Initial Environmental Examination ______

February 2015

Elongi Model High School Chhatak, Sunamganj, Bangladesh

BAN: Secondary Education Sector Investment Program (SESIP)

Prepared by the Directorate of Secondary Education and Ministry of Education. Table of Contents Abbreviation v Glossary vii Executive Summary ix

Chapter - 1 Project Description

1.1 Project Background 1 1.2 Legislative Requirements 2 1.2.1 Safeguard Requirements of ADB 2 1.2.2 Safeguard Requirements of the Government of Bangladesh 3 and Environmental Clearance requirement 1.2.3 Other Policies and Legislations 4 1.3 Description of the Project 5 1.3.1 Type of the Project 5 1.3.2 Location of the Project 6

Chapter - 2 Description of Existing Environment in the Project Area 2.0 General Consideration 13 2.1 Physical Environment 13 2.1.1 Land Form and Soil Classification 14 2.1.2 Hydrology 14 2.1.3 Water Quality 15 2.1.3.1 Surface Water Quality 15 2.1.3.2 Ground Water Quality 15 2.1.4 Air Quality 15 2.1.5 Ambient Noise Level 16 2.1.6 Climatic Condition 16 2.1.6.1 Rainfall 16 2.1.6.2 Wind 16 2.2 Biological Environment 16 2.2.1 Terrestrial Flora and Fauna 16 2.2.2 Aquatic Flora and Fauna 16 2.3 Socio-Economic and Physical Cultural Resources 17 2.3.1 Socio-Economic Resources 17 2.3.2 Physical Cultural Resources 19

Chapter - 3 Potential Environmental Impacts And Mitigation Measures

3.0 Introduction 20 3.1 Beneficial Impacts and Enhancement Measures 24 3.1.1 Impact at Pre –Construction Phase 25 3.1.2 Impact at Construction Phase 25 3.1.3 Impact at Operation Phase 25 3.2 Adverse Impacts And Mitigation Measures 26 3.2.1 Impact at Pre-construction Phase 29 3.2.2 Impact at Construction Phase 30 3.2.3 Impact at Operation Phase 33

Chapter - 4 Analysis of Alternatives 4.0 The ‘No Build’ Scenario 36 4.1 Consideration of Alternatives 36 4.2 Site Alternatives 36

Chapter - 5 Institutional Arrangements 5.0 Introduction 37 5.1 Institutions Associated with the Project 37 5.2 Institutional Capacity of Executing and Implementing Agency 37 5.3 Key Responsibilities of Executing and Implementing Agency, 38 EED 5.4 Key Responsibilities of the Contractor 39 5.5 Capacity Building and Training 40 Chapter - 6 Environmental Monitoring And Management Plan

6.0 Introduction 41 6.1 Environmental Management Plan (EMP) 41 6.2 Environmental Management During Construction Phase 47 6.2.1 Overview of Impacts and Mitigation Measures 47 6.2.2 Air Quality Management 47 6.2.3 Management of Solid Wastes 47 6.2.4 Noise and Vibration Level Management 47 6.2.5 Health and Safety Management 47 6.2.6 Sanitation Management 47 6.3 Environmental Management during Operation Phase 48 6.3.1 Overview of Impacts and Mitigation Measures 48 6.3.2 Water & wastewater Management 48 6.3.3 Socioeconomic Impact Management 48 6.3.4 Greening Program 48 6.3.5 School Management 49 6.3.6 Disaster Management 49 6.4 Monitoring Requirement 49 6.5 Monitoring Indicators 50 6.6 Cost of Monitoring 51

Chapter - 7 Information Disclosure, Public Consultation and Participation 7 Information Disclosure, Public Consultation and 53 Participation

Chapter - 8 Grievance Redress Mechanism 8 Grievance Redress Mechanism 56

Chapter- 9 Conclusion and Recommendations 9.1 Conclusion 60 9.2 Recommendations 60

List of Tables

Table 3.1 Checklists of Construction of multistoried building for 21

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District/Upazilla Education Office Table 3.2 Summary Analysis of Beneficial Impacts 24 Table 3.3 Summary Analysis of Adverse Impacts 27 Table 6.1 Environment Management and Monitoring Matrix 42 Table 6.2 Monitoring plan during construction phase of the project 50 Table 6.3 Monitoring plan during operational phase of the project 51

Table 6.4 Cost estimate for environmental monitoring measures during 51 construction Table 6.5 Cost estimate for environmental monitoring measures during 52 operation

List of Figures

Fig: 1.1 Sample photograph of Elongi Model School 5 Fig: 1.2 Bangladesh Map 7 Fig: 1.3 Sunamganj District map 8 Fig: 1.4 Chhatak Upazila Map 9 Fig: 1.5 Satellite Image of Proposed Project. 10 Fig: 1.6 Location map of the Proposed Project 11 Fig: 1.7 Pictures of the Project Site 12 Fig: 2.1 1 km Study Area of the Project 14 Fig: 7.1 Photograph of Consultation meetings 54 Fig: 8.1 Flowchart of Complaints/Grievance Redress Procedure 57 Fig: 8.2 Grievance Form 59

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ABBREVIATION

ADB Asian Development Bank BMD Bangladesh Meteorological Department BNBC Bangladesh National Building Code

CO2 Carbon Dioxide DOE Department of Environment DSHE Directorate of Secondary and Higher Education, ECA Environment Conservation Act 1995 ECR Environment Conservation Rules 1997 EED Education Engineering Department EMP environmental management plan GOB Government of Bangladesh IEE Initial environment examination NEMAP National Environmental Management Action Plan NGO Non-Government Organization NOx Oxides of Nitrogen OP Operation Policy PDPAPs Project Director,Affected Persons PIU Project Implementation Unit

PM2.5 Particulate Matter < 2.5µm

PM10 Particulate Matter < 10µm PPE Personal Protective Equipment PV Photo Voltaic REA Rapid Environmental Assessment SESIP Secondary Education Sector Investment Program

SO2 Oxides of Sulfur SPM Suspended Particulate Matter SPS Safeguard Policy Statement TOR terms of reference

WEIGHTS AND MEASURES oC degree Celsius dB(A) decibel acoustic km kilometer

Page | v km/h kilometer per hour kWe kilowatt-electric

KV Kilo volt(s)

KVA kilo Volt-Amps m meter mm millimeter m3 cubic meter m3/hr cubic meters per hour mg/l milligrams per liter m/s meters per second

MTPA metric tons per annum

MW megawatt ppm parts per million ppt parts per thousand

Rpm revolutions per minute

TPD tons per day

μg/m3 microgram per cubic meter

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GLOSSARY

Adverse impact: An impact that is considered undesirable.

Ambient air: Surrounding air.

Aquatic: Growing or living in or near water.

Baseline (or existing) conditions: The ‘baseline’ essentially comprises the factual understanding and interpretation of existing environmental, social and health conditions of where the business activity is proposed. Understanding the baseline shall also include those trends present within it, and especially how changes could occur regardless of the presence of the project, i.e. the ‘No-development Option’.

Beneficial impacts: Impacts, which are considered to be desirable and useful.

Biological diversity: The variety of life forms, the different plants, animals and micro organisms, genes they contain and the ecosystems they form. It is usually considered at three levels: genetic diversity, species diversity and ecological diversity.

Ecosystem: A dynamic complex of plant, animal, fungal and microorganism communities and associated non-living environment interacting as an ecological unit.

Emission: The total amount of solid, liquid or gaseous pollutant emitted into the atmosphere from a given source within a given time, as indicated, for e.g., in grams per cubic meter of gas or by a relative measure, upon discharge from the source.

Endangered species: Species in danger of extinction and whose survival is unlikely if the existing conditions continue to operate. Included among those are species whose numbers have been reduced to a critical level or whose habitats have been so drastically reduced that they are deemed to suffer from immediate danger of extinction.

Environmental effects: The measurable changes, in the natural system of productivity and environmental quality, resulting from a development activity.

Environmental Impact: An estimate or judgment of the significance and value of environmental effects for natural, socio-economic and human receptors.

Environmental Management: Managing the productive use of natural resources without reducing their productivity and quality.

Environment Management Plan (EMP): A Plan to undertake an array of follow-up activities which provide for the sound environmental management of a project/ intervention so that adverse environmental impacts are minimized and mitigated; beneficial environmental effects are maximized; and sustainable development is ensured.

Erosion: Process in which wind and water removes materials from their original place; for instance, soil washed away from an agricultural field.

Evaluation: The process of looking back at what has been really done or accomplished.

Fauna: A collective term denoting the animals occurring in a particular region or period.

Flora: All of the plants found in a given area.

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Habitat: The natural home or environment for a plant or animal.

Household: A household is identified as a dwelling unit where one or more persons live and eat together with common cooking arrangement. Persons living in the same dwelling unit having separate cooking arrangements constitute separate household.

Initial Environmental Assessment / Evaluation: Preliminary analysis undertaken to ascertain whether there are sufficient likely significant adverse impacts to warrant a ‘full’ EIA. In some countries, use of initial assessment forms a meaning of “screening” proposed projects.

Land use: Types include agriculture, horticulture, settlement, pisciculture and industries.

Mitigation: An action, which may prevent or minimize adverse impacts and enhance beneficial impacts.

Negative Impact: Negative change from the existing situation due to the project.

Public involvement / Public consultation: A range of techniques that can be used to inform, consult or interact with stakeholders’ affected / to be affected by a proposal.

Stakeholders: Those who may be potentially affected by a proposal, e.g. Local people, the proponent, government agencies, NGOs, donors and others, all parties who may be affected by the project or to take an interest in it.

Taka: Unit of Bangladeshi currency.

Terrestrial: Living on land.

Thana: Sub-district level of government administration, comprising several unions under district.

Union: Smallest unit of local self-government comprising several villages.

Upazila: Sub-district name. Upozila introduced in 1982.

Zila: Bengali word of district.

NOTES

This Initial Environmental Examination (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. Your attention is directed to the “terms of use” section of the ADB website.

In preparing any country program or strategy, financing any projects, or by making any designation of or reference to a particluar 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.

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EXECUTIVE SUMMARY

1. Project Description

Secondary Education Sector Investment Program (SESIP) will support the GOB’s 10 year plan to improve secondary education of Bangladesh into a more efficient, equitable, and higher- quality secondary education system using a multi tranche financing facility (2013–2023) with assistance of Asian Development Bank (ADB) and other development partners. This program will promote secondary education by upgrading the physical facilities and equipment of government secondary schools, constructing new upazila and district education offices, including school infrastructure development – construction and renovation of school buildings, including science labs, stack yards, and Madrasah Teaching Training Institute and upgrading Directorate of Secondary and Higher Education (DSHE) building.

Under this Secondary Education Sector Investment Program (SESIP), 3 to 4 storied school building is going to be constructed near the existing school building of Elongi Model High School at Kanchanpur village, Uttar Khuma Union, Chhatak Upazilla, Sunamganj district of Bangladesh. The project site is located at around 12 km west from Govindaganj crossing on Sylhet-Sunamganj road where Chhatak Upazila is 28 km road distance from the project site.

Considering that the program is expected to have limited and minimum adverse environmental impacts, the project is categorized as “B” for environment and an initial environment examination (IEE) is therefore has been carried out as per ADB environmental screening category. This report presents the results of Initial Environmental Examination (IEE) Study for the proposed Elongi Model High School new building to ensure that the potential adverse environmental impacts are appropriately addressed in line with ADB’s Safeguard Policy Statement (SPS, 2009) and the environmental laws, policies, and regulations of the Government of Bangladesh (GOB).

