South Asia Sub Regional Economic Cooperation Dhaka-Sylhet Corridor Road Investment Project

Initial Environmental Examination

Project Number: 53382-001 May 2021

Bangladesh: South Asia Sub regional Economic Cooperation Dhaka-Sylhet Corridor Road Investment Project

Improvement of the Existing Dhaka (Katchpur) - Sylhet National Highw ay (N2) into a 4-Lane Highway with Service Lane on Both Sides: Critical Habitat Assessment

Prepared by the Roads and Highways Division, Bangladesh, Dhaka for the Asian Development Bank.

Page i Terms as Definition AASHTO American Association of State Highway and Transportation Officials ADB Asian Development Bank AMAN Rice (grown in wet season) APHA American Public Health Association ARIPA Acquisition and Requisition of Immoveable Property Act As Arsenic BD Bangladesh BIWTA Bangladesh Inland Water Transport Authority BNBC Bangladesh National Building Code BOQ Bill of Quantities Boro Rice (grown in dry season) BRTA Bangladesh Road Transport Authority BWDB Bangladesh Water Development Board CITES Convention on Trade in Endangered Species CO Carbon Monoxide CoI Corridor of Impact CPRs Community Property Resources DMMP Dredged Material Management Plan DC Deputy Commissioner DO Dissolved Oxygen DoE Department of Environment DoF Department of Forest EA Executive Agency ECA Environmental Conservation Act ECR Environmental Conservation Rules EIA Environmental Impact Assessment EMP Environmental Management Plan EMoP Environmental Monitoring Plan Engineer The construction supervision consultant/engineer EPAS Environmental Parameter Air Sampler EPC Engineering Procurement and Construction EQS Environmental Quality Standards ESCAP Economic and Social Commission for Asia and the Pacific ESSU Environmental and Social Safeguards Unit FC Faecal Coliform FGD Focus Group Discussion FOB Foot Over Bridge GHG Greenhouse Gases GoB Government of Bangladesh GPS Global Positioning System GRC Grievance Redress Committee GRM Grievance Redress Mechanism GSIP Gender and Social Inclusion Plan ha Hectare HYV High Yielded Variety ICTPs International Conventions, Treaties and Protocols IEC Individual Environmental Consultant IoL Inventory of Losses IFC International Finance Corporation IRC Indian Roads Congress IUCN International Union for Conservation and Nature JVC Joint Venture Consultant

Page ii LGED Local Government Engineering Department LRFD Load Factor Resistance Design km Kilometre km/h kilometre per hour NM Noise Measurement NO Nitric Oxide NO2 Nitrogen Dioxide MG Metre Gauge MoEFCC Ministry of Environment, Forestry and Climate Change MoRTB Ministry of Road and Bridges O3 Ozone PCU Passenger Car Unit PDPs Project Displaced Persons PM 10 Particulate Matter (less than or equal to 10 microns) PM 2.5 Particulate Matter (less than or equal to 2.5 microns) PPE Personal Protective Equipment PPV Peak Particle Velocity PT Performance Target PWD Public Works Department RoW Right of Way SOx Sulfur Dioxide SPS Safeguards Policy Statement TC Total coliform TDS Total Dissolved Solid TOC Total Organic Carbon TSS Total Suspended Solid TPP Tree Planation Plan UN United Nation VG -40 Viscosity grade-40

Currency Equivalent Weight and Measures (as of 11 Jan 2021) I ha = 2.47 acre Currency Unit = Bangladesh Taka (BDT) 1 ha = 10,000sqm BDT 1.00 = $ 0.1182 1 Acre= 100 decimal $ 1.00 = BDT 84.6

This initial environmental examination 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 on ADB’s website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Page iii CONTENTS Page EXECUTIVE SUMMARY I I INTRODUCTION 1 A. Background of the Project and Rationale 1 B. Objectives of the Project and Outcome 1 C. Objective of the IEE 3 D. Extent of IEE Study 4 E. Approach and Methodology 5 II POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 8 A. GoB’s Legal Framework and Regulatory Requirements 8 B. Environmental Categorization of the Project by GoB 14 C. Environmental Clearance Procedures 14 D. International Treaties and Commitments 17 E. Specific Rules and Regulations Relevant to Road Projects 18 F. ADB’s Safeguard Policy and Categorization of the Project 22 III DESCRIPTION OF THE PROJECT 24 A. Location of the Project 24 B. Project Category 26 C. Characteristic of the existing Road 27 D. Traffic 31 E. Proposed Upgrading and Improvement of the Project Road 31 F. Construction Materials, Sourcing and Utilities Need 60 G. Social and Resettlement Considerations 63 H. Implementation Schedule of the Project 63 IV DESCRIPTION OF THE ENVIRONMENT 64 A. PHYSICAL ENVIRONMENT 64 A. Ecological Environment 94 B. Socio-economic Environment 111 V ANTICIPATED IMPACTS AND MITIGATION MEASURES 123 A. Methodology of Impacts Identifications 123 B. Screening of Anticipated Impacts 125 C. Assessment of Alternatives (Alignment Options) 133 D. Typical Potential Beneficial Impacts 137 E. Potential Adverse Impacts 137 F. Pre-construction Phase Impacts and Mitigations 137 G. Construction Period Impacts and Mitigations 153

Page iv H. Operational Phase Impacts and Mitigation 191 I. Emergency Response Plan: 206 VI GREEN HOUSE GAS EMISSION 208 A. Climate Change Mitigation 208 VII INFORMATION DISCLOSURE, CONSULTATIONS AND PARTICIPATION 220 A. Objective of the Public Consultation 220 B. Project Stakeholders 220 C. Consultations with Project Affected People/Beneficiaries 220 D. Consultations with Governmental Departments 222 E. Outcome of Consultations 226 F. Disclosure of Information 226 G. Virtual Consultation Meeting on Safeguard Issues 238 VIII GRIEVANCE REDRESS MECHANISM 239 A. ADB’s Requirement of Grievance Redress 239 B. Grievance Redress Mechanisms 239 IX ENVIRONMENTAL MANAGEMENT PLAN 242 A. Environmental Management Plan (EMP) 242 B. Environmental Monitoring Program (EMoP) 243 C. Environment Management Budget 244 D. Organisational Set-Up to Implement the EMP 246 X CONCLUSION AND RECOMMENDATION 251 BIBLIOGRAPHY 253

LIST OF TABLES

Table 1. Contract Package-wise Length and Civil Cost ...... 2 Table 2. Bangladesh Policies and Acts Relevant to Environment ...... 11 Table 3. Institutions involved to Permit NOC for Obtaining ECC from DOE ...... 17 Table 4: International Treaties, Conventions and Protocols Signed by GoB ...... 18 Table 5: Relevant to Labor Acts in Bangladesh ...... 22 Table 6. Environmental Regulatory Compliance of the Project ...... 23 Table 7: Existing RoW, Roads Intersections, Built up Areas, CD Structures ...... 28 Table 8: Projected Vehicles and PCU in Six Homogenous Sections ...... 31 Table 9: Adopted Design Criteria for the Project ...... 32 Table 10. Proposed Community Safety Drainage Structures ...... 37 Table 11: New and Reconstruction of Culverts and Bridges ...... 40 Table 12: Proposed Protection Works of the Project ...... 47 Table 13. Basic Road Design Features of the Project Road ...... 48

Page v Table 14. Quantity and Sourcing of Construction Materials ...... 62 Table 15: Name of Ambient Air Quality Testing Locations ...... 68 Table 16: Sensitive Receptors Located Alongside the Project Road ...... 74 Table 17. Flood prone Areas within the Project Alignment ...... 85 Table 18: Annual Maximum and Minimum Water Levels in the Project Area ...... 86 Table 19. Affected Waterbodies within the Proposed RoW...... 87 Table 20: Affected Waterbodies within RoW of the Proposed Realignments ...... 87 Table 21: Names of Surface water Sampling Locations and Sampling ID ...... 89 Table 22: Name of the Sampling Locations of Groundwater ...... 91 Table 23: Protected Areas Located within 10 Km buffer of Project Area ...... 97 Table 24. Affected Trees within the Proposed RoW of the Project ...... 102 Table 25: Presence of Migratory Birds at Rivers Banks of Major Bridge ...... 106 Table 26. Land Type Classes within the Project Districts ...... 111 Table 27: Length of Road under RHD by Road Classification, 2016 ...... 112 Table 28: Land use classification witin 10 km buffer...... 115 Table 29: Population, Sex, HHs Number, Average HH Size and Population Density ...... 118 Table 30: Tribal Population and Tribal Households in Project Areas ...... 119 Table 31: Affected Persons, HHs and Other Entities by the Project ...... 120 Table 32: Distribution of Affected Households/Units under 13 Packages ...... 121 Table 33: Criteria for rating the significance of impacts ...... 125 Table 34: Anticipated Impacts Screening for the Project ...... 126 Table 35. Assessment of Alternative Alignments ...... 134 Table 36. Affected Lands, HHs, Business and CPRs ...... 139 Table 37: Proposed Overpass, Flyover and Rail Overpass ...... 147 Table 38: Proposed FOBs for Community Safety at Sensitive Locations...... 149 Table 39: Homogenous Road Sections Considered in the Modelling Study ...... 157 Table 40: Calculation of Composite Emission Factor ...... 158 Table 41: Discrete Receptor Locations with Respect to the project road ...... 162 Table 42: Predicted GLCs at discreate Sensitive Receptors locations ...... 163 Table 43: Distance-wise Predicted GLCs from edge of project road ...... 165 Table 44. Vibration Source Levels at 25 ft for Construction Equipment...... 170 Table 45. Estimated PPV at various distance from equipment’s in mm/sec...... 171 Table 46. Estimated approximate RMS vibration velocity level (Lv) with distances...... 172 Table 47. Dolphin and Turtle Conservation Measures during Construction Work ...... 183 Table 48. Emission Factors of PM and NOx (2019 and 2038) ...... 193 Table 49. Overall Project Emissions Load of PM and NOx under different scenarios...... 194 Table 50: Vehicle types included in TNM 3.0...... 197

