areca catechu), Anaros, Akasmoni (Acacia mingium), Mehagoni (Swietenia mehagoni), Aam (Mangifera indica) , Narikel (Cocos nucifera), Kola (Musa sp.), Taal (Borassus flabeliffer), Segun (Tectona grandis), Labu, Ipil- Ipil, Neem (Azadirachta indica), etc. Jackfruit, mango, coconut, and banana are the most popular fruits in the area. The proposed area has some orchards with bananas, pineapple, etc.

4.3.4.2 Flora

MT Line

141. The most common cultivated plants in the homesteads include Narikel ( Coconut, Cocos nucifera), Aam (Mango, Mangifera indica ), Jam (blackberry, Syzygium cumini ), Kola (Banana, Musa sapientum ), Kamranga (Carambola , Averrhoa carambola), Tal (Palmyra-palm, Borassus flabellifer), Peyara (Guava, Psidium guajava ) , Boroi /Kul (Jujube Fruit, Zizyphus mauritiana), Kanthal (Jack fruit, Artocarpus heterophyllus), Mehogany (Swietenia mehogany). The other trees observed in the project area are Gamari, Pitraj, Gab, Bot (Ficus bengalensis)), and Khejur (Phoenix sylvestris).

142. The common shrub and herb species are Bansh (Bamboo, Bambusa tulda), bottle brush, Apang (Prickly Chaff-flower, Achyranthes aspera), Biskantali (Polygonum sp.), Kansh (Saccharum spontaneum) and Shon (Imperata cylindrica).

143. The area is mostly used for paddy cultivation. The lower part of the cultivated field is used for Aman cultivation and other varieties of rice in the upper part. The common weed species are Khdudipana (Duckweed, Lemna sp.), Euphorbia, Cynodon, Isoetes coromandeliana, etc.

144. About 16,418 trees are within the 20 m-ROW of the transmission line and will be affected by clearing. Some of the trees identified in the ROW are coconut, mango, bamboo, banana, guava, ipil-ipil, etc. Table 4.3 presents the trees within the 80 m-GIA.

Table 4.3 Trees within the GIA of MT Line

Number of Trees within the GIA Name of Tree Left side Middle side Right side Total (30 m) (20 m) (30 m) (80 m) Narikel (Cocos nucifera) 181 21 163 365 Aam (Mangifera indica) 134 120 165 419 Supari (Areca catechu) 2927 445 1106 4478 Rain tree (Albizia saman) 6 22 26 54 Segun (Tectona grandis) 20 2 6 28 Mehagoni (Swietenia mehagoni) 997 701 698 2396 Kanthal (Artocarpus heterophylla) 2541 1993 2501 7035 Kola (Musa sp.) 164 50 116 330 Karai (Albizia procera ) 59 46 33 138 Khejur (Phoenix sylvestris) 13 11 10 34 Bansh (Bmbusa tulda) 20350 8950 14960 44260 Taal (Borassus flabeliffer) 30 21 28 79 Bel (Aegle marmelos) - - 8 8 Boroi (Zizyphus maurtiana) ) 5 21 47 73 Kadam (Anthocephalus sp) - - 3 3 Jamboora (Citrus sp) 2 - - 2 Shajina - - 1 1 Mera 1 - 1 2 Ipil-Ipil 20 25 10 55 Guava - 5 12 17 Akasmoni 2282 964 1350 4596 Neem 8 - - 8 Jam 1 1 7 9 Shiris 10 - 1 11 Jalpai 6 1 7 14 Lebu 28 6 348 382 Anarosh 5000 3000 4000 12000 Lichu 8 2 12 22 Gamari 1 - 3 4 Daffol 2 - - 2 Pitraj - 11 10 21 Gab - - 1 1 Total 34,796 16,418 25,633 76,847 Source: CEGIS walk-over survey 2011

BN Line

145. Most of the agricultural land is planted to rice and other crops. Cultivated plants that are common are Kola (Musa sapientum), Shisu (Dalbergia sisoo), Kanthal (Artocarpus heterophylla), Narikel (Cocos nucifera), Aam (Mangifera indica), Jam (Syzygium cumini), Supari (Areca catechu), Kamranga (Averrhoa carambola), Taal (Borassus flabellifer), Peyara (Psidium guajava) and Kul (Zizyphus mauritiana).

146. Common shrubs and herb species identified during the survey done by CEGIS in April 2012 include Bansh (Bambusa tulda), Shon (Imperata cylindrica), Biskantali (Polygonum Sp.), Dhol Kolmi (Ipomoea carnea ), etc. while some common weed species are Durba Ghash (Cynodon Sp.), Mona Ghash, Kachuripana (Eichornia crassipes ), Khdudipana (Lemna Sp.), etc.

147. An estimated 47 trees within the 20-m ROW were identified. These trees will be affected by the transmission line route during construction. Table 4.4 presents the trees identified within the GIA.

Table 4.4 Trees within the GIA of BN Line

Number of Trees within the GIA Name of Tree Left side Middle side Right side Total (30 m) (20 m) (30 m) (80 m) Narikel (Cocos nucifera) 7 0 7 14 Aam (Mangifera indica) 0 0 10 10 Supari (Areca catechu) 0 0 31 31 Akashmoni (Acacia mingium) 17 1 19 37 Kanthal(Artocarpus heterophylla) 5 0 4 9 Kanthal(Artocarpus heterophylla) 5 0 4 9 Kola (Musa sapientum)) 16 6 0 22 Bansh (Bmbusa tulda) 70 15 20 105 Kul (Zizyphus Sp.) 0 0 3 3 Jambura (Citrus Sp.) 0 0 4 4 Epil-ipil 0 0 5 5 Babla 2 3 2 7 Peyara 4 0 13 17 Jam 5 4 5 14 Tentul 0 0 3 3 Bot-Gachh ( Ficus bengalensis) 1 2 0 3 Dumur (Ficus hispida) 0 4 0 4 Lebu 12 0 0 12 Shisu 12 1 12 25 Neem 5 1 0 6 Koroi 6 3 18 27 Menda 8 2 0 10 Kamranga 0 2 0 2 Charcoal 6 0 0 6 Khejur (Phoenix sylvestris) 10 0 0 10 Krishnachura 0 0 1 1 Kodom 0 0 2 2 Royna 0 0 3 3 Dewa 2 0 0 2 Sharifa 0 0 3 3 Lichu 3 0 0 3 Sharifa 0 0 3 3 Kafila 3 3 0 6 Gab 1 0 0 1 Morta 0 0 11 11 Shialkanta 0 0 12 12 Total 206 47 193 446 Source: CEGIS Walk-over survey, 2011

CRK Line

148. The area traversed by the transmission line route is mainly agricultural land and mostly used for pady cultivation. Common plants identified include Narikel (Coconut, Cocos nucifera), Aam (Mango, Mangifera indica ), Jam (blackberry, Syzygium cumini ), Kola (Banana, Musa sapientum ), Kamranga (Carambola , Averrhoa carambola), Tal (Palmyra-palm, Borassus flabellifer), Peyara (Guava, Psidium guajava ), Boroi /Kul (Jujube Fruit, Zizyphus mauritiana), Kanthal (Jack fruit, Artocarpus heterophyllus), Mehogany (Swietenia mehogany), and Khejur (Phoenix sylvestris), etc.

149. About 7,860 trees are within the 20-m ROW which may be affected to some extent during construction. However, the CRK Line will use the existing road easement. Table 4.5 gives the list of trees identified in the GIA.

Table 4.5 Trees within the GIA of CRK Line

Number of Trees within the GIA Name of Tree Left side Middle side Right side Total (30 m) (20 m) (30 m) (80 m) Narikel (Cocos nucifera) 177 283 300 760 Aam (Mangifera indica) 637 669 714 2020 Supari (Areca catechu) 355 629 309 1293 Rain tree (Albizia saman) 62 38 40 140 Segun (Tectona grandis) 3259 1873 1642 6774 Mehogany (Swietenia mahagonj) 500 22 442 964 Kanthal (Artocarpus heterophyllus) 897 452 490 1839 Kola (Musa sp) 1450 2240 1626 5316 Karai (Albizia procera) - 20 - 20 Tetul 2 - - 2 Bansh (Bmbusa tulda) 1350 720 1790 3860 Tal (Borassus flabeliffer) - 3 2 5 Bel (Aegle marmelos) 5 - 5 10 Boroi (Zizyphus sp) - 3 2 5 Kadam (Anthocephalus sp) 15 - 7 22 Jamboora (Citrus sp) - 2 - 2 Badorloi 3 - - 3 Shemul 6 - - 6 Banyan 13 18 4 35 Guava (Psidium guajava) 54 35 10 99 Akasmoni 8 25 57 90 Neem 5 5 - 10 Jam (Syzygium cumini) 15 - 5 20 Shiris 5 - - 5 Radhachura 3 - 10 13 Labu - 14 10 24 Anarosh garden 8 11 11 30 Lichu 77 15 8 100 Gamari 1002 755 392 2149 Kamranga (Averrhoa carambola) 2 - 5 7 Amloki 2 2 - 4 Shishu - 12 3 15 Krishnachura 6 - - 6 Atta 3 10 2 15 Kuksha - 2 - 2 Khejur (Phoenix sylvestris) - - 2 2 Jarul - 2 - 2 Total 9,921 7,860 7,888 25,669 Source: CEGIS Walk-over survey, 2011

4.3.4.3 Birds

150. There are two main groups of terrestrial birds found within the transmission line route. These are birds observed in the dry land such as homestead, open area, fallow land, and scrub grassland; and birds observed in the wetlands.

MT Line

151. Terrestrial birds observed are House Crow (Corvus splendens), Large-billed Crow (Corvus macrohrynchos), Asian Pied Starling (Sturnus contra), Common Myna (Acridotheres tristis), Spotted Dove(Streptopelia chinensis), Brown Shrike (Lanius cristatus ), Red-vented Bulbul (Pynonotus cafer), Baya Weaver (Ploceus philippinus), Chestnut-tailed Starling (Sturnus malabaricus), Blue Rock Pigeon (Columba livia), Brhaminy Kite (Haliastur indus), Black Kite (Milvus migrans), Grey-headed Fish Eagle (Ichthyophaga ichthyaetus), etc. Among the bird of prey species found within the

50 proposed area is the Grey-headed Eagle and is listed as Near Threatened by the IUCN Red List of Threatened Species in 2008 assessed by Bird International.14

BN Line

152. Terrestrial bird species found within the transmission line route are Black Drongo (Dicrurus macrocercus), House Crow (Corvus splendens), Large-billed Crow (Corvus macrohrynchos), Asian Pied Starling (Sturnus contra), Common Myna (Acridotheres tristis), Spotted Dove (Streptopelia chinensis), Red-vented Bulbul (Pynonotus cafer), Baya Weaver (Ploceus philippinus), Blue Rock Pigeon (Columba livia), Oriental Magpie Robin (Copsuchus saularis), Heart-spotted Woodpecker (Hemicircus canente), Brahminy Kite (Haliastur Indus), etc.

CRK Line

153. Birds frequently observed during the walk-over survey include House Crow (Corvus splendens), Large-billed Crow (Corvus macrohrynchos), Asian Pied Starling (Sturnus contra), Common Myna (Acridotheres tristis), Spotted Dove (Streptopelia chinensis), Brown Shrike (Lanius cristatus ), Red-vented Bulbul (Pynonotus cafer), Baya Weaver (Ploceus philippinus), Chestnut-tailed Starling (Sturnus malabaricus), Blue Rock Pigeon (Columba livia), Brhaminy Kite (Haliastur indus), Black Kite (Milvus migrans), Grey-headed Fish Eagle (Ichthyophaga ichthyaetus) etc .

4.3.5 Aquatic Ecology

4.3.5.1 Flora

154. The aquatic flora in the wetlands found within the project area consists of submerged plants, free floating plants, rooted floating plants, sedges and meadows, reed swamp (on ridges), and marginal (on surrounding saturated soil).

MT Line

155. Common submerged plants include species such as Aponogeton Sp., Hydrilla Sp. , Nechamendra Spp., Najas Sp., Ruppia Sp while the free-floating plants include Kachuripana (water hyacinth and Eichornia crassipes), Khudipana (Duckweed, Lemna sp.). Observed rooted plants are species such as Shapla (Nymphaea pubescens), Paniphal (Trapa sp.), Kolmi (Ipomoea aquatica), and Dhol Kolmi (Ipomoea carnea). It was noted that the dominant species in the aquatic habitat are Khudipana, Kachuripana, shapla and Kolmi.

156. Sedges and meadows are known amphibian plants. The amphibian species are: Nymphaea Spp., Nymphoides Sp., Hygroryza Sp., Polygonum Sp., Alisma Sp., Pontederia Sp., etc. The dominant family of marginal plants are Amaranthaceae followed by Cyperaceae and Gramineae. The dominant species are Topapana (Pistia strateotes) and Kolmi (Ipomoea aquatic).

BN Line

157. Common submerged flora observed within the site are Helencha (Ceratophyllum Sp.) Jhangi (Myriophyllum Sp.), Hydrilla verticillata, Najas, etc. while the free-floating

14 IUCN 2011, IUCN Red List of Threatened Species version 2011.2, www.iucnredlist.org. (Accessed 17 May 2012).

51 species include Kachuripana (Eichornia crassipes), Kutipana (Azolla pinnata ) and Khudipana (Lemna Sp. ).

158. Rooted floating plants are Shapla (Nymphaea pubescens), Kolmi (Ipomoea aquatica) and Dhol Kolmi (Ipomoea carnea). The sedges and meadow plants include Kachuripana (Pontederia Sp.) which is native to USA, Biskantali (Polygonum Sp.), and Kolmi (Ipomoea aquatic).

