INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Contract Package No.: e-GP/ CTEIP/2017-18/KAL/PT/01

January 2018

Coastal Towns Environmental Infrastructure Project (CTEIP) (ADB Loan No. L3133-BAN (SF)/L8284-BAN (SCF)/G0394-BAN (SCF))

Batch 2: Stage I CTEIP Programme

Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali

CURRENCY EQUIVALENTS

(as of 31 December 2017)

Currency unit – taka (Tk)

Tk1.00 = $0.01209

$1.00 = Tk82.650

NOTES (i) The fiscal year (FY) of the Government of Bangladesh ends on 30 June. FY before a calendar year denotes the year in which the fiscal year ends, e.g., FY2017 ends on June 2017.

(ii) In this report, "$" refers to US dollars.

This IEE is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the

Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

APPENDIX-E

Coastal Towns Environmental Infrastructure Project (CTEIP) (ADB Loan No. L3133-BAN (SF)/L8284-BAN (SCF)/G0394-BAN (SCF))

Local Government Engineering Department (Ministry of Local Government, Rural Development and Cooperatives)

INITIAL ENVIRONMENTAL EXAMINATION (IEE)

Batch 2: Stage I CTEIP Programme

Contract Package No.:e-GP/CTEIP/2017-18/KAL/PT/01

Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali

January 2018

Package: CTEIP/KAL/PT/01: IEE Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

Package: CTEIP/KAL/PT/01: IEE Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ABBREVIATIONS ABBREVIATION DESCRIPTION ADB Asian Development Bank AIDS Acquired Immunodeficiency Syndrome AP Affected Persons BAN Bangladesh BC Bituminous Carpeting BFIDC Bangladesh Forest Industries Development Corporation BFRI Bangladesh Forest Research Institute BNH Bangladesh National Herbarium BOQ Bill of Quantities BPL Below Poverty Line CC Cement Concrete CDTA Capacity Development Technical Assistance CIF Climate Investment Fund CTEIP Coastal Towns Environmental Infrastructure Project DC Deputy Commissioner DDS Detailed Design services DoE Department of Environment DO Dissolved Oxygen DoI Department of Irrigation DPHE Department of Public Health Engineering DSC Design and Supervision Consultant ECA Environmental Conservation Act ECC Environmental Clearance Certificate ECR Environmental Conservation Rules EIA Environmental Impact Assessment EMP Environmental Management Plan FGD Focus Group Discussion FHH Female House Hold GAP Gender Action Plan GoB Government of Bangladesh HFL High Flood Level HH House Hold ICB International Competitive Bidding ICCDC Institutional Capacity and Communication Development Consultant IEE Initial Environmental Examination ILO International Labor Organization ISA Initial Social Assessment LAO Land Acquisition Officer LGED Local Government Engineering Department LCC Location Clearance Certificate MoEF Ministry of Environment and Forest MCM Million Cubic Meters MLD Million Litres Per Day MoEF Ministry of Environment and Forest MS Mild Steel NFP National Forest Policy NGO Non-Governmental Organization NRW Non-Revenue Water NWP National Water Policy O&M Operations and Maintenance OBC Other Backward Classes PAF Project Affected Family PAP Project Affected Person PIU Project Implementation Unit PLO Project Liaison Officer

Package: CTEIP/KAL/PT/01: IEE i Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ABBREVIATION DESCRIPTION PMSC Project Management Supervision Consultant PMU Project Management Unit POL Petrol, Oil and Diesel PWD Public Works Department PPCR Pilot Programme for Climate Change PPTA Project Preparatory Technical Assistance RP Resettlement Plan REA Rapid Environmental Assessment SIA Social Impact Assessment SPCR Strategic Programme for Climate Resilience TLCC Town Level Co-ordination Committee SPS Safeguard Policy Statement TDS Total Dissolved Solids UBL Urban Local Body UHC Upazila Health Complex WBM Water-based Macadam WMM Wet-mix Macadam WTP Water Treatment Plant

WEIGHTS AND MEASUREMENTS °C Degree Celsius Ha Hectare Km Kilometer M Meter Mm Millimeter Tk Taka % Percentage

Package: CTEIP/KAL/PT/01: IEE ii Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

TABLE OF CONTENTS EXECUTIVE SUMMARY ...... vi CHAPTER 1: INTRODUCTION ...... 1 1.1 BACKGROUND 1 1.2 PURPOSE OF IEE 3 1.3 SCOPE OF SERVICES 4 1.4 APPROACH AND METHODOLOGY 4 1.5 FORMAT OF THE REPORT 5 CHAPTER 2: POLICY, LEGAL FRAMEWORK AND INSTITUTIONAL CAPACITY ...... 11 2.1 NATIONAL RELEVANT POLICIES AND STRATEGIES 11 2.1.1 National Environmental Policy ...... 11 2.1.2 National Water Policy (NWP) ...... 11 2.1.3 National Forest Policy (NFP 1994) ...... 11 2.1.4 Bangladesh Climate Change Strategy and Action Plan (BCCSAP 2009) ...... 11 2.2 LEGAL INSTRUMENTS 12 2.3 INSTITUTIONAL ARRANGEMENTS / FRAMEWORK 13 2.3.1 Bangladesh Institutional arrangement ...... 13 2.3.2 Department of Environment (DoE) ...... 13 2.3.3 Other relevant departments ...... 14 2.3.4 Environmental approval framework ...... 14 2.3.5 Occupational health and safety ...... 15 2.4 ENVIRONMENTAL CLEARANCE PROCEDURE 15 2.4.1 Bangladesh Environmental Standards ...... 17 2.4.2 Institutional Capacity ...... 18 CHAPTER 3: PROJECT DESCRIPTION ...... 19 3.1 STUDY AREA 19 3.2 EXISTING EVIRONMENT 19 3.2.1 Site 1: proposed PT at Bus Terminal ...... 19 3.2.2 Site 2: proposed PT at Nesariah Madrasa ...... 19 3.3 CONSIDERATIONS FOR PROPOSED PROJECT 20 3.4 LOCATION AND SELECTION OF THE SUBPROJECT 20 3.5 ENVIRONMENTAL CATEGORIZATION 20 3.6 ANALYSIS OF ALTERNATIVES 21 3.6.1 Without Project Alternative ...... 21 3.6.2 With Project Alternative ...... 21 3.7 PROPOSED DEVELOPMENT WORK AND CONSTRUCTION MATERIAL 21 3.8 CONSTRUCTION SCHEDULE 22 CHAPTER 4: ENVIRONMENTAL BASELINES ...... 23 4.1 METHODOLOGY USED FOR THE BASELINE STUDY 23 4.1.1 Secondary data ...... 23 4.1.2 Primary data ...... 23 4.2 PHYSICAL CHARACTERISTICS 23 4.2.1 Topography...... 23 4.2.2 Rainfall and Temperature ...... 23 4.2.3 Hydrology...... 24 4.2.4 Drainage and Flood Control ...... 24 4.2.5 Ambient Air Quality ...... 24 4.2.6 Ambient Noise ...... 24 4.2.7 Water Quality ...... 25 4.2.8 Wind ...... 25

Package: CTEIP/KAL/PT/01: IEE iii Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

4.3 BIOLOGICAL CHARACTERISTICS 26 4.3.1 Vegetation...... 26 4.3.2 Fisheries ...... 27 4.3.3 Agriculture...... 27 4.3.4 Economic Development ...... 27 4.5 SOCIO-ECONOMIC CHARACTERISTICS 27 4.5.1 Population ...... 27 4.5.2 Land use ...... 28 4.5.3 Socio-economic Status ...... 28 4.5.4 Other Existing Amenities for Community Welfare ...... 28 CHAPTER 5: POTENTIAL ENVIRONMENTAL IMPACTS ...... 29 5.1 INTRODUCTION 29 5.1.1 Approach ...... 29 5.2 POSITIVES IMPACTS 31 5.2.1 Impacts during Planning and Design Phase ...... 31 5.2.2 Impacts during Construction Phase ...... 31 5.2.3 Impacts during Project Operation ...... 32 5.3 NEGATIVE IMPACTS 32 5.3.1 Impact during Planning Phase ...... 32 5.3.2 Impact during Construction Phase ...... 32 5.3.3 Impact during Operation Phase ...... 37 5.4 IMPACTS ANALYSIS 37 5.5 CUMULATIVE IMPACT 38 CHAPTER 6: GRIEVANCE REDRESS MECHANISM ...... 45 6.1 GENERAL 45 6.2 GRIEVANCE REDRESS PROCESS 45 6.2.1 1st Level Grievance ...... 45 6.2.2 2nd Level Grievance ...... 45 6.2.3 3rd Level Grievance ...... 46 6.2.4 4th Level Grievance ...... 46 6.3 GRIEVANCE MECHANISM 47 CHAPTER 7: PUBLIC CONSULTATION ...... 48 7.1 PUBLIC CONSULTATIONS AND PARTICIPATION 48 7.2 PUBLIC CONSULTATION TOOLS 48 7.2.1 Public Consultation Meeting (PCM) ...... 48 7.2.2 Focus Group Discussions (FGDs) ...... 49 7.2.3 Stakeholder Consultation ...... 49 7.3 PUBLIC CONSULTATION HISTORY 49 7.4 FINDINGS OF PUBLIC CONSULTATION MEETING 50 CHAPTER 8: CONCLUSION AND RECOMMENDATIONS ...... 52 8.1 CONCLUSIONS 52 8.2 RECOMMENDATIONS 53 8.3 DISCLOSURE OF ENVIRONMENTAL SAFEGUARDS INSTRUMENTS 53 ANNEXURE I: RAPID ENVIRONMENTAL ASSESSMENT CHECKLISTS ...... 54 ANNEXURE II: GRIEVANCE REGISTRATION FORM ...... 55 ANNEXTURE IIIa: CATEGORIZATION FORM ...... 56 ANNEXURE IIIb: INVOLUNTARY RESETTLEMENT IMPACT CATEGORIZATION CHECKLIST ...57 ANNEXURE IV: LIST OF PARTICIPANTS (FGD) ...... 58

Package: CTEIP/KAL/PT/01: IEE iv Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

LIST OF TABLES Table 1 Sub-project‟s Scope of Work ...... 4 Table 2 Applicable GoB Environmental Legislation ...... 12 Table 3 Relevant Occupational Health and Safety Laws and Rules ...... 15 Table 4 DoE Classification according to EC 1997...... 17 Table 5 Relevant Environmental Quality Standards...... 18 Table 6 Typical Project Implementation Schedule ...... 22 Table 7 Ambient Air Quality in Kalapara Pourashava ...... 24 Table 8 Results for Surface Water Quality in Kalapara Pourashava ...... 25 Table 9 Kalapara population data ...... 27 Table 10 Environmental sectors in which the Subproject is expected to have insignificant Impacts ....30 Table 11 Impact Matrix of Potential Environmental Impacts of the subproject ...... 33 Table 12 Noise levels during construction, dB (A) ...... 36 Table 13 Noise due to construction machinery ...... 37 Table 14 Noise generated by various vehicle types in dB(A) ...... 37 Table 15 Impact Analysis matrix for the subproject in question ...... 39 Table 16 Modified Leopold Methodology of Risk Prioritization matrix ...... 41 Table 17 Explanation of color code used for Prioritization matrix ...... 41 Table 18 Potential Impact Prioritization assessment...... 42 Table 19 Summary of the FGDs and Public Consultation ...... 50

LIST OF FIGURES Figure 1 Cyclone risk in 10m low elevation coastal zone of Bangladesh ...... 1 Figure 2 Location map of Kalapara Upazila ...... 3 Figure 3 IEE approach and methodology resulting to EMP ...... 6 Figure 4 Location map of the proposed sub-project (CTEIP/KAL/PT/01) Site 01: Bus Terminal ...... 7 Figure 5 Location map of the proposed sub-project (CTEIP/KAL/PT/01) Site 02: Nesariah Madrasa ... 8 Figure 6 Detail Sketch of PT ...... 9 Figure 7 Bangladesh Environmental Regulatory Approvals Process...... 15 Figure 8 Environmental Clearance Process in Bangladesh ...... 16 Figure 9 Existing environment at Bus Terminal site ...... 19 Figure 10 Existing environment at Nesariah Madrasa ...... 20 Figure 11 Historical temperature (left) and rainfall (right) record in Patuakhali ...... 24 Figure 12 Wind Rose diagram (left) and wind speed graph (right) in Patuakhali ...... 25 Figure 13 Vegetation cover around the PT sites ...... 26 Figure 14 Riverside vegetation around the Bus Terminal PT site ...... 26 Figure 15 Trees to be removed at Nesariah Madrasa Site ...... 35 Figure 16 Grievance redress process ...... 47 Figure 17 FGD at Kalapara PT site ...... 50

Package: CTEIP/KAL/PT/01: IEE v Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

EXECUTIVE SUMMARY i. Coastal region of Bangladesh mostly comprises low-lying areas and is exposed to sea level rise, storm surges and frequent and intense storm events leading to widespread disastrous consequences. Uncontrolled urbanization, coupled with existing inadequate capacities of the Pourashavas to manage requisite infrastructure, makes this region still more vulnerable to adverse impacts of severe and highly variable climatic conditions. Such adverse conditions, along with the burden of increased urban growth, prevailing regional poverty, exacerbated by weak urban governance, have resulted in undue pressure on basic urban services and infrastructure, which has severely impaired economic growth. Because of these natural disasters, the population in the coastal region remains poor and development significantly lags behind the rest of the country even though there is a lot of potential for further development. However, the number, intensity and the regularity of such disasters appear to be increasing and this trend is restricting further development of the coastal region.

ii. The Coastal Towns Environmental Infrastructure Project (CTEIP) is a key infrastructure initiative of the Government of Bangladesh. The intervention is planned to develop climate resilient structures, including Public Toilets infrastructural works. Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali.

iii. The challenge for the project is that the Public Toilets are implemented in the most economically feasible, and environmentally and socially sensitive, manner. The PPTA feasibility study provided a comprehensive set of recommendations for the planning, design and implementation of the Project. Based on the recommendations of this study, the DDS Consultant has completed the detailed engineering design for the construction of the Kalapara Public Toilets.

iv. The proposed locations for the for construction of Public Toilets (Hereinafter referred to as PTs)in Kalapara Pourashava area under the package e-GP/CTEIP/KAL/PT/0was selected based on the recommendations of the PPTA report and subsequent site verification by the DDS Consultant, which is assessed to have minimum environmental impacts. The proposed subproject sites are located in Kalapara Pourashava. The subproject locations are generally undulating but are not located in areas prone to waterlogging and flash flood. There are no protected areas, wetlands, mangroves, or estuaries in or near the subproject location. Trees, vegetation (mostly shrubs and grasses), and animals are those commonly found in urban areas. The subproject sites are not located in or near any historically-, culturally-, archaeologically- or architecturally-significant or tourists area.

v. Categorization: An environmental assessment using ADB‟s Rapid Environmental Assessment (REA) checklist for urban development (Annexure I) was conducted and results of the assessment show that the subproject is unlikely to cause significant adverse impacts. Kalapara PT subproject is classified as environmental category B as per the ADB SPS 2009 as no significant impacts are envisioned. However as per DoE classification, the construction of Public Toilet works falls under engineering works capital greater than Tk100,000 in environmental category Red. The land on which PTs will be constructed is already available with authorities. Hence, there is no problem due to land acquisition, rehabilitation and resettlement. In order to follow ECA, Bangladesh and ADB SPS, this IEE has been conducted and prepared, which provides mitigation and monitoring measures to ensure no significant impacts because of implementation of this subproject.

vi. Initial Environmental Examination of construction PTs under package CTEIP/KAL/PT/0 has followed and fulfilled the requirements of the Environmental Assessment Review Framework (EARF) Subproject Selection Criteria enumerated in the PPTA document. vii. There is no resettlement or land acquisition required in this subproject since the PTs will be built on the open spaces which is without any infrastructure. Minor adverse environmental impacts will occur during the construction period, and will be of a relatively short duration.