Page vi Table 51: Vehicle speed used in noise modeling...... 198 Table 52: Forecasted Traffic for TNM 3.0 classified Vehicles ...... 199 Table 53: Predicted Noise at Sensitive Receptors with and without Mitigations ...... 201 Table 54: Distance-wise predicted noise level from Road Edge...... 203 Table 55. Traffic Growth for Traffic Forecast Analysis...... 209 Table 56. Homogenous section for TEEMP Modelling...... 210 TTable 57: Maximum PCU based on s tandard Cross-sections...... 211 Table 58. PCU Equivalent in TEEMP Model ...... 211 Table 59. Emission Factors of CO2 for vehicle types (2019 and 2038 )...... 212 Table 60: Fuel type scenario considered in the TEEMP (2019 an d 2038)...... 212 Table 61. Emission Standards of Fleet (%)...... 214 Table 62: Input Parameters for TEEMP...... 216 Table 63. Estimated Total CO2 Emission from Road Construction ...... 216 Table 64. Overall CO2 Emissions of Project ...... 217

LIST OF FIGURES Figure 1. Project Road with Thirteen Contract Package ...... 3 Figure 2. Process for Obtaining an ECC for ‘Red’ Category Project ...... 16 Figure 3: Location Map of the Project Area...... 25 Figure 4: Typical Cross-Sections for Rural and Urban Areas ...... 35 Figure 5: Proposed Bridge Roadway Configuration ...... 43 Figure 6. Large Major Bridges (>100m span) ...... 46 Figure 7: Average Maximum and Minimum Monthly Temperature in Project Area ...... 64 Figure 8: Monthly and Annually Average Rainfall in Project Area...... 65 Figure 9: Average Humidity in Project Area ...... 66 Figure 10: Prevailing Wind Speed and Annual Wind Rose of the Project Area ...... 66 Figure 11. Sampling Locations Map of Ambient Air Quality Testing ...... 68

Figure 12. Ambient Air concentration of PM10, PM2.5, SO2 and NO2 in Project Area ...... 71

Figure 13: Ambient Air concentration of CO, O3, TVOC and NO in Project Area...... 72 Figure 14. Sampling Location Map of Noise Level Measurement ...... 73 Figure 15: Noise Level alongside the project road ...... 74 Figure 16: Location Map of Vibration Measurement ...... 77 Figure 17. Vibration Level alongside the Project Road ...... 78 Figure 18. Contour Map of Olipur Realignment under DS-7 ...... 80 Figure 19: Geological Map of the Project Area ...... 81 Figure 20. Soil Texture Map of the Project Area ...... 82 Figure 21: Major Rivers Map of the Project Area ...... 83

Page vii Figure 22: Flood Map of the Project Area ...... 85 Figure 23. Surface Water Sampling Locations Map ...... 89 Figure 24. Results of Surface Water from Six Rivers ...... 89 Figure 25. Sampling Location of Sediment Collection from Six Rivers Crossings ...... 90 Figure 26. Location Map of Groundwater Sampling ...... 92 Figure 27: Concentration of As, Fe and Cr in Groundwater Samples ...... 92 Figure 28: Seismic Zone of the Project Area ...... 93 Figure 29: Bio-ecological Zone Map (IUCN) of the Project Corridor ...... 95 Figure 30: Agro-ecological Zone Map of the Project Corridor ...... 96 Figure 31: Protected Areas Located within 10 Km Buffer of Project Area ...... 98 Figure 32. Wildlife within Project Area ...... 103 Figure 33: Raghunandan Hill Forest Area under DS-7 section ...... 104 Figure 34: Landuse Map from Starting Point Dhaka Katchpur to Bhairab ...... 114 Figure 35: Landuse Map from Bhairab to Shayestaganj ...... 114 Figure 36: Landuse Map from Shayestaganj to Sylhet ...... 115 Figure 37. Landuse Coverage within Proposed RoW of the Project ...... 117 Figure 38: Proposed Viaduct at Raghunandan Hill Section ...... 145 Figure 39: Proposed Box-Culverts at Forest of Raghunandan Hill Section ...... 146 Figure 40: Land Elevation of the Study Area ...... 160 Figure 41: Modelling Base Case Simulation at Sensitive Receptors ...... 161 Figure 42. Bio-Engineering Slope Protection Works...... 175 Figure 43: Time-series of CO2 Emission at Different Scenarios of Project Life...... 218

LIST OF ANNEXURES

Annex 1: Rapid Environmental Assessment ...... 254 Annex 2. Existing Environmental Standard in Bangladesh ECR, 1997 ...... 259 Annex 3: Base-Year and Traffic Forecast as Daily Vehicle-Km...... 265 Annex 4: Justification for Selecting Locations of Ambient Air, Noise and Vibration ...... 266 Annex 5: Ambient Air Quality Testing Results...... 269 Annex 6: Photographs of Air Quality Monitoring...... 270 Annex 7: Noise Monitoring at Different Landuse and Results ...... 272 Annex 8: Photographs of Noise Level Monitoring ...... 273 Annex 9: CPRs Alongside the Existing Road and Realignment Sections ...... 275 Annex 10. Vibration Monitoring locations and Results ...... 289 Annex 11. Photograph of Vibration Measurement ...... 290

Page viii Annex 12: Surface Water and Sediment Samplings locations with Justification ...... 292 Annex 13. Results of Surface Water Quality in Project Area ...... 294 Annex 14. Photograph of Surface Water Sampling ...... 295 Annex 15: Results of Sediment Samples Collected from Six Riverbed...... 298 Annex 16: Photograph of Riverbed Sediment Sampling ...... 299 Annex 17: Test Results of Groundwater Samples ...... 300 Annex 18: Photograph of Groundwater Sampling ...... 301 Annex 19: Affected Trees within Proposed RoW ...... 302 Annex 20. Species Names, Habit, Habitat Type, Local Status of Impacted Trees...... 304 Annex 21: Ground level concentration of Pollutants at various sections ...... 309 Annex 22: Sensitive Noise Receptors from Existing and Proposed Road edge ...... 313 Annex 23: Noise Contour Map of Six Homogenous Sections ...... 317 Annex 24: Attendance Sheets of the Public Consutations ...... 323 Annex 25. Virtual Meeting Minutes of Safeguard ...... 348

Page ix Improvement of the Existing Dhaka (Katchpur) - Sylhet National Highway (N2) into a 4-Lane Highway with Service Lane on Both Sides: Critical Habitat Assessment

Drafted for the Asian Development Bank

May 9, 2021

Table of Contents Summary ...... 2 1. Introduction ...... 3 1.1 Purpose of this report ...... 3 1.2 ADB SPS and IFC PS6 ...... 3 2 Methodology ...... 5 2.1 Project Area and Unit of Analysis ...... 5 2.1.1 Project Area ...... 5 2.1.2 Area of Analysis (AOA) ...... 5 2.2 Priority Biodiversity Features...... 7 2.3 Critical Habitat Threshold Value ...... 9 3 Critical Habitat Determination ...... 11 3.1 Criterion 1: Globally or Nationally Critically or Endangered Species ...... 11 3.1.1 Birds ...... 11 3.1.2 Reptiles ...... 15 3.1.3 Fishes ...... 17 3.1.4 Mammals ...... 18 3.2 Criterion 2: Restricted Range or Endemic Species ...... 20 3.3 Criterion 3: Migratory species and/or congregatory species ...... 21 3.4 Potential Impacts on CH ...... 21 4 Protected areas and internationally recognized areas ...... 23 4.1 PS6 criteria ...... 23 4.2 Qualifying features ...... 23 4.3 Implications of protected areas and KBA for the Project ...... 27 5 Natural Habitat and Modified Habitat ...... 28 6 Conclusion and Implications ...... 28 7 References ...... 29

List of Tables Table 1: Summary of PS6 scheme for classifying area ...... 4 Table 2: Priority species recorded during baseline biodiversity surveys and the IBAT’s preliminary priority species within 50km buffer that may trigger Critical Habitat according to Criteria 1-2 ..... 8 Table 3: Data Deficient and Not Evaluated species in the study area ...... 21 Table 4: Impact of Proposed Project on CH and Biodiversity Action Plan (BAP) Requirement . 22 Table 5: Status and description of Protected Areas ...... 23 Table 7: Description and status of Key Biodiversity Areas ...... 26

Summary This report is the Critical Habitat Assessment for the proposed project - to develop a four-lane highway of the existing double lane 226km Dhaka - Sylhet road, Bangladesh, hereafter referred to as “the Project”. Based on the available information, all critical habitats and the protected areas are beyond the 10 km project road buffer zone. The proposed project is entirely within the agriculture and settlement areas. There are six major rivers and 11 minor ones where bridges will be constructed. Except for the upper reaches of the Meghna river, others are degraded can be classified as modified habitat. Since the existing bridge over the Meghna river already 4-lane no new construction would be required. Hence, no impact is envisaged on the endangered Gangetic river dolphin that is known to inhabit the Meghna river. However, the project still considers potential impacts (section 6) and mitigation measures (Section 7). This report aims to identify Natural Habitat and Critical Habitat-qualifying biodiversity associated with the project; outline the implications of the outcome of Critical Habitat Assessment (CHA) for the Project, and identify the recommended next steps for the Project. The Critical Habitat Assessment revealed one species that triggered Critical Habitat under Category 1 of IFC GN6, the avian species Gyps bengalensis (Table 4). None of the species triggered Critical Habitat in the other categories.. The extent of Critical Habitat within the Project area needs to be quantified, especially any residual loss relating to impacts from proposed road construction activities. The ADB SPS and IFC PS6 recommends a No Net Loss (NNL) for the Project and a Net Positive Impact (NPI) in Critical Habitat. NNL is achieved when biodiversity gains from the combination of avoidance, mitigation, rehabilitation and targeted conservation actions match biodiversity losses related to the Project impacts. The term NPI refers to the point where biodiversity gains exceed biodiversity losses from the Project impacts. Therefore, proper mitigation measures, and habitat restoration beyond the area of impact (AoI), should be implemented to ensure an NPI in Critical Habitat. This would also entail to closely monitor populations of CH triggering species in order to assess the effectiveness of proposed mitigation and restoration measures.

