Environmental and Social Management Framework
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|Environmental Management Framework |
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|Bangladesh Rural Water Supply and Sanitation Project (BRWSSP) |
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|Department of Public Health Engineering |
|The Local Government Division (LGD), MOLGRDC Government of Peoples Republic of Bangladesh |
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|October, 2011 |
Table of Contents
Acronyms and Abbreviations 4
Executive Summary 6
1. Introduction 11
1.1 Project Background 11
1.2 Purpose of the Environmental Management Framework (EMF) 11
1.3 Structure of EMF 12
2. Project Description 12
2.1 Objectives of the Project 12
2.2 Components of the Project 13
2.3 Anticipated Subproject Types 13
2.4 Project Target Areas 14
2.4.1 Physiography and Land-use Pattern 14
2.4.2 Hydrology 15
2.4.3 Ground Water 16
2.4.4 Ecology 18
2.4.5 Environmentally and Ecologically Sensitive Areas 19
2.5 Main Environmental Concerns in project areas 20
2.6 Arsenic Contamination of drinking water in Project areas 20
3. Environmental Policies, Laws and Rules 21
3.1 Bangladesh Legal Framework 21
3.2 Environmental Guidelines for Projects in Bangladesh 21
3.3 Environmental Category for BRWSSP 25
3.4 International Obligations 25
3.6 Bank's Environmental Safeguards 27
3.6.1 Environmental Assessment and OP 4.01 28
3.6.2 Projects on International Waterways and OP 7.50 29
3.6.3 Environmental Management in Sub-projects 29
3.6.4 Environmental Screening 2930
3.6.5 Classification for EA and Procedures 30
4. Requirements on Environmental Clearance in Bangladesh 30
4.1 General Procedure for EA 30
4.2 Application for Environmental Clearance – Green Category 31
4.3 Application for Environmental Clearance –Amber B & A Category 3132
4.4 Application for Environmental Clearance – Red Category 32
4.5 Validity Periods for Environmental Clearance Certificates 33
5. Subproject Preparation, Approval and Monitoring 33
5.1 Subproject Document Preparation 33
5.2 Appraisal and Approval 34
5.3 Annual Reports 3637
5.4 Annual Reviews 3637
6. Environmental Management Plan 3738
6.1 Subproject Planning 3839
6.2 Water quality analysis and quality Assurance in analysis 3940
7. Consultation & Disclosure 4041
7.1 Community / Stakeholder Consultations 4041
7.2 Disclosure 4042
8. Project Coordination and Implementation 4142
8.1 Organizational Structure 4142
8.2 Responsibility Allocation Framework 4142
8.3 Grievance Redress 4243
9. Capacity Building and Training 4243
9.1 Institutional Capacity Assessment 4243
9.2 Capacity Building 4344
9.4 Resources for EM and Capacity Building 4647
10. Conclusions and Recommendations 4748
Annex I: Environmental Management Forms 4849
Annex-II: Arsenic Rich Sludge Disposal from Fe/Mn/As Removal Plants 5354
Annex-III: Bangladesh Drinking Water Quality Standards 5657
Annex-IV: Stakeholders’ Consultation and Disclosure 5859
Tables:
Table 1: Type of Subprojects that may be financed by the project
Table 2: Environmental Issues and Relevant Laws and Regulations in Bangladesh
Table 3: ECR Environmental Categories for projects and industries
Table 4: Subproject Environmental Categories in BRWSSP and WB guidelines
Table 5: Environmental Assessment and Management Framework
Table 6: Criteria for Requiring a Field Appraisal
Table 7: Type of subprojects and their environmental category
Table 8: Capacity Building Criteria for managing C and B Category Subprojects
Table 9: Outline of different Training Needs
Acronyms and Abbreviations
|BBS |Bangladesh Bureau of Statistics |
|BOD |Bio-Chemical Oxygen Demand |
|BP |Best Practice |
|BRWSSP |Bangladesh Rural Water Supply & Sanitation Project |
|BWSPP |Bangladesh Water Supply Program Project |
|BRWSSP |Bangladesh Rural Water Supply And Sanitation Project |
|CBO |Community Based Organization |
|COD |Chemical Oxygen Demand |
|CWASA |Chittagong Water Supply and Sewerage Authority |
|DPHE | Department of Public Health Engineering |
|DG |Director General, DOE |
|DOE/DoE |Department of Environment |
|DTL |D-Water Tech Ltd. |
|DW |Drinking Water |
|EA |Environmental Assessment/ Appraisal |
|ECA |Environmental Conservation Act of 1995 |
|ECC |Environmental Clearance Certificate |
|ECR |Environmental Conservation Rules of 1997 |
|EHS |Environmental Health and Safety |
|EIA |Environmental Impact Assessment |
|EMF | Environmental Management Framework |
|EMS |Environmental Management System |
|EMP |Environmental Management Plan |
|ES |Environmental Screening |
|ER |Environmental Review |
|GOB |Government of the People’s Republic of Bangladesh |
|GP |Good Practices |
|GRC |Grievance Redress Committee |
|ISDS |Integrated Safeguard Datasheet |
|ISO |International Organization of Standardization |
|IEE |Initial Environmental Examination |
|LEA |Limited Environmental Assessment |
|MICS |Multiple Indicator Cluster Survey |
|MLD |Million Litres Per Day |
|MOEF |Ministry of Environment and Forestry |
|MOLGRDC | Ministry of Local Govt. Rural Development & Cooperatives |
|NEMAP |National Environmental Management Action Plan |
|NOC |No objection Certificate |
|NGO |Non Government Organization |
|NTU |Nephelometric Turbidity Unit |
|NWP |National Water Policy |
|OHT |Over Head Tank |
|OP |Operational Policy |
|PMU |Project Management Unit |
|QAQC |Quality Assurance and Quality Control |
|RPWS |Rural Piped Water Supply |
|RPWSS |Rural Piped Water Supply Schemes |
|SCC | Site Clearance Certificate |
|UNICEF |United Nations International Children’s Emergency Fund |
|UP |Union Parishad |
|WB |World Bank |
|WSS |Water and Sanitation Sector |
Executive Summary
Project Background
The national rural water supply coverage in Bangladesh was estimated as 97.4% in 2009 which has been reduced to an estimated 86% after adjusting for arsenic contamination (MICS 2009). GOB with support from World Bank has decided to take up this Rural Water Supply and Sanitation Project (BRWSSP) to increase sustainable access to safe water supply and piloting on improved sanitation in the rural areas of Bangladesh in limited scale. DPHE has been chosen as the implementing agency for this project as it has successfully implemented earlier the Bangladesh Water Supply Program Project (BWSPP) on pilot Rural Piped Water Supply Schemes using Public-Private Partnership model and Community Managed Non-Piped Water Supply Systems with World Bank financing.
Project Description
The overall objective of the proposed project would be to increase the sustainable access to safe water supply and to explore improved sanitation in the rural areas of Bangladesh, focused on supporting the Government to mitigate the Arsenic & other water quality and quantity problems including pathogen contamination of drinking water sources. This objective is to be achieved by scaling up and promoting the rural piped water supply systems with local public-private partnerships in financing and operation; scaling up the provision of safe water (point) sources managed by community user groups and carrying out sanitation and hygiene promotion programs in line with the Bangladesh “Total Sanitation Campaign” to promote household hygiene and safe sanitary practices in targeted villages.
Under these interventions, BRWSSP has proposed to fund 125 Rural Piped Water Supply Schemes, 20,000 Non-piped Rural Water Supply Schemes and Rural Sanitation in 20 Union Parishads (UPs). The first two of these components would ensure sustainable access or safe drinking water primarily in water quality & quantity problem areas through the tested service delivery models including Public Private Partnership with private sponsors as well as community managed point source options. The other component will support the government to carry out sanitation and hygiene promotion programs in targeted UPs which will include Technical Assistance for Social Marketing, Social Mobilization and Business Capacity Building. More specifically, this will include building awareness of rural households to demand hygienic sanitation services where supplies will be made available in affordable prices. There is also another component to the project which will support towards developing regulatory and oversight framework for the service provision models as well as a knowledge base on water quality monitoring through technical assistance.
Purpose of the EMF
The project components proposed have environmental safeguard issues and this EMF documents provides a framework to address these issues. The projects components are to be designed and implemented by integrating the national policies, guidelines, codes of practice and procedures proposed in this EMF. The objectives are to ensure that the activities undertaken in the project:
▪ Enhance positive environmental outcomes;
▪ Prevent negative environmental impacts;
▪ Identify and mitigate with appropriate measures, the adverse impacts that might arise;
▪ Obtain Environmental Clearance form DOE; and
▪ Ensure compliance with the World Bank’s environmental safeguards policies.
Structure of EMF
The EMF document is structured in a sequential manner to assist the reader to understand the background of the preparation of the document, its purpose, objectives and its implementation during design, implementation and operational stages of the project.
