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Environmental Impact Assessment Report Dhaka SEZ, Keraniganj Economic Submitted to Bangladesh Economic Zones Authority June 2016 Zone

Bangladesh Economic Zones Authority (BEZA) EIA Report- Dhaka SEZ

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

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Contents

List of Tables 8 ListofFigures 10

Abbreviation & Glossary 12

1. Executive Summary 14

1.1. Project Background 14 1.2. Baseline and Social Environment 14 1.2.1 Temperature 14 1.2.2 Relative Humidity 14 1.1.1 Rainfall 15 1.1.2 Wind speed and direction 15 1.1.3NaturalHazards 15 1.1.4 Biological Environment 15 1.1.5 Agricultural Resources 16 1.1.6 Livestock and poultry 16 1.1.7 Fisheries 16 1.1.8 Socio-economic 16

1.3. Environment and Social Impacts of the Proposed Project 17 1.4. Conclusion and Recommendations 22

2. Introduction 24

2.1. Project Background 24 2.2. Rationale for the Proposed Project 26 2.3.ScopeandMethodologyoftheStudy 27 2.4. Limitation of the Study 27 2.5. ToR Compliance Matrix 28 2.6. EIA Team 31 2.7.StructureoftheReport 31 2.8. References 32

3. Legislative, Regulation and Policy Consideration 35

3.1. Regulatory Requirements for the Proposed Project 35 3.2. Procedure for Obtaining Environmental Clearance from DoE, Bangladesh 38

4. Project Description 40

4.1. Project Introduction 40 3 EIA Report- Dhaka SEZ

4.2. Project Objectives and Options (Alternate Analysis) 42 4.3. Interventions under selected options and activities 45 4.4. Project Area of Influence 45 4.5. Existing Infrastructure in and around the Project Site/Project Activities 46 4.5.1 Power Supply for the proposed Site 47 4.5.2 Water Availability for the proposed Site 47 4.5.3 Gas Supply for the proposed Site 47 4.5.4 Telecom/ Internet connectivity to the proposed Site 47 4.5.5 Connectivity 47 4.5.6 Proposed Infrastructure 48

4.6. Project Schedule 33 4.7. Resources and Utilities Demand 33 4.7.1 Water 41 4.7.2 Power Requirement 41

4.8 Estimated Project Cost 41 4.9 Maps and Survey information 41 4.9.1 Project Location 41

4.10 Eco Sensitivity 44 4.11 Geology 44 4.12 Master Plan of Dhaka SEZ 47 4.12.1 Land Use Pattern within the Zone 47 4.12.2 Water Supply System 50

5. Description of Environment (Environment and Social Baseline) 53

5.1Methodology 53 5.2 Baseline data Collection 53 5.2.1 Meteorology 53 5.2.2 Water Resources 61 5.2.3 Land Resources 76 5.2.4 Ambient Air Quality 82 5.2.5 Ambient Noise Quality 84 5.2.6 Water Environment 85 5.2.7 Traffic Survey 87 5.2.8 Agricultural Resources 87 5.2.9 Livestock and poultry 88 5.2.10 Fisheries 88 5.2.11 Ecological Resources 88

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5.2.12 Socio-economic Conditions 90

6 Identification and Analysis of Key Environmental Issues 101

6.1 Environmental Sensitivity Investigation 101 6.2 Environmental Asset 101 6.3 Environmental Hotspot 102 6.4 Likely Beneficial Impacts 102 6.5 Community Recommendations and Alternative Analysis 102

7. Impacts Assessment 103

7.1 Introduction 103 7.2 Impact Identification 103 7.3 Impact on Air Environment 104 7.3.1 Pre-construction Phase 104 7.3.2 Construction Phase 105 7.3.3 Operation Phase 106

7.4 Impact on Noise Environment 107 7.4.1 Pre-construction and Construction Phase 107 7.4.2 Operation Phase 109

7.5 Impacts on Water Resources 109 7.5.1 Pre-Construction and Construction Phase 109 7.5.2OperationPhase 112

7.6 Impacts on Land resources 113 7.6.1 Pre-construction and Construction Phase 113 7.6.2 Operation Phase 115

7.7 Impacts on Biodiversity/Ecosystem 116 7.8 ImpactsonAgricultureresources 116 7.8.1 Impactsonagriculturalresources 116

7.9 Impacts on Fisheries 117 7.9.1 Impacts on fisheries during pre-construction and construction phase 117

7.10 Impacts on Occupational Health and Safety 117 7.11 Community Health and Safety 118 7.12FloodRisk 118 7.13 Sanitation and Disease Vectors 119 7.14 Impacts due to Climate Change 119 7.15 Cumulative Impacts 120 7.16 Impacts on socio-economy 121

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8. Public Consultations and Disclosure 122

8.1 Introduction and Objectives 122 8.2 Methodology of Stakeholder Consultations 122 8.3 Details of Public Consultations and Meetings 123 8.4 Consultation outcomes 127

9. Environmental Management Plan and monitoring indicators 133

9.1Introduction 133 9.2 Mitigation Plan 133 9.2.1 Preconstruction Operations 133 9.2.2 Construction Activity 134 9.2.2.1 Air Environment 134 9.2.2.2 Noise Environment 134 9.2.3 Mitigation Plan for Power Supply 144 9.2.4 Biological Environment/ Greenbelt Development 144 9.2.5 Emergency Preparedness Plan 145 9.2.6 Post Project Monitoring Plan 145 9.2.6.1 Micrometerology 145 9.2.6.2 Air Quality 145 9.2.6.3 Noice Quality 146 9.2.6.4 Surface Water 146 9.2.6.5 Groundwater 146 9.2.6.6 Soil Quality 146 9.2.6.7 Flora and Fauna: 147

9.3 Mitigation Plan for EZ 147 9.4 Monitoring Plan 149 9.5 Monitoring Indicators 150 9.6 Institutional Arrangement 151 9.7 Community development plan 151 9.8 Post Project Monitoring Plan 152 9.9 Environment Management Cell 152 9.10 Compensation Plan 153

10. Cost of EMP 154 11. Conclusion and Recommendation 155

11.1 Conclusions 155 11.2 Recommendations 155

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Annexure A: Primary monitoring results 156

A) GroundwaterResults 156 B) Noise Monitoring Results 157 C) Air Monitoring Results 158 D) Surface Water Analysis Results 159

Annexure B: Land Transfer Documents 160 Annexure C: Land Use by Broad Area Classification 162 Annexure D: Land Use by Industries and Services 163 Annexure E: Approved ToR from DoE 164 Annexure F: Compliance Matrix as per DoE 168

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List of Tables

Table 1: Environmental Impacts and Mitigation Plan for site preparation and construction of Administration Building ...... 17 Table 2: Mitigation Measures Suggested for Developer...... 20 Table 3: Site Details of the proposed site...... 24 Table 4: Photographs of the project site ...... 25 Table 5: Compliance of TOR Points ...... 28 Table 6: EIA Team...... 31 Table 7: Reference Used for EIA Study...... 32 Table 8: Regulatory Frameworks ...... 35 Table 9: Steps for Obtaining Clearances from DoE, Bangladesh...... 39 Table 10: SWOT Analysis of the Dhaka SEZ ...... 42 Table 11: Details of trains running from Dhaka district...... 48 Table 12: Implementation Schedule of Off-site Infrastructural Details ...... 33 Table 13: Estimated Project Cost ...... 41 Table 14: Proposed Land Use...... 49 Table 15: Monthly minimum and average minimum temperature during Jan 2005 to Dec 2014 ...... 53 Table 16: Monthly maximum and average maximum temperature during Jan 2005 to Dec 2014 ...... 54 Table 17: Monthly average relative humidity during Jan 2005 to Dec 2014...... 54 Table 18: Monthly total and 10 years average monthly rainfall during Jan 2005 to Dec 2014 . 55 Table 19: Land Type Classification...... 63 Table 20: List of Major Earthquakes in Bangladesh ...... 72 Table 21: List of Tornadoes had hit the Bangladesh ...... 75 Table 22: Land Type Classification ...... 78 Table 23: Soil types in Dhaka District ...... 79 Table 24: Ambient Air Quality Assessment, 2016 ...... 82 Table 25: Ambient Air Quality data collected from EIA report of Siddhirganj Power Plant (µg/m3)...... 83 Table 26: World Bank Group General EHS guidelines (Ambient Air quality guidelines)...... 83 Table 27: Ambient Noise Quality data collected from the EIA report of Siddhirganj Power Plant (Decibal) ...... 84 Table 28: Ambient Noise Quality analysed at the Dhaka SEZ, Keraniganj...... 84 Table 29: Surface Water Quality Assessment of Dhaleshwari River, 2016 ...... 85 Table 30: Water Quality Parameters of Dholeswari River, 2014 (by DoE)...... 86 Table 31: Quality of ground water samples collected from the proposed Dhaka SEZ site, 2016 87 Table 32: Socio-Economic Profile of Keraniganj Upazila...... 91 Table 33: Source of Livelihood Profile of Keraniganj Upazila ...... 92 Table 34: Demographic profile of the Unions under Keraniganj Upazila ...... 92 Table 35: Demographic profile of the Unions under Keraniganj Upazila ...... 93 Table 36: Socio-Economic Profile of SirajdikhanUpazila...... 94 Table 37: Source of Livelihood Profile of Sirajdikhan Upazila...... 94 Table 38: Demographic profile of the Unions under Sirajdikhan Upazila ...... 95 Table 39: Literacy Rates Segregated by Unions in Sirajdikhan Upazila...... 95

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Table 40: Demographic Data ...... 96 Table 41: PAPs categorized based on their age ...... 96 Table 42: Literacy level of PAPs ...... 97 Table 43: Health Status of affected households...... 98 Table 44: Availability of Health Facilities at Keraniganj Upazila ...... 98 Table 45: Employment Status of PAPs ...... 99 Table 46: Environmental Assets of the project area ...... 101 Table 47: Classification of Social and Environmental Components...... 103 Table 48: Impact Matrix for Proposed Off-site Infrastructure ...... 103 Table 49: Noise levels generated by construction equipments (measured at 1 m distance)...... 107 Table 50: Types of Consultations...... 123 Table 51: Details of Consultation ...... 123 Table 52: Positive Impacts perceived by the Stakeholders ...... 127 Table 53: Negative Impacts perceived by the Stakeholders ...... 128 Table 54: Photographs of Stakeholders Consultation...... 128 Table 55: Environmental Impacts and Mitigation Plan for constructiomn of access road, Boundary Wall & Administration Building...... 135 Table 56: Mitigation Measures Suggested for Developer...... 147 Table 57: Environmental Monitoring Plan ...... 149 Table 57: Cost for EMP Implementation ...... 154

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List of Figures

Figure 1: Location Map of Dhaka SEZ ...... 26 Figure 2: Location of Economic Zone...... 41 Figure 3: Mouza map of proposed site ...... 41 Figure 4: Site Surrounding Features...... 41 Figure 5: Project Area of Influence...... 46 Figure 6: Embankment Details...... 50 Figure 7: Embankment cross-section details ...... 51 Figure 8: Structural Details for Pile, Plinth beam and Fencing ...... 52 Figure 9: EZ location on Upzila Map ...... 42 Figure 10: Project site and surroundings...... 42 Figure 11: Mouza Map with the project site ...... 42 Figure 12: Contour Map of the Proposed EZ ...... 43 Figure 13: Topography of the Site ...... 43 Figure 14: Geological Map of Bangladesh...... 45 Figure 15: Geological Map of Keraniganj ...... 47 Figure 16: Broad Zone Demarcations ...... 47 Figure 17: Land Use by Broad Area Classification ...... 48 Figure 18: Land use by Industries and Services ...... 48 Figure 19: Water Supply and Drainage Network...... 51 Figure 20: Diagram for Water Supply System...... 51 Figure 21: Wind Rose Diagrams...... 56 Figure 22: Sunshine hours in Dhaka City, 2015 ...... 60 Figure 23: Drainage Pattern of the Project Site ...... 61 Figure 24: Digital Elevation Map of Bangladesh...... 62 Figure 25: Riverbank Erosion Pattern in Bangladesh...... 63 Figure 26: Change in River Morphology...... 64 Figure 27: Flow Regime of Dhaleshwari River, 2004...... 65 Figure 28: Flow Regime of Dhaleshwari River, 2007...... 66 Figure 29: Flow Regime of Dhaleshwari River, 2010...... 66 Figure 30: Flow Regime of Dhaleshwari River, 2012...... 66 Figure 31: Flow Regime of Dhaleshwari River, 2014...... 67 Figure 32: Flow Regime of Dhaleshwari River, 2016 ...... 67 Figure 33: Groundwater Zoning Map in Bangladesh, 2010 ...... 69 Figure 34: Seismicity Map of Bangladesh...... 70 Figure 35: Cyclone affected area map of Bangladesh ...... 73 Figure 36: Cyclone tracking map of Bangladesh...... 73 Figure 37: Flood affected area map of Bangladesh ...... 74 Figure 38. Agroecological Regions of Bangladesh...... 76 Figure 39: General Soil map of Bangladesh...... 78 Figure 40: General Soil map of Banngladesh (highlighting Keraniganj)...... 80 Figure 41: Geological log for Manikgonj District...... 81 Figure 42. Land Use Pattern around the subject Site, Keraniganj ...... 82 Figure 43. Project Area and Project Area of Influence, Dhaka SEZ ...... 90 Figure 44: Layout Map of Keraniganj Upazila...... 91

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Figure 45: Sirajdikhan Upazilla Map...... 93 Figure 46: Age wise PAP distribution...... 97 Figure 47: Literacy Level of the surveyed PAPs...... 98 Figure 48: Employment status of PAPs...... 99 Figure 49: Embankment cross-section details ...... 118

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Abbreviation & Glossary

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

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VOC Volatile Organic Compounds kmph Kilometer per Hour HDPE high-density polyethylene m/s meter / second H&S Health and Safety mg/kg microgram per kilogram mg/l microgram per liter NOx Oxides of Nitrogen

PM10 Particulate Matter less than 10 micron size

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

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

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1. Executive Summary

1.1. Project Background

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

Bangladesh Economic Zone Authority (BEZA) has been promulgated under the Bangladesh Economic Zones Act, 2010 to develop the Economic Zones across the country. BEZA, after the initial site assessment, finalized to develop an Economic Zone housing RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution industries in the Keraniganj upazila under Dhaka district of Bangladesh.

As part of the Private Sector Development and Support Project (PSDSP), supported by the World Bank, PricewaterhouseCoopers Private Limited (PwC) was appointed by BEZA to undertake the Environmental Impact Assessment for the Dhaka SEZ, Keraniganj economic zone. An area of 105 acres will be used to develop the EZ. The proposed categories of industries would be: RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution. Along with the EIA for the EZ, impacts and mitigation measures because of off-site infrastructure are also elucidated. The offsite infrastructure that have been proposed are:  Administrative Building  Land Filling  External power supply system and substation at project site  Water supply arrangement at project site from borewells; and  Approach road construction towards the southwestern corner of the proposed EZ PwC was appointed by BEZA to carry out the environmental and social impact assessment study for the development of the proposed EZ. As per the procedure, proposed Terms of Reference (ToR) was submitted to DOE in May 2016. Approved ToR was granted by DoE vide Memo No. DoE/Clearance/30.26.38.3.831.250215/226, dated 13 June, 2016. Copy of the approved ToR by DoEB is attached as Annexure II. The EIA study for the development of proposed Dhaka EZ has been carried out as per the ToR issued by DoEB, World Bank’s requirements and Environmental Management Framework of BEZA.

1.2. Baseline and Social Environment 1.2.1 Temperature

The data shows that the monthly minimum (average) temperature at Dhaka varies between 13.50C and 26.60C and maximum temperature varies between 24.46C and 34.50C. The minimum and maximum temperature data indicates that December to February months are relatively cooler and April and May are the relatively hotter months. 1.2.2 Relative Humidity

The average relative humidity at Dhaka varies between 57.30 % in the month of March and 80.20 % in the month of August.

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1.1.1 Rainfall

The rainy season in Dhaka mainly prevails from May to October. The average monthly rainfall in Dhaka for the period Jan 2005 to Dec 2014 varied between 3.5 mm in the month of January and 412.8 mm in the month of July. The rainfall follows the general climate pattern with the highest rainfall in the summer from April to October and minimum rainfall in the winter from November to March. 1.1.2 Wind speed and direction

The dominant wind speed is in the calm condition followed by 1 to 2.5 m/sec. The predominant wind direction from Jan to Dec is south followed by south-east.

The area experiences wind speeds lower than 5 m/s for 98% of time. Of this half the time (44.4%of the time) is calm condition throughout the year (wind speeds in the range of 1-2.5 m/s). This indicates the weather conditions are not favorable for dispersion of pollutants released in the air. Month wise prevailing wind speeds are as follows: predominantly calm conditions prevail during January to March and September to December periods with the area experiencing wind speeds in the range of 1-2.5 m/s. The remaining five months experience lesser calm conditions and wind speeds in the range of 2.5 – 5 m/s. 1.1.3 Natural Hazards

The seismicity map of Bangladesh shows that Keraniganj lies in Zone-2 which shows intermediate level of seismic activity. However, one of the major active tectonic belt of Bangladesh is at the eastern side. In the earthquake zoning map of 1993, 26 percent of Bangladesh falls in high risk, 38 percent moderate and 36 percent in low risk zone in terms of earthquake vulnerability. The distribution of recorded earthquakes indicate a major clustering of seismicity around the Dauki Fault and scattering of other events along other major fault systems of Bangladesh. The magnitude of the earthquakes are moderate (4-6) and majority of them are shallow depth.

As per tectonic classification, the area falls under Faridpur trough of Western platform flank which is adjacent to the hinge line.Tectonically this area is inactive and no apparent major structure like fault or fold exists in the region that might be geologically significant (Sir William Halcrow and Partners ltd., 1993).

Keraniganj does not lie in risk area and high wind area.

The flood map shows that Keraniganj which is abuted by Dholeswari River, is exposed to high flood risk. 1.1.4 Biological Environment

Rice is the dominant agricultural crop. Among the rice crops, boro covers the largest area followed by amon and aus (Census of Agriculture 2008). Jackfruit is extensively grown and is an important cash crop.

Reptile and Amphibians Different species of fresh water tortoises ana turtles such as pond tortoise (Melanocheys trijuga), reacock soft shell turtle (Trionyx hurum), common roof turtle species of lizard like house lizard (Hemiductylus brooki), wall lizard (Hemiductylus frenatus), yellow water monitor(Varanus flaviscens), stripped skink, grey land monitor etc. are found in Dhaka. Mammals Rhesus monkey (Macaca mullata) is fairly common in the district, until recently, a large number of monkeys were seen frequently jumping around in the Dhaka city. They have now retreated to the city and far beyond. Other mammals that are commonly fourn in this district are: Bengal Fox (Vulpes bengalensis), Jackal (Canis aureus), grey mongoose (Herpestes edwarsi) etc. Bats are represented by a few species’ including India fruit bats. At times, porpoises are seen in the rivers of the district. Rodents are represented by different species of squirrels, rats and mice. 15 EIA Report- Dhaka SEZ

Birds The common birds of the district include bhat shalik (Acridotheres tristis), house sparrow (Passer domesticus), magpie robin (Copsychus saularis), black drongo (Dicurus macrocercus), spotted dove (Streptopelia chinensis), lesser golden backed woodpecker (Picusmyrmeco phoneus), white breasted kingfisher (Alcedo atthis), pond heron (Ardeola grayii), little cormorant (Phalacrocran niger), white breasted water hen (Amauronis phoenicurus), rose ringed parakeet (Psittacula cupatria), common hawk cuckoo (Cuculus microplerus), tailor bird (Orthotomus sutorius), koel (Eudynamis scolopacea), barn owl (Tyto alba) , house crow (Corvus splendens), brahminy kite (Haliaster Indus). The smaller and song birds include the bush lark, halde pakhi, (Oriolus xanthornus) weaver bird, shrike, warblers, purple sun bird etc.

Fishes Fishes are caught in the ponds, rivers, creeks and beels of the district. The popular edible fishes are hilsa (Hilsa ilisha), ruhi (Labeo rohita), catla (Catla catla), mrigel (Cirrhinus mrigala), kalbaush (Labeo calbasu), sarpunti (Puntius sarana), chital (Notopterus chitala), airh (Mystus aor), pabda (Ompok pabda), bacha (Eutropichthys vacha), pangas (Pangasius pangasia), koi (Anabas testudineus), shing (Heteropneustes fossilis), magur (Clarius batrachus) etc.

1.1.5 Agricultural Resources

The proposed aite area is being extensively used for agriculture purposes. The project site consists of a total of 105 acres of land. Out of that, 40 acres is Khas land remaining 65 acres is privately owned land. The land use is majorly agriculture practised within the project site. Potato, Sweet Potato, Pui Shak, Lal Shak are the major vegetables being cultivated within the project area. Agriculture serves as the main source of livelihood for the private land owners.

1.1.6 Livestock and poultry

There is no livestock and poultry at the proposed site location. 1.1.7 Fisheries

Fishing or practice of pisciculture are not being practiced within the projet area. 1.1.8 Socio-economic

In the project area of influence, Most of the affected people were found to be within the age bracket of 18-30 which constituted 31.8% of the total affected PAPs. Considering the age group ranging from 18-40 as the youth age bracket, a total of 171 within that age bracket were found to be impacted. So 52% of the total affected people are in the age group of 18-40 which is considered as the youth bracket age group.

Of the total affected population, 26% have achieved secondary level of education where as 14% of the population has achieved primary level of education. Illiterate populations comprise of 17% of the total PAPs. A mere 3% of the PAPs are technically qualified (graduates and masters). The low education levels emphasize the need for stress on technical education and skill enhancement programmes in the region.

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

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50% of PAPs are housewives. 16.20% of the total PAPs constitute farmers, 14.67% of the total PAPs are unemployed. All of them are males. The unemployed male population constitute students also.

Women in the region primarily are involved in household work, cultivation and other agriculture activities. They are also involved in decision making involving decisions like education of children, decisions before social functions etc.

1.3. Environment and Social Impacts of the Proposed Project

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

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

The following table provides with the mitigation measures: Table 1: Environmental Impacts and Mitigation Plan for site preparation and construction of Administration Building

Impact Mitigation Measures

Removal of  When clearing the site, care shall be taken to keep vegetation clearing at a minimum and Vegetation only from the RoW  Removal of as little vegetation as possible during the development and re-vegetation of bare areas after the project. Setting up of  The construction camps should be at least 500 m distance from habitations from the construction nearest settlements to avoid conflicts and stress over the infrastructure facilities with the camps/labour local community. camps  Location for stockyards for construction materials will be identified at least 1 km from water sources  The living accommodation and ancillary facilities for labour shall be erected and maintained to standards and scales approved by the resident engineer  All sites used for camps will be adequately drained. There should not be any risk of periodic flooding, nor located within 300 feet of pools, sink holes or other surface collections of water  The camps will be located such that the drainage from and through the camps will not endanger any domestic or public water supply  All sites will be graded, ditched and rendered free from depressions such that water may get stagnant and become a nuisance  Construction camps shall be provided with sanitary latrines (1 per 25 pax), bathing facility and urinals.  Sanitary latrines shall be under cover and so partitioned off as to secure privacy, and shall have a proper door and fastenings  Adequate and suitable facilities for washing clothes and utensils shall be provided and maintained for the use of contract labour employed therein.  Sewerage drains will be provided for the flow of used water outside the camp.  Drains and ditches will be treated with bleaching powder on a regular basis.  The sewage system for the camp will be properly designed, built and operated so that no health hazard occurs and no pollution to the air, ground or adjacent watercourses takes place.  Clean potable drinking water facility should be provided at the site and the water quality should be monitored regularly  Crèche facility should be provided for children if female workers are employed  First aid facilities should be made available at construction camp. First aid box should contain small, medium and large sized sterilized dressings, sterilized burns dressings, 2 %

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alcoholic solution of iodine, bottle containing salvolatile, snakebite lancet, , bottle of potassium permanganate crystals, scissors, Ointment for burns & surgical antiseptic solution  1 first aid box should be available for every 50 labour  A person trained in first-aid treatment should be made in charge who will always be readily available during emergency  A suitable motor transport shall be kept readily available to carry injured or ill person to the nearest hospital. Landfilling  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in downwind direction of the identified sites for getting landfilling material.  The soil used for landfilling should have similar characterisctis to the native soil and free of any type of contamination.