2 1. Introduction 1.1 Purpose of this report This report is the Critical Habitat Assessment for the proposed project - to develop a four-lane highway of the existing double lane 226km Dhaka - Sylhet road, Bangladesh, hereafter referred to as “the Project”. The project will involve widening, construction of 66 major/minor bridges, and 305 nos. of culverts. It also includes the construction of 1 flyover bridge, 6 overpasses, 5 rail over bridges (ROBs), 26 foot-over-bridges (FOBs) etc. The entire project length is divided into 13 segments of stretches as Contract Packages DS1 – DS12 (A+B) taking into consideration of the project road length, location, nature of work, size of contracts, construction cost and period based on ADB’s Guidelines. The Project is aligned with ADB SPS requirements and the International Finance Corporation (IFC) Performance Standards as best practice for the Project, including Performance Standard 6 (PS6) on Biodiversity Conservation and Sustainable Management of Living Natural Resources (IFC 2019). The ADB SPS requires projects in Natural Habitat to design mitigation measures to achieve at least no net loss of biodiversity. It requires projects in Critical Habitat to demonstrate ‘no measurable adverse impacts, or likelihood of such, on the critical habitat which could impair its high biodiversity value or the ability to function’, no ‘reduction in the population of any recognized endangered or critically endangered species or a loss in an area of the habitat concerned such that the persistence of a viable and representative host ecosystem be compromised’, and mitigation of any lesser impacts. This report aims to: 1. Identify Critical Habitat-qualifying biodiversity associated with the project; 2. Outline the implications of the outcome of CHA for the Project; and 3. Identify the recommended next steps for the Project. 1.2 ADB SPS and IFC PS6 The ADB Safeguard Policy Statement (ADB SPS 2009) requires the assessment of whether the project is planned in an area that may qualify as Critical Habitat or Natural Habitat. This assessment followed more detailed guidance in the International Finance Corporation Performance Standard (PS) 6 and its accompanying guidance note (IFC 2019). The PS6 aims to: protect and conserve biodiversity; maintain the benefits from ecosystem services; and promote the sustainable management of living natural resources through the adoption of practices that integrate conservation needs and development priorities. PS6 identifies three classes of area based on (i) vegetation condition (‘quality’ or ‘state’) and (ii) significance for biodiversity (Table 1). PS6 uses the term ‘habitat’ to refer to these areas, rather than the actual vegetation within them. These classes are: • Modified Habitat; • Natural Habitat; and • Critical Habitat. Critical Habitat is a subset of Modified and Natural Habitat.

3 Area condition is classified as either Natural or Modified based on the extent of human modification of the ecosystem. The threshold for classifying a habitat as Modified rather than Natural is high: only the most heavily disturbed habitats would be classified as Modified. Monoculture forestry plantations, arable fields and urban areas show “substantial modification” and would be classed as Modified; selectively logged tropical forest usually retains most original species and ecological processes and so would in most cases still be considered Natural Habitat. Areas of high biodiversity value are termed Critical Habitat by the IFC PS6 requires an assessment of the presence of Critical Habitat, considering the principles of threat (vulnerability) and geographic rarity (irreplaceability). Critical Habitat Assessment (CHA), therefore, is a process for identifying significant biodiversity risks associated with the Project. Identification of Critical Habitat is independent of the state of the habitat: Critical Habitat qualifying biodiversity may be present even in heavily degraded Modified Habitat, such as rare Gangetic dolphin in the human-disturbed aquatic environment in Meghna river in Bangladesh.

Table 1: Summary of PS6 scheme for classifying area

2 Methodology 2.1 Project Area and Unit of Analysis 2.1.1 Project Area A detailed description of the habitats that the road passes through is described in section 5 of the IEE report, and the details of flora and fauna found in the project area in annexes of the IEE report. This report along with other expert documents was used to prepare this CHA. IUCN has classified Bangladesh into 25 Bio-ecological Zones in the context of physiographic and biological diversity. The project area falls under the bio-ecological zone of Brahmaputra –Jamuna floodplain (4c), Surma-Kushiyara floodplain (4d), Meghna floodplain (4e) and Haor basin (5a). The ecological resources of the project area comprise different environmental aspects, such as flora and fauna, environmentally sensitive areas/ protected areas, rare and endangered species, biodiversity hotspots and special habitats. The Bio-ecological zones defined by IUCN (2000) for Bangladesh are the protected landscapes considering their ecological importance. The eco- resources of the country have been depleted due to demographic pressure, natural calamities, deteriorated law and order, poor management, and land use conflicts. Hence, the GoB considered several of the sites as environmentally sensitive and declared these as protected areas through gazette notifications. Amongst the notified 29 ecologically sensitive landscapes, estuarine land, wetland, mangrove forest and virgin hill forests are also included. No protected area or internationally recognised areas intersect with the Project area (Area of Influence/AOI or direct impact zone of 300m radius). The nearest protected areas, Rema-Kalenga Wildlife Sanctuary is 7km away from the AOI, Khadimnagar National Park (9km), Tilagor Eco Park (5.7km) and Hail Haor Important Bird Area (9.4km). The project will not have any impact on these protected areas. The observation of recent satellite imageries shows that the project area falls within a highly modified habitat composed mostly of an agricultural landscape, followed by urban areas, semi-urban, and rural settlements. The main hydrological features present in the Project area are the Arial Khan, Old Brahmaputra, Meghna, Titas, Khowai, Kushiyara, and Surma Rivers. Meghna is the main river habitat in the project area known to harbour the Gangetic River Dolphin (IUCN, EN). However, no new bridge will be constructed over the Meghna river as the existing one is already a 4-lane bridge. There are no reports of sighting of dolphins in the other rivers of the project area as the volume of the rivers are critically low particularly during the dry season. Moreover, there are no IUCN red-listed aquatic species in these rivers. Nonetheless, precautionary measures are proposed to mitigate the impacts in the event the endangered such as Gangetic dolphin are observed in the project areas. 2.1.2 Area of Analysis (AoA) The scale at which the Critical Habitat Assessment is conducted depends on underlying ecological processes for the habitat in question and is not limited to the footprint of the project. Paragraph 65 of IFC’s Guidance Note 6 requires that an ecologically appropriate area of analysis is delineated during assessment to determine the presence of critical habitat for each species with regular occurrence in the project’s area of influence, or ecosystem, covered by Criteria 1-4.

Figure 1 Bio-ecological Zone Map (IUCN) of the Project Corridor

Project Area

2.1.2.1 Aquatic AoA For aquatic species, freshwater habitat is the most important parameter to consider in the selection of an ecologically contiguous area. The Arial Khan, Old Brahmaputra, Meghna, Titas, Khowai, Kushiyara and Surma Rivers are the primary rivers along the Dhaka-Sylhet double laning project. Meghna river is an important river within the project area where all other rivers are its tributaries. It joins the Padma river before flowing into the Bay of Bengal. The biodiversity features associated with freshwater may be affected by changes in the quality of water in the river because of the construction and operation of the project upstream and downstream. Therefore, on a precautionary basis and in recognition of the migratory ecology of many aquatic species, the AoA includes the river basins extending up to 150 km upstream and downstream from the bridge sites. The total area of the aquatic AoA is approximately 8,685 km2. 2.1.2.2 Terrestrial AoA The terrestrial AoA has been defined based on consideration of habitat continuity and scale of potential impacts across the landscape. Natural Habitats within the area likely to support high conservation value species include protected areas and wetland ecosystems. An ecologically contiguous area of these habitats was identified by using satellite images and GOB maps on

6 protected areas. The AoA also encompasses several internationally and nationally recognized protected areas including Khadimnagar national park, Rema Kalenga national park, Tilagorh eco- park and Hail Haor. For designated sites and mobile fauna, the AoA was taken to be a 10 km radius or buffer around as well as the Project direct AoI itself. The area encompasses over 2,260 Km2 or 226,000 ha in total and addresses species that move widely in the area to the extent that information on them is available. For plants and less mobile species, the AoA was taken to be the Project direct AoI, which was an area of 300m on either side of the centerline of the proposed road (around 6270 ha). 2.2 Priority Biodiversity Features Baseline survey data were collected on five biodiversity groups (i.e. birds, reptiles and amphibians, flora, fish, and mammals) between December 2019 and March 2020 by the biodiversity expert of the IEE study team. Surveys were conducted mainly within the Project AOI and its vicinity including main rivers within the project area. The aim of these surveys was to obtain a global picture of the presence and distribution of threatened species that may occur in the Project area, as well as to gather baseline data, results of which are presented in Annexes 26-28 of the IEE report. These field surveys complemented an initial desktop and literature review, as well as stakeholder’s engagement, and thus fulfilled IFC GN67-68. In addition to the field surveys, IBAT provided a list of priority species that could occur within the 50 km buffer. The total is 70 priority species belonging to nine different orders. The species belonging to the marine environment (project area lies deep inland), ones that do not exist/extinct from Bangladesh have been dropped from CHA. Only 16 priority species were identified as potentially triggering Critical Habitat based on Criteria 1-2 (detailed in section 1.2), and are presented in Table 2. An individual Critical Habitat assessment is provided for these species in section 3.0. Several migratory bird species were recorded during baseline surveys; however, all of these species are classified as Least Concern on the IUCN Red List, having a large distribution range and population size, and were therefore considered unlikely to trigger Critical Habitat based on Criteria 3.