CRK Line

159. Aquatic flora identified within the CRK Line are submerged plants, free-floating plants, and amphibian plants. Submerged plants include Aponogeton Sp., Hydrilla Sp., Nechamendra Spp., Najas Sp., Ruppia Sp while floating plants are represented by Kachuripana (Water Hyacinth and Eichornia crassipes) Khudipana (Duckweed, Lemna sp.). The amphibian plants are Nymphaea Spp., Nymphoides Sp., Hygroryza Sp., Polygonum Sp., Alisma Sp., Pontederia Sp. etc.

4.3.5.2 Birds

MT Line

160. The aquatic birds found within the transmission line route include Little Cormorant (Phalacrocorax niger), Indian Pond Heron (Ardeola grayii), Little Egret (Egretta garzetta), Red-wattled Lapwing (Vanellus indicus), White-breasted Water hen (Amaurornis phoniecurus), Little Cormorant (Phalacrocorax niger), Grey Heron ( Ardea cinera), Purple Heron (Ardea pupurea), Cinnamon Bittern (Ixobrychus cinnamomeus)), Asian Openbill (Anastomus oscitans), Common Snipe (Gallinago gallinago), Bronze-winged Jacana (Metopidius indicus), etc.

BN Line

161. Aquatic birds identified in the MT Line route are also in the BN Line route except for Great Egret (Casmorodiusalbus), Common Pochard (Aythya ferina), and Wood Sandpiper (Tringa glareola).

CRK Line

162. Aquatic birds found within the CRK Line are Little Cormorant (Phalacrocorax niger), Indian Pond Heron (Ardeola grayii), Little Egret (Egretta garzetta), Red-wattled Lapwing (Vanellus indicus), White-breasted Water hen (Amaurornis phoniecurus), Grey Heron (Ardea cinera), Purple Heron (Ardea pupurea), Cinnamon Bittern (Ixobrychus cinnamomeus)), Asian Openbill (Anastomus oscitans), Common Snipe (Gallinago gallinago), and Bronze-winged Jacana (Metopidius indicus).

4.3.6 Amphibians, Reptiles and Mammals

MT Line

163. Of the amphibians, the Common Indian Toad (Bufo melanostictus) is frequently found within the route while the Balloon Frog (Uperedon globulosus), a fossorial species, was observed in both the agricultural land and forest. The Ornate Microhyla (Microhyla ornata), a terrestrial frog, inhabits the lowland scrub, grassland, agricultural land and pasture land while the Indian Cricket Frog (Limnonectes limnocharis) is highly adapted to human habitation.

164. Common lizards are House Gecko (Hemidactylus flaviviridis), Common Garden Lizard (Calotes versicolor), and Jerdon’s Calotes (Calotes jerdoni). The Bengal Monitor (Varanus bengalensis) is a burrow-dweller and has been found within the areas traversed by the transmission line route.

165. The Checkered Keelback (Xenochrophis piscator) and Ornate Flying Snake (Chrysopelia ornata) are widely distributed throughout the route while the Indian Monocled Cobra (Naja kaouthia) was also observed.

166. Common mammals found are Lesser Bandicoot Rat (Bandicota bengalensis), Large Bandicoot Rat (Bandicota indica), Common Mongoose (Herpestes ewardsii), Asian House Shrew (Suncus murinus), Common Palm Civet (Paradoxorus hermaphrodites), Jackal (Canis aureus), Indian Wild Boar (Sus scrofa), etc. Among the flying mammals that have been observed are Indian Flying-fox (Pteropus giganteus) and Indian Pipistrelle (Pipistrellus coromanda).

BN Line

167. Most of the species found in the MT Line route are also found in the BN Line. Other species identified are Indian Bullfrog (Hoplobatrachcus tigerinus), Skipper Frog (Euphlyctis cyanophlyctis) and Cricket Frog (Fejervarya limnocharis).

168. The Spotted Pond Turtle (Geoclemys hamiltonii) and the Brahminy River Turtle (Hardella thurjii) are also idenfied. Commonly-found lizards are the House lizard (Hemidactylus brooki) and Common Garden Lizard (Calotes versicolor). These species are known to live around human habitation, homestead, forest edges, etc.

169. Snake species are Striped Keelback (Amphiesma stolata) and Vine Snake (Ahaetulla nasuta). The Indian Rat Snake (Ptyas mucosa) thrives on agricultural fields and scrublands in the proposed route.

CRK Line

170. Skipper frog (Euphlyctis cyanophlyctis) is found within the CRK Line which is commonly found in wetland habitats and is considered to be most successful in adapting to altered habitats. Other common species are Indian Bullfrogs, Puddle frog (Occidozyga lima), Asian Painted Frog, Red Microhylid frog, Cricket frog, Two-stripe grass frog, Indian Tree frog, and Asian Brown tree frog.

4.3.7 Socioeconomic Profile

4.3.7.1 Administrative Boundary

171. The 20-m ROW is defined as the direct impact area (DIA) while the general impact area (GIA) is referred to as the DIA and the 30-m buffer along both sides of the transmission line equivalent to 80 m.

172. The unions traversed by the transmission lines were considered for environmental baseline analysis while the general socioeconomic profile was prepared at the union level. The MT LIne spans over the two districts of Mymensingh and Tangail, eight upazilas, and 25 unions. The BN Line route is within the districts of Brahmanbaria and Narshingdi, four upazilas and 18 unions. Within the CRK Line route are three districts, seven upazilas, and 15 unions.

173. Data from Bangladesh Bureau of Statistics (BBS) and walk-over survey conducted by CEGIS in November 2011, April 2012, and May 2012 were used to describe the socioeconomic conditions of the population.

4.3.7.2 Demography

MT Line

174. According to the 2011 data from the BBS, the estimated number of households within the MT Line route is 185,323 with a total population of 836,367. The average household size is 4.5. Male population is slightly higher (52%) than female population (48%). Literacy rate is about 37.7% compared to the national rate of 45.4%. Male population is more literate (41.1%) than female population (34.1%).

BN Line

175. From the estimated data of BBS, the total number of households is 80,697 with an average household size of 5.5. The percentage male population is almost the same (50:50) as the percentage female population. Literacy rate is 33% compared to the national rate of 45.4%. Male population is more literate (36%) than the female population (30%).

CRK Line

176. About 70% of the population belong to ethinic minority. BBS (2012) estimates that the population is 192,192 consisting of 47% female and 53% male with an average hoiusehold size of 5. Literacy rate of female population is 40.8% and 49.6% for male population.

4.3.7.3 Housing and Building Structures

MT Line

177. Route survey conducted by CEGIS (2011) shows that there are a total of 307 housing structures within the GIA which consists of a building house and 306 tin sheet houses. There is no housing structure within the 20-m ROW. However, seven building structures for small-scale commercial use will be affected by the ROW.

BN Line

178. There are 32 housing structures within the GIA which consists of two building house and 29 tin sheet houses. There is no housing structure in the ROW but one unused building structure on the land earmarked for the improvements of the Narshingdi Substation (SS).

CRK Line

179. The walk-over survey done by CEGIS in April 2012 shows that an estimated 156 housing structures are within the ROW which consists of building, semi- pacca and tin sheet houses. These structures will be affected to some extent during construction.

4.3.7.4 Employment

MT Line

180. The BBS Report (2011) shows that agriculture (33%) is the main employment of the population within the MT Line. Other occupations include household work (25%), own business (4%), construction (2%), industry and transport (1%). About 23% of the population indicates that they are looking for work and 2% indicate that they are not working.

BN Line

181. Almost one-third (35%) of the population is doing household work and about 30% not working. Agriculture work covers 20% of the population and about 5% is involved in business work.

CRK Line

182. About 33% of the local population reported that they are doing household work and 25% has no employment. Agriculture-related work represents 21% and a small part (3%) reported that they do business as occupation.

4.3.7.5 Water Supply and Sanitation

MT Line

183. The main source of drinking water is groundwater taken through tube wells (89.34%) and about 9% still use rivers as their source of drinking water.

184. About one-third (or 31.8%) of the population have no sanitation facilities while 32.3% have ring slab latrines.

BN Line

185. Major source of drinking water is tube well (95%) and only 3% of the population use other sources such rivers, khals, etc. for drinking water.

186. Almost 50% of the population use other types of toilet facilities (e.g.,kancha) and only 38% have sanitary facilities. The type of sanitation facility is dominated by ring slab (68%) followed by water sealed type.

CRK Line

187. Almost 88% of the households use tube well as their source of water supply. Other sources include pond and charra. Most of the households have kancha latrines (51%) and 35% have sanitary latrine facilities.

4.4 Anticipated Environmental Impacts and Mitigation Measures

188. The environmental impacts of transmission line projects are generally localized within the ROW but could have some effects on the natural and socio-cultural resources. While all the engineering and sound survey approach have been applied in selecting the best alignment, residual effects cannot be entirely avoided due to terrain and demography

55 of the project area. An environmental management plan (EMP) including an environmental monitoring plan will ensure that these residual impacts can be contained.

4.4.1 Pre-construction and Design Phase

Selection of transmission line route

189. This phase involves the selection of the transmission line route through desktop review of information from available maps, aerial photos, high resolution remotely sensed data, and technical drawings and plans from PGCB. A walk-over survey will involve the establishment of temporary access tracks to determine the type and number of trees and plants that may be affected, type of settlements and shops within the ROW, and natural physical features and public utilities that may be traversed by the transmission line route. These activities may cause temporary and minimal disturbance to local people within the ROW of the option route selected for further study.

190. However, these impacts can be minimized by careful route selection using relevant sources of information, and criteria that avoid, to the extent possible, the important cultural and historical sites, protected areas and sanctuaries, and settlements. Informal consultation with local people can help in selecting the best route with the least environmental and social impacts.

4.4.2 Construction Phase

191. Broadly, the activities during construction phase involve clearing of ROW, establishment of temporary access tracks, setting up of materials storage areas along the route and work sites, transport of material and equipment to the site, excavation of tower foundation, cementing/concreting of tower foundation, erection of the towers, and conductor stringing. The PMUs will ensure that the Contractor's contract will include the obligation to compensate for any temporary damage, loss or inconvenience as result of the project during the construction phase (Sect. 19 of Electricity Act 1910, 1982 Acquisition and Requisition of Immovable Properties, SPS 2009).

Preparation of workplan to control construction-associated impacts

192. The preparation of workplan will help ensure the smooth implementation of construction activities and will avoid any impacts of unplanned activities by the Contractor(s). The workplan include the temporary pedestrian and traffic management, materials and waste management, noise and dust control (as appropriate), and community and safety plan.

Recruitment of project staff and orientation of workers

193. The project is an opportunity for local people to engage in non-agricultural employment and the presence of workers may become small-scale and temporary business opportunity for enterprising local people to provide services such as food, temporary lodging, etc. However, potential impacts in recruitment of project staff are conflict due to workers’ migration increasing the competition with local labour. This could result to lack of project support from local people.

194. Contractor(s) will be directed to use local labour for manual work and eligible local workforce for clerical and office jobs. PGCB will encourage local village groups (if any) to monitor the Contractor(s) to ensure that local hiring is given priority.

195. PGCB will conduct briefing for Contractor(s) on the EMP, records management, and reporting. Orientation of PGCB to Contractor(s) and workers will provide an understanding of their responsibility in implementing the EMP and an agreement on the critical areas to be monitored. Part of the orientation and briefing to Contractor(s) and workers will be on awareness about socially transmitted disease such as HIV/AIDS to prevent potential incidence.

Clearing of vegetation within the ROW

196. Based on the walk-over survey of CEGIS (2011) for MT Line, an estimated 16,418 plants such as Kanthal (Artocarpus heterophylla), Aam (Mangifera indica), Supari (Areca catechu), Mehagoni (Swietenia mehagoni), Narikel (Cocos nucifera), Bansh (Bmbusa tulda), and mixed vegetation of herbs and shrubs are within the ROW while for the BN Line, about 47 trees will be cleared. In the CRK Line, about 7,860 trees will be affected consist of mainly Kola (Musa sp.), Segun (Tectona grandis), and Aam (Mangifera indica).

197. All trees, bushes and saplings within the ROW limit will be cleared as they are within the clearance belt of the transmission line. Within the 30-m buffer at each side of the ROW, low-type of vegetation may be affected temporarily and crushed during the stringing of conductors. Clearing of vegetation will cause loss of habitat to some wildlife such as birds, snakes, rats, insects, etc.

198. According to the socioeconomic survey done in May 2012, the areas affected by the T/L are mainly farms planted to oil seed in winter season or about 97.1% of the estimated total affected and the rest allocated to timber and fruit trees.15 Other winter crops are wheat and potatoes.

199. Affected people within the ROW will be compensated for their standing crops, plants and trees damaged by clearing of vegetation. About Taka 13,296,626 (or $160,200.31) is allocated for compensation to crops, timber and fruit trees affected by the 20-m ROW. Table 4.6 presents the compensation plan.

Table 4.6 Compensation for Affected Trees and Crops along the T/L Route ROW

Description Unit Cost (Taka) Number of Unit Cost (Taka) MT Line 16,418 trees 6,731,380 Timber and BN Line 410 per tree 47 trees 19,270 fruit trees CRK Line 7,860 trees 3,222,600 Crops MT Line 200 hectares 2,116,800 10,584 per BN Line 114 hectares 1,206,576 hectare (ha) CRK Line Not applicable Not applicable Total Cost (Taka) 13,296,626 Source: BAN: Power System Expansion and Efficiency Improvement Investment Program Tranche 1, Resettlement and Ethnic Minority Development Plan, 5 July 2012

200. Replanting of trees will be done at Narshingdi, Rangamati and Khagrachari Substations and in other areas identified in consultation with the Department of Forests (DOF). Species of trees that are medium height with high productivity such as lemon, guava, etc. are preferred. The replanting activities will be monitored by PGCB, DOF and local authorities.