In case of dredging activity for landfilling purposes:

 Dredging should not impact natural drainage courses  Dredging sites should be located away from sensitive locations  Permission from concerned local body should be taken before finalizing the location  Magnitude and frequency of dredging activity should be monitored to avoid impacts on the natural drainage  Prior to dredging activity, analyse the soil sample to prevent impacts on the receiving environment as a result of mismatch in soil characteristics;  During dredging activity, physical barriers such as silt screen/ curtains should be employed to prevent the spread of suspended sediments;  Maintain the extent of the turbidity plumes close to the dredging and disposal areas to minimise impacts on marine fauna habitat;  Visually inspect for any marine life and terrestrial organisms and stop dredging activity in case of any organism in the vicinity;  Monitoring should be done continuously during dredging to observe impacts on the marine life and in case of visible impacts, stop the dredging activity;  Dredging should be carried out during day time to minimize impacts on marine life. Identification of  The dumping sites shall not be located within designated Forest/protected areas dumping sites for  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in debris downwind direction of the identified dumping sites  Dumping shall not impact natural drainage courses  Dumping sites should be located at least 1 km from sensitive locations  Permission from concerned local body should be taken before finalizing the location  Agriculture lands should be avoided & waste lands should be preferred  Selected site should not support significant vegetation  The area should be sprinkled with water to suppress the dust emissions  Plant species suitable to grow in that conditions should be planted at the time of closure Soil Erosion and  Contractor should plan the activities so that no loose earth surface is left out before the Sedimentation onset of monsoon. control  Top soil from debris disposal sites & along the road side should be stripped and kept under covered shed for plantation  After the construction activity is over, top soil will be utilized for landscaping activity.  To avoid soil compaction along the transportation routes, only identified haul roads would be used for transportation.  Along sections abutting water bodies, stone pitching needs to be carried out  High embankments should be provided with chutes and drains to minimize soil erosion.  Turfing of low embankments and plantation of grasses and shrubs should be done in slope stabilization.  Soil erosion checking measures as the formation of sediment basins, slope drains, etc, should be carried out.  Construction of Side Slope of Filled Land of 1:2 by suitable soils with proper compaction as per design. Slope surface should be covered by top soils/ cladding materials and grass turfings with suitable grass. Disposal of Debris  Waste from construction camp should be segregated at site. Food/wet waste should be and any waste composted in pit at the site, recyclable should be send to authorized recyclers and rejected generated waste should be disposed regularly through responsible agency in the area  Dustbins should be provided at the site and construction camps to prevent littering of waste  Storage area of minimum 2 days should be provided at construction camp for storage of the waste generated from labour camps

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 Construction debris should also be segregated at the site. This debris should be used for filling to the extent possible. Recyclable waste should be sold through authorized dealers and reject waste should be sent to the identified debris disposal site  All arrangement for transportation during construction including provision, maintenance, dismantling and clearing debris, where necessary will be considered incidental.  Construction debris should be stored under covered sheds on paved surfaces to prevent leaching  Any hazardous waste generated during construction activity shall be stored at designated place and then disposed through the TSDF using high temperation incenaration or any other chemical, thermal, biological, and physical methods. Chemical methods include ion exchange, precipitation, oxidation and reduction, and neutralization.  Contaminated runoff from storage areas should be captured in ditches with an oil trap at the outlet.  Utmost care shall be taken to ensure that the DoE norms are met for the safe collection, transport and disposal of construction waste and debris. Dust Generation  Vehicles delivering materials should be covered with tarpaulin to reduce spills and dust blowing off the load.  Compaction of prepared site to re-strain the fugitive emissions.  Water should be sprayed in the cement and earth mixing sites as well as after compaction.  In high dust areas, workers should be provided and encouraged to use masks.  Regular maintenance, servicing of the vehicles and periodic emission check for equipment and machinery would be carried out in conformity with the Central Motor Vehicles Rules, 1989.  Water will be sprayed on the haul road.  All the vehicles entering the project site will be checked for Pollution-Under-Control Certificates.  Air quality monitoring to be carried out during construction phase to check the pollutants level in the air Procurement &  Specifications of crushers, hot mix plants and batching plants, other Construction Vehicles, Setting up of Equipment and Machinery to be procured should comply to the DoE Standards/ norms Crushers, Hot-mix  Hot mix plants, crushers and batching plants shall be located at distance of approx 1 km plants, other from nearest habitation, archaeological site, sensitive areas, forests etc. Vehicles,  Aadequate stack height and emission control devices such as bag house filters, cyclone Equipment and separators, water scrubbers etc., should be attached Machinery  Impervious platform for storage of bituminous and other liquid hazardous chemical  Pollution control measures for Diesel Generator (DG) set i.e. stack height (calculated by H = h+ 0.2 * Sqrt(kVA) where h = height of building where generator set is installed and kVA is total generator capacity), acoustic enclosure etc. should be ensured  Proper lighting arrangement shall be made around plant site if the plants are operated during dark hours.  Provision of readily available first aid kit, fire fighting equipments at the plant site at appropriate location to respond in case of accident.  Periodical monitoring of air quality and noise levels as per conditions stipulated under the statutory clearance from DoE. Whenever the emission exceeds the permissible level the plants should be stopped and necessary repairing works of faults should be done to bring down the emission levels Contamination of  Impervious platform and oil and grease trap for collection of spillage from construction soil equipment vehicle maintenance platform will be appropriately provided at construction camp, servicing area and liquid fuel and lubes at storage areas.  Proper management of waste from labour camps and construction site  Proper disposal of wastewater generated from labour camp and construction site Contamination of  Construction close to water bodies shall be avoided surface & ground  Car washing / workshops near water bodies will be avoided. water  Avoid excavation during monsoon season  Loosened soil will be stabilized by Contractor through landscaping and developing vegetation, wherever possible, once construction activity is completed at any site.  Sanitation facility with septic tank followed by soak pit will be developed. Common toilets will be constructed on site during construction phase and the waste water would be channelized to the septic tanks and soak pits in order to prevent waste water to enter into the water bodies.  Provision of oil & grease traps upstream of storm water drains  Surface run off due to construction activity will not be discharged in open without treatment.

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Loss of water  No excavation from the bund of the water bodies. bodies/ surface /  No earth will be excavated for development of any off-site facility ground  No debris disposal near any water body.  Prior written permission from authorities is required for use of water for construction activity.  Construction labours to be restricted from polluting the source or misusing the source.  Labour camps will be located away from water bodies. Drainage and  The Contractor will always clear all the cross drainage structures and natural drainage runoff before onset of monsoon in order to keep all drainage unblocked Earth, stones, wastes and spoils will be properly disposed off, to avoid blockage of any drainage channel.  All necessary precautions will be taken to construct temporary or permanent devices to prevent inundation Noise from  Construction activities would be carried out in the daytime only. Vehicles, Plants  The construction equipment would be provided with adequate noise control measures and and Equipment should comply with the noise standards as prescribed by DoE  Regular maintenance of vehicles and equipment would be carried out and corrective action taken in case of any deviation.  Ear muff/ear plug shall be given to the workers working around or operating plant and machinery emitting high noise levels.  DG sets if installed should be provided with acoustic enclosures  Labour working in noise prone area should be provided with ear plugs and job rotation should be practiced to prevent the prolonged exposure of any workers to high noise levels Loss or damage to  Vegetation will be removed from the construction zone before commencement of vegetation construction. All works will be carried out such that the damage or disruption to flora is minimum.  Only ground cover/shrubs that impinge directly on the permanent works or necessary temporary works will be removed with prior approval from the Environmental Expert. Loss, damage or  Construction workers will be directed not to disrupt or damage the fauna. disruption to  Construction vehicles will run along specified access to avoid accidents to flora and fauna. fauna Accidents  Safety officer should be appointed at site to ensure all the safety guidelines are being followed at site  Cautionary guidance should be provided at site to aware people about the associated risk with the area. Entry to the fuel storage room or machinery operation room should be restricted only to authorized trainer personnel  All Accidents shall be reported immediately and incident analysis, preventive measures shall be implemented. Clearing of  Contractors shall prepare site restoration plans. The plans shall be implemented prior to Construction of demobilization. Camps &  On completion of works, all temporary structures shall be cleared, all rubbish burnt, excreta Restoration or other disposal pits or trenches filled in and sealed and the site left clean and tidy. Occupational  All construction worker should wear PPEs including safety jacket, helmet, gloves, gum Health & Safety boots, ear plugs, mask while working at the site Plan  Workers should be made aware about the health issues related with open defecation  Training to workers should be provided for handling the construction equipment and machinery  Training to the workers should be provided to handle the emergency situations like fire, floods etc.  First aid facility and sufficient nos. of trained personnel should be available at all the time at construction camp  Cautionary signage and notice should be displayed in local language and English at the required places like fuel storage area so that hazards can be avoided. A security guard should be deputed in these areas and entry should be restricted  A register of all toxic chemicals delivered to the site shall be kept and maintained up to date. The register shall include the trade name, physical properties and characteristics, chemical ingredients, health and safety hazard information, safe handling and storage procedures, and emergency and first aid procedures for the product. Disaster Precaution will be taken to prevent danger of the workers and the public from fire, flood, Management drowning, etc. All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

Table 2: Mitigation Measures Suggested for Developer

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Impact Mitigation Measures

Identification of Site for Disposal  Site identified should be 1.0 km away from settlement, sensitive of construction Debris, locations, like school, hospital, religious structures, reseve forest and construction labour camp and any other eco-sensitive zone etc. plant site  Site identified should be approved by BEZA and PMC  Site should be located in downwind direction from settlement area  Fertile agricultural land and community land should be avoided for setting of these facilities Air Pollution  Sprinkling of water during construction phase on all unpaved roads, site and haul roads  Avoiding excess pilling of raw material and debris at site  Storage & transportation of raw material and debris in covered conditions  Regular cleaning of site  Guiding signage should be provided at the site for vehicles  Timings of the construction material vehicles should be fixed and should be during non-peak hours to prevent traffic congestion and traffic jams  Usage of low energy intensive building material like fly ash mic cement and bricks  Usage of low sulphur diesel for running DG sets, construction vehicles and equipments  Obtaining temporary electricity connection during construction phase and operating DG sets only during power failure  Open burning of wood or any other material should be prohibited at site and all the workers should be made aware about the same Water Pollution & water  Minimizing the run-off from the site by construction of sediment Conservation basins  Maintaining the flow of water sprinklers so as to avoid wastage of water  No debris should be thrown or disposed off in any water body like river, pond, canal etc or ground water source like functional or abandoned well  Excavation should not be carried out during monsoon  Provision of temporary storm water drainage system during construction phase to drain the storm water  Excavated pits should be provided with garland drains to prevent enterance of water inside the pit  Provision of oil & grease traps wih the storm water drains draining the parking and fuel storage area  Provision of septic tanks and soak pits at the site & labour camps for disposal of sewage generated by construction labour  Waste generated by construction camps should be disposed off regularly at the identified site for debris disposal  Provision of cross drainage structures like balancing for maintaining the drainage pattern  Stone & bricks should be purchased only from licenced vendors  Keeping provision of land for development of STP and ETP for each industry  Keeping provision of land for development of CETP  Tank alarms should be installed so as to prevent overflow of water  Leakage detection should be carried out quarterly so as to detect any leakages in the gas pipeline Soil Quality  Top soil, if excavated from the project site should be stored in covered condition and should be used later for landscaping purpose  Storage of raw materials, debris and fuel on paved surfaces  Training the workers to handle the material so as to minimize spillage of material on soil  Provision of cross drainage structures to prevent water logging and soil erosion

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 Stone pitching with grass turfing should be done for the high embankment close to water body  Disposal of construction debris, municipal waste from labour camps and hazardous waste from site should be disposed off at the identified site  Keeping provision of land for development of soild waste management facility within the EZ site  No open area should be left without the vegetation to protect the soil.  Mulching of soil should be done regularly to prevent direct exposure of soil to wind and water Noise Pollution  Construction vehicles, machinery and equipment used for construction purpose should meet the standards prescribed by DoE  Upkeeping and regular maintenance of all the construction vehicles, machinery and equipment used for construction purpose  Provision of acoustic enclosures, noise mufflers, silencers etc with the DG sets and any noise generating machinery  Provision of temporary noise shield/barrier in areas where more noise will be generated Ecology  Only identified trees should be fell down after obtaining permission from forest department  Comensatory plantation should be carried out in ratio of min 1:2 under guidance of forest department  Development of 10 m (minimum) thick green buffer all along the periphery of EZ  Boundary should be constructed around the EZ site to prevent trespassing of the animals  Native plant species requiring should be considered for plantation  Timber should be purchased only from authorized vendors  No waterbody should be filled outside the EZ site  The mangroves adjacent to the site location should not be cut or impacted. Disaster and Risk Management  Provision of first aid kit and first aid room and well trained first aid practioner at the site all the time  Ambulance facility should be provided at the site  Tie-ups with local hospital should be made to handly emergency case, if any  Availability of safety officers and supervisiors at all the time on the site  Workers should be given training for handling construction vehicles, equipment and handling emergency situations like fire, floods, earthquake and cyclone  Cautionary signage should be provided in the areas associated with risks like storage of explosives, fuels, heavy construction material etc. Entry for only trained authorized personnel should be allowed in such areas with adequate safery measures  Emergency handling cell & room should be developed at the site and should be headed by project & safety manager  Contact no. of nearest fire-station and hospitals should be displayed within the emergency handling room

1.4. Conclusion and Recommendations

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

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

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

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

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

 Environmental monitoring should be conducted as proposed in environment management plan.  Before development, seperate environment impact assessment study should be carried out by individual units proposed to be developed in the EZ.

 Ecological assessment should be carried out for the proposed EZ before commencement of the project.

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

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2. Introduction

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

Bangladesh Economic Zone Authority (BEZA) has been promulgated under the Bangladesh Economic Zones Act, 2010 to develop the Economic Zones across the country. BEZA, after the initial site assessment, finalized to develop an Economic Zone housing RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution based industries in the Keraniganj upazila under Dhaka district of Bangladesh.

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

2.1. Project Background

The proposed Economic Zone site falls in Keraniganj upazila. The project involves development of EZ and off-site facilities for Dhaka SEZ, Keraniganj Economic Zone by BEZA. The site is surrounded by BSCIC Industrial Estate which comprises of small cottage scale industries. The site details are provided in table 1. The total proposed project area comprises of 105 acres. The major roads which connect Keraniganj with the rest of the country are:  Nawabganj-Dohar-Srinagar road (R820)’; and  Dhaka Mawa Highway. The project site is abuted by Dhaleshwari River- towards the southern side, agricultural and residential settlements towards the – northern side, BSCIC Industrial Estate towards the western side and agricultural land and Sonakanda village towards the eastern side. The site photographs are shown in table below. The proposed project involves development of following offsite facilities:

 Administrative building  Land filling  External power supply system and substation at project site  Water supply arrangement at project site from borewells; and  Approach road construction towards the southwestern corner of the proposed EZ.

Table 3: Site Details of the proposed site

Parameters Details Site co-ordinates 23° 39' 47.11"N to 23° 39' 57.72"N latitude, 90° 18' 28.95"E to 90° 19' 7.74"E longitude Site boundaries on East Agricultural land Site boundaries onWest BSCIC industrial estate Site boundaries on North Agri land & Residential area Site boundaries on South Dhaleswari River Total area of the site 105 acres Land tenure details 40 acres khas (already transferred to BEZA) and 65 acres private Vicinity of proposed site Proposed EZ area is surrounded by:  BSCIC Industrial Estate-West  Dhaleshwari River-South  Agricultural Land and Residential Settlements- North

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Existing land use Agriculture

Table 4: Photographs of the project site

Agricultural Fields at Project Site Agricultural Fields at Project Site

Vegetations at the Project Site Boundary of Bin Habib LPG Plant

Agricultural Fields at the Project Site Agricultural Fields at the Project Site

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Figure 1: Location Map of Dhaka SEZ

Site Location

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

2.2. Rationale for the Proposed Project

Bangladesh is primarily an agricultural economy with close to 50% of the labor force employed in agriculture. Industry sector contribution to Gross Domestic Product (GDP) has hovered around 25-30% only for past few years. Manufacturing sector of Industry shows predominance of export led garments and textile industries and comprise of 52% share of total exports in Bangladesh making it the world’s second largest garment manufacturer. Bangladesh also needs to bolster exports of other indigenous products, which will happen through enhanced industrial infrastructure, capacity building, and policy initiatives. Similarly, the country may choose to substitute imports of capital goods and other items of domestic consumption, provided there is adequate investment in industrial infrastructure to enable domestic manufacturing. The Government of Bangladesh has, in the past, successfully provided tailored infrastructure services and business environment conditions through EPZs. EPZs were used as a strategic instrument for attracting Foreign Direct Investment (FDI) and dealing with the shortcomings of the overall investment climate, business registration, licensing, etc. which were restricting investments in the Domestic Tariff Area (DTA). To overcome the limitations of EPZ model, new EZ regime has been adopted by the Government of Bangladesh so as more spill-over can be harnessed by local firms from FDI , additional investments can be encouraged within value chains, more local produce can be procured and better linkages can be established between manufacturing firms and educational institutions. The EZ development, a zoned industrialization, is required in Bangladesh to maximize the growth benefits of agglomeration and ease the increasing urban congestion. More importantly, the project will enable new sources of growth, where investor will show their interest.

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2.3. Scope and Methodology of the Study

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

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

2.4. Limitation of the Study

The present EIA Report has been prepared based on the field investigations / assessment, primary data collected from on-site monitoring and testing and secondary data from data collected from Department of Public Health and Engineering (DPHE), Department of Environment (DoE), Bangladesh Meteorological Department (BMD), Bangladesh Water Development Board (BWDB), and published journals, and books, public consultation and site observations. The environmental and social assessment is based on the information collected from the various Agencies, community consultations and observations. Professional judgement and subjective interpretation of facts and observations has been applied for the preparation of the EIA Report. Since offsite facilities are proposed to be developed by BEZA, required information essential for EA are available. The onsite (industrial area detailed planning will be carried out by prospective private developer) information are available limited to feasibility assessment. 27 EIA Report- Dhaka SEZ

2.5. ToR Compliance Matrix

The EIA study has been conducted in accordance with the ToR issued submitted to DOE. Table 2 presents the point-wise compliance of the issued ToR. Table 5: Compliance of TOR Points

S. No. ToR Point Compliance

I The project authority shall conduct a comprehensive EIA study has been carried out in Environmental Impact Assessment (EIA) study line with the ToR Approved by considering the overall activity of the said project in DoE and WB guidelines accordance with this ToR and following additional suggestions II The EIA Report should be prepared in accordance Agreed with following indicative outlines: 1 Executive Summary Refer Chapter 1 2 Introduction: (background, brief description, Refer Chapter 2 rationale of the project, scope of study, methodology, limitation, EIA team, references) 3 Legislative, regulation and policy consideration Refer Chapter 3 (covering the potential legal, administrative, planning and policy framework within which the EIA will be prepared) 4 Project Description Refer Chapter 4 i. Introduction Section 4.1 ii. Project objective Section 4.2 iii. Project options Section 4.2 iv. Interventions under selected options Section 4.3 v. Project activities: A list of the main project activities Section 4.5 to be undertaken during site clearing, construction as well as operation vi. Project schedule: The phase and timing for Section 4.6 development of the project vii. Resources and utilities demand: Resources required Section 4.7 to develop the project, such as soil and construction material and demand for utilities (water, electricity, sewerage, waste disposal and others), as well as infrastructure (road, drains, and others) to support the project viii. Map and survey information Section 4.8 Location map, cadastral map showing land plots (project and adjacent area), geological map showing geological units, fault zone, and other natural features 5 Environmental and Social Baseline Refer Chapter 5 5.1 Meteorology Section 5.2.1 5.1.1 Temperature Section 5.2.1.1 5.1.2 Humidity Section 5.2.1.2 5.1.3 Rainfall Section 5.2.1.3 5.1.4 Wind Speed Section 5.2.1.4 5.1.6 Sunshine hours Section 5.2.1.5 5.2 Water Resources Section 5.2.2 5.2.1 Surface Water System Section 5.2.2.1 5.2.2 Tropical cyclones and Tidal Flooding Section 5.2.2.8 & 5.2.2.9 5.2.3 Salinity Section 5.2.2.2 5.2.4 Drainage Congestion and Water Logging Section 5.2.2.1 5.2.5 Erosion and Sedimentation Section 5.2.2.3 5.2.6 River Morphology Section 5.2.2.4

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5.2.7 Navigation Section 5.2.2.5 5.2.8 Ground Water System Section 5.2.2.6 5.3 Land Resources Section 5.2.3 5.3.1 Agroecological Regions Section 5.2.3.1 5.3.2 Land Types Section 5.2.3.2 5.3.3 Soil Texture Section 5.2.3.3 5.3.4 Land Use Section 5.2.3.4 5.4 Agriculture Resources Section 5.2.8 5.4.1 Farming Practice Section 5.2.8 5.4.2 Cropping Pattern and Intensity Section 5.2.3.1 and 5.2.8 5.4.3 Cropped Area Section 5.2.8 5.4.4 Crop Production Section 5.2.8 5.5 Livestock and Poultry Section 5.2.8 5.5.2 Livestock/Poultry Diseases Section 5.2.9 5.6 Fisheries Section 5.2.10 5.6.1 Introduction Section 5.2.10 5.6.2 Problem and Issues Section 5.2.10 5.6.3 Habitat Description Section 5.2.10 5.6.4 Fish Production and Effort Section 5.2.10 5.6.5 Fish Migration Section 5.2.10 5.6.6 Fish Biodiversity Section 5.2.11.2 5.7 Ecological Resources Section 5.2.11 5.7.1 Bio-ecological Zone/Protected Areas Section 5.2.11 5.7.2 Common Flora and Fauna Section 5.2.11 5.7.3 Ecosystem Services and Function Section 5.2.11 5.8 Socio Economic Condition Section 5.2.12 5.8.1 Socio Economic Condition Section 5.2.12 5.8.2 Quality of Life Indicators Section 5.2.12 5.8.3 Income and Poverty Section 5.2.12 5.8.4 Gender and Women Section 5.2.12 5.8.5 Common Property Resources Section 5.2.12 5.8.6 Conflict of Interest and Law and Order Situation Section 5.2.12 6 Identification and Analysis of Key Environmental Refer Chapter 6 Issues (Analysis shall be presented with Scenarios, Maps, Graphics, etc. for the Case of Anticipated Impacts on Baseline) 6.1 Environmental Sensitivity Investigation Section 6.1 6.2 Environmental Aspect/Valued Environmental Section 6.2 Components 6.1 Environmental Hot Spots Section 6.3 6.1 Likely Beneficial Impacts Section 6.4 6.1 Community Recommendations Section 6.5 6.1 Alternate Analysis Section 6.5 7 Environmental and Social Impacts/Impact Refer Chapter 7 Assessment 7.1 Introduction Section 7.1 7.2 Impact on Water Resources Section 7.5 7.2.1 Pre-construction Phase Section 7.5.1 7.2.2 Construction Phase Section 7.5.1 7.2.3 Post-construction Phase Section 7.5.2 7.3 Impact on Land Resources Section 7.6 7.3.1 Pre-construction Phase Section 7.6.1 7.3.2 Construction Phase Section 7.6.1 7.3.3 Post-construction Phase Section 7.6.2 7.4 Impact on Agriculture Resources Section 7.8 7.4.1 Pre-construction Phase Section 7.8 7.4.2 Construction Phase Section 7.8 7.4.3 Post-construction Phase Section 7.8

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7.5 Impact on Fisheries Section 7.9 7.5.1 Pre-construction Phase Section 7.9 7.5.2 Construction Phase Section 7.9 7.5.3 Post-construction Phase Section 7.9 7.6 Impact on Ecosystem Section 7.7 7.6.1 Pre-construction Phase Section 7.7 7.6.2 Construction Phase Section 7.7 7.6.3 Post-construction Phase Section 7.7 7.7 Socio Economic Impact Section 7.16 and Section 7.13 and Section 7.11 7.7.1 Pre-construction Phase Section 7.16 and Section 7.13 and Section 7.11 7.7.2 Construction Phase Section 7.16 and Section 7.13 and Section 7.11 7.7.3 Post-construction Phase Section 7.16 and Section 7.13 and Section 7.11 8. Public Consultation and Disclosure Refer Chapter 8 8.1 Introduction Section 8.1 8.2 Objectives of Public Consultation and Disclosure Section 8.1 Meeting 8.3 Approach and Methodology of Public Consultation Section 8.2 and Disclosure Meeting 8.4 Public Consultation Meetings (PCMs) Section 8.3 8.5 Public Disclosure Meetings (PDMs) Section 8.4 9. Environmental Management Plan and Monitoring Refer Chapter 9 Indicators 9.1 Introduction Section 9.1 9.2 Mitigation Plan Section 9.2 9.3 Enhancement Plan/Institutional Arrangements Section 9.6 9.4 Contingency Plan/Emergency Preparedness Plan Section 9.3 9.5 Compensation Plan Section 9.10 9.6 Monitoring Plan Section 9.4 9.7 Monitoring Indicators Section 9.5 10 Cost Estimation for Environmental Mitigation Refer Chapter 10 Measures and Monitoring 11. Conclusions and Recommendations Refer Chapter 11 III Without obtaining approval of EIA report by the Agreed Department of Environment, the Project authority shall not be allowed to conduct earth filling or any kind of physical intervention in the proposed project site and also not be able to start the physical activity of the project. IV This approval of the Terms of Reference (ToR) would Agreed not mean any acceptance or site clearance of the Project. V The proposed EIA study would not establish any Agreed claim, right in favour of the proponent for getting site clearance or environmental clearance. VI. Without obtaining Environmental Clearance, the Agreed project authority shall not be able to start the operation of the project. VII. The project authority shall submit the EIA along with Agreed the No Objection Certificate (NOC) from the local authority, NOC from Forest Department (if it is required in case of cutting any forested plant, private or public) and NOC from other relevant agencies for operational activity etc. to the Bagerhat District Office of DOE with a copy to the Head Office of DOE in Dhaka.