Relevant Country Environmental Laws and Regulation
The present Policies, Acts, Rules & Regulations with respect to the Environmental issues in the country are under the custodianship of the Ministry of Environment and Forest (MOEF)/Department of Environment (DoE). However, there are also some sectoral laws dealing with different environmental issues in Bangladesh which were enacted at different periods but are largely obsolete now. The activities under the project are covered by the Policies, Acts, Rules & Regulations under ECA 95 and ECR 97.
World Bank's Environmental Safeguards
The main purposes of the Bank’s safeguard policies are to (i) avoid harm to the environment and affected people and provide affected people an opportunity to participate in the development process; (ii) improve project design and performance; and (iii) protect the reputation of the Bank. The current set of safeguard policies cover a broad range of topics from environmental assessment to natural habitats, forests, resettlement, and Indigenous Peoples and others. The policies are the reflection of international conventions and internationally accepted principles of good practice in project preparation and implementation. Similar principles, supporting the aspirations for sustainable development, are generally reflected in policies in Bangladesh like most developing countries; however, implementation is often weak and variable. Out of Bank’s safeguards policies only OP 4.01 related to environment is triggered in the Project. Considering the environmental impacts according to WB policy, the project has been classified in the B category. The legal policy OP 7.50 (i.e., Projects on International Waterways) is not triggered in this project.
The zones of impact of the tubewells involved in the sub-projects are expected to be less than 50 meters on the groundwater aquifers. So, in order to avoid any adverse impact on possible water use in neighboring countries, no tubewell will be located within 500 meters of the international boundary.
Requirements on Environmental Clearance for projects in Bangladesh
In Bangladesh, the EA procedure has three tiers which are; (i) Screening; (ii) Initial Environmental Examination (lEE); and (iii) Detailed EIA. The rural piped water supply subprojects in BRWSSP can be classified in the Orange-B category (ECA97, Schedule-1, item-28: Water Purification Plant), and need to obtain the clearance from the DOE in two stages i.e., (i) Initial Stage in which a Site Clearance Certificate (SCC) is obtained and (ii) an advanced Stage in which an Environmental Clearance Certificate (ECC) is obtained. Although, it is not clearly specified in the rules, DOE does provide clearance to EMF for projects with multiple sub-projects with small environmental footprints. The PMU will seek DOE clearance for the EMF, so that clearance for individual subprojects are not required..
Environmental Management Plan
In the context of a project, environmental management is concerned with the implementation of the measures necessary to minimize or offset adverse impacts and to enhance beneficial impacts. The EMP ensures that the mitigation and benefit enhancement measures identified in the EMF/LEA are fully implemented and a clear line of responsibilities for the purpose are assigned. It is expected that for most of the sub-projects, groundwater from arsenic free aquifer will be used. However, in cases where unavoidable, treatment plant to remove Arsenic and other harmful or aesthetic contaminants will be established. At the sub-project level, quality of water will be ensured through testing during feasibility studies and implementation (testing will include all relevant parameters notified in the GOB standards for drinking water that are expected to be exceeded). Although, the aim would be to avoid problematic sources, by exploring and tapping safe sources (by location), adequate arsenic removal plants/technologies and conventional water treatment will be used, wherever required. Adequate assessment will be undertaken to understand the aquifer thickness, hydraulic gradient and its recharge capacity prior to the installation of deep tube wells. Safe drilling techniques will be employed following the standard protocol being used by the DPHE. In cases where Arsenic laden sludge will be produced, adequate measures will be ensured for its proper disposal using approved protocols.
Community / Stakeholder Consultations
Community/stakeholder discussions are basic requirements in the OP4.01 for project preparation and implementation. As the basic principles require, inputs and feedbacks received from stakeholder consultations are the major determinants in the selection, location and design of the project and its implementation. Accordingly, a public consultation on the EMF was done with the participation of the stakeholders.
Disclosure
The PMU will disclose this EMF document on the DPHE website. The PMU will ensure that copies of the document are available at the project sites, DPHE local offices and DPHE Head Office in Dhaka, so that the document is accessible to the general public. The executive summary of the EMF in Bangla will also be made available alongside. The PMU will inform the public through a notification in two local newspapers (i.e. one Bangla and one English) about the stakeholders’ consultation on the EMF and the EMF accessibility.
Grievance Redress
The Project Management will establish a procedure to answer to project-related queries on environmental issues and address complaints and grievances about any irregularities in application of the guidelines adopted for assessment and mitigation of environmental safeguards impacts. The complaints related to project activities that may create inconveniences during construction should be addressed based on consensus, the procedure will help to resolve issues/conflicts amicably and quickly without resorting to expensive, time-consuming legal actions. For the purpose, a Grievance Redress Committee (GRC) will be formed by the PMU.
Capacity Building
For establishing a sound Environmental Management System (EMS), the PMU will ensure EMS as a valuable tool that provides a structure for strategic goal setting, improved decision making and efficient resource allocation across management priorities, balancing the management of operations throughout the value chain. The implementation of an EMS which minimizes negative and advance positive impacts on the environment is an achievable goal through implementation an environmental policy. The components of the EMS on capacity building will consist of human resource development as well as investment in environment infrastructures including resources for health and safety measures.
Monitoring, Reporting and Audit
The purpose of monitoring measures that will be undertaken are to ensure that the environmental concerns are addressed, environmental assets are protected and quality is enhanced through mitigation measures and these are monitored and reported in an efficient and effective manner. Yearly report on the project’s environmental performance should be submitted to the appropriate authorities and shared with the WB for review of the effectiveness of environmental management.
Conclusions and Recommendations
The proposed sub-projects under the BRWSSP will have mostly positive impacts on the beneficiaries and their environment. However environmental impacts (if any) can be managed if the procedures given in this EMF are followed, so that there are no harmful impacts on the local community. The EMF is a document which provides guidelines as to how the environmental safeguard issues can be addressed for the project. The project staff and other relevant persons should be trained so that they can fully implement the actions needed under the EMF. Provision for adequate funding has been made in the project’s operational budget for the purpose.
1. Introduction
1.1 Project Background
The national rural water supply coverage in Bangladesh was estimated as 97.4% according to the Multiple Indicator Cluster Survey (MICS) conducted by Bangladesh Bureau of Statistics and UNICEF (BBS/UNICEF, 2009). However, safe water coverage has been adjusted as 86% considering arsenic contamination according to MICS. Institutionally, the Department of Public Health Engineering (DPHE) under Ministry of Local Government, Rural Development and Cooperatives (MOLGRDC) is responsible for planning, designing and implementing water supply and sanitation services in rural and urban areas except city corporation areas of Dhaka, Chittagong and Khulna. DPHE has implemented different types of water supply systems in the country. These include both point source options and local piped water supply options. Recently DPHE has successfully implemented a number of pilot Rural Piped Water Supply Schemes using Public-Private Partnership model and Community Managed Non-Piped Water Supply Systems under the World Bank financed Bangladesh Water Supply Program Project (BWSPP). Based on the lessons learnt from BWSPP, World Bank and DPHE (i.e., on being designated by GOB) have decided to take up this follow on project, the Rural Water Supply and Sanitation Project (BRWSSP). The objective of the project is to increase sustainable access to safe water supply and piloting on improved sanitation in the rural areas of Bangladesh in limited extent, focused on supporting the Government in mitigating the deteriorating water quality arising from arsenic, pathogens, salinity and other causes.
1.2 Purpose of the Environmental Management Framework (EMF)
BRWSSP will entail implantation of water supply and sanitation sub-projects all over the country. The details of the subprojects are not known at the present time and these will be identified during project implementation. The sub-projects in the project will be be designed and implemented by integrating the general policies, guidelines, codes of practice and procedures proposed in this EMF.
All proposed requests for funding the sub-projects will be subject to environmental screening exercise in order to prevent execution of projects with significant negative environmental impacts; decrease potential negative impacts through adaptations in design, location or execution; prevent or mitigate negative cumulative impacts; enhance the positive impacts of subprojects; and prevent additional stress on environmentally sensitive areas. World Bank Operational Policy on Environmental Assessment (OP 4.01) is triggered for this project. In order to avoid potentially adverse environmental impacts, this policy will be used for assessing potential environmental problems and taking mitigation measures.
More specifically the objectives of this EMF are:
• To establish clear procedures and methodologies for the environmental review, approval and implementation of subprojects to be financed under the Project;
• To specify appropriate roles and responsibilities, and outline the necessary reporting procedures, for managing and monitoring environmental concerns related to subprojects;
• To determine the training, capacity building and technical assistance needed to successfully implement the provisions of the EMF;
• To establish the areas for project funding requirements to implement the EMF requirements; and
• To provide practical resources for implementing the EMF.
The implementation of EMF will help to ensure that activities under the proposed project will:
• Protect human health;
• Enhance positive environmental outcomes; and
• Prevent negative environmental impacts as a result of either individual subproject or their cumulative effects.
1.3 Structure of EMF
The EMF document is structured in a sequential manner to assist the reader to understand the background of the preparation of the document, purpose, objectives and its implementation during design, implementation and monitoring stages of any sub-project under the project. The chapters are appropriately labeled so as to provide information on the coverage.