15 BAN: Power System Expansion and Efficiency Improvement Investment Program Tranche 1, Resettlement and Ethnic Minority Development Plan, 5 July 2012.

201. Crops and plants that are less than 3 m tall such as sugarcane, corn, rice, etc will remain along the buffer area of the ROW. Agricultural activities within the ROW will be allowed after construction but with restrictions to height of vegetation.

202. To minimize impact to wildlife, schedule of work will avoid the breeding season and destruction of nests will be prohibited. In some areas, loss of habitat due to stringing of conductors will naturally regenerate in about 2-3 years.

Land acquisition and clearing for transmission towers and substations

203. Some acquisition and clearing of land, excavation and earthmoving will be done at the ROW, tower foundation sites for the MT Line and BN Line, and in the substations at Narshingdi, Rangamati and Khagrachhari. The MT Line and the BN Line will use a four- legged steel lattice type transmission towers while the CRK Line will use steel poles. Some agricultural land will be lost permanently at the base of the transmission towers.

204. Installation of the MT Line will involve about 333 towers which could result to a maximum loss of agricultural land approx. 269.73 m2 (or 0.027 ha). About 211 towers will be erected for the BN Line resulting to a loss of about 170 m2 (0.017 ha) of agricultural land. A total of about 0.044 ha of agricultural land will be lost due to the MT line and BN Line. Table 4.7 gives a summary of the affected land by Component 2.

Table 4.7 Summary of Land Affected by Component 2

Area permanently Area permanently Area affected affected by affected by new Subcomponent Total (ha) by ROW (ha) base of substation and transmission improvements (ha) towers (ha) MT Line 199.973 0.027 Not applicable 200 BN Line 113.983 0.017 0.18 (privately-owned) 114.18 4.0 (government- CRK Line 120 Not applicable 124 owned)

205. Only the exact amount of construction material (i.e., sand, gravel, concrete, etc) will be brought on-site at the transmission towers so that stockpiling will be avoided. Adequate storage for construction materials needed for the substations will be provided.

206. Earthmoving for transmission line will be isolated to tower sites only. Tower foundations involve small-scale excavations and the excavated topsoil will be used for backfilling. There will be no slope modifications at the location of the towers as the site is generally flat for MT Line and BN Line. Adequate measures will be done to prevent erosion at Rangamati substation which is located in a hilly area. Where necessary, downhill slopes within the Rangamati substation will be treated with revetments, provide retaining walls or sow soil binding grass around the site to contain soil erosion.

207. Potential increase in suspended particulate matter and vehicular emissions due to land clearing and use of construction vehicles are not expected during the installation of towers but may slightly increase at the construction of the substations in Narshingdi, Khagrachari and Rangamati. Water will be sprayed to any exposed or opened land area at the substations sites to suppressed dust level particularly during the summer season. Contractor(s) will be required to maintain construction vehicles regularly to minimize the contribution of vehicular emissions.

208. Local people may be inconvenienced by potential increase in noise level and ground vibration from construction vehicles. Contractor(s) shall take adequate measures to minimize noise level and nuisance in the vicinity of transmission tower sites and substations by following the traffic management plan and construction schedule.

Erection of towers and stringing of conductors

209. The erection of towers and stringing of conductors for the MT Line will result to temporary dismantling of seven shops within the ROW consisting of tea stalls and grocery shops. The seven shops will be reconstructed away from the ROW and owners will have better shops compared to the present condition. One unused building will be affected by the BN Line and no housing structures will be affected by the CRK Line as it will run through the existing road easement. A budget of Taka 2,175,000 (or US$26,205) was allocated as compensation for the removal and/or damages to the seven shops and one unused building.16

210. The erection of towers and poles as well as stringing of conductors may interfere with road crossings which may pose safety risks to the public and construction workers. To minimize the risks, adequate danger and clearly visible warning signs will be posted at designated sites while scaffoldings will be placed over road crossing points. Contractor(s) will be required to instruct drivers of construction vehicles to strictly follow road regulations. Security personnel will be assigned to prevent trespassing and accidents. If necessary, tower erection sites will be fenced. Surrounding area within the tower sites will be kept clean.

211. Site engineers will find out the location of the nearest hospital and first aid treatment will be set up within the construction sites and field office. Workers will be provided with hard hats, safety shoes, and safety belts while designated staff will be provided with communication devices. The Contractor(s) will comply with relevant safety measures required by law and best engineering practices.

212. The BN Line will run through flood-prone areas and two river crossings along Meghna River. The design of transmission towers will incorporate recorded flood levels for the last 50 years. To ensure the integrity of the towers and public safety, the increase in height will depend on the highest flood level recorded with a margin of 2.5 m. A 2-km river crossing line will accommodate the adjustment of river crossing at the Meghna River.

4.4.4 Operation Phase

Presence of transmission towers

213. Presence of transmission towers may obstruct ground surface but this will be confined to the area of tower footings which will be about 15 m from each other. Transmission lines generally run above 8 m from ground level and the chance of disturbance and obstruction to passage of wildlife is remote.

Potential exposure to electromagnetic radiation

214. There were concerns about potential risks of cancer from exposure to electromagnetic radiation from overhead transmission lines and substations. The Bureau of Health Devices and Technology of the Department of Health in the Philippines

16 BAN: Power System Expansion and Efficiency Improvement Investment Program Tranche 1, Resettlement and Ethnic Minority Development Plan, 5 July 2012.

59 measured on 19 April 2004 the strength of electric and magnetic field generated by a 138 kV double circuit transmission line and from transformers in the substations as follows:17

138 kV Transmission Line International Commission on Non- Ionizing Radiation Type of Exposure Centerline Conductors Protection (ICNRP) limit of exposure for the general public Electric field, kV per meter 1.76 1.503 4.17 Magnetic field, milliGauss 0.813 0.823 833 (mG) Substations 150 MVA 50 MVA transformer transformer Electric field, kV per meter 1.891 0.148 4.17 Magnetic field, mG 15.75 4.71 833

215. Given the results above for 138 kV transmission line and 150 MVA transformer, the 132 kV double circuit transmission lines, the expansion of existing Narshingdi substation, and the new substations at Rangamati and Khagrachhari are not expected to pose health risks to the public. The substations will use a maximum of 75 MVA transformer. Substations will be fenced and security staff will be assigned to prevent public access.

Fugitive emissions from SF6 handling equipment

216. SF6 is used as an insulator and electric arc arrestor in electrical equipment such as lightning arrester, high voltage circuit breakers, transformers, and switches/switchgears. Aside from being a potent greenhouse gas (i.e., global warming potential is 23,900 times compared to CO2), SF6 is an inorganic, non-toxic gas that may be an occupational safety concern due to possible asphyxiation if it is not used in a well- ventilated areas. There is potential for SF6 to leak during the operation phase and its decomposition byproducts may pose a risk to occupational exposure of workers. Given its global warming potential, release or leakage of SF6 into the atmosphere should be minimized avoided.

217. Leak sources will be identified in a timely manner using handheld leak detector and monitoring of SF6 level will be monitored regularly. To determine the baseline concentration, data on existing SF6 containing equipment being used will be collected in an inventory. Monitoring of SF6 level will improve the preventative maintenance procedures in PGCB facilities and will enhance awareness of staff to potential sources of GHG emissions.

Failure of transmission line system

218. Accidental failure of transmission lines may expose wildlife and the public to the danger of electrocution hazards. Transmission line system is designed with a protection system that shuts off during power overload or similar emergencies. Regular monitoring and maintenance will ensure the safety and integrity of towers and transmission lines. PGCB will conduct information and education campaign to local people on awareness to transmission line safety practices.

17 National Transmission Corporation, Negros-Panay Overhead Transmission Line and Substation Expansion Project, IEE Checklist of Cebu-Negros-Panay Interconnection Updating Project, Annex 8, September 2004.

Clearing of vegetation within the ROW

219. Local people will not be allowed to plant large trees higher than 3 m within the ROW to keep the integrity of the power transmission system. Regular trimming of vegetation or lopping of trees within the ROW will be done to ensure the required vertical spacing between the conductors and the vegetation is maintained for safety reasons.

Encroachment to ROW

220. Encroachment to ROW is potentially dangerous to both people and the power transmission system. To prevent encroachment, land use practices and any other infrastructure that will have negative impact to the power transmission system will be restricted.

4.5 Analysis of Alternatives

221. Alternatives were considered during the preliminary design and selection of the T/L routes to minimize land and vegetation clearing, land acquisition, and other associated impacts with the aid of existing satellite images, aerial photos, land use/cover and topographic maps, bioecological zone map, spatial distribution and location of permanent wetlands, ecologically-critical areas, and walk-over survey. 18 Table 4.8 shows the summary of alternative sites.

Table 4.8 Summary of Alternative Sites for Transmission Line

Route Length, km Transmission Line Description Option (approx.) 1 107.54 Longest route but not crossing settlements 2 101.58 Shortest route but crossing more MT Line settlements than Option 1 and Option 3 3 102 Moderate length but crossing more settlements than Option 1 1 54.48 Shortest route and crossing no settlements 2 57.28 Longest route and crossing more BN Line settlements than Option 1 and Option 3 3 55.98 Moderate length but crossing more settlements than Option 1 1 83.79 Longest but not crossing settlements 2 81.85 Moderate length but crossing more CRK Line settlements than the Option 1 3 80.62 Shortest route but crossing more settlements than Option 2 Source: Route analysis and survey done by CEGIS, 2012.

222. Based on these alternatives, Options 1 were found to be the most suitable for the three T/L as these will have (or no) settlements crossing under the 20-m ROW, heavy equipment can easily transport the construction materials, and potential disturbance to the communities will be the least. Detailed engineering design will finalize the actual length of

18 PGCB commissioned the Center for Environmental and Geographic Information Services (a public Trust under the Ministry of Water Resources) to conduct the survey and prepare the IEE for submission to DOE required to obtain the site clearance.

61 the route based on additional survey, geographical and topographical conditions, and further minimizing the associated environmental and social impacts.

223. In the selection of technology, only the BN Line and MT Line will use transmission towers. The CRK Line will use transmission poles and utilize the existing road easements given that this route is within the most hilly area in Bangladesh.

224. For the new substations, the primary consideration for site selection is the avoidance of land acquisition. The 2 ha of land for the Rangamati SS will be government- owned under the Defence Department which was previously used as a military station while for the Khagrachari SS, the 2 ha allocation will come from the 4.8 ha of land owned by the Bangladesh Agriculture Development Corporation under the Department of Agriculture.19

4.6 Information Disclosure, Consultation, and Participation

Consultation and Participation

225. To inform local level stakeholders about the project, informal consultations were done during the preparation of the IEE and the walk-over survey.20 Consultations aim to provide information about the concept of the project, temporary problems or inconvenience associated with the project during the walk-over survey and construction stage, and the mitigation or solutions to these associated problems to minimize the effects.

226. Informal consultations and discussion meetings with local people were carried out by the Social Team of the Center for Environmental and Geographic Information Services (CEGIS), contracted by PGCB, during the walk-over surveys for the ROW (November 2011, April and May 2012). During these consultations, people raised questions/issues and facilitators from CEGIS took notes and provided response to the issues raised.

227. A summary of the concerns raised during the consultations done by CEGIS are given below:

Perceptions of the local people

They are already aware that a proposed transmission line will be put up in their area from high officials of PGCB and the local administration. PGCB staff frequently visited the project sites to talk to local people about the project. Since the route survey has been done, people within the ROW are also aware about the proposed route alignment for the transmission line but they are not aware of when the project will actually commence and how much time will be required to complete the project.

Concerns identified by local people

Some farmers may not be able to cultivate the land due to the tower basement.

19 BAN: Power System Expansion and Efficiency Improvement Investment Program Tranche 1, Resettlement and Ethnic Minority Development Plan, 5 July 2012. 20 Department of Environment requires both an IEE and an EIA for projects classified as Red category such as power transmission. The IEE is required for site clearance after which an EIA will be conducted to secure the environmental clearance certificate. Formal public consultations of the affected people will be conducted during the EIA preparation.

Some households within the 80-m GIA will be disturbed during project implementation. For the BN Line, flood water during monsoon remains for as long as seven months. Passenger boats and cargo vessels may have difficulty navigating due to the presence of transmission towers. Potential difficulty in cultivating the land under the power lines and transmission towers as well as cattle rearing particularly during the rainy season. In the events of severe thunderstorms, the high voltage line may be dangerous and may be safety risks.

Suggestions from local people

People who would be affected in terms of loss of land should be compensated with land and properly resettled, if possible; People who would lose their livelihood such as sharecroppers and leaseholders should be compensated with cash; and, For displaced people, they should be accommodated for employment in the project depending on academic qualifications.

Agreement on overall proposed recommendations

All APs should be properly compensated for their standing crops and trees that may be damaged; Compensation money should not be given directly to the APs in the presence of Chairman/Member of the Union Parishad or Upazila Parishad but be transferred through their bank accounts; Proper compensation rate should be determined for different crops; No work for the project will commence until proper compensation is given to the displaced people; and, A third party of neutral monitoring agency should be engaged to monitor the compensation process to ensure that displaced people are properly compensated.

228. Overall, local people along the transmission line route expressed their support to the project and are optimistic of the potential employment opportunities from the project.