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2.6. EIA Team

BEZA has appointed M/s PricewaterhouseCoopers Pvt. Ltd. For carrying out environmental and social impact assessment studies for development of five upcoming EZs in Bangladesh. As per the procedure, proposed Terms of Reference (ToR) was submitted to DOE in May 2016. Approved ToR was granted by DoE vide Memo No. DoE/Clearance/5457/2016/228, dated 13 June, 2016. Copy of the approved ToR by DoEB is attached as Annexure II. The EIA study for the development of proposed Sabrang EZ has been carried out as per the ToR issued by DoEB, World Bank’s requirements and Environmental Management Framework of BEZA. The PwC team appointed for carrying out the ESIA studies is mentioned below: Table 6: EIA Team

Team Member Position Experience Yasir Ahmad Team Leader and More than 12 years of experience in Environmental Environmental Specialist and Social policy development, Social/Environmental audits, Environmental and Social impact assessment (ESIA) reviews, Environmental Due-diligence, Responsible investment related engagements for various industrial sectors including infrastructure, retail etc. Dr. D.J Rao Environmental and Tourism Doctrate with more than 28 years of experience in Specialist Environmental and Social Impact Assessment (ESIA) for diverse sectors, Community /Stakeholders’ Consultation, Risk Management, Environment and Social Mitigation Plan, carbon and sustainability strategy, etc. Mr. Sandeep Kota Project Manager More than 8 years of experience in Environment and Social impact assessment, Environmental management plan, Health and Safety compliance audits, Environmental Due-diligence, Responsible investment related engagements for various industrial sectors. Ms. Anjali Yadav Environmental Expert Five years of experience in Environment and social impact assessment, Environmental and social reviews, Environment and social policy development, Environment health and safety audits, Site investigation & characterization, Environmental site assessments (phase I & phase II ESA) and Remediation of soil and groundwater. Mr. Dhiman Environmental Expert Five years of experience in Environment and social Chakraborty impact assessment, Environmental and social reviews, Environment and social policy development, Environment health and safety audits, Site investigation & characterization, Environmental site assessments (phase I & phase II ESA) and Remediation of soil and groundwater 2.7. Structure of the Report

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

Chapter 2: Introduction

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This chapter provides background information of the project background, rationale for the proposed project, scope and methodology adopted for EIA study, limitations of the study, TOR compliance matrix, details of the EIA team, structure of the report and references.

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

Chapter 4: Project Description This chapter presents the details of the project, project objectives and options, interventions under selected options and activities, project area of influence, project activities, existing infrastructure in and around the site, project schedule and resources and utilities demand.

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

Chapter 6: Identification and Analysis of Key Environmental Issues This chapter identifies and details the key environmental issues related to the project.

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

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

Chapter 9: Environmental Management Plan and Monitoring indicators This Chapter provides mitigation and control measures to attenuate and/or eliminate environmental impacts, which are likely to be caused by the proposed project. An Environmental Management Plan (EMP) has been developed to mitigate the potential adverse impacts and to strengthen the beneficial impacts. This chapter also provides the environmental monitoring plan proposed for the project.

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

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

2.8. References

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

Table 7: Reference Used for EIA Study

S. No. Reference Government Departments 1. Bangladesh Economic Zone Authority

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2. Department of Public Health and Engineering 3. Department of Environment 4. Bangladesh Meteorological Department 5. Bangladesh Forest Research Institute 6. Bangladesh Bureau of Statistics 7. Geological survey of Bangladesh 8. Bangladesh Water Development Board 9. Department of Disaster Management 10. Bangladesh Inland Water Terminal Authority (BIWTA) 11. Keraniganj Upazila Office 12. Keraniganj Union Office 13. District Forest Department, Cox Bazar Journals & Books 1. Population and Housing Census-2011, Community Report: Munshiganj, Bangladesh Bureau of Statistics, Statistics and Informatics Division, Ministry of Planning 2. Sirajur Rahman Khan, Revised by Michiel Damen, ITC, Cyclone Hazard in Bangladesh, 2013 3. Banani Mandal, Arunava Mukherjee, Subrata Sarkar & Samir Banerjee, Study on the Ornamental Fin Fish of Indian Sundarbans with Special Reference to Few Floral Sources for Carotenoid Pigmentation, 2012 4. Community Report Dhaka Zila June 2012, Population and Housing Census 2011, Bangladesh Bureau of Statistics, Statistics and Informatics Division, Ministry of Planning 5. District Dhaka 2011 Dhaka, Bangladesh Bureau of Statistics (BBS), Statistics and Infrmation Division (SID), Ministry of Planning, Government of the People’s Republic of Bangladesh 6. Sample Baseline and Preliminary Estimation by Baangladesh University of Engineering and Technology (BUET), 2012. 7. Keraniganj Upazila Health Complex, Ministry of Health and Family Welfare (MOHFW), Health Bulletin 2014 8. Tonmoy Sarker, Sedimentation process at Navigation Channel of Mongla Port on the Pasur Sibsa river system in Bangladesh, UNESCO IHE Institute of Water Education The Netherlands 9. “Consequences of Climate Change on Fish Biodiversity in the River Turag, Bangladesh: A Community Perception Studies” by B.Paul, Md. Hasan Faruque and Dewan Ali Ahsan; World Journal of Fish and Marine Sciences 6 (2): 136 – 141; Department of Fisheries, University of Dhaka 10. Adhikary, S.K., Gupta A. D. & Babel M.S., Modelling Groundwater Fow and Salinity Intrusion by Advective Transport in the Regional Unconfined Aquifer of SouthWest Bangladesh 11. Bangladesh Delta Plan 2100 Formulation Project, River System Management, 2015 12. Assessing Risk to Groundwater from On-Site Sanitation: Scientific Review and Case Studies, British Geological Survey 13. Land Use Change Detection of the Buriganga River using GIS tools and its Water Management for Promoting a Sustainable Environment, Syed Mahmud-ul-Islam, May 2011 14. “Investigation of Vertical Distribution of Soil Elements at Central Part of Bangladesh Using Neutron Activation Analysis” by Md. Saifur Rahman, Syed Md. Hossain, Md. Jamal Uddin; International Journal of Environmental Protection: Feb 2013, Vol. 3 (5 – 13) 15. Final Report on Development of Deep Aquifer Database and Preliminary Deep Aquifer (First Phase), March 2006, Local Government Division, Ministry of LGRD. Existing Studies 1. Md. Golam Mahabub Sarwar, Impacts of Sea Level Rise on the Coastal Zone of Bangladesh, Land University International Masters, Programmes in Environmental Sciences, 2005 2. Lubna Seal, Mohammed Abdul Baten, Salinity Intrusion in Interior Coast: A New Challenge to Agriculture in South Central part of Bangladesh, Unnayan Onneshan-The Innivators 3. Fisheries Statistical Yearbook of Bangladesh, 2012-2013, department of Fisheries, Bangladesh, Ministry of Fisheries and Livestock 4. Final Report, Prepraration of Detailed Area Plan (DAP) for DMPD area: Location 3, RAJUK 5. Research Report on State of Bangladesh’s Water by Hamidur Rahman Khan with the support of Nippon Foundation, 2004 6. “Bangladesh Delta Plan 2100 Formulation Project”: River Systems Management ; Baseline Study, August 2015: General Economics Division, Planning Commission, Government of Bangladesh 7. “Effects of Climate Change on River Morphology in Bangladesh and a Morphological Assessment of Sitalakhya River” by S.Hossain, M.Rahman, F. Nusrat, R. Rahman and N.F.Anisha: Journal of River Research Institute (RRI) Website 1. Wikipedia 2. Google maps 3. http://www.bangladeshtourismdirectory.com/bangladesh-archaeological-sites-list.html 4. Google earth imageries 5. http://www.saarc-sadkn.org/countries/bangladesh/disaster_mgt.aspx (Bangladesh Disaster Knowledge Network)

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6. http://www.bangladeshdeltaplan2100.org/wp-content/uploads/2016/02/Sustainable-Transportation-3- IWTFinal-June-2016.pdf 7. http://en.banglapedia.org/index.php?title=Agroecological_Zone 8. http://www.timeanddate.com/sun/bangladesh/dhaka?month=12&year=2015 Others 1. Site visits 2. Initial Site Assessment Reports 3. WB General EHS Guidelines 4. WB Performance Standards 2012 5. BEZA EMF

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3. Legislative, Regulation and Policy Consideration

3.1. Regulatory Requirements for the Proposed Project

This section highlights the regulatory requirements set out by Government of Bangladesh (GoB) and World Bank (WB) in relation to protection of environment and its resources as well as protection of the social environment from adverse impacts associated with the project development. These requirements are summarized below. Table 8: Regulatory Frameworks

Name Key Requirement Applicability Remarks Acts/Rules The Environment Mandatory requirement of prior Applicable. The Site approval certificate is Conservation environment clearance for certain project is classified to be obtained from DoE Act, 1995 and category of project for under red category subsequent conservation and improvement of EIA study required amendments in environment and control and to be undertaken 2000 and 2002 mitigation of pollution of the and 2010 environment.

To ascertain responsibility for compensation in case of damage Environment to ecosystem Conservation Rules, 1997 Restriction on polluting (Subsequent automobiles, sale and production Amendments in of environmental harmful items. 2002 and 2003) Promulgation of standards for quality of air, water, noise and soil for different areas for different purposes.

Declaration of ecologically critical areas

Promulgation of standard limit for discharging and emitting waste.

Formulation and declaration of environmental guidelines.

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

Environment To give high priority to Applicable as the All the developments to be Court Act, 2000 environment pollution project shall have carried out as per ECA, 1995 and subsequent prevention environmental & ECR, 1997 and amendments in impacts amendments. 2002 The Penal Code Chapter XIV of the Penal Code Applicable. It is required to take all the provides offences affective public measures proposed and health, safety, convenience, suggested by DoE,

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decency and morals; Section 277: Bangladesh during both Falling Water or Public Spring or construction an operation Reservoir; Section 278: Making phase to minimize the Atmosphere Noxious to Health; environmental pollution Section 284: Negligent Conduct with Respect to Poisonous Substance; Section 285: Negligent Conduct with Respect to Fire or Combustible Matter; Section 286: Negligent Conduct with Respect to Explosive Substance. Section 277: whoever voluntarily corrupts or fouls the water of any public spring or reservoir, to render it less fit for the purpose for which it is ordinarily used will be punished under the law. Section 278: whoever voluntarily vitiates the atmosphere in any place so as to make it noxious to the health of persons in general dwelling or carrying on business in the Neighbourhood or passing along a public way will get punishment. The Protection Prohibit or regulate the Applicable. The Necessary permission and Conservation construction, temporary or project involves would need to be taken for of Fish Act, 1950 permanent of weirs, dams, bunds, construction of construction of and subsequent embankment and other embankment and embankment. amendments structures other structures. in 1982 Water Pollution Prevention of water pollution Applicable from the Applicable during both Control prospective of construction stage ( e.g. Ordinance 1970 prevention of sewage and equipment pollution washing and maintenance liquid waste discharges at construction camps) and operation phase (tourism activities) The ground Water Management of Ground Water Applicable. Three Permission should be taken Management Resources. nos. tube wells will before digging tube wells Ordinance 1985 be dug to develop Tube well shall not be dug in any water supply system place without permission from during operation Upzilla parishad. phase The Embankment An Act to consolidate the laws Applicable. The Regulatoy authority and Drainage Act relating to embankment and project involves Ministry of Water 1952 drainage and to make better construction of Resources and FCD provision for the construction, embankment. maintenance, management, removal and control of embankments and water courses for the better drainage of lands and for their protection from floods, erosion and other damage by water. Wetland Adhere to a formal Applicable. The Permission to be taken Protection Act environmental impact proposed site from the Ministry of Water 2000 assessment (EIA) process, as set location has low Resources and DOE out in EIA guidelines and lying area. manuals for water sector projects or related to alteration of natural drainage.

No construction of roads if likely to effect the flow of navigable

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water ways without clearance from concerned authorities

Upland flow in water channels to preserve eco-system

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

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

Stop unplanned construction on riverbanks and indiscriminate clearance of vegetation on newly accreted land. The Building An Act to provide for the Applicable as the Regulatory authority is Construction Act prevention of haphazard project involves Ministry of Works 1952 (with latest construction of building and development of amendment excavation of tanks which are infrastructure 2006) likely to interfere with the planning of certain areas in Bangladesh The Vehicle Act, To regulate vehicular exhaust Applicable as heavy Regular maintenance and 1927 emissions vehicle movement is upkeeping of the vehicles The Motor involved both during should be carried out. Vehicles construction and Regulatory authority is Ordinance, 1983 operation phase Bangladesh Road Transport The Bengal Motor Authority Vehicle Rules, 1940 The Factories Act, This Act pertains to the Applicable as the Regulatory authority is 1965 occupational rights and safety of workers will be Ministry of labour Bangladesh factory workers and the employed during Labour Law 2006, provision of a comfortable work construction and amendment 2013 environment and reasonable operation phase of Bangladesh working conditions. EZ Labour Rules 2015 Policies National For sustainable development Applicable for all Usage of energy efficient Environment development building material, fuel etc. Policy, 1992 projects should be encouraged National Conservation of natural habitats, Applicable for all Usage of energy efficient Environment bio-diversity, energy, sustainable development material, green building Management development and improvement projects techniques, reduction of Action Plan 1995 of life of people carbon foot prints etc. National Sustainable development of Applicable for all Usage of energy efficient Conservation Industrial Sector development material, green building Stratergy projects techniques, reduction of carbon foot prints etc. The National Protecting the environment by Applicable. EIA Energy efficient materials Energy Policy, requiring an EIA for any new study is to be carried and techniques should be 1995 energy development project, out explored introduction of economically viable and environment friendly technology. The National To ensure efficient and equitable Applicable. Ground Conjunctive use of water Water Policy, management of water resources, water is required to should be explored 2000 proper harnessing and be withdrawn for development of surface and fulfilling water

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ground water, availability of requirement during water to all concerned and operation phase institutional capacity building for water resource management The National Addresses options for water Applicable as it is Installation of sewage Water quality, considerations behind tourism sector reatment facility within the Management measures to clean up industrial project and will premises Plan, 2001 pollution, where effluent involve generation of discharge monitoring and zoning sewage regulations for new industries are emphasized World Bank’s Safeguards OP 4.01 Ensures sustainability and Triggered Project classified as Environmental environmental feasibility of the Category A considering Assessment project. Projects are classified impacts of project into A, B & C category depending on the nature and extent of the impact. OP 4.04 Ensures conservation of natural Triggered The project is likely to Natural habitats habitats and discourages affect the natural habitat of disturbance of any natural habitat the marine ecosystem. due to project development by Hence the OP 4.04 is recommending adoption of trigerred. alternative method/route/approach or adopting management measures OP 4.12 Ensures safeguards to address Triggered The proposed land is Involuntary and mitigate risks due to devoid of any structures. Resettlement involuntary resettlement such as Small temporary kaccha economic, social and huts have been constructed environmental risks. to house the workers employed in the salt farming and are used for a period of 6 months during the phase of salt farming. Also, there is private land of 60.5 acres in the proposed project area. Private Sector Development Support Project Environment Describes all the mandatory Triggered EIA report is prepared referring to Management environmental and social the guidelines mentioned in Framework clearances and purpose of the BEZA’s EMF. (EMF) same required to be taken before development of the project The framework sets out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the project activities to eliminate adverse environmental impacts, offset them, or reduce them to acceptable levels.

3.2. Procedure for Obtaining Environmental Clearance from DoE, Bangladesh

Bangladesh has very simple administrative framework regarding environmental aspect. It has strong interface between local government and federal Government. Department of Environment is responsible for

38 EIA Report- Dhaka SEZ grant of environmental clearance to a project. In addition to three are other ministries to deal with specific area of importance to the country like Forests, Water.

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

Table 9: Steps for Obtaining Clearances from DoE, Bangladesh

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4. Project Description

4.1. Project Introduction

The proposed project involves development of EZ and off-site facilities for Dhaka SEZ Keraniganj Economic Zone proposed to be developed by BEZA. The total proposed project area comprises of 105 acres. The major roads which connect Narayanganj with the rest of the country are:  Zinzira-Keraniganj-Nawabganj-Dohar-Srinagar road (R820);  Dhaka Mawa Highway The site is abutted by Dhaleswari River on the southern side, Keraniganj BSCIC Industrial Estate on the eastern side, Sonakanda mouza on the western side and agricultural lands on the northern side. The BSCIC Industrial Estate comprises of small cottage scale industries like plastic industries, leather industries. The agricultural lands on the northern side of the village are mostly privately owned. It is envisaged that the Economic Zone will comprise of RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution based industries. The site details are provided in figures below. The proposed project involves development of following offsite facilities to make site appropriate for development of economic zone:

 Development of boundary wall  Constrution of around 350m approach road  Construction of administrative building  Land filling  External power supply system and substation at project site  Water supply system for project site

Following development of offsite facilities, economic zone shall be developed under Public Private Partnership Model and a separate Environmental Clearance shall be obtained on a later date. It is envisaged that the Economic Zone will comprise of RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution based industries.

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Figure 2: Location of Economic Zone

Figure 3: Mouza map of proposed site

Figure 4: Site Surrounding Features

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Source: ISA report

4.2. Project Objectives and Options (Alternate Analysis)

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

Table 10: SWOT Analysis of the Dhaka SEZ

Parameters Strengths Weaknesses  Zinzira-Keraniganj-Nawabganj-Dohar- Srinagar Road (R820) passes adjacent to the proposed site. Approach Road  The EZ will be connected with the R820 highway by construction of 15m wide two lane access for a length of 600 m The water requirement is proposed to be met through the bore wells (2 bore wells within the site to meet the initial demand of Water availability 1 MLD, the bore well depth of around 150 to 200 meter) to be constructed at the project site  The proposed site is located on the bank of Dhaleswari River and the Landfilling depth of waterlogging in the proposed Requirements site is around 5-6 ft during monsoon season. Therefore, Landfilling of depth 6-10 feet needs to be undertaken. 42 EIA Report- Dhaka SEZ

 Landfilling shall leads to cost implications before the commencement of the development works.  The proposed site comprises of private agricultural land and houses, thus attract resettlement issues.  There are 4 number of household structures affected by the project along with 65 acres of agricultural land. The Resettlement issues project affected persons include the 108 land owners of the 65 acers of private land, who practice crop cultivation throughout the year.  The private land owners and affected household structures will be compensated based on the entitlement matrix as part of the RSMF. The proposed site comprises of private lands where the existing land use is for Loss of agricultural activities, thus the acquisition income/livelihood of the private lands will result in livelihood loss for the land owners Parameters Opportunities Threats  The proposed site is located in Keraniganj upzila, which is located 18 km away from the zero-point of Dhaka city.  The road distance between the centre Road connectivity of Keraniganj upzilla and the proposed site is about 2 kms.  The proposed site is connected to both Zinzira-Keraniganj-Nawabganj-Dohar- Srinagar Road (R820) and Dhaka Mawa highway (N8).  The distance between the proposed site and the Dhaka railway station is approx. 20 km. Dhaka is connected with the rail network to other parts of Rail connectivity the country.  Currently, there are approx. 329 trains per day stops at Dhaka railway station for transporting passengers to Chittagong and Kolkata.  The proposed site is located about 30 km North East of Hazrat Shahjalal International Airport in Dhaka. Air connectivity  Dhaka Airport is the largest airport in the country. The travelling time from the proposed site to Dhaka Airport is approx. 2 to 2.5 hours.

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The proposed site has access to the following substations:  33/11 kV Sonakanda substation (with 20 MVA capacities) is located approx. 3 km from the proposed EZ. This substation has excess capacity which could be utilized for the initial phase.  150 MW Hasnebod power station is located 30 km from the proposed site. Power connection  100mw power plant operated by M/s. Power pac is located 3.5 km on the east side near Dhaka Mawa road.  New 33/11 kv substation is also proposed adjacent to the site. Since, there are multiple options to source the power supply to the proposed EZ, hence the 24×7 uninterrupted electricity supply could be a possibility.

 The proposed site falls in the Keraniganj upzilla. As per the Bangladesh government plan, Keraniganj Upazila shall be integrated into Dhaka municipality in the near future, to accommodate the expansion of the capital.  A number of industries such as Ceramic industry, beverage industry, Existing industrial press and publication, garments ecosystem industry, foot ware, jute mills, textile mills, printing and dying factory, transformer industry, automobile industry, biscuit and bread factory, pharmaceutical industry, cosmetic industry, soap factory, rice mill, flour mill, ice factory, ball pen industry, polythene industry, saw mill, brick field, cold storage, welding, plant nursery, etc. are located in Keraniganj upzilla.  The proposed site is located in Keraniganj. Keraniganj is connected to Proximity to major Dhaka city by two bridges viz. Buriganga Bridge-1 and 2. cities  It is also located adjacent to Dhaka- Mawa Highway and Dhaka-Dohar Highway.

The proposed industry to be developed at  There are a total of 120 Govt. primary the site is SEZ which requires highly Availability of schools, 18 private primary schools, 4 qualified and trained manpower with educational junior high schools, 6 co-education technical know-how. institutions in the colleges, 2 girls’ colleges and 30 high There is no educational institution of nearby areas to schools in Keraniganj upzilla. international reputation in the project area supply quality However, there are no international which can train local stakeholders with the manpower standard educational facilities and technology institutions in this area. requisite technical know-how for working in SEZ.

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 One government hospital (Upzilla Health Complex) is available in Keraniganj upzila with 31 beds and a Availability of private hospital in the Pourashava of For quality healthcare facility, people have the upzilla. medical facilities to commute to Dhaka city.  The upzilla has 1 health complex, 1 community health centre, 16 non govt. medical clinics, 6 diagnostic centres and 13 family planning centres. Employees require access to good residential facility in the vicinity of the IT EZ. At present within 5 km radius of the proposed EZ, there are no such amenities available. Keraniganj is an outskirt area of Dhaka Metropolitan, and hence Availability of good international standard residential facility residential facility and quality lifestyle is not available in the and quality lifestyle nearby areas of the proposed site. in the nearby areas Planned Jhillmill township is planned in close proximity (approx. 5 km) to the proposed site. Once operational, it is poised to provide good residential facility and quality lifestyle to the employees of the proposed site.

4.3. Interventions under selected options and activities

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

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

It is proposed to develop the proposed EZ for RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution, industries. Following development of offsite facilities, economic zone shall be developed under Public Private Partnership Model and a separate Environmental Clearance shall be obtained on a later date.

4.4. Project Area of Influence

Tthe project area of influence encompasses, as appropriate:

The area likely to be affected by: (i) the project and the client’s activities and facilities that are directly owned, operated or managed (including by contractors) and that are a component of the project; (ii) impacts from unplanned but predictable developments caused by the project that may occur later or at a different location; 45 EIA Report- Dhaka SEZ or (iii) indirect project impacts on biodiversity or on ecosystem services upon which Affected Communities’ livelihoods are dependent.

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

Figure 5: Project Area of Influence

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

Infrastructure assessment is part of technical feasibility. The infrastructure part presented in the subsequent sections is very preliminary. The proposed site falls under under agriculture and aquaculture zone of Dhaka district. As observed during site visit, the proposed EZ has a level difference of 6 m (approx.) with a gentle slope towards South direction where the site is abutted by the river. According to the contour variation, the depth of landfilling across the project area shall vary. The natural slope of ground is advantageous for gravity network of water supply, sewer and storm water drains. The contour maps of the proposed EZ for 5 km and 10 km radius are presented respectively in below figures. The project site consists of a total of 105 acres of land. Out of that, 40 acres is Khas land remaining 65 acres is privately owned land.Based on the interaction with the UNO officials and local inhabitants, flood level during monsoon season varies from 5 feet to 6 feet depth inside the proposed EZ area. To avoid inundation during monsoon season, minimum land filling above the flood level is considered. Thus an average depth of 6 feet to 10 feet of land filling has been envisaged for the proposed EZ area.

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4.5.1 Power Supply for the proposed Site

33/11 kV Sonakanda substation (with 20 MVA capacities) is located 3 km (approx.) from the proposed EZ. This substation has excess capacity which could be utilized for the initial phase. 150 MW Hasnebod power station is located 30 km from proposed EZ. 100mw power plant operated by M/s. Power pac is located just 3.5 km on the east side near Dhaka Mawa road. New 33/11 kv substation is also proposed adjacent to the site.

4.5.2Water Availability for the proposed Site

Water line is available upto BSCIC Industrial Estate. Local inhabitants are dependent on the tube well water for drinking purpose. There are a total of 5,574 tubewells in Keraniganj upazilla. Dhaleshwari and Buriganga are the main rivers situated in this region. Groundwater is available at a depth of 150-250 feet from NGL. Water requirements for the construction and operational phase of the EZ shall be sourced from the borewells proposed to be constructed at the project site.

4.5.3Gas Supply for the proposed Site

At present there is no gas transmission / distribution network is available in this region.

4.5.4 Telecom/ Internet connectivity to the proposed Site

Bangladesh's landline telecommunications system is owned by the state. The Bangladesh Telephone andTelegraph Board (BTTB) is the organization that controls telecommunications in the country. Besides BTTB, which operates in all urban areas, there are two private operators. Bangladesh Rural Telecom Authority and Sheba Telecommunications provide telephone services to rural areas. Digital telephone systems are being introduced into Bangladesh. VSAT technology is used to connect to the Internet in Bangladesh. Around 54 Internet Service Providers operate in the country. Satellite Internet in Bangladesh enables individuals to access the internet in remote areas through terrestrial means. In 2014, Bangladesh Submarine Cable Company Limited (BSCCL) had 200Gbps (88MIU-km) bandwidth available and Bangladesh was using only 32Gbps or 16% of it.94 Thus, Bangladesh Govt. had approved a proposal for exporting around half of the country’s internet bandwidth to the North Eastern states of India as Bangladesh was utilizing only 16% of its total bandwidth. Bangladesh has a total of 82 MIU-km of unused bandwidth and Govt. has given approval to BSCCL for renting or leasing of internet bandwidth. Hence, it can be concluded that the supply of internet bandwidth is far larger than the demand throughout the region.