2. Project Description
2.1 Objectives of the Project
The overall objective of the proposed project would be to increase the sustainable access to safe water supply and improved sanitation in the rural areas of Bangladesh, focused on supporting the Government to mitigate the arsenic & other water quality and quantity problems including pathogen contamination of drinking water sources. This objective is to be achieved by:
• Scaling up and promoting the rural piped water supply systems with local public-private partnerships in financing and operation;
• Scaling up the provision of safe water (point) sources managed by community user groups;
• Carrying out sanitation and hygiene promotion programs in targeted villages in line with the Bangladesh “Total Sanitation Campaign” to promote household hygiene and safe sanitary practices, and the provision of sanitation facility in target villages;
• Supporting the development of a natural disaster WSS response mechanism (Institutional setups, response arrangements, funding mechanisms, etc) for expeditious intervention in the event of natural disasters; and
• Supporting the development of adequate regulations and monitoring of groundwater, characterization of aquifer, and relevant environmental studies.
2.2 Components of the Project
BRWSSP has proposed four major investment components: (1) Rural Piped Water Supply Schemes; (2) Non-piped Rural Water Supply Schemes; (3) Rural Sanitation and (4) Regulatory and Oversight Framework for Service Provision, including Water Monitoring. First two of these components would ensure sustainable access to safe drinking water primarily in the water quality & service coverage problem areas through the tested service delivery models including Public Private Partnership with private sponsors as well as community managed water supply options. One component will support the government to carry out sanitation and hygiene promotion programs in targeted villages in line with the Bangladesh ‘Sanitation Campaign’ while another component will support towards developing regulatory and oversight framework for the service provision models as well as a knowledge base on water quality monitoring through technical assistance.
2.3 Anticipated Subproject Types
A list of subprojects that may be financed by the project is given in Table 1. This list provides general information to the local communities/ private agencies on the generic type of subprojects that may be implemented under the project. Such subprojects should be judged on merit and will be financed if they have manageable environmental dimensions within the framework.
Table 1: Type of Subprojects that may be financed by the project
|Rural Piped Water Supply Schemes (RPWSS) |
| Implementation of 125 rural piped water supply schemes. |
|Major Components in each RPWS : |
|Test Tube Wells ( 2 units) |
|Production Wells ( 2 units) |
|Pump House cum Office Room |
|Treatment Plant (if required) |
|Water Reservoir (OHT) |
|Distribution Network |
|House Connection |
|Electro- Mechanical Works (Pumps, Motors etc) |
|Non-piped Rural Water Supply Schemes |
|14,000 Point Water Sources (Contributory fund from users) |
|6,000 Point Water sources ( Emergency meet up- no contributory fund) |
| Rural Sanitation |
|Sanitation in 20 UPs in the rural piped water supply schemes areas |
| 4. Regulatory and Oversight Framework and Water Monitoring |
2.4 Project Target Areas
As the project is expected to cover all parts of the country where water quality (including Arsenic contamination) is an issue in phases, it is necessary to keep in mind the general variation in the environmental conditions expected in different parts of the country. A brief description of the important environmental resources and environmental issues are given in this section.
2.4.1 Physiography and Land-use Pattern
Bangladesh is located between 20O34´ and 26O38´ N, and 88O01´ and 92O41´ E. The area of the country is 147,570 square km with a coast line of about 700 km in length. The land is flat to the extent of about 80% intersected by numerous rivers and their distributaries. The land area has a general slope of 1O-2O (5-10cm/km) from north to south. The soils in the flat areas mostly (~80%) consist of recent alluvium. The rest 20% of the area consists of uplands (~8%) and hill areas (~12%). The uplands consist of Barind Tract in the north western part, Madhupur Tract in the central part and the Lalmai Hills in the east. The upland soils are derived from old Pleistocene sediments and are typically reddish or brownish in color. The hill areas consist of Chittagong Hill Tracts, hill ranges of northeastern Sylhet and hills along the narrow strip of Sylhet and Mymensingh Districts. The hill soils are derived from tertiary rocks, unconsolidated tertiary and Pleistocene sediments. Most of the land is used for agriculture. Land use is generally classified into five categories as agricultural, forest, cultivable, waste or current fallow and as ‘not available for cultivation’. The category of ‘not available for cultivation’ consists of mainly of urban, rural settlements and industrial land. Different regions in the country are different in respect of Physiography and Land-use pattern. Such differences would be recognized in subproject planning.
2.4.2 Hydrology
Bangladesh is the largest delta in the world formed by the Ganges, the Brahmaputra, and the Meghna river systems. This delta is characterized by flat terrain interlaced with the intricate system of rivers and tidal channels, which carry an enormous quantity of sediment-laden water downstream. The three major rivers have a huge catchment area of 1,554,000 sq km, spreading, over five countries, namely, Bhutan, Nepal, China, India, and Bangladesh. There are about 700 rivers, canals, and streams in Bangladesh, with a total length of approximately 22,155 km, which occupy a riverine area of about 9,384 sq km.
The main river system occupying the delta is formed by the Ganges and the Brahmaputra, which are known as the Padma and the Jamuna, respectively once they enter Bangladesh. The Jamuna joins the Padma near Aricha, and flows up to Chandpur where it joins the Meghna and the combined flow is called the Meghna. It comprises a large estuary, known as the Meghna estuary, at the northeastern apex of the Bay of Bengal. The Ganges, primarily a meandering stream, is about 2,600 km long, and flows parallel to the Himalayan range. It is fed mainly by rivers rising in the southern slopes of the Himalayas and enters Bangladesh at the western extremity of Rajshahi region. The Brahmaputra arises in Tibet, and flows in an easterly direction north of the Himalayan range before turning south through the mountains, it then flows west down the Assam valley for a distance of about 700 km, and enters Bangladesh as a wide-braided river, in the Rangpur area. The meandering Meghna river drains the Sylhet Basin and parts of the adjacent Shillong Plateau, and Tripura Hills.
The rivers flowing from the hills situated in the southeast of Bangladesh, namely Feni, Karnaphuli, Sangu, Matamuhuri and Knaaf flow into the Bay of Bengal. The most important river in this region is the Karnaphuli, which is also the longest at 274 km.
A vast amount of water (1,106 km3)[1] flows through Bangladesh mostly during June-October. The rivers of Bangladesh also carry huge amounts of sediment, an estimated 24 billion tons/year. These sediments are subjected to coastal dynamic processes generated mainly by river flow, tide, and wind actions. The ultimate result are additional new land in some places due to accretion, forming islands called chars, and loss of land in some other places due to erosion. Bangladesh is also richly endowed with numerous perennial and seasonal water-bodies known locally as haors, beels, baors, khals, pukurs and dighies. Rivers, canals, beels, lakes, and haors are open wetlands while baors, dighis, ponds, and ditches constitute closed ones. The haors are depressions located between two or more rivers, and function as small internal drainage basins. The lowest points of the haors and beels are lake-like deep depressions retaining water permanently or for a greater part of the year. The beels are usually connected to the adjacent rivers by one or more drainage channels, locally termed as khals. Baors are oxbow lakes from the old meandering bends of rivers that have been cut off from the main stream. Pukurs and dighies refer to ponds of various sizes. To these may be added the vast estuarine systems and mangrove swamps of the south and southeast regions, as well as innumerable man-made water bodies of various sizes. Hydrology of a given area is extremely important for any subproject which may have impact up on water bodies. Impact on water flow by any subproject would be carefully considered in subproject planning. The quality of water is also an important factor in subproject planning.
2.4.3 Ground Water
Below the zone of aeration extending from surface to only a few meters below the ground, the soil in Bangladesh is saturated with water. Saturation means that all pore spaces in the soil are filled with water and this zone is defined by a groundwater table. However, in substantial part of the country the water table goes beyond the limit of suction pump (27 ft) particularly in dry season when the irrigation pumps operate in full swing. Bangladesh soils consist of unconsolidated sediments and the pore spaces are simply the openings between the grains. Lithologic drill logs show layers of gravel, sands of different grades, silt and clay down to great depths in succession.
Hydrogeologists classify soil layers as to their ability to yield water to wells or springs. A layer which is permeable enough to supply water to wells or springs is referred to as an "Aquifer", while an “Aquiclude” is impermeable and an “Aquitard” tends to be very poorly permeable. The aquifers are sand or gravel layers that may be a few centimeters to many meters’ thick. Like other similar areas in the world, the sand intervals which constitute the aquifers are probably lens-shaped with varying degree of lateral and vertical interconnectedness. This interconnectedness usually decreases with depth. The extent of the aquifers may vary from a few km2 to many thousands of km2. So, a large aquifer may easily contain a trillion liters or even more water. Even a small aquifer would probably contain a couple of billion liters.
An aquifer is referred to as confined when it is bounded by aquicludes or aquitards that impede flow into it. The primary source of recharge to the aquifers is assumed to be historic runoff from the rainfalls. Groundwater is in principle renewable but in certain cases the period needed for replenishment (100s to 1000s of years) is very long in relation to the normal time-frame of human activity. For this reason, it is valid in such cases to talk of the utilization of non-renewable groundwater or the ‘mining of aquifer reserves’. Water in the confined aquifers can be literally thousands of years old. This is the reason for concern about the aquifer systems and their specific susceptibilities to negative impacts under abstraction stress. For water balance studies three and four aquifer models have been shown to be adequate. However, in reality in many regions of Bangladesh more aquifers can be found stacked on top of one another where from water can be extracted. The hydrogeology of Bangladesh area has been studied for more than fifty years and the details are available elsewhere (Kinniburgh and Smedley, 2001).