229. Additional consultations were done by the project preparatory technical assistance Consultants in the form of consultation meetings, socioeconomic surveys, and interviews.21 A total of 17 consultation meetings were carried out from May 8-28, 2012 attended by 267 persons where 44% consists of women (Appendix 5). Meetings were also held specifically for women (seven meetings) and the ethnic minorities (four meetings). Aside from these meetings, key informant interviews were conducted on 17-18 April 2012 and on 8-14 May 2012 to address the social implications of the project component.

230. The ethnic minorities within the CRK Line confirmed that the transmission line and the substations will not affect any site with social, cultural or spiritual significance to them and they are not expecting that the construction and operation activities of the project will breach any tradition and belief or disrupt any ritual.

231. No major issues or concerns were raised during the consultations carried out in April and May 2012 but they are expecting enhanced benefits from the project such as

21 Consultation meetings and key informant interviews carried out during the preparation of Resettlement and Ethnic Minority Development Plan following SPS 2009.

63 employment, development of local industries, increasing the technical skills of local labour, and entrepreneurship development.

232. Attendance to the public consultation meetings is given in Appendix 6. Feedback of local people during these consultations and the findings of the environmental and social assessment were presented in a Safeguards Workshop with PGCB, BPDB, and REB on 28 May 2012 (see Appendix 7).

233. A summary sheet containing relevant project information in Bangla will be made available by PGCB at their offices in Dhaka, at the Mymensingh Substation, Tangail Substation, and Chandraghona Substation as well as in its field offices in Rangamati and Khagrachhari. Once accepted by ADB, the IEE will be posted in the PGCB website as required by ADB’s SPS 2009 and Public Communications Policy 2011. Consultation with key project stakeholders in varying degree will continue throughout the life of the project.

4.7 Grievance Redress Mechanism

234. PGCB will ensure that local people will have the opportunity to express their legitimate grievance or file a complaint about the project by establishing a process to address the issues raised. This can be achieved by careful implementation of the EMP, continuing consultation and communication with stakeholders (as appropriate) during implementation by the Project Management Unit (PMU), PGCB, Contractor(s), and local government authorities. Contact details of the PMU for filing complaints will be posted in the project areas.

235. A grievance redress committee (GRC) at the union level will be set up by PGCB as soon as the project commence. Formation of GRC will be done through a gazette information from the Ministry of Power, Energy and Mineral Resources (MPEMR) and will ensure equal representation of women in the members of GRC. Figure 4.3 shows the organization of the GRC.

Figure 4.3 Grievance Redress Committee of Component 2

236. GRC will convene twice in a month and will keep a record of the grievances, classify, prioritize, and provide the solution(s) within 30 days from the date of the complaint. The record will include the contact details of the complainant, date the complaint was received and the nature of the complaint, agreement on corrective actions

64 and the date it was enforced, and the final outcome. All complaint-related documentation such as minutes of the meeting and decisions will be summarized and become part of the semi-annual monitoring report submitted to ADB.

237. The GRC will report to the complainant(s) about the developments regarding their grievances and the decisions of the GRC. If the grievance is not addressed, the complainant can seek legal redress of the grievance in the appropriate Courts.

238. The grievance redress mechanism is generally integrated in the compensation process for temporary damages and land acquisition (if any) in the Resettlement Plan (RP). As such, the cost of implementing the grievance redress mechanism will be taken from the administration cost which is part of the total cost of the RP of the project. In the event that the administration cost is not sufficient, the budget for the GRC will be taken from the contingency cost also included in the RP. The GRC will continue to function during the life of the Project.

239. Briefly, the process is described below:

Step 1 Affected persons (APs) are informed of their losses and entitlements in writing by PGCB (or PGCB-designated representative such as an NGO supporting the implementation of RP) or through a face-to-face meeting on resettlement and compensation issues. If the APs are satisfied with the terms of the entitlements, they can claim for payments from the PGCB. If there are disagreements, the APs can approach PGCB (or PGCB-designated representative such as an NGO supporting the implementation of RP) for clarification about their queries and concerns. If the APs are satisfied with the outcome, they can proceed with claims for compensation of their entitlements.

Step 2 If the issue(s) remains unresolved, the APs can go to the GRC assisted by PGCB (or PGCB-designated representative such as an NGO supporting the implementation of RP) who will refer the case with written documentation. The GRC will conduct hearing and resolve the issue within 30 days from the receipt of the complaint. The APs must be present during the hearing of the complaint and the Minutes will be documented and made available to the APs. PGCB Manager approves the Minutes and the decision sent to the APs. If an agreement is reached and the APs are satisfied with the decision, compensation can be claimed from PGCB.

Step 3 If still the issue(s) remains unresolved, the case is referred by the GRC to the appropriate court of law for settlement.

4.8 Environmental Management Plan

4.8.1 Mitigation

240. Table 4.9 presents the environmental impacts and mitigation measures with cost estimates while Table 4.10 presents the summary of budget estimates for the implementation of environmental management plan (EMP) during construction. The EMP will be updated before the start of civil works and as needed to accommodate any change in the condition of the site, performance of Contractor(s), and feedback from local people or other stakeholders.

4.8.2 Monitoring

241. Environmental monitoring during construction will be a day-to-day process to ensure that any departure or non-compliance to the EMP are avoided or immediately addressed so that any unforeseen impacts are quickly discovered and remedied.

242. Regular monitoring and maintenance of the power transmission system during operation will help ensure the integrity and safety of the structures and components, thus, minimizing safety risks to the public. Table 4.11 presents a summary of the environmental monitoring plan.

4.8.3 Implementation Arrangements

243. Management and general supervision of project implementation will be done by the PMU headed by the Project Director from PGCB. The overall implementation of the EMP will be carried out under the supervision of the Project Director, PMU. An environmental staff (or a firm that will be retained during implementation), who will be primarily responsible for ensuring that the EMP is properly implemented, will be recruited for the project prior to award of the civil works contract. Aside from this, he/she will coordinate and interact with Project Director, PMU on compliance to ADB requirements, relevant government agencies and local authorities on environmental issues and clearances, update and finalize the IEE, and will prepare environmental monitoring reports for submission to ADB at least twice a year during construction and annually during operation phase.

244. The Contractor(s) will be informed of their responsibility to comply with the EMP and the requirements of ADB. There are specific responsibilities for EMP compliance during construction phase that will rest with the Contractor who will be monitored by the environmental staff of the project.

4.9 Conclusion and Recommendation

255. The transmission line route has been selected using high-resolution remotely sensed data and is being designed with particular attention to avoiding protected areas, urban settlements, and sites with cultural and historical values. High-resolution remotely sensed images have been used in selecting the best route avoiding settlements and ecologically sensitive areas, and will generally traverse agricultural crop fields. This has been reconfirmed by the IEE team members who walked along the entire length of the alignment.

256. The project will contribute to the reliability of power transmission within the areas of Mymensingh, Tangail, Brahmanbaria, Narshingdi, Chandraghona, Rangamati, and Khagrachhari. Informal consultations with local people along the transmission line showed their keen interest in the project and are optimistic of the potential employment opportunities due to the project.

257. The project will not cause significant adverse environmental impacts during construction and operation. The adverse impacts of vegetation and land clearing within the ROW during the installation of transmission towers, stringing of conductors, and construction of new substation in Rangamati and Khagrachhari can be easily mitigated by proper planning and best practices in construction engineering to minimize the impacts.

258. To the extent possible, seasonal variations will be incorporated in scheduling and in carrying out the construction works to accommodate cropping/harvesting of local people directly affected by the ROW and the breeding of wildlife and other animals. People, whose crops, trees and other plants will be affected and damaged will be compensated.

259. Measures for mitigation and monitoring have been included in the EMP with cost estimates (where appropriate). The transmission towers will be erected and the line will be installed under expert supervision of the EPC and monitored by PGCB. The contractor will be required to comply with the EMP and the relevant national regulations on environment, labour, and occupational health and safety. Local hiring will be given priority. The project will have long-term positive impacts arising from improved quality and reliability of power transmission.

260. PGCB will secure the necessary environmental clearance from the DOE prior to any civil works and will post the IEE in their website as part of information disclosure required by ADB’s SPS 2009 and Public Communications Policy 2011.

Table 4.9 Environmental Management Plan

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected Pre-Construction and Design Phase Selection of Land and Mainly desktop review Study topographical and Included in the Project costs Design or survey transmission line people Walk-over survey may geotechnical information, forest engineers and route cause temporary and and environmental data, etc, and PMU-PGCB minimal disturbance to integrate with engineering localized area design and consultation with local people Construction Phase Orientation for People Awareness of workers Conduct briefing and training Included in the Project costs PMU-PGCB contractor and on the environmental for Contractor on the EMP, workers requirements during records management, and construction and their reporting responsibility as part of Consensus about the critical the team areas to be monitored and the Contractors’ required mitigation measures understanding of their responsibility in implementing the EMP Prepare workplan People Avoid effects of Temporary pedestrian and Included in Project costs Contractor(s), to control Land Contractors’ unplanned traffic management plan PMU-PGCB construction- Air Quality activities Materials management plan associated and Noise Smooth work Waste management plan impacts Water Quality implementation Noise and dust control plan Community and Safety plan Recruitment of People Conflict due to Use local labour for manual Included in the Project costs Contractor(s), project staff and potential workers’ work and eligible local PMU-PGCB workers migration workforce for clerical and Lack of local support office jobs to the project Encourage local village Opportunity for local groups or peoples people to engage in organization (if any) to non-agricultural monitor project contractors employment

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected Potential increase People Presence of None required ------in demand for construction workers services may become small- scale and temporary opportunity for enterprising local people to provide the services such as food, temporary housing, etc. Land clearing, Land Land clearing will be Vegetation within the ROW 5 for MT Line 5 for BN Line 10 for CRK Contractor(s), earthmoving and done only at the that are less than 3m in Line PMU-PGCB topsoil removal, tower sites height will be allowed to grow. and stockpiling of Only the exact Civil works guidelines will be soil and other amount of strictly implemented by the materials construction material Contractor. (i.e., sand, gravel, Tower foundations involve etc) will be located in small-scale excavations and the tower sites excavated topsoil will be used (impact will be for backfilling. temporary and Loss of agricultural land is insignificant). minimal. Agricultural activities Earthmoving will be for crops lower than 3 m with done during the ROW will be allowed after excavation of tower construction. foundation. There will be no slope modification as the site is generally flat. About 0.027 ha of agricultural land will be lost at the base of the tower to accommodate tower footings for MT Line and about 0.017 ha for BN Line.

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected Air quality Potential for Stringing of conductors is not 5 for MT Line 5 for BN Line None for CRK increased suspended expected to cause deterioration Line particulate matter and of ambient air quality vehicular emissions Construction vehicles will be maintained to minimize vehicular emissions. Noise Potential increase in Contractor shall take adequate --- noise level and measures to minimize noise ground vibration from level and nuisance in the construction vehicles vicinity of transmission line sites by following traffic management plan and construction schedule Provision of Land Contractor shall Temporary construction camps Included in the Project cost Contractor(s) temporary Water Quality provide temporary will not be needed for quarters and field facilities for workers installation of transmission line office at project including field office only. In the event, it will be site and warehouse absolutely needed, location will requirements be selected in consultation with PMU-PGCB and local authorities. Clearing of Land For MT Line, an Compensation to affected land 35 for MT 15 for BN Line 30 for CRK DOF, vegetation at the estimated 16,416 owners of their damaged Line (covers (covers Line (covers Contractor(s), ROW trees are within the crops, plants and trees. wildlife and expenses for flora and PMU-PGCB ROW, 47 trees for Crops and plants that are less flora flora and wildlife BN Line and 7,860 than 3 m in height such as protection, wildlife protection, trees at CRK Line. sugarcane, corn, rice, etc will and protection, and This also includes be maintained along the ROW. vegetation and vegetation herbs and shrubs.  Planting of trees at enhancement) vegetation enhancement) enhancement)

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected No wetland Rangamati, Khagrachari, and 133 as compensation for trees and crops (cost vegetation will be Narshingdi SS and at other estimates from BAN: Power System Expansion affected. suitable sites identified in and Efficiency Improvement Program Tranche 1, Vegetation at the consultation with DOF. Species Resettlement and Ethnic Minority Development tower foundation will of trees that are of medium Plan, 5 July 2012) be cleared and only height with high productivity trees that grow taller such as lemon, guava, etc are than 3 m at maturity preferred. within the ROW will be permanently cleared. Low-type of vegetation may be affected and crushed during conductor stringing. Loss of habitat for Avoid breeding season and 5 for MT Line 5 for BN Line 5 for CRK DOF, Contractor(s), some wildlife such as destruction of wildlife nests and Line PMU-PGCB birds, snakes, rats, habitat etc Revegetation program will help Less sedentary restore the loss habitat of some wildlife may be wildlife affected by clearing In some areas, loss of habitat of vegetation due to stringing of transmission line will naturally regenerate in 2-3 years. Erection of towers People Interference with road Danger and clearly visible 5 for MT Line 10 for BN Line None Contractor(s), and stringing of Land crossings warning signs will be posted at (contingency (Cash to PMU-PGCB transmission line designated sites to cover cover any Scaffoldings will be placed over unexpected unexpected road crossing points events event) causing harm to the public and workers)