Table 2: Priority species recorded during baseline biodiversity surveys and the IBAT’s preliminary priority species within 50km buffer that may trigger Critical Habitat according to Criteria 1-2 Family Species English Name IUCN RR END Confirmed Status in the DMU? Birds/Aves Accipitridae Gyps bengalensis White-rumped CR N N N Vulture Accipitridae Gyps tenuirosris Slender-billed CR N N N Vulture Accipitridae Haliaeetus Palla’s Fish-eagle EN N N N eucoryphus Anatidae Aythya baeri Baer's Pochard CR N N N Emberizidae Emberiza aureola Yellow-breasted CR N N N Bunting Accipitridae Aquila nipalensis Steppe Eagle EN N N N Laridae Sterna acuticauda Black-bellied Tern EN N N N Acrocephalidae Acrocephalus Large-billed DD N N N orinus Reed-warbler Reptiles Testudinidae Indotestudo enlongata Elongated CR N N N Tortoise Geoemydidae Batagur dhongoka Three-striped CR N N N Roofed Turtle Geoemydidae Batagur baska Northern River CR N N N Terrapin Geoemydidae Geoclemys hamiltonii Spotted Pond EN N N N Turtle Mammals Platanistidae Platanista gangetica Gangetic Dolphin EN N N N gangetica Hylobatidae Hoolock hoolock Western Hoolock EN N N N Cercopithecidae Trachypithecus Phayre’s Leaf- EN N N N phayrei monkey Manidae Manis crassicaudata Indian Pangolin EN N N N Freshwater Fishes Cyprinidae Tor putitora Golden mahseer EN N N N Dasyatidae Urogymnus polylepis Giant Freshwater EN N N N Ray Siluridae Wallago attu VU N N N Sisoridae Bagarius yarrelli VU N N N Sciaenidae Johnius gangeticus DD N N N Siluridae Ompok bimaculatus NT N N N Megalopidae Megalops Indo-Pacic Tarpon DD N N N cyprinoides Note: IUCN Status: CR – Critically Endangered, EN – Endangered and DD – Data Deficient; RR – Restricted Range and END – Endemic. Y- Yes and N - No

2.3 Critical Habitat Threshold Value Critical habitat is an area which contains features that are essential for the conservation of a species or habitat of conservation concern and may require targeted management and protection. Critical habitat may include an area that is not currently occupied by a species but is necessary for its recovery. The critical habitat definition presented in paragraph 16 of Performance Standard 6 is in line with criteria captured from a range of definitions of priority habitat for biodiversity conservation in use by the conservation community and incorporated in related governmental legislation and regulations. Critical habitats are areas of high biodiversity value that include at least one or more of the five values specified in paragraph 16 of Performance Standard 6 and/or other recognized high biodiversity values. There is no one criterion that is more important than any other for making critical habitat designations or for determining compliance with Performance Standard 6. For ease of reference, these values are referred to as “critical habitat criteria” for the remainder of this document. Each criterion is described in detail in paragraphs GN70–GN83. Critical habitat criteria are as follows and should form the basis of any critical habitat assessment: (GN53)

• Criterion 1: Critically Endangered (CR) and/or Endangered (EN) species • Criterion 2: Endemic or restricted-range species • Criterion 3: Migratory or congregatory species • Criterion 4: Highly threatened and/or unique ecosystems • Criterion 5: Key evolutionary processes Projects that are located within internationally and/or nationally recognized areas of high biodiversity value may require a critical habitat assessment. Examples include the following: (GN54)

• Areas that meet the criteria of the IUCN’s Protected Area Categories Ia, Ib and II. GN9 • Key Biodiversity Areas (KBAs), GN10 which encompass Important Bird and Biodiversity Areas (IBAs). To facilitate decision-making, numerical thresholds have been defined for the first four critical habitat criteria (i.e., CR/EN species; endemic/restricted-range species; migratory/congregatory species; threatened and unique ecosystems). The thresholds presented in this Guidance Note were obtained from globally standardized numerical thresholds published in the IUCN’s A Global Standard for the Identification of Key Biodiversity Areas and Red List Categories and Criteria. The thresholds are indicative and serve as a guideline for decision-making only. There is no universally accepted or automatic formula for making determinations on critical habitat. The involvement of external experts and project-specific assessments is of utmost importance, especially when data are limited (as will often be the case). (GN56) For Criterion 5, there are no numerical thresholds. Best available scientific information and expert opinion should be used to guide decision-making with respect to the relative “criticality” of a habitat in these cases. (GN57)

To process Critical Habitat determination, the population in the AoA was compared to its global population using its range or abundance. Where estimates for a species population were not available, expert opinion from specialists that conducted biodiversity baseline surveys was required to determine the significance of the discrete management unit with respect to the global population. As population abundance is rarely available for a specific species, the extent of occurrence (EOO) and the Area of Occupancy (AOO) were mainly used as a proxy for population size. The EOO is defined as the area contained within the shortest continuous imaginary boundary which can be drawn to encompass all the known, inferred or projected sites of present occurrence of a taxon, excluding cases of vagrancy. In cases where the habitat contained within the EOO is highly fragmented, or that the species in question occur at low density and that large parts of its range are considered unsuitable, the AOO may be a more powerful proxy to abundance, as the AOO species excludes the case of vagrancy from the EOO.

3 Critical Habitat Determination Species potentially triggering Critical Habitat were screened against the IFC Criteria 1-2 and their respective thresholds. Their detailed assessment is presented in the subsections below. 3.1 Criterion 1: Globally or Nationally Critically or Endangered Species 3.1.1 Birds 1) White-rumped vulture, Gyps bengalensis, (CR, A2bce+4bce) White-rumped vultures have been identified as Critically Endangered bird species both globally and nationally [1]. This species is assessed as Critically Endangered because of extremely rapid population decline and it may go extinct within a few years primarily as a result of feeding on carcasses of animals treated with the veterinary drug diclofenac and ketoprofen. It has been in the list of IBAT’s priority species that could occur within the 50 km buffer. Its global population is now estimated to fall within the range 2,500-9,999 mature individuals. SAVE (Saving Asia's Vultures from Extinction) has developed the concept of Vulture Safe Zones; areas (with a minimum of 100 km radius, equating to 30,000 km2) around important vulture breeding colonies. The Government of Bangladesh has declared two safe zones for vultures, where ‘zero tolerance' will be shown towards using diclofenac and other harmful veterinary drugs [2]. The designated areas are Sylhet, parts of Dhaka and Chittagong divisions covering an area of 19,663.18 km2 (1,966,318 ha) as the Vulture Safe Zone 1 which covers the proposed project road area [4] (Refer F. Surveys conducted in 2014 by IUCN Bangladesh and Bangladesh Forest Department showed the White-rumped Vulture population has further declined to about 260 individuals (Alam et al., 2016b). Most of the vultures were found in Habiganj district in Sylhet division (n=80), Khulna (n=50) and Bagerhat (n=40) districts in Khulna division [5 (Alam, Ahmed, & Rahman, 2016)]. The baseline survey was not able to document the occurrence of this species in the AOA. However, past surveys have documented the existence of vulture in Habiganj district (around 80 numbers in Rema Kalenga Wildlife Sanctuary). This represents 30.8% of the national population. Bangladeshi population represents 2.6% of the global population. Though the national population may look insignificant at the global level, the DMU population represents significant numbers at the national level. Further, the proposed project road falls within the Vulture Safe Zones. Therefore, this species triggers Critical Habitat.

2) Slender-billed Vulture, Gyps tenuirostris (CR, A2ce+4ce) The Critically Endangered Slender-billed Vulture, Gyps tunuirostris occurs throughout South and Southeast Asia. The species is native to Bangladesh, Cambodia, India, Laos, Myanmar and Nepal, and feared regionally extinct in Malaysia, Thailand and Vietnam (BirdLife International 2013). In Bangladesh, there is one recent record from Rema Kalenga Wildlife Sanctuary. It used to occur in the northeast, central and southeast of Bangladesh (Red List of Bangladesh, Volume 3: Birds 2015). This species is seen soaring and feeding usually in small groups and often joins with other vulture species. It inhabits dry open country and forested areas, usually away from human habitation, but also occurs in cultivated areas, wastelands and dumps in human neighbourhoods. It feeds almost entirely on carrion at rubbish dumps and carcasses dumped in open areas (Khan 2008). The global population of this species stand in the range of 1000 - 2,499 numbers. However, there are no national and local figures for this species. Given the species existence at Rema Kalenga Wildlife Sanctuary, which is about 10km away from the Project direct AoI and the large distances travelled by this species, the AOA is not considered Critical Habitat. 3) Palla’s Fish-eagle, Haliaeetus leucoryphus, (EN, C2a(ii)) This species has a small, declining population as a result of the widespread loss, degradation and disturbance of wetlands and breeding sites throughout its range. The global population is now estimated to be considerably lower than was previously thought, and is now thought to comprise a single, migratory subpopulation. It has therefore been up-listed to Endangered. Global population is placed in the range of 1,000–2,499 mature individuals, and considered to comprise a single migratory population, rather than multiple isolated subpopulations. Its EOO and AOO is estimated as 154,541 km2 and 5,699 km2 respectively. It occurs mainly in the haors and open water central, southwest and northeast regions of Bangladesh as well as in other larger wetlands and the Sundarbans Mangrove Forest (Islam and Kamruzzaman 2008, Khan 1987, 2008, 2015). This species is an uncommon breeding migrant to Bangladesh. Its population is small (< 250) and declining as a result of loss and degradation of habitat and disturbance at breeding sites [7]. Breeding takes place from September-February in northern India and Myanmar (BirdLife International 2001), and in Bangladesh it returns to nest sites in late August (Sourav et al. 2011) [6].