Groundwater is a vital natural resource for the reliable and economic provision of potable water supply in both the urban and rural environment. It thus plays a fundamental role in human well-being. Until the emergence of the Arsenic problem, groundwater was hailed for providing the access to clean drinking water in Bangladesh. It is necessary to exercise caution in the large scale exploitation of confined deep aquifers, as these may be depleted giving rise serious problems in the future. As Arsenic contamination is quite extensive for aquifers in some areas, it is essential to test shallow tubewells for drinking water to ensure that Arsenic level in the water is below the national standard. In general deeper aquifers have lesser probability of arsenic contamination. However, the depths having arsenic free aquifers vary depending on the area. So, it is necessary to check the Arsenic content in the aquifer before a production well is established. In case of BRWSSP arsenic contaminated aquifer will be avoided as far as possible. In case source water without Arsenic is unavailable in a given area, the water will be treated for Arsenic removal to comply with the Bangladesh drinking water standard. The details on Arsenic related issues are given in Annex-II.
Two types of tubewells namely hand tubewells and mechanized tubewells will be used in the project as water sources. In the case of hand tubewells, water withdrawn is typically a few thousand liters per day and such extraction can be considered as insignificant perturbation unlikely to have any impact on the aquifer. In the case of mechanized tubewells for piped water supply, the water production is unlikely to exceed 500,000 liters per day. Even such production is small compared to aquifer capacity to impact the water quality of aquifers. However, there are concerns that in case of deep aquifers there may be drawdown of Arsenic contaminated water from shallow aquifers. To alleviate such concerns, DPHE has developed sealing procedure to isolate shallow and deep aquifers for production wells. It may be noted that such drawdown is highly unlikely as deeper aquifers have higher pressure and pumping rate is rather small to have impact on this pressure.
2.4.4 Ecology
The terrestrial and aquatic ecosystems in the country support a large number of diverse biological populations, both plant and animal. The most important terrestrial ecosystem in Bangladesh is that of the forests. Large varieties of species exist in the forest areas and depend on various biotic and abiotic components of the forest for their survival. The total land under forest in Bangladesh is about 2.56 million ha, which includes officially classified and unclassified state lands, and forestlands accounted for by village forests and tea or rubber gardens. Although a significant part of the existing forest area is designated as State Forest, most of this land is actually barren of tree vegetation. In terms of per capita forestland, Bangladesh ranks amongst the lowest in the world. The forests of Bangladesh have been disappearing at an accelerating rate.
The Sundarban forest areas support a very rich and diverse fauna and flora. These are: mammals (49), reptiles (87), birds (355), amphibians (14), fishes (237), crustaceans (38), mollusks (34), insects (240) and over 220 species of plants. It is an important staging and wintering area for migratory shore birds, gulls, and terns. The Sundarbans are the habitat of the Bengal Tiger probably the most notable of Bangladesh's fauna species. However, many small members of the cat family are found throughout the forest areas.
Wetlands are invaluable components of the environment and bio-diversity in Bangladesh. Bangladesh possesses considerable wetland areas, among which the principal ones are rivers and streams, freshwater lakes and marshes, including haors, baors, and beels, water storage reservoirs, fish ponds, flooded cultivated fields, and estuarine systems with extensive mangrove swamps. The coastal and inland wetlands encompass the vast floodplains and delta system of the Ganges, Meghna and Brahmaputra rivers. The total area of the wetlands in the country has been variously estimated at seven to eight million hectares, or about 50 per cent of the total land surface. The wetlands in Bangladesh are increasingly being recognized as habitat and refuge for a large variety of wildlife, and a safe nesting site for avifauna. The marsh vegetation associated with wetlands also forms important breeding areas for a wide variety of waterfowl, and roosting places for a large number of resident and migratory birds.
The nutrient products of wetlands in Bangladesh are carried by rivers and floodwater, and benefit the systems downstream. The grazing systems in these regions support cattle that recycle nutrients, enrich soil, and are used as draft animals. The plant diversity provides refuge for predators of pests, e.g., snakes, frogs, and certain fish species, and this helps agriculture in general. Bangladesh does not possess adequate infrastructure for sewage treatment and the wetlands function as natural system for the treatment of pollutants. The wetlands of Bangladesh are being drastically affected by the impacts of the increasing human population. The wetlands are being lost to flood control, drainage and irrigation development. Severe erosion in the catchment areas is causing increased siltation, and having major impacts on the key wetland areas. The exploitation of the haor wetland ecosystem began due to ever-expanding agrarian settlements, and they are being reclaimed as agricultural land for production of rice. The beels are being drained, and embankments built to save crops from flash floods. These changes in land use patterns have occurred in tandem with a decline in fish and migratory birds. Swamp forests that were once extensively distributed are now on the verge of extermination. As the projects area covers all of the country, some sub-projects/schemes are likely to be located in the forest and wetland areas. As subprojects are small, likely impacts of these on the ecology are expected to be small. However, impact minimization on ecology would be a cornerstone in subproject design. In case environmental assessment shows any significant environmental impacts in any proposed scheme, such schemes will not be funded under the project.
2.4.5 Environmentally and Ecologically Sensitive Areas
Environmentally sensitive areas are defined as being areas that are of significant value in their natural state, or areas that are of socio-cultural significance or sensitivity. Cultural or historical sites and densely populated urban centers are examples of the latter category. Ecologically Sensitive Areas can be defined as areas that may contain unique features, maintain key natural processes, support endangered, endemic or threatened plants or animals and their habitats, or provide important breeding areas for wildlife. Some Ecologically Sensitive Areas are natural, while others may have been significantly altered by certain human activities. In terms of management, some Ecologically Sensitive Areas will prosper when left undisturbed while others will require intensive management to restore or maintain their natural values.
The ECA 1995 refer to Environmentally Sensitive Areas as Ecologically Critical Areas. According to this legislation, environmental protection is deemed particularly relevant in Ecologically Critical Areas, which are defined as areas where degradation of the environment has reached or threatens to reach a critical state. In the sensitive areas, environmental and ecological impacts tend to be more severe than elsewhere, and therefore, extra precautions must be taken to avoid significant environmental impacts. In many cases, this will mean extra investments in mitigation measures, while in some cases these areas will simply have to be avoided, resulting, for example, in the abandonment of a subproject or the re-alignment of a section of road.
2.5 Main Environmental Concerns in project areas
The key environmental concern in the present project is the Arsenic contamination in the groundwater which will be taken up in the next section. The other environmental concerns for rural and small urban and peri-urban areas in Bangladesh include:
• Flooding
• Drainage
• River bank erosion
• Surface water quality
• Seasonal fluctuations in ground water table
• Groundwater quality
• Saline intrusion (coastal areas)
• Wetland deterioration
• Land degradation
• Ambient Air Pollution
• Indoor Air Pollution
• Forestry management
• Biodiversity conservation
• Fish and fisheries resource management
2.6 Arsenic Contamination of drinking water in Project areas
As this is an issue of important public health concern, it is discussed separately here. In case, where existing tubewell are mostly arsenic contaminated, arsenic mitigation option such as deep tubewell, ring well, pond sand filter will be explored first. In this case, arsenic treatment will not be required. However, as a last assort, if removal of arsenic is required, the water will be treated for Arsenic removal to comply with the Bangladesh drinking water standards. Removal of Arsenic from contaminated groundwater to the level less than the current Bangladesh standard of 0.05 mg/L can be achieved using proven methods and technologies. A whole plethora of treatment options are available such as conventional treatment (coagulation, co-precipitation with Fe/Mn, and softening), sorption processes (activated alumina, ion exchange, iron-oxide-coated sands) and membrane processes (nano-filtration, reverse osmosis, ultra-filtration, micro-filtration). Pre-oxidation of arsenite to arsenate has been found to be helpful in most of the processes.
The conventional Fe/Mn removal plants also remove As and this method is most likely to be used as there is a considerable body of local experience on this type of plants in Bangladesh, this process also removes Arsenic is most likely to be used here and it is highly cost effective. In the process of removal of iron and manganese, arsenic is also removed as it binds to Fe. If the naturally occurring amount of iron and manganese is not enough to get the desired arsenic removal, more iron may be added but this will be probably unnecessary in Bangladesh as ground water in Arsenic contaminated areas also have high iron content. Pre-oxidation using aeration is the common method convert arsenite to the more perceptible arsenate form but other methods such as potassium permanganate or hydrogen peroxide may also be used. Sludge from As removal process can also be an issue but can be handled safely if appropriate procedure is used. The details on Arsenic related issues are given in Annex-II.