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected Construction waste Appropriate signs will be 5 for MT Line 5 for BN Line 5 for CRK Contractor(s), left by workers installed for public safety Line PMU-PGCB Surrounding area within tower sites and substations will be kept clean Potential safety risks Maintain necessary fence or 5 for MT Line 5 for BN Line 5 for CRK Contractor(s), to public barricade (as appropriate), (Contingency (contingency Line PMU-PGCB sufficient lights, signs and to cover any to cover any (contingency danger signals, and take all unexpected unexpected to cover any required precautions for event) event) unexpected public safety event) Assign security personnel to prevent accidents and trespassing Require Contractor to direct drivers of construction vehicles to strictly follow road regulations Potential safety risks Study prepared safety plan 5 for MT Line 5 for BN Line 5 for MT Line Contractor(s), to workers before start of construction (contingency (contingency (contingency PMU-PGCB Provide every workers with to cover to cover to cover hard hat, safety shoes and unexpected unexpected unexpected belts events events events Set up first aid treatment causing harm causing harm causing harm within construction sites and to workers) to workers) to workers) field office Observance and compliance with relevant safety measures required by law and best engineering practices Provide communication devices to designated workers Temporary The seven shops will be re- 21.75 for MT Line and BN Line (cost estimates District dismantling of seven constructed away from the from BAN: Power System Expansion and Commissioner shops within the ROW. Owners will get better Efficiency Improvement Program Tranche 1, Office, ROW of MT Line. shops than the present Resettlement and Ethnic Minority Development Contractor(s),

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected These seven shops condition. Plan, 5 July 2012) PMU-PGCB consist of tea stalls Compensation will be and grocery shops provided to owners of will be shifted away structures affected by the MT from the ROW. Line and BN Line One unused building will be affected by the BN Line. Operation Phase Hazards due to People and Electrocution hazards A protection system that shuts Included in the O & M costs of Project PGCB and/or accidental failure wildlife will occur only if off during power overload or Contractor (if this of transmission someone comes too similar emergencies will be service is lines close or in contact installed outsourced) with the transmission Transmission lines are line cable insulated (or covered) to minimize impacts to birds and bats Regular monitoring and maintenance to ensure safety and integrity of towers and power lines As part of corporate social responsibility initiatives, conduct information and education campaign to local people to enhance awareness on transmission line safety practices. Encroachment to People Potential danger to Periodic inspection and Included in the O & M costs PGCB and/or ROW both people and maintenance of ROW Contractor (if this power transmission Restrict landuse practices service is structures and any other infrastructure outsourced) that will negatively affect power transmission system

Environmental Component Description of Mitigation/Enhancement Estimated Cost* Responsible Project Activity Likely to be Potential Impact Measures (Lahk Taka) agency/unit Affected Clearing of Land Restriction of planting Regular trimming to maintain Included on the O&M costs PGCB and/or vegetation within large trees within the adequate distance between Contractor (if this the ROW (i.e., ROW to keep the top of tree and the service is pruning of integrity of power conductors outsourced) vegetation higher transmission system than 3 m) Presence of People Potential exposure to Electric and magnetic field Included on the O&M costs PGCB and/or overhead electromagnetic from the 132 kV overhead Contractor (if this transmission line radiation transmission line and 75 MVA service is and substations transformers are expected to outsourced) be way below the limits set by ICNRP of 4.17 kV/m for electric field and 833 mG for magnetic field Substations will be fenced and security staff assigned to prevent public access Information and education campaign will be conducted to local people to create awareness on safety practices Use of SF6 People Fugitive emissions Leaks will be monitored in a Included on the O&M costs PGCB and/or handling Air from SF6 handling timely manner Contractor (if this equipment equipment SF6 level will be recorded as service is SF6 is a potent GHG an inventory to determine outsourced) consumption *Estimates provided by CEGIS (2012)

Table 4.10 Environmental Monitoring Plan

Responsibility Project Stage Parameter/Indicator Location Frequency (Implementation and Supervision) Pre- Soil sampling Tower sites Once before PMU-PGCB, Construction construction Contractor Loss in crop production Along the Monthly District alignment Commissioner`s staff, PMU-PGCB, Contractor Preparation of approach Along the Once before PMU-PGCB, roads alignment and construction Contractor substations Local recruitment of Tower sites and Monthly PMU-PGCB, workers and staff substations Contractor Construction Spraying of water to Along the Weekly at Contractor, PMU- exposed land and before alignment and alignment PGCB movement of construction substations Every day at vehicles substation sites Solid waste management Along the Every week Contractor, PMU- alignment and PGCB substations Danger and warning signs Along the Once a month Contractor, PMU- for safety of workers and the alignment and PGCB public substations Announcement to the public Along the As needed Contractor, PMU- of works schedule alignment and PGCB substations Operation Failure of transmission Along the Every month PGCB towers alignment Trimming of vegetation or Along the Quarterly PGCB lopping of trees alignment ROW Inventory of SF6 Substations and Semiannual PGCB T/L Pilferage of cables Along the Quarterly PGCB alignment

Appendix 1

Department of Environment Classification of industrial units or projects based on its location and impact on environment

Schedule 1 - Environment Conservation Rules 1997 [ See Rule 7(2) ]

(A) GREEN CATEGORY

1. Assembling and manufacturing of TV, Radio, etc. 2. Assembling and manufacturing of clocks and watches. 3. Assembling of telephones. 4. Assembling and manufacturing of toys (plastic made items excluded). 5. Book-binding. 6. Rope and mats (made of cotton, jute and artificial fibers). 7. Photography (movie and x-ray excluded). 8. Production of artificial leather goods. 9. Assembling of motorcycles, bicycles and toy cycles. 10. Assembling of scientific and mathematical instruments (excluding manufacturing). 11. Musical instruments. 12. Sports goods (excluding plastic made items). 13. Tea packaging (excluding processing). 14. Re-packing of milk powder (excluding production). 15. Bamboo and cane goods. 16. Artificial flower (excluding plastic made items). 17. Pen and ball-pen. 18. Gold ornaments (excluding production) (shops only). 19. Candle. 20. Medical and surgical instrument (excluding production). 21. Factory for production of cork items (excluding metallic items). 22. Laundry (excluding washing).

Foot Notes:

(a) Units of all kinds of cottage industries other than those listed in this Schedule shall remain outside the purview of Environmental Clearance Certificate (Unit of cottage industry means all industrial units producing goods or services in which by full-time or part-time labour of family members are engaged and the capital investment of which does not exceed Taka 5 (five) hundred thousand). (b) No industrial unit listed in this Schedule shall be located in any residential area. (c) Industrial units shall preferably be located in areas declared as industrial zones or in areas where there is concentration of industries or in vacant areas. (d) Industrial units likely to produce sound, smoke, odor beyond permissible limit shall not be acceptable in commercial areas.

(B) ORANGE-A CATEGORY

1. Dairy Farm, 10 (ten) cattle heads or below in urban areas and 25 cattle heads or below in rural areas. 2. Poultry (up to 250 in urban areas and up to 1000 in rural areas). 3. Grinding/husking of wheat, rice, turmeric, pepper, pulses (up to 20 Horse Power). 4. Weaving and handloom. 5. Production of shoes and leather goods (capital up to 5 hundred thousand Taka). 6. Saw mill/wood sawing. 7. Furniture of wood/iron, aluminum, etc.,(capital up to 5 hundred thousand Taka). 8. Printing Press.

9. Plastic & rubber goods (excluding PVC). 10. Restaurant. 11. Cartoon/box manufacturing/printing packaging. 12. Cinema Hall. 13. Dry-cleaning. 14. Production of artificial leather goods (capital up to 5 hundred thousand Taka). 15. Sports goods. 16. Production of salt (capital up to 10 hundred thousand Taka). 17. Agricultural machinery and equipment. 18. Industrial machinery and equipment. 19. Production of gold ornaments. 20. Pin, U Pin. 21. Frames of spectacles. 22. Comb. 23. Production of utensils and souvenirs of brass and bronze. 24. Factory for production of biscuit and bread (capital up to 5 hundred thousand Taka). 25. Factory for production of chocolate and lozenge. (capital up to 5 hundred thousand Taka). 26. Manufacturing of wooden water vessels.

1. PVC items. 2. Artificial fiber (raw material). 3. Glass factory. 4. Life saving drug (applicable to formulation only). 5. Edible oil. 6. Tar. 7. Jute mill. 8. Hotel, multi-storied commercial & apartment building. 9. Casting. 10. Aluminum products. 11. Glue (excluding animal glue). 12. Bricks/tiles. 13. Lime. 14. Plastic products. 15. Processing and bottling of drinking water and carbonated drinks. 16. Galvanizing. 17. Perfumes, cosmetics. 18. Flour (large). 19. Carbon rod. 20. Stone grinding, cutting, polishing. 21. Processing fish, meat, food. 22. Printing and writing ink. 23. Animal feed. 24. Ice-cream. 25. Clinic and pathological lab. 26. Utensils made of clay and china clay/sanitary wares (ceramics). 27. Processing of prawns & shrimps. 28. Water purification plant. 29. Metal utensils/spoons etc. 30. Sodium silicate. 31. Matches. 32. Starch and glucose. 33. Animal feed. 34. Automatic rice mill. 35. Assembling of motor vehicles. 36. Manufacturing of wooden vessel. 37. Photography (activities related to production of films for movie and x-ray). 38. Tea processing.

39. Production of powder milk/condensed milk/dairy. 40. Re-rolling. 41. Wood treatment. 42. Soap. 43. Repairing of refrigerators. 44. Repairing of metal vessel. 45. Engineering works (up to 10 hundred thousand Taka capital.) 46. Spinning mill. 47. Electric cable. 48. Cold storage. 49. Tire re-treading. 50. Motor vehicles repairing works (up to 10 hundred thousand Taka capital). 51. Cattle farm: above 10 (ten) numbers in urban area, and above 25 (twenty five) numbers in rural area. 52. Poultry: Number of birds above 250 (two hundred fifty) in urban area and above 1000 (one thousand) in rural area. 53. Grinding/husking wheat, rice, turmeric, chilly, pulses – machine above 20Horse Power. 54. Production of shoes and leather goods, above 5 (five) hundred thousand Taka capital. 55. Furniture of wood/iron, aluminum, etc., above 5 (five) hundred thousand Taka capital. 56. Production of artificial leather goods, above 5 (five) hundred thousand Taka capital. 57. Salt production, above 10 (ten) hundred thousand Taka capital. 58. Biscuit and bread factory, above 5 (five) hundred thousand Taka capital. 59. Factory for production of chocolate and lozenge, above 5 (five) hundred thousand Taka capital. 60. Garments and sweater production. 61. Fabric washing. 62. Power loom. 63. Construction, re-construction and extension of road (feeder road, local road). 64. Construction, re-construction and extension of bridge (length below 100 meters). 65. Public toilet. 66. Ship-breaking. 67. G.I. Wire. 68. Assembling batteries. 69. Dairy and food.

Foot Notes:

(a) No industrial unit included in this list shall be located in any residential area. (b) Industrial units shall preferably be located in areas declared as industrial zones or in areas where there is concentration of industries or in vacant areas. (c) Industrial units likely to produce sound, smoke, odor beyond permissible limit shall not be acceptable in commercial areas.

(D) RED CATEGORY

1. Tannery 2. Formaldehyde 3. Urea fertilizer 4. T.S.P. Fertilizer 5. Chemical dyes, polish, varnish, enamel 6. Power plant 7. All mining projects (coal, limestone, hard rock, natural gas, mineral oil, etc.) 8. Cement 9. Fuel oil refinery 10. Artificial rubber 11. Paper and pulp 12. Sugar 13. Distillery 14. Fabric dying and chemical processing

15. Caustic soda, potash 16. Other alkalis 17. Production of iron and steel 18. Raw materials of medicines and basic drugs 19. Electroplating 20. Photo films, photo papers and photo chemicals 21. Various products made from petroleum and coal 22. Explosives 23. Acids and their salts (organic or inorganic) 24. Nitrogen compounds (Cyanide, Cyanamid, etc.) 25. Production of plastic raw materials (PVC, PP/Iron, Polyesterin etc.) 26. Asbestos 27. Fiberglass 28. Pesticides, fungicides and herbicides 29. Phosphorus and its compounds/derivatives 30. Chlorine, fluorine, bromine, iodine and their compounds/derivatives 31. Industry (excluding nitrogen, oxygen and carbon dioxide) 32. Waste incinerator 33. Other chemicals 34. Ordnance 35. Nuclear power 36. Wine 37. Non-metallic chemicals not listed elsewhere 38. Non-metals not listed elsewhere 39. Industrial estate 40. Basic industrial chemicals 41. Non-iron basic metals 42. Detergent 43. Land-filling by industrial, household and commercial wastes 44. Sewage treatment plant 45. Life saving drugs 46. Animal glue 47. Rodenticide 48. Refractories 49. Industrial gas (Oxygen, Nitrogen & Carbon-dioxide) 50. Battery 51. Hospital 52. Ship manufacturing 53. Tobacco (processing/cigarette/Biri-making) 54. Metallic boat manufacturing 55. Wooden boat manufacturing 56. Refrigerator/air-conditioner/air-cooler manufacturing 57. Tyre and tube 58. Board mills 59. Carpets 60. Engineering works: capital above 10 (ten) hundred thousand Taka. 61. Repairing of motor vehicles: capital above 10 (ten) hundred thousand Taka 62. Water treatment plant 63. Sewerage pipe line laying/relaying/extension 64. Water, power and gas distribution line laying/relaying/extension 65. Exploration/extraction/distribution of mineral resources 66. Construction/reconstruction/expansion of flood control embankment, polder, dike, etc. 67. Construction/reconstruction/expansion of road (regional, national & international) 68. Construction/reconstruction/expansion of bridge (length 100 meter and above) 69. Murate of Potash (manufacturing)

Foot Notes:

(a) No industrial unit included in this list shall be allowed to be located in any residential area.

(b) Industrial units shall preferably be located in areas declared as industrial zones or in areas where there is concentration of industries or in vacant areas. (c) Industrial units likely to produce sound, smoke, odor beyond permissible limit shall not be acceptable in commercial areas. (d) After obtaining location clearance on the basis of Initial Environment Examination (IEE) Report, the Environmental Impact Assessment (EIA) Report in accordance with the approved terms of reference along with design of ETP and its time schedule shall be submitted within approved time limit.