The baseline survey did not record the occurrence of this species in the project area. A thorough surveys might reveal a more widespread AOO, but currently approximately 3.7% of its EOO is included in the AOA, therefore this species will not trigger Critical Habitat. 4) Baer’s Pochard, Aythya baeri, (CR, A2cd+3cd+4cd; C2a(ii)) Baer’s Pochard is listed as a critically endangered duck species in the world. Globally, this species breeds in the Amur and Ussuri basins in Russia and north-eastern People’s Republic of China. It winters mainly in eastern and southern mainland People’s Republic of China, India, and Myanmar, with smaller numbers in Japan; North Korea; South Korea; Hong Kong, China; Taipei,China; Nepal; Bhutan; Thailand; Lao PDR; Vietnam; and rarely to Mongolia (BirdLife International 2012). In Bangladesh, it occurs mainly in the haors of the northeast region (Tanguar and Hakaluki Haors). The population of this species has been declining rapidly over the years. The decline of the highest annual counts of Baer’s Pochards in Bangladesh are as follows: 1,714 in 1990-1999; 216 in 2000-2009 and 17 in 2010-2014. Its EOO and AOO are estimated as 3,914 km2 and 1,455 km2 respectively. This species is gregarious and is usually seen in groups with other ducks. It forages in shallow water mostly by diving and feeds mainly on submerged vegetation at 1.26–1.88 m deep water. It is diurnal and crepuscular (Khan 2008). It is a rare winter migrant and it is estimated that the population has declined by 90% over the last ten years, and by 99% since the early 1990s. Less than 10 individuals have been recorded in each of the last four winters. The population is estimated to be less than 50 and is decreasing. Wang et al. (2012) stated that the global population is likely less than 1,000 individuals and could be much less than this, and so it is placed in the band 250-999 individuals, equating to 167-666 mature individuals, rounded here to 150- 700 mature individuals, which now potentially can be considered to be in one sub-populations (R. Hearn in litt. 2016). While the national population is only 1.4% of the global population of 700 matured individuals, the Tanguar, Pashua, Hakaluki, and Hail Haors birds represent probably 100% of the Bangladeshi bird population. The percentage of this critically endangered bird within AOA (Hakaluki & Hail Haors) is uncertain as the recent population count is not available. Further, given the locations of Hail and Hakaluki Haors 10 Km and 50 Km away respectively from the project direct area of influence, the critical habitat is not triggered. 5) Yellow-breasted Bunting, Emberiza aureola (CR, A2acd+3cd+4acd) The formerly common winter visitor is now rare in Bangladesh. The sighting records suggest a sharply declining population (Thompson et al., 2014). The area of occupancy (AOO) is estimated to be less than 2,000 km2, and the extent of occurrence (EOO) 14,118 Km2. Under the Bangladeshi red list, the species is categorised as Vulnerable under criterion B2. However, globally, it is enlisted as a critically endangered species. This rare and critically endangered species was recently sighted at Baikka beel, an Important Bird Area (IBA). There are some sightings reported in the northeast regions of the country. The Baikka beel is part of the Hail Haor located 10 Km from the project footprint.

In Europe, the breeding population was estimated to number 20,000-100,000 breeding pairs, equating to 60,000-300,000 individuals (BirdLife International 2004). Europe, at least formerly, formed 25-49% of the global range. The European population is now estimated to number just 120-600 mature individuals (BirdLife International 2015). This species occupies a large range, but is declining in much of it and is listed as “vulnerable” in Bangladesh. The species is migratory and gregarious. It forages by creeping through grasses, bushy meadows close to the water and cultivated fields in winter. It is diurnal and feeds on grass seeds, cereal and insects. The species is known to winter at Baikka beel and is a KBA citation species. The population both at the national and the AoA level are not known. Overall, it is now a rare bird in Bangladesh. Given the species existence at Baikka Beel, which is 10km away from the Project direct AoI and the large distances travelled by this species, the AoA is not considered Critical Habitat. 6) Black-bellied Tern, Sterna acuticauda (CR, A2acd+3cd+4acd) This species is an extremely rare resident of the large rivers of Bangladesh. Its population has declined over the 20 years by more than 90% (98 in 1995 and 2 in 2012). It is feared to have extirpated now (a recent survey at its traditional habitats failed to record any individual of this species). Although the countrywide survey has not been conducted, it can be assumed with certainty that the population is less than 50. This resident species is, therefore, assessed Critically Endangered owing to a very small and restricted population (Red List of Bangladesh, Volume 3: Birds, 2015). This species is gregarious and lives in the fresh waters, such as large rivers, lakes and other inland waters and rarely coastal zones (Islam 2008). It is diurnal and forages in flight, dipping to the water surface, flying over lands and close to water. It feeds on small fish, crustaceans and insects (Islam 2008). Globally it occurs in Bangladesh, Cambodia, India; Lao People’s Democratic Republic, Myanmar, Nepal, Pakistan, Thailand, Viet Nam (BirdLife International 2012). In Bangladesh, it occurs along the major rivers of the central and northern region (Islam 2008). The EOO of this species is around 4,647 km2 and AOO is 793 km2. The global population of this species is in the range of 6,700-17,000 mature individuals. In Bangladesh, the population is lower than 50 and decreasing; 98 individuals in 1995; 2 individuals in 2011; probably 0 in 2014 (Chowdhury et al. 2014). Since the national population <0.3% of the global population and with no record of this species within the AoA, Critical Habitat is not triggered. 7) Steppe Eagle, Aquila nipalensis (EN, A2abcd+3bcd+4abcd)

This uncommon winter migrant is widely distributed in Bangladesh. The area of occupancy (AOO) is estimated to be 1,39,772 km2, and the extent of occurrence (EOO) 2,22,509 Km2. IUCN has categorised this species as Endangered while in Bangladesh it has been listed as Least Concern. The reason is that the species is not a habitat specialist and occurs in a wide variety of habitats. There is no notable threat to it, and there is no indication that the population is declining in Bangladesh (Red List of Bangladesh, Volume 3: Birds, 2015). This species is migratory and is seen singly in areas of the countryside mainly around wetlands. Small flocks can gather at thermals, roosts and good feeding sites. It feeds mainly on small mammals, birds, reptiles (Haque and Kamruzzaman 2008). The baseline biodiversity survey was not able to identify this species. The global population is estimated to be in the range of 50,000 - 75,000. However, there are no population estimates for this species at the national (Bangladesh) or AoA level. Given the large area of occurrence and no special habitat requirement for this species, the AoA is not considered Critical Habitat. 8) Large-billed Reed-warbler, Acrocephalus orinus (DD, ver 3.1) IUCN listed this species under the Data Deficient category owing to the limited knowledge of the species. The breeding extant include Afghanistan and Tajikistan while the non-breeding extant include Bangladesh, Myanmar and Thailand. India is known to have a resident population. This species is migratory. It forages alone in bushes, scrubs and reeds near wetlands. It is diurnal and feeds on insects. The global population and its trend are not known. An individual was also trapped and ringed in Baikka Beel, Bangladesh in December 2011 (Round et al. 2014). Since the only known existence of this species at Baikka Beel, which is 10km away from the Project direct AoI, the AoA is not considered Critical Habitat. 3.1.2 Reptiles 1) Elongated Tortoise, Indotestudo elongate (CR, C2a) Indotestudo elongata is a critically endangered species that is widely distributed across South and Southeast Asia. The westernmost limit of the species range is in Kaleshar Wildlife Sanctuary in the foothills of the Himalayas in the Aravali Range. It has localised occurrences in northern and eastern India, Nepal and Bangladesh, Bhutan and much of Myanmar, Thailand and Cambodia, and scattered occurrences in Lao PDR and Viet Nam, and extreme northwestern Peninsular Malaysia (Iverson 1992). It is rarely found in the hill forests of the northeast, east and southeast Bangladesh. The Area of Occupancy is 1,052 km and populations of mature individuals at Inani Reserve Forest (a subpopulation) is predicted to be less than 50, which signifies Critically Endangered [C2a(i)], so the

species is assessed as Critically Endangered (Red List of Bangladesh, Volume 4: Reptiles & Amphibians, 2015). Since the area of occupancy lie outside AOA and the project direct AoI, the AoA is not considered Critical Habitat 2) Three-striped Roofed Turtle, Batagur dhongoka (CR, A1cd+A2bc) The Extent of Occurrence of Batagur dhongoka is very large (84,102 km2) as also the Area of Occupancy (4,508 km2), which are beyond the threshold of Threatened Category. However, the species is very rare in its entire range in the Ganges (Padma) and the Jamuna River Systems of Bangladesh and assumed to have a very small and restricted population and the population reduction is more than 90% in the last 10 years. Considering all these facts, this taxon has been assessed as Critically Endangered (Red List of Bangladesh, Volume 4: Reptiles & Amphibians, 2015). Batagur dhongoka is an animal of deep flowing large rivers, like the Ganges (Padma) and the Jamuna River systems, and also in the sandbanks and riverbanks of these rivers as this species basks and lays eggs there. This diurnal species is semi-aquatic (Asian Turtle Trade Working Group 2000) and is found in large rivers (Das 2002, Islam 2009). It basks on the shore, sandbanks and logs (Islam 2009). Males are omnivorous, feeding on water plants and mollusks, females are herbivorous (Das 2002). Females lay 21-35 eggs on a sandbank during March-April (op. cit.). The large river (Padma and Jamuna River Systems) habitats of this critically endangered species are outside the AoA and the Project AoI; hence the AoA is not considered Critical Habitat. 3) Northern River Terrapin, Batagur baska (CR, A2acd+4cd; C1+2a(i)) Batagur baska is listed as Critically Endangered as recent surveys revealed no viable population in the wild and only 2- youngs were found in the Sundarbans in 2013. As per the Red List of Bangladesh Volume 4, once there was a sizable population that has been virtually decimated due to overhunting and consumption by the people of a particular community living beside the Sundarbans. Batagur baska once ranged from Orissa and West Bengal in India through Bangladesh and Myanmar (lower Ayayarwady, Sittaung and Thanlwin [Salween]), and possibly as far south as the Andaman Sea side of Thailand at the Kra river. It is now limited to the Sundarbans area of India and Bangladesh, with three females in two different temple ponds in Myanmar (S. Singh and P. Praschag pers. comm. 2018). Populations of river terrapins in Southeast Asia previously referred to as this species is now considered a separate closely related species, the Southern River Terrapin (Batagur affinis). Since the existences of Batagur baska is outside the AoA and the project direct AoI, the AoA is not considered Critical Habitat.