3. Environmental Policies, Laws and Rules
This section describes relevant national environmental management requirements and as well as the World Bank safeguards policies applicable to the Project and its subprojects. In each case, national and local institutions that will be involved in reviewing and approving subprojects identified, along with their respective roles and responsibilities. Responsibilities may include issuing approvals for undertaking a subproject and ensuring compliance to obligatory requirements under laws and regulations.
As stated earlier, the World Bank EA category assigned to the Project is B A brief description of the relevant World Bank safeguard policy is provided to explain how their requirements will be complied with or used.
3.1 Bangladesh Legal Framework
The requirements for compliance with environmental regulations are laid down by the policy, legal and regulatory framework in the country. A large number of laws related to environmental issues, some dating back to 19th century exist in Bangladesh. The most important of these are the Environment Conservation Act, 1995 (ECA95) and the Environment Conservation Rules (under the ECA, 1995), 1997(ECR97). Many of the other laws are cross-sectoral and are only partially related to environmental issues. Most of the old legislations have become largely obsolete also with the promulgation of ECA95 and ECR97. The relevant laws and regulations related to important environmental issues in Bangladesh are shown in table 2.
3.2 Environmental Guidelines for Projects in Bangladesh
As pointed out earlier the most important of the laws/rules in table 2, are the ECA95 and the ECR97. The ECA95 is primarily an instrument for the Department of Environment (DOE) and for controlling industrial pollution. The Act also includes ‘Polluter Pay Principle’ in general terms in that as it states "if any particular activity is causing damage to the eco-system, the responsible party will have to apply corrective measures". The ECR97 was promulgated under ECA 95 to operationalize the enforcement of the Act. The modifications to ECR can be brought about by executive orders requiring no new legislation. Thus, the rules can be modified from time to time when sound technical reasons exist without going through the long drawn legislative process.
Table 2: Environmental Issues and Relevant Laws and Regulations in Bangladesh
|Issues |Laws/Regulations |Enforcing Agency |Regulated/Enforced Items |
|Water pollution |ECA, 1995 |MOEF/DOE |Promulgation of standards for water quality |
| |ECR 1997 |,, |Promulgation of discharge limits |
| |Environmental Court Act, 2000 |,, |Prosecution of offenders |
| |The Local Government Ordinance, 1983 |,, |Control of Environmental sanitation in rural |
| | |UPs |areas |
|Air pollution |ECA, 1995 |MOEF/DOE |Promulgation of standards for air quality |
| |ECR 1997 (amended 2005) |,, |Promulgation of emission standards for Motor |
| |Environmental Court Act, 2000 |,, |vehicles and industries |
| |Brick Burning Control Act, 1989 |,, |Prosecution of offenders |
| |(Amended 1992) |,, | |
| |Motor Vehicle Act, 1983 | |Prosecution of offending vehicles |
| | |BRTA/Police | |
|Noise pollution |ECA, 1995 |MOEF/DOE |Promulgation of standards for noise levels |
| |ECR 1997 |,, | |
|Toxic or hazardous |ECA, 1995 |MOEF/DOE |Promulgation of standards and management rules. |
|waste pollution |ECR 1997 |,, | |
|Solid waste pollution |Nuclear Safety and Radiation Protection | |Promulgation of standards and rules for |
| |Ordinance, 2000 |BAEC |management of radioactive materials. |
|Marine pollution |ECA, 1995 |MOEF/DOE |Promulgation of standards for water quality |
| |ECR 1997 | |Promulgation of discharge limits |
| |Environmental Court Act, 2000 |,, |Prosecution of offenders |
|Pollution of fisheries|The Protection and Conservation of Fish |MOLF |Promulgation of regulatory measures |
| |Act, 1950 | | |
|Pesticides and |The Agricultural Pesticides Ordinance, |DA |Approval of permissible pesticides |
|fertilizers |1971 | | |
|Forest conservation |ECA, 1995 |MOEF/DOE |Declaration of Ecologically Critical Areas |
| |ECR 1997 |,, |Reserve Forest, protected Forest, Village Forest|
| |The Forest Act 1927 | | |
| | |MOEF/DOF | |
|Wildlife conservation |ECA, 1995 |MOEF/DOE |Declaration of Ecologically Critical Areas |
|and national parks |ECR 1997 | | |
| |The Wild Life (Preservation) (Amendment) |,, | |
| |Act, 1974 | | |
Depending on the extent of impact on the environment, industries and projects are classified in four different categories under the ECR 1997. The four categories are: Green, Orange A, Orange B and Red. The procedures for obtaining ‘Environmental Clearance (EC)’ for different categories of projects are also provided in the ECR. Green category industries are to be granted EC within 15 days. The Green Category Schedule does not list specific projects. For other categories, schedules containing lists of industries and projects are provided in the ECR. For Orange A & B and Red category of industries and projects, an application for EC must include a ‘Feasibility Report (FR)’ and an ‘Initial Environmental Examination (IEE)’ report. A Process Flow Diagram and a Layout Plan are also needed for industries. IEE report must include a ‘Terms of Reference’ for the Environmental Impact Assessment (EIA) for Red Category industries and projects. An EIA report is mandatory for final approval and issuing of an ‘Environmental Clearance’ for Red Category industries and projects. The ECR, 1997 lists the contents required for both IEE and EIA reports. Table 3 lists project types included in the ECR and categories. Although, it is not clearly specified in the rules, DOE does provide clearance to EMF for projects with multiple sub-projects having small environmental footprints.
Table 3: ECR Environmental Categories for projects and industries*
|Category |Sub-projects/ |Clearance |WB project |Comments |
| |Industries |Requirements |Category | |
|Green |No Projects Listed in |None |C |Only local authority clearance needed |
| |the ECR (Only | | |Many BRWSSP subprojects (point sources and |
| |Industries) | | |household sanitation units) will in this category|
| | | | |and should not require any environmental |
| | | | |clearance from DOE. |
|Orange A |Small-scale industries |IEE, Feasibility |B |Although small scale piped water supply is not |
| | |Report | |listed under this category, Considering the |
| | | | |impacts, the BRWSSP subprojects are likely to |
| | | | |fall in this category. |
|Orange B |Medium Scale industries|IEE, Feasibility |B |BRWSSP subprojects can be classified in this |
| | |Report | |category also as water purification plants fall |
| | | | |under this category (i.e., Sl. 28 of the list). |
|Red |Water Treatment Plant |IEE, Feasibility |A/B |This is a category for large scale water |
| | |Report, EIA | |treatment plant and BRWSSP subprojects are not |
| | | | |expected in this category |
* Full list available in schedule-1 of ECR97.
3.3 Environmental Category for BRWSSP
In keeping the historical precedence in the country, the BRWSSP subprojects are to be classified into 3 categories as shown in table 4.
‘C’ those whose expected impacts are small in scale, do not require special study other than ER, and can be addressed through standardized environmental techniques or technical methods. ER in these cases should be performed using a screening list. The point sources are likely to fall in this category.
‘B’ those whose impacts are larger and more complex, requiring preparation of a Limited Environmental Assessment (LEA) and incorporation of recommended mitigation measures into subproject design. The piped water supply schemes are likely fall in this category.
‘A’ those whose potential impacts involve significant environmental risk, and these will not receive funding under the BRWSSP.
Table 4: Subproject Environmental Categories in BRWSSP and WB guidelines
|Category Attributes |GOB category |World Bank category |EA Process |
|Subprojects likely to have some minor impacts |Green |C |Environmental Review (ER) by |
|on the environment but for which sufficient | | |proponent and clearance by PMU. |
|standard mitigation measures have been | | | |
|identified | | | |
|Subprojects that have some moderately |Orange A&B, Red |B |ER by the proponent, Limited |
|significant environmental impacts, for which | | |Environmental Assessment (LEA) by |
|mitigation measures can be readily identified | | |qualified individuals and clearance |
| | | |by PMU once EMF is cleared by DOE. |
|Subprojects that potentially have significant | Red |A |Subprojects in this category will NOT|
|impacts on the environment; (mitigation | | |be eligible for BRWSSP funding |
|measures may be identified, but there remains | | | |
|a risk of significant impacts) | | | |
3.4 International Obligations
Bangladesh is party to a number of international environmental conventions, treaties and protocols. These have to be taken into account in the implementation of BRWSSP subprojects where applicable. In the implementation stage of the project, NGOs and Citizens Groups may invoke these agreements if they have concerns on infringements.