Appendix 2

Relevant Environmental Standards from Bangladesh ECR 1997

Schedule 2 Standards for Air [See Rule 12]

Density in microgram per cusec meter

Suspended Sl. Categories of Carbon Oxides of Particulate Sulphur dioxide No. Area Monoxide Nitrogen Matter (SPM) a. Industrial and 500 120 5000 100 mixed b. Commercial and 400 100 5000 100 mixed c. Residential and 200 80 2000 80 rural d. Sensitive 100 30 1000 30

Notes: (1) At national level, sensitive area includes monuments, health center, hospital, archeological site, educational institution, and government designated areas (if any). (2) Industrial units located in areas not designated as industrial areas shall not discharge pollutants which may contribute to exceeding the standard for air surrounding the areas specified at Sl. nos. c and d above. (3) Suspended Particulate Matter means airborne particles of a diameter of 10 micron or less.

Schedule 3 Standards for Water [See Rule 12]

(A) Standards for inland surface water Parameter Best Practice based pH BOD DO Total Coliform classification mg/L mg/L number/100 a. Source of drinking water for 6.5-8.5 2 or less 6 or above 50 or less supply only after disinfecting: b. Water usable for 6.5-8.5 3 or less 5 of more 200 or less recreational activity : c. Source of drinking water for 6.5-8.5 6 or less 6 of more 5000 or less supply after conventional treatment : d. Water usable by fisheries: 6.5-8.5 6 or less 5 of more --- e. Water usable by various 6.5-8.5 10 or less 5 of more 5000 or less process and cooling industries : f. Water usable for irrigation: 6.5-8.5 10 or less 5 of more 1000 or less

Notes: 1. In water used for pisiculture, maximum limit of presence of ammonia as Nitrogen is 1.2 mg/l. 2. Electrical conductivity for irrigation water – 2250 µmhoms/cm (at a temperature of 25°C); Sodium less than 26%; boron less than 0.2%.

(B) Standards for drinking water

SI Parameter Unit Standard No. 1 Aluminum mg/L 0.2 2 Ammonia (NH3) “ 0.5 3 Arsenic “ 0.05

SI Parameter Unit Standard No. 4 Barium “ 0.01 5 Benzene “ 0.01 6 BOD5 20°C “ 2.0 7 Boron “ 1.0 8 Cadmium “ 0.005 9 Calcium “ 75 10 Chloride “ 150-600* 11 Chlorinated alkanes “ 0.01 Carbon tetrachloride 1.1 dichloroethylene “ 0.001 1.2 dichloroethylene “ 0.03 1.2 dichloroethylene “ 0.03 trichloroethylene “ 0.09 12 Chlorinated phenols “ - pentachlorophenol “ 0.03 - 2.4.6 trichlorophenol “ 0.03 13 Chlorine (residual) “ 0.2 14 Chloroform “ 0.09 15 Chromium (hexavalent) “ 0.05 16 Chromium (total) “ 0.05 17 COD “ 4.0 18 Coliform (fecal) n/100 ml 0 19 Coliform (total) n/100 ml 0 20 Color Hazen 15 unit 21 Copper mg/L 1 22 Cyanide “ 0.1 23 Detergents “ 0.2 24 DO “ 6 25 Fluoride “ 1 26 Hardness (as CaCO3) “ 200 – 500 27 Iron “ 0.3 – 1.0 28 Kjeldhl Nitrogen (total) “ 1 29 Lead “ 0.05 30 Magnesium “ 30 – 35 31 Manganese “ 0.1 32 Mercury “ 0.001 33 Nickel “ 0.01 34 Nitrate “ 10 35 Nitrite “ <1 36 Odor “ Odorless 37 Oil and grease “ 0.01 38 pH --- 6.5 – 8.5 39 Phenolic compounds mg/L 0.002 40 Phosphate “ 6 41 Phosphorus “ 0 42 Potassium “ 12 43 Radioactive materials Bq/l 0.01 (gross alpha activity) 44 Radioactive materials Bq/l 0.1 (gross beta activity) 45 Selenium mg/L 0.01 46 Silver “ 0.02 47 Sodium “ 200 48 Suspended particulate matters “ 10 49 Sufide “ 0 50 Sulfate “ 400 51 Total dissolved solids “ 1000 52 Temperature “ 20-30 53 Tin “ 2 54 Turbidity JTU 10 55 Zinc mg/L 5

Schedule 4 Standards for Sound [See Rule 12]

Standards determined at dBa unit Sl No Category of areas Day Night a. Silent zone 45 35 b. Residential area 50 40 c. Mixed area 60 50 (mainly residential area, and also simultaneously used for commercial and industrial purposes) d. Commercial area 70 60 e. Industrial area 75 70

Notes: 1. The time from 6 a.m. to 9 p.m. is counted as daytime. 2. The time from 9 p.m. to 6 a.m. is counted as night time. 3. Area up to a radius of 100 meters around hospitals or educational institutions or special institutions/ establishments identified/to be identified by the Government is designated as Silent Zones where use of horns of vehicles or other audio signals, and loudspeakers are prohibited.

Schedule 5 Standards for Sound originating from Motor Vehicles or Mechanized Vessels [ See Rule 12]

Category of Vehicles Unit Standards Remarks *Motor Vehicles (all types) dBa 85 As measured at a distance of 7.5 meters from exhaust pipe. 100 As measured at a distance of 0.5 meter from exhaust pipe.

Mechanized Vessels dBa 85 As measured at a distance of 7.5 meters from the vessel which is not in motion, not loaded and is at two thirds of its maximum rotating speed. 100 As measured at a distance of 0.5 meter from the vessel which is in the same condition as above. * At the time of taking measurement, the motor vehicle shall not be in motion and its engine conditions shall be as follows:-

(a) Diesel engine – maximum rotating speed. (b) Gasoline engine –at two thirds of its maximum rotating speed and without any load. (c) Motorcycle – If maximum rotating speed is above 5000 rpm; two thirds of the speed, and if maximum rotating speed is less than 5000 rpm, three-fourth of the speed.

Schedule 6 Standards for Emission from Motor Vehicles [ See Rule 12 ]

Parameter Unit Standard Limit Black Smoke Hartridge Smoke Unit (HSU) 65 Carbon Monoxide gm/km 24 percent area 04 Hydrocarbon gm/km 02 ppm 180 Oxides of Nitrogen gm/km 02 ppm 600 * As measured at two thirds of maximum rotating speed.

Schedule 10 Standards for Waste From Industrial Units or Projects Waste [ See Rule 13 ]

Discharge To Public Sewerage Sl. Inland Parameters Unit system connected to Irrigated No. Surface treatment at second Land Water stage 1 Ammonical nitrogen (as mg/L 50 75 75 elementary N) 2 Ammonia (as free ammonia) mg/L 5 5 15 3 Arsenic (as As) mg/L 0.2 0.05 0.2 o 4 BOD5 at 20 C mg/L 50 250 100 5 Boron mg/L 2 2 2 6 Cadmium (as Cd) mg/L 0.5 0.05 0.05 7 Chloride mg/L 600 600 600 8 Chromium (as total Cr) mg/L 0.5 1.0 1.0 9 COD mg/L 200 400 400 10 Chromium (as hexavalent Cr) mg/L 0.1 1.0 1.0 11 Copper (as Cu) mg/L 0.5 3.0 3.0 12 Dissolved oxygen (DO) mg/L 4.5-8 4.5-8 4.5-8 13 Electro-conductivity (EC) micromho/cm 1200 1200 1200 14 Total dissolved solids mg/L 2100 2100 2100 15 Flouride (as F) mg/L 2 15 10 16 Sulfide (as S) mg/L 1 2 2 17 Iron (as Fe) mg/L 2 2 2 18 Total kjeldahl nitrogen (as N) mg/L 100 100 100 19 Lead (as Pb) mg/L 0.1 1 0.1 20 Manganese (as Mn) mg/L 5 5 5 21 Mercury (as Hg) mg/L 0.01 0.01 0.01 22 Nickel (as Ni) mg/L 1.0 2.0 1.0 23 Nitrate (as elementary N) mg/L 10.0 Not yet set 10 24 Oil and grease mg/L 10 20 10 25 Phenolic compounds (as mg/L 1.0 5 1.0 C6H5OH) 26 Dissolved phosphorus (as P) mg/L 8 8 15 27 Radioactive substance (to be specified by Bangladesh Atomic Energy Commission) 28 pH ---- 6-9 6-9 6-9 29 Selenium (as Se) mg/L 0.05 0.05 0.05 30 Zinc (as Zn) mg/L 5 10 10 oC (summer) 40 40 40 31 Temperature o C (winter) 45 45 45 32 Suspended solids (SS) mg/L 150 500 200 33 Cyanide (as Cn) mg/L 0.1 2.0 0.2

Notes: (1) These standards shall be applicable to all industries or projects other than those specified under the heading “Standards for sector wise industrial effluent or emission.” (2) Compliance with these standards shall be ensured from the moment an industrial unit starts trial production, and in other cases, from the moment a project starts operation. (3) These standards shall be inviolable even in case of any sample collected instantly at any point of time. These standards may be enforced in a more stringent manner if considered necessary in view of the environmental conditions of a particular situation. (4) Inland Surface Water means drains/ponds/tanks/water bodies/ ditches, canals, rivers, springs and estuaries. (5) Public sewerage system means treatment facilities of the first and second stage and also the combined and complete treatment facilities. (6) Irrigable land means such land area which is sufficiently irrigated by waste water taking into consideration the quantity and quality of such water for cultivation of selected crops on that land. (7) Inland Surface Water Standards shall apply to any discharge to a public sewerage system or to land if the discharge does not meet the requirements of the definitions in notes 5 and 6 above.

Schedule 11 Standards for Gaseous Emission from Industries or Projects [See Rule 13]

Standard present in a unit Sl.No. Parameters 3 of mg/Nm 1. Particulate (a) Power plant with capacity of 200 Megawatt or above. 150 (b) Power plant with capacity less than 200 Megawatt. 350 2. Chlorine 150 3. Hydrochloric acid vapor and mist 350 4. Total Fluoride F 25 5. Sulfuric acid mist 50 6. Lead particulate 10 7. Mercury particulate 0.2 8. Sulfur dioxide kg/ton acid (a) Sulfuric acid production (DCDA* process) 4 (b) Sulfuric acid production (SCSA* process) 20 (*DCDA: Double Conversion, Double Absorption; SCSA: Single Conversion, Single Absorption.) Lowest height of stack for dispersion of sulfuric acid (in meter) (a) Coal based power plant (1) 500 Megawatt or above 275 (2) 200 to 500 Megawatt 220 0.3 (3) Less than 200 Megawatt 14(Q) (b) Boiler (1) Steam per hour up to 15 tons 11 0.3 (2) Steam per hour more that 15 ton 14(Q) [Q = Emission of Sulfur dioxide (kg/hour)]. 9. Oxides of Nitrogen (a) Nitric acid production 3 kg/ton acid (b) Gas Fuel based Power Plant (1) 500 Megawatt or above 50ppm (2) 200 to 500 Megawatt 40ppm (3) Below 200 Megawatt 30ppm (c) Metallurgical oven 200ppm 10. Kiln soot and dust mg/Nm3 (a) Blast Furnace 500 (b) Brick Kiln 1000 (c) Coke oven 500 (d) Lime Kiln 250

Appendix 3

Relevant Environmental Laws and Regulations in Bangladesh

Title Responsible Agency Key Features The Environment Department of Declaration of Ecologically Critical Areas; Conservation Act, 1995 and Environment, Ministry of Obtaining Environmental Clearance subsequent amendments in Environment and Forest Certificate; 2000 and 2002 Regulation with respect to vehicles emitting smoke harmful for the environment; Regulation of development activities from environmental perspective; Promulgation of standards for quality of air, water, noise, and soils for different areas and for different purposes; Promulgation of acceptable limits for discharging and emitting waste; Formulation of environmental guidelines relating to control and mitigation of environmental pollution, conservation and improvement of environment Environment Conservation Department of Declaration of Ecologically Critical Area; Rules, 1997 and Environment, Ministry of Requirement of Environmental Clearance subsequent amendments in Environment and Forest Certificate for various categories of projects; 2002 and 2003 Requirement for IEE/EIA according the appropriate category of the project; Renewal of the environmental clearance certificate within 30 days after the expiry; Provides standards for quality of air, water & sound and acceptable limits for emission/discharges from vehicles and other sources The Factories Act, 1965 Ministry of Labour This Act relates to the occupational rights and Bangladesh Labour Law safety of factory workers and the provision of a 2006 comfortable work environment and reasonable working conditions. The Building Construction Ministry of Works An Act to provide for the prevention of Act 1952 and subsequent haphazard construction of building and amendments excavation of tanks which are likely to interfere with the planning of certain areas in Bangladesh The Vehicle Act, 1927; The Bangladesh Road Exhaust emission; Vehicular air and noise; Motor Vehicles Ordinance, Transport Authority Road safety 1983;The Bengal Motor Vehicle Rules, 1940 Water Supply and Ministry of Local Management and Control of water supply and Sanitation Act, 1996 Government, Rural sanitation in urban areas. Development and Cooperatives The Ground Water Upazila Parishad Management of ground water resources; Tube Management Ordinance well shall not be installed in any place without 1985 the license granted by Upazila Parishad The Private Forests Regional Forest Officer, Conservation of private forests and for the Ordinance Act, 1959 Forest Department afforestation on wastelands The Protection and Ministry of Fishery Protection and Conservation of fish in Conservation of Fish Act Government owned water bodies 1950 and subsequent amendments in 1982 Natural Water Bodies Rajdhani Unnayan According to this Act, the character of water Protection Act 2000 Kartipakkha/Town bodies i.e. rivers, canals, tanks, or floodplains Development identified as water bodies in the master plans or Authority/Municipalities in the master plans formulated under the laws establishing municipalities in division and district towns shall not be changed without approval of concerned ministry.