2. Description of Existing Environment in the Project Area

Baseline environment is concerned with existing physical, biological and socio economic conditions of the area where the project is going to be set up. The land form and soil type, surface water, ground water, ambient air quality and noise level have been analyzed to evaluate the primary baseline of the area.

Chhatak Upazila (Sunamganj district) with an area of 434.76 km2, is bordered by Dowarabazar Upazila to the north, Jagannathpur Upazila to the south, Companiganj, Sylhet Sadar Upazila, and Bishwanath Upazila to the east, Sunamganj Upazila to the west. The Surma river flows through the Chatak town, which is a major way of transportation in the area since the road and rail aren't such reliable. From the literature, it is found that the area occupies on relatively higher parts of Surma-Kusiyara Floodplain and Noncalcareous Grey Floodplain soils are the only general type.

The area has a subtropical climate with maximum temperature range from 25-31oC and minimum temperature range of 13-25oC. The morning humidity varies from 83 percent in March to 96-97 percent for most of the rest of the year. June is the wettest month with an average precipitation of 1,370 mm, while November and December are the driest months, with an average precipitation of 6-7 mm. Almost 80 percent of the total rainfall (5900 mm) takes place during the monsoon season. Because of the funnel-shape formation of the land mass in the upper portion of the Bay of Bengal where Bangladesh is located, cyclones often have disastrous

Page | ix effects. The Project site is close to the Himalayan foothills, and it is not affected by the damaging storm surges created by the cyclones. The prevailing wind direction is southeasterly and easterly from January to March and northeasterly from April to December. The wind speed is 4 to 8 m/second.

Despite the two cement plants, one pulp and paper factory and a number of smalls scale lime producers, the air quality in the area is relatively good.

There is hardly any forest at Sunamganj area. Flora consists of various type shrubs, herbs and other agricultural crops. Fish stocks have been depleted by over fishing. Common freshwater fishes in this region are cirrhinus reba, labeo bata, silonia, pangasium, and badis badis. Domesticated animals such as goats, cow, ducks, and chickens are the main fauna in the area.

According to Bangladesh Bureau of Statistics, total population in this region is 334546; male 171761, female 162785. Main sources of income of people living here is agriculture. Average literacy rate is 36.3%; male 40.0%, female 32.4%. Some important manufactories are present such as: Chhatak Cement Factory, Chhatak Pulp and Paper Mill, Lafarse Surma Cement Company etc.

3. Potential Environmental Impacts and Mitigation Measures

The construction of the project can create some adverse impact on the existing environment. The acoustic impacts, dust emission, traffic congestion, safety and sanitation during the construction period would be limited to construction of building and site preparation. Since the new building would be set up in existing school premises, the resettlement won’t be an issue here. During construction, the contractor will adopt all necessary measures to reduce the probable environmental impacts from different aspects. There are minimal impacts during operation period and school administration will be responsible to take necessary steps during operation.

The significant impacts in different phases i.e. (i) due to project location and preparation, (ii) construction phase and (ii) operation phase have been identified using the checklist process. From this process, the main potential environmental impacts, which may arise due to construction, can be grouped as follows: (i) Atmospheric emissions and Air quality, (ii) Noise generation, (iii) Water pollution and waste water disposal, and (iv) Health and safety.

These aspects have been examined and the findings are summarized below:

(i)

Summary Analysis of Beneficial Impacts: Alongi Model High School

Project Activities Beneficial Impacts

Pre-Construction 1. Land value  Land value enhancement anticipated due to the development

Construction

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Summary Analysis of Beneficial Impacts: Alongi Model High School

Project Activities Beneficial Impacts

2. Employment  Major employment opportunity (positive impact)

3. Increasing local  Local business will be enhanced due to the construction activities business

 Safe drinking water supply 4. Installation of tube well

Operation 5. Socio -economic  New construction of educational institutes will attain more access and impact retention of students.  Development of secondary education may develop the society and neighbourhood.

6. Landscaping  A net increase in green cover would provide increased habitat for birds and small mammals (Positive impact). 7. Renewable energy  Solar panel may be installed at the roof of the building to save energy and option CO2 emission.

8. Rain water  Provision of “Rain water harvesting” systems in the building will meet the harvesting water demand.

(ii)

Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

Pre-Construction 1. Land acquisition  Loss of access to the site (students playing in the area); inconvenience.

2. Site preparation,  Clearing of vegetation (minor impact). clearing and  Reduction in visual aesthetics of the current land (access road, truck traffic, earthworks construction equipment and eventually a building on site).  Land development may create problems in local drainage pattern (minor impact).  Emission of Dust (minor impact).  Improper management of construction debris and solid waste may pose risk to the students and others (minor impact).

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Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

 Associated noise (minor impact).

Construction 3. Influx of workers  Health & safety of workers at site may pose to risk in some cases (minor impact).  Concentration of labor force creates un-hygienic condition and risk of safe drinking water and sanitation hazard (medium adverse impact).

4. Construction  Piling, brick/stone crushing and equipment installations may create noise equipment / materials (minor impact)  Carrying of construction materials may create traffic congestion (minor impact).  Cutting/filling, stockpiling of construction material and traffic movement may create dust emission (minor impact)  Improper site security, poor management of construction debris and solid waste may pose risk to the workers, current students and others (minor impact).

5. Vehicle and  Slightly more congestion near the main entrance to the School (minor pedestrian traffic impact).  Increased number of vehicles on local roads will result in increased wear and tear of local roads thus reducing lifespan of affected roads (minor impact).  Pedestrians and cyclists using local roads will have to exercise more care with increase of vehicular traffic on the said roads (minor impact).  There will be an increase of exhaust emission from vehicles, which will pollute local atmospheric air (minor impact). 6. Employment of  The Environmental and Social Safeguard Policies of the DOE/ADB child labour in the prohibits all kinds of child labour (lower than 14 years) and personnel construction activities engagement in construction works of the projects.

Operation 7. School  Improper seating arrangement Environment  Insufficient interval time between classes  Poor condition of classrooms  Unsatisfactory Teacher Student ratio  Gender inequity  Absence of separate washrooms for boys and girls

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Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

 Suffocation problem if improper ventilation  Safe drinking water supply to the students 8. Vehicle and  Slightly more congestion near the main entrance to the School (minor pedestrian traffic impact). adjacent to School  Increased number of vehicles on local roads will result in increased wear building and tear of local roads thus reducing lifespan of affected roads; (minor impact).  Pedestrians and cyclists using local roads will have to exercise more care with increase of vehicular traffic on the said roads; (minor impact).  There will be an increase of exhaust emission from vehicles, which will pollute local atmospheric air (minor impact).

9. Generation of  Risk of poor solid waste management. consumables  Risk of sanitation hazard.

10. Increased  Increased risk of water shortages and electricity load shedding. demand on local services

11. Extreme climate  Sunamganj is a flood and earthquake prone area. events, disasters and  Fire hazard or any medical emergency may arise during operation of the emergency school.

4. Analysis of Alternatives

The ‘No Build’ alternative in the present case would mean there would be shortage of classrooms and other facilities in Elongi Model High School and hence, the development of secondary education of Chhatak will be hampered. So, the 'No build' alternative is unacceptable, and the potential socioeconomic benefits of implementation of such a project far outweigh the adverse impacts, all of which can be controlled and minimized to an acceptable level.

The proposed school building site is owned by Elongi Model High School and is a vacant land, thus involved no resettlement issues. So, there is no logic to find alternative site for the project since it is in the existing school premises.

5. Institutional Arrangements

Ministry of Education, Bangladesh implements their all national policies and development projects in secondary and higher education sector through the Directorate of Secondary and Higher Education (DSHE). The DSHE has been allocated public funds from the Government of

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Bangladesh (GOB) under a loan from Asian Development Bank (ADB) towards the Secondary Education Sector Development Program (SESIP). DSHE has given the responsibility of planning, designing, implementing and supervising the construction of Elongi Model High School to Education Engineering Department (EED). The operation of Elongi Model High School will be managed by the school management and periodically supervised by SESIP. EED is expected to maintain the direct responsibility for environmental management plans associated with all the SESIP civil works. However, EED will engage contractor for the construction of Elongi Model High School through bidding. Building contractors will be responsible to take all the necessary measures adopting the Environmental Code of Practices during construction period. The implementation of the EMP and/or Environmental Code of Practices by the contractor(s) is to be supervised by the Construction Supervision Consultant, in close consultation with the project implementation unit (PIU) of EED.

6. Environmental Monitoring and Management Plan

In the context of a project, Environmental Management Plan (EMP) is concerned with the implementation of the measures necessary to minimize and offset the adverse impacts and to enhance beneficial impacts. Unless the mitigation and benefit enhancement measures are identified and fully implemented, the prime function of the IEE cannot be achieved.

For surveillance of the environmental performance of a project continuous monitoring of the quality of the local environment, environment in the work-zone and the general impact zone have to be performed. For a three story building, monitoring is mainly important during the construction phase. The EED (Education Engineering Department) is responsible to implement the overall environmental monitoring and management plan. However, during the construction stage, the contractors are responsible to mitigate all environmental impacts related with the construction activities. School Headmaster, school management and SESIP will monitor the school environment during operation stage of the building.

7. Information Disclosure, Public Consultation and Participation

Public consultations are very important and sensitive issues for setting up a new project in any area of Bangladesh. Given the very limited scope of this project (construction of a 3-storey school building), and the expected almost negligible environmental impacts associated with building construction, public consultation and participation processes have been just preliminary to date. Initial information disclosure and consultation were undertaken during the field visit in February 2015.

In the consultation process, local communities, Public representatives, school teachers and local government personnel were consulted.

8. Grievance Redress Mechanism

As a result of this public participation during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. To settle such issues effectively, an effective and transparent channel for lodging complaints and grievances will be established. The Grievance Mechanism will be implemented during both the construction and operational period of the project to ensure that all complaints from students, teachers and local communities are dealt appropriately, with corrective actions being implemented, and the complainant being informed of the outcome. It will be applied to all complaints from affected

Page | xiv parties. The school shall set-up a grievance redress committee that will address any complaints during both the construction and operational period of the project.

9. Conclusion and Recommendations

Though there are certain adverse environmental impacts associated with the implementation of Elongi Model High School, these are manageable provided recommendations in the EMP are followed with due diligence.

The project is indispensable in view of the current secondary education at Chhatak. The impact on the social environment is positive given the secondary education at Chhatak will be developed and more access opportunities will be created for local students from the project. The project will help in socioeconomic growth and improving quality of education at Chhatak.

One of the most critical issues for the project is safety. This has been adequately addressed through compliance with national building code (BNBC) in the construction to ensure safety during natural disasters like earthquake.

The project has been designed to comply with the country’s environmental laws and regulations, especially on air emissions, ambient air quality, wastewater effluent, and noise. The project management has taken steps to ensure that the project meets the ADB’s environmental standards.

Given the proponent’s commitments, actions undertaken for further measures to be adopted in due course of time as required, Elongi Model High School is going to be an important and environmentally sustainable school development project.

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1 PROJECT DESCRIPTION

1.1 BACKGROUND

1. The Government of Bangladesh (GOB) recognizes education, which stimulates and empowers people to participate in their own development, as the most important instrument for reducing poverty and improving the quality of life. Therefore, The GOB placed priorities for the overall development of the education scenario of Bangladesh at different levels i.e. Primary, Secondary and Higher Secondary Levels. Commitment to improving the education condition of Bangladesh in all levels has led the Government of Bangladesh towards the Secondary Education Sector Investment Program (SESIP) which will support the overall secondary education development in Bangladesh.