4.5.5 Connectivity

Keraniganj is located 18 km away from the zero-point of Dhaka city. The road distance between the centre of Keraniganj upzilla and the proposed EZ is about 2 kms. Proposed EZ is located in between Zinzira- Keraniganj-Nawabganj-Dohar-Srinagar Road (R820) and Dhaka Mawa highway (N8).

4.5.5.1 Road

 Zinzira-Keraniganj-Nawabganj-Dohar-Srinagar Road (R820) passes adjacent to the proposed EZ. Connecting road for a length of 750 m from R820 need to be widened and strengthened.  Dhaka Mawa highway (N8) is accessible from the proposed EZ via Dhamsur-sonakanda road at a length of 5 km. Widening of this road will attract more issues as there are several market place(s), educational institution(s), religious places and residential areas located on both the sides of the road.

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4.5.5.2 Rail

Dhaka is connected with the rail network to other parts of the country. The Dhaka railway station is located at a distance of 20km (approx.) from proposed EZ. The frequency of passanger and commuter trains from Dhaka to other parts of Bangladesh is shown in table below.

Table 11: Details of trains running from Dhaka district

Details of Train Service Frequency (number of trains per day) Intercity 82 Main Express and Commuter 78 DEMU Commuter 32 Shuttle/Local 137 Total 329

4.5.5.3 Airport

 The proposed Dhaka IT EZ is located about 30 km North East of Hazrat Shahjalal International Airport in Dhaka.  Dhaka Airport is the largest airport in the country. The travelling time from the proposed site to Dhaka Airport is 2 to 2.5 hours (approx.).  Govt. of Bangladesh intends to construct a new international airport (Bangabandhu Sheikh Mujib International Airport) with a view to create a hub airport in close proximity to Dhaka and to meet the demand of future growth in aviation sector.  Not only the air traffic in Bangladesh has increased, but also the cargo traffic has escalated and none of the airports in the country are currently equipped to handle the massive flow of trade and passengers. The location of this proposed airport is not yet finalized; however the new proposed airport shall be located in Dhaka division (within 50-70 km radius of the proposed EZ).

4.5.5.4 Port and Harbour Connectivity

Chittagong port

The Port of Chittagong is the principal Port of Bangladesh. Proposed EZ is located at a about distance of 276 km from this EZ. However, for development of RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution, industry, proximity to port is not a prerequisite. 4.5.6 Proposed Infrastructure

Some of the major project activities will involve:

 Site Development – It is proposed to develop the entire area of site for land filling work. An embankment adjacent to the river is proposed to protect the site from flooding upto +4 m from NGL and minimum site filling of average 1 m from the existing NGL for the entire site area

 Construction of Access Road - The main raod connecting the different industrial set-up in BSCIC Industrial estate will be used as the approach road for the EZ also. The existing BSCIC road will connect the EZ with R820 highway. Down south, construction of an access road is required which shall eventually connect the EZ with R820 highway.

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

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

 Water supply – The water requirement is proposed to be met through the bore wells (2 bore wells within the site to meet the demand of 1 MLD, the bore well depth of around 150 to 200 meter) to be constructed at the project site

 External power supply system – An electrical requirement of 38.26 MVA has been envasised for the operation phase of the EZ. Options for drawing power shall be exercised from Hasnebod Power station or PowerPac Power Station or the nearest Sonakanda Power Station.

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Figure 6: Embankment Details

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Figure 7: Embankment cross-section details

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Figure 8: Structural Details for Pile, Plinth beam and Fencing

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4.6. Project Schedule

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

Table 12: Implementation Schedule of Off-site Infrastructural Details

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

4.7. Resources and Utilities Demand

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

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Details for BOQ of Bund and Fencing Work (1/8)

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Details for BOQ of Bund and Fencing Work (2/8)

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Details for BOQ of Bund and Fencing Work (3/8)

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Details for BOQ of Bund and Fencing Work (4/8)

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Details for BOQ of Bund and Fencing Work (5/8)

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Details for BOQ of Bund and Fencing Work (6/8)

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Details for BOQ of Bund and Fencing Work (7/8)

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Details for BOQ of Bund and Fencing Work (8/8)

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4.7.1 Water

Water requirement during construction phase is estimated to be app. 4.4 MLD, which includes Domestic water requirement of construction workers. For storing rain water during construction phase, temporary rain water harvesting ponds can be constructed at the site. Water for construction shall be sourced from rain water harvesting ponds & Ground water. The total water requirement for operational phase is estimated at about 1 MLD which is proposed to be met through the bore wells (2 bore wells within the site to meet the initial demand of 1 MLD) to be constructed at the project site. 4.7.2 Power Requirement

Power demand during construction phase is quite significant. Power required has been estimated to be 38.26 MVA. Power supply system will be developed at later stage by developer. The nearest sub-station to the proposed EZ is Sonakanda substation having capacity of 20 MVA. The 33/11 Sonakanda substation is located 3 Kms (approx.) from the proposed EZ. This substation has excess capacity which could be utilized for the initial phase. 150 MW Hasnebod power station is located 30 km from proposed EZ. 100mw power plant operated by M/s. Power pac is located just 3.5 km on the east side near Dhaka Mawa road. New 33/11 kv substation is also proposed adjacent to the site. 4.8 Estimated Project Cost

The project cost as envasised for this project includes the following things as tabulated in the table below:

Table 13: Estimated Project Cost

Infrastructure BDT USD Site Dvelopment 53,809,280 672,616.00 Embankment & fencing 49,131,678 614,145.98 Access Road 55,296,746.7 691,209.33 Administrative Building 13,0476,579 1,630,957.24 External Water Supply (PTW) 63,435,000 792,937.50 Pumping Main 1,983,000 24,787.50 External Power Supply 115,583,659 1,444,795.74 Boundary Wall 21,300,372.91 266,254.66 Total 491,016,315.61 6,137,703.95

4.9 Maps and Survey information 4.9.1 Project Location

The economic zone is proposed to be located in the Sonakanda mouza at Keraniganj Upazila of Dhaka district of Bangladesh approximately 18 kms from the National Capital city of Dhaka. The total land area demarcated for the proposed economic zone is 105 acres which includes land under private ownership (65 acres) and Khas Land (40 acres). The project site is located at approximately 2 kms from the center of Keraniganj Upazila. The proposed EZ is located in between Zinzira-Keraniganj-Nawabganj-Dohar- Srinagar road (R820) and Dhaka Mawa Highway. The site is abutted by Dhaleswari River on the southern side, Keraniganj BSCIC Industrial Estate on the eastern side, Sonakanda mouza on the western side and agricultural lands on the northern side. The BSCIC Industrial Estate comprises of small cottage scale industries like plastic industries, leather industries. The agricultural lands on the northern side of the village are mostly privately owned. It is envisaged that the Economic Zone will comprise of RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, non processing area, Educational Institutions, Training Institution, based industries.

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The below figure indicates the site locations, features in the vicinity and the road connectivity with the site.

Figure 9: EZ location on Upzila Map

Site Location

Figure 10: Project site and surroundings

Figure 11: Mouza Map with the project site

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Figure 12: Contour Map of the Proposed EZ

Figure 13: Topography of the Site

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Agricultural Fields at Project Site

Vegetations at the Project Site Boundary of Bin Habib LPG Plant

Agricultural Fields at the Project Site Agricultural Fields at Project Site

4.10Eco Sensitivity

The proposed site is not abutted by any ecologically sensitive areas or locations. There are no reserve forests or Ecologically Critical Area around the site location.

4.11 Geology

Keraniganj Thana is situated in the physiographic region of the Central Valley Flat. This region is characterized by stabilized river courses. There are levee formations along the rivers. Most settlements occur along the levees; settlements are sparsely distributed in the backwash areas behind the levees. River Buriganga on the east and river Dhaleswari is flowing on the west borders of the Thana. The Buriganga originated from the Dhaleswari on the north and these two rivers again joined on the south (border of Munshiganj Zila). The Buriganga has an elongated meandering course, which is called the 'Dhaka Reach'.

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Keraniganj has a thick cover of Holocene sediments and lies in the central part of the Bengal Basin. To the east lies the uplifted and highly oxidized Pliestocene sediments of the Madhupur Tract and to the south across the Dhaleswari River is the easternmost part of the slightly uplifted older Meghna estuarine and floodplain sediments of the Tippera Surface (Coleman, 1969). To the north and west lies the young Brahmaputra (Jamuna) floodplain sediments of the Recent Ganges-Brahmaputra Delta. Tectonically Keraniganj falls within the northeastern part of the Faridpur Trough (gravity low) of the Bengal Basin. The Faridpur Trough is bounded by the Barisal Gravity High in the east and southeast and a hinge zone in the west. In the northeast it finds its continuation in the Sylhet Trough. The Faridpur Trough is characterized by a general gravity low trending north-east. The basement is deeply buried here (about 8 to 10 Km. below mean sea level) (Guha, 1978).

In the Seismic Zoning Map of Bangladesh, Keraniganj falls in Zone II where the maximum intensity of it is not likely to exceed VIII (modified Mercalli Scale) and the suggested basic horizontal seismic co-efficient is 0.05 (Seismic Resistant Design of Structure, 1979).

The soils of the area are Quaternary Holocene (recent) alluvial deposits. The area is situated on the right bank (south bank) of the Buriganga in Keraniganj Thana. Alluvial deposits carried by Brahmaputra- Jamuna, Ganges-Padma and Meghna rivers and their numerous tributaries and distributaries formed a large part of Bangladesh. Alluvial deposits of Bangladesh have been defined into several units in the Geological Map of Bangladesh (1990). Alluvial deposits range from flood sand to over bank silt and pounded clay. The project area has overlapping alluvial sand deposit (asd), alluvial silt deposit (asl) and alluvial silt-clay deposit (asc). Refer the figure below for the geological map of Bangladesh and the type of geology at Keraniganj.

Alluvial sand unit (asd) is composed of light to brownish grey, coarse sand to fine silty sand and sand is generally sub-rounded. Alluvial silt unit (asl) is composed of light to medium-grey, fine sandy to clayey silt, commonly poorly stratified; average grain size decreases away from main channels; chiefly deposited in flood basins and inter-stream areas. Alluvial silt unit includes small back swamp deposits and varying amounts of thin, inter-stratified sand, deposited during episodic or unusually large floods. Included in this unit are thin veneers of sand spread by episodic floods over flood-plain silts.

Soils on the settlement formations mostly followed the sand and silty sand. Two types of soil may be found in the Keraniganj one is sand and silty sand, other is clay and silty clay. Physical properties of soil may be categorized into 4 groups. The characteristics of each group are as follows.

A) Group-A Dominantly silty clay and clay, low permeability, high water holding capacity, high compressibility, poor drainage, level to depressed relief, medium to high plasticity.

B) Group-B Dominantly sand, high permeability, low water holding capacity, low compressibility, good drainage, low plasticity, low ridge and depressed relief.

C) Group-C Dominantly clay silt and sand, moderate permeability and drainage, moderate water holding capacity, low to moderate compressibility, level relief with local ridge, high shear strength. A separate report is presented on the soil condition of the study area with eight volumes. A map on the borehole points also attached with that report.

Figure 14: Geological Map of Bangladesh

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46 EIA Report- Dhaka SEZ

Figure 15: Geological Map of Keraniganj

Keraniganj

4.12 Master Plan of Dhaka SEZ 4.12.1 Land Use Pattern within the Zone

The proposed land use pattern is determined by considering the land requirements for various broad area classification i.e. Export Processing Area (EPA), Domestic Processing Area (DPA) and non-Processing Area.

Figure 16: Broad Zone Demarcations

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Figure 17: Land Use by Broad Area Classification

Figure 18: Land use by Industries and Services

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Table 14: Proposed Land Use

Plot Type Number Area in Area in % of Plots Acres Hectares 1 Export Processing Area (EPA) CETP1 2 1.99 0.806 1.89 CSTP 2 1.99 0.806 1.89 Integrated Textile 10 10.196 4.128 9.66 Light Engineering (Part) 6 5.824 2.358 5.52 Pharmaceutical (Part) 2 2.7688 1.1208 2.67 RMG 14 15.655 6.336 14.83 Ware House 1 0.992 0.402 0.94

2 Domestic Processing Area (DPA) Light Engineering (Part) 6 5.824 2.358 5.52 Pharmaceutical (Part) 3 4.153 1.681 4.00 Plastic Industries 6 5.976 2.419 5.66 Printing and Packaging Factory 3 3.294 1.333 3.12

1 The required capacity of the CETP is 8,226 m3/day. Accordingly the space has been allocated.

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SFB 1 0.998 0.404 0.95 O.W.T & Water Treatment Plant 1 1.001 0.405 0.95 Power Plant/ Sub-Station 1 0.538 0.218 0.51

3 Commercial Area 1 1.596 0.646 1.51 (Bank, Insurance Company, Restaurant etc)

4 Non Processing Area Administrative Building & Custom House 1 1.729 0.7 1.64 Dormitory 1 0.455 0.184 0.43 Embankment - 3.484 1.411 3.30 Fire Services 1 0.309 0.125 0.29 Footpath - 0.962 0.389 0.91 Gas Factory Area 1 1.604 0.649 1.52 Green 3 0.763 0.309 0.72 Guest House With Helipad 1 1.001 0.405 0.95 High Class Residence 1 1.69 0.684 1.60 Jetty Terminal 1 0.918 0.371 0.87 Khal - 2.022 0.818 1.92 Park 1 0.392 0.159 0.37 Play Ground 1 0.708 0.287 0.67 QA / QC Lab 1 0.474 0.192 0.45 Health Service 1 0.495 0.2 0.47 Road 2 12.814 5.186 12.14 Round About - 0.009 0.004 0.01 School Cum Day Care Center 1 1.134 0.459 1.07 Slope - 3.051 1.235 2.89 Solid Waste Dumping Station 1 0.28 0.113 0.26 Truck Stand 1 2.156 0.872 2.04 Vocational Training Center 1 1.011 0.409 0.96 Walkway - 0.319 0.129 0.30 Water Reservoir 3 2.657 1.076 2.52 Worker Accommodation 1 2.286 0.925 2.17

Total 83 105.519 42.712 100.00

4.12.2 Water Supply System In the proposed economic zone, the water consumption demand will be about 10,000 cubic meters per day. 4.12.2.1 River Water

A water reservoir is planned to be built in 2.657 acres in the economic zone. The water in the water reservoir will be taken from Dhaleswari River. After treatment of river water, the water can be supplied to Economic Zone. Initially whole year’s water requirement may be fulfilled from this source. However over time, as new industries will be set-up, additional source of water needs to be pursued. In full capacity of the zone, around 7-8 months water can be drawn from the river. During dry season, under-ground water will be required. 4.12.2.2 Underground Water

The initial demand of 10 MLD is proposed to be met through 20 bore wells to be sunk at the project site. 4.12.2.3 Water Distribution Network

Water Distribution Networks deliver water to each factory along the roads, coming through the tower and tank at several places built inside the zone. The treatment system is composed of the following:

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 River water intake  Reservoir  Treatment Plant  Tank and Tower  Distribution Pipe Network Below figure shows the water supply and drainage network

Figure 19: Water Supply and Drainage Network

Green Pocket Gate Plastic Green Plastic Industry Industry RMG Park Dormitory Pocket Worker Gate Plastic Accommodation Plastic Plastic Industry Industry Plastic Industry Industry

RMG RMG RMG RMG RMG RMG

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e & S Helipad e r i F Main Gate Bridge 15m Wide Road 15m Wide Road

Light Light Truck Stand Integrated Integrated Integrated Integrated Engineering Engineering Administrative Textile Textile Textile Textile Pharmaceutical Em Building ba nkm & Custom ent House Integrated Integrated Light Integrated Integrated Light d Textile Textile Textile Textile Engineering Engineering a Pharmaceutical o R

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Footpath

A gravity feed system will be used to supply water to the water supply pipe line located along the footpath of the road inside the Project. The size of main water supply pipe will be from 150 mm. –350 mm. and water supply pressure is in the range of 1.0 – 3.0 bars. Main water supply pipe will be of high density polyethylene (HDPE) if available, to avoid corrosion as well as breaking in the future. Below figure shows the water supplu system.

Figure 20: Diagram for Water Supply System

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52 EIA Report- Dhaka SEZ

5. Description of Environment (Environment and Social Baseline)

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

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

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

5.1 Methodology

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

5.2 Baseline data Collection

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

Meteorological data is used to anticipate the dispersion and diffusion of pollutants, once discharged into the atmosphere. The baseline conditions of physical parameters are provided in subsequent sections: 5.2.1.1 Temperature

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

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

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

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

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 24.50 25.30 24.60 24.50 25.90 23.80 23.40 24.10 24.20 24.30 24.46 Feb 29.10 31.30 27.10 26.10 29.70 28.90 28.70 28.50 28.90 27.20 28.55 Mar 32.20 33.20 31.50 31.70 33.30 34.10 32.10 33.00 33.40 32.40 32.69 Apr 34.40 33.70 33.70 34.50 35.60 35.50 33.50 33.50 34.20 36.40 34.50 May 33.20 33.80 34.80 34.70 34.60 34.30 33.40 34.60 31.70 35.20 34.03 Jun 33.40 32.40 32.50 32.50 34.50 33.10 32.60 33.20 33.70 33.20 33.11 Jul 31.50 32.40 31.50 31.80 32.30 33.00 32.30 32.60 32.70 32.90 32.30 Aug 32.10 32.50 32.50 32.10 32.50 33.10 31.10 32.60 32.00 32.20 32.27 Sep 32.80 31.90 32.00 32.60 32.50 32.50 32.40 32.90 32.60 32.90 32.51 Oct 30.60 32.30 31.50 31.40 32.20 32.40 32.70 32.30 31.50 32.20 31.91 Nov 29.10 29.70 29.00 29.70 30.20 30.10 29.70 28.70 30.20 30.20 29.66 Dec 27.10 26.90 25.80 25.60 26.00 26.10 25.00 24.00 26.30 24.50 25.73

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

5.2.1.2 Relative Humidity

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

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

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

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Sep 81.00 80.00 80.00 81.00 81.00 79.00 77.00 79.00 81.00 76.00 79.50 Oct 80.00 76.00 78.00 77.00 73.00 74.00 73.00 71.00 78.00 72.00 75.20 Nov 72.00 68.00 77.00 69.00 66.00 68.00 67.00 68.00 66.00 66.00 68.70 Dec 66.00 69.00 69.00 79.00 69.00 66.00 73.00 77.00 72.00 77.00 71.70

5.2.1.3 Rainfall

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

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

Month 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 Ave of 10 years Jan 1 0 0 23 1 0 0 10 0 0 3.5 Feb 3 0 30 56 1 48 0 1 8 12 15.9 Mar 155 0 11 45 43 22 20 37 26 10 36.9 Apr 91 181 163 91 14 37 123 269 32 80 108.1 May 291 185 185 205 168 177 235 137 378 147 210.8 Jun 259 326 628 577 170 308 314 175 325 342 342.4 Jul 542 331 753 563 676 167 356 226 302 212 412.8 Aug 361 167 505 319 482 340 409 282 212 391 346.8 Sep 514 663 179 279 298 169 207 81 172 156 271.8 Oct 417 61 320 227 74 174 112 38 131 49 160.3 Nov 3 5 111 0 4 0 0 68 0 0 19.1 Dec 0 0 0 0 0 81 0 5 4 0 9.0

5.2.1.4 Wind Speed and Direction

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

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

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

As indicated in the below wind rose diagram, the area experiences wind speeds lower than 5 m/s for 98% of time. Of this half the time (44.4%of the time) is calm condition throughout the year (wind speeds in the range of 1-2.5 m/s). This indicates the weather conditions are not favorable for dispersion of pollutants released in the air. Month wise prevailing wind speeds are as follows: predominantly calm conditions

55 EIA Report- Dhaka SEZ prevail during January to March and September to December periods with the area experiencing wind speeds in the range of 1-2.5 m/s. The remaining five months experience lesser calm conditions and wind speeds in the range of 2.5 – 5 m/s.

Figure 21: Wind Rose Diagrams

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5.2.1.5 Sunshine Hours

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

Figure 22: Sunshine hours in Dhaka City, 2015

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13 13 13.5 13.5 13 12 12.5 12 11 11.5 11 10

Source: http://www.timeanddate.com/sun/bangladesh/dhaka?month=12&year=2015 5.2.2 Water Resources 5.2.2.1 Surface Water systems and Drainage

The major water body abutting the site on its southern side is the Dhaleswari River. There are no other surface water systems within the project influence area. Buriganga is a tributary of the Dhaleswari River that joins Meghna River. At the western side a small river Turag joins Buriganga in the northern part of the Dhaka city area. The upstream of the Buriganga was formerly a branch of the Dhaleswari River and contributed substantially to the flow in the Buriganga which became silted up. The main sources of water of the Buriganga River come through the Turag River along with the local runoff (SWMC, 1996). The Turag provides the main flow of the Buriganga. At Munshiganj, it connects with the Dhaleshwari. The Buriganga head part is silted at Chhaglakandi at most times and opens only during the time of flood. The natural drainage system of the site also faces a constraint of elevation levels with respect to the mean sea level (MSL). Reportedly central Bangladesh where district Dhaka is located has the lowest elevation levels. An elevation of less than 5m is reported for central Bangladesh while the northern and southern extremes are reportedly located at the highest elevation levels of greater than 40m above MSL. Low elevation with respect to MSL would also impact the drainage system. Problems of water logging and stangnant water would be a common issue here because of the lack of proper drainage system. Refer the below Digital Elevation Map from CEGIS for the relative elevation levels of entire Banglaedesh.

Figure below shows the drainage map of the subject site.

Figure 23: Drainage Pattern of the Project Site

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Figure 24: Digital Elevation Map of Bangladesh

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5.2.2.2 Salinity

Salinity of Dhaleswari River was calculated based on the Electrical Conductivity results obtained from Department of DoE of the year 2014. Refer the below table for the average salinity levels (in ppt) in Dhaleshwari River. The levels of salinity as calculated from the tabe below reports to be 0.09667 PPT at Muktarpur Ghat and 0.1674 PPT at Horindhora Ghat of Dhaleshwari River.

Table 19: Land Type Classification

Locations/S Ja Fe Mar Apri M Ju July Aug Septe O Nov Dec Aver alinity n b ch l ay ne ust mber ct age (PPT) (PPT ) Muktarpur 185.3 401 552 Ghar (EC µS/CM) Salinity* 0.047 0.102 0.14 0.09 21 17 064 667 Horindhora 1304 1304 149.4 174.9 353 (EC µS/CM) Salinity* 0.33 0.33 0.03 0.04456 0.08 0.167 223 223 806 05 994 4 * 1PPT (of salt dissolved in water) = 3925 µS/cm Source: State of Bangladesh’s Water, Research Report, 2004 (Nippon Foundation)

5.2.2.3 Erosion and Sedimentation

No erosion site at EZ site and at river bank is observed. Though during the time of site screening, dredging along the river shore was observed. Dredging along the river shore shall make the soil loose with low compaction factor. Excessive dredging activity might result in erossions along the shoreline of the river. Map showing areas prone to river bank erosion is given below in the below figure.

Figure 25: Riverbank Erosion Pattern in Bangladesh

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5.2.2.4 River Morphology

The Dhaleshwari River is a left bank distributary of the Jamuna River. Presently, the river has become a mere flood spill channel due to vulnerability of its off-take to sedimentation and thus, has also has become a low- energy river. Its off-take has changed significantly during 1973 to 2010 (below figure). During 1960s, about 8- 9% of the Jamuna flow volume was diverted through the Dhaleshwari River which has reduced to less than 1% during the late 2000s. Due to the decreased discharge, the width of the river has been reduced from 1200 m (during the early 1940’s) to 300 m. The river has no significant erosion-accretion process and accretion is the prevailing process in some reaches. The length and average width of the river is about 292 km and 144 m respectively

Figure 26: Change in River Morphology

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The flow regime of the Dhaleshwari River since 2004 is presented in the following figure:

Figure 27: Flow Regime of Dhaleshwari River, 2004

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Figure 28: Flow Regime of Dhaleshwari River, 2007

Figure 29: Flow Regime of Dhaleshwari River, 2010

Figure 30: Flow Regime of Dhaleshwari River, 2012

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Figure 31: Flow Regime of Dhaleshwari River, 2014

Figure 32: Flow Regime of Dhaleshwari River, 2016

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There is not much significant differences in the flow regime satellite images of the Dhaleshwari River from 2004 to 2016. Few tributaries of the river towards south of the project site (close to Fulhar) has dried out since 2010, as shown in the satellite images above. 5.2.2.5 Navigation

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

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

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

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

5.2.2.6 Groundwater Systems

The study of the groundwater demand from different parts of the country shows that northwest and north central region depend on groundwater a lot for the supply of the water. Groundwater resources are determined by properties of groundwater storage reservoir and volume of annual recharge. Mainly rainfall, flooding and stream flow in rivers penetrate earth surface and recharge groundwater reservoirs. Although Bangladesh has been considered rich in groundwater resources, the total groundwater storage data is absent. National Water Plan Phase-II estimated average groundwater as 21 cubic kilometres (cu km) in 1991. However, with the increased trend of urbanisation and irregular rainfall behaviour, surface run-off has increased in recent times, which reduces groundwater recharge considerably. Figure below is the groundwater zoning map in Bangladesh, 2010. From the map it could be seen that the groundwater level in and around the subject site is shallow. The groundwater level as reported by the figure below is somewhere between 0.5m-3m below ground level (bgl).