Title Responsible Agency Key Features Antiquities Act 1968 Ministry of Cultural Affairs Governs the preservation of national cultural heritage, protects and controls ancient monuments, regulates antiquities as well as the maintenance, conservation and restoration of protected sites and monuments, controls planning, exploration and excavation of archaeological sites. Bangladesh Wild Life Ministry of Environment and The wildlife law provides for the protection of (Preservation) Act 1974 Forest Bangladesh Wild wildlife as well as the habitats. The Act defines Life Advisory Board various protected areas in the form of game reserve, national park and wildlife sanctuary and aims at preserving wildlife of those protected areas. The wildlife sanctuary regime also requires undisturbed breeding ground for the protection of wildlife as well as all natural resources in the sanctuary. The Forest Act 1927 and Ministry of Environment and This Act aims to consolidate the laws relating to subsequent amendments in Forest forests, and duty leviable on timber and other 1982 and 1989 forest-produce. The law was mainly enacted to generate revenues from forest products. The Act empowers the Government to declare portions of its forests as Reserved or Protected and by doing that it may take measures for in situ conservation of biodiversity. Any acts or omission detrimental to the natural resources of reserved and protected forests are prohibited and are punishable offences. Among them, the more serious ones include making fresh clearing of forest lands, removing timbers, setting fires, felling or otherwise damaging trees, clearing or breaking up any land for cultivation or any other purpose.

The Act was amended in 2000 to accommodate provisions to establish social forestry involving local community participation in the management regime. Following the Act, social forestry rules are under preparation by the Forest Department. Environment Court Act, Judiciary and Ministry of This Act has been enacted in order to establish 2000 and subsequent Environment & Forest environmental courts in each administrative amendments 2002 division of Bangladesh. Under this Act, the court has concurrent jurisdiction, i.e. to try both civil and criminal cases. The basis for instituting a case is a violation of the “environmental law”, meaning the Bangladesh Environment Conservation Act, 1995 and Rules made thereunder. In particular the environment court is empowered to:

Impose penalties for violating court orders; Confiscate any article, equipment and transport used for the commission of the offence; Pass any order or decree for compensation; Issue directions to the offender or any person (a) not to repeat or continue the offence; (b) to take preventive or remedial measures with relation to any injury, specifying the time limit and reporting to the DOE regarding the implementation of the directions.

Under this Act the Director General of the DOE

Title Responsible Agency Key Features has the power to impose heavy penalties to industrial polluters who are dumping untreated wastewater into the environment or not operating their legally mandated Effluent Treatment Plants. The Embankment and Ministry of Water This Act consolidates the laws relating to Drainage Act 1952 Resources and Flood embankment and drainage and to make better Control and Drainage provision for the construction, maintenance, (FCD) 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.

In particular the Act is empowered to impose: penalty for obstructing persons in exercise of powers under this Act penalty for unauthorised interference and abuttment thereof penalty for injuring embankment, etc penalty for diverting rivers or grazing cattle on embankments

Removal of obstruction and repair of damage

Appendix 4

Details of Audit and Site Investigations for Component 1

1.0 Audit and Site Investigation Procedure

The audit and site investigation for the conversion of the existing open cycle gas turbine power plants was conducted through review of available relevant project documents, site visits to the power plants, and meetings and interviews with key management staff of BPDB and NWPGC as well as the operations technical staff of the power plants. The power plants were visited on the following dates:

Shahjibazar Power Plant – 10 April 2012 Sylhet Power Plant – 11 April 2012 Baghabari Power Plant – 24-25 May 2012 Khulna Power Plant – 24-25 May 2012

Data gathering was conducted from 26 March until 29 May 2012 to complement the site visits. The list of persons met is presented in Table A4.1.

Table A4.1 List of Persons Met During the Audit and Site Investigation

Name of Staff Designation Location Dhurjjati Prosad Sen Manager, Shahjibazar Power Station, Shahjibazar, Hobiganj, Sylhet BPDB Nazmul Karim Sub-Assistant Engineer, Shahjibazar Shahjibazar, Hobiganj, Sylhet Power Station, BPDB Belal Ahmed Executive Engineer, Sylhet Power Kumargao, Sylhet Chowdhury Station, BPDB Md. Abduhu Board Member, Planning and WAPDA Bhaban, Dhaka Ruhullah Development, Bangladesh Power Development Board (BPDB) Khaled Mahmood Director, Design 1, BPDB WAPDA Bhaban, Dhaka K. M. Hassan Chief Executive, BPDB WAPDA Bhaban, Dhaka Rewzaul Kabir Director for Project Planning, BPDB WAPDA Bhaban, Dhaka Md.Abdul Hakim Manager, Baghabari Power Station, Baghabari, Shahjadpur, Sirajgonj BPDB Md. Emdadul Haque Executive Engineer, Baghabari Power Baghabari, Shahjadpur, Sirajgonj Station, BPDB Biswanath Sarker Sub-Assistant Engineer, Baghabari Baghabari, Shahjadpur, Sirajgonj Power Station, BPDB A. M. Kurshedul Managing Director, North-West Power Corporate Office, Dhaka Alam Generation Company Ltd Tushar Kanti Paul Deputy General Manager/Project Corporate Office, Dhaka Director, 150 MW Khulna Power Plant, NWPGCL Mashuda Parwin Assistant Manager (Environment), Corporate Office, Dhaka NWPGCL Harendra Nath Chief Engineer, 150 MW Khulna Power Goalpara, Khulna Mondal Plant, NWPGCL Sreenath Acharjya Plant Manager, Khulna Power Goalpara, Khulna Company Ltd. Md. Hasibal Hasan Engineer, NWPGCL Goalpara, Khulna

2.0 Findings and Areas of Concern

2.1 Shahjibazar Power Plant

2.1.1 Existing non-operational gas turbine units

Unit 1, Unit 3, and Unit 7 were retired in 1996. Unit 2 and Unit 4 require rehabilitation and overhauling and have been shut down. In August 2011, Unit 5 and Unit 6 stopped operating due to rotor grounding. A Technical Committee was set up by BPDB to study and determine the feasibility of rehabilitating and overhauling of Unit 2, Unit 4, Unit 5 and Unit 6. All these units are more than 40 years old and spare parts requirements to do the rehabilitation and overhaul may no longer be available in the market, and thus, BPDB decided that all these units will be retired. Unit 8 and Unit 9 will be converted to combined- cycle power plants.

Unit 1, Unit 3 and Unit 7 were retired almost 16 years ago but these units are still within the Shahjibazar Power Plant. With Unit 5 and Unit 6 non-operating since August 2011, all the seven units are idle with no definite plan for decommissioning. Some of the stacks of the units are corroding and the continued abandonment of these units may pose environmental risks (see Figure 3.4).

Figure A4.1 Non-operating Gas Turbine Units at Shahjibazar Power Plant

2.1.2 Compliance to national environmental regulations

Unit 8 and Unit 9 started operating in 2000 but its compliance to national environmental regulations is unclear as no environmental reports or environmental clearance was provided. No environmental monitoring and reporting are being done. There is no staff in the power plant designated to deal with environmental issues associated with power plant operation and to coordinate with DOE, the public, and other stakeholders.

2.1.3 Services within the property of the power plant

There are about 70 families of staff living within the 24.3-ha compound of the Shahjibazar Power Plant. Services provided to the residents include a small hospital, elementary school, a mosque, open space for outdoor recreation like soccer and cricket, multi- purpose hall for community activities, commercial area to meet daily requirements of

91 residents, fire fighting system, and a small public space in front of the main office building where a war hero memorial is located. Staff without family, who reside within the compound, have different living quarters to those staff with family. Drinking water is provided to both the power plant operation and the residents in the compound supplied by the groundwater well operated by Shahjibazar Power Plant.

Medical services include an ambulance, a doctor, two pharmacists, a midwife and a nurse. Open space is made available near the residential area for staff with family to serve as community garden for vegetables and other cash crops. A mechanism is in place to monitor and control planting and use of the open space to ensure that conflict among the users is avoided and minimized.

2.1.4 Safety and security

The Shahjibazar Power Plant is separated from the rest of the structures such as residential areas, school and other amenities within the 60-acre compound by a boundary wall. Another boundary wall surrounds the entire property with strategically located security gates. Drainage structures are maintained.

2.1.5 Environmental aesthetics and solid waste management

The property of the power plant is located in a large area with adequate green open space. Trees were planted on designated areas such as walkways (see Figure 3.5). Given the adequate space, there are no garbage scattered around the area and the solid waste management is done through burning and composting.

Figure A4.2 Trees Planted within the Shahjibazar Power Plant

2.1.6 Future plans

Aside from the conversion of Unit 8 and Unit 9 into CCGT, additional power plant capacity of 300 MW CCGT is part of future plans of BPDB. The environmental implications of increased capacity need to be evaluated.

2.2 Baghabari Power Plant

2.2.1 Compliance to national environmental regulations

Compliance to national environmental regulations is unclear as no site clearance or environmental clearance was provided. No environmental monitoring or reporting is being

92 done. An EIA for Unit 2 was prepared by a local consulting firm on behalf of BPDB in September 2001. National regulations require that for power projects, an IEE and an EIA need to be submitted to DOE.

There is no environmental staff or a staff designated to deal with environmental issues and to coordinate with DOE or the public.

The new 50 MW peaking power plant is relatively close to residences and given that it operates at night, the noise generated is a concern and may need monitoring to ensure that it is within the healthy and safe level.

2.2.3 Services within the property of the power plant

Services provided to staff and their families include residences, office building, conference hall, guest house, primary school, a mosque, open space as park, and a medical clinic. The medical clinic has a doctor and a pharmacist to deal with minor or common illnesses. There is a filtration system to provide drinking water to both staff and their families.

2.2.4 Environmental aesthetics and solid waste management

The premises have good landscaping with fruit-bearing trees such as jackfruit, lychee, and mango planted around the residential areas, power plant, and office buildings. Fruits are harvested and divided to staff.

There are four open dumpsites for solid wastes within the property with depth of up to 10 feet. Garbage dump are covered by soil before another layer of garbage is dumped.

2.2.5 Safety and security

The power plant is separated from the residences, mosque, school and other amenities with a gate operated by security personnel. The entire property is secured by high concrete wall and barbed wire. The substations operated by PGCB, which are adjacent to Unit 2, are separated by a gate. Aside from the security, a military contingent is assigned and stationed between the property of BPDB and PGCB to ensure the security of the facility. However, some technical staff operating the power plant do not use safety gear such as safety shoes and helmet.

2.3 Sylhet Power Plant

2.3.1 Compliance to national environmental regulations

An IEE, based on the requirements of the DOE was prepared in January 2010 and the site clearance was issued on 16 February 2010. Given that the power plant started operating only on 26 March 2012, there is no environmental monitoring report yet.

There is no environmental staff or a staff assigned to handle environmental issues associated with power plant operation.

2.3.2 Safety and security

Sylhet Power Plant is separated from the other existing power plants at Kumargaon Power Station complex with a concrete wall and gate. The entire property is secured by high concrete wall and metal bars particularly on the side of Surma River.

There are visible safety posters and signs at strategic locations within the power plant. However, some posters are not in Bangla but in Chinese. Some areas have poor drainage with waters accumulated for days. There are construction debris that need to be removed as this may pose safety risks to staff.

2.4 Khulna Power Plant

2.4.1 Compliance to national environmental regulations

An IEE was prepared and the site clearance with seven conditions was issued by the DOE on 23 May 2007. The site clearance is renewed every year subject to compliance of the set conditions and is still valid until 22 May 2012. The EIA was prepared for NWPGC by a consultant in March 2010 and approved by the DOE on 31 May 2010.

2.4.2 Designated environmental staff

The Summary IEE of Khulna Power Plant submitted to ADB in 2007 mentions that a safeguards implementation unit will be established in NWPGC as the Executing Agency (Appendix 13, para.9, p81). Also, one of the conditions of DOE in the site clearance issued on 23 May 2007 is to develop an “in-house environmental monitoring system” with equipment and expertise.

NWPGC has an Assistant Manager for Environment reporting directly to the Deputy General Manager (P&D) at the Corporate Office in Dhaka whose responsibilities, among others, are to implement the environmental management system and to monitor air quality, water quality and noise level. In May 2012, an additional staff was recruited and will be assigned onsite at Khulna to deal with the environment, health and safety (EHS) issues.

2.4.3 Environmental monitoring and reporting

The EPC submits progress reports to NWPGC but it does not include environmental aspect. According to NWPGC, the new staff recruited in May 2012 will deal with the requirements of environmental monitoring and reporting under the guidance of the environment staff at the Corporate Office in Dhaka.

2.4.4 Safety and security

Visit on 25-26 May 2012 at the construction site in Khulna showed that there are appropriate safety posters and visible signs. There is a first aid treatment centre and a health personnel onsite. Personal protection equipment such as hard hats and vests are provided to construction staff. Waste management, traffic management, storage of construction materials, and drainage condition are considered good. Labor shed is provided to workers with washing area.

2.4.5 Dismantling of 40 MW Aggreko Ltd rental power plant

The rental contract agreement between Aggreko Ltd and BPDB will expire in September 2012. Dismantling activities may potentially cause temporary disturbance and safety risks within the Goalpara Power Station and the residents living near the complex.