2. The National Education Policy (NEP) of the Government of Bangladesh (GOB) has been approved by the National Parliament of Bangladesh in 2010. It envisions a holistic and balanced development of the entire education sector, aiming for all children to complete eight years of primary education and continue for four years of secondary education, considered as a job entry point. Hence, with the context of the implementation strategy of the NEP-2010, the Secondary Education Sector Investment Program (SESIP) has been designed by GOB, taking the Asian Development Bank (ADB) as a core development partner, in particular, to support implementation of key reforms envisaged in the Policy using a multi tranche financing facility (MFF) (2013-2023) in a phased manner. SESIP was approved by ADB’s Board on 27 September 2013, and the Periodic Financing Request 1 (Tranche 1) for $90 million (2013–2017) was approved by the ADB President on 21 October 2013. A Sector Wide Approach (SWAp) that supports the government to lead common secondary education program framework with the enhanced harmonization of ADB and other development partners’ assistance has been adopted aiming at three outputs: (i) Enhanced Quality & Relevance of Secondary Education; (ii) Increased Equitable Access and Retention of all Students, and (iii) Strengthened Secondary Education Management and Governance.

3. SESIP will support school infrastructure improvement for equitable access for all students. Facilities will support enhanced use of information and communication technology for pedagogy, and include construction/renovation for school information hubs (640 schools), construction of 385 School buildings, vertical extensions and outfitting for training venues in 64 District Education Offices (DEOs), upgrading of 100 priority schools/madrasahs, new DSHE building construction, and provision of safe drinking water, sanitation, and drainage facilities.

4. This is a new school building project for Elongi Model High School, Chhatak, Sunamganj of SESIP with a view to improving the secondary education sector of Chhatak upazila.

5. This Initial Environmental Examination (IEE) Study Report for the proposed construction project of Elongi Model High School, a 3 to 4 storied building to be constructed under the Secondary Education Sector Investment Program (SESIP), at Kanchanpur village, Uttar Khuma Union, Chhatak Upazilla, Sunamganj district of Bangladesh. The project site is located at around 12 km west from Govindaganj crossing on Sylhet-Sunamganj road where Chhatak Upazila is 28 km road distance from the project site. The environment assessment has been carried out to ensure that the potential adverse environmental impacts are appropriately addressed in line with ADB’s SPS, 2009, Environmental Policy, 2002, and Environmental Assessment Guidelines, 2003.

1.2 Legislative Requirements

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6. The implementation of the SESIP related infrastructural works and the other subproject will be governed by ADB’s Safeguard Policy Statement (SPS, 2009) and the environmental laws, policies, and regulations of the Government of Bangladesh (GOB).

7. As an institutional arrangement, Government of Bangladesh has designated the “Department of Environment" (DOE) with the sole responsibility for the regulatory functions to enforce of the provisions of environmental laws, rules and regulations to prevent environmental degradation in the country. Under these legal provisions, the industrial/project proponents must take mitigation measures for protecting the environment from pollution impacts and must get ‘Environmental Clearance’ from DOE before setting up and running their projects. These rules are equally applicable to both new and the existing projects. There are some other sectorial rules related to the projects, which predate environmental legislations. These legislations have become effectively obsolete with the promulgation of the ECA, 1995 and the ECR, 1997 and their subsequent amended versions.

1.2.1 Safeguard Requirements of ADB

8. All projects funded by ADB must comply with ADB’s SPS, 2009 and Operational Manual F1, 2010. The purpose of the SPS is to establish an environmental review process to ensure that projects undertaken as part of programs funded under ADB’s loans are environmentally sustainable and sound, are designed to operate in compliance with applicable regulatory requirements, and are not likely to cause significant environmental, health, or safety hazards. ADB’s SPS include operational policies that seek to avoid, minimize, or mitigate adverse environmental and social impacts, including protecting the rights of those likely to be affected or marginalized by the development process. For ‘Category A’ project, an EIA including an EMP is required. For ‘Category B’, an IEE, including an EMP, is required and for ‘Category C’, an EIA or IEE is not required, although environmental implications need to be reviewed through preparation of a due diligence report (DDR). The proposed program has been categorized as ‘Category B’ from an environmental point of view and an IEE, along with EMP, are required to be prepared and disclosed. The assessment will be carried out to ensure that the potential adverse environmental impacts are appropriately addressed in line with ADB’s SPS, 2009.

1.2.2 Safeguard Requirements of the Government of Bangladesh and Environmental Clearance requirement

9. A wide range of policies, laws, and regulations related to environmental issues are in place in Bangladesh. The main provisions for environmental protection and pollution control in Bangladesh are contained in the Environmental Conservation Act, 1995 and Environmental Conservation Rules (ECR), 1997. Under the ECR, projects are classified as ‘Green’, ‘Orange A’, ‘Orange B’, and ‘Red’ to determine the level of environmental assessment required.

10. Green Category projects are considered relatively pollution-free and hence do not require initial environmental examination (IEE) and EIA. An environment clearance certificate (ECC) from the Department of Environment (DoE) is adequate for a project that fall into the Green category.

11. Orange Category projects fall into two categories. ‘Orange A’ projects are required to submit general information, a feasibility report, a process flow diagram and schematic diagrams of waste treatment facilities along with their application for obtaining DoE environmental clearance. Orange B projects are required to submit an Initial Environmental Examination (IEE) report, along with their application and the information and papers specified for Orange B projects.

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12. Red Category projects are those which may cause significant adverse environmental impacts and are, therefore, required to submit an EIA report. It should be noted that they may obtain an initial site clearance on the basis of an IEE report, and subsequently submit an EIA report for obtaining environmental clearance along with other necessary papers, such as feasibility study reports and no objections from local authorities. The DoE has recently developed IEE and EMP checklists in order to simplify the preparation of conventional and voluminous IEE and EMP reports that contain irrelevant and unnecessary information.

13. As per ECR ‘97 all existing and new industries and projects in Orange B and Red category require an Environmental Management Plan (EMP) to be prepared (after conducting an IEE or EIA) and submitted along with other necessary papers while applying for environmental clearance.

14. Construction of multi-storied buildings is considered as ‘Orange B’ category in ECR, 1997. However, there is no fixed definition of a multi-storied building. In practice, a building of more than 10 stories within Dhaka City (as per building construction rules of RAJUK) and a building of more than 6 stories outside of Dhaka city will be considered as ‘Orange B’ category. It is expected that the physical facilities outside of the Dhaka will not be more than 6 storied building and as such, no environmental clearance will be required. If new construction of more than 6 storied building is considered, Initial Environmental Examination (IEE) and Environmental Management Plan (EMP) would be required to get the environmental clearance from the Department of Environment (DOE) as per ECR ’97.

1.2.3 Other Policies and Legislations

15. In addition to the Environmental Conservation Act and Rules, there are a number of other policies, plans and strategies which deal with the water sector, agricultural development, coastal area, protected area, disaster management and climate change. These are the National Water Policy, 1999; the Forest Act 1927 (last modified 30th April 2000); National Forest Policy, 1994; the National Conservation Strategy 1992; National Environmental Management Action Plan (NEMAP) 1995; National Policy for Safe Water Supply and Sanitation 1998, National Policy for Arsenic Mitigation 2004, National Sanitation Strategy 2005, Coastal Zone Policy, 2005; National Food Policy 2006; Coastal Development Strategy, 2006; National Agricultural Policy, 1999; National Fisheries Policy, 1996; National Livestock Development Policy, 2007; Standing Orders on Disaster, 1999 (revised in 2010); National Adaptation Programme of Action, 2005 (revised in 2009),Bangladesh Capacity Development Action Plan for Sustainable Environmental Governance 2007, Bangladesh Climate Change Strategy and Action Plan, 2009; National Plan for Disaster Management, 2010-2015; Solid Waste Management Rules 2010, Noise Pollution (Control) Rules 2006, etc. The Bangladesh National Building Code, 2006 and Bangladesh Labor Act, 2006 will also be important regarding the occupational health and safety of workers and laborers to be involved in the Project’s infrastructure development. Besides these the Cabinet has recently approved “Environment Court Bill 2010‟ and Bangladesh Wildlife (Preservation) Bill 2010.

16. The National Building Code 2006 and National Labor Act 2006 have defined certain measures to ensure proper safety and work environment as well as the compensation measures to the laborers. By national law, in order to be compensated, contractors must follow these safety provisions and compensation arrangements. The implementing agency must ensure that the appropriate occupational health and safety provisions have been included in the bidding documents and are being implemented by contractor. Many schools in disaster prone areas are also used as cyclone/flood shelters for the community. If the school will be considered as shelter, the concerned District Committee should be consulted about its location and other information. As per the Safe Drinking Water Supply and Sanitation Policy 1998, provision for arsenic safe drinking water and adequate sanitation will

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have to be ensured for schools. The water quality needs to be monitored to ensure that the supplied water is safe for drinking.

17. As per categorization, the proposed building of Elongi Model High School, at Chhatak, Sunamganj, Bangladesh falls under the category ‘B’ for ADB. Category-B projects are considered to have relatively minimum environmental impact; hence, Initial Environmental Examination (IEE) along with Environment Management Plan (EMP) is required to be carried out. It is expected that the building will not be more than 6 stories and as such, no environmental clearance will be required from DOE of GOB. If a new construction of more than 6 stories is considered, IEE and EMP would be required to get the environmental clearance from DOE as per ECR, 1997.

1.3 Description of the Project

18. The proposed project is quite straightforward. It will involve construction of a School building in the vicinity of Kanchanpur Village, which is about 28 km road distance from Chhatak Upazila. Though there is no school building design available at this moment but SESIP has planned to build the school buildings based on their previous school design (3-4 stories straight building with a wide stair at the middle of the building and long corridor at each floor). As is common in most Government buildings in Bangladesh, the outer façade is brick and flat roof. Figure 1.1 shows some typical school building of SESIP.

Figure 1.1: Proposed Sample Photograph of a School Building

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1.3.1 Location of the Project

19. The Project location is 24°58'12.28"N & 91°38'2.35"E of Kanchanpur Village. The most commonly used communication way with Chhatak upazila is by Bus. The Uttar Khurma Union is about 28 km from Chatak Upazilla and 12 km from the Gobindaganj crossing towards on Sylhet-Sumanganj road towards Sunamganj. The Meghalaya state of India is situated at the north, Companiganj & Sylhet sadar are at the east, Jagannathpur & Bishwanath at the south and Dowarabazar & Dakkin Sunamganj upazila are at the west to the project site.

20. The land of the project site is vacant and fallow land. The Bangladesh map, Sunamganj district map, Chattak Upazila map is shown in Figure 1.2, 1.3, and 1.4. The satellite map of the project is shown in Figure 1.5. The location map and the site photograp have been shown in Figure 1.6 and Figure 1.7.

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Figure 1.2: Bangladesh Map

Proposed

Elongi Model High School

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Fig 1.3 Sunamganj District Map

Proposed

Elongi Model High School

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Figure 1.4: Chattak Upazila Map

Proposed

Elongi Model High School

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Figure 1.5: Satellite Image of the Proposed Project

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Figure 1.6: Location Map of the Proposed Project

Figure 3.4: Satellite Image of the Proposed Project

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Figure 1.7: Photograph of the Project Site

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2.0 GENERAL CONSIDERATION

21. Baseline data on environment is important to understand existing physical, biological, cultural, economic and social environmental characteristics. This information serves as the basis for identification, prediction and evaluation of impacts of the project activities. Mainly there are two principal objectives in examining and defining the existing environment:

(i) To recognize potential environmental impacts of the project and enable mitigation measures to be identified. (ii) To provide a base line against which environmental conditions in the future project may be measured and to document conditions which were either existing or developing before the introduction of the project and not due to the project.