4) Spotted Pond Turtle, Geoclemys hamiltonii (EN, A2cd+4cd)

Globally, Geoclemys hamiltonii is found in Bangladesh, India, Nepal and Pakistan (Asian Turtle Trade Working Group 2000). It has been classified as endangered. In Bangladesh, the species was considered rare after an abrupt population decline in the past 20 years and total disappearance from extensive parts of its range (Rashid and Khan 2000). By 2011, the species was considered to be more threatened than previously thought and estimated to have lost at least half its population since 1980, qualifying nationally as Endangered (M.A. Rashid pers. comm. at Singapore Red List Workshop, 2011). There are few sighting records in Chittagong, Dhaka, Jessore, Manikganj, Narshingdi and Sylhet. It is an uncommon species in the Ganges and Brahmaputra river systems and adjacent water bodies. The population has declined more than 50% due to trapping in fishermen’s net, professional poachers and over-exploitation and due to habitat loss. Therefore, the species is an Endangered one under the Red List of Bangladesh, Volume 4: Reptiles & Amphibians. Geoclemys hamiltonii is aquatic and carnivorous; diets include mollusks, insect larvae, earthworms, meat and fish, fruits and leaves. Females lay 13-24 eggs in a clutch, and more than one can be laid in a year, and the incubation period is 23-76 days (Das 2002). It inhabits freshwater river systems, wetlands, shallow water, beels, haors and ponds. The global, national and local population within the AoA are unknown. However, it is agreed in general that the population is decreasing. Further assessment on this species may be necessary to gain insight into species status within the AoA. As the AoA is right along the edge and constitutes less than 1% of its known range. Therefore, the AoA is not considered critical habitat for this species. 3.1.3 Fishes 1) Tot putitora, (EN, A2abcd) The species is under severe threat from overfishing, loss of habitat, and decline in quality of habitat resulting in the loss of breeding grounds, and from other anthropogenic effects that have directly resulted in declines in harvest in its entire locations. Its Extent of Occurrence (EOO) and Area of Occupancy (AOO) is estimated as 1,300 km2 and 488 km2, respectively. It has so far been noted just from two locations in the upstream of the trans-boundary rivers with India. The species is, therefore, assessed as Endangered and is in need of urgent conservation efforts to save it from becoming regionally extinct in the country. It is endemic to Asia and distributed in Bangladesh, India, Malaysia, Nepal, Pakistan, Sri Lanka, and some south east countries of Asia (Shrestha1990, Rahman 2005, Nguyen et al. 2008). In Bangladesh, Tor mahseer occurs in Someswari River in Netrokona. It is found occasionally in Kaptai Lake in Rangamati District and Tanguar Haor, Sunamgong (pers. obs. 16 June 2014). There is no report of this species within the AoA. Therefore, this species does not trigger Critical Habitat.

2) Urogymnus polylepsis, (EN, A2bcd)

Bottom-dwelling in nature, the giant freshwater stingray inhabits sandy or muddy areas and preys on small fishes and invertebrates. Females give live birth to litters of one to four pups, which are sustained to term by maternally produced histotroph ("uterine milk"). This species faces heavy fishing pressure for meat, recreation, and aquarium display, as well as extensive habitat degradation and fragmentation. These forces have resulted in substantial population declines in at least central Thailand and Cambodia. As a result, IUCN has assessed the giant freshwater stingray as Endangered. It is found in large rivers and estuaries in Southeast Asia and Borneo, though historically it may have been more widely distributed in South and Southeast Asia. Historical records from Myanmar, the Ganges River in India, and the Bay of Bengal have similarly not been corroborated by any recent accounts. There is no report of this species within the AoA. Therefore, this species does not trigger Critical Habitat. 3.1.4 Mammals 1) Gangetic river dolphin, Platanista gangetica gangetica (EN, A2abcde +3bcde +4abcde) This species Gangetic river dolphin, Platanista gangetica gangetica, has been declared as endangered globally by IUCN, 2012 and placed in the First Schedule of Bangladesh Wildlife (Preservation & Security) Acts, 2012 [1]. South Asian River Dolphin continues to decline as populations are extirpated due to habitat loss related to escalating water demands, large engineering structures (e.g., high dams, barrages, and embankments), and long-term climate changes (Smith et al. 2010, Chaudhary et al. 2012, Braulik et al. 2014). The global population estimates are about 3,500 individuals throughout its distribution range (Sinha et al. 2014). On the other hand, Sinha and Kannan (2014) tabulated a total of 3,526 individuals for the Ganges River subspecies [3]. Gangetic Dolphins are distributed in major river systems in Bangladesh including the rivers Padma, Jamuna, Burhi Ganga, Kushiyara, Meghna, Karnaphuli-Sangu and the Sundarbans [2]. However, the rivers within the AOA are only Meghna and Kushiyara river system. It is reported that during October 1995 and April 1996 for 113 km section of the Kushiyara River located between the Bangladesh–India border and the confluence of the Korangi River has recorded a sighting rate of 0.08 sightings/km (mean group size = 3.8 dolphins [2]. Water level in Kushiyara river remains critically low in winter season to support dolphins. Although a previous study conducted back in 1995-1996 reported 34-43 dolphins from the Kushiyara Rivers (Smith et al., 1998) [4]. However, there are also studies which suggest that minor river system, tributaries like Kushiyara river might no longer be suitable for dolphins in winter months. Existing Sherpur Bridge at Km 185+600 of Dhaka-Sherpur Bridge is the nearest point on Kushiyara river and is the part of the proposed project [3]. On the other hand, identified nearest critical winter habitats of Gangetic Dolphins is near Bhairab Bridge (from Km 67+800) on Meghna river where good numbers of dolphins are spotted within

400m North (Upstream) of Bhairab Bridge during field survey in February, 2019 [3]. However, no data on dolphin population size or density could be found on the areas near Bhairab Bridge. Literature review of secondary sources reveals that the AoA is not likely to support population size ≥0.5% of the global population and ≥ 5 reproductive units. Hence the Critical Habitat is not triggered for this species. 2) Western hoolock, Hoolock hoolock, (EN, A4acd) This species is found in eastern Bangladesh, northeastern India, and northwestern Myanmar (west of the Chindwin River). It might possibly occur in People’s Republic of China (extreme southeastern). The distribution in India is restricted to points south of the Brahmaputra and east of the Dibang (Dingba Qu) Rivers (Choudhury 2001). Animals that once were common in the plains of northeastern India before that habitat was cultivated for agriculture and tea are not so anymore (Islam and Feeroz 1992). There are estimated to be about 200-280 hoolocks in Bangladesh (Islam et al. 2006, Molur et al. 2005). In Bangladesh, the main threats are the combined effects of habitat loss, fragmentation, human interference and hunting (Islam and Feeroz 1992, Molur et al. 2005). Hoolock hoolock remains Endangered, based upon a suspected population reduction of at least 50% over the period of three generations, based on ongoing and significant levels of forest loss in Bangladesh, northeastern India and Myanmar. Hoolock hoolock is now restricted to mixed evergreen forests of northeast and southeast of Bangladesh (Ahsan 1994, Khan 1982, 2015). These habitats are outside the AoA, in the 50 km range; hence the Critical Habitat is not triggered. 3) Phayre’s Leaf-monkey, Trachypithecus phayrei, (EN, A2cd) Trachypithecus phayrei phayrei is listed as Endangered as it is suspected to have undergone a decline of more than 50% over the last three generations (36 years). Trachypithecus phayrei phayrei occurs in Bangladesh, northeastern India (Assam, Mizoram, and Tripura), and western Myanmar. The population in Bangladesh has declined by more than 80% in the last 20 years, making it very vulnerable in its extremely fragmented locations (Molur et al. 2003). In Bangladesh it is listed as Schedule III in the Bangladesh Wildlife (Preservation) (Amendment) Act, 1974. This species is found in several protected areas throughout its range, including Lawachara National Park, Rema-Kalenga Sanctuary (Bangladesh). The population trend is known to be declining though its population at the global, national and local level are not known. Since the species exist outside the AoA (in the northeastern and southeastern corners of the country), it does not trigger Critical Habitat.