3.0 Corrective Action Plan

The following corrective actions are recommended for the four existing power plants included in the conversion to CCGT:

(i) comply with site clearance and environmental clearance required by DOE as set forth by ECA 1995 and ECR 1997; (ii) conduct baseline environmental quality measurements prior to the operation of CCGT as submission of environmental monitoring reports twice a year will be required by ADB; (iii) conduct environmental monitoring and reporting required by ADB and DOE; and, (iv) implement the environmental management plan and environmental monitoring program

Environmental quality parameters such as suspended particulate matter, noise level, oil & grease for groundwater, critical heavy metals such as arsenic and lead should be measured. Secondary data on community public health (e.g., mortality and morbidity rates) should be collected prior to commissioning of the combined-cycle gas turbine power plant. These baseline environmental data can be compared to monitoring data during implementation to determine environmental changes through time, if any.

Shahjibazar, Baghabari and Sylhet should designate staff to deal with environmental issues related to power plant operation and to coordinate with DOE, ADB and other project stakeholders, as appropriate.

Below are power plant specific recommendations:

3.1 Shahjibazar Power Station

3.1.1 Decommissioning plan

Some of the gas turbine units were retired more than 15 years ago. BPDB should determine the best and highest usage of the remaining gas turbine units, if any, including the space where these units are located. A decommissioning plan should be developed by BPDB following best practices and in compliance to relevant national regulations before any dismantling works commence. Presence of asbestos-containing materials (if any) should be dealt with properly to avoid exposure of workers.

3.1.2 Solid waste management and safety

A more structured solid waste management within the compound (i.e., power plant and the residential areas) should be identified aside from composting and burning. Recycling and reuse efforts should be encouraged and a controlled dumpsite-landfill site should be identified given that additional power plant capacity is part of the future plan of BPDB (i.e., 300 MW combined-cycle power plant).

Staff should be required to wear safety gear (as appropriate) when assigned in the operation of CCGT. Revisit the disaster and/or emergency preparedness plan to accommodate adaptation to climate change.

3.2 Baghabari Power Plant

Solid waste management and safety Solid waste management should be improved by identifying the best location for dumpsite. The dumpsites should be lined with impervious materials to prevent leaching and potential contamination of groundwater. The area can be fenced or trees can be planted around the dumpsite to serve as buffer.

Staff on duty at the power plant should be required to wear safety gear. Disaster plan or emergency preparedness plan should accommodate climate change. Storage area of

95 drums containing oil and lubricants (and also empty drums) should be lined or paved with impervious material or concrete to prevent seepage and potential soil and groundwater contamination. Noise levels at and around the 50 MW peaking power plant should be monitored to determine that they are within the health and safe levels.

3.3 Sylhet Power Plant

Solid waste management and safety Garbage and construction debris should be disposed of properly and drainage system should be improved to prevent accumulation of water is some areas as this may be a potential cause of diseases. Staff on duty at the power plant should be required to wear appropriate safety gear.

3.4 Khulna Power Plant

Dismantling of 40 MW rental power BPDB should require Aggreko Ltd to submit a dismantling plan prior to start of any dismantling works describing the activities and measures to ensure public safety. The dismantling plan should cover toxic and hazardous waste management. The dismantling plan should be made available to ADB for review and clearance.

Appendix 5

Consultation Meetings Held from May 8-28, 2012

Date of Number of Number of District, Subdistrict and Union Total Consultation Men Women 8 May 2012 Tangail, Tangail Sadar, Pachh Betoir 12 8 20 8 May 2012 Tangail, Ghatail, Pakutia 17 15 32 9 May 2012 Mymenshing,Mymenshing,Vobo Khali 18 16 34 10 May 2012 B. Baria, B. Baria, Ramrail, Ulchapara 15 16 31 11 May 2012 Norshindi, Norshindi, Mohishashur 18 27 45 Rangamati, Rangamati Sadar, Ragamati 27 19 46 13 May 2012 Sadar Khagrachari, Khagrachari Sadar, 7 3 10 13 May 2012 Khagrachari Sadar Khagrachari, Khagrachari Sadar, May 14, 2012 Khagrachari Sadar 10 13 23 28 May 2012 Dhaka 15 11 26 Total 139 128 267

Appendix 6

List of Persons who Attended the Consultation Meetings

Date Location Participants May 08, 2012 Tangail, Tangail Sadar, Pachh Md. Abul Hossain Betoir Md. Alauddin Md. Lal Mahmud Md. Lokman Hossain Md. Abul Hossain Md. Sekander Ali Md. Abed Ali Md. Johurul Md. Khorshed Alam Md. Taher Bepari Md. Joshim Uddin Md. Shahadat Hossain Ms. Shirin Akter Ms. Asiya Begum Ms. Nur Jahan Ms. Parvin Begum Ms. Monira Begum Ms. Aduri Begum Ms. Parul Akter Ms. Asha Akter May 08, 2012 Tangail, Ghatail, Pakutia Md. Solaiman Hossain Md. Ronju Miah Md. Lal Miah Md. Al Amin Ali Md. Jahangir Md. Baijid Md. Mukul Mia Md.Topu Ahmed Md. Abdus Samad Md. Din Islam Md. Giash Uddin Md. Shahjahan Md. Sujon Mia Md. Sobuj Mia Md. Sirajul Islam Md. Aminul Islam Md. Motaher Hossain Ms. Saleha Begum Ms. Ontora Islam Ms. Laile Khatun Ms. Khaleda Begum Ms. Majeda Begum Ms. Jaba Akter Ms. Saleha Begum Ms. Amina Begum Ms. Josna Begum Ms. Joytun Khanam Ms. Rasheda Begum Ms. Sufia Begum Ms. Maleka Begum Ms. Champa Begum Ms. Bina Begum May 09, 2012 Mymenshing,Mymenshing,Vobo Md. Kalimuddin Khali Md. Abul Hossain Md. Abul Hossain Md. Abdul Kuddus Md. Hamidul Islam Md. Ain Uddin

Date Location Participants Md. Mojibor Md. Abul Kalam Azad Md. Liton Sharkar Md. Abdur Rashid Md. Abdur Rashid Md. Nazrul Islam Md. Aynul Hoque Md. Abed ali Md. Mozid Md. Kamrul Md. Jahan Ali Md. Tomizuddin Ms. Hosne Ara Ms. Ayesha Begum Ms. Nazma Ms. Rahima Ms. Kalpona Akter Ms. Johora Khatun Ms. Shelina Akter Ms. Bela Rani Ms. Farjana Akter Ms. Jahera Khatun Ms. Bilkis Akter Ms. Hazera Khatun Ms. Shampa Akter Ms. Rajoni Akter Ms. Sobura Akter Ms. Amena Khatun May 10, 2012 B. Baria, B. Baria, Ramrail, Md. Moshiur Rahman Ulchapara Md. Shah Alam Md. Shikder Ahmed Md. Hazi Humayun Md. Rosul Mia M A Ghafur Md. Habibur Rahman Khan Md. Mia Hossain Md. Anwar Md. Ataur Rahman Chowdhury Md. Rashedul Hoque Md. Hanif Md. Abdul Kuddus Md. Yunus Mia Md. Khalil Mia Ashrifa Haque Ms. Musana Ms. Ishrat Jannat (Shelina) Ms. Sharifa Begum (Jony) Ms. Minara Begum Ms. Hosne Ara Begum Ms. Nur Jahan Ms. Nilufa Begum Ms. Tahmina Akter Ms. Shirina Ms. Rehana Ms. Latifa Ms. Jamela Ms. Anu Ms. Sufia Ms. Rizia Ms. Monowara Ms. Helena Ms. Nasima Ms. Hoshna

Date Location Participants Ms. Anu (Abeda) Ms. Angura Ms. Malancha Ms. Rubina Ms. Johura Begum Ms. Rafia Begum Ms. Shajeda Begum May 10, 2012 Norshindi, Norshindi, Mohishashur Md. Alamgir Bhuiyan Md. Altaf Hossain Md. Iqbal Hasan Bachchu Md. Ripon Bhuiyan Md. Julfiker Ahmed Bhuiyan Mohammad Amzad Hossain Md. Abdul Barik Md. Mohshin Kabir Bhuiyan Md. Mozammel Hoque Mohammad Islam Md. Abul Hossain Md. Shahjahan Molla Mohammad Sharif Bhuiyan Md. Mozaffar Ali Md. Shiraj Mir Md. Ramizuddin Pradhan Md. Ali Ahmed Md. Gaffar Mia Ms. Taherunnesa Ms. Rumi Anas Ms. Mafia Akter Ms. Taslima Akter Ms. Mahfuza Begum Ms. Aleha Akter Ms. Taslima Ms. Josna Ms. Momena Ms. Maleka Begum Ms. Lutfunnesa Ms. Sayeda Akter Ms. Monira Nashir Ms. Beauty Begum Ms. Asma Akter Ms. Juyena Akter Ms. Jahanara Akter May 13, 2012 Rangamati, Rangamati Sadar, Md. Saiful Islam Ragamati Sadar Ms. Zebun Nessa Ms. Joytun-nur-Begum Ms. Roksana Akter Mr. Dhirendra Chakma Md. Robiul Alam Md. A. R. Muzib Mr. Kalayan Chakma Md. Neaz Ahmed Mr. Dipak Khisa May 13, 2012 Khagrachari, Khagrachari Sadar, Md. Jahidul Alam Khagrachari Sadar Mr. Rana Bikram Tripura Mr. Chandra Shekhar Das Md. Abdus Salam Mr. Uttam Sarker Mr. Kalyan Mitra Barua Mr. Chandan Kumar Dey Md. Jafor Ahammod Md. Islam Uddin Md. Shahjahan Miah

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Date Location Participants Md. Shajjad Hasan S U M Mahmudul Alam Ms. Parveen Khondoker Md. Shah Alam Md. Mashudul Haq Md. Mehedi Hasan Helal Mr. Mony Ray Marma Ms. Khaleda Begum May 13, 2012 Rangamati, Rangamati Sadar, Mr. Nivaran Chakma Ragamati Sadar Mr. Karunamoy Chakma Mr. Ranendra Chakma Mr. Pritimoy Chakma Mr. Manoy Dewan Mr. Hitosh Chakma Mr. Sabuj Chakma Mr. Enam Chakma Mr. Sajib Chakma Mr. Prachurjo Chakma Mr. Kingshuk Chakma Mr. Raton Chakma Mr. Niloy Chakma Mr. Evan Chakma Mr. Sapon Chakma Mr. Repon Dewan Ms. Minati Chakma Ms. Kajalika Chakma Ms. Rajshona Chakma Ms. Ratna Chakma Ms. Anika Chakma Ms. Bashundhara Chakma Ms. Chandrika Chakma Ms. Banchita Dewan Ms. Chanda Dewan Ms. Rina Dewan Ms. Barsha Dewan Ms. Sweety Chakma Ms. Manila Chakma Ms. Ila Chakma May 14, 2012 Khagrachari, Khagrachari Sadar, Mr. Kyajari Marma Khagrachari Sadar Mr. Proshanzit Chakma Mr. Aung Chairy Marma Mr. Mong Sathowai Mr. Mong Che Aung Marma Mr. Mong Kya Ching Mr. Dhanaraj Tripura Mr. Sathooi Prue Marma Mr. Sanupuro Marma Mr. Toijm Tipra Ms. Bashari Marma Ms. Jhorna Tripura Ms. Ammasey Marma Ms. Suimrau Marma Ms. Rupali Chakma Ms. Nunika Chakma Ms. Nang Kroi Ms. Kra Swaong Ms. Ma Tu Ms. Khuing Mraso Ms. Jen Si Ms. Rupaiyo Na Tripura Ms. Chin Bai Marma

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Appendix 7

List of Participants Safeguards and Capability Strengthening Planning Workshop for Executing Agencies 28 May 2012

Name Position Organization Mr. Jalal Uddin Ahmed Chowdhury Chief Engineer, Generation BPDB Mr. Durjiti Prasad Shen Manager, Shahjibazar Power Plant BPDB Mr. Ranada Prasad Roy Manager, Sylhet 150 MW Power Plant BPDB Mr. Mutahar Rahman Chowdhury Director, Training BPDB Mr. Khan Manzur Murshed Deputy Director, Training BPDB Executive Engineer, 820 MW Peaking Mr. Harun-ur-Rashid BPDB Power Plant Project Mr. Shafiqul Islam Deputy Director, Design & Inspection-1 BPDB Mr. Ratan Kumar Pal Deputy Director, Project Planning BPDB Mr. S.M. Zahid Hasan Deputy Divisional Engineer BPDB Mr. Mahbub Ahmed DGM, GC - Chittagong PGCB Mr. Chowdhury Alamgir Hossain DGM, Design PGCB Mr. Shafiqur Rahman DGM, Khulaura- Sherpur Project PGCB Mr. Bazlur Maunir Manager, RTS PGCB Mr. Abdur Rashid Khan. Manager, MIS PGCB Mr. Ali Hossain Manager, ICT PGCB Mr. Probir Kanti Das Manager, GMD-Ctg. (N) PGCB Mr. Mir Motahar Hossain Manager, Attached to MD PGCB Mr. Sarder Mohammad Zafrul Hasan Manager, TLD-1 PGCB Deputy Manager, Kulaura-Sherpur Mr. Refat Bin Sayed PGCB Project Mr. Sk. Nurul Absar Chief Engineer (Project) REB Mr. Kaisar Ahmed Director (Program Planning) REB Mr. Nurul Islam Bhuiyan Project Director, 1.8 Million Project REB Mr. Mizanur Rahman Khan Project Director, REE -DPP-1 REB Mr. Abdus Sattar Biswas Deputy Project Director, REUP REB Mr. Engr. Kamal Uddin Ahmed Deputy General Manager, P&D NWPGCL