22. The baseline environmental quality is assessed through field studies within the impact zone for various components of the environment, viz. air, noise, water, and land and socio-economic. For IEE study, the emphasis is given on the environmental features that are of particular significance to the present project. Considerations are given to both the environment and ancillary area that seems to be affected

2.1 Physical Environment

23. Chhatak Upazila (Sunamganj district) with an area of 434.76 km2, is bordered by Dowarabazar Upazila to the north, Jagannathpur Upazila to the south, Companiganj, Sylhet Sadar Upazila, and Bishwanath Upazila to the east, Sunamganj Upazila to the west. The area of Chhatak town has 9 wards and 22 mahallas. The main river that runs through the town is the river Surma, which is well connected with the rest of the country, as it flows from the Indian border at Karimganj through Sylhet into Chhatak, then to Sunamganj and to the capital, Dhaka. Although the town is served with a highway and railway, connecting the town with the rest of the country, the river is still an important way of transportation of goods in addition to the road and rail. The river Surma is wider in Chhatak than in Sylhet, and can be used by cargo ships all year round unlike Sylhet which has its rivers drying up during the winter seasons due to silt travelling down the river from India. On a clear day, the Khasi Hills in the Meghalaya state of India are clearly visible to the north giving the town a very scenic background with even the waterfalls are visible during the rainy season. Chatak is also famous for the cement manufacturing and paper industries.

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Figure 2.1: 1 km Study Area of the Project

24. Some of the notable features of the surroundings are:

(i) The project is covered with sandy soil. The project will be built within the Elongi school compound on school’s own land, the land is partially developed, vacant and will require little land rising. There are few homesteads at the west side of the existing school building but the other sides are the cultivated lands. (ii) Like other parts of Bangladesh domestic animals and a few common birds are seen around the plant site; (iii) Here are no wild-life, natural forest and vegetation, endangered species present in and around the plant site

2.1.1 Land Form and Soil Classification

25. The study area is the Chatak upazilla and Sunamganj district .This region occupies the relatively higher parts of Surma-Kusiyara floodplain formed on sediments of the rivers draining into the Meghna catchments area from the hills. The area is mainly smooth broad ridges and basins. The soils are grey, heavy silt clay loams on the ridges and clays in the basins. Non calcareous Grey Floodplain soils are the only general type. Organic matter content of soils is moderate. The reaction of soils ranges from strongly acidic to neutral.

2.1.2 Hydrology

26. Sunamganj district lies on the “North-Eastern Depression” of Bangladesh; the depression is characterized by flat terrain with low land elevation. People of this district are pioneer in using shallow and deep tube wells for drinking and irrigation purpose. Most of the arable lands are usually irrigated by ground water to grow crops, mainly HYV rice and different types of vegetables grow during winter season in the area. According to BGS and DPHE (2001), private ownership of tube wells are the common features of the district, which penetrate through shallow alluvial aquifers to depth 10-60 m for drinking purpose. Irrigation boreholes typically tap deeper aquifers in the region at 70-100 m depth. In some areas of the district, deep tube wells pump out ground water from a depth of 150m or more. The deep tube wells have been installed to avoid high salinity at shallower levels. Shallow hand-dug wells are found in some areas, though they are much less common than tube well.

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2.1.3 Water Quality

2.1.3.1 Surface Water Quality

27. Sunamganj portion of Surma River, which is significant due to the presence of two major industries – a paper mill and a cement factory. The other significant feature is the conveyors that travel from India to Chattak. The river was found to be highly turbid in the monsoon season but moderately clean during off monsoon. The water quality data of the river was not readily available but apparently it is evident that the water is certainly unfit for drinking purposes without any form of treatment during monsoon.

2.1.3.2 Ground Water Quality

28. The sources of water supply to the area are through hand-dug wells, boreholes and surface water. These sources of water supply especially from the hand-dug wells and surface water are polluted due to human activities like pit latrines. Since the chatak area is not very densely populated and most of the areas are marshy, the ground water quality is still good in the area.

2.1.4 Air Quality

29. Air quality depends on substances, which are present in atmosphere. Air is called polluted when these substances are present in such concentrations that they produce undesirable effects on human beings, animal and as well, as plant life. These substances include gases (SOx, NOx, CO, etc.), Suspended Particulate Matter (smoke, dust, fumes, etc.), and many others. Concentration of different pollutants above allowable level can have adverse impacts on plant, animal and human life. Despite the two cement plants, one pulp and paper factory, and a number of smalls scale lime producers, the air quality in the area is relatively good. Chhatak Cement plant has an electrostatic precipitator and bag filters for dust control and the other cement plant is operating intermittently because of technical problems.

2.1.5 Ambient Noise Level

30. There is no noise level data available for the site. It is assumed that the existing noise level should be within the allowable limit since there is no industrial activity found within the vicinity of the project site.

2.1.6 Climatic Condition

31. The area has a subtropical climate with maximum temperature range from 25-31oC and minimum temperature range of 13-25oC. December to February are the cold months while April to August are the hot and humid. The morning humidity varies from 83 percent in March to 96-97 percent for most of the rest of the year.

2.1.6.1 Rainfall

32. The area is affected by the southwest monsoon, which normally starts in May and ends in September. June is the wettest month with an average precipitation of 1,370 mm, while November and December are the driest months, with an average precipitation of 6-7 mm. Almost 80 percent of the total rainfall (5900 mm) takes place during the monsoon season. Because of the funnel-shape formation of the land mass in the upper portion of the Bay of Bengal where Bangladesh is located, cyclones often have disastrous effects. The Project site is close to the Himalayan foothills, and it is not affected by the damaging storm surges created by the cyclones.

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2.1.6.2 Wind

33. The prevailing wind direction is southeasterly and easterly from January to March and northeasterly from April to December. The wind speed is 4 to 8 m/second.

2.2 BIOLOGICAL ENVIRONMENT

2.2.1 Terrestrial Flora and Fauna

34. There is hardly any forest at Sunamganj area. Household and road side plantation are the main greenery of the area. Flora consists of various type shrubs, herbs and other agricultural crops. In summer most of the cultivable areas are planted with vegetable or the land is left fallow.

2.2.2 Aquatic Flora and Fauna

35. Fish stocks have been depleted by over fishing. Common freshwater fishes in this region are cirrhinus reba, labeo bata, silonia, pangasium, and badis badis. Historically, tigers and jackals lived the forest of the Sylhet, but they are no longer present. Domesticated animals such as goats, cow, ducks, and chickens are the main fauna in the area.

2.3 SOCIOECONOMIC AND PHYSICAL CULTURAL RESOURCES

2.3.1 Socioeconomic Resources

36. According to Bangladesh Bureau of Statistics & Banglapedia the socio economic condition of Chatak Upazilla are given below.

(i) Population: Total 334546; male 171761, female 162785; Muslim 313971, Hindu 20238, Buddhist 74, Christian 17 and others 246.

(ii) Ownership of agricultural land: Landowner 46.87%, landless 53.13%; agricultural landowner: urban33.48% and rural 48.86%.

(iii) Main sources of income: Agriculture 52.15%, non-agricultural labourer 10.33%, industry 0.60%, commerce 10.19%, transport and communication 1.19%, service 7.16%, construction 0.89%, religious service 0.42%, rent and remittance 3.23% and others 13.84%.

(iv) Literacy rate and educational institutions: Average literacy 36.3%; male 40.0%, female 32.4%. Notable educational institutions: Chhatak Degree College (1972), Gobindaganj A Haque Smriti Degree College (1974), Jaua Bazar College (1995), Chhatak Technical School and College (1981), Chandranath Girls’ High School (1857), Chhatak Multilateral High School (1941), Gobindaganj High School (1957), Jalalia Alim Madrasa (1980).

(v) Main crops: Paddy, sesame, linseed, vegetables. Main fruits Orange, pineapple, litchi.

(vi) Fisheries, dairies and poultries: Fishery 30, dairy 37, poultry 130, nursery 7.

(vii) Communication facilities: Pucca road 173.92 km, mud road 305.90 km; railway 34 km; waterway 170 nautical miles.Extinct or nearly extinct traditional transport Palanquin.

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(viii) Industries: Chatak Cement Factory, Chatak Pulp and Paper Mill, Lafarge Surma Cement Company, and Pre States Concrete Slipper Co. are notable. Cottage industries like weaving, cane and bamboo work, crafts made of reed and chhan (a kind of tall grass).

(ix) Hats, bazars and fairs: Hats and bazars are 28, most noted of which are Chhatak Bazar, Gobindaganj Bazar, Jaua Bazar, Dular Bazar.

(x) Main exports: Orange, natural gas, cement, lime stone, paper and pulp.

(xi) Access to electricity: All the wards and unions of the upazila are under rural electrification net-work. However 18.82% of the dwelling households have access to electricity.

(xii) Natural resources: Lime, limestone, sand, gas, bamboo and cane.

(xiii) Water bodies: Main river: SURMA; Helu, Haluda, Kuri, Baruka and Satbila beels are notable.

(xiv) Sources of drinking water: Tube-well 56.88%, pond 23.95%, tap 3.98% and others 15.19%. The presence of arsenic has been detected in 23.5% of the shallow tube-well water in the Paurasabha area and 12.26% of the shallow tube well water in the union areas. Sanitation 36.05% (rural 32.40% and urban 60.65%) of dwelling households of the upazila use sanitary latrines and 48.71% (rural 51.02% and urban 33.13%) of dwelling households use non sanitary latrines; 15.24% of households do not have latrine facilities.

(xv) Health centres: Upazila health centre 1, union health and family planning centre 10, community clinic 12.

(xvi) NGO activities Operationally: Important NGOs are BRAC, CARE.

2.3.2 Physical Cultural Resources

37. Cultural and Archaeological heritage: Monipuri Rush Purnima Mela, Durbin Shah Mela, relics of Bagbari Tila.

3. POTENTIAL ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

3.0 Introduction

38. In case for most industrial/Infrastructure projects, potential negative impacts sometime could be far more numerous than beneficial impacts. The regional and national economic benefits associated with the implementation of any development project are considered to fall outside the scope of an IEE/EIA, and therefore not considered here. However, it is generally expected that these long-term benefits will ultimately trickle down to the local population and will make a contribution to an improvement in the quality of life.

39. Scoping of impacts. The potential impacts due to implementation of Project are identified by using simple checklists. This method is described below.

40. Checklist. Checklist is comprehensive lists of environmental effects and impacts indicator designed to stimulate the analysts to think broadly about possible consequences of contemplated actions (Munn, 1979). The table below represents the checklists developed for

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the present project. In this checklist, actions, which may affect at the various stages of the project activities, are listed and the degrees of Significant Environmental Impacts (SEIs) are shown. The terms none, minor, moderate, and major are used in the checklists to evaluate the magnitude of SEIs. In the checklist, the location, construction, and operational phases of the proposed development are considered separately in order to distinguish the short-term and long-term impacts.