Package: CTEIP/KAL/PT/01: IEE vi Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

Adequate provisions have been incorporated into the planning and design of the PTs to minimize or mitigate the unavoidable environmental impacts that are a result of the works. viii. The environmental costs are estimated as Tk 210, 000 refer to Appendix F:See the Environmental Management Plan (EMP), for details of the cost break-up.

ix. The major positive achievements of construction of the PTs are:  The sub project will be beneficial to the citizens of Kalapara Pourashava and the floating population.  It will improve the quality of life of people as well as benefit individual and public health with improvements in hygiene.  This will reduce the incidence of disease associated with poor sanitation.  This will also lead to economic gains as people will be less away from work and indirectly increase their income.

x. The major negative impacts, to be limited within and around the areas of construction sites, will be changes in land use, soil loss in terms of soil erosion from RoWs, borrow-pits, quarries, etc., soil pollution, disruption in drainage patterns, water pollution, air pollution, noise pollution, etc.Therefore the subproject is unlikely to cause significant adverse impacts. The potential adverse impacts that are associated with design, construction, and operation can be mitigated to standard levels without difficulty through proper engineering design and the incorporation or application of recommended mitigation measures and procedures.

xi. The subproject‟s potential cumulative impacts were considered with respect to valued components in environmental and socio-economic categories. There are no foreseeable projects that may overlap with the subproject. xii. Tree plantation is proposed along PTs as protection against negative attributes of climate change phenomena, soil erosion near the road and toward improving the quality of environment. This will keep the ecological function in circulation. The noise impact at source will be mitigated by job rotation and use of earplug and other measures suggested in EMP. xiii. There are limited opportunities to provide environmental enhancements, but certain measures were included. For example it is proposed that the subproject will employ in the workforce people who live in the vicinity of construction sites to provide them with a short-term economic gain; and ensure that people employed in the longer term to maintain and operate the new facilities are residents of nearby communities. Tree plantation and gardening are proposed in the limited areas available in the public toilet compounds. The environmental mitigation measures as stipulated in EMP and in the obtained environmental permit shall be monitored during implementation of the PT sub-project. In order to perform monitoring of EMP, the contractor shall engage experienced laboratory and third party services in complying the required environmental testing of parameters listed in SEMP listed as Annex F. xiv. The labour camps shall be established with the septic tank and soak pit for treatment and disposal of sewage and sludge water to avoid pollution of water bodies. Contractor shall submit the EMP for construction campsite for approval of engineer in charge. In addition, contractor shall arrange water of required quality for the camp and construction activities. xv. The environmental monitoring will be required before the start of the construction and during the construction phase. The parameters of Water Quality, Air Quality, Noise quality, and Soils shall be monitored; as specified in SEMP listed as Annex F. xvi. During public consultation recommendations were drawn including: i) involve local communities in all stages of project planning and development, ii) establish permanent communication between project initiators and local authorities, iii) setup grievance redress mechanism which will publicized through Pourashava level co-ordination committee and monitoring register and iv) during construction, local people including women shall be given first priority in the employment of skilled and unskilled labour.

Package: CTEIP/KAL/PT/01: IEE vii Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) xvii. In view of above, it is concluded that the Project will bring benefit to the people of the area. The negative impacts occurring during implementation are within the manageable limits and shall be mitigated with the proposed Environmental Management Plan and hence project may be implemented. xviii. LGED will disclose this Environmental Management Framework by making copies available at its head office and in District / Pourashava where the Project is situated. The copies shall also be made available to the Local Government‟s Agencies, the Environmental and Social Group and other stakeholders. The Government of Bangladesh will also authorize the Asian Development Bank to disclose this IEE and EMP electronically through its InfoShop

Package: CTEIP/KAL/PT/01: IEE viii Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

CHAPTER 1: INTRODUCTION 1.1 BACKGROUND Coastal region of Bangladesh is densely populated (35.1 millions) and mostly comprised of low lying areas (< 10m) and is exposed to Sea Level Rise (SLR), storm surges and frequent and intense cyclone events leading to widespread disastrous consequences (see Figure 1).

Uncontrolled urbanization, coupled with existing inadequate capacities of the Pourashavas to manage requisite infrastructure makes this region even more vulnerable to adverse impacts of severe and highly variable climatic conditions prevailing in Bangladesh. Such adverse conditions, along with the burden of increased urban growth and prevailing regional poverty exacerbated by weak urban governance, have resulted in undue pressure on basic urban services and infrastructure, which has severely impaired economic growth. Therefore, the population in the coastal region remains poor and development significantly lags behind the rest of the country even though there is a lot of potential for further development. However, the number, intensity and the regularity of such disasters, many of which are related to climate change, appear to be increasing and this trend is restricting further development of the coastal region.

Recently, Climate Change (CC) has become more critical issue, particularly in low lying coastal areas, exposed to SLR. Climate change will exacerbate many of the current problems and natural hazards Bangladesh faces. Floods, droughts, tropical cyclones and storm surges are likely to become more frequent and severe in coming years. The changes will threaten the significant achievements, Bangladesh has made over the last 20 years and it will make it difficult to achieve the Millennium Development Goals. According to IPCC‟s 4th Assessment Report, global warming will result in sea level rises between 0.18 and 0.79 meters1. This has major implications for coastal infrastructure in relation to storm surges and salinity intrusion.

In a recent study2, it was estimated that increased storm surges and growth in the road network, will lead to additional damages of around $239.5 million to roads, bridges, culverts, etc and a loss of about $52.7 million in road infrastructures.6 These estimates are based on repair and damage costs from Figure 1Cyclone risk in 10m low elevation coastal zone of Bangladesh the 2007 Sidr cyclone As well the increased risk of flooding, sea level rise will also increase saline intrusion of water supply sources (both surface water, and shallow groundwater), which will deteriorate water quality and the

1 IPCC. (2007). Climate Change 2007: Impacts, Adaptation and Vulnerability: Summary for Policymakers. Working Group II Contribution to the Intergovernmental Panel on Climate Change Fourth Assessment Report. IPCC, Geneva. 2Dasgupta, S., Huq, M., Khan, Z.H., Ahmed, M.M.Z., Mukherjee, N., Khan, M.F., Pandey, K. (2010). Vulnerability of Bangladesh to Cyclones in a Changing Climate: Potential Damages and Adaptation Cost\ Policy Research Working Paper, 5280, World Bank.

Package: CTEIP/KAL/PT/01: IEE 1 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) availability of potable water, with disproportionate impacts to women and the poor, including impacts on maternal health. Backup of sewage and water logging due to inadequate drainage will result in a deterioration of public health through the increased prevalence of waterborne diseases. The Coastal Towns Environmental Infrastructure Project (CTEIP) is a key infrastructure initiative of the Government of Bangladesh. The Project was prioritized in the Government's 2010 Strategic Programme for Climate Resilience (SPCR), prepared under the Pilot Program for Climate Resilience (PPCR), whereby the CTEIP is eligible for financing from the Strategic Climate Fund (SCF) within the multi-donor coordinated Climate Investment Funds (CIF) as a pilot project for demonstrating ways to mainstream climate resilience into development. Intervention is planned to develop climate resilient structures, including Cyclone Shelters; roads and bridges; water supply; sanitation; drainage; solid waste management; municipal facilities and flood protection infrastructural works.

Kalapara Upazila is a coastal region located in Patuakhali district, Bangladesh with an area of 483.08 sq km, located in between 21°48' and 22°05' north latitudes and in between 90°05' and 90°20' east longitudes The Pourashava is bounded by Dhanisafa Union to the north, Bara Masua Union to the west, Tushkhali to the north and Tikikata Union to the south-east.(Figure 2).The upazila is vulnerable to frequent cyclones and storm surges that originate from the Bay of Bengal. The PTs are designed to meet all weather requirements This Initial Environmental Examination (IEE) has been conducted by EPTISA Services de Ingenieria S.L., the Detailed Design Services (DDS) Consultant under the CTEIP, in accordance with the ADB‟s requirements and guidelines. The IEE is based upon a study of available reports and documents, including the Project Preparatory Technical Assistance (PPTA), under TA 8128 BAN; relevant sections of the Capacity Development Technical Assistance (CDTA) Report; discussions with related stakeholders and PIU/Pourashava authorities. Read this IEE in conjunction with the following documents, attached to this Bid Document:

 Environmental Management Plan (EMP) attached hereto as Appendix F;  Resettlement Plan (RP): (Due Diligence Report) attached hereto as Appendix G;  Gender Action Plan (GAP) attached hereto as Appendix H.

Package: CTEIP/KAL/PT/01: IEE 2 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

Source: Banglapedia Figure 2 Location map of Kalapara Upazila

1.2 PURPOSE OF IEE The initial environmental examination aims to provide guidance on safeguard screening, assessment, institutional arrangement and process to be followed for components of the project, where design takes place after Boards approval. This IEE (i) describes the project and its components; (ii) explains the general anticipated environmental impacts and mitigation measures for the subprojects; (iii) specifies the requirements that will be followed in relation to screening and categorization, assessment, and planning, including arrangements for meaningful consultation with affected people and other stakeholders and information disclosure requirements; (iv) assesses the capability of the project proponents to implement national laws and ADB‟s requirements, and identifies needs for capacity building; (v) specifies implementation procedures, institutional arrangements, and capacity development requirements; and (vi) specifies monitoring and reporting requirements. Moreover, this IEE is to ensure, in line with ADB EARF, that the PT project, in the entirety of its project cycle, will not deteriorate or interfere with the environmental sensitivity of the project area, but rather improve environmental quality.

Package: CTEIP/KAL/PT/01: IEE 3 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

1.3 SCOPE OF SERVICES The scope of the project includes nine infrastructure categories: (i) roads, bridges and culverts, (ii) solid waste management, (iii) cyclone shelters, (iv) Cyclone Shelter and Access Roads, (v) markets, (vi) bus terminals, (vii) drainage and flood control, (viii) water supply, and (ix) sanitation. The major components to be taken up in Kalapara under this project are described in Table 1. This report is on IEE of construction of 2 Public Toilets (PTs) in Kalapara Pourashava and the package is designated as e-GP/CTEIP/KAL/PT/0.

The proposed sites for the PTs under Kalapara Pourashava, District: Patuakhali are located within the Pourashava area, which are mostly within urban and semi urban areas. This subproject e- GP/CTEIP/2017-18/KAL/PT/01 includes the construction of 2 PTs, one located in the Kalapara Bus Terminal and the other one located at the Khepupara Nesaruddin Fazil Madrasa (see Figure 4and Figure 5).See Table 1 for the summarized scope of work.

The PTs will be CC paved with two ramps on the sides. Separate male-female basin areas are designated. The detailed sketch of the PTs are provided in Figure 6.

Table 1Sub-project’s Scope of Work

Sl.No. Name of components Nos. Feature Type of Pavement

1 Front area 1 2.809m wide CC Pavement 2 Ramp 2 1.000m wide CC Pavement 3 Urinal 1 For male only 4 Bath, utility (storage), room for 1 each caretaker 5 WC for Handicapped 2 1 for male, 1 for female Source: Detailed Design Report 2018

The scope of work includes ensuring that construction and/ or implemented of the works will be in an environmentally sustainable manner and in full compliance with Bangladesh‟s and the Asian Development Bank‟s environmental safeguard policies and regulations. The scope of services in brief is as follows:

 Document baseline data for various environmental attributes on physical, water, ecological pollution and physical cultural resources and Socio-economic profile;  Assess positive and negative environmental impacts of the proposed works;  Prepare environmental mitigation measures and management plans to effectively address the impacts;  Prepare IEE so that these are acceptable to Department of Environment (DoE), Bangladesh and the Asian Development Bank;  Prepare post-project monitoring programs, institutional arrangement to implement the environmental plans; and  Prepare cost estimates for the management and monitoring programs.

1.4 APPROACH AND METHODOLOGY The package CTEIP/KAL/PT/01has followed the Environmental Assessment Review Framework (EARF) subproject selection criteria as enumerated in PPTA document. The approach in preparation of Initial Environmental Examination has been to follow the sequence of steps adopted in an EIA study in relation to EARF. Apart from following standard environmental impact assessment practices and procedures, methodologies have deployed advanced technologies, techniques and tools to the extent these are applicable and relevant to this project. The approach and methodology flow chart are presented in Figure3. Toward ascertaining baseline conditions and assessing the impacts during construction and operation of the project, the consultants have taken into account the various parameters of the environment – topography, physiography, soils, hydrology and drainage,

Package: CTEIP/KAL/PT/01: IEE 4 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) meteorology, qualities of ambient air and noise, surface water, groundwater, biodiversity, socio- economic aspects including gender issues, land/property, physical and cultural resources. The baseline data for environmental attributes were collected from primary and secondary sources. The primary sources include site visits and visual inspection. The secondary sources include the reports, books, maps and documents from various government and non-government organizations on subject matter. The impacts are assessed for various phases of project cycle namely:  Impacts due to project location and design,  Impacts due to project construction, and  Impacts due to project operation.

1. The impacts are categorized as negative and positive. The standard methodology for the review, field visit data collection, impact assessment and formulation of management plans is adopted. The Bangladesh National Acts, Legislation and Laws were consulted with a view to ensuring compliance with various requirements. The environmental attributes were compiled from both primary and secondary sources. 2. The management plans are essential to ensure that stress/ loads on the systems are within carrying capacity. The management plan aims at maintaining the environmental quality of project area at-least in pre-project stage. An environmental management strategy/ plans was developed to mitigate the adverse impacts. Efforts are made to enhance the quality of environmental attributes. 3. It is necessary to monitor the environmental attributes during construction and operation. Monitoring would indicate any environmental problems, which have reviewed. This will facilitate to assess the effectiveness of management and/or mitigation measures. 4. 1.5 FORMAT OF THE REPORT

This report has been prepared taking into consideration the IEE mechanisms, procedures and contents spelt out in Environmental Conservation Act of 1995 and its amendments in 2000, 2002 and 20103 of Bangladesh and ADB Environmental Assessment Guidelines (2003) and Safeguard policy statement (2009). The main findings are reported in conclusions and recommendations for discloser locally and the ADB web site. The report has an Executive Summary in the beginning.  Chapter 1introduces the project along with the project background, objectives and scope of the study and an outline on the approach and methodology adopted for the study.  Chapter 2 is a concise document on the policy and strategies; legal instruments, and institutional arrangement under which the project will be developed.  Chapter 3 is on the Project Description, which highlights the need for the development. The project Construction Schedules material requirements and cost of project are also summarized.  Chapter 4 is on the baseline environmental and social conditions in pre-construction phase in sufficient detail to enable an adequate assessment of the potential environmental and social impacts.  Chapter 5 is on Screening of Potential Environmental Impacts and describes the environmental impacts that could occur because of the proposed project.  Chapter 6 is on Grievance Redress Mechanism;  Chapter 7 is on public consultation;  Chapter 8 is on Conclusion and Recommendations.

The literature, books, reports and maps referred are presented as footnotes in the main body of the report. At the end, the report has Annexure, which are reported in the main body of the report.