4) Bengal Slow Loris, Nycticebus bengalensis, (EN, A2acd+3cd+4acd) This species listed as an endangered occurs in Bangladesh, Cambodia West of the Mekong River, People’s Republic of China (southern and western Yunnan and possibly in southwestern Guangxi), north-eastern India, Lao PDR, Myanmar (including the Mergui Archipelago), Thailand north of the Isthmus of Kra, and Viet Nam. In Bangladesh, it is rare and currently distributed in mixed evergreen forests of the northeast and southeast only (Red List of Bangladesh, Volume 2: Mammals, 2015). So, it is inferred that at least 50% of its population has been reduced due to the decline of its AOO, EOO, over the last two decades or so, unprecedented changes in habitat qualities and potential level of exploitation that are continuing unabated. It has been wiped out from its former range in the Sal forests (Khan 1987). Thus, it has been categorized as Endangered under the Red List of Bangladesh, 2015. The population trend is known to be decreasing though its population at the global level is not known. In Bangladesh, no specific nationwide population survey on this species has been carried out, but a 2015 survey recorded 34 Bengal slow lorises (18-night survey) in Satchari National Park of Sylhet division. The species was also recorded in Rema-Kalenga Wildlife Sanctuary (Feeroz et al, 2011) and Rajkandi Reserve Forest of Sylhet area (M. Foysal, T. Khan, pers. comm). Feeroz (2013) reported N. bengalensis as being rare in Teknaf Wildlife Sanctuary of Chittagong region [1]. Since the species exist outside the AOA (within a 50 km range in the northeastern and southeastern corners of the country), it does not trigger Critical Habitat. 5) Indian Pangolin, Manis crassicaudata, (EN, A3d+4d) Globally, it occurs in Bangladesh, India, Nepal, Pakistan and Sri Lanka (Baillie et al. 2014). In Bangladesh, from the 1950s to the early 1970s it used to be fairly common all over the country with village groves and all terrestrial forests except the Sundarbans. Starting 1980s its number started dwindling due to excessive hunting, loss of village groves, clearing and burning of natural forests by the government agencies and the hill-dwelling people for commercial forestry and Jhum cultivation (Khan 1982, 1987, 2015). It is now rare and found mostly in the southeast region of Bangladesh (IUCN Bangladesh, 2000). The population trend is known to be declining though its population at the global, national and local level are not known. Since the species exist outside the AOA (only in the southeastern corners of the country), it does not trigger Critical Habitat. 3.2 Criterion 2: Restricted Range or Endemic Species No Criterion 2-qualifying features have been identified for the Project.

3.3 Criterion 3: Migratory species and/or congregatory species Criterion 3-qualifying avian migratory species such as White-rumped vulture (Gyps bengalensis), Palla’s fish eagle (Haliaeetus leucoryphus), Baer’s pochard (Aythya baeri), Yellow-breasted bunting (Emberiza aureola), Steppe eagle (Aquila nipalensis), Large-billed Reed-warbler (Acrocephalus orinus) are discussed thoroughly under section 3.1 - Criteria 1: Globally or Nationally Critically or Endangered Species. The white-rumped vulture triggers critical habitat under Criterion 1 due to the importance of local population but does not qualify under Criterion 3, as the population within the vulture-safe zone falls below 1% of the global population. The rest were eliminated as critical habitat triggering species under Criterion 1 and are, therefore, not qualifying species under Criterion 3, i.e. unlikely to meet the 1% regular or cyclical presence of these species in the area or the area predictably supporting ≥ 10% of the global populations during periods of environmental stress. The nearest East Asian-Australasian Flyway Network and Central Asian-Indian Flyway Network Site is the Hail Haor at 9.4km away. Around 27 freshwater migratory fish species list has been generated through the IBAT freshwater function. Of which, 22 are of the least concern (LC) with wide EOO as per the IUCN red list; 2 species are vulnerable (VU); 2 data deficient (DD) and 1 near threatened (NT).

Table 3: Data Deficient and Not Evaluated species in the study area Family Species English Name IUCN Confirmed Possibility Status in the to trigger AoA? CH? Siluridae Wallago attu Wallago catfish VU N N Sisoridae Bagarius yarrelli Goonch/ Giant VU N N devil catfish Sciaenidae Johnius gangeticus Croaker DD N N Siluridae Ompok bimaculatus Butter catfish NT N N Megalopidae Megalops cyprinoides Indo-Pacic Tarpon DD N N

Wallago attu and Bagarius yarrelli are both in the vulnerable category; however, these species do not qualify for Critical Habitat because of their large extent of occupancies 10,446,620 km2 and 9,387,540 km2 respectively.

Two species (Johnius gangeticus & Megalops cyprinoides) are Data Deficient or have not yet been evaluated on the IUCN global Red List, and thus there is limited information available about them. Both Johnius gangeticus and Megalops cyprinoides are not known to inhabit the rivers within the project areas. Therefore, these species are not Critical Habitat qualifying biodiversity features.

Ompok bimaculatus or butter catfish is classified as near threatened under IUCN Red List. It is widely distributed in Pakistan, India, Sri Lanka, Bangladesh and Myanmar (Ng and Hadiaty 2009). Thus, this species will not trigger Critical Habitat. 3.4 Potential Impacts on CH Having determined the potential for CH to be present within the AoA, an assessment is then required of the potential for the road construction and operation to affect the proposed CH, and hence the need for any specific species or habitat action plans (Refer Table 4).

Table 4: Impact of Proposed Project on CH and Biodiversity Action Plan (BAP) Requirement Species/Habitats Reason for Protection Potential for Significant Residual BAP? Impacts from Construction or Operation of the Road? White-rumped vulture, This critically endangered The chances of direct impact from Not required – since the Gyps bengalensis species have been the project on this species is very likelihood of direct impact (IUCN: CR, A2bce+4ce) recorded in Habiganj low as there are no reports of by the project is almost district under Sylhet nesting and breeding sites within none. Nonetheless, division. Further, parts of project direct AoI. However, during project could work with the proposed project fall in construction, labourers may cause the Bangladesh Forestry the Vulture Safe Zones disturbance or harass the birds if it Department in assisting (VSZ). happens to be in the construction vulture conservation zone. program.

4 Protected areas and internationally recognized areas 4.1 PS6 criteria IFC PS6 paragraph 20 addresses project activity in Legally Protected Areas (LPAs) and Internationally Recognised Areas (IRAs). Where a Project is within an LPA or IRA, the client should meet the requirements of paragraphs 13 to 19 of PS6 (paragraphs 13-15 relate to Natural Habitat, and paragraphs 16-19 to Critical Habitat) (IFC 2012a). In addition, the client should:

• Demonstrate that the proposed development in the LPA/IRA is legally permitted; • Act in a manner consistent with any government recognized management plans for such areas; • Consult Protected Area sponsors and managers, Affected Communities, Indigenous Peoples and other stakeholders on the proposed project, as appropriate; and • Implement additional programs, as appropriate, to promote and enhance the conservation aims and effective management of the area’. 4.2 Qualifying features There are 10 protected areas and 15 Key Biodiversity Areas (KBA) that qualify as Critical Habitat for this Project (Table 5 and 6). Of the 15 KBA, 10 are inside India which has been left out.

Table 5: Status and description of Protected Areas Name Distance Description Khadimnagar 10 Km Status: LPA National Park Designation: Nationally protected Area: 679 ha (6.79 km2) IUCN Protected Area Management Category: Category II protected areas are large natural or near natural areas set aside to protect large- scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Description: The park is a major national park and nature reserve in Bangladesh. The park is located at Sylhet Sadar Upazila, Sylhet District in the North-East region of the country. It is located mainly on the Hills and is surrounded by Kalagool, Bhurjan and Goolni tea estates. The Forest was declared as national park by the Bangladesh government on 13 April 2006 under the Bangladesh wildlife (Preservation) Amendment Act of 1947. Rema Kalenga 10 Km Status: LPA National Park Designation: Nationally protected Area: 1795.54ha IUCN Protected Area Management Category: Category II protected areas are large natural or near natural areas set aside to protect large- scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Description: Rema-Kalenga Wildlife Sanctuary was established in 1982 and later expanded in 1996. Rema-Kalenga wildlife sanctuary is rich in rare species plants & animals. The forest currently has 37 species of mammals, 167 species of birds, seven species of

Name Distance Description amphibian, 18 species of reptiles and 638 species of plants. It is located 10 km east of the project area. Tilagorh Eco-Park 10 Km Status: LPA Designation: Nationally protected Area: 112 acres IUCN Protected Area Management Category: NA Description: The park is located in Tilagor area of Sylhet district, is the third Eco-park of Bangladesh. It is located 10 km west of the project area. Bangabandhu 50 Km Status: LPA Safari Park Designation: Nationally protected Gazipur Area: 1542 ha IUCN Protected Area Management Category: NA Description: It is a safari park located in Gazipur about 40 km north of Dhaka, Bangladesh capital city. The park is divided into 5 major sections. They are the Core Safari, Safari Kingdom, Biodiversity Park, Extensive Asian Safari Park and Bangabandhu Square. This safari park is home to 47 species of animals and birds out of which 28 species are native. Barshijora Eco- 50 Km Status: LPA Park Designation: Nationally protected Area: 887 acres IUCN Protected Area Management Category: NA Description: Barshijora Eco Park was established on 887 acres of reserve forest near Moulvibazar town in 2006. The forest was declared reserve in 1916. It is located east of the project area. Bhawal National 50 Km Status: LPA Park Designation: Nationally protected Area: 940 ha IUCN Protected Area Management Category: Category V Protected Landscape/ Seascape: A protected area where the interaction of people and nature over time has produced an area of distinct character with significant, ecological, biological, cultural and scenic value: and where safeguarding the integrity of this interaction is vital to protecting and sustaining the area and its associated nature conservation and other values.. Description: Bhawal National Park was established and maintained as a National Park in 1974; it was officially declared in 1982 under the Wildlife Act of 1974. By origin, it was the forest of Madhupur under the rule of Bhawal Estate. It is located in Gazipur, Dhaka Division of Bangladesh, approximately 40 km north of Dhaka city, only 20 km drive from Gazipur and 20 km from Kapasia. The core area of the park covers 940 hectares but extends to 5,022 ha of surrounding forest. Its purpose is to protect important habitats as well as to provide opportunities for recreation. It has been kept under IUCN Management Category V, as a protected landscape. The most common flora is the unique coppice sal forest. Lawachara 50 Km Status: LPA National Park Designation: Nationally protected Area: 1,250 ha IUCN Protected Area Management Category: II National Park: Category II protected areas are large natural or near natural areas set aside to protect large-scale ecological processes, along with the complement of species and ecosystems characteristic of the area,