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Table 3.1: Checklists of Construction of Multistoried School Building

Project Phase Action Affecting SEIs without Mitigation Type Comments Environmental Resources Measures & Values None Minor Medium Major Adverse Beneficial Project Land value depreciation x No land value changes anticipated Location Loss of and displacement x No loss of and displacement from homesteads from homestead land land; no impact Loss of and displacement x Loss of and displacement from Agricultural land from agricultural land will not occur; no impact Damage to nearby x No impact anticipated operation Disruption to drainage x x Land development may create problems in local pattern drainage pattern, minor impact Blockade of wildlife x No wildlife in the area, no impact passage Encroachment into x No precious ecological issues; no impact precious ecological Construction Blockade of natural x x Cutting/Filling and construction site preparation Stage drainage would create natural drainage blockade during rainy season, minor impact Worker accident x x Irregularly may occur in construction period, minor impact Safe drinking water and x x Concentration of labor force create un-hygienic Sanitation hazard condition, medium impact Noise/vibration hazard x x Piling, brick/stone crushing and equipment installations may create noise, minor impact Traffic congestion x x Carrying of construction materials will create traffic congestion Emission of Dust x x Cutting/filling, stockpiling of construction material and traffic movement may create dust emission, minor impact Surface water pollution x No water discharge from the site, no impact Solid waste management x x Improper management of construction debris and solid waste may pose risk to the neighbors, minor impact

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Project Phase Action Affecting SEIs without Mitigation Type Comments Environmental Resources Measures & Values None Minor Medium Major Adverse Beneficial Occupational health & x x Health & safety of workers at site may pose to safety of workers risk in some cases, minor impact Site security x x Improper site security may pose risk to the school children or community, minor impact Employment x x Major employment opportunity during construction, medium positive impact Operation/ Pollution from liquid x No liquid discharge from the project, domestic running Stage discharge sewage should be disposed through septic tank, no impact Pollution from solid waste x x Minor domestic solid waste may generate; minor impact Air quality x No air pollution; no impact Noise hazard x No noise generation is expected; no impact.

Traffic congestion x No traffic congestion: no impact Renewable energy option x x Solar panel may be installed at the roof of the building may save energy and CO2 emission Socioeconomic impact x x Development secondary education may develop the society and neighborhood. Employment x x Medium Employment opportunity during operation

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3.1 Beneficial Impacts and Enhancement Measures

41. Potential environmental impacts (both positive and negative) associated with all project phases were identified in section 3.0 by using checklist method. The Summary of beneficial impacts from the assessment is tabulated below:

Table 3.2: Summary Analysis of Beneficial Impacts Summary Analysis of Beneficial Impacts: Elongi Model High School

Project Activities Beneficial Impacts

Pre-Construction 1. Land value  Land value enhancement anticipated due to the development Construction 2. Employment  Major employment opportunity (positive impact)

3. Increasing local  Local business will be enhanced due to the construction activities business 4. Installation of  Safe drinking water supply tube well

Operation 5. Socio -economic  New construction of educational institutes will attain more access impact and retention of students.  Development of secondary education may develop the society and neighbourhood.

6. Landscaping  A net increase in green cover would provide increased habitat for birds and small mammals (Positive impact). 7. Renewable  Solar panel may be installed at the roof of the building to save 2 energy option energy and CO emission.

8. Rain water  Provision of “Rain water harvesting” systems in the building will meet harvesting the water demand.

42. Beneficial impacts likely to result from implementation of the proposed project impacts and enhancement measures are considered in section 3.1.

3.1.1 Impact at Pre –Construction Phase

3.1.1.1 Land Acquisition:

43. The proposed project site in the school premises doesn’t require any relocation of homestead since the project would be implemented at the school’s own vacant land. No

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precious ecological issue is involved with this project since the project site is barren land, has no natural habitat and is not immediately adjacent to watercourses.

3.1.2 Impact at Construction Phase

44. During construction period, short duration job opportunities for local people will be created. In addition to this, all construction sites attract small traders, who supply food and other consumable to the work force. Although the numbers of people who benefited in this way are relatively small, the impacts on individuals can be disproportionately high compare to the other local people. Tube wells will be installed during construction.

45. Benefit maximization measure. Although labor recruitment is a matter of construction contractor who has the right to determine whom he shall employ, but still the project proponent shall encourage to hire local people wherever possible and to give preference to employment of the land less people. Installation of tube wells will provide safe drinking water facilities to the workers as well as to the students.

3.1.3 Impact at Operation Phase

3.1.3.1 Socioeconomic impact:

46. The most significant positive impact of the project would be the development of secondary education in Chhatak upazila, which will eventually produce more skilled labor force and thus may develop the society and country on a broader scope. The other important positive impact of the project would be the employment of personnel for the operation of school. Employment may be both permanent and temporary.

47. Benefit maximization measure. School activities should be reported and monitored to ensure better quality of education.

3.1.3.2 Landscaping:

48. A landscape is a subjective concept that cannot be precisely quantified. However, in general, any project when not designed considering the local landscape, then it creates visual intrusion to the people. The proposed project has minimal amount of vegetation to be affected due to the construction. A significant net positive effect is possible with the design of the building and its surroundings to accommodate both the School building itself and a net increase in green cover on the site.

49. Benefit maximization measure. Plantation of trees around the school building i.e. grass and shrubs would provide increased habitat for birds and small mammals and enhance the visual aesthetics of the current land.

3.1.3.3 Renewable energy option:

50. Solar power is one of the best renewable energy options. It is the conversion of sunlight into electricity that may be used for supporting electricity demand of the building and for individual outdoor lights by adding some design and budget modifications.

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51. Benefit maximization measure. Solar photovoltaic (PV) panels are to be installed in the school premises or at roof. It is a low cost sustainable solution to meet the electricity demand.

3.1.3.4 Rain Water Harvesting:

52. Rainwater harvesting is a technique used for collecting, storing, and using rainwater for landscape irrigation and other domestic uses. Sunamganj faces heavy rainfall almost all over the year. Rainwater harvesting may contribute to the solution of water logging problem associated the heavy rainfall at Chatak.

53. Benefit maximization measure. Rainwater harvesting systems can be installed with minimal skills. Installation of storage tanks at roof top is the easiest way of rain water harvesting. The water storage tank size should be large enough to contain the captured water and the system should be sized to meet the water demand throughout the dry season specifically, the rainfall capturing area such as a building roof must be large enough to maintain adequate flow.

3.2 Adverse Impacts and Mitigation Measures

54. The minor, temporary adverse environmental impacts that have been identified are itemized below, according to each project phase. Most of these relate to the building construction process, and can be relatively easily mitigated with standard best practices that are increasingly being required of the construction industry.

Table 3.3: Summary Analysis of Adverse Impacts Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

Pre-Construction 1. Land acquisition  Loss of access to the site (students playing in the area); inconvenience.

2. Site preparation,  Clearing of vegetation (minor impact). clearing and  Reduction in visual aesthetics of the current land (access road, truck traffic, earthworks construction equipment and eventually a building on site).  Land development may create problems in local drainage pattern (minor impact).  Emission of Dust (minor impact).  Improper management of construction debris and solid waste may pose risk to the students and others (minor impact).  Associated noise (minor impact). Construction

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Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

3. Influx of workers  Health & safety of workers at site may pose to risk in some cases (minor impact).  Concentration of labor force creates un-hygienic condition and risk of safe drinking water and sanitation hazard (medium adverse impact).

4. Construction  Piling, brick/stone crushing and equipment installations may create noise equipment / materials (minor impact)  Carrying of construction materials may create traffic congestion (minor impact).  Cutting/filling, stockpiling of construction material and traffic movement may create dust emission (minor impact)  Improper site security, poor management of construction debris and solid waste may pose risk to the workers, current students and others (minor impact).

5. Vehicle and  Slightly more congestion near the main entrance to the School (minor pedestrian traffic impact).  Increased number of vehicles on local roads will result in increased wear and tear of local roads thus reducing lifespan of affected roads (minor impact).  Pedestrians and cyclists using local roads will have to exercise more care with increase of vehicular traffic on the said roads (minor impact).  There will be an increase of exhaust emission from vehicles, which will pollute local atmospheric air (minor impact). 6. Employment of  The Environmental and Social Safeguard Policies of the DOE/ADB child labour in the prohibits all kinds of child labour (lower than 14 years) and personnel construction activities engagement in construction works of the projects.

Operation 7. School  Improper seating arrangement Environment  Insufficient interval time between classes  Poor condition of classrooms  Unsatisfactory Teacher Student ratio  Gender inequity  Absence of separate washrooms for boys and girls  Suffocation problem if improper ventilation  Safe drinking water supply to the students 8. Vehicle and  Slightly more congestion near the main entrance to the School (minor

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Summary Analysis of Adverse Impacts: Elongi Model High School

Project Activities Possible Impacts

pedestrian traffic impact). adjacent to School  Increased number of vehicles on local roads will result in increased wear building and tear of local roads thus reducing lifespan of affected roads; (minor impact).  Pedestrians and cyclists using local roads will have to exercise more care with increase of vehicular traffic on the said roads; (minor impact).  There will be an increase of exhaust emission from vehicles, which will pollute local atmospheric air (minor impact).

9. Generation of  Risk of poor solid waste management. consumables  Risk of sanitation hazard.

10. Increased  Increased risk of water shortages and electricity load shedding. demand on local services

11. Extreme climate  Sunamganj is a flood and earthquake prone area. events, disasters and  Fire hazard or any medical emergency may arise during operation of the emergency school.

55. Adverse impacts likely to result from implementation of the proposed project and mitigation measures are considered here in section 3.2.

3.2.1 Impact at Pre –Construction Phase

3.2.1.1 Land Acquisition:

56. As discussed earlier the proposed school building will be built on pre-occupied land and the proposed site is not currently being used for any school or community purposes, or providing natural habitat, so there are no negative environmental effects associated with acquisition of the land for the Elongi Model High School new building construction. Hence, no mitigation measure is needed.

3.2.1.2 Site preparation, clearing and earthworks:

57. The pre-construction phase involves site preparation, clearing of existing vegetation and some earthworks for levelling the surface. These activities may cause some negative impacts such as:

(i) Change in Landscape; (ii) Emission of Dust;

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(iii) Associated noise; and (iv) Improper management of construction debris and solid waste may pose risk to the neighbors.

A. Mitigation Measures

58. Change in landscape. The proposed project site has some grass and scrub vegetation that will be affected due to the land development. But with completion of the school building and planting of new vegetation and trees around the building, the school building site should recover the visual aesthetics and also a net gain in green cover is possible as discussed in 3.1.3.2.

59. Emission of dust and associated noise. Site preparation activities will generate dust and noise. Both these adverse effects will be short term and within tolerable limit at the pre- construction stage and can be mitigated. By sprinkling water on dry surface, spreading of dust can be controlled. Working activities should be limited to day time only.

60. Waste management. Construction debris and wastes should be properly collected and disposed to safe place.

3.2.2 Impact at Construction Phase

3.2.2.1 Disruption of Earth surface-Site preparation, Clearing and Earthworks

61. Construction activities and possible impacts are temporary impacts associated with the construction work. As soon as the construction phase is finished, the impacts will be neutralized but some standard manner of construction can mitigate the effects in the construction phase.

62. Mitigation measures. Cutting and filling operation should be kept minimum. The proponent should ensure construction of proper drainage facility. Regular water sprinkle should be used to minimize fugitive dust emission. Safe working procedures should be ensured by the contractor. Most appropriate time for undertaking construction work is dry season. The heavy equipment should be operated at day time.

3.2.2.2 Potential Environmental Impacts of Dust

63. The air quality in the project area may slightly deteriorate for the time being during construction mostly due to dust emission. Dust produced will potentially negatively affect the following:

(i) Employees generally construction workers; (ii) School students, teachers and general public; and (iii) Vegetation.