3ECA Amendment 2000 focuses on ascertaining responsibility for compensation in cases of damage to ecosystems, increased provision of punitive measures both for fines and imprisonment and the authority to take cognizance of offences. ECA Amendment 2002 elaborates restrictions on polluting automobiles; restrictions on sale, production of environmentally harmful items like polythene bags; assistance from law enforcement agencies for environmental actions; break up of punitive measures; and authority to try environmental cases. In ECA Amendment 2010, no individual or institution (government or semi- government/non-government/ self-governing can cut any hill or hillock; earth-fill or change the status of any water body/wetland/lakes/natural canals, etc., even in national interest; the aforementioned activities can be done only after getting clearance from respective the departments/agencies/authorities.

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DESK RESEARCH

- Lit review - Acts and legislation - Reconnaissance - Discussion

SCOPING FIELD VISIT

- Screening - GPS analysis - Method development - Visual analysis - Identification of parameters - Photographic documentation - Etc.

ECOLOGY POLLUTION PHYSICAL SOCIAL

- Flora - Water - Topography - Demography - Fauna - Air - Hydrology - Infrastructure - Fisheries and - Noise - Land use - Cultural forestry - Soil - Drainage resources - Food chain - Economy - Education

ENVIRONMENTAL BASELINE PUBLIC CONSULTATION

- Compilation of baseline data - Collect public opinion - Cross check and superimposition - Share info with stakeholders with design - Analysis and interpretation

ANALYSIS AND SCREENING OF No Impact ENVIRONMENTAL IMPACTS

Impact

POTENTIAL ENVIRONMENTAL IMPACT ASSESSMENT FIELD VERIFICATION (IEE) - Review for actual cost - Review for applicability PREPARATION OF EMP - Rationale

ENV MONITORING PROGRAMS

Figure 3 IEE approach and methodology resulting to EMP

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Figure 4 Location map of the proposed sub-project (CTEIP/KAL/PT/01) Site 01: Bus Terminal

Package: CTEIP/KAL/PT/01: IEE 7 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

Figure 5 Location map of the proposed sub-project (CTEIP/KAL/PT/01) Site 02: Nesaruddin Madrasa

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Figure 6 Detail Sketch of PT

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Package: CTEIP/KAL/PT/01: IEE 10 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

CHAPTER 2: POLICY, LEGAL FRAMEWORK AND INSTITUTIONAL CAPACITY

2.1 NATIONAL RELEVANT POLICIES AND STRATEGIES

This Section describes the relevant policies and strategies, legal instruments, institutional arrangement and framework applicable to CTEIP-related rehabilitation and /or construction activities in various Pourashava areas in the Bangladesh coastal region. It summarizes the National Laws and describes the procedure for obtaining environmental permits to allow project implementation. Over the years the Government of Bangladesh has enacted environmental acts, rules, policies and regulation toward imposing restrictions facilitating minimization / mitigation of likely impacts due to development projects. The most important Act is Environmental Conservation Act, 1995 (ECA, 1995) and Environmental Conservation Rules (ECR, 1997).

2.1.1 National Environmental Policy

The National Environmental Policy was adopted in 1992 and is now under revision. It embraces different sectors related to agriculture, forest, power, health, transport, housing etc. The central theme of policy is to ensure protection and improvement in environment. The policy gives a thrust to sustainable development and long-term use of natural resources. The National Environment Policy contains policy statements and strategic options with regard to population and land-use management, management and utilization of natural resources and other socio-economic sectors, as well as the necessary arrangements for the implementation of the policy. The policy enables:

 the country to strike a dynamic balance between population and resources while complying with the balance of ecosystems;  to contribute to sustainable and harmonious socio-economic development such that, both in rural and urban areas, and well-being in a sound and enjoyable environment; and  To protect, conserve and develop natural environment.

2.1.2 National Water Policy (NWP)

The National Water Policy 2004 (NWP) aims for sustainable management of water. The Policy also integrates the environmental impact assessment for water development projects. The policy stresses on issues related to climate change such as:

 Augmentation of dry season flows;  Awareness raising in consumptive use of surface and ground water;  Structural and non-structural mitigation measures (early warning systems).

2.1.3 National Forest Policy (NFP 1994)

National Forest Policy (NFP) was established in 1994. Under this policy it is proposed to increase the forest cover and to promote and oversee forestry activities. The policy fixed the target of forest cover at least 20% of geographic area by the year 2015. Tree plantation on the roadside verges courtyards of rural organization such as Union Parishad, school, Eidgah, mosque-Moktob, temple, club, orphanage home, madrassa etc. and other fallow lands around will be encouraged. The government will encourage this type of initiative and extend technical and other supports.

2.1.4Bangladesh Climate Change Strategy and Action Plan (BCCSAP 2009)

The Bangladesh climate change strategy and action plan was approved in 2009. The climate change plan is built on six pillars namely i) food security, social protection and health; ii) Comprehensive Disaster Management; iii) infrastructure; iv) research and knowledge management; v) Mitigation and low carbon development; and vi) capacity building and institutional. The strategy and action plan emphasize on eensuring existing assets (e.g., coastal and river embankments) are well maintained and fit for purpose and that urgently needed infrastructure is put in place to deal with the likely impacts

Package: CTEIP/KAL/PT/01: IEE 11 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) of climate change. - enhance the capacity government ministries, civil society and private sector to meet the challenge of climate change.

2.2 LEGAL INSTRUMENTS

The environmental policies are prepared by the Ministry of Environment and Forests (MoEF). MoEF also has formulated regulation toward clearance of projects from environmental angles based on environmental impact assessment report. The Department of Environment is responsible for environmental issues while forest issues are looked after Department of Forests. Over the years the MoEF has adopted number of legal instrument in the form Acts for the protection and conservation of the environment. Table 2 summarizes the Environmental Legislation applicable to the sub-project.

Table 2 Applicable GoB Environmental Legislation

Sl.No Legislation Requirement for the Project Relevance

1 Environmental  Restriction on operation and process, which can be The provisions of the Act apply to Conservation Act of continued or cannot be initiated in the ecologically the entire subproject in the 1995 and amendments critical areas construction and operation and in 2000, 2002and  Regulation on vehicles emitting smoke harmful to the maintenance (O&M) phases. 20104 environment  Remedial measures for injuries to ecosystems  Standards for quality of air, water, noise and soil for different areas and limits for discharging and emitting waste  Environmental guidelines 2 Environmental  Environmental clearances The subproject is categorized as Conservation Rules of  Compliance to environmental quality standards RED and requires LCC and ECC. 1997 and amendments All requisite clearances from DoE in 2002 and 2003 shall be obtained prior to commencement of civil works.

3 Forest Act of 1927 and  Clearance for any felling, extraction, and transport of Refer to Baseline and EMP amendments (2000) forest produce 4 Bangladesh Climate  Ensure existing assets (e.g., coastal and river Considered in project design Change Strategy and embankments) are well maintained and fit for purpose components Action Plan of 2009 and that urgently needed infrastructure is put in place to deal with the likely impacts of climate change.  Enhance the capacity government ministries, civil society and private sector to meet the challenge of climate change 5 Bangladesh Labor Law  Compliance to the provisions on employment The provisions of the act apply to of 2006 standards, occupational safety and health, welfare the entire subproject in the and social protection, labor relations and social construction and O&M phases. dialogue, and enforcement Provides the safety of workforce  Prohibition of employment of children and adolescent during construction phase.

(Source: TA 8128 Coastal Towns Infrastructure Improvement Project Volume 6)

4ECA Amendment 2000 focuses on ascertaining responsibility for compensation in cases of damage to ecosystems, increased provision of punitive measures both for fines and imprisonment and the authority to take cognizance of offences. ECA Amendment 2002 elaborates restrictions on polluting automobiles; restrictions on sale, production of environmentally harmful items like polythene bags; assistance from law enforcement agencies for environmental actions; break up of punitive measures; and authority to try environmental cases. In ECA Amendment 2010, no individual or institution (government or semi-government/non-government/ self-governing can raise any hill or hillock; earth-fill or change the status any water body/wetland/lake/natural canal, etc., even in national interest; the aforementioned activities can be done only after getting clearance from respective departments.

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2.3 INSTITUTIONAL ARRANGEMENTS / FRAMEWORK

2.3.1 Bangladesh Institutional arrangement

The environmental approvals process in Bangladesh is overseen by the Department of Environment (DoE), under the auspices of the Ministry of Environment and Forests (MoEF). The key national regulations which drive this process are:  Bangladesh Environment Conservation Act, 1995 (ECA) and associated amendments - the ECA is the overall instrument which authorizes DoE to establish the EIA process and associated regulations.  Environment Conservation Rules, 1997 (ECR) and associated amendments - the ECR provides the framework to the IEE/EIA process including the phasing of the various steps of the studies, and categorization of various industry types based on regulatory requirements. These regulations also provide various complimentary regulations such as effluent discharge and air emissions limits for industries. DoE has also published the EIA Guidelines for Industries, 1997 (EIAGI)–while not a formal regulatory instrument, this is currently the official industry guideline for preparing IEE/EIA studies in Bangladesh in accordance with the requirements of the ECR.

2.3.2 Department of Environment (DoE)

The main Ministry, Department, Institutions and Boards responsible for development of policy, framing regulation, developing projects, monitoring and approval of issues related to environment protection and conservation are presented in this section. The Department of Environment (DoE) was established in 1977 under the Environment Pollution Control Ordinance, 1977. During 1987-89, Forestry was a Division of Agriculture Ministry with a Secretary to Government in charge of the Forestry Division. With the formation of the new Ministry of Environment and Forests, in 1989, both the departments were transferred to this new Ministry. The DoE has been placed under the MoEF as its technical wing and is statutorily responsible for the implementation of the Environment Conservation Act, 1995. Besides these two departments, MoEF controls the Bangladesh Forest Industries Development Corporation (BFIDC), Bangladesh Forest Research Institute (BFRI) and Bangladesh National Herbarium (BNH).

The Ministry of Environment & Forests is the nodal agency in the administrative structure of the Central Government, for the planning, promotion, co-ordination and overseeing the implementation of environmental and forestry programmes. MoEF oversees all environmental matters in the country and is a permanent member of the Executive Committee of the National Economic Council. The Ministry also plays a pivotal role as a participant of United Nations Environment Programme (UNEP). The principal activities undertaken by Ministry of Environment & Forests consist of conservation & survey of flora, fauna, forests and wildlife, prevention & control of pollution, forestation & regeneration of degraded areas and protection of environment, in the framework of legislations. The main tools utilized for this include surveys, impact assessment, control of pollution, regeneration programmes, support to organizations, research to solve solutions and training to augment the requisite manpower, collection and dissemination of environmental information and creation of environmental awareness among all sectors of the country's population. The organizational structure of the ministry covers a number of divisions, directorate, board, subordinate offices, autonomous institutions and public sector undertakings. In short, Ministry of Environment & Forest (MoEF) has the following major functions:

A. Management of environment and ecology. B. Matters relating to environment pollution control. C. Conservation of forests and development of forest resources (government and private), forest inventory, grading and quality control of forest products. D. Forestation and regeneration of forest extraction of forest produce. E. Plantation of exotic cinchona and rubber. F. Botanical gardens and botanical surveys. G. Tree plantation.

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H. Planning cell is responsible for preparation of schemes and coordination in respect of forest. I. Research and training in forestry. J. Mechanized forestry operations. K. Protection of wild birds and animals and establishment of sanctuaries. L. Matters relating to marketing of forest produce. M. Liaison with international organizations and matters relating to treaties and agreements with other countries and world bodies relating to subjects allotted to this Ministry.

2.3.3 Other relevant departments

Apart from two major departments, i.e., Department of Environment and Department of Forest, working under this ministry, there are two others as discussed below:

 Bangladesh Forest Research Institute (BFRI)is mandated to provide research support to the Forestry sub-sector of the country, including Forest Department, Bangladesh Forest Industries Development Corporation, NGO and other private enterprises. BFRI's research activities aim to develop appropriate technologies to maintain sustainable productivity of forest land and of forest industries without resource depletion.  Bangladesh National Herbarium (BNH) is a plant survey, collection, identification and conservation organization. It documents the plant biological diversity of the country and its collections are accessible samples of natural population. The collection of the herbarium is a national property that goes down to the posterity through generation for hundreds of years and work as reference materials on the flora of the country. The National Herbarium serves as repository of technical information on plant genetic resources and advises the Government on technical aspects of question dealt with by the herbarium. It also provides direction required in the implementation of policies laid down by the Government in relation to plant biodiversity conservation.

2.3.4 Environmental approval framework

7Key milestones in the approvals process are outlined in Figure 7. These comprise:  Project Authorization Letter: Formal authorization of the Project by the Department of Energy and Mineral Resources is required in order for the environmental approvals process to formally commence.  No Objection Certificate (NOC) – An NOC must be received from the Deputy Commissioner in the sub-project area before the SCC application can be made.

 Site Clearance Certificate (SCC) – An SCC will be issued by DoE upon approval of the IEE study (note that the IEE submission is to include the Project Authorization Letter, NOC and SCC application form). The SCC will include a ToR for the IEE/EIA study, and typically provides authorization for site establishment works5 to commence.  Environmental Clearance Certificate (ECC) – The ECC will be issued by DoE upon approval of the EIA study (including associated EMP). The ECC allows project construction to commence, and contains specific approvals requirements for matters such as pollution control and environmental monitoring.

5This typically includes activities such as site clearing, construction of access roads and site fencing.

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Figure 7 Bangladesh Environmental Regulatory Approvals Process

2.3.5 Occupational health and safety

During construction, the project will conform to the labor laws and occupational and health related rules as outlined in Table 3.

Table 3Relevant Occupational Health and Safety Laws and Rules

Title Overview Bangladesh Labor Act, 2006 Provides for safety of work force during construction period. The act provides guidance of employer’s extent of responsibility and the worker’s right to compensation in case of injury caused by accident while working. Sewerage Authority Act, 1996 The act calls for ensuring water supply and sewerage system to the public, preservation of system, and other related health and environmental facilities for the community. Labor Relations under Labor General concerns during the project implementation state that the project manager must Laws, 1996 recognize labor unions. Public Health (Emergency Calls for special provisions with regard to public health. In case of emergency, it is Provisions) Ordinance, 1994 necessary to make special provisions for preventing the spread of disease, safeguarding the public health, and providing adequate medical service, and other services essential to the health of respective communities and workers during construction-related work. The Employees State Health, injury and sickness benefit should be paid. Insurance Act, 1948 The Employer's Liability Act, Covers accidents, risks, and damages with respect to employment injuries 1938 Maternity Benefit Act, 1950 Framed rules for female employees, who are entitled to various benefits for maternity Source: Bangladesh Government Rules and Regulation book.

2.4 ENVIRONMENTAL CLEARANCE PROCEDURE

Under ECR 1997 industrial units and projects are classified into four categories according to “their site and impact on the environment”, and each category (Green, Orange-A, Orange-B and Red) requires a

Package: CTEIP/KAL/PT/01: IEE 15 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) different level of environmental assessment as a prerequisite for granting the ECC that allows the project to proceed. The Environmental Clearance Certification Process is shown in Figure 7.

Figure 8 Environmental Clearance Process in Bangladesh Rule 7 of the ECR indicates that the application for ECC must be made to the relevant DoE Divisional Officer, and the application for RED category projects will include the following:

 Completed Application for ECC, and the appropriate fee;  Report on the feasibility of the project;  Report on the IEE for the project;  Report on the environmental management plan (EMP);  No objection certificate from the local authority;  Emergency plan relating to adverse environmental impact and plan for  Mitigation of the effect of pollution; and  Outline of the relocation and rehabilitation plan (where applicable).

Under the ECR, DoE has 30 days to respond to receipt of the ECC application for an RED category project.