Figure 33: Groundwater Zoning Map in Bangladesh, 2010

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

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

The transmission property of the main aquifer is good to excellent over most of the country but it is deteriorating towards the south and the east. Underlying the main aquifer, there is a deeper water bearing

69 EIA Report- Dhaka SEZ unit separated by one or more clay layers of varied thickness referred as the deep aquifer that has been exploited by tube wells in Dhaka and in the coastal areas. In the areas near the coast the water table is descending due to over extraction or salinity contamination of upper or main aquifer7. Strong declining trends (0.5–1 metre/year) in dry-period groundwater levels are observed in the central part of the country surrounding the Dhaka city. Moderately declining trends (0.1–0.5 metre/year) occur in western, northwestern, and northeastern areas. In the northern table land areas and floodplains of the major rivers, magnitudes of declining trends are low (0.01–0.05 m/yr). Stable or slightly rising trends (0–0.1 metre/year) are generally observed from the Meghna estuary to the southern coastal areas in the country. A similar overall pattern is seen during wet periods except in the northern table land areas, southwestern delta plains and southern coastal areas where wet period trends are slightly rising or stable.

Specifically for Keraniganj, It is quite difficult to delineate precisely the aquifer system of this area due to a lack of good quality borehole information. However, an attempt has been made to delineate a generalised aquifer system. The upper (shallow) aquifer is at a depth of between 5 to 7 metres from the ground surface, and its thickness varies from 30 to 60 metres. The water-level in the aquifer is typically at a depth of about 3 m below the ground surface. The long term hydrograph of Keraniganj shows no evidence of long-term water-level fluctuations. The lower (deeper) aquifer is located at a depth of between 40 to 70 metres from the ground surface with an undefined base. Most of the hand tube wells of this area are constructed down into the lower aquifer. In Keraniganj recharge from rainfall and floodwater is high even where the presence of an overlying silty-clay layer produces leaky or semi confined conditions. Recharge by horizontal inflow from low lying areas and from the Buriganga river occus throughout the year.

5.2.2.7 Seismicity

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

Figure 34: Seismicity Map of Bangladesh

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Source: BMD

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

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

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

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

Table 20: List of Major Earthquakes in Bangladesh

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

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

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Figure 35: Cyclone affected area map of Bangladesh

Source: Department of Disaster Management

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

Figure 36: Cyclone tracking map of Bangladesh

Source: Department of Disaster Management

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5.2.2.9 Tidal Floods

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

There are two types of floods which occur in Bangladesh: annual floods (barsha) that inundate up to 20% of the land area; and low frequency floods of high magnitude that inundate more than 35% of the area (bonna). The major floods that occurred in 1954, 1955, 1974, 1984, 1987, 1988, 1993, 1998, 1999, 2000 and 2007 have been very destructive and caused serious threat to lives and economy. In the context of human exposure in flood hazard zones, nearly 19,279,960 people are present in these zones and Bangladesh ranks 1st among 162 nations. Similarly, the modelled amount of GDP in seismically hazardous zones puts Bangladesh 3rd among 162 countries. The flood affected area map of Bangladesh is provided in the figure below. The map shows that Keraniganj in Dhaka district, lies in River/Monsoon flood area. Floods or Water logging during monsoon season However, during stakeholder discussions it was found that flash floods occur during monsoon time and the flood level varies from 4 feet to 5 feet within the area of the proposed EZ.

Figure 37: Flood affected area map of Bangladesh

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Source: Department of Disaster Management

5.2.2.10 Tornado

It is the pre-monsoon period when most of the abnormal rainfall or drought conditions frequently occur in different parts of Bangladesh. Also there are severe local seasonal storms, popularly known as nor’westers (kalbaishakhi). Severe nor’westers is generally associated with tornadoes. Tornadoes are embedded within a mother thundercloud, and moves along the direction of the squall of the mother storm. The frequency of devastating nor’westers usually reaches the maximum in April, while a few occur in May, and the minimum in March. Nor’westers and tornadoes are more frequent in the afternoon. Nor’westers may occur in late February due to early withdrawal of winter from Bangladesh. The occasional occurrence of nor’westers in early June is due to the delay in the onset of the southwest monsoon over the region (Karmakar, 1989). List of the nor’westers and tornadoes is given in table below. The data shows that Manikganj district in Dhaka which is very close to Keraniganj Upazila got hit by tornado way back in 1973..

Table 21: List of Tornadoes had hit the Bangladesh

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

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9th May, 1976 Narayanganj 1st April, 1977 Faridpur 26th April, 1989 Saturia (Manikganj) 14th May, 1993 Southern Bangladesh 13th May, 1996 Tangail 4th May, 2003 Brahmanbaria 21st March, 2005 Gaibandha

5.2.3 Land Resources 5.2.3.1 Agroecological Regions

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

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

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

Figure 38. Agroecological Regions of Bangladesh

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5.2.3.2 Land Types

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

The sediments deposits of Bangladesh mainly consists of those laid down by the Ganges, Brahmaputra and Meghna (GBM) river systems. Holocene floodplain deposits cover most of the surface area of present-day

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Bangladesh. According to geographic and geomorphic distribution, the Holocene floodplains are divided in four classes:  Piedmont plains  Meander floodplains  Tidal floodplains  Estuarine floodplains

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

Table 22: Land Type Classification

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

As per the classification, project site will be covered under medium lowland. 5.2.3.3 Geomorphology/ Soil Texture

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

Figure 39: General Soil map of Bangladesh

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

Extensive areas throughout the flood plain are occupied by broad ridges on which rather yellowish, friable, silt loams and silty clay loams predominate. Some of those have dark grey topsoils which are acid when dry, but slightly alkaline when flooded; subsoils are moderately alkaline, but non-calcareous. In the southern half of Narayanganj district there are extensive deep basins which have dark grey compact clays with moderately alkaline subsoils usually overlying a yellowish and loamy substratum. The soil types of Dhaka are presented in below table. Flooding depths are mainly less than 5 feet in the east but increases to 10 feet in west. The general soil map of Bangladesh is provided in the below figure.

Table 23: Soil types in Dhaka District

Soil type Description Non-calcareous Raw sandy and silty alluvial deposits, usually stratified either from the surface or below the cultivated topsoil in the active floodplain areas (young char lands) or massive in the older flood plain areas. Non-calcareous grey Prismatic and/ or blocky structured predominantly grey sandy loams to silty clay floodplain soils loams on young floodplain ridges and silty clay loams to clays in basins. Slightly acid to neutral. They become saline in dry season in the coastal areas. Non-calcareous dark grey Structured dark grey loamy soils on old flood plain ridges and clay in basins. floodplain soils Slightly acid to somewhat alkaline in reaction. The basin clays have heavy consistence.

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Figure 40: General Soil map of Banngladesh (highlighting Keraniganj)

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Figure 41: Geological log for Manikgonj District

Source: “Investigation of Vertical Distribution of Soil Elements at Central Part of Bangladesh Using Neutron Activation Analysis” Md. Shafiur Rahman, Syed Mohammod Hossain, Mohammed Jamal Uddin; International Journal of Environmental Protection, Feb 2013, Vol-3

Manijgonj is the the district immediately west of Keraniganj. Geological information of Manikgonj has been shown as a representative for Keraniganj. Both Manikgonj and Keraniganj has the same set of soil texture as shown in the above figure of General Soil Map of Bangladesh. 5.2.3.4 Land Use

Land Use pattern at Keraniganj proposed site:

The proposed EZ is planned on an area of 105 acres. Out of the total 105 acres,40 acres was with DC which has been transferred to BEZA at present and remaining 65 acres is privately owned land. The entire area has presently no utility. Presently approximately 75 acres of land is under agricultural use. Apart from agricultural use, the land is not under any usage.

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

The proposed EZ is abutted by Dhaleswari River on its Southern side. The site is abutted by BSCIC Indistrial area to its immediate west. Beyond that there are agricultural fields with pockets of residential settlements. Towards the immediate east of the site lies the Sonakanda Village. Beyong that, there are agricultural land with small pockets of residential settlement. Five (5) Kms down north lies the Rohitpur town. Between the site and the town, lies wide spread agricultural lands with sparse residential houses.

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

Figure 42. Land Use Pattern around the subject Site, Keraniganj

5.2.4 Ambient Air Quality

PwC conducted the analysis of ambient air quality parameters within the subject site premises. The laboratorical analysis was done by experts of MIST. The rationale behind undertaking the ambient air quality analysis was to understand the baseline air quality. The results of the primary monitoring were compared against the recent National Ambient Air Quality Standards (NAAQS) published by DoE in 2005. Table below tabulates the ambient air quality assessment conducted by PwC on 5th August, 2016. Refer Annexure C for the Ambient Air Quality Assessment Report from MIST.

Table 24: Ambient Air Quality Assessment, 2016

Parameters Units National Ambient World Bank Results Air Quality EHS Standards (DoE, Guidelines 2005) Volatile Organic ppm --- 2.04 Carbon (VOC) Carbon dioxide ppm --- 342.0 (CO2)

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Carbon monoxide ppm 35.0 ppm (1 hour) 2.75 (CO)

Oxygen (O2) % --- 20.9 Relative Humidity % --- 68.2 Sulfur Dioxide ppm 0.14 ppm (24 hours) 20 PPM (24 0.11 (SO2) hours) Nitrogen Oxide ppm 0.053 ppm (Yearly) 40 ppm (Yearly) 0.012 (NOx) Ozone (O3) ppm 0.12 ppm (1 hour) BDL* Hydrogen Sulfide ppm --- 2.17 (H2S) Suspended µg/m3 200 µg/m3 (8 hours) 92.8 Particulate Matter (SPM) Particulate Matter µg/m3 --- 50 µg/m3 (24 50.1 (PM 10) hours) Particulate Matter µg/m3 --- 25 µg/m3 (24 39.4 (PM 2.5) hours)

As shown in the above table, none of the reported concentrations were found to exceed the DOE standards. Though the weighted average concentrations of PM2.5 and PM10 were found to exceed the World Bank EHS standards. The baseline analysis of the selected parameters of air suggests that the quality of ambient air meets the standard criteria and at present none of the reported concentrations of the key parameter exceeds the standards as per the NAAQS (DoE, 2005).

The ambient air quality data was also collected from secondary sources. There are no industries in Keraniganj in the close proximity of the proposed site area. Siddhirganj Power Plant is located approximately 30 Kms from the proposed EZ location. Secondary data from the EIA report of Siddhirganj Power Plant has been used to determine the baseline air quality. Table below shows the ambient air quality data collected from the EIA study for the Siddhirganj Power Plant which was conducted in 2014. The data was compared with the existing Schedule-2 standards of “Standards of Air” under ECR, 1997. The air quality data shows that the concentration of SPM was reported to exceed the Standards of Air (Schedule- 2) ECR-1997. Reported concentration of NOx and SO2 were found to be below than the the Standards of Air (Schedule-2) ECR-1997. Subsequently, onsite ambient air monitoring for analysing the concentration of the SPM was also conducted at site. The primary monitoring was conducted by Department of Environment, Bangladesh, Dhaka unit.

Table 25: Ambient Air Quality data collected from EIA report of Siddhirganj Power Plant (µg/m3)

Sample Location SPM NOx SO2 Siddhirganj 2 x 150 MW power plant 361.72 28 ND Plant Gate 370.62 36.52 12.40 Sukkur Pur Market 385 45.2 18.20 Standard Limits as per ECR 1997, 200 100 80 Bangladesh

Table 26: World Bank Group General EHS guidelines (Ambient Air quality guidelines)

Parameter Guideline Value (µg / m3) PM2.5 25 (24-hour averaging period) 10 (1-year averaging period) PM10 50 (24-hour averaging period) 20 (1-year averaging period) SOx 500 (10 min averaging period) 20 (24 hour averaging period)

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NOx 200 (1 hour averaging period) 40 (1 year averaging period)

5.2.5 Ambient Noise Quality

The ambient noise quality data presented in this section is collected from secondary sources as well as primary monitoring conducted at the subject site. Since there are no industrial estates within radius of 30 kilometres of the proposed site, ambient noise secondary data reported in the EIA report of Siddhirganj Power Plant, 2014 has been used as a reference. Apart from the secondary data, analysis on-field of the ambient noise quality was also conducted. DoE, Bangladesh Dhaka unit was engaged to analyse the ambient noise quality. Table below higlights the ambient noise quality at several locations outside the Siddhirganj Power Plant.

Table 27: Ambient Noise Quality data collected from the EIA report of Siddhirganj Power Plant (Decibal)

Location Noise at day level (dBA) Noise at night level (dBA) Location 1 80.7 67.6 Location 2 76.1 55.7 Location 3 81.2 56.6 Location 3 77.1 64.4 Location 4 65.6 59.9 Location 5 71.9 59.2 Location 6 84.4 70.6 Location 7 72.4 60.8 Location 8 85.9 67.3 Location 9 73.1 65.1 Location 10 96.9 72.5 Location 11 91.4 73.3 Location 12 93.0 75.5 Location 13 84.4 64.2 Location 14 97.6 83.2 Location 15 81.8 56.7 Location 16 86.5 58.3 Location 17 94.8 69.3 Location 18 97.6 67.4 Location 19 115.0 63.5 Location 20 82.5 99.9 Location 21 115.0 98.7 Location 22 72.1 62.1 Location 23 90.0 65.2 DoE (Bangladesh) 75 70 Standard for Industrial zone (day time) as per ECR 1997 in Bangladesh

Ambient noise quality monitoring was conducted by DoE on 7th June, 2016. The analysis was conducted on the western side of the proposed site, adjacent to the BSCIC Industrial Estate. Table below shows the noise level as reported by DoE, Bangladesh Dhaka unit. Refer Annexure A for the reported results of ambient noise conducted by DoE, Bangladesh.Refer Annexure B for the Noise Monitoring Assessment Report from DoE.

Table 28: Ambient Noise Quality analysed at the Dhaka SEZ, Keraniganj

Sample Location Date Time Sound Level (dBa) West of the proposed 01st June, 2016 1210 hrs 40.2 EZ

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Sound Standards (ECR, 1997) (for mixed area) 60 Bangladesh Stadnard at day time for Residential Area as per Noise 55.0 Pollution (control), Rules, 2006

The reported sound level was found to be lower than the ECR, 1997 standards and also with the Noise Pollution (control), Rules, 2006. 5.2.6 Water Environment

The project site is abutted by Dhaleshwari River- on its South, BSCIC Industrial aea immediately on its west, agricultural and residential settlements on its east and north. The river is the route of the communication with Chandpur, Chittagong as the port of cargo. Besides these, the people live on and around the Sitalakhya River utilize its water for their household washing, bathing and other necessary daily works. 5.2.6.1 Surface Water Quality

The site location is abutted by Dhaleshwari River on its immediate south. Surface water from Dhaleshwari River was collected on 7th August, 2016 for the analysis of basic surface water parameters. The test was conducted by experts from MIST. The rationale was to understand the present baseline concentrations of some parameters. The reported concentrations of the parameters are tabulated in the table below. Refer Annexure D for the Surface Qater Quality Assessment Report from MIST.

Table 29: Surface Water Quality Assessment of Dhaleshwari River, 2016 Parameters Units Bangladesh Reported Standards for Concentration Inland Surface Water (ECR, 1997) pH - 6-9 6.96 TDS mg/L 2100 285 DO mg/L 4.5-8 2.08 EC µS/cm 1200 591 TSS mg/L 150 86 BOD5 mg/L 50 2.16 COD mg/L 200 21 Iron (Fe) mg/L 2 0.12 Ammonia mg/L 50 0.73 Cadmium (Cd) mg/L 0.05 0.0009 Chromium (Cr) mg/L 0.5 0.0011 Lead (Pb) mg/L 0.1 0.0018 Total Coliform Cfu/100ml NA >150 Faecal Coliform Cfu/100ml NA 03

None of the reported concentration of the specific parameters were found to exceed the standard Inland Surface Water concentration.

Secondary data for the surface water quality was also provided by Department of Environment, Bangladesh. DoE, Bangladesh undertake monthly monitoring cycle of the river water qualities at 2 locations along the river viz. Muktarpur Ghat and Horindhora. Table below tabulates the water quality parameters, month wise of the year 2014. Figure 16 shows monthly variation in pH, DO, BOD, COD, TDS and Chloride in Dholeshwari River samples, monitored by DoE, Bangladesh in the year 2014.

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Table 30: Water Quality Parameters of Dholeswari River, 2014 (by DoE)

Sampling Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Locations pH Muktarpur Ghar - - - - - 7.19 - - - 7.16 7.35 Horindhora 7.72 - 7.65 7.65 - - 7.20 7.43 - 6.91 - ECR, 1997 8.5 8.5 8.5 8.5 8.5 8.5 8.5 8.5 8.5 8.5 8.5 8.5 DO (PPM)) Muktarpur Ghar 3.5 1.1 0.3 Horindhora 4.3 4.3 6.2 4.1 4.1 ECR, 1997 5 5 5 5 5 5 5 5 5 5 5 5 BOD (PPM) Muktarpur Ghar 17.8 3.5 21 Horindhora 0 16 16 8.8 0 6 ECR, 1997 6 6 6 6 6 6 6 6 6 6 6 6 COD (PPM) Muktarpur Ghar 75 33 230 Horindhora 39 39 25 12 ECR, 1997 200 200 200 200 200 200 200 200 200 200 200 200 TDS (PPM) Muktarpur Ghar 87.3 198.1 287 Horindhora 635 635 71.9 79.7 163.1 ECR, 1997 2100 2100 2100 2100 2100 2100 2100 2100 2100 2100 2100 2100 Chloride (PPM) Muktarpur Ghar 11 4.4 19 Horindhora 21 21 6 5 4.2 ECR, 1997 600 600 600 600 600 600 600 600 600 600 600 600 Suspended Solids (PPM) Muktarpur Ghar 15.7 28 18 Horindhora 9 9 8 14 20 ECR, 1997 150 150 150 150 150 150 150 150 150 150 150 150 EC (µS/cm) Muktarpur Ghar 185.3 401 552 Horindhora 1304 1304 149.4 174.9 353 ECR, 1997 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 1200 Total Alkalinity (PPM) Muktarpur Ghar 14 28 208 Horindhora 75 80 80 17 14 30 ECR, 1997 150 150 150 150 150 150 150 150 150 150 150 150

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

 pH value of Dholeswari River at all locations was within the standards for inland surface waters (6.5- 8.5) for the reported period.  DO was below standard (5 mg/L) at all locations, except at Horindhora (approximately 40 km from proposed site) in July.  BOD was found to exceed the standard (6 mg/L for fisheries) during monsoons (July) at both the sampling locations and winters (December) at Muktarpur Ghat. BOD was reported to be 17.8 mg/L and 8.8 mg/L in the month of July for both the sampling locations and it was reported to be 21 mg/L in the month of December at Muktarpur Ghat.  COD was found to exceed in only one sample collected from Muktarpur Ghat in the month of December (ECR, 1997 standard: 200 mg/L).  TDS varied from 71.9 to 635 mg/L with the lowest during the monsoons and maximum during the summers, as against the standard (2100 mg/L for wastewater after treatment). High TDS could be attributed because of the extensive dredging process found to happen within the river and the shorelines of the river.

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 Concentration of Suspended Solids was found to be below the standard limits prescribed by ECR, 1997 (150 mg/L).  Electrical Conductivity (EC) was also found to be much below the prescribed standard for comparison. (1200µS/cm).  Concentrations of Alkalinity was found to exceed at Muktarpur Ghat during winters as against the standard prescribed as 150 mg/L.

5.2.6.2 Ground water Quality

On-site analysis of groundwater for specific parameters was conducted for establishing the baseline standards of the groundwater. DoE, Bangladesh, Dhaka unit, undertook the analysis of the groundwater sample collected from a hand pump located at the western side of the proposed EZ site. Table below tabulates the analytical results with their corresponding standards as reported in the ECR, 1997. Refer Annexure A for the reported results from DoE, Bangladesh. Refer Annexure A for the Groundwater Quality Assessment Report from DoE.

Table 31: Quality of ground water samples collected from the proposed Dhaka SEZ site, 2016

Parameter Unit Result Bangladesh Standard as per ECR 1997 1. pH 6.82 6.5-8.5 2. TS mg/l 285 - 3. EC µS/cm 453 - 4. Fe mg/l 0.3 0.3-1.0 5. DO mg/l 1.4 6 6. BOD mg/L ND 0.2 7. COD mg/L ND 4.0 8. Oil and Grease mg/L ND 0.01

The reported analytical result from DoE mentions that all the analysed parameters were found to be below their respective standards. Paramaters like Electrical Conductivity (EC) and Total Solids (TS) doesn’t have available standards under ECR, 1997 Drinking Water Standards (Schedule 3b). The reported analytical result suggests that at present the groundwater is not impacted. The water apparently is being used by the local residential people for drinking and for other domestic purposes. 5.2.7 Traffic Survey

The construction and operation of EZ will involve transportation of materials. The proposed site is located near the Dholeshwari River. Dholeshwari River is extensively used for goods and human transportation. Fishing activities are carried out extensively.

Based on the anecdotal informations, queries while undertaking interviews reveals that the Sitalakhya River is being extensively used for human transporations and transportation of fishes. The river connects major towns and hence people prefer to use mechanised boats and steemers to travel from one point of Bangladesh to another along the waterway. Since, the river especially along the EZ proposed site doesn’t have establishment of any major industries, transportations of heavy goods, oil, cement, machinery etc doesn’t happen much. 5.2.8 Agricultural Resources

The proposed aite area is being extensively used for agriculture purposes. The project site consists of a total of 105 acres of land. Out of that, 40 acres is Khas land remaining 65 acres is privately owned land.

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The land use is majorly agriculture practised within the project site. Potato, Sweet Potato, Pui Shak, Lal Shak are the major vegetables being cultivated within the project area. Agriculture serves as the main source of livelihood for the private land owners.

5.2.9 Livestock and poultry

There is no livestock and poultry at the proposed site location. 5.2.10 Fisheries

Fishing or practice of pisciculture are not being practiced within the projet area. 5.2.11 Ecological Resources

The flora fauna information provided in this section is collected through literature. Bio-ecologically Keraniganj under Dhaka Division (proposed project’s sub-project site) falls under the Brahmaputra- Jamuna Floodplain (IUCN Bangladesh, 2002). On the other hand, agro-ecologically the area falls under the Young Brahmaputra-Jamuna Floodplain (BARC/UNDP/ FAO, 1995). The non-calcareous gray / dark gray floodplain soil provide suitable environment for growing various types of floral species, and also provide supportive habitat for various types of fauna including varieties of fish species. General ecological features of the sub-project site of the proposed project are given below: 5.2.11.1 Terrestrial Ecology

It has two major component namely terrestrial fauna (mammal. bird, reptile and amphibia) and terrestrial flora (tree, herb and shrub). Both components are generally distributed in a site as per its carrying capacity and most of them are distributed in and around the semi-urban homesteads, fallow lands, along the road, market and building sites, in open areas, and besides water bodies (pond, canals, rivers) of the study area.

Terrestrial Fauna: Faunal species require both terrestrial and aquatic environment. Terrestrial environment dependent fauna are referred to as terrestrial fauna, and aquatic environment dependent fauna are referred to as aquatic fauna. The study site has both terrestrial and aquatic environment that supports various species of terrestrial and aquatic fauna. Most of the terrestrial faunal species found here are fairly common (see Fig. 4.44) in comparison to other plain districts of Bangladesh. Faunal species that are adapted in altered semi urban habitat are commonly seen in the study sites. The common terrestrial faunal species are:

Amphibian: Common Toad – Bufo melanostictus, Cricket Frog - L. limnocharis, M. Tree Frog - P. maculates,Bull Frog - H. tigerinus.

Reptile: C. House Lizard - Hemidactylus flaviviridis, C. House Lizard – Hemidactylus frenatus, G. Monitor Lizard - V. bengalensis, C. Garden Lizard - Calotes versicolor, C. Wolf Snake – Lycodon aulicus, Rat Snake - Coluber mucosus, C. Vine Snake -Ahaetulla nasutus,

Bird: C. Tailorbird - O. sutorius, O. Magpie Robin - Copsychus saularis, Rufous Tree Pie - D. vagabunda, Rock Pigeon - Columba livia, Common Myna – Acridotheres tristis, Brahminy Kite – Haliastur indus,W- throated Fantail - Rhipidura albicollis. Black Drongo - D. macrocercus, Jungle Crow - C. macrorhynchus, House Crow- Corvus splendens, Asian Palm Swift - Cypriirus parvus, Paddy field Pipit - Anthus rufulus, Indian Cuckoo - C. micropterus, Red-vented Bulbul - Pycnonotus cafer, Spotted Dove - S. chinensis, House Sparrow - Passer domisticus, A. Pied Starling - Sturnus contra, W. T. Kingfisher - Halcyon smyrnensis, B-H Oriole - Oriolus xanthornus, B. H. Shrike - Lanius schach.

Mammal: Jackal – Vulpes bengalensis, Small Indian Mongoose - H. auropunctatus, House Mouse - Mus musculus, Indian Pipistrelle - P. coromandra, Indian Field Mouse - Mus booduga, Indian mole Rat - B.

88 EIA Report- Dhaka SEZ bengalensis, Bandicoot Rat - Bandicota indica, Grey Musk Shrew - Suncus murinus, Fulvous Fruit Bat - Rousettus leschenaultia, Flying Fox - Pteropus gigantius.

Terrestrial Flora: Flora can grow naturally or artificially in terrestrial and aquatic environment, if the natural conditions are favorable. Common natural vegetation (terrestrial and aquatic) grows naturally in plenty in the rainy season. Most of the flora, particularly the trees, are planted in the study site for economic purposes by the local inhabitants and are fairly common, and distributed in scattered way, and have similarity in comparison to other plain districts of Bangladesh. The study site has vast low land where aquatic flora grows in plenty in the rainy season. Some important plant species were observed in the surveyed areas like medicinal plant e.g. Chatim - Alstonia scholaris, part of which is generally used as a traditional medicine. The existing terrestrial floral diversity makes a complex ecosystem in which some wildlife has direct relationship through their ecological niche.