64. Though the emissions are temporary and not expected to contribute significantly to the ambient air quality and will be within prescribed limits for industrial regions by National Ambient Air Quality Standards, necessary measures are to be taken.

65. Mitigation measures. Regular sprinkling of water on open surface and dust emitting grounds should be done regularly until paving is done during dry season and keeping all soil, sand, and aggregate piles covered (whether on the site, or on trucks) to minimize the air

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pollution during the construction stage. If there is any complain of dust emission from students, teachers and neighbors, should be given proper attention.

3.2.2.3 Potential Environmental Impacts of Noise

66. Construction works may cause objectionable noise nuisance to workers, students or teachers.

67. Mitigation measures. For managing noise nuisance, construction works should be limited to daytime hours and all employees likely to be exposed to ear noise must use ear protectors. School authority and students must be notified in writing on the date of commencement of construction work at least one month in advance. Where applicable and possible, exceptionally noisy machines should be fitted with noise reduction devices. However, the noise impacts will be local; limited to the premises and very short term.

3.2.2.4 Waste Management

68. Improper dumping of spoil materials and solid wastes may cause environmental degradation of the school area and students, teachers and neighbouring people will face problem like: Bad smell, aesthetically unpleasant environment, diseases etc.

69. Mitigation measures. Introduction of proper solid waste management system at site is necessary. Human generated wastes may be controlled by raising awareness among workers on solid waste management with waste minimization, recovery, and recycling. Specific dumping containers are to be kept at site. All waste materials should be disposed in proper places after completion of construction.

3.2.2.5 Sanitation Hazard & Drinking Water

70. The health of the project personnel, construction workers and laborers living at the site could be impacted if arrangement of sanitation and drinking water is not ensured adequately and properly. During construction stage, lots of local labors will work and hence they would generate considerable amount of human waste. These are the potential source for spread of diseases, as various insects will play dominating role in the spread of diseases. There are chances for the spread of water borne diseases also.

71. Mitigation measures. Proper sanitation system should be provided and at the same time, regular, proper and safe disposal of human waste should be ensured. Contractors and workers should obey appropriate means of waste removal and sanitation measures. Adequate number of toilets and bathrooms should be made for the workers, and proper disposal system (septic tank) of sewage waste should be implemented for sanitation purpose and the workers should be aware to practice those facilities.

72. The project activities shall make higher demand on the local utilities and service facilities particularly potable water, health and sanitary facilities. There should be sufficient number of tube-wells for drinking purpose.

3.2.2.5 Occupational health & safety of workers and students

73. Health and safety issues associated with construction activities will be an issue for workers, students, teachers and others. Under controlled situation, accident is not expected.

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However, occasionally accident may occur during earth cutting, casting, construction works and installation of heavy machinery. The protection of head, eye, ear, and hand, foot of the workers, laborers and project personnel could be affected if proper and adequate arrangement is not ensured.

74. Mitigation measures. The workers should wear PPE (Personal Protective Equipment), safety goggles, and other necessaries. The whole work site will have to be fenced off and marked, so as to prevent the access of school children and neighbours to the construction site.. When land clearing is complete, the work area is finished, and facilities are in place, all of the above impacts and risks will be neutralized.

3.2.2.6 Increase in Vehicular Traffic in the Area

75. Increase in vehicular traffic in the area is likely to be experience during construction phase of the school building because of trucks ferrying in off construction material and carrying waste material from site. Following are the impacts likely to occur due to increased traffic:

(i) Slightly more congestion near the main entrance to the school. (ii) Increased number of vehicles on local roads will result in increased wear and tear of local roads thus reducing lifespan of affected roads. (iii) Pedestrians and cyclists using local roads will have to exercise more care with increase of vehicular traffic on the said roads. (iv) There will be an increase of exhaust emission from vehicles, which will pollute local atmospheric air.

76. Mitigation measures. The Elongi Model High school is located in a remote rural area and there is only a narrow earthen road passing near the school which is not busy with motor traffic any way. So, the contractor should have to carry the construction material through river way or use rickshaw van or human puller to carry the construction material to the site. So, the traffic related congestion and air pollution would not be an issue in this case.

3.2.2.7 Extreme climate events and disasters

77. Design and construction of School building building in Chhatak, Sunamganj should consider ‘climate proofing design’ since it is a flood and earthquake prone area.

78. Mitigation measures. Raising plinth level for flood and earthquake resistant design should be incorporated in design consideration of the building. Alternative solutions and final designs should be subject to expert and community consultation.

3.2.3 Impact during Operation Phase

79. There are few adverse environmental impacts expected with operation of the School building.

3.2.3.1 Impact on School Environment

80. School environment during operation of the school building is important to ensure a student friendly environment and better quality of education. If the environment fails to provide students a comfortable study zone, retention of students and better quality education is not possible. Improper seating arrangement, poor condition of classrooms, unsatisfactory teacher-

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student ratio, absence of separate washrooms for boys and girls, suffocation problem etc. are possible adverse impacts that will eventually lead to a poor school environment.

81. Mitigation measures. The building would be designed to ensure the comfortable seating arrangements of students, proper ventilation, sufficient male female toilets & washrooms and balanced teacher-student ratio will be maintained to ensure better school environment and thus students will be able to concentrate on study more.

3.2.3.2 Increased demand of electricity and water

82. The building will require services (notably water and electricity), which could cause additional demand during periods of low water availability and grid load-shedding.

83. Mitigation measures. The proposed building design features that address water and energy conservation (described above in 3.1.3.3 & 3.1.3.4) would help considerably in this regard.

3.2.3.3 Impact Due to Solid Waste

84. Operation of the school building will result in production of solid waste, which will require careful storage, separation and handling. It is important that sewage from the School building should not be an issue to the community.

85. Mitigation measures. Properly marked waste containers should be available at each floor and outside the building. All solid waste will be segregated properly. Some solid Waste may have secondary use and these will be sold to the secondary dealers. Other solid wastes will be disposed to the safe places carefully. Regular cleaning of wastes is essential. Every day, Sweeping and washing should be done to provide students a waste free healthy environment.

3.2.3.4 Impact due to Liquid Discharge

86. The school building will not create any process liquid. The liquid discharge will be mainly water used for domestic and toilet uses.

87. Mitigation measures. The domestic liquid waste will be disposed through a septic tank. The project will have planned drainage system to discharge the surface runoff.

3.2.3.5 Emergency response

88. The initial response to an incident is a critical step in the overall emergency response. Like all other important school buildings, Elongi Model High School must have adequate measures against accidents or incidents to meet the emergency.

89. Mitigation measures. The stairs of the building will be well designed and adequate for easy passage of the occupants. Fire safety management training and mock drill should be practiced periodically and emergency equipment and facilities like fire extinguisher/water hose, first aid etc. must be available to manage fire hazard or any medical emergency.

4. ANALYSIS OF ALTERNATIVES

4.0 The ‘No Build’ Scenario

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90. From a purely physical environmental point of view, the 'do-nothing’ is preferable to any project implementation, since it would avoid creation of any of the adverse impact associated with the project. However, It is concluded that the 'No Build’ alternative is unacceptable, and the potential socio-economic benefits of implementation of such project far outweigh the adverse impacts, all of which can be controlled and minimize to an allowable level.

4.1 Consideration of Alternatives

A. Provision of More Classrooms:

91. The ‘No Build’ alternative in the present case would mean there would be shortage of classrooms and other facilities in Elongi Model High School. So, the 'No build' alternative is unacceptable.

B. Secondary Education Sector Development:

92. New building construction for Elongi Model High School will ensure more access to students and retention of students. Thus it will help in development of secondary education sector in Chhatak and will contribute in building of a more efficient nation.

C. Employment Opportunity:

93. The project will create some employment opportunity during construction. There are possibilities to employ local people and thus may contribute to the development of financial status of those people, though this will be a short duration benefit.

4.2 Site Alternatives

94. The project has been designed to provide extra space to Elongi Model High School at its own vacant space adjacent to existing school building. So, there is no logic to find alternative site for the project since it is in the existing school premises.

5. INSTITUTIONAL ARRANGEMENTS

5.0 Introduction

95. As discussed earlier, construction of the “Elongi Model High School” is a infrastructure development project of SESIP, an education development project by Ministry of Education (MOE), Bangladesh. The project is jointly being financed by GOB and ADB (Asian Development Bank). The institutional arrangement for the construction and operation the project will be discussed in this chapter.

5.1 Institutions Associated with the Project

96. Ministry of Education is the Government Institution for decision making of all education policies and development projects. The Directorate of Secondary and Higher Education (DSHE) is responsible for administration, management and control of particularly general secondary and higher education including madrasah and other special types of education related projects. The DSHE has been allocated public funds from the Government of Bangladesh (GOB) under a loan from Asian Development Bank (ADB) towards the Secondary Education Sector Development

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Program (SESIP). DSHE has given the responsibility of planning, designing, implementing and supervising the construction of Elongi Model High School to Education Engineering Department (EED) and SESIP will also monitor the progress of the project time to time. EED is expected to maintain the direct responsibility for environmental management plans associated with all the SESIP civil works. However, EED will engage contractor for the construction of Elongi Model High School through bidding. Building contractors will be responsible to take all the necessary measures during construction period.

5.2 Institutional Capacity of Executing and Implementing Agency

97. Education Engineering Department (EED) is the implementing agency of DSHE. The agency is mainly responsible for planning, designing, and construction of civil works. The Assistant or Sub-Assistant Engineer of the EED will be generally assigned environmental tasks in addition to his technical responsibilities. In most cases, basic knowledge on environmental safeguard is inadequate among the engineers in the EED. There is no institutional setup, position, or assigned personnel looking after environmental safeguards issue. An environment unit shall be established at the central office of the planning cell of the EED under the Ministry of Education. An environment focal person from DSHE will be appointed in the environmental unit of EED who will cover environmental safeguard issues, including mainstreaming of environmental best practices, coordinating environmental management activities in school programs, and facilitating capacity building activities of central and local level stakeholders. He will also be responsible for planning, assessment, implementation, monitoring and reporting of EMP.

98. It is recommended that the Environmental team have a useful conversation with the local communities regarding activities that have potential environmental impacts. Environmental management is likely to be most successful if such decisions are taken in consultation with the local community.

99. During the operation period of the project, the school committee should establish own monitoring team headed by the head master.

5.3 Key Responsibilities of Executing and Implementing Agency, EED

100. The Program Director or his assigned official at the EED will be responsible for overall environmental compliance.

101. The Assistant Engineer of EED will be responsible for project specific environmental compliance and relevant reporting in EED assessment in order to prevent adverse environmental impacts and other climate and disaster-related risks.

102. EED and DSHE will be responsible for preparing site specific IEE & EMP for each project, obtaining and ensuring clearance required from government or local government agencies/committees, if necessary.

103. Children friendly, (with proper light and ventilation) aesthetically pleasing and environmentally sound school shall be promoted by EED.

104. Provision for adequate sanitation facilities shall be provided for the teachers and students with regular cleaning and routine maintenance. The toilets for girls and boys shall be separate with privacy and water facility.

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105. The design should harmonize with local surroundings, including landscaping and planning for other uses for all additionally created spaces, proper ventilation, and lighting in order to minimize negative impacts on environmental quality and property values.

106. Alternative solutions and final designs should be subject to public and community consultation with special emphasis on students/teachers. The preference of students and teachers will be given priority in designing the infrastructure.