2.4.1Environmental Category: Bangladesh

For the purpose of issuance of Environmental Clearance Certificate, the industrial units and projects shall, in consideration of their site and impact on the environment, be classified into the following four categories: (a) Green; (b) Orange – A; (c) Orange – B; and (d) Red. The Industries and projects included in the various categories are specified in sub-rule (1) have been described in Schedule – 1.

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The ECA indicates that all industrial units or projects must obtain a Location Clearance Certificate (LCC) and Environmental Clearance Certificate (ECC) from the Department of Environment (DoE). No industrial unit or project shall be established or undertaken without obtaining environmental clearance from DoE in the manner prescribed by the rules. The environmental category of projects is listed in Schedule – 1 of ECR and the PT construction sub-project in Kalapara falls in RED.Table 4 describes DoE classification for Engineering works.

Table 4 DoE Classification according to EC 1997

Sl.No Components Items in Schedule-1 of ECR DOE Classification

1 Sl. No. 60 of ECR Engineering Works: Capital above 10 (ten) hundred thousand Taka RED

Source: ECR 1997

2.4.2 Environmental Category: ADB

Asian Development Bank (ADB) requires the consideration of environmental issues in all aspects of ADB‟s operations, and the requirements for environmental assessment are described in ADB SPS (2009). This states that ADB requires environmental assessment of all project loans, program loans, sector loans, sector development program loans, loans involving financial intermediaries, and private sector loans.

Screening and categorization: The nature of the environmental assessment required for a project depends on the significance of its environmental impacts, which are related to the type and location of the project; the sensitivity, scale, nature, and magnitude of its potential impacts; and the availability of cost-effective mitigation measures. Projects are screened for their expected environmental impacts, and are assigned to one of the following four categories:

 Category A: Projects could have significant adverse environmental impacts. An EIA is required to address significant impacts.

 Category B: Projects could have some adverse environmental impacts, but of lesser degree or significance than those in category A. An IEE is required to determine whether significant environmental impacts warranting an EIA are likely. If an EIA is not needed, the IEE is regarded as the final environmental assessment report.

 Category C: Projects are unlikely to have adverse environmental impacts. No EIA or IEE is required, although environmental implications are reviewed.

 Category FI: Projects involve a credit line through a financial intermediary or an equity investment in a financial intermediary. The financial intermediary must apply an environmental management system, unless all projects will result in insignificant impacts.

As per above ADB environmental classification, the sub-project in Kalapara falls in Category B.

2.4.1Bangladesh Environmental Standards

The Ministry of Environment and Forest has developed standards from time to time for water and air quality for discharge in the ambient air. The relevant standards are summarized in Table 5.

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Table 5Relevant Environmental Quality Standards

Sl. No Standards ECR 1997 Rule 1 Air Quality Schedule 2 2 Inland Surface Waters Schedule 3 3 Drinking Water Schedule 3 4 Noise Schedule 4 5 Sound from Motor Vehicles Schedule 5 6 Emission from Motor Vehicles Schedule 6 7 Odor Schedule 8 8 Sewage Discharge Schedule 9 9 Waste water from Industrial Units Schedule 10 Source: ECR 1997

2.4.2Institutional Capacity

The MoEF has the capacity to formulate policy, legislation, standards and review the environmental impact assessment (EIA) of the development projects. The project is cleared by two committees. The Pourashava gives the site clearance by location clearance committee (LCC). The project is submitted to DoE for environmental clearance committee (ECC). The projects are implemented at local or Pourashava level and executed at central level. Local Government Engineering Department (LGED) executes the projects on water supply, sewerage, solid waste management, etc. The environmental impact assessment is conducted by the consulting agencies by outsourcing. The sphere of LGED activities is for a better environment and health. Most of the engineers involved with design and construction activities are familiar with the environmental issues. LGED has also appointed an Executive level officer to look into the critical issues. The LGED is assisted by consultants for monitoring of environmental attributes and training. LGED has established a quality control lab where parameters related to water, waste water and soils can be monitored. However, there is a scope to train engineers at each level for conducting environmental impact assessment and preparation of management plans. Further, to avoid adverse negative environmental impacts of a proposed works, no contract tender should be launched before specific IEE / EIA based on final design is prepared, DoE approve the EMP with the management measures.

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CHAPTER 3: PROJECT DESCRIPTION

3.1 STUDY AREA

Kalapara is located in Patuakhali District of Barisal Division on the southern part of Bengal Basin making a part of Barisal Gravity High. It is the largest Upazila of Patuakhali District in respect of both area and population. Kalapara is located between 21o48' and 22o36 north and between 90o08 and 90o41 east. It is bounded on the north by Barisal zila, on the east by Bhola zila, on the south by the Bay of Bengal and on the west by Kalapara.

Ground-level elevation of Kalapara varies between 1.5m and 4.2m above sea-level with an average elevation of about 2.43m. Subproject components are located in Kalapara urban area or in its immediate surroundings which became a police station in 1873, an Upazila in 1983 and a Class-B Pourashava in 2010. The subproject sites are located in existing right of way (RoWs) and government-owned land. There is no natural habitat left at these sites. There are, as well, no protected areas, wetlands, mangroves, or estuaries in or near the subproject location. There are no forest areas either, within or near Kalapara. The location map is shown in Figure 2 in Chapter 1.

3.2 EXISTING EVIRONMENT

Two nos. of PTs are to be constructed in the subproject under package CTEIP/KAL/PT/01. Existing environment around this proposed package are described in the next paragraphs.

3.2.1 Site 1: proposed PT at Bus Terminal

 Feature: Construction of Public Toilet at Kalapara Bus Terminal with separate male-female WCs and WC for the handicapped. Existing Environment

The proposed PT is beside the Kalapara Bus Stand. The Bust Stand is located at the Dhaka- Kukata Highwaywhich is also a junction of two local roads. The north face of the bust stand is towards the Andermanik River. The site is devoid of vegetation. Some temoprary structures are also found at the bust stand which are used for various purposed like storage, dumping etc. except for the Andhermanik river, there are two additional waterbodies nearby, i.e. two ponds. See Figure 9 for details.

3.2.2Site 2: proposed PT at Khepupara Nesaruddin Fazil Madrasa

 Feature: Construction of Public Toilet at Khepupara Nesaruddin Fazil Madrasa with Figure 9 Existing environment at Bus Terminal site separate male-female WCs and WC for the handicapped.

Package: CTEIP/KAL/PT/01: IEE 19 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

Existing Environment

The proposed PT is located at the Khepupara Nesaruddin Fazil Madrasa. The site is located between a road and a pond. The site has vegetation including large plants on the road side. Some photos are

Figure 10 Existing environment at Khepupara Nesaruddin Fazil Madrasa presented in Figure 10 that explains the present condition of the proposed site.

3.3 CONSIDERATIONS FOR PROPOSED PROJECT

PT construction under the subproject is considered using the following utilization factors: (i) leading to existing and proposed works, or any other establishment used as a shelter during disasters; (ii) used for key public safety and health care facilities for post-disaster response; (iii) critical for emergency evacuation during disasters; (iv) access for emergency services, and provision of post-disaster recovery and reconstruction goods (relief workers, food, medical supplies, etc.); (v) contributing to flood defenses and vulnerable areas; (vi) frequently inundated due to floods; and (vii) serving slum areas. Simultaneously with consideration of the above factors, assessment has also been made of each of the subproject PTs against whether: (i) existing crest level is 600 millimeters (mm) above existing normal flood level; (ii) embankments are protected against surges; and (iii) drainage is adequate to accommodate storm flows toward ensuring resilience to climate change and other disaster-related phenomena.

3.4 LOCATION AND SELECTION OF THE SUBPROJECT

The proposed sites for construction of the PT is located within the Pourashava area, which is mostly semi-urban area. The PTs are designed as an important infrastructure for local citizens and floating people.The proposed sites are aready under pourashava‟s jurisdiction, therefore no land acquisition will be required.

The following have been considered during selection of the subproject:

 The Pourashava will own the PTs.  There are no existing toilet facilities in the Pourashava  The river is just near the river, which might need additional projection for the toilet to resist any leakage. The design included such possibilities.

3.5 ENVIRONMENTAL CATEGORIZATION As mentioned earlier in this report, the construction of the proposed works, as per ECA 1995 classification and ADB SPS 2009 categorization, falls in Bangladesh environmental category RED and in ADB SPS category B, respectively. As a consequence of the construction of the proposed works, which entails improvement of existing infrastructure and existing RoW‟s, there is no problem

Package: CTEIP/KAL/PT/01: IEE 20 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) due to land acquisition, rehabilitation and resettlement. The environmental issues related to construction are anticipated during construction phase. IEE has, hence, been conducted following ECA, Bangladesh and ADB SPS 2009. The potential adverse environmental impacts are mainly related to the construction period, which can be minimized by the mitigating measures and by adopting environmentally sound engineering and construction practices as referred to in the Environmental Management Plan (EMP).

3.6 ANALYSIS OF ALTERNATIVES

Various options were explored during the IEE stage of the proposed PT construction project and were weighed from all considerations such as cost, environment, and ease of implementation and maximum utilization of available infrastructure. The aim of alternative analysis has been to arrive at a development option, which maximizes the benefits while minimizing the adverse impacts. The two alternatives were considered “No Project Scenario” and “With Project Scenario”. More alternatives are presented along with environmental management plan.

3.6.1 Without Project Alternative

The „No Project Option‟ in respect to the proposed project implies that the status quo is maintained. This option may be suitable alternative from an environmental perspective as it ensures non- interference with the existing environmental conditions. This option will however, involve several losses on socioeconomic condition both to the local population and the nation as a whole. The local farmers/ population will continue to face the constraints they are currently experiencing due to inefficient transport network and system and the anticipated economic development aimed at fulfilling the infrastructure gap remain unattainable. The „No Project Option‟ is the least preferred from the socio-economic and partly environmental perspective due to the following factors:

 The socio-economic status of the Kalapara residents would remain unchanged with reduced interaction both at local and national levels;  The local skills would remain under-utilized as no employment opportunities will be created for local population who would have otherwise worked at the project area;  Reduced hygienecondition due to current non-existing infrastructure;  No project scenario case will also avoid social impacts due to the implementation of the project.

3.6.2 With Project Alternative

Implementation of the project will contribute to socioeconomic improvement and will have positive impacts on residents‟ life quality. The „With Project Alternative‟ has the following advantages:

 There will be improved and assured hygiene facilities to the residents of the Pourashava/District.  Construction of PT will stimulate hygiene as well as socio-economic development of the area.

3.7 PROPOSED DEVELOPMENT WORK AND CONSTRUCTION MATERIAL

The Kalapara PT sub-project proposes the construction of 02 PTs. Bidding process shall not be launched for the sub-project until ECC is obtained. The design report summarizes the quantities of construction material6. These have been further utilized in assessing the environmental impact due to construction of PTs. Part 1 of detailed estimate section of DED report summarizes the proposed development work and construction material needed. Section 3.8 gives a list of activity to be performed during the construction of the sub-project.

6 Detailed Design Report PAT/RD/01. LGED: December 2017

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3.8 CONSTRUCTION SCHEDULE

Construction schedule of Roads depends on the methodology adopted for construction. In general, the time period will also depend on the resources put in place by the contractor. Designs were finalized in December 2017. The package for the construction of the Kalapara PT is proposed to be implemented by post-qualified contractors under a single envelope single stage bidding process through National Competitive Bidding (NCB) procedures. The sub-project may take about 12 months for construction. A Typical Construction Schedule is shown in Table 6 including pre-construction and post construction activities. The post construction will also include defect liability period of 12 months.

Table 6 Typical Project Implementation Schedule

Duration of month (number) Pre- Construction Post-construction Activity construction

12 14 16 18 20 22 24 26 27 28 30 ------2 4 6 8 10 - - - - - SL No 0 3 5 7 9 11 13 15 17 19 21 23 25 26 27 29

01 Detail designs, Tender documents and BOQ

02 Notice inviting Tender, Tender process evaluation & award

03 Mobilization, Preliminary works

04 Site Clearance

05 Foundation

06 Super structure

07 Fittings, paintings etc.

08 Electrification, plumbing

09 Testing, Commissioning, Monitoring and Evaluation and Defect liability Period Source: Consultant’s computation Note: Actual implementation schedule may differ.

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CHAPTER 4: ENVIRONMENTAL BASELINES

4.1 METHODOLOGY USED FOR THE BASELINE STUDY

4.1.1 Secondary data

Data for this study has been primarily collected through comprehensive literature survey, discussion with stakeholder agencies, and field visits to the proposed subproject sites. The literature survey broadly covered the following:

 subproject details, reports, maps, and other documents available with the ADB CDTA PPTA and DDS consultants, LGED, and Kalapara Pourashava;  relevant acts and extraordinary gazettes, and guidelines issued by Government of Bangladesh agencies; and  Literature on land use, soil, geology, hydrology, climate, socioeconomic profiles, and environmental planning documents collected from Government of Bangladesh agencies and websites.  Web search for literature

4.1.2 Primary data

Visits were undertaken to the subproject sites toward assessing the existing environment (physical, biological, and socioeconomic) and gathering information in respect of the proposed sites and scale of the proposed subproject. A separate socio-economic study was conducted to determine the demographic information, archeological and religious places, densely populated pockets, and settlements. The methods used for primary data collection were:

 Transect walk, field GPS measurement, photographic records, need basis environmental survey, observations,

Data were collected during the above site visits and were analyzed based upon which interpretations were made to assess the physical, biological, and socio-economic features of the project area. The relevant information is presented in the subsequence paragraphs.

4.2 PHYSICAL CHARACTERISTICS

4.2.1 Topography

Kalapara Upazila has a flat topography with minimum and maximum ground level varying between 1.5m and 4.2m and average elevation of about 2.43m. It is greatly influenced by the river network and canals.

The Pourashava area is located on the southern part of Bengal Basin making a part of Barisal Gravity High. The sedimentary layers are mostly horizontal to sub-horizontal and are free from major tectonic deformation in the fore deep area covering the central part of the basin and this is expressed as river to delta plain topography of the land.

4.2.2 Rainfall and Temperature

The average monthly rainfall variation at Patuakhali BMD station (from 1973 to 2014)is shown in Figure 9. The hyetograph shows that the highest and lowest values of rainfall are observed during the months of July (610 mm) and December (7.6 mm) respectively. Figure 9 below also shows the variations of average maximum and average minimum temperatures at the Patuakhali BMD station (from 1973 to 2013). The average maximum temperature values range from around 29°C (January) to around 36°C (April). Significant fluctuations in average minimum temperatures have been found, which varies from 10.3°C (January) to 24°C (August).

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Figure 11Historical temperature (left) and rainfall (right) record in Patuakhali Source: www.meteoblue.com

4.2.3 Hydrology

Hydrology of Kalapara Pourashava is due to the river Andharmanik running along its western flank and the canals passing through it which influence its surface water hydrological state. Both the river and the major canals are tidal in nature exhibiting semi-diurnal tidal fluctuations. Besides, there are 7 large ponds along the subproject PTs.

4.2.4 Drainage and Flood Control

Kalapara Pourashava drains out its storm water to river Andharmanik through a network of canals. The primary drains comprise the natural canals and channels, and are almost entirely unlined earth, while the tertiary drains are pucca brick and concrete drains. The secondary drains comprise both natural earth and pucca channels.

4.2.5 Ambient Air Quality

Other than normal, there are no undue air emission sources at the construction site except for limited vehicular emissions from inter-Pourashava traffic which are occasional and limited to a 3-4 meter width on both sides of the market bound roads.