Tree: Jackfruit - Artocarpus heterophylla, Rain tree/Rendi - Samanea saman, Mango - Mangifera indica, Mehagini - Swietenia mahagoni, Banyan tree - Ficus religiosa, Teak/Segun – Tectona grandis, Boroi/Kul – Zizyphus mauritiana, B. heart/Sharifa - Annona reticulate, Coconut - Cocos nucifera, Eucalyptus - Eucalyptus citriodora, Krishnachura - Delomix regia, Banana - Musa sapientum, Kamranga - Averrhoa carambala, Kadam - Anthocephalus chinensis, Tamarind - Tamarindus indica, Bamboo – Bambusa sp., Date palm /Khejur - Phoenix sylvestris, Tal/Palm - Borassus fiabellifer, Betel nut/Supari - Areca catechu, , etc.

Herb and Shrub: Natural floral species (herb and shrub) primarily includes: Danda Kalash – Leucus aspera, Assamlata - Mikania scandens, Bhant - Clerodendrum viscosum, Hatisur - Heliotropium indicum, Dholkalmi - Ipomoea fistulosa, Sheyalmutra - Blumea lacera, Telakucha - Coccinia indica, Reri/Venna - Ricinus communis, Durbaghas – Cynodon dactylon, Kash - Saccharum officinarum, Shongrass/Patila - Phragmites sp., Thankuni - Mimosa invisa, Lazzaboti - Mimosa pudica, Bishkatali - Polygonum hydropiper, Fern - Drynaria quercifolia, Kantanotey - Amaranthus spinosus,etc. 5.2.11.2 Aquatic Ecology

It has also two major components, namely aquatic fauna (mammal. bird, reptile and amphibia) and aquatic flora (tree, herb and shrub). Both components are inter- and intra-liked and create a harmonic environment where both floral and faunal species get benefits from each other.

Aquatic Fauna: The study site has vast low land that act as a seasonal wetland during monsoon and support varieties of aquatic fauna. Some aquatic fauna used these vast lands as their temporary habitat, while others as permanent habitat. In the rainy season, the native fish species breed here in plenty. The common aquatic faunal species are:

Amphibian: Skipper frog – Euphlyctis cyanophlyctis.

Reptile: Common Skink - Mabuya carinata, Indian Roofed Turtle - Kachuga tecta, Checkered Keelback - Xenochrophis piscator, C. S. Water Snake - Enhydris enhydris, Olive Keelback - Atretium schistosum. Bird: Great Egret - Egretta alba, Small Egret – Egretta gazetta, Intermediate Egret – Egretta intermedia, W-breasted Waterhen - Amaurornis phoenicurus, B. Winged Jacana - Metopidius indicus, Indian Pond heron - Ardeola grayii, Little Cormorant - Phalacrocorax niger, Snipe - Gallinago henura, Common Kingfisher - Alcado athis.

Mammal: No mammal

Fish: One-stripe Spinyeel - Macrognathus aculeatus, Swamp Barb - Puntiuschola, Rosy Barb - Puntius conchonius, Indian Carplet - A. microlepis, Magur – Clarius batrachus, Stinging Catfish - Heteropneustes fossilis, Rohu - Labeo rohita, Catla - Catla catla, Mrigal - Cirrhinus mrigala, L-whiskered Catfish - Aorichthys aor, Freshwayer Shark – Wallago attu, Paddy Eel - Pisodonophis boro, Gery Fetherback - Notopterus notopterus, Humped Fetherback - Notopterus chitala, Asiatic Snakehead - Channa orientalis,

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Spotted Snakehead -Channa punctatus, Striped Snakehead - Channa striatus, Giant Snakehead - Channamarulius, Tank Goby - Glossogobius giuris, Bumblebee Goby - Brachygobius nunas, Climbing Perch - Anabas testudineus, Gangetic Mystus - Mystus cavasius, Tengra Mystus - Mystus tengara, Mottled Nandus - Nandus nandus, Gangetic Mudeel - Monopterus cuchia, Indian Threadfish - Polydactylus indicus.

Aquatic Flora: Due to the vast amount of low land, the study site has various types of aquatic flora (tree, herb and shrub), most of which are distributed in and around the water bodies (pond, canal, river, ditch etc). In rainy season, the aquatic flora get favorable condition that helps them to grow in plenty, Aquatic flora plays an important role for biodiversity conservation. Aquatic flora grow in rivers, ponds, canals, ditches and low lying cultivated fields as submerge, free-floating and rooted floating states. The common aquatic floral species are:

Tree: Barun/Banny - Crataeva nurvala, Keshordam – Ludwigia adscendense,

Herb and Shrub: Pitali–Trewia nudiflora, Koroj - Pongamia pinnata, Kalmi - Ipomoea aquatica, Jhanjhi - Ceratophyllum dumersum, Water Lily/Sada Shapla - Nymphaea nouchali, Phutki/Janglidhan - Hygroryza aristata, Patajhangi - Vallisneria spiralis, Jhangi - Utricularia aurea, Floating Grass – Echinoclo acolonum, Water Chestnut – Trapabi spinosa, Spiral Algae - Spirogyra sp., Ghenchu - Aponogeton natans, Janjhi/Kurcli - Hydrilla verticillata, Water Hyacinth/ Kachuripana - Eichhornia crassipes, Indurkanipana - Salvinia cuculata, Topa pana - Pistia strateotes, Khudipana - Lemna perpusilla, etc. 5.2.12 Socio-economic Conditions

The key parameters that are required to establish a baseline socio-economic profile of population within the project’s area of influence include gender, ethnicity, social structure, employment patterns, sources of income, local tenure and property rights arrangements, use of community and natural resources. Primary information gathered by undertaking the screening survey, individual consultations and other stakeholder interaction and secondary information sourced from published references has been analyzed to establish the socio-economic baseline. 5.2.12.1 Project Area

The project area of influence comprises of the Project affected persons who constitutes the direct impact area, Keraniganj Upazilla and Sirajdikhan Upazilla. The social fabric of the project affected persons indicate the proximity with the Sirajdikhan Upazilla which abuts the Sonakanda mouza. Thus it was pragmatic to consider the Sirajdikhan Upazilla also under the project area of influence. The figure below highlights the project site and the project area of influence.

Figure 43. Project Area and Project Area of Influence, Dhaka SEZ

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5.2.12.2 Socio-Economic profile of Bandar Upazilla

Keraniganj is an Upazila located in Dhaka district. The town Keraniganj is located on the southwest of Dhakacity onthe bankof Buriganga River. It islocatedbetween the parallels of 23degreesand 41 minutes latitudes and meridians of 90 degrees and 20 minutes longitudes. The district is abutted by two rivers vis- à-vis Buriganga and Dhaleshwari River. The district covers a total area of 166.87 square kms. Keraniganj is the largest upazila in Dhaka district in respect to population. It came into existence in 1817. Keraniganj accounts for about 11.4% of the total area of Bangladesh. The below figure depicts the layout map of the Keraniganj.

Figure 44: Layout Map of Keraniganj Upazila

The project area comprises of the Keraniganj Upazilla and the Sonakdanda Mouza where the project is proposed to be developed. The Socio-Economic profile of Keraniganj is represented in the below table:

Table 32: Socio-Economic Profile of Keraniganj Upazila

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Indicators Quantity Area (Sq. km) 166.87 Union/Wards (No.) 12 Mouzas/Mahallas (No.) 123 Villages (No.) 423 Households (No.) 77,970 Population (No.) 7,94,360 Population density (per Sq. Km) 5000 Male (%) 53.1 Female (%) 46.9 Sex Ratio (Females/ 1000 males) 883 Number of Child Birth (No.) 20,635 Literacy (7+) Overall (%) 58.5 Males (%) 60.8 Females (%) 56 Religious Institutions Mosques 585 Temples 96 Source: District Statistics, Dhaka Zila, 2011

The source of livelihood indicators of Bandar Upazila are provided in table below.

Table 33: Source of Livelihood Profile of Keraniganj Upazila

Indicators Quantity Source of Livelihood (in %) Agriculture 10.37 Agricultural Labors 7.05 Wage Labors 5.63 Commerce 26.26 Service 17.68 Construction 3.1 Fishery 1.02 Industry 1.78 Hawkers 1.07 Transport 7.38 House Renting 1.23 Others 17.43

Source: Community Report, Dhaka Zila, June 2012 The demographic profile of Unions under Keraniganj Upazila are provided in table below.

Table 34: Demographic profile of the Unions under Keraniganj Upazila

Union Area in Households Population Sex Sex Ratio Acres Total Male Female (Male/Female)*100

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Aganagar 369 15,547 73,012 44,927 28,085 160 Basta 4,915 7,150 34,181 16,886 17,295 98 Hazratpur 4,161 7,488 33,069 16,320 16,749 97 Kalakatia 4,297 9016 40,007 19,261 20,746 93 Kalindi 1,677 10,251 46,783 24,467 22,316 110 Konda 6,270 13,887 67,204 34,821 32,383 108 Rohitpur 3,730 7,172 31,563 15,645 15,918 98 Sakta 4,051 12,828 58,075 15,645 15,918 107 Subhadya 2,563 52,587 2,25,865 1,22,612 1,03,253 119 Taranagar 4,295 9,465 42,203 21,441 20,762 103 Tegharia 4,330 7,189 32,416 16,766 15,650 107 Zinjira 433 25,490 1,09,982 58,635 51,347 114 Source: Bangladesh Bureau of Statistics, Census 2011

The literacy rates in all the 12 unions in the Keraniganj upazila, sourced from the Bangladesh Bureau of Statistics are provided in table below.

Table 35: Demographic profile of the Unions under Keraniganj Upazila

Name of Area (Acres) Populations Literacy Rate (%) the Union Male Female Male Female Aganagar 369 44,927 28,085 66.3 59.6 Kalatia 4,297 19,261 20,746 62.2 59.5 Kalindi 1,677 24,467 22,316 65.8 60.5 Konda 6,270 34,821 32,383 55.1 51.9 Zinjira 433 58,635 51,347 63.0 58.9 Taranagar 4,295 21,441 20,762 61.7 55.3 Tegharia 4,330 16,766 15,650 57.2 50.2 Basta 4,915 16,886 17,295 59.1 55.6 Rohitpur 3,730 15,645 15,918 56.6 53.1 Subhadya 2,563 1,22,612 1,03,253 60.1 56.1 Sakta 4,051 15,645 15,918 63.3 58.3 Hazratpur 4,161 16,320 16,749 47.7 43.7 Source: Bangladesh Bureau of Statistics, Census 2011 5.2.12.3 Socio-Economic Profile of Sirajdikhan Upazilla

The socio-economic profile of Sirajdikhan Upazilla is detailed below. Sirajdikhan Upazilla is a part of the Munshiganj district. Sirajdikhan Upazila of Munshiganj district lies at the immediate southeast of Keraniganj upazila Sirajdikhan Upazilla consists of 14 unions. Refer the below figurefor the map of Sonargaon Upazilla.

Figure 45: Sirajdikhan Upazilla Map

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The Socio-Economic profile of Sirajdikhan Upazila is represented in the below table.

Table 36: Socio-Economic Profile of SirajdikhanUpazila

Indicators Quantity Area (sq. Kms) 180.19 Union/Wards (No.) 14 Mouzas/Mahallas (No.) 119 Villages (No.) 178 Households (No.) 59,470 Population (No.) 2,88,107 Population density (per Sq. Km) 1599 Male (%) 49.82 Female (%) 50.17 Sex Ratio (Females/ 100 males) 93 Number of Child Birth (No.) 20,635 Literacy (7+) Overall (%) 54.9 Males (%) 54.9 Females (%) 54.9 Religious Institutions Mosques 166 Temples 22 Mazar 2 Dargah 1 Source: Population and Housing Census, Munshiganj Zila, 2011

The source of livelihood profile for SirajdikhanUpazila is provided in table below.

Table 37: Source of Livelihood Profile of Sirajdikhan Upazila

Indicators Quantity

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Source of Livelihood (in %) Agriculture 28.72 Fishing 1.89 Agricultural Labors 27.46 Wage Labors 2.05 Industry 1.55 Commerce 13.7 Service 8.86 Loom 1.51 Construction 2.53 Others 11.73 Source: Community Report, Munshiganj Zila, June 2011

The demographic profile of the unions under Sirajdikhan Upazila is provided in table below.

Table 38: Demographic profile of the Unions under Sirajdikhan Upazila

Union Area Households Population Sex Sex Ratio in Acres Total Male Female (Male/Female)*100 Balur Char 5,763 8548 73,012 24,967 22,018 99 Basail 4,160 4,964 34,181 12,368 12,431 99 Bayaragadi 2,516 2,638 11,921 5,833 6,088 96 Chitrakot 3,845 2,986 14,365 6,826 7,539 91 Icchapur 2,411 4,882 22,432 11,133 11,299 99 Jainsar 3,195 3,431 16,225 8,056 8,169 99 Kayain 4,303 5,565 25,283 12,414 12,869 96 Kola 1,757 2,014 9,507 4,669 4,838 97 Latabdi 3,910 4,311 21,878 10,735 11,143 96 Madhyapara 2,055 3,206 14,363 7,111 7,252 98 Malkhanagar 1,319 3,609 16,600 8,209 8,391 98 Rajanagar 3,411 4,702 22,034 10,979 11,055 99 Rasunia 3,143 4,916 22,258 11,066 11,192 99 Sekharnagar 2,729 4,101 19,457 9,193 10,264 90 Source: Bangladesh Bureau of Statistics, Census 2011

The literacy rates in Sirajdikhan upazila are provided in table below.

Table 39: Literacy Rates Segregated by Unions in Sirajdikhan Upazila

Name of Area (Acres) Populations Literacy Rate (%) the Union Male Female Male Female Balur Char 5,763 24,967 22,018 38.0 41.0 Basail 4,160 12,368 12,431 57.2 57.3 Bayaragadi 2,516 5,833 6,088 55.2 55.2 Chitrakot 3,845 6,826 7,539 70.3 64.1 Icchapur 2,411 11,133 11,299 57.0 57.1 Jainsar 3,195 8,056 8,169 57.9 55.3 Kayain 4,303 12,414 12,869 66.7 63.7 Kola 1,757 4,669 4,838 52.3 53.9 Latabdi 3,910 10,735 11,143 48.0 46.9

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Madhyapara 2,055 7,111 7,252 50.8 50.0 Malkhanagar 1,319 8,209 8,391 56.4 55.4 Rajanagar 3,411 10,979 11,055 62.7 58.7 Rasunia 3,143 11,066 11,192 56.1 57.2 Sekharnagar 2,729 9,193 10,264 64.8 64.4 Source: Bangladesh Bureau of Statistics, Census 2011 5.2.12.4 Socio-economic profile of Direct Impact Zone

To better understand the socio-economic environment of the project affected persons within the project’s area of influence, a detailed survey was undertaken from 12th to 20th April 2016. The team surveyed a total of 327 PAP’s. The proposed area demarcated for the EZ development along with the settlements in the nearby vicinity is construed as the project area of influence. The land use of the area demarcated for the EZ is predominantly agriculture which is also evident from the crop cultivation practices being followed in the region. The EZ site constitutes 65 acres of privately owned lands. The 108 land owners and their family members are categorized are the Project Affected Persons (PAP’s) from the acquisition of the privately owned land parcels. The daghs and the private land owners information has been sourced from the Rohitpur local Union office. Apart from the privately owned agricultural land, there are also 3 homesteads which form a part of the PAH’s. Apparently, the project site doesn’t have any CPRs.

Demographic Characteristics

Demographic characteristics are obtained for the people whose house or privately owned land is impacted because of proposed EZ development. The demographic data as tabulated in table below indicate that the females constitutes 45% of the total project affected landowners populations while the males constituted 65%. Table 40: Demographic Data

S. No. Scenario No. of PAPs No. of PAPs Sex Average PAH‘s* (%) Total Male Female Ratio* Household Size 1 Project 42 100 327 177 150 847 8 Affected Persons Total 38 100 327 177 150 847 8 Source: Census survey March-April 2016

Below table shows the age wise distribution of the PAPs that were surveyed. Most of the affected people were found to be within the age bracket of 18-30 which constituted 31.8% of the total affected PAPs. Considering the age group ranging from 18-40 as the youth age bracket, a total of 171 within that age bracket were found to be impacted. So 52% of the total affected people are in the age group of 18-40 which is considered as the youth bracket age group.

Table 41: PAPs categorized based on their age

Age Group Number of PAPs Percentage of the total PAPs (%) 14-17 27 8.25 18-30 104 31.80 31-40 67 20.48 41-60 101 30.88 61 and above 28 8.56 TOTAL 327 100 Source: Census survey March-April 2016

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

Figure 46: Age wise PAP distribution

9% 8% 14-17 18-30 31% 32% 31-40 41-60 20% 61 and above

Religion

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

Literacy Level

Of the total affected population, 26% have achieved secondary level of education where as 14% of the population has achieved primary level of education. Illiterate populations comprise of 17% of the total PAPs. A mere 3% of the PAPs are technically qualified (graduates and masters). The low education levels emphasize the need for stress on technical education and skill enhancement programmes in the region. Below table illustrates the literacy level percentage.

Table 42: Literacy level of PAPs

S. No Literacy Level of Number percentage Number of Percentage PAPs Males Females 1 Illiterate 29 8.86 28 8.56 2 Can read and write 44 13.45 49 14.98

3 Primary Schooling 24 7.33 21 6.42 (class 1-5) 4 Class 6th to 8th 21 6.42 20 6.11

5 Class 9th to 10th 16 4.89 17 5.19

6 SSC/HSC 35 10.70 14 4.28 Equivalent 7 Graduate and 7 2.14 1 0.30 Equivalent 8 Masters and 1 0.30 0 0.0 Equivalent Total 177 54.12 150 45.87 Source: Census survey March-April 2016

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

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Figure 47: Literacy Level of the surveyed PAPs

Illiterate

Can read and write 2%0% 15% 17% Primary Schooling (class 1-5) 10% Class 6th to 8th

29% 13% Class 9th to 10th 14% SSC/HSC Equivalent

Graduate and Equivalent

Health Status

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

Table 43: Health Status of affected households

S. No Health Status of PAHs Number %

1 Illness 17 41.46

2 No Illness 24 58.53

Total 75 100 Source: Census survey April 2016

As per the findings of the social survey a total of 2 major Health care facilities equipped with better diagnostic tools are available at Rohitpur Union. Details of availability of health facilities as per census survey of April 2016 are mentioned in below table.

Table 44: Availability of Health Facilities at Keraniganj Upazila

S. No Health Facilities Number

1 Private Clinic 1

2 Private Hospital 1

Total 2

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

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Table 45: Employment Status of PAPs

S. No Employment Number Percentage Number of Percentage Status/Occupation of Males Females 1 Wage Labour 1 0.305 0 0.0 2 Factory Worker 19 5.81 10 3.05 3 Farmer 53 16.20 4 1.22 4 Government Service 5 1.52 0 0.0 5 Carpenter 3 0.917 0 0.0 7 Unemployed 48 14.67 133 40.67 8 Migrant Worker 40 12.23 0 0.0 (Abroad) 10 Student 3 0.91 0 0.0 11 Old Person 4 1.22 3 0.91 12 Teacher 1 0.305 0 0.0 Total 177 54.12 150 45.87 Source: Census survey March-April 2016

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

Figure 48: Employment status of PAPs

Wage Labour Factory Worker Farmer 1%2%0%0% 9% 17% Government Service 12% Carpenter 2%1% Housewife Unemployed 21% Migrant Worker (Abroad) 35% Factory Worker Student Old Person Teacher

Gender assessment

Women in the region primarily are involved in household work, cultivation and other agriculture activities. They are also involved in decision making involving decisions like education of children, decisions before social functions etc.

However, data collected from household survey reveals lower participation of women in financial decisions which indicate the need for the women empowerment in the region.

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Inference

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

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6 Identification and Analysis of Key Environmental Issues

6.1 Environmental Sensitivity Investigation

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

Environmental assets identified in the study area are listed below: 1. Air Quality of the area 2. Noise level of the area 3. Water Quality of the area 4. Transportation system of the area 5. Ecosystem of study area Identified environmental assets of the project are likely to be impacted due to development of the off-site facilities at all the pre-construction, construction and operation stages of the project. Project activities which may have an impact on the environmental assets and the associated impacts are listed below. The detailed impact identification and mitigation measures are given at Chapter 7. Table 46: Environmental Assets of the project area

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

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

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

6.3 Environmental Hotspot

The project area is abutting Dhaleshwari River. There are no ecological hot spots within and around the subject site. The site doesn’t have any forest, ecologically sensitive zone around it. 6.4 Likely Beneficial Impacts

The project involves development of EZ and off-site facilities. It is proposed to develop RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, non processing area, Educational Institutions, Training Institution at the proposed EZ. The likely benefits from the proposed development are listed as below: 1. Rapid Economic development 2. Large scale direct and indirect employment generation 3. Development of infrastructure facilities 4. Technological enhancement for management of environmental management ( like water treatment, waste management, environmental monitoring ) 5. Permanent source of employment, fixed monthly income; 6. Better living standards

6.5 Community Recommendations and Alternative Analysis

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

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7. Impacts Assessment

7.1 Introduction

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

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

Table 47: Classification of Social and Environmental Components

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

7.2 Impact Identification

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

Table 48: Impact Matrix for Proposed Off-site Infrastructure

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

i Land Acquisition for  Displacement of  access road people

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 Change in land use  pattern of existing agricultural land  Impact on livelihood 

ii Site Preparation Removal of Vegetation.  Loss of tree cover and Impact on aesthetic  aspects B Construction Phase i Development of EZ and Loss of Top soil  Construction of Soil contamination due  Boundary wall, Access to spillage of material Road, bridge, electrical Surface water  & water supply system contamination and administration Air pollution  building Noise pollution  Increase in traffic  Un pleasant view  Impact on Health &  safety Social impact  

C Operational Phase i Development of Off-site Impact on the ambient  Infrastructure, i.e. Air Quality Boundary wall, access Noise Pollution  road, water supply Potential for surface  system, electrical supply water pollution due to line and administration waste discharge building and operation Economic Development  of industries Accessibility  Groundwater depletion  Rainwater harvesting  Potential for land  contamination due to industrial activities Improved drainage  Electrification of the  area Improved health and  sanitation facilities Increased Run-off  Generation of  Employment Natural drainage pattern  ii Green Buffer  Improved Ecology  development around  Air Quality  each industrial plot Improvement  Aesthetics 

7.3 Impact on Air Environment 7.3.1 Pre-construction Phase

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

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

7.3.2 Construction Phase

The proposed project involves construction activities which includes:

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

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

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

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

Mitigation Measures to be implemented are:

To mitigate the construction impacts, BEZA should have contract agreements with contractors as well as sub-contractors to implement the measures provided in EMP.  Sprinkling of water at construction site and haul roads  Construction of barricades between the settlements and the site to minimize travel of fugitive emissions towards settlements  Tree Plantation on the either side of the approach road to mitigate the fugitive dust emissions  Minimizing stockpiling by coordinating excavations, spreading, re-grading, compaction and importation activities  Cease or phase-down work if excess fugitive dust is observed, investigate source and take suppression measures such as water spray  Proper maintenance of engines and use of vehicles  Adequate parking space should be provided for the construction vehicles so as to prevent idling of the vehicles and the emissions generating from them  Vehicles carrying construction material and debris should be covered with tarpaulin cover  Raw materials, excavated soil and other debris should be stored under covered sheds  Green buffer should be developed all along the EZ boundary  Provision of face mask to workers to minimize inhalation of dust particles  Construction vehicles and machinery should be regularly serviced and check for pollution control  Low sulphur diesel should be used for running construction equipment and vehicles  Covering the scaffolding (in case of administration building) to reduce the dust emission in outside environment

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 Speed of vehicles on site is recommended to be 10-15 km/hr which will help in minimizing fugitive dust emissions due to vehicular movement  Vehicles should be checked regularly for PUC as per DoE standards  During transportation of materials and equipments by waterway, low sulfur fuel should be used. The boat should not be kept idle and be implemented with latest emissions control technologies.  During loading and unloading of material and equipment at the ship, the engine should be switched off.

7.3.3Operation Phase

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

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

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

The major air pollutants generated from textile mills include Suspended Particulate Matter (SPM), sulphur dioxide gas, oxide of nitrogen gas, etc. The hydrocarbons are emitted from drying ovens and from mineral oils in high-temperature drying/curing. The residues from fibre preparation also emit pollutants during heat setting processes. Carriers and solvents may be em itted during dyeing operations depending on the types of dyeing processes used and from wastewater treatment plant operations. Carriers used in batch dyeing of disperse dyes may lead to volatilisation of aqueous chemical emulsions during heat setting, drying, or curing stages. Inhalation of the dust generated where cotton fibre is converted into yarn and fabric significantly contributes to byssinosis (an occupational lung disease). So, periodic checkups shall be done for the workers. Rotating of workers shall be done to reduce exposure levels.