Name Distance Description which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Description: The park is located at Kamalganj Upazila, Moulvibazar District in the northeastern region of the country. It is within the 2,740 ha (27.4 km2) West Bhanugach Reserved Forest. Lawachara National Park covers approximately 1,250 ha (12.5 km2) of semi-evergreen forests Biome and mixed deciduous forests Biome. The land was declared a national park by the Bangladesh government on 7 July 1996 under the Wildlife Act of 1974. The park is located within 50 Km radius and in the east of the project area. Mirpur Botanic 50 Km Status: LPA Garden Designation: Nationally protected Area: 84 ha IUCN Protected Area Management Category: NA Description: The National Botanic Garden of Bangladesh and the Bangladesh National Herbarium make up the largest plant conservation center in Bangladesh, with an area of around 84 hectares (210 acres). It is located at Mirpur in Dhaka, beside the Dhaka Zoo. It was established in 1961. It is one of the greatest botanic gardens of Bangladesh, a knowledge center for nature lovers and botanists and a tourist destination. The herbarium has a scientific collection of approximately 100,000 preserved specimens of plants. Satchari National 50 Km Status: LPA Park Designation: Nationally protected Area: 243 ha IUCN Protected Area Management Category: II National Park: Category II protected areas are large natural or near natural areas set aside to protect large-scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Description: Satchari national park is located in Habiganj District, Bangladesh declared as national park based on the 1974 Wild Life Preservation Act, in 2005. Satchari National Park. Sepahijola 50 Km Status: LPA Wildlife Sanctuary Designation: Nationally protected Area: 18.53 km2 IUCN Protected Area Management Category: IV Habitat/Species Management Area: Category IV protected areas aim to protect particular species or habitats and management reflects this priority. Many Category IV protected areas will need regular, active interventions to address the requirements of particular species or to maintain habitats, but this is not a requirement of the category. Description: Sepahijala Wildlife Sanctuary is in Tripura, India of some 18.53 km2 about 25 kilometres from the city centre, located in Bishalgarh. It is a woodland with an artificial lake and natural botanical and zoological gardens.

Table 6: Description and status of Key Biodiversity Areas Name Distance Description Hail Haor 10 Km Status: LPA Designation: Important Bird Area Area: 21,896 ha IBA Criteria: A1, A4i, A4iii Assessment Year: 2004 IBA Trigger Species: 1. Baer’s Pochard (Aythya baeri) – Critically Endangered 2. Greater Spotted Eagle (Clanga clanga) – Vulnerable 3. Fulvous Whistling-duck (Dendrocygna bicolor) – Least concern 4. Lesser Whistling-duck (Dendrocygna javanica) – Least concern 5. Palla’s Fish Eagle (Haliaeetus leucoryphus) – Endangered Aila Beel 50 Km Status: LPA Designation: Important Bird Area Area: 1,195 ha IBA Criteria: A1, A4i, A4iii Assessment Year: 2004 IBA Trigger Species: 1. Northern Pintail (Anas acuta) – Least concern 2. Common Teal (Anas crecca) – Least concern 3. Baer’s Pochard (Aythya baeri) – Critically Endangered 4. Common Pochard (Aythya ferina) – Vulnerable 5. Tufted Duck (Aythya fuligula) – Least concern 6. Ferruginous Duck (Aythya nyroca) – Near Threatened 7. Lesser Whistling-duck (Dendrocygna javanica) – Least concern 8. Common Coot (Fulica atra) – Least concern 9. Lesser Adjutant (Leptoptilos javanicus) – Vulnerable 10. Gadwall (Mareca Strepera) – Least concern 11. Garganey (Spatula querquedula) – Least concern Hakaluki Haor 50 Km Status: LPA Designation: Important Bird Area Area: 19,310 ha IBA Criteria: A1, A4i, A4iii Assessment Year: 2004 IBA Trigger Species: 1. Northern Pintail (Anas acuta) – Least concern 2. Common Teal (Anas crecca) – Least concern 3. Baer’s Pochard (Aythya baeri) – Critically Endangered 4. Common Pochard (Aythya ferina) – Vulnerable 5. Tufted Duck (Aythya fuligula) – Least concern 6. Ferruginous Duck (Aythya nyroca) – Near Threatened 7. Lesser Whistling-duck (Dendrocygna javanica) – Least concern 8. Common Coot (Fulica atra) – Least concern 9. Lesser Adjutant (Leptoptilos javanicus) – Vulnerable 10. Gadwall (Mareca Strepera) – Least concern 11. Little Cormorant (Microcarbo niger) – Least concern Rajkandi 50 km Status: LPA Reserved Forest Designation: Nationally protected

Name Distance Description Area: 2,450 ha IUCN Protected Area Management Category: IV Habitat/Species Management Area: Category IV protected areas aim to protect particular species or habitats and management reflects this priority. Many Category IV protected areas will need regular, active interventions to address the requirements of particular species or to maintain habitats, but this is not a requirement of the category. Description: Rajkandi Reserve Forest is located in Kamalganj upazilla under Moulvibazar district of Bangladesh. This reserved forest covers an area of 2,450 hectares in Rajkandi forest range that lies between the 24º12´-24º17´N and 91º51´-91º55´E, and comprises diverse habitats and ecosystems. This tropical semi-evergreen forest falls within the Indo-Burma* hot-spot of biodiversity (Myers et al., 2000). It lies to the east of the project area.

*This is a geographical reference on the biodiversity hotspot covering all non-marine parts of Cambodia, Lao People’s Democratic Republic, Myanmar, Thailand, Viet Nam, and southern parts of People’s Republic of China. Rema Kalenga 10 Km Status: LPA National Park Designation: Nationally protected Area: 1795.54ha IUCN Protected Area Management Category: Category II protected areas are large natural or near natural areas set aside to protect large- scale ecological processes, along with the complement of species and ecosystems characteristic of the area, which also provide a foundation for environmentally and culturally compatible, spiritual, scientific, educational, recreational, and visitor opportunities. Description: Rema-Kalenga Wildlife Sanctuary was established in 1982 and later expanded in 1996. Rema-Kalenga wildlife sanctuary is rich in rare species plants & animals. The forest currently has 37 species of mammals, 167 species of birds, seven species of amphibian, 18 species of reptiles and 638 species of plants. It is located 10 km east of the project area. 4.3 Implications of protected areas and KBA for the Project The Project footprint is not within or overlapping the Protected areas and KBA. Nevertheless, the Project should be aware of the potential for indirect impacts on this site and apply the mitigation measures prescribed in IEE report to avoid and minimise them.

INTERNAL. This information is accessible to ADB Management and staff. It may be shared outside ADB with appropriate permission.

5 Natural Habitat and Modified Habitat IFC GN6 defines Natural Habitats as ‘areas composed of viable assemblages of plant and/or animal species of largely native origin, and/or where human activity has not essentially modified an area’s primary ecological functions and species composition’. IFC GN6 defines Modified Habitats as ‘areas that may contain a large proportion of plant and/or animal species of non-native origin, and/or where human activity has substantially modified an area’s primary ecological functions and species composition’. The entire project area falls under the modified habitat of agricultural and settlement areas. The natural habitat as defined in the IFC GN6 are all located outside the 10 km buffer zone mainly towards the northeast, east and southeast of the country. These natural habitats are legally protected areas consisting of wetland (Ramsar sites) and national parks (Refer Table 5). 6 Conclusion and Implications The Critical Habitat Assessment revealed one species that triggered Critical Habitat for Category 1 under IFC GN6, the avian species (Gyps bengalensis), Refer Table 2. None of the species triggered Critical Habitat in the other categories. The extent of Critical Habitat within the Project area needs to be quantified, especially any residual loss relating to impacts from proposed road construction activities. The IFC PS6 recommends a No Net Loss (NNL) for the Project and a Net Positive Impact (NPI) in Critical Habitat. NNL is achieved when biodiversity gains from the combination of avoidance, mitigation, rehabilitation and targeted conservation actions match biodiversity losses related to the Project impacts. The term NPI refers to the point where biodiversity gains exceed biodiversity losses from the Project impacts. Therefore, proper mitigation measures, and habitat restoration beyond the AoI, should be implemented to ensure an NPI in Critical Habitat. This would also entail to closely monitor populations of CH triggering species in order to assess the effectiveness of proposed mitigation and restoration measures.

7 References 1) Siddique et al. (2008); IUCN Bangladesh (2015); Birdlife International (2016b) 2) A B M Sarowar Alam et al., 2016; Vultures and Vulture Safe Zones of Bangladesh 3) IUCN, International Union for Conservation of Nature Bangladesh Country Office 2015 4) Birdlife International. 2017. https://dx.doi.org/10.2305/IUCN.UK.2017- 3.RLTS.T22695194A118307773.en 5) Alam, A. B., Ahmed, S., & Rahman, S. (2016). Vultures and vulture safe zones of Bangladesh. Dhaka: IUCN, Bangladesh Country Office. 6) BirdLife International and Handbook of the Birds of the World (2018) 2018. https://dx.doi.org/10.2305/IUCN.UK.2018-2.RLTS.T22695130A131934599.en 7) IUCN, International Union for Conservation of Nature Bangladesh Country Office 2015