These agreements are summarized for in the following:
4. International Plant Protection Convention, Rome, 1951 (Ratified 1978)
5. International Convention for the Prevention of Pollution of the Sea by Oil, London, 1954 (Ratified 1981)
6. Convention on Wetlands of International Importance, especially as Waterfowl Habitat, Ramsar, 1971 (Ramsar Convention) (Ratified 1992)
7. Convention Concerning the Protection of the World Cultural and Natural Heritage, Paris, 1972 (World Heritage Convention) (Ratified 1983)
8. Convention on International Trade in Endangered Species of Wild Fauna and Flora, Washington, 1973 (CITES Convention) (Ratified 1982)
9. Agreement on the network of Aquaculture Centers in Asia and Pacific (NACA), 1988
10. Montreal Protocol on Substances that Deplete the Ozone Layer, Montreal, 1987 (Ratified 1990), (London Amendment, 1990) (Ratified 1994)
11. Convention on Biological Diversity, Rio de Janeiro, 1992 (Ratified 1994).
12. International Convention to Combat Desertification, 1994.
13. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, Basel, 1989 (Ratified 1993)
14. United Nations Framework Convention on Climate Change, New York, 1992 (Ratified, 1994)
3.5 Bank's Environmental guidelines
The World Bank has mandatory EA guidelines in the form of OP/BP/GPs. The World Bank has several policies governing environmental assessment (EA) of projects. OP/BP/GP 4.01, issued in January 1999, is the central document that defines the Bank's environmental assessment requirements. This directive outlines Bank policy and procedures for the environmental assessment of Bank lending operations. Environmental consequences should be recognized early in the project cycle and taken into account in project selection, sitting, planning, and design by preventing, minimizing, mitigating or compensating for adverse environmental impacts and enhancing positive impacts. EA includes the process of mitigating and managing environmental impacts throughout project implementation. The Environmental Assessment Sourcebook (1993) and its updates (1996, 1997) provide technical guidance on these issues.
In addition to OP/BP/GP 4.01, there are other directives that cover a number of specific environmental issues which may be optionally used in this project. These are OP 4.04 (Conservation of Natural Habitats), OP 4.09 (Pest Management),OP 4.36(Forestry Management) and OP 7.50 (Projects on International Waterways). As the project area covers the whole of country, there is likelihood that these policies may be applicable to a scheme. Such a scheme will not be implemented in the BRWSSP.
A screening process for all World Bank projects classifies them into one of three environmental assessment categories. Projects in Category "A" potentially cause significant and irremediable environmental impacts. Category "B" projects cause lesser impacts, which are often essentially remediable or can be mitigated. Category "C" projects can be expected to have little or no environmental impact. Category A projects require a full, detailed Environmental Impact Assessment, which needs to be approved before the Bank can give its support. Category B projects require the implementation of an Limited Environmental Assessment (LEA, which requires far less details than an EIA. Category C projects do not require an LEA or EIA.
The BRWSSP has been classified as Category "B" because as a whole, as it may result in only small-scale, and remediable impacts. In practice, most subprojects/schemes (i.e., point sources) are likely to be belonging to Category C. In some cases (i.e., RPWSS) subprojects will fall under Category B, and subprojects that fall under Category A will not be eligible for funding under BRWSSP. The equivalence of Bank guideline categories and those of BRWSSP are shown in table 4.
The present EMF deals with project specific application of Bank polices outlined above. The draft EMF has now been disclosed in country and is now available on the DPHE website (.bd) along with translation of the executive summary in Bangla. It will be disclosed in the Bank’s Info Shop as per World Bank’s Disclosure Policy prior to appraisal.
3.6 Bank's Environmental Safeguards
The main purposes of the Bank’s safeguard policies are to (i) avoid harm to the environment and affected people and provide affected people an opportunity to participate in the development process; (ii) improve project design and performance; and (iii) protect the reputation of the Bank. The current set of safeguard policies cover a broad range of topics from environmental assessment to natural habitats, forests, resettlement, and Indigenous Peoples and others. The policies are the reflection of international conventions and internationally accepted principles of good practice in project preparation and implementation. Similar principles, supporting the aspirations for sustainable development, are generally reflected in policies in most client countries; however, implementation is often weak and variable.
From the preliminary review of project activities, it has been determined that the Environmental Assessment (OP/BP 4.01) Policy will be triggered by the proposed project due to its focus on construction and extension of water supply and household sanitation systems. This Environmental Management Framework (EMF) has been prepared to identify and assess the potential impacts under different components of the proposed project. Each sub-project/scheme in the components has to be screened individually for potential environmental impacts through ER initially, and will be subjected to appropriate Limited Environmental Assessment (LEA). As appropriate detailed design of the project components for carrying out component specific LEAs will be available during project implementation only, the system to support the process of environmental review and clearance is defined through this Environmental Management Framework (EMF). As OP 4.01 is triggered and the possibility of triggering OP 7.50 was considered in the project, these are discussed in some details in following sections.
3.6.1 Environmental Assessment and OP 4.01
The World Bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making. EA is a process whose breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, sitting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation.
The investments pertaining to improving water and sanitation are likely to cause minor and reversible environmental impacts, which can be managed through appropriate mitigation measures. Considering the nature and magnitude of potential environmental impacts from relatively limited scale and magnitude of reconstruction works, the project is classified as category ‘B’ on an overall basis. As the exact nature and location of these investments are not yet fully known at the time of project preparation, this EMF is presented as the safeguard document, adherence to which will mitigate the environmental risks. This includes environmental procedures and requirements. This EMF includes procedures for ensuring compliance to legislations on environmental requirements to be adhered to during the construction and also in the monitoring & reporting arrangements.
At project level, the impact of the project on groundwater resources can be assessed by the number of tubewells currently operated in the country which consists of about 1.33 million[2] mechanized tubewells and 8.61million hand tubewells. Only about 250 mechanized tubewells and 20,000 hand tubewells will be involved in BRWSSP, which is miniscule compared to current activities in the groundwater sector in this country. The amount of water involved in the project is only a very small addition to the current rate of abstraction to have any significant impact. However, if it is considered that the project is replacing contaminated water supplies with piped and clean water, there should be no impact at all.
3.6.2 Projects on International Waterways and OP 7.50
Triggering of OP 7.50 was considered in the project.
The project is groundwater based and does not involve or has any impact on International or any other Waterways. Current activities in the groundwater sector both in Bangladesh and India are thousands of times larger and these activities have not impacted waterways in any significant way over the period of several decades. The zones of impact of the tubewells involved in the sub-projects are expected to be less that 50 meters on the groundwater aquifers. So, in order to avoid any adverse impact on possible water use in neighboring countries, no tubewells will be located within 500 meters of the international boundary. Thus, it is assessed that this policy should not be triggered in the project.
3.6.3 Environmental Management in Sub-projects
Once the project goes into implementation, the DPHE and its partners that will implement the subprojects on the ground, will be required to prepare and implement the activities according to the stipulations adopted in this EMF. The PIC is likely to be supported by services of environment specialists to screen the individual subprojects and, if required, prepare and implement the impact mitigation plans. Responsibility for conducting an EA that meets the requirements of the DOE and World Bank will rest with the PMU in DPHE. The Bank team will review EA related documents periodically.
3.6.4 Environmental Screening
Screening is necessary to decide whether or not a particular investment should be undertaken from an environmental perspective and classify the sub-project according to regulatory requirements both national and Bank guidelines. The extent of environmental work that might be required prior to the commencement of the sub-projects will depend on the outcome of the screening process described below.
The PIC is responsible for the screening of each sub-project under the project. PIC will carry out the screening by completing the Environmental and Social Screening Form developed (by consultant under PMU) for the purpose. Completion of this screening form will facilitate the identification of potential environmental and social impacts, determination of their significance, assignment of the appropriate environmental category, proposal of appropriate environmental mitigation measures, or recommend the execution of a Limited Environmental Assessment (LEA), if necessary.
3.6.5 Classification for EA and Procedures
Once the environmental screening is done, the subprojects can be categorized according to both Bangladesh and WB requirements. There are prescribed procedures for processing different category projects in the Bangladesh law and rules as given in table 4. In addition to that, WB requirements over and above the prescribed procedure in the Bangladesh law will also need to be followed. In Bangladesh, the Department of the Environment (DOE) is the authority responsible for providing environmental clearances. The effectiveness of this process is still constrained due to a lack of transparency and consultation, as well as the rather limited resources of the DOE. However, in the current project, the subprojects are expected to have only limited environmental footprint as such the PMU will approach the DOE for the approval of this EMF rather than IEE/EIA for individual subprojects. It may be noted that there are instances in which DOE has provided umbrella clearance to EMF type documents.
4. Requirements on Environmental Clearance in Bangladesh
4.1 General Procedure for EA
In Bangladesh the EA procedure has three tiers which are:
▪ Screening;
▪ Initial Environmental Examination (lEE); and
▪ Detailed EIA
Screening as explained earlier decides whether the EIA process should be applied to a development project and if it is required, it’s type i.e. IEE &/or EIA or limited EIA.
All industries and projects listed in “Red” category are required to carry out IEE and subsequent EIA. In order to fulfill the requirement of DoE, it is required to conduct EIA, which should include the following:
▪ Identification of impacts of the project activities, both during construction and operational stages, on the various environmental components and recognizes those which are critical to the changes.
▪ Prediction of the environmental impacts using qualitative and if possible, quantitative methods.
▪ Recommendation of EMP to reduce adverse environmental impacts and enhance positive contributions of the project.
▪ Presentation of the results of environmental impact identification, prediction and assessment, with suggested mitigation measures.
▪ To set the basis for continuous monitoring of key project activities and environmental conditions.