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

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

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Mitigation Measures

 Provision should be made for peripheral green belt all along the EZ boundary. Green belt should have minimum of three rows of local variety of tree. Tree species should be selected such that first inside row is of smaller height, middle row of tree is of medium height and last row of tree is of higher height so that green belt formed appears like a canopy.  Development of thick green belt (10 m) and organized greens within each industrial plots  Power Generators should be provided with stacks of adequate height ((calculated by H = h+ 0.2 * Sqrt(kVA) where h = height of building where generator set is installed and kVA is total generator capacity)) to allow enough dispersion of emission. High power generating generators and DG sets shall be provided with electrostatic precipitator or scrubber within the stack to adsorb the unburnt hydrocarbons before the fumes are released to the environment  The industries should obtain clearance from DoE, Bangladesh as applicable. Air pollution control measures shall be adopted by respective industries in line with DOE permission  Air pollution monitoring should be carried out quarterly by all industries to check the air pollution level.  Preference of usage of clean fuel like LPG, low sulphur diesel should be explored for use within the EZ  Energy conservation should be adopted by opting the alternate energy options like solar power  Carbon emissions shall be minimized by adopting adequate measures  Odour should be managed at the site using odour suppressant and planting fragnant flowering trees.  Mechanized boats which shall be used for transportation of goods and people shall be operated with fuel low in sulphur content.

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

Pre-construction phase will involve site clearance activity for development of access road and utilities. The site clearance will involve removal of vegetation and land levelling activities. Operation of different machineries and equipments for construction activities, running of heavy load traffic for construction materials transportation, and regular traffic movement may generate noise during construction period. The heavy equipment, machineries, transportation and earthworks used for the construction activities are the major sources of noise. It is envisaged that there will be an increase in traffic and thereby in traffic noise impacts on the receptors near the approach road from the transportation of equipment, construction materials. As detailed in the earlier sections, the residents in the vicinity of the site would be impacted due to the noise emissions. The impact of noise generation on the settlements could be significant as the nearby settlement is within 2 km from the site area. It is anticipated that in an RMG, Integrated Textile, Pharmaceuticals, Light Engineering Warehouse, Plastic Industry, Printing and Packaging Factory, Commercial Area, Non processing area, Educational Institutions, Training Institution there wouldn’t be much units from where heavy noise could be anticipated. Noise from generators, water and booster pumps could be the sources for noise generation. All the generators shall be equipped with acoustics covers which shall mitigate the noise. Operational and booster pumps shall be maintained periodically and shall be kept in an isolotaed room to minimize the noise generation from them. Table below shows the typical noise levels generated by some of the construction equipment expected to be used during the construction phase. As seen from the below table, the local peak noise level for non-continuous construction activity may reach to as high as 96 dB(A), depending on the type of equipment. The impact, however, is expected to be temporary and localised.

Table 49: Noise levels generated by construction equipments (measured at 1 m distance)

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

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

Mitigation Measures

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

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

To deal with noise exposure by construction workers in construction site, pocket guide by OSHA is helpful.

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

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

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

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

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

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

Mitigation Measures

 Pumps should be fitted in close room, preferably acoustic enclosure to reduce the noise generation  Green buffer of 10 m should be developed all along the project boundary. Green buffer should compose of the 2-3 rows of plants of variable height and thick canopy so as to form continuous barrier. This will help in reducing the noise level significantly.  Noise regulators must put a strong mandate and fine on vehicle operators which are not properly maintained, produce noise (silencers not proper).  All industries should obtain clearance from DoE before establishing industrial unit and should comply with all the conditions mentioned in the letter of environment clearance  All industries should install the new machiney of modern make which complies with the noise standards prescribed by DoE.  Job rotations should be practiced for workers in working at noise intensive locations to prevent prolonged exposure to high noise level as it may lead to deafness, fatigue, head ache, nausea and drowsiness. Propose PPEs muct be made cumpolsory for workers working at locations where the intensity of noise is high.  Acoustic design with sound proof glass paneling will be provided for critical operator cabins / control rooms of individual modules as well as central control facilities.  Proper greasing, periodic checkups for frictionless movements.  Honking should be prohibited within the economic zone

7.5 Impacts on Water Resources 7.5.1 Pre-Construction and Construction Phase

Impacts on Ground & Surface Water ResourcesSignificant quantity of water will be required for various construction activities & domestic purpose. The water requirement will be sourced from borewells of 200- 225 m depth proposed to be contructed onsite. Excess withdrawal of ground water may lead to depletion of aquifers. Thus, measures should be taken to minimize the water extraction by reducing water consumption and wastage. Mitigation measures are given below.

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

Impact on Surface Water and Ground water Quality The major source of wastewater generation during construction phase is from the labour camp, which will be established for project construction activity. There is a potential for contamination of surface and groundwater resources resulting from improper management of sewage. The quality of water bodies could also be affected due to surface runoff from contaminated soil (soil contamination due to oil/ fuel spillage and leakages), particularly during monsoon season. The surface runoff carrying the loose top soil will lead to increased sedimentation in the receiving water bodies. Contamination to water bodies may also result due to oil spilling during construction activities and/or surface runoff from the construction site to the adjacent water body. Thus measures are required to be taken to minimize the surface water pollution.

Mitigation Measures  To avoid excavation activities during rains  To prevent piling up of excavated soil, raw material and construction debris at site by proper management and disposal  Minimize run-off by using sprays for curing  Maintaining appropriate flow of water sprinklers at site  Construction of storm water drains along with sedimentation tanks with sand bags as partition as barrier for direct flow of run off to river.  Collection & Reusing of curing over flow, tyre wash water etc within the site  Construction of adequate nos. of toilets and proper sanitation system to prevent open defecation along the river banks/water supply lines  Construction of soak pits/septic tanks to dispose-off the domestic waste water generated from labour camps to prevent disposal of sewage in surface water bodies  Proper collection, management and disposal of construction and municipal waste from site to prevent mixing of the waste in run-off and entering the water bodies  Labourers should be given training towards proactive use of designated areas/bins for waste disposal and encouraged for use of toilets. Open defecation and random disposal of sewage will be strictly restricted;  Spill/ leakage clearance plan to be adopted for immediate cleaning of spills and leakages.  There should be a containment tank installed of 1.5 times the HFO storage capacity in order to prevent accidental leakage of oil (source: fuel-oil piping and storage – ICC)  Adequate management of the spent lubricant collection and disposal through contractors who are authorized to recycle or dump in Government approved landfills.

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 The construction debris, oil and lubricant drums shall be kept on a secondary containment system so as to prevent leaching. Leaching could be an issue during monsoons and hence secondary containment shall be there to keep construction debris and oil drums to prevent leaching downwards and impacting the shallow groundwater.  Care should be taken that during transportation of construction material and equipments by waterway, there should not be any spills or leakages in the sea.

Impacts of Dredging

BEZA has proposed to carry out landfilling with dredged material from the adjacent river. The dredged material is mostly sand except thin top layer. During the site visit, at certain places sand extraction (dredging) has been observed from the river. This material is stored on the banks of the river, which will be ultimately used as construction material. This sand has lot of demand and has economic value.

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

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

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

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

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

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

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

Mitigation Measures

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

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7.5.2 Operation Phase

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

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

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

Mitigation Measures

 Each industry should obtain consent of DoE Bangladesh before construction and operation and should comply to the conditions laid by them  The Industry should also obtain the consent of the water abstraction limit from DoE, Bangladesh.  No leachate, waste water and waste material should be stored in pervious unlined area/pond.  Each industry should treat the effluent and sewage generated by them so as to achieve zero discharge and no untreated effluent should be discharged into any water body  STP and ETP designed on the basis of effluent quantity and characteristics, should be installed for each industry in the EZ  The EZ should install a common CETP plant  Each industry should practice rain water harvesting to minimize the water consumption and reduce run-off from the site  Proper management of waste should be done to prevent any contact between the waste and storm water  Storm water drains should be lined to separate from effluent drains  Storm water system should be inspected & cleaned before monsoon every year  Peripheral drain shall also be lined and shall not be connected to internal storm water drainage system.  The top soil shall be preserved and used for covering the sand layer at EZ site. Vegetation turffing shall be made at the side slops of the EZ areas to prevent erosion and siltation in the river.  River water quality shall be monitored periodically  Ground water quality shall be monitored periodically.  Sludge should be dried into cakes and used as manure for green belt.  The industries within the EZ shall comply with the “Zero Discharge” clause recently introduced by DoE, Bangladesh. Proper design and application methodology shall be determined before the industrial set-up  The abstraction of groundwater shall be done at a sustainable flow rate. Step-Test and Pump-Test shall be conducted before deciding the rate of groundwater abstraction and the volume to understand the target aquifer charecteristics.  As, the continuous abstraction of groundwater, could impact the groundwater level, rainwater harvesting units within the subject site shall be constructed to recharge the aquifer especially during the 3 to 4 months of monsoons.  Practices like reverse boring shall be strictly avoided.

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7.6 Impacts on Land resources 7.6.1 Pre-construction and Construction Phase

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

 Dredging and landfilling activity  Soil erosion due to vegetation clearance and excavation activities;  Top soil degradation  Generation of waste (hazardous and non-hazardous) from site clearance, excavations, civil works and activities of construction workers (general waste and sewage); and  Possible contamination of soil due to potential spills of lubricating oil, fuel oil, concrete etc.

7.6.1.1 Soil Erosion

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

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

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

7.6.1.2 Soil Compaction

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

7.6.1.3 Landfilling with Dredged Material

The project site is located in low lying area and landfilling will be done during site development activity. Generally in Bangladesh, landfilling is done with dredged material. Dredging activity may be carried out near the site location or away from site. Dredging activity will have two fold impacts - firstly as a result of the dredging process itself and secondly as a result of the landfilling of the dredged material.

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

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

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

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7.6.1.4 Waste Generation

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

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

7.6.1.5 Soil Contamination

Soil contamination during the construction phase may result from filling activity, leaks and spills of oil, lubricants, or fuel from heavy equipment and wastewater. Such spills could have a long-term impact on soil quality, but are expected to be localized. The soil at project site is sandy clay. The soil strata has higher permeability, thus allowing contamination at greater depth. Storm water run-off from the contaminated area can pollute the downstream soil and water quality of receiving water body. Spill control measures such as the storage and handling of chemicals and fuel in concrete areas with secondary containment will be implemented to minimize impacts in the event of a spill.

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

Mitigation Measures

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

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

7.6.2 Operation Phase 7.6.2.1 Impact on Soil Quality

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

Mitigation Measures

 Provision shall be made for proper storage and disposal of industrial waste by receptive industries.  Provisions shall be made to segregate e-waste with rest of the wastes generated.  Alliance shall be done with e-waste recycling vendor and the segregated e-waste shall be send to the vendor for recycling purposes  A Common waste storage areas shall be designated for industrial domestic waste.  The domestic waste shall be kept away from the industrial waste. Dried domestic waste could be used as manure  Waste should be segregated at source into hazardous and non hazardous waste. Further the waste should be segregated into recyclable and rejected waste. Recyclable waste should be sent to authorize vendors for recycling and rejected waste should be disposed off as per the norms specified by DoE for the particular waste.  Industrial waste generated should be stored on sealed surfaces and should be disposed off as per guidelines of DoE, Bangladesh.  Local environmental bodies shall be consulted for the initiation for the designing and constructing localized landfill for the disposal of process waste.

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 No chemical/hazardous raw material should be allowed to spill over the land and should be operated in covered systems  Excessive packaging should be reduced and recyclable products such as aluminum, glass, and high-density polyethylene (HDPE) are being used where applicable.  Organic waste should be resold to value addition industries or can be feeded to live stock.  Use of advanced techniques to control specific portions of the manufacturing process to reduce wastes and increase productivity.  Sludge generated in effluent treatment plant should be sold to authorized recyclers.

7.7 Impacts on Biodiversity/Ecosystem

The development of the EZ will not involve tree felling. However the discharge of waste in rivers, will impact the aquatic life and it should be ensured that there will not be any discharge into the surface water to minimize the impact on the acquatic life.

Green buffer of 10 m all around the project site will include most of the native plant species, which will significantly improve the ecology of the area. This green buffer will provide habitat for the avifauna, reptiles and small mammals and will enhance ecology of the area. Plantation should also be carried out along the both side of access road. Post development of the economic zone & setting up of industries, there could be some impacts on the ecosystem of the area. Industrial development will involve generation of emissions, effluents and increased vehicular movements. These altogether may have overall negative impact on the eco-system of the site and the nearby areas as the air pollutant will impact the existing vegetation and avifauna in the area. As the proposed industries include IT and ITES, it is envisaged that the impact on the biodiversity will be minimal. Mitigation Measures

 Periodic monitoring shall be carried out as per the monitoring plan for air, water, noise and soil and ensure that no impact  No waste shall be discharged in water bodies.  Tree survival rate shall be monitored

7.8 Impacts on Agriculture resources 7.8.1 Impacts on agricultural resources

The development of the EZ is envasiged on land which are presently under agricultural practice. All the agricultural lands falling within the site boundary shall be acquired by BEZA and proper compensation based on present market rates shall be provided. There could be impacts that can be envisased during the construction phase to the nearby agricultural lands. Discharge of water, sumping of construction debris etc can impact the agricultural resources and invariably production. Mitigation Measures

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

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 During the operation phase, the treated water shall not be discharged on the agricultura fields. 7.9 Impacts on Fisheries 7.9.1 Impacts on fisheries during pre-construction and construction phase

The proposed site for EZ development is not presently being used for pisciculture purposes or for fishing purposes. The proposed area doesn’t have any lakes or ponds where in past or in present times fishing or fish culture is practised. Thus no significant impact on fisheries is anticipated due to the project development. 7.10 Impacts on Occupational Health and Safety

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

Mitigation measures to be implemented are:

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

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 The contractors should ensure H&S standards of labour camps. The labour camps will be established in the proposed site area. Additionally, the PIU team should conduct random spot checks to determine any issues related to improper waste disposal or the living conditions in these camps (i.e. presence of secure shelter and flooring, number of persons per room, number of toilets for the manpower, water availability etc.);  Additionally a “Code of Conduct” can be instituted for the operational phase that takes into account (a) health & safety aspects; (b) restrictions on activities – Dos and Don’ts; (c) labour camp regulations; (d) zero tolerance of illegal activities by construction personnel including: unlicensed prostitution; illegal sale or purchase of alcohol; sale, purchase or consumption of drugs; illegal gambling or fighting which will be shared with all contractors for induction of their employees/supervisors/workers;  Training should be provided to all the transport workers on road safety, particularly, the safety precautions to be undertaken while driving through busy village roads;  Strong protocols should be built as part of contractual obligations around zero tolerance of child labour or harassment of women workers and even health and safety aspects. These should also be monitored by supervision and monitoring team; and  A register of Materials Safety Data Sheets (MSDS) relating to all hazardous substances on board, will be maintained

7.11 Community Health and Safety

Public safety, particularly of pedestrians and children can be threatened during construction activities. The health and safety (H&S) impacts related to the project can be categorized into two types- occupational health and safety and community health and safety. It is anticipated that the construction (including transport and handling), erection and commissioning and operational activities will have medium risks on both occupational H&S and community H&S aspects.

The mitigation measures that can be adopted are as follows:

 Construction activities should be timed, and provision for pedestrians should be made  Excavated trenches/ditches and freshly cut steep side slopes should be clearly marked and fenced for the safety of passersby and workers alike. Project or construction vehicles should be briefed on speed limit within sensitive areas such as schools, commercial and residential areas  The community must be informed of the type of activities being undertaken for the project and the health and safety measures that can be undertaken by them as a precautionary measure. Additionally, the emergency response plan must also be communicated to the villages in the vicinity  Linkage of Communication, Disclosure and Grievance Redressal Mechanism should also cover labourers so that any concerns on working conditions and/or contractor mal-practices can be managed.

7.12 Flood Risk

The project site is abutted by Dhaleshwari River immediatesouth,, agricultural land and residential settlements to the north of the proposed site, BSCIC Industrial Estate- to the West of the proposed site and agricultural land towards the east. Based on the stakeholder interactions, the flood level during monsoon season varies from 5 feet to 6 feet depth inside the proposed EZ area. To avoid inundation during monsoon season, minimum land filling of 0.6 m above the flood level is considered. Thus an average depth of 8 feet to 10 feet of land filling has been envisaged for the proposed EZ area. An embankment adjacent to the river is proposed to protect the site from flooding upto +4 m from NGL and minimum site filling of average 1 m from the existing NGL for the entire site area as shown in below figure.

Figure 49: Embankment cross-section details

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7.13 Sanitation and Disease Vectors

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

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

7.14 Impacts due to Climate Change

Bangladesh is one of the most vulnerable countries to Climate change. Dhaka, the capital city of Bangladesh is exposed to different types of climatic conditions, and climate change hazards such as cyclone, tidal surge, coastal inundation and salinity intrusion due to sea level rise, erratic rainfall, flood, river bank erosion, drought, landslide. The proposed site location is abutting Dhaleshwari River which possess high flood risk alleviated by the impact of the climate change.

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

Climate change has a major bearing on the status of biodiversity. Out of Bangladesh’s 260 freshwater fish species, more than 40% are now threatened towards extinction and may soon follow the path of other wetland fauna and flora. If this continues, an area of 1.3 billion ha will completely lose its original levels of biodiversity by 2050. Since 1985, wild carp spawn catches have declined by 75% and catch of wild major carps and large catfish have declined by 50%.

Based on the paper “Effects of Climate Change on River Morphology in Bangladesh and a Morphological Assessment of Sitalakhya River” by S.Hossain, M.Rahman, F. Nusrat, R. Rahman and N.F. Anisha; Journal of River Research Institute (RRI); its being reported that from 1989 till 2009, because of the issue of climate change, there is -0.25 m to -13.4 m changes in the river bed elevation. The top width is reducing at a rate of 18 m – 45 m per year.

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

7.15 Cumulative Impacts

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

The cumilitive impacts of the project will be:

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

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7.16 Impacts on socio-economy

The project does have adverse impacts. The proposed area for EZ development have 65 acres of privately owned land which is owned by 108 land owners and along with that the site also has 4 kaccha structures. Though no commercial establishments and business set-ups are also not reported within the project site area. The development of the project does involve loss of livelihood.

Mitigation Measures

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

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8. Public Consultations and Disclosure

8.1 Introduction and Objectives

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

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

8.2 Methodology of Stakeholder Consultations

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

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

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

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8.3 Details of Public Consultations and Meetings

The public consultations in the form of local and focused group discussions were carried out during the period from 8th April till 9th May 2016. The extent of likely adverse impacts was one of the major criteria for deciding the locations of public consultations. Types of consultations done with various participants using various tools including, interviews with government officials, individual consultations, key informant interviews, focus group discussion, stakeholder consultations, etc, are presented in below table: Table 50: Types of Consultations

Level Type Key Participants Individual Local level Consultation People along the project area Individual Sample Door to Door Personal People along the project area including those interactions that are not impacted directly Settlement Focus Group Discussion PAP, Women, weaker sections, agriculturist, School teachers

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

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

Table 51: Details of Consultation

Issues Raised Suggestion form BEZA’s response s t n n Participants a o e i p t t i a a c i c D t o r L a P  The privately owned land  Adequate livelihood 1- Project information is used for agriculture support and income shall be shared regularly and it serves as the restoration to the and transparently primary source of affected persons 2- Provision of income income for most of the  Compensation in restoration plan and households. The land accordance with the skill development owners have been market rate for the training to the PAP’s

e practicing crop affected landowners 3. Payment of g

a cultivation and have not and house owners compensation at market l l 6 i

1 been imparted training value before the V 0

2 a in alternate domain. The commencement of the / 2 d 1 4

n land acquisition of the pre-construction phase 0 a / k 3 agricultural land will of the project 1 a

n affect the source of o

S livelihood and the income restoration will be challenging without skill development to work in alternate work streams.  Who will compensate for the difference in Mouza

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rate and market price of the land

 Land Acquisition would  Adequate relocation 1. Design shall be also result in physical for affected families adjusted to minimize the displacement for 4 who are losing impact homesteads. The residents structures 2. Payment of alternate relocation  Try to minimize the compensation at market options for the land acquisition. value before the homesteads needs to be  Expeditious beginning of the pre- in the near-by vicinity payment of the construction phase of  There shouldn’t be any compensation the project

) delay in compensation 3. Provision of adequate

a (before the

e notice period shall be r for their lost assets beginning of the pre- a

t  Social issues (Health, construction included in LAP c

e 4. Provision for j sanitation, Employment activities) o

r and Poverty and etc.) employment p opportunities for the o t

t effected landowners and n 6 1 e house owners; c 0

a 2 5. Alternative land for j / 8 d 4 shelter shall be provided a 0 ( / 9

e for homesteads 1 g

a 6. As a measure to l l i reduce unethical V

a practices during the d

n construction strong a

k protocols will be built as a

n part of contractual o

S obligations around zero tolerance of child labour or harassment of women workers and even health and safety aspects. These will also be monitored by supervision and monitoring team.

 Whether the industrial  trainings which 1. Employment set-up at the Economic should include opportunities for the Zone proposed shall classroom lecture affected youths shall be provide them with sessions from provided on a priority a

e employment experts and on-field basis. r a

opportunities hands on experience. 2. Interest specific t

n  Since the opportunities The skill training trainings shall be e 6 c

1 should focus on soft provided to all the a will require specific j 0 2 d trainings, will they be skills development, youths affected by the / a 6

4

e community-oriented development of this 0 provided with trainings / h t 9 so that they become courses, project 1 n i

competent polytechnical 3. The training modules h t  Will there be any courses, craftsman will vary based on the u

o employment training (for semi- requirement and the Y opportunity during the skilled interest of the construction phase opportunities). The stakeholders. courses should also be holistic.

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 Priority for local  The training population system should lead to trained young people in employable skills who are open to immediate employment opportunities.  The project affected youths shall be prioritized for employment opportunities  Stakeholders working in  Compensation Middle East countries commensurate with (Saudi Arabia, Kuwait, their foregone Dubai) were consulted earnings and also

 Job security if in case factoring the Though the s

r compensation will be e they decide to quit their currency exchange k 6 1 r job and return to  Relevance of the lower compared to 0 o

2 foregone earnings, the

w Bangladesh training programme /

4 t 4 additional benefits of 0 n  Time period for training to meet the job / a 9 r requirements working in an employee 1 and the compensation g i during the training conducive environment M with stringent labor standards such as right to join a trade union, collective bargaining are non-tangible incentives.  PAPs shall get the first  The affected people 1. Lists of affected priority for any kind of shall be provided the people will be populated an opportunity first and the utmost during the RAP  The design for the EZ priority for providing implementation and the development shall be any kind of an affected people will be done in a way that should opportunity be its prioritized for minimize the adverse compensation, job employment social impacts etc opportunities.  The PAPs and the PAHs  Trainings shall be 2. Compensations for shall be compensated open to all. Well land, structures, and

r based on the current renowned experts crops to the private land e c i market rates of the land shall be requested to owners will be provided f f come for few days to on the basis of the O and structures

6 d 1  Compensation shall be share their current rates. The 0 n 2 a experience. The class compensation will be / granted before the L 3

4 provided before the 0 C commencement of room lectures shall / A 3 be coupled with on- commencement of the 1 construction a l

i field trainings construction. z a  Compensations for 3. The site does not p

U trees, land, involve cutting of any structures for trees. The only location privately owners which has few trees and shall be provided one CPR has been based on the market proposed to be cordoned rates and the same off. shall be reimbursed before any kind of an activity begins at the proposed land

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 Employment  People whose lands and 1. Employment opportunities within the houses are getting opportunities EZ affected should be commensurate with the  Provisions for the safety of provided with skill of the PAP’s will be the residents during the employment provided. construction period opportunities 2. The safety standards  Provision of residential  Provide will be made part of the

Z quarters for the workforce accommodations for contract of the agency E

e  Possibility of sexual employees and their executing the h

t construction work. harassment of women family members within f

o

3. Labor camps will be 6 employed in the EZ and walking distance of the 1 r e 0 EZ. provided for

2 also of the women in the n / 0 r construction workforce. 1 4  Ensure that the

o vicinity of the project due 0 c

/ 4. There will be zero

t to the influx of migrant residential areas in the 8 s 1

e population vicinity don’t face tolerance on the sexual

w harassment and also

h safety issues during the t

r construction. child abuse. The same o

N  Ensure strict code of will be incorporated as conduct for the part of the contract of contractor to prevent the agency executing the sexual harassment and works at the site. child abuse. Further tightened security will be provided to mitigate the cases of sexual harassment.  The expected  The Union Parishad 1. The local government commencement of Office extended full bodies and the PAPs operation of the EZ support for this project. shall be timely informed  The access road for the  Priority for about the project proposed EZ employment should be developments  The EZ should be even for the people 2. Employment developed keeping in mind residing in the opportunities

r the opportunities for local Rohitpur union. commensurate with the u

p skill of the local villagers

t people staying in the  People who are affected i

h Rohitpur Union shall be well informed will be provided. o 3. Provision of the R in advance about the  As the construction work ,

e security will be of

6 might be undertaken next phases of the c 1 i f

0 outmost significance for

f during the night, the developments. The 2 / O the EZ. Round the clock

6

5 security measures for local government d 0 a / women during night shift bodies and the PAPs security guard will be 9 h

s 0 provided for the EZ.

i should be ensured. shall be informed well r

a before the P commencement of the n o

i land acquisition. n

U  The authorities should be updated on the status of the development of the EZ.  Specially appointed night guards should be ensured for the security .