However, the air quality testing was performed in Kalapara Pourashava in 2017 through the Environmental Testing of CTEIP implemented Contracts. Results of the air quality monitored at the sub-projects location have been showed in below. Refer to Table 7 for results of air quality test showing that the ambient air quality parameters of locations for Kalapara are within National Standard for Bangladesh.

Table 7 Ambient Air Quality in Kalapara Pourashava

Parameters Unit Bangladesh Standard KAL/WS/01 PM2.5 µg/m3 65 29.67 PM10 µg/m3 150 102.53 SPM µg/m3 200 111.54 SO2 µg/m3 365 32.21 NOx µg/m3 100 29.27 CO mg/m3 10 <1 Source: CTEIP Environmental Test Report (Package KAL/WS/01), July 2017

4.2.6 Ambient Noise

The en-route area is peri-urban to urban within the location of the proposed works. The noise levels in the Pourashava are similar to that of any small urban area. In the respective locations of the works, noise is due to vehicles, machinery and other related activities, and is normally in the range of 55 to 75 dB(A).

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4.2.7 Water Quality

Surface water quality was measured in dry season (February 2016) by CEGIS7. Results show: the pH value is higher than neutral scale (pH=7), which means the water in these locations was alkaline yet. Values of TDS in dry season were found very low in the Baleshwar (Kocha) and Pona Rivers and internal khals which varies from 172 to 232 ppm. Values of DO were Values of DO were mostly found slightly above to the standards set by DoE for both irrigation (5 to 6 mg/l) and fishing (5mg/l). Salinity of the surface water was not found in this period yet, since rainwater was still present inside the polder and tidal flow of seawater from the Bay of Bengal was yet to intrude.

However, local people opined that in dry season, specifically during the month from April to May, concentration of salinity in both ground and surface water found to be moderate to high level. Water hyacinths were observed on the surface water in the month of February, which is an indicator of freshwater presence. Refer to Table 8 for the test results of the KAL/WS/01 package for details of the test results.

Table 8Results for Surface Water Quality in Kalapara Pourashava

Water Quality Parameters Unit KAL/WS/01 Method of Analysis Bangladesh Standard for Potable water pH --- 8.8 pH Meter 6.5-8.5 Turbidity NTU 01 Tb Meter 10 100 Total Dissolved Solids (TDS) mg/l 540 TDS Meter

Total Suspended Solids (TSS) mg/l 03 Gravimetric 10 0 Fecal Coliform (FC) N/100ml 0 MFM

Total Coliform (TC) N/100ml 0 MFM 0 Source: Environmental Test Result, CTEIP KAL/WS/01, July 2017

4.2.8 Wind

Figure 10below shows the distribution of average monthly wind speed at Patuakhali BMD station (from 1973 to 2013). Wind speed is the highest in April (around 167 kph) and the lowest in December (around 49.7 kph). During cyclone SIDR (2007) and AILA (2009), 1-minute sustained wind speeds were recorded as 260 kph and 120 kph respectively. SIDR caused more damage due to its high wind

Figure 12 Wind Rose diagram (left) and wind speed graph (right) in Patuakhali

Source: www.meteoblue.com

7 CEGIS 2017. EIA Report. Coastal Embankment Improvement Project, Phase-I (CEIP-I)

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speed.

4.3 BIOLOGICAL CHARACTERISTICS

4.3.1 Vegetation

Kalapara Pourashava location is mainly devoid of vegetation other than nominal roadside trees, with some secondary growth trees and shrubs. From observation the following trees were commonly recognized during field visit: a. fruit bearing tree: mango, Guava, banana, Jamun, custard-apple, tamarind etc. b. others: chambal, rentree, rendi, koroi, mehagony etc. There is no forest area or any sensitive habitat along or within the influence areas of the project roads (See Figure 13). There are no national parks or sanctuaries. There are also no rare or endangered species reported. There was no evidence of wild life of the higher species within the urban location.

Figure 13 Vegetation cover around the PT sites

The Madrasa site has vegetation on both sides. Bus Terminal site is located on the bank of Andhermanik river. Few mudflat shrubs and grass are grown naturally in the area, which are of no conservation significance (See Figure 14). There are no national parks or sanctuaries. There are also no rare or endangered species reported. There was no evidence of wild life of the higher species within the urban location.

The site vegetation is typically dominated by annuals or herbaceous perennials such as water- purslane (Ludwigiapalustris), smartweeds (Persicaria spp.), rice cut-grass (Leersiaoryzoides), swamp- candles (Lysimachiaterrestris), ditch-stonecrop (Penthorumsedoides), or little spike-rush (Eleocharisacicularis).

Figure 14 Riverside vegetation around the Bus Terminal PT site

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4.3.2 Fisheries

The fish habitats are primarily classified under two broad categories, capture fishery and culture fishery. Internal khals as well as floodplains are considered as capture fish habitats. The culture fish habitats are of two types: Homestead fishponds and commercial fishponds. The main fish species reported in fish farming ponds are mainly major carps and exotic carps. At present major carps such as ruhu (Labeorohita), catla (Catlacatla) and mrigal (Chirrhinuscirrhosus) along with exotic carps such as silver carp (Hypophthalmichthys molitrix), grass carp (Ctenopharyngodonidella) ,bighead carp (Aristichthysnobilis) and common carp (Cyprinuscarpio) are cultured in ponds and gained much popularity because of its easy culture system, rapid growth, disease resistance and high market price. During field visit in December2017the consultant observed that culture fisheries (90%) dominate Kalapara fish market. The rest is capture fisheries (10%).

4.3.3 Agriculture

Agricultural farming practices within most of the study area have adjusted to the agro climatic conditions prevailing in the Kharif (March-October) and the Rabi (November-February)seasons. The crop year starts from the Kharif-I season characterized by high temperature, high evaporation, low humidity and low rainfall. S. Vegetables, T. Aus (Local) and T. Aus (HYV) are grown in this season. High rainfalls, lower temperatures, high humidity, low solar radiation and high floods that recede towards the end of the season, characterize the Kharif-II season. T-Aman (Local) and T. Aman (HYV) crops are grown in this season. The Rabi season is characterized bylow temperatures, high solar radiation, low evaporation, insignificant rainfalls and low humidity. A wide range of crop varieties such as W. Vegetables, Spices, Potato, Chilli, Wheat, Pulses, Oilseeds and Boro (HYV) crops area grown in these seasons. Sugarcane and Orchard are perennial crops in this area. Some occasional overlapping occurs in the area. Such as Kharif-I crops (S. Vegetables, T. Aus) are harvested in Kharif- II season, Kharif-II crops (T. Aman) are harvested in the Rabi season and Rabi crops (W. Vegetables, Spices, Potato, Chilli, Wheat, Pulses,Oil seeds and Boro) are harvested in Kharif-I season.

4.3.4 Economic Development

The Pourashava has insufficient capacity and resources and is finding it difficult to respond to the need for forward planning and investment in basic urban infrastructure and services. This undercut sustainable local urban governance, makes local planning ineffective and undermines local economic development. The impact of climate change further exacerbates the weaknesses in municipal management more generally.

4.5 SOCIO-ECONOMIC CHARACTERISTICS

4.5.1 Population

Information on population and number of households with average size of Kalapara is presented in Table 9.

Table 9 Kalapara population data

Administrative Area Households Population Unit (km2) (nos.) Total Male Female Pourashava 3.75 4,347 17992 8887 8445 Ward No – 01 0.70 745 3319 1783 1536 Ward No – 02 0.34 498 1501 824 677 Ward No – 03 0.39 417 1681 824 857 Ward No – 04 0.25 286 1331 702 629 Ward No – 05 0.30 272 1193 601 592 Ward No – 06 0.40 424 1662 821 841 Ward No – 07 0.32 325 1347 654 693 Ward No – 08 0.40 425 1824 945 879 Ward No – 09 0.65 955 3474 1733 1741 Source: BBS Housing Census Report 2011

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4.5.2 Land use

Kalapara Pourashava is comprised of various categories of land, where prominent land use categories are residential, water bodies and agricultural. Dominance of residential land use (about 42% of the total) followed by agricultural land (about 22%) and water body land use (about 19%). Basing on the percentage of land under different use categories the ranking is: Residential (42.20%), Agriculture (21.58%), Water bodies (18.88%), Urban Green Space (5.08%), Circulation Network (3.26%), Commercial (2.34%), Government Services (1.82%), Industrial/Processing and Manufacturing (1.77%), Education and Research (1.41%), Community Services (1.09%), Health Facility (0.21%), Restricted area (0.14%), Transport & Communication (0.08%), Non-Government Services (0.05%) and Mixed Use (0.05%), and Recreational Facility (0.04%).

4.5.3 Socio-economic Status

About 18% of the respondents are engaged in business activities. The scenario reveals that there are significant numbers of respondents who are engaged as small businessman, while 10% service holders both government and semi-government including employees in private offices. The unskilled labours are rickshaw and van pullers accounts for 0.7% of the total occupation group in the study area. Only 3.6% is unemployed.

4.5.4 Other Existing Amenities for Community Welfare

The Upazila Health Complex (UHC) in Kalapara is responsible for providing health services although there are a few private doctors and pharmacies in the town. There are 10 doctors and 12 nurses/health technicians in UHC.

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CHAPTER 5: POTENTIAL ENVIRONMENTAL IMPACTS

5.1 INTRODUCTION

This section identifies the potential impacts that the various elements of the proposed sub-project may have on aspects of the physical, biological and socio-economic environment. The identification of the potential impacts will be considered for the two distinctive Project stages (construction and operation) as detailed in later in this Chapter. The activities undertaken during each of these Project stages form the basis for potential impact identification and analysis.

Assessment of potential impacts requires a multi-disciplinary approach in which a wide range of issues are taken into consideration to identify and determine which potential sub-project impacts may be significant and therefore require the application of reasonable and effective management and/or mitigation. Most sub-projects taken under CTEIP result in positive and negative potential impacts on the environment, society and economy, all of which are identified and assessed in this section.

Certain impacts identified in this section have the potential to be significant. The determination of whether a given potential impact is significant depends on several factors:

. The potential for on-site and off-site impacts; . The potential for direct and indirect impacts; . The frequency and duration of a potential impact; . The geographic area affected by a potential impact . The period of time affected by any potential impact; . The sensitivity of the receiving environment; and . The degree of confidence with which the potential impacts of the action/activity are known and understood. Measures of potential impact significance as part of the Project planning and assessment phase presented in this IEE have been determined using a risk based model. The model is known as Leopold Matrix for risk assessment (Leopold et al. 19718).

5.1.1 Approach

Issues for consideration have been raised by the following means: (i) input from interested and affected parties; (ii) desktop research of information relevant to the proposed subproject; (iii) site visits; and (iv) evaluation of proposed design scope and potential impacts. Categorization of the subproject and formulation of mitigation measures have been guided by ADB‟s REA Checklist for subprojects and ADB SPS 2009.

The subproject will not have major negative impacts because activities will be localized/site-specific and short in duration, corridors of impact of will be on existing public ROWs, and construction will be conducted within a relatively small area. Because of these, several aspects of the environment are not expected to be significantly affected by the subproject (Table 10).

Refer to the guidelines detailed in the Traffic Management Plan (TMP) given in Annexure I of the Environmental Management Plan (EMP), whereby the Contractor shall prepare and submit for approval from the Employer, details of all required mitigate measures, associated with vehicular and pedestrian road-user issues, during any possible closure and/or infringement to road access through the course of implementation.

8 Leopold, Luna B.; Clarke, Frank E.; Hanshaw, Bruce B.; Balsley, James R. (1971). A Procedure for Evaluating Environmental Impact. Geological Survey Circular 645. Washington: U.S. Geological Survey.

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Table 10 Environmental sectors in which the Subproject is expected to have insignificant Impacts

Field Rationale A. Physical Characteristics Topography, landforms, geology  Required amount of materials will not cause alteration of topography, and Soils landforms, geology and soils.  Erosion hazard is insignificant as trenching and excavation works will be conducted only during construction stage (short-term) and specific to sites along public ROWs. Climatic conditions  Short-term production of dust is the only effect on atmosphere. However, impact is short-term, site-specific and within a relatively small area. There are well developed methods for mitigation. Water quality  Trenching and excavation, run-off from stockpiled materials, and chemical contamination from fuels and lubricants may result to silt-laden runoff during rainfall which may cause siltation and reduction in the quality of adjacent bodies of water. However, impact is short-term, site-specific and within a relatively small area. There are well-developed methods for mitigation. Air quality  Conducting works at dry season and moving large quantity of materials may create dusts and increase in concentration of vehicle related pollutants (such as carbon monoxide, Sulphuroxides, particulate matter, nitrous oxides, and hydrocarbons) which will affect people who live and work near the sites.  However, impact is short-term, site-specific and within a relatively small area. There are well-developed methods for mitigation. Acoustic environment  Construction activities will be on settlements, along and near schools and areas with small-scale businesses. Temporary increase in noise level and vibrations may be caused by excavation equipment, and the transportation of equipment, materials, and people.  However, the proposed subproject will follow existing ROW alignment and impact is short-term, site-specific and within relatively small area. There are well developed methods for mitigation. B. Biological Characteristics Biodiversity  Activities being located in the built-up area of Kalapara Pourashava will not cause direct impact on biodiversity values.  The construction activities anticipate removal of few shrubs which are mainly bushy trees that produce local fuel wood. Those trees are of not of any commercial value or not ecologically vulnerable. Locals may collect that fuel wood after felling of the trees. C. Socioeconomic Characteristics Land use  No alteration of land use. Rehabilitation of existing roads and bridges are prioritized over new construction, using vacant government land and right of way (ROW). Type of community spread  No alteration on type of community spread.  Road closure is not anticipated. Hauling of construction materials and operation of equipment on-site can cause traffic problems. Existing provisions for  The proposed subproject will follow existing ROW alignment and impact is pedestrians and other forms of short-term, site-specific and within relatively small area. There are well transport developed methods for mitigation. Socio-economic status  Subproject components will be located in government land and existing ROWs thus there is no requirement for land acquisition or any resettlements.  Manpower will be required during the 6-monthsconstruction stage. This can result to generation of contractual employment and increase in local revenue. Thus potential impact is positive and long-term.

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Field Rationale Social receptors  Although construction of subproject components involves quite simple techniques of civil work, the invasive nature of excavation and the subproject sites being in built-up areas of Kalapara Pourashava where there are a variety of human activities, will result to impacts to the sensitive receptors such as residents, businesses, and the community in general. These anticipated impacts are temporary and for short duration. D. Historical, Cultural, and Archaeological Characteristics Physical and cultural heritage  The subproject components are not located in or near, excavation works will not be conducted in the vicinities of identified historical, and sites.

5.2 POSITIVES IMPACTS

Based on project particulars Chapter 3 and the existing environmental conditions Chapter 4 potential positive impacts have been identified that are likely to result from the proposed project and wherever possible these have been quantified. Positive impacts have been identified for different phases of project cycle and discussed in the following sections

5.2.1 Impacts during Planning and Design Phase

 Employment opportunities

During the planning and design period, new jobs will be created for the skilled and unskilled manpower in the community to conduct topographical and geological investigations. In addition, employment will also be generated for planning and design of infrastructure. Women will also have equally an opportunity to secure employment.

 Skills transfer

The international consultant will associate with local partners. In the process of planning and design the local technical manpower will work with the international experts. This process of working together will transfer design and planning tools, computer design software and other useful guideline which are used in similar topographical conditions in the world.

 Training

The international consultant will provide training to local counter parts for activities likely to be implemented during planning and construction phases. This training and trained manpower will go a long way in meeting the requirements of the country in the infrastructure sector and buildings in particular.