The legal requirements for EA under different categories are described in detail in the ECR97 Schedule-1. Procedure and guidelines for different categories of the projects are briefly given here for ready reference. For any projects, the sponsor or PMU needs to obtain the clearance from the DOE in two stages explained earlier:
a. Initial Stage: Site Clearance Certificate (SCC)
b. Advanced Stage: Environmental Clearance Certificate (ECC)
The requirement for SCC is the IEE report and EIA or limited EIA are needed for the ECC. Upon receiving site clearance, the proponent can undertake land development and infrastructure development programs, and can install machinery for Orange category projects. However, the industrial units or projects can’t get gas connection to go for trial production.
4.2 Application for Environmental Clearance – Green Category
Applications for the environmental clearance for industries and other projects listed under category ‘Green’ need the following documents:
I. General information pertaining to the industry or project;
II. Description of the product along with that of the raw material; and
III. No objection certification (NOC) from the local authority.
4.3 Application for Environmental Clearance –Amber B & A Category
Applications for the environmental clearance for industries and other projects listed under categories ‘Amber B & A’ need the following documents:
I. General information pertaining to the industry or project;
II. Description of the product along with that of the raw materials;
III. The process flow diagram;
IV. The layout plan (indicating the site for effluent treatment plant);
V. Waste disposal system;
VI. Outlines of relocation, rehabilitation plan (where applicable);
VII. Other relevant information (where applicable);
VIII. Feasibility Study Report of the industry or project (applicable only for proposed industries or projects);
IX. Initial Environmental Examination (IEE) Report with the process flow diagram, layout plan (indicating the site for effluent treatment plant), design of the effluent treatment plant (applicable only for proposed industries or projects);
X. Environment Management Plan with process-flow diagram, layout plan (indicating the location of effluent treatment plant), design and efficiency of the effluent treatment plant (applicable only for existing industries or projects);
XI. No-objection certificate (NOC) from the local authority;
XII. Contingency plan in respect of adverse environmental impacts together with plan to reduce pollution load;
XIII. Outlines of relocation, rehabilitation plan (where applicable); and
XIV. Other relevant information.
4.4 Application for Environmental Clearance – Red Category
Applications for the environmental clearance for industries and other projects listed under category ‘Red’ need the following documents:
I. Feasibility Study Report of the industry or Project (applicable only for proposed industries or projects);
II. Initial Environmental Examination (IEE) Report together with the terms of reference of Environmental Impact Assessment (EIA). and the process-flow diagram of the industry or project, or, the Environmental Impact Assessment (EIA) Report prepared on the basis of terms of reference approved earlier by the Department of Environment, layout plan (indicating the site for effluent treatment plant), design and time-schedule to construct the effluent treatment plant, process-flow diagram (applicable only for proposed industries or projects);
III. Environment Management Plan (EMP) together with process-flow diagram, layout plan (indicating location of effluent treatment plant), design and efficiency of the effluent treatment plant (applicable only for existing industries or projects);
IV. No-objection-certificate (NOC) from the local authority;
V. Contingency plan in respect of adverse environmental impacts together with plan to reduce pollution load;
VI. Outlines of relocation, rehabilitation plan (where applicable); and
VII. Other relevant information.
4.5 Validity Periods for Environmental Clearance Certificates
|Categories of Project |Validity |Renewal Period |
|Green |1 year |30 days before expiry of the validity|
| | |period |
|Orange A & B |1 year | |
|Red |year | |
5. Subproject Preparation, Approval and Monitoring
In this section, the process for addressing the environmental concerns through the institutional arrangements and procedures used by the Project for managing the identification, preparation, approval and implementation of subprojects are discussed. The generic steps discussed below (Sections 5.1 through 5.5) are similar for all subprojects. It is crucial that the procedures are clearly linked to the project-defined subproject cycle so they can be readily included in, or referenced from, the Project Implementation Guidelines.
5.1 Subproject Document Preparation
Taking into consideration the learning from different earlier projects in the Bangladesh, BRWSSP has been designed to address environmental concerns during subproject preparation and these are described here in some detail.
In general, it is expected that DPHE team will work with agencies in relation to subprojects/schemes (i.e., sponsors, NGOs/CBOs etc) in preparing ER/LEA documents to avoid or minimize adverse environmental impacts. An ER checklist (i.e., Form 1 in Annex I) together with information on typical project impacts and mitigation measures will be used to carry out this work. The aim of the checklist is to assist in identifying potential impacts based on field investigations. The standard approach for community participation methods in the project will be used to address the environmental concerns also. The ER checklist identifies the potential impacts of the subprojects; describes the measures that can be built into a subproject to address these impacts. The completed ER checklist must be preserved along with other project documentation or any additional reports that may be required (e.g. LEA (Form 2 in Annex I) for category-B subprojects). The checklist contains a certification by the subproject preparation team that all measures required to avoid or minimize adverse environmental impacts are included in the subproject design. In some situations for the most effective use of resources, it may be appropriate to prepare any needed additional reports (e.g. LEA) after a subproject proposal has been approved in principle. In these situations, a subproject cannot be finally approved and funded until such reports are received and approved.
It is advisable to use skilled personnel for special reports (e.g. LEA) preparation. Although, these require extra resources to prepare, these studies and reports may be worth the extra effort for an otherwise excellent subproject. In these cases, the subproject committee should discuss the issues involved with the local authority to confirm the need to carry out the work.
To satisfy the requirements of the Bank’s safeguards policies, it should be emphasized that in some subproject situations mitigation measures will be need to be specified more precisely than others, either in the application or as an annex to it. It is expected that, with project training, the DPHE teams will be able to assist subproject sponsors in adequately addressing these situations, when preparing their applications.
5.2 Appraisal and Approval
This section focuses on the procedures that will be used when reviewing and then approving subproject applications. These procedures need to be consistent with applicable national approval procedures. They also need to be integrated into the planned project process of approving subprojects. The roles and responsibilities of various authorities at different levels, as appropriate and subproject sponsor are illustrated in table 5.
The procedures first specify how the review authority determines whether a subproject proposal, along with the completed ER checklist and any appropriate required reports already prepared, can be cleared for approval. The first step is an appraisal to determine if all the relevant information has been provided, and if these are adequate.
From an environmental point of view, the review authority needs to determine if it is satisfied that the subproject sponsor has thoroughly considered all potential adverse effects of the subproject, and included measures in the subproject plan to adequately address them.
If the appraisal indicates that the proposed subproject may have environmental concerns that are not adequately addressed in the proposal, or if the application does not meet certain criteria, the review authority (PMU) may requires a field appraisal before the application can be considered further. The criteria for a field appraisal report are given in table 6.
Table 5: ENVIRONMENTAL ASSESSMENT AND MANAGEMENT FRAMEWORK
|Milestones |Objectives |Process |Responsibility |Decision/Product |
|1. Subproject Screening |
| Environmental Scoping |Scope subprojects |Review of the subproject proposal by trained |Proponent and PMU |Assign Environmental |
| |from environmental |resource persons from DPHE to assign an | |Category to subproject |
| |perspective |Environmental Category to it. | | |
| | | | | |
|Environmental Screening|Screen subprojects |Review of the subproject proposal using trained | |Completed ER form for |
| |from environmental |resource persons from to fill the ER Form for |Proponent |subproject proposal |
| |perspective |Category ‘C’. |and PMU | |
| | |Review of the subproject proposal using trained | | |
| | |resource persons to fill the ER Form and produce a| |LEA Report for |
| | |LEA report for Category ‘B’. |Proponent and PMU |subproject proposal |
|2. Subproject Appraisal |
| Detailed Environmental|Appraise |Review ER for category C subprojects by DPHE. |PMU |Confirmation of |
|Appraisal |environmental | | |Environmental category.|
| |components of |Review LEA by DPHE for category B subprojects | | |
| |subproject |Conduct site visits to Crosscheck: | |Sub-project Appraisal |
| | |- type of Environmental issues; |PMU |Report with decision |
| | |- magnitude of Environmental issue; | |to: |
| | |- adequacy of Environmental management measures | | |
| | |provided; | |- accept project as |
| | |- cost of implementing Environmental management | |submitted |
| | |measures; | |- accept project with |
| | |Suggest: | |modifications |
| | |- modifications to be incorporated in environmental| |- reject project |
| | |l components of the subproject; | | |
| | |- appropriate changes in other components of | | |
| | |subproject; | | |
| | |Finalize environmental components as part of | | |
| | |project appraisal report. | | |
Table 6: Criteria for Requiring a Field Appraisal
|Criteria |Field Appraisal |
|1. A subproject may affect a protected area or a natural |A field appraisal determines if the subproject will adequately |
|habitat |avoid adverse effects on the protected area or natural habitat. |
|2. A subproject may have an impact on ecologically sensitive |A field appraisal determines the scale and level of impact. The |
|ecosystems (e.g. wetland or marshes) |application may need to be revised to describe how the subproject|
| |will avoid or minimize adverse impacts to ecologically sensitive |
| |areas. This may require a distinct LEA. |
|4. A subproject may involve, or result in: |A field appraisal determines the scale and level of potential |
| |impact. The application may need to be revised to avoid or |
|Production of waste (e.g., Arsenic laden sludge); |minimize potential adverse effects, and may include a LEA. |
Based on the appraisal and, if needed, the field appraisal, the review authority may approve a subproject with recommended conditions and implementation supervision (e.g., Arsenic laden sludge disposal).