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 What could be likely  Since the existing 1. As suggested, officials impacts on BSCIC, if any approach road will be from EZ shall keep a  Since the approach road used for the EZ, close tab on the extent of passes through BSCIC and appropriate impacts on air and will be jointly shared by maintenance of the water. The EMP which EZ, will EZ authorities look road should also be shall be developed with e c

i after the maintenance of ensured the EIA, shall be f f the same  The training followed and O

e implemented diligently

t  Will the workers working programmes should be a

t open for all. Workers 2. Trainings 6 at BSCIC get an equal s 1 E

0 programmes shall be opportunity in the training from BSCIC should also l 2 / a

5 open to all. Workers i

5 programmes organized by get equal opportunity r 0 t

/ from BSCIC shall be

s EZ to enroll 9 u

0 provided equal

d  Will the EZ take sufficient himself/herself under

n opportunities for the I the training steps in minimizing the air

C training programmes I and water impacts as programmes C

S BSCIC is immediately west  EZ should have a well- B of the subject site. Any documented and impact on air or water can applicable EMP for also adversely affect the them to minimize the working environment of impacts on air and BSCIC water

8.4 Consultation outcomes

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

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

Further, the analysis of the key positive impacts, apprehensions and perceived negative impacts and the suggestions/recommendations as documented during stakeholder consultations are detailed in below table. Table 52: Positive Impacts perceived by the Stakeholders

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Positive impacts perceived by the stakeholders

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

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

Table 53: Negative Impacts perceived by the Stakeholders

Negative impacts perceived by the stakeholders

 Loss of primary source of livelihood

 Compensation will be lower than the market rate and apprehension of the delay in providing the compensation

Table 54: Photographs of Stakeholders Consultation

Multiple stakeholder consultations and FGDs undertaken as part of the project

Focused Group Discussions (FGDs) being conducted with the PAPs at the North-western corner of the site area

Stakeholder consultation being conducted at Bin Habib BD Ltd, the LPG packaging plant northwest corner of the site area.

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Focused Group Discussions (FGDs) being conducted with the PAPs at the Sonakanda Village

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Stakeholder consultation held Union Land Officer and an official from Bin Habib BD Ltd.

Group Consultations with women PAPs.

Group Discussions with the Youth residing in the surrounding areas

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Group Discussions with Migrant Workers

Socio-economic survey conducted with PAPs at Sonakanda Village

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9. Environmental Management Plan and monitoring indicators

9.1 Introduction

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

The purpose of EMP is to:

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

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

9.2 Mitigation Plan 9.2.1 Preconstruction Operations

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

In case of the dredged material is used for filling, ships will carry the dredged material to the site area. In any case, the following general measures may be adopted:  In both cases, shortest possible route should be selected for transporting the material and densely populated settlements may be bypassed as far as practicable.  If the material is dusty the containers should be covered  The trucks used for transportation should meet exhaust (Schedule 6 – ‘Standards for Emission from Motor’ of The Environment Conservation Rules 1997 (Amended 2002); and noise emission standards as per Schedule 5 – ‘Standards for sound originating from Motor Vehicles or Mechanised Vessels’ of The Environment Conservation Rules 1997 (Amended 2002).  To avoid fugitive dust, water may be sprayed at the places where vehicles are moving

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

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9.2.2 Construction Activity

The following are the major construction activities:

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

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

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

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

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

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

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

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

The construction of access road south of the BSCIC Industrial Estate has been proposed. The impacts associated with construction of access road, boundary wall and administration building along with proposed mitigation measures are given below. No impacts are anticipated during operation phase. The Contractor shall carry out all mitigation and enhancement measures (including those related to mitigation of air/noise/water pollution; drainage/traffic congestion) as specified in the EMP tabulated below. Table 55: Environmental Impacts and Mitigation Plan for constructiomn of access road, Boundary Wall & Administration Building

Impact Mitigation Measures Time Frame Implentation Supervision & of Mitigation Monitoring Measures Removal of  When clearing the site, care Pre- Contractor BEZA/PMC Vegetation shall be taken to keep construction vegetation clearing at a phase minimum and only from the RoW  Removal of as little vegetation as possible during the development and re-vegetation of bare areas after the project. Setting up of  The construction camps should Pre- Contractor BEZA/PMC construction be at least 500 m distance from construction camps/labour habitations from the nearest phase camps settlements to avoid conflicts and stress over the infrastructure facilities with the local community.  Location for stockyards for construction materials will be identified at least 1 km from water sources  The living accommodation and ancillary facilities for labour shall be erected and maintained to standards and scales approved by the resident engineer  All sites used for camps will be adequately drained. There should not be any risk of

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periodic flooding, nor located within 300 feet of pools, sink holes or other surface collections of water  The camps will be located such that the drainage from and through the camps will not endanger any domestic or public water supply  All sites will be graded, ditched and rendered free from depressions such that water may get stagnant and become a nuisance  Construction camps shall be provided with sanitary latrines (1 per 25 pax), bathing facility and urinals.  Sanitary latrines shall be under cover and so partitioned off as to secure privacy, and shall have a proper door and fastenings  Adequate and suitable facilities for washing clothes and utensils shall be provided and maintained for the use of contract labour employed therein.  Sewerage drains will be provided for the flow of used water outside the camp.  Drains and ditches will be treated with bleaching powder on a regular basis.  The sewage system for the camp will be properly designed, built and operated so that no health hazard occurs and no pollution to the air, ground or adjacent watercourses takes place.  Clean potable drinking water facility should be provided at the site and the water quality should be monitored regularly  Crèche facility should be provided for children if female workers are employed  First aid facilities should be made available at construction camp. First aid box should contain small, medium and large sized sterilized dressings, sterilized burns dressings, 2 % alcoholic solution of iodine, bottle containing salvolatile, snakebite lancet, , bottle of potassium permanganate crystals, scissors, Ointment for burns & surgical antiseptic solution  1 first aid box should be available for every 50 labour  A person trained in first-aid treatment should be made in

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charge who will always be readily available during emergency  A suitable motor transport shall be kept readily available to carry injured or ill person to the nearest hospital. Landfilling  Residential facility or sensitive During Contractor BEZA/PMC facilities like hospitals, schools Construction etc shall not be located in downwind direction of the identified sites for getting landfilling material.  The soil used for landfilling should have similar characterisctis to the native soil and free of any type of contamination.

In case of dredging activity for landfilling purposes:

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

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Identification of  The dumping sites shall not be During Contractor BEZA/PMC dumping sites for located within designated Construction debris Forest/protected areas  Residential facility or sensitive facilities like hospitals, schools etc shall not be located in downwind direction of the identified dumping sites  Dumping shall not impact natural drainage courses  Dumping sites should be located at least 1 km from sensitive locations  Permission from concerned local body should be taken before finalizing the location  Agriculture lands should be avoided & waste lands should be preferred  Selected site should not support significant vegetation  The area should be sprinkled with water to suppress the dust emissions  Plant species suitable to grow in that conditions should be planted at the time of closure Soil Erosion and  Contractor should plan the During Contractor BEZA/PMC Sedimentation activities so that no loose earth Construction control surface is left out before the onset of monsoon.  Top soil from debris disposal sites & along the road side should be stripped and kept under covered shed for plantation  After the construction activity is over, top soil will be utilized for landscaping activity.  To avoid soil compaction along the transportation routes, only identified haul roads would be used for transportation.  Along sections abutting water bodies, stone pitching needs to be carried out  High embankments should be provided with chutes and drains to minimize soil erosion.  Turfing of low embankments and plantation of grasses and shrubs should be done in slope stabilization.  Soil erosion checking measures as the formation of sediment basins, slope drains, etc, should be carried out.  Construction of Side Slope of Filled Land of 1:2 by suitable soils with proper compaction as per design. Slope surface should be covered by top soils/ cladding materials and grass turfings with suitable grass.

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Disposal of Debris  Waste from construction camp During Contractor BEZA/PMC and any waste should be segregated at site. Construction generated Food/wet waste should be composted in pit at the site, recyclable should be send to authorized recyclers and rejected waste should be disposed regularly through responsible agency in the area  Dustbins should be provided at the site and construction camps to prevent littering of waste  Storage area of minimum 2 days should be provided at construction camp for storage of the waste generated from labour camps  Construction debris should also be segregated at the site. This debris should be used for filling to the extent possible. Recyclable waste should be sold through authorized dealers and reject waste should be sent to the identified debris disposal site  All arrangement for transportation during construction including provision, maintenance, dismantling and clearing debris, where necessary will be considered incidental.  Construction debris should be stored under covered sheds on paved surfaces to prevent leaching  Any hazardous waste generated during construction activity shall be stored at designated place and then disposed through the TSDF using high temperation incenaration or any other chemical, thermal, biological, and physical methods. Chemical methods include ion exchange, precipitation, oxidation and reduction, and neutralization.  Contaminated runoff from storage areas should be captured in ditches with an oil trap at the outlet.  Utmost care shall be taken to ensure that the DoE norms are met for the safe collection, transport and disposal of construction waste and debris. Dust Generation  Vehicles delivering materials During Contractor BEZA/PMC should be covered with Construction tarpaulin to reduce spills and dust blowing off the load.  Compaction of prepared site to re-strain the fugitive emissions.

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 Water should be sprayed in the cement and earth mixing sites as well as after compaction.  In high dust areas, workers should be provided and encouraged to use masks.  Regular maintenance, servicing of the vehicles and periodic emission check for equipment and machinery would be carried out in conformity with the Central Motor Vehicles Rules, 1989.  Water will be sprayed on the haul road.  All the vehicles entering the project site will be checked for Pollution-Under-Control Certificates.  Air quality monitoring to be carried out during construction phase to check the pollutants level in the air Procurement &  Specifications of crushers, hot Pre- Contractor BEZA/PMC Setting up of mix plants and batching plants, Construction Crushers, Hot- other Construction Vehicles, mix plants, other Equipment and Machinery to Vehicles, be procured should comply to Equipment and the DoE Standards/ norms Machinery  Hot mix plants, crushers and batching plants shall be located at distance of approx 1 km from nearest habitation, archaeological site, sensitive areas, forests etc.  Aadequate stack height and emission control devices such as bag house filters, cyclone separators, water scrubbers etc., should be attached  Impervious platform for storage of bituminous and other liquid hazardous chemical  Pollution control measures for Diesel Generator (DG) set i.e. stack height (calculated by H = h+ 0.2 * Sqrt(kVA) where h = height of building where generator set is installed and kVA is total generator capacity), acoustic enclosure etc. should be ensured  Proper lighting arrangement shall be made around plant site if the plants are operated during dark hours.  Provision of readily available first aid kit, fire fighting equipments at the plant site at appropriate location to respond in case of accident.  Periodical monitoring of air quality and noise levels as per conditions stipulated under the statutory clearance from DoE.

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Whenever the emission exceeds the permissible level the plants should be stopped and necessary repairing works of faults should be done to bring down the emission levels Contamination of  Impervious platform and oil During Contractor BEZA/PMC soil and grease trap for collection of Construction. spillage from construction equipment vehicle maintenance platform will be appropriately provided at construction camp, servicing area and liquid fuel and lubes at storage areas.  Proper management of waste from labour camps and construction site  Proper disposal of wastewater generated from labour camp and construction site Contamination of  Construction close to water During Contractor BEZA/PMC surface & ground bodies shall be avoided Construction water  Car washing / workshops near water bodies will be avoided.  Avoid excavation during monsoon season  Loosened soil will be stabilized by Contractor through landscaping and developing vegetation, wherever possible, once construction activity is completed at any site.  Sanitation facility with septic tank followed by soak pit will be developed. Common toilets will be constructed on site during construction phase and the waste water would be channelized to the septic tanks and soak pits in order to prevent waste water to enter into the water bodies.  Provision of oil & grease traps upstream of storm water drains  Surface run off due to construction activity will not be discharged in open without treatment.  STP and ETP shall be there for each and every unit  A CETP shall also be there Loss of water  No excavation from the bund of During Contractor BEZA/PMC bodies/ surface / the water bodies. construction ground  No earth will be excavated for development of any off-site facility  No debris disposal near any water body.  Prior written permission from authorities is required for use of water for construction activity.  Construction labours to be restricted from polluting the source or misusing the source.

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 Labour camps will be located away from water bodies. Drainage and  The Contractor will always During Contractor BEZA/PMC runoff clear all the cross drainage Construction structures and natural drainage before onset of monsoon in order to keep all drainage unblocked Earth, stones, wastes and spoils will be properly disposed off, to avoid blockage of any drainage channel.  All necessary precautions will be taken to construct temporary or permanent devices to prevent inundation Noise from  Construction activities would Throughout Contractor BEZA/PMC Vehicles, Plants be carried out in the daytime construction and Equipment only.  The construction equipment would be provided with adequate noise control measures and should comply with the noise standards as prescribed by DoE  Regular maintenance of vehicles and equipment would be carried out and corrective action taken in case of any deviation.  Ear muff/ear plug shall be given to the workers working around or operating plant and machinery emitting high noise levels.  DG sets if installed should be provided with acoustic enclosures  Labour working in noise prone area should be provided with ear plugs and job rotation should be practiced to prevent the prolonged exposure of any workers to high noise levels Loss or damage to  Vegetation will be removed During Contractor BEZA/PMC vegetation from the construction zone Construction before commencement of Phase construction. All works will be carried out such that the damage or disruption to flora is minimum.  Only ground cover/shrubs that impinge directly on the permanent works or necessary temporary works will be removed with prior approval from the Environmental Expert. Loss, damage or  Construction workers will be During Contractor BEZA/PMC disruption to directed not to disrupt or Construction fauna damage the fauna. Phase  Construction vehicles will run along specified access to avoid accidents to flora and fauna.

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Accidents  Safety officer should be During Contractor BEZA/PMC appointed at site to ensure all Construction the safety guidelines are being followed at site  Cautionary guidance should be provided at site to aware people about the associated risk with the area. Entry to the fuel storage room or machinery operation room should be restricted only to authorized trainer personnel  All Accidents shall be reported immediately and incident analysis, preventive measures shall be implemented. Clearing of  Contractors shall prepare site Post Contractor BEZA/PMC Construction of restoration plans. The plans Construction Camps & shall be implemented prior to Restoration demobilization.  On completion of works, all temporary structures shall be cleared, all rubbish burnt, excreta or other disposal pits or trenches filled in and sealed and the site left clean and tidy. Occupational  All construction worker should During Contractor BEZA/PMC Health & Safety wear PPEs including safety Construction Plan jacket, helmet, gloves, gum boots, ear plugs, mask while working at the site  Workers should be made aware about the health issues related with open defecation  Training to workers should be provided for handling the construction equipment and machinery  Training to the workers should be provided to handle the emergency situations like fire, floods etc.  First aid facility and sufficient nos. of trained personnel should be available at all the time at construction camp  Cautionary signage and notice should be displayed in local language and English at the required places like fuel storage area so that hazards can be avoided. A security guard should be deputed in these areas and entry should be restricted  A register of all toxic chemicals delivered to the site shall be kept and maintained up to date. The register shall include the trade name, physical properties and characteristics, chemical ingredients, health and safety hazard information, safe handling and storage procedures, and emergency

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and first aid procedures for the product. Disaster Precaution will be taken to prevent During Contractor BEZA/PMC Management danger of the workers and the Construction public from fire, flood, drowning, etc. All necessary steps will be taken for prompt first aid treatment of all injuries likely to be sustained during the course of work.

9.2.3 Mitigation Plan for Power Supply

Laying of electrical transmission may involve various environmental and social issues. Mitigation Plan has been prepared addressing all the potential issues. Transmission line construction impacts can be minimized by the following precautions to be taken during construction of transmission line:  Proper back filling of debris at the completed foundation locations to enable cultivation by farmers  Assessment of crop loss and proper crop loss compensation  Ensuring safety of workers while constructing towers, identifying nearby medical facilities for emergency situations Along with the above general mitigation methods mentioned above would help in minimising construction period impacts of power line. 9.2.4 Biological Environment/ Greenbelt Development

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

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

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

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

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

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

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9.2.5 Emergency Preparedness Plan

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

 Accidents preventions procedures/ measures  Fire prevention planning and measures  Fire water storage and foam system  Accident/emergency response planning procedure  Grievance redressal mechanism  Emergency control centre  Emergency information system with role & responsibility and command structure  Recovery procedure  Assessment of damages and rectification  Evaluation of functioning of disaster management plan  Accident investigation  Clean-up and restoration 9.2.6 Post Project Monitoring Plan

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

9.2.6.1 Micrometerology

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

9.2.6.2 Air Quality

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

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

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

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9.2.6.3 Noice Quality

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

9.2.6.4 Surface Water

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

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

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

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

9.2.6.5 Groundwater

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

9.2.6.6 Soil Quality

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

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

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 Organic matter (%)

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

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

9.2.6.7 Flora and Fauna:

During the primary ambient environmental quality monitoring around the EZ location, flora and fauna on the site and surrounding the EZ has not been monitored to assess the flora and fauna before construction of the project. Thus, it is recommended to carry out a one-time assessment of baseline flora and fauna surrounding the project location before completion of the project. There after terrestrial and aquatic flora and fauna should be monitored to observe any alteration in their species composition and replacement. This could be done in association with local universities and research institutions which carry out such studies frequently. Such monitoring would help in taking necessary steps at the appropriate stage to prevent further deterioration of the surrounding ecology and protect the flora-fauna. The frequency of sampling could be once in a year during post monsoon season (Oct to Dec).

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

9.3 Mitigation Plan for EZ

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

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

 Industries should obtain environment clearance individually from DoE prior to establishment and commencement. Measures that should be taken by developer and individual industrial owners whicle development and operation phase is tabulated in table below Table 56: Mitigation Measures Suggested for Developer

Impact Mitigation Measures

Identification of Site for Disposal  Site identified should be 1.0 km away from settlement, sensitive of construction Debris, locations, like school, hospital, religious structures, reseve forest and construction labour camp and any other eco-sensitive zone etc. plant site  Site identified should be approved by BEZA and PMC  Site should be located in downwind direction from settlement area

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 Fertile agricultural land and community land should be avoided for setting of these facilities

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

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 Mulching of soil should be done regularly to prevent direct exposure of soil to wind and water

Noise Pollution  Construction vehicles, machinery and equipment used for construction purpose should meet the standards prescribed by DoE  Upkeeping and regular maintenance of all the construction vehicles, machinery and equipment used for construction purpose  Provision of acoustic enclosures, noise mufflers, silencers etc with the DG sets and any noise generating machinery  Provision of temporary noise shield/barrier in areas where more noise will be generated Ecology  Development of 10 m (minimum) thick green buffer all along the periphery of EZ  Boundary should be constructed around the EZ site to prevent trespassing of the animals  Native plant species requiring should be considered for plantation  Timber should be purchased only from authorized vendors  No waterbody should be filled outside the EZ site  The mangroves adjacent to the site location should not be cut or impacted. Disaster and Risk Management  Provision of first aid kit and first aid room and well trained first aid practioner at the site all the time  Ambulance facility should be provided at the site  Tie-ups with local hospital should be made to handly emergency case, if any  Availability of safety officers and supervisiors at all the time on the site  Workers should be given training for handling construction vehicles, equipment and handling emergency situations like fire, floods, earthquake and cyclone  Cautionary signage should be provided in the areas associated with risks like storage of explosives, fuels, heavy construction material etc. Entry for only trained authorized personnel should be allowed in such areas with adequate safery measures  Emergency handling cell & room should be developed at the site and should be headed by project & safety manager  Contact no. of nearest fire-station and hospitals should be displayed within the emergency handling room

9.4 Monitoring Plan

The objective of environmental monitoring during the construction and operation phases is to compare the monitored data against the baseline condition collected during the study period to assess the effectiveness of the mitigation measures and the protection of the ambient environment based on national standards. A monitoring schedule has been sketched based on the environmental components that may be affected during the construction and operation of the project and is given below. Table 57: Environmental Monitoring Plan

S. Aspect Source of Monitoring Frequency Executing Enforceme No. Impact Methods and Agency nt Agency Parameters 1.0 Construction Phase 1.1 Local Manpower Construction Contractor’s Monthly Contractor BEZA & PMC Absorption Works report No. of people working in the project 1.2 Soil Erosion Excavation, Survey & Monthly Contractor BEZA & PMC disposal, cut & fill observation; and land clearing Extent and degree activities for site of erosion;

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levelling and Structures for internal roads, controlling soil disposal erosion 1.3 Greenbelt - Survival rate of Half Yearly Contractor/B BEZA & PMC Development species planted; EZA Density of vegetation 1.4 Air Quality Transportation of Survey & Once in each BEZA & PMC construction observations; season for materials, road Levels of PM10, two weeks at construction, PM2.5, SO2, NOx, 3 locations construction of CO utilities 1.5 Waste Restoration of Status of Quarterly Contractors BEZA & PMC Management disposal sites and protection construction areas measures 1.6 Noise Level Noise levels Ambient Daily Contractors BEZA & PMC compliance with Equivalent respect to continuous Sound industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations 1,7 Drinking Water Contamination All physio- Monthly Contractor BEZA & PMC chemical & biological parameters 2.0 Operation Phase 2.1 Noise Levels Noise levels Ambient Monthly Individual BEZA compliance with Equivalent Industrial respect to continuous Sound Units industrial Pressure Levels standards (Leq) at day and Night time at 6 to 8 locations Plant periphery Monthly Individual BEZA and near noise Industrial generation Units sources 2.2 Biological Horticulture/ Survival rate of Quarterly BEZA BEZA Environment Greenbelt plants and shrubs Development Survival rate of Quarterly Individual BEZA plants and shrubs unit at individual unit 2.3 Ambient air Ambient air Ambient air Quaterly Individual BEZA quality quality levels quality Industrial compliance with monitoring at Units respect to individual industrial industries – standards Monitor levels of PM10, PM2.5, SO2, NOx, CO 2.4 Ground water Ground water Borewells Quaterly BEZA BEZA quality quality levels installed at site compliance with respect to industrial standards

9.5 Monitoring Indicators

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

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

9.6 Institutional Arrangement

BEZA has developed Environmental Management Framework with the help of World Bank. The institutional arrangement is aligned as per this framework. BEZA will have an Environmental and social cell which will coordinate with site engineers and PMC. 9.7 Community development plan

It is recommended the EZ owners to involve the local community during the project development. The EZ owner/its contractors may recruit local workforce to the extent possible during construction phase. The EZ owner would identify technically qualified unemployed youth around the project location and other nearby areas, and employ as far as practical. The EZ owner should form a forum/ association/ trust along with its industrial units to look after community development activities of EZ. All the industrial units should periodically contribute to this Trust. The Trust would represent EZ and its industries for all matters related to community and its development. This would act as interface between EZ and community. The Trust should encourage its industrial units to recruit local unemployed youth in the jobs during operational phase. For this if required arrange training for the local people to develop skilled manpower required if sufficient skilled manpower is not available to carry out technical work in the industrial units during operational phase.

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

Some specific community development programs that could be considered by the Trust in coordination with other industries in the locality are suggested here:  Conducting awareness programs in surrounding villages on health impacts due to environmental pollution (air, noise, water, solid waste, etc), and precautions to be taken to minimise health impacts.  Conducting periodic health check-ups to the EZ (including industries) staff and in the surrounding villages to identify pollution related diseases.  Encouragement to residents in the nearby localities for self-employment ventures, such as by assisting them in arranging micro finances to develop them as artisans/ skilled personnel.  Periodic training programs on health and sanitary education, women and child development, and income generation schemes.  Participation in improving the existing medical and educational facilities of the area - for this purpose, it is suggested that the Trust provide funds for facilities improvement (providing toilets, furniture, additional space creation, any other needed) to the local hospitals and schools

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 Development of greenbelt/greenery or tree plantation in the nearby vacant government lands to build a green and clean environment in the surrounding areas and to reduce pollution impacts to some extent.  Sponsoring fellowships to students in surrounding villages to encourage them to go for higher education  Construction of a hospital in EZ area in collaboration with other industries to improve health status  Conduct or sponsor camps to clean up river ghats, jetties and terminals in the surrounding areas.

9.8 Post Project Monitoring Plan

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

9.9 Environment Management Cell

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

The EMC will be responsible for the following:

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

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

In addition the following staff at laboratory are required:  One STP and ETP and TSDF In-charge

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 One Chemist cum laboratory incharge  Three Plant Operators (one per shift) and three TSDF operators  Laboratory/Field Assistants  Sampling assistants

9.10 Compensation Plan

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

Compensation has also been enumenrated for the a) loss of agricultural crops; b) loss of omesteads along with the c) compensation for acquiring 65 acres of private land. The total compensation that has been enumerated under the above headings comes out to be BDT 2,279,419,615.

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10. Cost of EMP

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

Table 58: Cost for EMP Implementation

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

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11. Conclusion and Recommendation

11.1 Conclusions

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

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

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

 Proposed environment management plan should be implemented strictly both during operation and construction phase of the project.  Proper training of maintaining environment, health and safety should be given to Project management unit in both construction and operation phase

 Provision of garland drain, thick green belt, ETP, STP, segregated storm water shall be adhered to.

 Environmental monitoring should be conducted as proposed in environment management plan  Seperate environment impact assessment study is to be carried out by individual industry before development.

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Annexure A: Primary monitoring results

A) Groundwater Results

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B) Noise Monitoring Results

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C) Air Monitoring Results

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D) Surface Water Analysis Results

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Annexure B: Land Transfer Documents

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Annexure C: Land Use by Broad Area Classification

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Annexure D: Land Use by Industries and Services

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Annexure E: Approved ToR from DoE

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Annexure F: Compliance Matrix as per DoE

S.No Comments PwC Response 1 The EIA report needs to incorporate the Master Plan in Please refer setion 4.12 for the land use the report body and also in the annexure plan. Page number 47. The same has also been shown in Annexure C and Annexure D; page number-162 and 163 2 The EIA report needs to have the land transfer (mutation) Please refer Annexure B. Page Number- documents 160 and 161 3 The EIA report needs to incorporate the approved ToR Please refer Annexure E. Page Number-164

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