5.2.2 Impacts during Construction Phase

Employment Opportunities

During the construction phase it is estimated that about 20 people will be working as labour both skilled and unskilled. A majority of unskilled labour will be sourced from the local residents and hence this will create and employment. In addition, new jobs will be created in the Government to implement, monitoring and evaluation of the project. Women will also have an opportunity to secure employment.

Enhanced Social Interaction

The National and International; local and regional manpower will be working together for the project. This interaction will enhance social interaction between the people of two different places and levels. Boost to Industrial Activities

During construction, country made product will be utilized such as cement, gravel, reinforced pipes etc. The consumption of these will give boost to industrial production of material manufacturing

Package: CTEIP/KAL/PT/01: IEE 31 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) organization. In addition, the transport sector will be benefited for transport of material from manufacturing site to construction site. This will provide direct and indirect employment. Improvement of Hygiene

Construction of PTs will improve peoples‟ access to better hygiene, therefore promoting improved health condition.

5.2.3 Impacts during Project Operation

The proposed works will play an important role in its post construction period. It will ensure adequate transport communications particularly during critical times of storm events, which will be useful in ensuring the safety and life of people during such storm events. This will add directly to GDP by saving the life of people.

5.3 NEGATIVE IMPACTS

Impacts on environmental component due to project activities, during different phases of project cycles, are summarized in Table 11. Mostly the impacts during project construction have been considered and reported.

5.3.1Impact during Planning Phase

Change of Land Use due to Proposed PT/Borrow/Quarry Areas

This area need to be identified in the vicinity of proposed PTs to avoid transport problems. Emphasis should be laid on maximum use of the stripped top soil in road junctions, redevelopment of borrow areas and additional landscape works in the project. Excavations of earth from borrow areas may also lead to loss of topsoil and soil erosion problem during rains. Refer to Table 11 for the impact matrix of potential environmental impacts for the pre-construction and construction phases of implementation.

5.3.2 Impact during Construction Phase Soil Loss

The soil loss will be in terms of top soil erosion from right of way, borrow pits, quarries, and storage of material areas. Erosion is of relevance to slope stability, which is a level topography. The construction will be completed in 6 months. The soil erosion is likely to take place due to construction of PTs and subsequent excavation. Excavated earth material will be reused in the construction or will be used to fill the low laying areas hence its disposal is not likely to have impact on the environment. To prevent the soil erosion, monsoon season work is likely to be stopped during the construction; vegetation will need to be cleared within the proposed RoW, which may pose some soil erosion problem during first few rains. Embankment/slopes near newly constructed structures may be prone to the soil erosion. Such embankment and slopes will need to be stabilized as soon as construction is over. The impact of soil loss is of short duration and will be reversible.

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Table 11 Impact Matrix of Potential Environmental Impactsof the subproject Project Activity Pre- construction Construction Phase Operation Phase Component Phase Affected Vehicles & Removing Land Site Contractor Machines Construction/mod Construction trees and Quarries Operation Demarcation clearance camps operation & ification of site Machinery vegetation maintenance Soil Loss of land Loss of Soils Localized Contamination Contamination by Increase Soil pollution from Pollution due to Soil contamination Erosion and from wastes fuel and lubricants in erosion, Construction Spoils spills due to surface loss of top soil siltation runoff Compaction of and slope In madrasa soil instability site, tree removal is expected

Ground Water Evaporation Water extraction Water extraction Exploitation of Maintenance of for drinking and for cleaning water for trees /shrubs other purposes construction

Surface water No loss of Change in Siltation Torrent Pollution from Contamination by Water Change in water Pollution due to Degradation due water body is water quality runoff sanitary & other fuel & lubricants logging quality and spill into water to spills & road expected wastes and reduction of GW bodies runoff mosquito recharge breeding

Drainage Interference with Cleaning & natural drainage maintenance and water logging

Air Quality Increase in Reduced Pollution due to Dust & air Dust Dust pollution SPM, SO2 SPM buffering of air fuel burning pollution pollution pollution, change in

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Project Activity Pre- construction Construction Phase Operation Phase Component Phase Affected Vehicles & Removing Land Site Contractor Machines Construction/mod Construction trees and Quarries Operation Demarcation clearance camps operation & ification of site Machinery vegetation maintenance climate

Noise Quality Increase in Reduced Increase in Vibration Vibrators, mixing Increase in Increase in noise Noise level buffering of Noise level from plant noise etc. Noise levels due to Noise blasting increased traffic. operation s

Flora & Fauna  Loss of trees Loss of trees Cutting of trees Disturbance to  Impact on for fuel burning Flora and fauna Fishery

Socio- Land Acquisition No tree of Transmission of economic conservation Disease significance were found in the site

Loss to Utilities

Source: Consultant’s deduction

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Soil Pollution

The soil pollution may occur due to: first - stripping of soil which is rich in carbon to nitrogen ratio being 13.8 to 18.2; secondly due to improper disposal of waste material on the open ground. The waste likely to fall on the ground may be solid waste / liquid waste form labour camps.Soil pollution may also be due to spillage of oil and grease by construction machinery and equipment. Appropriate waste disposal methods have to be adopted. Proper care should be taken while locating the above utilities / facilities to minimize the soil pollution. The impacts are of short duration and will be reversible.

Tree removal

In the Madrasa site, removal of trees are expected. Especially, trees beside the road are expected to

Figure 15 Trees to be removed at Khepupara Nesaruddin Fazil Madrasa Site be removed to construct the PT. See Figure 15 for detail.

Health Risks due to Waste Disposal

Health risks include disease hazards due to lack of sanitation facilities (water supply and human waste disposal) to the workers during construction both at construction site and at Contractor‟s camp. Unscientific disposal of waste from contractor‟s camp can lead to contamination of both ground and surface water. This could lead to outbreak of water borne disease such as diarrhoea, dysentery, typhoid etc. The solid waste generated (about 120 kg/day) in contractor‟s camp if not treated properly may cause leaching and environmental pollution. Management measures include proper sanitation, health care, and solid waste disposal facilities. In addition to these, efforts need to be made to avoid water spills, adopt disease control measures. The impact will be of short duration and reversible.

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Pollution at Construction Site

Construction materials will be required for the construction of PT pavement, bridges and culverts, roadside drains etc. The contractor as construction waste / spoils leaves behind about 10-15% of the construction material. Dumping of construction waste / spoil in haphazard manner may cause surface and ground water pollution near the construction sites and breeding site for mosquitoes, hence, it is proposed to clean the area and dump/dispose the construction spoils at the dumping site specified by the local authority to avoid any adverse impact on health and well-being of people.

Air Pollution

The impact on air environmental is a factor of type of vehicle, fuel used and its capacity. The consultant has taken emission factor to estimate the pollution potential on air environment during construction. The material will be transported by canal route and hence the impact on air environment will be insignificant. In the construction phase, air quality impacts are of short duration. The most important pollutant during this phase will be suspended particulate matter. Such deterioration of air quality can be assigned to:

 Fugitive dust emission from construction activities like excavation, back-filling and concreting;  Hauling and dumping of earth & construction spoils;  Vehicular movement along the feeder roads or temporary diversions.  Gaseous emission from construction equipment and vehicular traffic.

Impacts on air quality will be low and spatially restricted along the immediate site of construction. The above will be operated at different location the impact at a particular site will be insignificant.

Noise Levels

The magnitude of impact during the construction phase will depend upon the types of the equipment used, the construction methods employed and the scheduling of the work. Noise associated with development/construction affects the environment through which road passes.

Construction and maintenance generally require the use of heavy machinery, and although these activities may be intermittent and localized, they nevertheless contribute sustained noise during equipment operation. Construction activities are expected to produce noise levels in the range of 80- 85 dB (A) at 15 m distance, which will decrease, with increase in distance. Noise due construction machinery is predicted as presented in Table 12. The noise levels will be with a limit of 55-65 dB (A) at a distance of 100-125 m from construction site. The expected noise levels due to operation of construction machinery at site are summarized in Table 13. The noise levels will decrease with distance.

Table 12 Noise levels during construction, dB (A)

Source Dump Truck Compactor Dozer Excavation by Shovel Excavation by caterpillar Noise Level dB(A) 83 81 85 87 87 Source Distance (m) 15 15 15 15 15 Noise Levels at Distance (m) from source 20 78.5 76.5 80.5 82.5 82.5 25 76.1 74.1 78.1 80.1 80.1 30 74.0 72.0 76.0 78.0 78.0 35 72.1 70.1 74.1 76.1 76.1 40 70.5 68.5 72.5 74.5 74.5 45 69.0 67.0 71.0 73.0 73.0 50 67.5 65.5 69.5 71.5 71.5 55 66.2 64.2 68.2 70.2 70.2

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Source Dump Truck Compactor Dozer Excavation by Shovel Excavation by caterpillar 60 65.0 63.0 67.0 69.0 69.0 75 61.5 59.5 63.5 65.5 65.5 100 56.5 54.5 58.5 60.5 60.5 125 54.6 52.6 56.6 58.6 58.6 150 53.0 51.0 55.0 57.0 57.0 175 51.7 49.7 53.7 55.7 55.7 200 50.5 48.5 52.5 54.5 54.5 225 49.5 47.5 51.5 53.5 53.5 250 48.6 46.6 50.6 52.6 52.6 Source: http://www.worksafe.govt.nz/worksafe/

Table 13Noise due to construction machinery

Sl. No. Machine Operation Noise In dB(A) 1 Dump Truck Haul 83 2 Compactor Fill 81 3 Dozer Fill 85 4 Excavation by Shovel Cut 87 5 Excavation by Caterpillar Cut 87 Source: http://www.worksafe.govt.nz/worksafe/

5.3.3 Impact during Operation Phase

Noise Levels

During the operation phase of the PT, movement of heavy and light vehicles is expected to give rise to higher ambient noise levels. In order to quantify the project induced noise impacts with respect to existing noise levels, noise monitoring was carried out. The day time noise levels may be 35 to 45 dB (A). Assessment of noise impacts due to the project have been carried out using Highway Noise Model based on the guidelines suggested by Federal Highway Administration (FHWA). The maximum speed assumed for the present scenario is 40 km/hr. Table 14 shows noise emitted by different vehicle types. The computed results have indicated a maximum increase in noise level to the tune of 5 dB (A) being average around 43 dB (A) during peak hours.

Table 14 Noise generated by various vehicle types in dB(A)

Vehicle Type Speed (kmph) Cars Trucks Buses 2-Wheelars 40 65.0 81.0 81.0 68.0

Water and Soil Pollution

The spill of oil, grease and other chemical/ material on roads may pollute the soil and surface and ground water. Such spills shall be closely monitored.

5.4 IMPACTS ANALYSIS

Checklist is the list of environmental parameters or impact indicators, which the environmentalist is encouraged to consider when summarizing the potential impacts. A typical checklist identifying the anticipated environmental impacts due to the project activities are shown in Table 15. The impacts have been categorized and analyzed in the following manner:

i. Nature (positive/negative, direct/indirect); ii. Magnitude (high, moderate, low); iii. Extent/location (area/volume covered, distribution); iv. Timing (during construction or operation, immediate; or delayed); v. Duration (short term/long term, intermittent/continuous); vi. Reversibility/irreversibility;

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vii. Likelihood (probability, uncertainty); and viii. Significance (local, regional, global)

The risk prioritization matrix provided in Table 16 has been developed specifically for use in this IEE. It has been prepared to be generally consistent with Leopold Matrix of risk analysis and draws from the experiences of social and environmental professionals from within Bangladesh and internationally. The risk prioritization matrix is the primary tool by which the risk assessment is undertaken. It forms the basis of this IEE and its methods. Table 17 explains Table 16, while Table 18represents the list-of prioritized risks.

5.5 CUMULATIVE IMPACT

The subproject‟s potential cumulative impacts were considered with respect to valued components in environmental and socio-economic categories. There are no foreseeable projects that will overlap with the subproject.

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Table 15 Impact Analysis matrix for the subproject in question

Extent/ Reversible S. No. Activity Potential Impact Nature Magnitude Timing/ Phase Duration Likelihood Significance Location /Irreversible i) Planning and Design of PT Skill Transfer & Positive Low Medium Pre-Construction Long Term Likely Regional Training Direct ii) Disposal of waste material, Soil Pollution construction spoils, spill of oil Negative Low Small area Construction Short Term Reversible Occasional Local and grease from construction Direct machinery. iii) Exposed surface due to Soil Loss/ Erosion Negative Low Small area Construction/ Operation Short Term Reversible Likely Local widening of ROW, borrow pits, on ROW Direct quarries site construction of Soil Loss from Negative cross drainage Borrow/Quarry Low Small area Construction Short Term Reversible Likely Local Direct Areas iv) Vehicles Movement on Loss of soil fertility Negative Low Small area Construction Short Term Reversible Likely Local adjoining productive land Direct v) Construction of ramps, borrow Change in Natural Negative Low Small area Construction Short Term Reversible Seldom Local areas and quarry sites Drainage Pattern Direct vi) Runoff from roads, quarry site Water Pollution Negative Small and borrow areas; construction Medium Construction Short Term Reversible Seldom Local Direct Distribution of abutments on canals vii) Disposal of waste Health Risk Negative Low Low Construction Short Term Reversible Occasional Local Direct viii) Use of water in Construction Increased Water Negative Low Low Construction Short Term Reversible Likely Local and drinking Demands Direct ix) Widening of the approach road Encroachment into Negative for work area, construction of water bodies Medium Low Construction Short Term Irreversible Seldom Local Direct PTs x) Movement of vehicles for Air Quality Negative Low Low Construction/ Operation Long Term Reversible Seldom Regional construction works Direct Increase in Green Negative Low Low Construction/ Operation Long Term Reversible Likely Regional House Gases Direct Fuel Consumption Negative Direct/ Low Low Construction/ Operation Long Term Irreversible Likely Regional Indirect Noise Levels Negative Low Low Construction/ Operation Long Term Reversible Likely Regional Indirect xi) Construction and operation of Employment Positive Large High Construction/Operation Long Term Likely Local PTs Opportunities Direct Distribution

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Extent/ Reversible S. No. Activity Potential Impact Nature Magnitude Timing/ Phase Duration Likelihood Significance Location /Irreversible Enhancement of Positive Large Medium Construction/Operation Long Term Permanent Likely Regional Rural Economy Direct Distribution xii) Operation and maintenance Reduction in length Positive Medium Permanent Operation Long Term Likely Regional and travel time Direct Enhanced Social Positive Medium Permanent Construction/Operation Long Term Likely Regional Interaction Direct xiii) Construction Activities Workers Safety Negative Low Temporary Construction Short Term Reversible Seldom Local xiv) Employment of outside labour Health Safety Temporary/ (Transmission of Negative Low Construction Short Term Reversible Seldom Local Permanent STD, HIV/AIDS) Explanation of Color codes: Magnitude Likelihood Nature Significance Duration Low: Impacts such as localized or short Likely:Consequence can reasonably be Positive Direct: Positive impact Local: Impacts anticipated to be effecting Short Term: Expected to affect during term effects on habitat, species or expected to occur in life the project expected which has a direct activity- only local site area project time plus couple of months environmental media. consequence linkage

Medium: Impacts such as localized but Occasional:Conditions may allow the Positive Indirect: Positive impact Region: Impacts anticipated to be Long Term: Expected to affect even irreversible habitat loss or widespread, consequence to occur during the project expected with no direct activity- effected regional ecology and landscape after completion of the project period, long-term effects on habitat, species or lifetime, or the event has occurred within consequence linkage especially during O&M environmental media similar projects

High: Loss of a significant portion of a Seldom: Exceptional conditions may Negative Direct: Negative impact valued species or loss of effective allow consequences to occur within the expected which has a direct activity- ecosystem function on a landscape scale. project lifetime consequence linkage