107. All areas and infrastructure affected during construction should be restored to their original condition, specially sidewalks, green street dividers, green-belt/fence, gardens, sidewalk trees, utilities, and side streets impacted by traffic diversion.

108. Annual water quality monitoring of all the installed tube-wells under the project and existing one will be carried out to ensure safe drinking water facilities to the students and teachers. Rain water harvesting could be promoted by EED.

5.4 Key Responsibilities of the Contractor

109. The EED, through its Sector Program Support Unit, is responsible to implement the overall EMP. However, during the construction stage, the construction contractor is responsible for the safe environment of the project area during the construction. In this context, the EMP should be included into the bidding documents of all the construction packages so that it serves as a condition of contract for adopting the Environmental Code of Practices by the prospective contractor(s). The implementation of the EMP and/or Environmental Code of Practices by the contractor(s) is to be supervised by the construction supervision engineer, in close consultation with the project implementation unit (PIU) of EED. The responsibilities of the contractor will be as follows:

(i) Provision of adequate healthcare facilities (first aid) within construction sites; (ii) Training of all construction workers in basic safety; sanitation and healthcare issues; specific hazards of their work; personal protection equipment for workers, such as safety boots, helmets, gloves, protective clothing, goggles and ear protection; (iii) Safe drinking water for all workers; (iv) Safe access across the construction areas; (v) Arrangement for water spray at the construction area throughout the construction time; (vi) Ensure that no child labor will be deployed; (vii) Ensure proper site security and prohibit the construction area from access of general public; (viii) Keep work areas clean and tidy; and (ix) Ensure that there is adequate provision of correctly marked waste containers made available at convenient locations for the disposal of wastes.

5.5 Capacity Building and Training

110. For proper implementation the EMP, qualified manpower is absolutely essential. There should be a core group of people in the project who will be well trained on environmental issues but all staffs involve with the project should be given basic training on environmental issues. The

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skills of staff should be upgraded periodically through need based training program. Students and teachers should be given training periodically to ensure a better environment in school.

6. ENVIRONMENTAL MONITORING AND MANAGEMENT PLAN

6.0 Introduction

111. In the context of a project, Environmental Monitoring and Management Plan is concerned with the implementation of the measures necessary to minimize and offset the adverse impacts and to enhance beneficial impacts. Unless the mitigation and benefit enhancement measures are identified in IEE and fully implemented, the prime function of the IEE cannot be achieved. Thus, the objectives of environmental monitoring and management plan for the present project are:

(i) Identification of monitoring requirements and monitoring indicators; (ii) Mitigation measures to reduce or eliminate negative impacts; and (iii) Enhancement measures to maximize positive impacts.

112. Monitoring performance of a project is very important and sometimes vital. For surveillance of the environmental performance of a project and monitoring of the quality of the local environment, environment in the work-zone and the general impact zone have to be performed appropriately. For a three storied school building, monitoring is mainly important during the construction phase. The EED (Education Engineering Department), is responsible to implement the overall environmental monitoring and management plan. However, during the construction stage, the contractors are responsible to mitigate all environmental impacts related with the construction activities.

113. The cost of the Environmental Management Plan (EMP) has to be divided into several parts to reflect the different phases of the project and the requirements of each phase. The cost of EMP must include the costs of the capacity building, public consultation and the quality control requirements and the budget allocation should be made in the yearly operational budget of the plant.

6.1 Environmental Management Plan

114. All beneficial and adverse impacts which may likely to occur at different phases of the project have been discussed with appropriate measures in section 4. In view of the earlier discussion an Environmental Management and Monitoring Plan has been prepared.

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Table 6.1: Environment Management and Monitoring Matrix

Activity Environmental Impact Mitigation/Benefit Enhancement Measures Responsibility Monitoring Agency During Construction Phase Impact on Air Quality o Regular Watering should be done. o All soil, sand, and aggregate piles should be covered (whether on the site or on trucks). o The sand and other such dispersible material must be removed after completion of work. Noise/vibration hazard o Construction works should be limited to daytime hours. o All employees likely to be exposed to high noise must use ear protectors. o School authority and students must be notified in Construction work/ writing on the date of commencement of Contractor PD/EED use of equipment / construction work at least one month in advance. materials o Provide sufficient buffer strip around the project site. o Proper Acoustically designed machinery should be used. o Avoid noisy operation during school time. Waste management o Awareness must be raised among workers on solid waste management. o Specific dumping containers are to be kept in the site. o All waste materials should be disposed in proper places after completion of construction.

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Impact on health and o The workers should wear PPE (Personal Protective safety Equipment), safety goggles, and other necessaries. o Set up warning signs, signals and provide helmets for workers in accordance with relevant accident prevention and work safety procedure o Restrict access to the construction site.

Sanitation hazard and o Supply good quality drinking water to the workers by Influx of workers Contractor PD/EED impact on drinking water installing tube well. o Provide well-planed sanitary facilities o Provide regular health inspection among workers o Promote health education campaign among workers

Impact on employment & o Employ local people wherever possible. family finance o Ensure child labor is not employed.

Increased vehicle and Traffic congestion, impact o Avoid carrying of materials in peak hour of road Contractor PD/EED pedestrian traffic on safety traffic. o Provide adequate parking for vehicles. o Raise awareness among all users to follow traffic rules.

Climate extremities Impact on design o Raise the plinth level of building to prevent from Contractor PD/EED due to geographic consideration flood. location o Use appropriate materials in design.

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During Operation Phase Continuing school Impact on school activities Environment o Seating arrangement of students should be  Seating comfortable. arrangement o Interval time between classes should be within the  Interval time tolerable time limit in the classes of the schools.  Classrooms o Environment-friendly classrooms should be ensured. Headmaster/ school  Teacher-student o Balanced teacher and student ratio should be DSHE management ratio ensured.  Gender equity o Gender equity should be followed during the  Suffocation admission. problem due to o Provision of adequate ventilation in the classrooms improper is needed. ventilation Increased demand of Impact on water and o Install solar PV panels for electricity generation. electricity and water electricity supply o Introduce “Rain water Harvesting” system. o Energy efficient lights can be used. Headmaster/ school DSHE o Electric fan, light and other appliances should be management checked periodically and if problem is found, it should be fixed immediately. Impact due to Solid Waste o Collect all solid wastes properly, recycle where possible and dispose in proper place. Headmaster DSHE Generation of more consumables Impact due to liquid o Dispose all domestic waste water through septic discharge tank Headmaster DSHE

Increased vehicle and Additional need for parking, o Provide adequate parking for vehicles. pedestrian traffic impact on safety o Raise awareness among all users to follow traffic Headmaster DSHE rules.

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Need for proper Impact on sanitation and o Supply good quality drinking water to the students sanitation and drinking water and teachers. drinking water o Check the quality of drinking water. Headmaster DSHE o Provide well-planned sanitary facilities. o Separate washrooms for boys’ and girls’ should be available maintaining proper privacy. o Impact on secondary School activities should be reported and Headmaster/ school education continuously monitored. management Socioeconomic DSHE impact Impact on employment & o Employ local people wherever possible. family finance o Avoid child labor employment. Headmaster

Landscaping Enhancing visual o Plant trees around the project site. aesthetics and Headmaster DSHE environmental quality o First aid facilities should be available. Emergency Fire hazard or any medical o Firefighting equipment must be present. Headmaster DSHE Management emergency o Fire safety management training and mock drill should be practiced periodically.

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6.2 ENVIRONMENTAL MANAGEMENT DURING CONSTRUCTION PHASE

6.2.1 Overview of Impacts and Mitigation Measures

115. The following impacts are the most significant in the construction phase:

(i) Impacts on air quality; (ii) Noise and vibration impacts; (iii) Waste management; (iv) Occupational health and safety; and (v) Sanitation hazard.

6.2.2 Air Quality Management

116. Contractor must ensure regular sprinkling of water on dusty surface and covering of all dispersible materials to mitigate spreading of dust. Air quality will be monitored during construction.

6.2.3 Management of Solid Wastes

117. The project contractor need to ensure that properly marked solid waste containers are available at the project site and should motivate the workers to keep the site clean. Collected wastes will be disposed in proper place after the construction period daily.

6.2.4 Noise and Vibration Level Management

118. Adequate measures have been proposed for the control of noise and vibration in previous discussion. Noise level monitoring would be performed periodically and the workers exposed to noise should have adequate protective device.

6.2.5 Health and Safety Management

119. The project construction contractor is responsible for ensuring safe workplace for all; the workers, affected students, teachers and others. Access to workplace must be restricted to provide higher degree of safety and people working in the site must wear PPEs. In case of any medical emergency, adequate healthcare facilities must be available. Since the project area is frequently affected by flood and earthquake, the building design should consider these disaster issues.

6.2.6 Sanitation Management

120. Adequate toilet facilities and safe drinking water must be available at the construction site. The project contractor will ensure proper sanitation of the site. Tube well will be installed for safe drinking water purpose.

6.3 ENVIRONMENTAL MANAGEMENT DURING OPERATION PHASE

6.3.1 Overview of Impacts and Mitigation Measures

121. Operation phase of Elongi Model High School doesn’t have much significant adverse impacts on the surrounding environment. The beneficial impact of the project is mainly in

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socioeconomic point of view. Local staff of DSHE will monitor the impacts of the project in operation phase and Headmaster of the school will continuously monitor the school activities during operation of the building.

122. The impacts are mainly:

(i) School environment; (ii) Socioeconomic impact; (iii) Greening program; (iv) Solid waste management; (v) Waste water disposal; and (vi) Sanitation hazard.

6.3.2 Water & waste water Management

123. The proposed project would have water use for domestic purpose mainly. Water will also be needed for plants around the project building. All domestic sewage will be disposed through the septic tank. The quality of drinking water must be checked annually to check the acceptability of water free from Arsenic and other contamination.

6.3.3 Socioeconomic Impact Management

124. The main purpose of this development project is to provide more space to use for the school. This will ultimately strengthen the secondary education at Chhatak Upazila. Headmaster and a local staff from DSHE will monitor the performance of Elongi Model High School.

6.3.4 Greening Program

125. A green belt development program with different kinds of trees would be undertaken. The vegetation would purify the air, reduce noise level, maintain ecological balance and generally contribute to the scenic beauty of the air. Soil in and around the plant site is fertile and plenty of water is available. Hence, the green belt as an environmentally sound and friendly project with a buffer zone surrounding the plant area may be created in a short time and therefore green area will be increased and reduce the environmental impacts.

6.3.5 School Management

126. The environment of school must be child friendly and environmentally sound. Condition of classrooms and environment of school should not be such that, students face difficulty to concentrate on studies. Therefore, ensuring good environment in school and proper management of school activities is essential. School management and DSHE both will give effort to ensure better education environment in Elongi Model High School.

6.3.6 Disaster Management

127. The disaster management plan should consist of preventive measures including, formulation and strict implementation of safety codes and measures; periodic inspection of firefighting equipment and it’s planned maintenance; aware the students about electric shock; declaring the school office as “no smoking zone”; mock drills by the fire fighting cells/ groups, disaster management trainings among students and teachers etc.

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6.4 Monitoring Requirement

128. Environmental monitoring is an essential tool in relation to environmental management as it provides the basic information for rational management decisions. The prime objectives of monitoring are the following:

(i) To check on whether mitigation and benefit enhancement measures are actually being adopted and are providing effective in practice; (ii) To provide a means whereby impacts which were subject to uncertainty at the time of preparation of IEE, or which were unforeseen, can be identified, and steps to be taken to adopt appropriate control measures; and (iii) To provide information on the actual nature and extent of key impacts and the effectiveness of the mitigation measures which, through a feedback mechanism, can be taken into account in the planning and execution of similar projects in future.