Negative Indirect: Negative impact expected with no direct activity- consequence linkage

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Table 16 Modified Leopold Methodology of Risk Prioritization matrix

CONSEQUENCE Widespread and Socio-economic Widespread and temporary, or, Widespread and Entire villages, Consequence Descriptions Temporary and temporary, or, localized and permanent effects on communities or Social / People largely (Without application of localized effects on localized and permanent effects on livelihood and/or groups are displaced Economic unaffected mitigation and management peoples’ livelihoods permanent effects on livelihood and/or displacement of and livelihoods are measures) peoples’ livelihoods displacement of people affected people Illness or adverse (Highest possible score can be 36, which is a combination of Serious illness or Health Consequence effect with limited or Illness or adverse 1-10 serious illness >10 serious illness or Catastrophic, and Likely and lowest possible score can be 1, severe adverse Descriptions no impacts on ability effects with mild to or chronic exposure chronic exposure which is combination of Incidental and Rare. The scores are health effect requiring (Without application of Health No impact to function and moderate functional resulting in fatality or resulting in fatality or converted into a scale of 10 for easier interpretation and a color a high level of mitigation and management medical treatment impairment requiring significant life significant life code is assigned to better visual representation. Table 17 medical treatment or measures) required is limited or medical treatment. shortening effects. shortening effects. explains the color code. Scores are presented in parentheses management. while scores converted into 10 are presented after the not necessary. Localized, long term Impacts such as parentheses) Widespread and Persistent reduction Loss of a significant Environmental Impacts such as degradation of localized but persistent in ecosystem function portion of a valued Consequence Descriptions localized or short- sensitive habitat or irreversible habitat changes in habitat, on a landscape scale species or loss of (Without application of Environment term effects on widespread, short- loss or widespread, species or or significant effective ecosystem mitigation and management habitat, species or term impacts to long-term effects on environmental media disruption of a function on a measures) environmental media. habitat, species or habitat, species or LIKELIHOODS sensitive species. landscape scale. environmental media environmental media Ranking Incidental Minor Moderate Major Severe Catastrophic Likelihood Descriptions Ranking Index 1 2 3 4 5 6 (Without application of mitigation and management measures) Rare Rare or unheard of 1 (1) 1 (2) 1 (3) 1 (4) 2 (5) 2 (6) 2 Remote Has occurred once or twice within industry 2 (2) 1 (4) 2 (6) 2 (8) 3 (10) 3 (12) 4 Reasonable to expect that the consequence will not occur Unlikely 3 (3) 1 (6) 2 (9) 3 (12) 4 (15) 5 (18) 5 during this project though has occurred several times in industry Exceptional conditions may allow consequences to occur within Seldom 4 (4) 2 (8) 3 (12) 4 (16) 5 (20) 6 (24) 7 the project lifetime Conditions may allow the consequence to occur during the Occasional 5 (5) 2 (10) 3 (15) 5 (20) 6 (25) 7 (30) 9 project lifetime, or the event has occurred within similar projects Consequence can reasonably be expected to occur in life the Likely 6 (6) 2 (12) 4 (18) 5 (24) 7 (30) 9 (36) 10 project Table 17 Explanation of color code used for Prioritization matrix

5: Risk is tolerable 7: Risks are 8: Risks are 9: Risks are 10: Risks are 2: Low risk, 3: Low risk, 4: Low risk, 6: Further risk 1: Low risk, if reasonable unacceptably high unacceptably high unacceptably high unacceptably high mitigations may be mitigations may be mitigations may be mitigations may be reduction is mitigations are in and mitigations and mitigations and mitigations and mitigations applied applied applied applied required place must be applied must be applied must be applied must be applied

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Table 18 Potential Impact Prioritization assessment

POTENTIAL IMPACT LIKLIHOOD CONSEQUENCE RISK RANKING

Without the application of mitigation or management measures 1.0 Construction stage 1.1 Mobilization and site establishment § Odours from the field camp facilities and waste management facilities may be detectable by local people. 3 6 5.0 § Dust resulting from the disturbance of land may be detectable and affect local people and/or crops. 2 5 2.7 § Sanitation and amenities may pollute surface water or groundwater systems. 2 5 2.8 § Runoff from disturbed areas and stockpile areas may introduce pollutants into water bodies 1 5 1.4 § Waste generation may result in pollution of surrounding environments. 1 6 1.7 § Rubbish has the potential to attract animals 3 5 4.1 § If Project activities encroach beyond acquired footprint, land local people’s livelihoods may be affected. 4 5 5.6 § Noise generation from field camp and mobilization activities may affect local people. 3 5 4.2 § Lighting for Project demarcation, security and field camps may affect local people. 3 5 4.2 § Influx of workers increases local population which may pressure local infrastructure 2 6 3.3 § Influx of workers increases pressure on local facilities such as health and community services 3 3 2.5 § Additional traffic including transport and heavy machinery may result in damage to road infrastructure 2 5 2.8 Average score 3.4 1.2 Civil works § Dust from earthworks may affect local people and/or crops. 2 5 2.9 § Emissions from Project vehicles and heavy machinery may contribute to greenhouse gas concentrations 1 6 1.7 § The Project activities and features changes the existing visual landscape 1 6 1.7 § Project activities may produce noise that could affect people 2 5 278 § Vibrations from civil works may affect nearby infrastructure 5 2 2.8 § Floodplain encroachment may increase localized inundation potential 2 4 2.2 § Hazardous substances may lead to the pollution of terrestrial or groundwater environments 2 5 2.8

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POTENTIAL IMPACT LIKLIHOOD CONSEQUENCE RISK RANKING

§ Runoff from disturbed areas and stockpile areas may introduce pollutants into water bodies 1 5 1.4 § Soil erosion may occur from embankments and disturbed areas as a result of the civil works 1 6 1.7 § Activities may produce noise and vibrations that affect local fauna 2 5 2.8 § Pedestrian and vehicular access may be temporarily restricted (e.g. increased travel times). 1 5 1.4 Average score 2.2 1.3 Installation of equipment packages § Noise exceeding the standards of the Government of Bangladesh 2 5 2.8 § Transport of equipment can cause vibration 1 6 1.7 § Cranes and placement of bulky equipment may change the existing visual landscape 1 6 1.7 Average score 2.0 1.4 Connection to Electricity, water supply etc. § People who rely on the existing water supply may be affected during any temporary disruptions of supply 2 5 2.8 § Explosions or accidents may occur during commissioning 5 4 5.6 § Hazardous substances used in the cut-over or commissioning could pollute the environment 4 4 4.4 Average score 4.3 1.5 Demobilization of construction stage § Removal of waste facilities and sanitation facilities may result in the production of odours 6 6 10.0 § Demobilization of the field camp may leave disturbed areas of land which generate dust 5 6 8.3 § Excess waste, chemicals or hazardous materials are left on site and pollute the surrounding environment 2 4 2.3 § Demobilization may leave litter and disturbed land which pollutes receiving environment 2 6 3.3 § Demobilization of workers and associated reduction in local population may affect local business. 1 6 1.7 Average score 5.2 2.0 Operation Phase 2.1 Normal Operation § Constructed infrastructure changes the existing landscape 1 6 1.7

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POTENTIAL IMPACT LIKLIHOOD CONSEQUENCE RISK RANKING

§ Site runoff and wastewater discharges may contain substances which pollute water bodies 2 4 2.2 § Long term groundwater abstraction may result in localized groundwater level drawdown 6 6 10.0 § Waste generation may result in pollution of surrounding environments 1 6 1.7 § The operation of the facility may create noise that exceeds the standards of the GoB 3 5 4.2 § The operation of the facility will require operational lighting which may affect local people adversely 4 5 5.6 § Stranded foods and light may attract native fauna (i.e. bats, insects, birds) resulting their death/injury 3 4 3.3 § The construction of the Project may reduce the existing line of sight 3 2 1.7 Average score 3.8 2.2 Uncontrolled events or emergencies § An uncontrolled or emergency event could affect nearby flora and fauna 5 1 1.4 § An uncontrolled or emergency event could affect nearby residents or community members 5 1 1.4 Average score 1.4 Source: Consultant’s Calculation

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CHAPTER 6: GRIEVANCE REDRESS MECHANISM

6.1 GENERAL

Generally, complaint procedures are developed for those who have been adversely affected by the Project infrastructure and/or have not been compensated as per law/ legal entitlement. In this case no land related dispute is applicable as the land is already owned by the authorities. A project-specific grievance redress mechanism (GRM) will be established to receive, evaluate, and facilitate the concerns, complaints, and grievances about the social and environmental performance at the level of the project. The GRM will aim to provide a time-bound and transparent mechanism to voice and resolve social and environmental concerns linked to the project. A common GRM will be in place for social, environmental, or any other grievances related to the project. GRM was discussed with stakeholders during field visits. The GRM will provide an accessible and trusted platform for receiving and facilitating grievances related to the project. The multi-tier GRM for the project is outlined below, each tier having time-bound schedules and with responsible persons identified to address grievances and seek appropriate persons‟ advice at each stage, as required.

Pourashava-wide public awareness campaigns will ensure that awareness on grievance redress procedures is generated through the campaign. The project implementation unit (PIU) safeguards assistant and institutional capacity and community development consultants (ICCDC) that will conduct Pourashava-wide awareness campaigns to ensure that poor and vulnerable households are made aware of grievance redress procedures and entitlements, and will work with the PIU safeguards assistant to help ensure that their grievances are addressed. Affected persons (APs) will have the flexibility of conveying grievances/suggestions by dropping grievance redress/ suggestion forms in complaints/suggestion boxes that have already been installed by project Pourashavas or through telephone hotlines at accessible locations, by e-mail, by post, or by writing in a complaint register in Pourashava offices.

The grievance registration form is available in Annexure II. Careful documentation of the name of the complainant, date of receipt of the complaint, address/contact details of the person, location of the problem area, and how the problem was resolved will be undertaken. The project management unit (PMU) safeguards officer will have the overall responsibility for timely grievance redressal on environmental and social safeguards issues and for registration of grievances, related disclosure, and communication with the aggrieved party through the PIU safeguards assistant.

6.2 GRIEVANCE REDRESS PROCESS

In case of grievances that are immediate and urgent in the perception of the complainant, the contractor and supervision personnel from the project management and supervision consultants (PMSC) on-site will provide the most easily accessible or first level of contact for quick resolution of grievances. Contact phone numbers and names of the concerned PIU safeguards assistant, contractors, PMU safeguards officer, PMSC environmental and social safeguards specialists will be posted at all construction sites at visible locations.

6.2.1 1st Level Grievance

The contractors, PIU supervision personnel and PIU safeguards assistant can immediately resolve issues on-site in consultation with each other, and will be required to do so within 3 days of receipt of a complaint/grievance. Assistance of ward level coordination committees (WLCC) will be sought if required for resolution of the issue, by any one or all of them jointly.

6.2.2 2nd Level Grievance

All grievances that cannot be redressed within 3 days at field/ward level will be jointly reviewed by the grievance redress committee (GRC) at town-level and PIU safeguards assistant, who will attempt to

Package: CTEIP/KAL/PT/01: IEE 45 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) resolve them within 7 days. The PIU safeguards assistant will be responsible to see through the process of redressal of each grievance.

6.2.3 3rd Level Grievance

The PIU safeguards assistant will refer any unresolved or major issues to the PMU safeguards officer and PMSC (third level of grievance redress), who will resolve them within 15 days.

6.2.4 4th Level Grievance

Significant major issues that are beyond the jurisdictional authority of the GRC or those that have the potential to cause social conflicts or environmental damage or those that remain unresolved at PMU level, will be referred to the project steering committee (PSC) to be resolved within 14 days. All paperwork (details of grievances) needs to be completed by the PIU safeguards assistant and circulated to the respective WLCC, GRC and PSC members at least a week in advance of the scheduled meetings. All decisions taken by the GRC and PSC will be communicated to the APs by the PIU safeguards assistant. Despite the project GRM, an aggrieved person shall have access to the country's legal system at any stage, and accessing the country's legal system can run parallel to accessing the GRM and is not dependent on the negative outcome of the GRM. In the event that the established GRM is not in a position to resolve the issue, the affected person also can use the ADB Accountability Mechanism (AM) through directly contacting (in writing) the Complaint Receiving Officer (CRO) at ADB headquarters or the ADB Bangladesh Resident Mission (BRM). The complaint can be submitted in any of the official languages of ADB‟s DMCs. The ADB Accountability Mechanism information will be included in the PID to be distributed to the affected communities, as part of the project GRM.

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6.3 GRIEVANCE MECHANISM

Grievance redress process can be diagrammatically represented as presented in Figure 12 below:

Aggrieved Persons

FIELD/WARD LEVEL 1st Level Contractor, PIU Supervision 3 days Grievance Grievance Personnel and PIU Safeguards Days3 Redressed Assistants (to be assisted by AssistanceDays of WLCC ICCDC) (as and when required) Not redressed days

nd TOWN LEVEL 7 days 2 Level Grievance PIU Safeguard Assistant and Redressed Grievance GRC

Not redressed

3rd Level PMU LEVEL 15 days Grievance Grievance PMU Safeguard Officer and PMSC Safeguard Specialists Redressed

Not redressed

th 4 Level PROJECT STEERING Grievance COMMITTEE

Figure 16Grievance redress process

Records will be kept by PIU of all grievances received, including contact details of complainant, date the complaint was received, nature of grievance, agreed corrective actions and the date these were processed and final outcome. The number of grievances recorded and resolved and the outcomes will be displayed/disclosed in the PMU office, municipal office, and on the web, as well as reported in monitoring reports submitted to ADB on a semi-annual basis. All costs involved in resolving the complaints (meetings, consultations, communication and reporting/information dissemination) will be borne by the concerned PIU at town-level; while costs related to escalated grievances will be met by the PMU.

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CHAPTER 7: PUBLIC CONSULTATION

7.1 PUBLIC CONSULTATIONS AND PARTICIPATION

Public participation and community consultation has been taken up as an integral part of environmental assessment process of the project. Consultation was used as a tool to inform and educate stakeholders about the proposed action both before and after the development, decisions were made. It assisted in identification of the impacts problems associated with the project as well as the needs of the Project Affected People (PAP). This participatory process helped in reducing the public resistance to change and enabled the participation of the local people in the decision-making process.

7.2 PUBLIC CONSULTATION TOOLS

Following three (3) tools were used for Public Consultation:

a. Public Consultation Meeting (PCM) b. Focus Group Discussions (FGDs) c. Stakeholder Consultation

7.2.1 Public Consultation Meeting (PCM)

Presentations, panel debates, keynotes, workshops, and lectures are all examples of information sharing meetings. The primary goal of these meetings is for the speaker to share information with the attendees. At information sharing meetings attendees have historically been passive listeners.

While there are several types of information sharing meetings, they usually feature two main roles: the presenter(s), and the audience members.

Presenter: Often, the presenter is in a position of authority, like a manager passing on information or instructions to subordinates, or a subject matter expert sharing her knowledge with those present. The role can also fall on a keynote speaker, members of a panel, or project leader, to name just a few.

Audience members: Audience members make up the bulk of participants in information sharing meetings. Depending on the meeting size, there may be as many as hundreds, or even thousands, of audience members present. Their level of interest, and motivation to absorb the information shared, is highly dependent on their motivation for attending. In some cases, they have chosen to attend out of their own interest, while in other cases they are required to attend by their employer, professor, or other authority.

During these consultations, the communities were explained about the project, its benefits, social and environmental impacts. The participants were encouraged to (i) be open and make known their concerns and claims. The presentation highlighted the project background, objectives, expected upcoming activities, social economic information, and environmental information. The salient features of the meetings are presented below:

 Create awareness of the project;  To obtain stakeholders responses, feedback and concerns on the project;  To obtain environmental information on the community.

After the presentations, the community was given opportunity to give their views, comments and queries. Different community problems were addressed during the meeting in which the local participants expressed repeatedly their main concerns as follows:

 Transportation connectivity and access;

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 Prospects of jobs and income generating activities;  Disruption to nearby road users and public access during construction phase.

Comments or questions raised by audience were responded to. The consultant explained that positive and negative impacts of the project on people and the environment will be analysed such as air pollution, dust, influx of people, employment. All the participants confirmed that they appreciate the Project. The project received high degree of acceptability, which will boost local economy due to improved climate change resilient designs, road access and assured durability.

7.2.2 Focus Group Discussions (FGDs)

A focus group discussion (FGD) is a good way to gather together people from similar backgrounds or experiences to discuss a specific topic of interest. The group of participants is guided by a moderator (or group facilitator) who introduces topics for discussion and helps the group to participate in a lively and natural discussion amongst them.

The strength of FGD relies on allowing the participants to agree or disagree with each other so that it provides an insight into how a group thinks about an issue, about the range of opinion and ideas, and the inconsistencies and variation that exists in a particular community in terms of beliefs and their experiences and practices.

FGDs can be used to explore the meanings of survey findings that cannot be explained statistically, the range of opinions/views on a topic of interest and to collect a wide variety of local terms. In bridging research and policy, FGD can be useful in providing an insight into different opinions among different parties involved in the change process, thus enabling the process to be managed more smoothly. It is also a good method to employ prior to designing questionnaires.

Key issues discussed were similar to those already voiced during the community consultation meetings and included:

 Community benefits realized as a result of the sub-project scheme;  Resettlement and Environmental issues and mitigation measures according to Resettlement Framework prepared and approved by ADB and government Bangladesh for this project (no resettlement is required);  Participation of local community during the construction phase;  Roles and responsibilities of different stakeholders for realizing desired outcome;  Potential social and economic impacts of the proposed PTs construction.

7.2.3 Stakeholder Consultation

Consultation is a formal process by which the Commission collects input and views from stakeholders about its policies. Consultation is a continuous process and formal stakeholder consultations complement the Commission's broader interaction with stakeholders (e.g. meetings or exchanges or through existing permanent platforms for dialogue). The term 'stakeholder consultation' applies to all consultations with stakeholders in the process of the evaluation or the preparation of a policy initiative or the implementation of an existing intervention.

7.3 PUBLIC CONSULTATION HISTORY

Initial Public consultation has been carried out in the project area with the objectives of minimizing probable adverse impacts of the project and to achieve speedy implementation of the project through bringing in awareness among the community on the benefits of the project. As part of the project consultations, efforts were made to consult with the public as well as a number of local authorities, to

Package: CTEIP/KAL/PT/01: IEE 49 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE) determine their thoughts, opinions and feedback on the impact of the proposed Shelter in their respective locations. Information and comments collected from the public early in the study process were of use.

Different stakeholders were consulted to give them the opportunity to express their views and concerns. As part of the process, they were also provided with relevant and sufficient information on the project prior to its start-up. These stakeholders include the central and local authorities, as well as the local population so as to determine their thoughts, opinions and feedback on the impact of the project. Attendees in the consultation meeting were apprised of the processes through which the project was to proceed toward implementation and the environmental impacts to arise out of such processes along with the steps to be taken toward mitigating the impacts. They were told about the impacts all of which could be easily mitigated. The audience expressed satisfaction of such mitigation measures. The FGD / Public

Figure 17 FGD at Khepupara Nesaruddin Fazil PT site consultation was held during field visit in 28November 2017 (Figure 17).

As part of the impact assessment, the consultants conducted focus group discussions with selected groups at the locations of the proposed roads construction, refer to the Due Diligence Report given in Appendix G.

7.4 FINDINGS OF PUBLIC CONSULTATION MEETING

For details of the public consultations and Focus Group discussions held during the design stage of the sub-project, refer to the Due Diligence Report given in Appendix G. The people in the area largely depend on agriculture. Most of the people were keen to know the possibility of employment in the project. There is a requirement of about 120 people during the peak period of the project. The employment is largely depending on the types of job and will be assessed on a case to case basis by the contractor according to needs. The findings of the FGDs and Public Consultation are summarized in Table 19.

Table 19 Summary of the FGDs and Public Consultation

Happy for this project, as it comes to improve our hygiene system. There has been an increasing Question 01 demand for a PT in Kalapara. Answer Accepted thankfully Question What are the roles and responsibilities of construction and operations Managers? 02 Pourashava will play role as implementing agency in construction, operation and maintenance of Answer the proposed Roads in the Pourashava area Question How will Pourashava support cost for major maintenance? 03 This is the responsibility of the Pourashava to manage required fund for repair and maintenance, Answer as well as logistics during disaster period for realizing development objective of this project

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Question What will be the criteria for labour recruitment during construction? 04 This largely depends on the types of job and will be assessed on a case-to-case basis by the Answer contractor according to needs. Question How does this project help vulnerable people, people with disabilities? 05 The layout has provided separate space for male, female and pregnant women including separate Answer toilet. Ramp access to ground floor is provided to take care of people with disabilities. Question Priority for jobs should also consider women; women can do the same work. 06 Answer Priority will include women and there will not be any discrimination. Raised the issue of employment, he suggested that the local people should be the first ones to be Question employed in the project. 07 The consultant team explained that local people would be employed accordingly to job Answer requirement.

Question Wishes to speed up the project. 08 Answer It was explained that implementation would take place immediately after the rainy season. Question The construction creates lot of dust and noise, is there any increase anticipated. 09 The increase in dust and noise will be at construction site and all mitigation measures will be put in Answer place by the contractor

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CHAPTER 8: CONCLUSION AND RECOMMENDATIONS

8.1 CONCLUSIONS

Based on Project Description (Chapter 3), Environmental Baseline Data (Chapter 4), Environmental Impacts (Chapter 5), and Environmental Mitigation Measures, (SEMP in Annex F), the following conclusions are drawn: i) The sub-project of construction of PT is in plain terrain in the Kalapara District of Barisal Division. This is known as Package No. CTEIP/KAL/PT/01. The PTs have been selected based on criteria explained in PPTA. ii) The PPTA feasibility study has provided a comprehensive set of recommendations for the planning, design and implementation of the Project. Based on the recommendations of this study, the DDS Consultant has completed the detailed engineering design for the construction of PTs in Kalapara. iii) The construction of PTs in this area will help in economic development of the town. The PTs will help improve social and cultural environment and development of other sectors like agriculture, commerce and trade. Hence the proposed PTs will play an important role in economic growth and reduction of poverty. The supporting activities in trade and material supply will also be benefitted from the project. iv) The few minor adverse environmental impacts will occur during the construction period, and will be of a relatively short duration. Adequate provisions have been incorporated into the planning and design of the PTs to minimize or mitigate these unavoidable environmental impacts that are a result of the works. v) The major positive achievements of the sub-project are: a. Construction of PTs will serve not only the influence area but also the surrounding area in the town. b. Construction of PT will stimulate ancillary projects and subsequent investment which will improve economic status of the local population; c. More employment of people during construction phases; d. Will be potential socio-economic enhancement of rural economy by connecting people to other upazila and zilas; e. Skill Transfer and Training.

vi) The noise and air quality of the project area is within the permissible limits. The overall impact on air and noise quality during construction is limited to site and of short duration and can be mitigated. vii) It is proposed to plant trees on Khepupara Nesaruddin Fazil Madrasa site to mitigate the negative impacts. This will keep the ecological function in circulation. The noise impact at source will be mitigated by job rotation and use of ear plug and other measures suggested in EMP. Retaining wall is planned to protect the ponds from soil erosion and water pollution. In addition, embankments wherever required has been protecting against erosion due to climate change by jute fabric and sowing of grass. viii) The environmental mitigation measures as stipulated in the EMP and in the obtained environmental permit shall be monitored during implementation of the sub-project. In order to perform monitoring of EMP the contractor shall engage experienced laboratory and third- party services in complying the required environmental testing of parameters listed in SEMP. ix) The labour camp shall be established with the septic tank and soak pit for treatment and disposal of sewage and sludge water to avoid pollution of water bodies. Contractor has to make own arrangement for water supply for construction and domestic purpose. x) The environmental monitoring will be required before the start of the construction and during the construction phase. The parameters of Water Quality, Air Quality, Noise quality, and Soils shall be monitored; as specified in SEMP.

Package: CTEIP/KAL/PT/01: IEE 52 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

xi) During public consultation recommendations were drawn including: i) involve local communities in all stages of project planning and development, ii) establish permanent communication between project initiators and local authorities, iii) setup grievance redress mechanism which will publicized through Pourashava level co-ordination committee and monitoring register and iv) during construction, local people including women shall be given first priority in the employment of skilled and unskilled labour.

8.2 RECOMMENDATIONS

In view of above, it is concluded that the Project will bring benefit to the people of the area and especially during emergency created by cyclones. The negative impacts occurring during implementation are within the manageable limits and shall be mitigated with the proposed Environmental Management Plan and, hence, the project may be implemented.

8.3 DISCLOSURE OF ENVIRONMENTAL SAFEGUARDS INSTRUMENTS

The LGED will disclose this Environmental Management Framework by making copies available at its head office and in District / Pourashava where the Project is situated. The copies shall also be made available to the Local Government‟s Agencies, the Environmental and Social Group and other stakeholders. The Government of Bangladesh will also authorize the Asian Development Bank to disclose this IEE and EMP electronically through its InfoShop.

Package: CTEIP/KAL/PT/01: IEE 53 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ANNEXURE I: RAPID ENVIRONMENTAL ASSESSMENT CHECKLISTS Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali

Screening Questions Yes No Remarks A. Project Siting

Is the project area adjacent to or within any of the following areas:

 Underground utilities No

 Cultural heritage site No

 Protected Area No

 Wetland/Ponds No

 Mangrove No

 Estuarine No

 Buffer zone of protected area No

 Special area for protecting biodiversity No

 Bay No

B. Potential Environmental Impacts

Will the Project cause:

 Encroachment on historical/cultural areas? No

 Encroachment on precious ecology (e.g. sensitive or protected areas)? No

 Impacts on sustainability associated sanitation and solid waste disposal systems? No

 Dislocation or involuntary resettlement of people? No

 Disproportionate impacts on the poor, women and children, Indigenous Peoples or other No vulnerable groups?  Accident risks associated increased vehicular traffic, leading to loss of life? yes EMP to be followed

 Increased noise and air pollution resulting from increased traffic volume? Yes EMP: to be followed

 Occupational and community health and safety risks? yes EMP to be followed

 Risks and vulnerabilities related to occupational health and safety due to physical, No chemical, biological, and radiological hazards during project construction and operation?  Generation of dust in sensitive areas during construction? Yes EMP: to be followed

 Requirements for disposal of fill, excavation, and/or spoil materials? Yes EMP to be followed

 Noise and vibration due to blasting and other civil works? Yes EMP: to be followed

 Long-term impacts on groundwater flows as result of needing to drain the project site prior No to construction?  Long-term impacts on local hydrology as a result of building hard surfaces in or near the No building?  Large population influx during project construction and operation that causes increased burden on social infrastructure and services (such as water supply and sanitation No

systems)?  Social conflicts if workers from other regions or countries are hired? No

 Risks to community safety caused by fire, electric shock, or failure of the buildings safety No features during operation.  Community health and safety caused by management and disposal of waste? yes EMP to be followed

 Community safety risks due to both accidental and natural hazards, especially where the structural elements or components of the project are accessible to members of the affected No community or where their failure could result in injury to the community throughout project construction, operation and decommissioning? Note: Hazards are potentially damaging physical events.

Package: CTEIP/KAL/PT/01: IEE 54 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ANNEXURE II: GRIEVANCE REGISTRATION FORM (Bangla translation to be available) The Coastal Towns Environmental Infrastructure Project (CTEIP) welcomes complaints, suggestions, queries and comments regarding project implementation. We encourage persons with grievance to provide their name and contact information to enable us to get in touch with you for clarification and feedback.

Should you choose to include your personal details but want the information to remain confidential, please inform us by writing/typing *(CONFIDENTIAL)* above your name.

Date Place of Registration

Contact Information/Personal Details

Name Gender * Male Age

* Female

Home Address

Place

Phone no.

E-mail

Complaint/Suggestion/Comment/Question Please provide the details (who, what, where, and how) of your grievance below:

If included as attachment/note/letter, please tick here:

How do you want us to reach you for feedback or update on your comment/grievance?

FOR OFFICIAL USE ONLY

Registered by: (Name of Official Registering Grievance)

Mode of Communication:

Note/Letter

E-mail

Verbal/Telephonic

Reviewed by: (Names/Positions of Officials Reviewing Grievance)

Action Taken:

Whether Action Taken Yes Disclosed: No

Means of Disclosure:

Package: CTEIP/KAL/PT/01: IEE 55 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ANNEXTURE IIIa: CATEGORIZATION FORM INVOLUNTARY RESETTLEMENT IMPACT CATEGORIZATION

Date: ___/___/2018

A. Project Data

Country/Project No./Project : Country: Bangladesh Title ADB No.: (No. to be designated) Coastal Towns Environmental Infrastructure Project (CTEIP) Subproject: e-GP/CTEIP/2017-18/KAL/PT/01

B. Involuntary Resettlement Category

[ ] New [ ] Recategorization ― Previous Category [ ]

 Category A  Category B  Category C  Category FI

C. Comments

Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali

No resettlement issues.

Package: CTEIP/KAL/PT/01: IEE 56 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ANNEXURE IIIb: INVOLUNTARY RESETTLEMENT IMPACT CATEGORIZATION CHECKLIST Construction of 2 nos. Public Toilets in Kalapara Pourashava, District: Patuakhali

Not Probable Involuntary Resettlement Effects Yes No Remarks Known Involuntary Acquisition of Land 1. Will there be land acquisition? No Not 2. Is the site for land acquisition known? applicable Not 3. Is the ownership status and current usage of land to be acquired known? applicable Not 4. Will easement be utilized within an existing Right of Way (ROW)? applicable Not 5. Will there be loss of shelter and residential land due to land acquisition? applicable 6. Will there be loss of agricultural and other productive assets due to land Not acquisition? applicable Not 7. Will there be losses of crops, trees, and fixed assets due to land acquisition? applicable Not 8. Will there be loss of businesses or enterprises due to land acquisition? applicable 9. Will there be loss of income sources and means of livelihoods due to land Not acquisition? applicable

Involuntary restrictions on land use or on access to legally designated parks and protected areas

10. Will people lose access to natural resources, communal facilities and services? No

11. If land use is changed, will it have an adverse impact on social and economic No activities? 12. Will access to land and resources owned communally or by the state be No restricted? Information on Displaced Persons: Not Applicable Any estimate of the likely number of persons that will be displaced by the Project? [--] No [--] Yes If yes, approximately how many? ______

Are any of them poor, female-heads of households, or vulnerable to poverty risks? [--] No [--] Yes

Are any displaced persons from indigenous or ethnic minority groups? [--] No [--] Yes

Note: The project team may attach additional information on the project, as necessary.

Package: CTEIP/KAL/PT/01: IEE 57 Section 6: Employer’s Requirements: Subsection 3 Particular Specification: Appendix-E: Initial Environmental Examination (IEE)

ANNEXURE IV: LIST OF PARTICIPANTS (FGD)

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