129. There are two basic forms of monitoring: (i) visual observation or checking, coupled with inquiries, and (ii) physical measurement of selected parameters.

130. In the phase of construction, monitoring of some selected parameters like air, water, noise etc. is done by physical measurement. It should be mentioned here that the monitoring program should be such so that it can ensure compliance with national environmental standards. The importance of this monitoring program is also for ensuring that the plant does not create adverse environmental changes in the area and providing a database of operations and maintenance, which can be utilized if unwarranted complaints are made.

6.5 Monitoring Indicators

131. Environmental monitoring requires a set of indictors that could be conveniently measured, assessed and evaluated periodically to establish trends of impacts. The monitoring program, in view of the possible impacts as assessed earlier, should consider the indicators for the impact assessment related to following issues is presented in Table 6.2 in the following page.

132. It is desirable that the mitigation measures for the negative impacts and environmental enhancement for positive impacts are implemented according to the suggestions presented in this report. There are two types of environmental monitoring activities associated with the project, during construction and during operation of the project. Each of the components is to be dealt with according to the requirement of suggested measures.

A. Monitoring During Construction

133. The environmental monitoring during the construction phase should primarily be focused on addressing the possible negative impacts arising from:

(i) Generation and disposal of sewage, solid waste and construction waste; (ii) Increased traffic; (iii) Generation of dust (particulate matter); (iv) Generation of noise; and (v) Deterioration of water quality.

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134. The environmental monitoring should also focus on enhancing the possible beneficial impacts arising from employment of local workforce for construction works. Table 6.2 summarizes the potentially significant environmental parameters needed to be monitored during the construction phase.

Table 6.2: Monitoring Plan During Construction Phase of the Project Issue Parameters Location Monitoring Frequency Ambient air PM10, PM2.5, SPM, NOx, SO2 Around the project Once a Quarter Quality site Ground water pH, TDS, Ammonia, Nitrate, At the project site Once in a six months Phosphate, As, Fe, Mn and Coliforms Noise level Noise at different locations and to Around the project Once a quarter. nearest receptor site and nearest receptor Health Health status of the workers, At site Once a quarter visual observation and record check

B. Monitoring During Operation

135. Post construction monitoring is limited to a number of impact parameters to see the actual performance of the project. Most of the impacts can be monitored by visual observation or checking with inquiries. Rainwater harvesting and solar lighting system will be monitored by visual observation on annual basis by EED.

136. The school management and head teacher will be responsible for overall environmental monitoring during the operation phase of the school building.

137. Table 6.3 summarizes the potentially significant environmental parameters needed to be monitored during the operation phase.

Table 6.3: Monitoring Plan During Operational Phase of the Project Issue Parameters Location Monitoring Frequency Groundwater pH, Ammonia, Nitrate, Phosphate, Near Project Site Once a year As, Fe, Mn and Coliforms Solid waste Visual observation At the project Once a year Management Emergency Fire extinguisher and other health At the project site Once a year Devices & safety issues

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6.6 Cost of Monitoring

138. The following are the cost of monitoring for the environmental parameters during construction and during operation period of the proposed biogas plant respectively:

Table 6.4: Cost Estimate for Environmental Monitoring Measures During Construction Item Parameters unit cost Unit per Total cost per (Taka) year year (Taka) Ambient air PM10, PM2.5, SPM, NOx, SO2 25000.00 04 100,000.00 Quality Groundwater pH, Ammonia, Nitrate, Phosphate, As, Fe, 15000.00 02 30,000.00 Mn and Coliforms Noise level Noise at different locations 10000.00 04 40,000.00 Total Cost 1,70,000.00

Table 6.5: Cost Estimate for Environmental Monitoring During Operational Phase Item Parameter unit cost Unit per Total cost per (Taka) year year (Taka) Groundwater pH, Ammonia, Nitrate, Phosphate, As, 15,000.00 01 15,000.00 Fe, Mn and Coliforms Solid waste Visual observation At the project Once a 5000.00 Management site year Emergency Fire extinguisher and other health & At the project Once a 5000.00 Devices safety issues site year Total 25000.00

7. INFORMATION DISCLOSURE, PUBLIC CONSULTATION, AND PARTICIPATION

139. Public consultation is a means of involving all primary and secondary stakeholders in decision-making process in order to address their concerns, improve project design, and give the project legitimacy. Public consultation, if conducted in a participatory and objective manner, is a means of enhancing project sustainability.

140. Community input (both of knowledge and values) on socioeconomic and environmental issues can greatly enhance the quality of decision-making. Information disclosure, public consultation and participation was therefore conducted in the project area not only to satisfy the legal requirements of the IEE process of ADB but also to improve and enhance the social and environmental design of the project.

141. Given the very limited scope of this project (construction of a 3-storey school building on own land) and the expected almost negligible environmental impacts associated with building construction, public consultation and participation processes have been just preliminary to date. Initial information disclosure and consultation were undertaken during the field visit in February 2015.

142. In the consultation process, following key stakeholders were consulted:

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Ainun Nahar Panna UNO ,Chhatak Upazila Oliur Rahman Choudhary Upazila Chairman, Chhatak Md Belal Ahmed Chairman, Uttar Khurma Union Hazi Md. Moyna Mia Former President, School Management Committee. Md. Nurul Islam Head Master, Elongi Model High School Md. Ruhul Amin Asst. Head Teacher Abdur Rahim Asst. Teacher Math Md. Abdul Wahab Asst. Teacher Islamic Education Md. Anwarul Islam Asst. Teacher Sociology Abu Syed Asst. Teacher English Rezana Begum Office Assistant. Jahanara Khatun Asst. Teacher Bangla Md. Nazrul Islam Asst. Teacher Computer Nironjon Baiddo Asst. Teacher Agriculture Md. Abdus Sattar Local Community Hazi Md. Jamal Uddin Local Community Md. Arzok Ali Local Community Md. Monu Mia Local Community

Figure 7.1: Photograph of Consultation Meetings

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Table 7.1: Concerns Raised by the Communities during Stakeholder Consultations Issues Concern Raised by the Community Communities’ Remarks

Employment Provision of semi-skilled and unskilled jobs Maximum unskilled jobs should be for the local labor allocated to the locals

Compensation Several kinds of losses or damages may Project authority should ensure the happen due to the construction and proper guideline for compensation operational purpose purpose. Repair of local Existing road may be damaged by Project authority should repair the roads construction activity local roads in a regular basis Update the Local UNO should be updated about the project EED should update UNO about the Govt development and construction activities project status time to time time to time

143. It is recommended that this IEE and subsequent detailed building designs be taken back to the people who have been consulted initially, as they will ultimately have some role in management of the school building project. In any case, it is expected that there will not be much public interest in this specific building project, given its location and small scale. However, there will be expectations of increased employment opportunities due to the construction project; available jobs will therefore have to be advertised and delegated fairly.

8. GRIEVANCE REDRESS MECHANISM

144. Public participation, consultation and information disclosure has been undertaken as part of the IEE process. The school authority has already been consulted for the environmental concerns. As a result of this public participation during the initial stages of the project, major issues of grievance are not expected. However, unforeseen issues may occur. To settle such issues effectively, an effective and transparent channel for lodging complaints and grievances will be established. The grievance redress mechanism should be scaled to the risks and adverse impacts of the project. It should address affected people’s concerns and complaints promptly, using an understandable and transparent process. It should also be readily accessible to all sections of the community at no cost and without retribution.

145. The Grievance Mechanism will be implemented during both the construction and operational period of the project to ensure that all complaints from local communities are dealt appropriately, with corrective actions being implemented, and the complainant being informed of the outcome. It will be applied to all complaints from affected parties.

146. The mechanism will be accessible to diverse members of the community, including more vulnerable groups such as women and youth. Multiple means of using this mechanism, including face-to-face meetings, written complaints, telephone conversations should be available. Confidentiality and privacy for complainants should be honored where this is seen as necessary or important.

147. A grievance redress mechanism and procedures is setup to provide opportunity for project affected persons to settle their complaints and grievances amicably. The established grievances redress procedures and mechanism ensures that project affected persons are

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provided with the appropriate compensations and that all administrative measures are in line with the law. It also allows project affected persons not to lose time and resources from going through lengthy administrative and legal procedures. Grievances are first preferred to be settled amicably. The project shall set-up a grievance redress committee that will address any complaints during both the construction and operational period of the project.

Figure 8.1: Flowchart of Complaints/Grievance Redress Procedure

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148. The procedures to be followed and adopted by the grievance redress should be transparent and simple to understand or uniform process for registering complaints provide project affected persons with free access to the procedures. The response time between activating the procedure and reaching a resolution should be as short as possible. An effective monitoring system will inform project management about the frequency and nature of grievances. GRC (Grievance Redress Committee) will arrange regular meetings where the activities and the outcomes/measures taken according to the Complaints Database are to be monitored. In addition to the above, if there are any grievances related to environmental management issues in the project area, the GRC will record these grievances and suggestions and pass it on to the relevant consultant for necessary action and follow-up. In case a dispute is not resolved by arbitrational tribunal, then if any of the Party disagrees, the aggrieved party has the right to appeal to the ordinary courts of law. However, the preferred option of dispute settlement ought to be the option of settling the dispute amicably because recourse to courts may take a very long time even years before a final decision is made and therefore, should not be the preferred option for both parties concerned.

149. A grievance form is presented here and hard copies of both English and Bangla will be made available at the Elongi Model High School.

Figure 8.2: Grievance Form Sample Grievance Reporting Form Contact Details Name:

Address:

Telephone Number/ Cell Phone Number:

Email:

How would you prefer to be contacted (please tick box)

Details of your Grievance

(Please describe the problems, how it happened, when , where, and how many times, as relevant)

What is your suggested resolution for the grievance?

Signature: Date:

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9. CONCLUSION AND RECOMMENDATIONS

9.1 CONCLUSION

150. The present IEE report finds that though there are certain adverse environmental impacts associated with the implementation of Elongi Model High School, these are manageable provided recommendations in the EMP are followed with due diligence. The project is indispensable in view of the current secondary education scenario at Chhatak. The impact on the social environment is positive given the secondary education sector at Chhatak will be developed and more access opportunities will be created for local students from the project. The project will help in socioeconomic growth and improving quality of education at Chhatak.

151. One of the most critical issues for the project is safety. This has been adequately addressed through compliance with national building code (BNBC) in the construction to ensure safety during natural disasters like earthquake.

152. The project has been designed to comply with the country’s environmental laws and regulations, especially on air emissions, ambient air quality, wastewater effluent, and noise. The project management has taken steps to ensure that the project meets the ADB’s environmental standards.

153. Given the proponent’s commitments, actions undertaken for further measures to be adopted in due course of time as required, Elongi Model High School is going to be an important and environmentally sustainable school development project.

9.2 Recommendations

154. In order to manage the potential adverse environmental impacts, especially in the construction phase of the project, the recommendations provided in the EMP should be followed with due diligence. Some of important actions required are:

(i) Activation of Environmental Monitoring Committee, holding of its regular meeting and preparation of the monitoring report. (ii) Activation of Emergency Management and Safety Committee and holding of its regular meeting. (iii) Training of staff on EMP related issues. (iv) Activation of the Grievance Redress Committee and prompt response to public complaints. (v) Allocation of adequate resources in the yearly budget for implementation of EMP.

155. However, most important issue is the commitment for the implementation of the actions required under the EMP by the management.

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