5.3 Annual Reports
PMU will be required to report annually on their subproject activities during the preceding year. These annual reports should capture the experience with implementation of the EMF procedures.
The purpose of these reports is to provide:
• A record of the subproject transactions;
• A record of experience and issues running from year-to-year throughout the subproject that can be used for identifying difficulties and improving performance; and
• Practical information for undertaking an annual review.
5.4 Annual Reviews
The scope of work and procedures for carrying out annual reviews of the implementation of the EMF in the subprojects are specified here. The purpose of the reviews is two-fold:
• to assess compliance with EMF procedures, learn lessons, and improve future EMF performance; and
• to assess the occurrence of, and potential for, cumulative impacts due to project-funded and other development activities.
It is expected that these reviews will be carried out by the Bank’s task team or an authorized third party not involved in the subproject implementation. If third-party annual reviews are involved, these reviews will be the principal sources of information to project management for improving performance, and to the World Bank supervision missions. Thus, they should be undertaken after the annual report has been prepared and should be available for Bank supervision of the Project.
6. Environmental Management Plan
This section describes how subprojects will respond to the needs for environmental management (OP4.01), including pest management(OP4.09) and the conservation of protected areas, natural habitats(OP4.04), forests (OP4.36) and physical and cultural resources (OP 4.11). The types of subprojects which will be implemented in the project are shown in table 7.
Table 7: Type of subprojects and their environmental category.
|Sub-project Types in Rural Piped Water Supply |Environmental Category |Environmental |Comments |
|Schemes (RPWS) |(Project/WB) |Category(GOB) | |
|1. Rural Piped Water Supply Schemes (RPWS) |B |Orange-B |If DOE clearance for EMF is |
|Major Components in each: | |(Item-28) |obtained, clearance for |
| | | |individual sub-projects may not|
|Test Tube Well ( 2 nos.) | | |be needed. |
|Production Well ( 2 nos.) | | | |
|Pump House/Office Room | | | |
|Treatment Plant (if required) | | | |
|Water Reservoir (OHT) | | | |
|Distribution Network | | | |
|House Connection | | | |
|Electro- Mechanical Works (Pumps, Motors etc) | | | |
|2. Non-piped Rural Water Supply Schemes |C |Green |DOE clearance not required |
|Point Water Sources (Hand Tubewells) | | | |
|3. Rural Sanitation |C |Green |DOE clearance not required |
|Individual household Sanitary Toilets | | | |
The primary goal of this project is the supply of clean water for drinking. So, it is imperative that water quality should be analyzed in a quality assured manner, so that water quality meets the regulatory Bangladesh Standards for water quality. Because of its importance water quality analysis is is discussed separately under section 6.2.
6.1 Subproject Planning
The subproject planning should strive for plans and designs that avoid creating adverse environmental impacts that have to be explicitly managed. “Environment” is broadly defined to include the natural environment (air, water and land), and human health and safety. At the time of the implementation of any sub-project, the potential environmental impacts must be clearly identified and if needed an Environmental Management Plan (EMP) formulated, implemented and the plan’s performance monitored during and after execution of project activities. The impacts should be avoided or neutralized where possible or mitigated in conformity with Bangladesh’s and the World Bank’s prescriptions for sound environmental management.
For C category subprojects only ER is required. A screening format (Form 1) for ER/IEE is given in annex I. The subproject design should ensure that environmental concerns are taken care of and this is verified in the approval process and no action in addition to project implementation should be necessary. Only in the category B subprojects where explicit limited environment assessment (LEA) is required, an environmental management plan (EMP) is to be included. A format (i.e., Form 2) for LEA is given in annex I .
It should be emphasized that a LEA should fit the needs of a subproject and be easy to use. There is no standard format or length. For many small-scale subprojects, it may be no more than a few paragraphs or perhaps just a table. On subprojects with more significant environmental concerns (e.g. waste management), a more substantive LEA may be warranted to highlight its importance.
The basic elements of an LEA are:
• A description of the possible adverse effects that the LEA is intended to deal with;
• A description of planned mitigation measures, and how and when they will be implemented;
• A program for monitoring the environmental effects of the subproject -- both positive and negative;
• A description of who will be responsible for implementing the LEA measures; and
• A cost estimate and source of funds.
Community participation is essential in preparing a LEA since local knowledge is important in identifying, designing and planning the implementation of practical mitigation measures. It is especially important where the success of the LEA measures depends on community support and action, both in implementing mitigation measures and in monitoring their effectiveness.
In order to make the project effective, environmental management must be fully integrated with the overall project management effort, which itself should aim at providing a high level of quality control, leading to a project which has been properly designed and constructed and functions efficiently throughout its life. At sub-project completion a report should be prepared on the implementation of the EMP.
6.2 Water quality analysis and quality Assurance in analysis
Ground water carries with it many substances which may be classified as biological, chemical (both inorganic and organic), physical, and radiological impurities. These substances may give water a bad taste, color, odor, or cloudy appearance (turbidity), and cause hardness, corrosiveness, staining, or frothing. Some of these substances are harmful to human health or transmit diseases. In a drinking water supply system, the harmful substances are removed or rendered harmless. One means of establishing and assuring the purity and safety of drinking water is to set a standard for various contaminants. A standard is a definite rule, principle, or measurement which is established by governmental authority considering the local condition, such as, social, economical and food habit.. The standards are sometimes established on an interim basis until better information becomes available. This is also the reason why the standards differ from country to country[3]. The Drinking Water standards can be considered as minimum standards to be met by all public water systems. The Bangladesh drinking water quality standards is given in annex-III.
In all the subprojects, it will be a mandatory requirement that Bangladesh drinking quality standards are met. To this end, it will be necessary to test water quality parameters during construction of the tubewells and the piped water systems. In the construction stages, it is expected that tests will be mainly carried out for the critical parameters based on technical judgment as it neither necessary nor cost effective to monitor all the water quality parameters specified in the standards. Many of the parameters are usually measured using portable equipment/kits. However, for final certification of a subproject for water quality, samples taken should be analyzed at a laboratory with adequate QAQC system in place. This is because in the case of earlier kit based analysis of Arsenic, there were reported cases of misclassification of Arsenic safe tubewells[4] and this should not happen again in the present project. For laboratory analysis, proper protocols have to be followed from sampling to analysis and certification. For example, when taking samples, there are quite specific time limits on how long the sample can be left before analysis. If the sample is collected in a bottle and transported back to a laboratory or office, then the sample should be stored at below 4oC and analyzed within 4-6 hours.
For piped water supplies, the numbers of samples to be taken is usually based on the population that is served by piped water system. This may need to be calculated based on water usage study data especially because of the intermittent nature of supplies under the project. Loss of pipe pressure during non-supply period, contamination can happen with minor leaks in the pipes. All activities associated with QAQC aspects are aimed at one target: the production of reliable data with a minimum of errors.
It is expected that all water quality analysis work will be contracted to DPHE laboratory system. However, in case DPHE laboratories are unable to provide analytical services in a timely manner, the analytical work may be outsourced to other laboratories with an adequate QAQC system in place.
7. Consultation & Disclosure
7.1 Community / Stakeholder Consultations
Community/stakeholder discussions are basic requirements in the EMF preparation and implementation. As the basic principles require, inputs and feedbacks received from stakeholder consultations are the major determinants in the selection, location and design of projects and their implementation. A Stakeholder Consultations workshop was held on October 10, 2011 in which total of 45 invited participants from the concerned Agencies/Organization participated. The documentation on the discussions in respect of participation, deliberations and the decisions reached along with disclosure notification ( published December 21/22, 2011) are given in Annex-IV. The stakeholders gave strong support for the implementation of the project considering its beneficial impacts and were convinced that environment impacts of the project can be managed, so that no harmful effect will be caused to the environment or to the people.
7.2 Disclosure
The DPHE has disclosed this EMF summary in Bangla to the public in Bangladesh, and authorized the World Bank to disclose it at its Country Office Information Center and in its Infoshop. The DPHE has supplied copies of the documents at the DPHE head office and other offices, public libraries, and other places accessible to the general public. DPHE has also informed the public through a notification on December 22, 2011, in two newspapers (Bangla and English) about the EMF disclosure and where it could be accessed for review.
8. Project Coordination and Implementation
The roles and responsibilities for all participants (e.g., PMU, NGOs, CBOs, Sponsors) in preparing, reviewing, approving and implementing subprojects are given in some detail in this section. This includes institutional arrangements for managing the subproject cycle.
8.1 Organizational Structure
In order to ensure that the policy obligations and associated procedures in the Environmental Framework (EMF) are operationalized, the BRWSSP organizational support structure for subproject planning, review and implementation is to be appropriately organized. BRWSSP management will arrange for qualified teams to support preparation and oversee the implementation of the Environmental component of the subprojects. The team members should be adequately briefed and trained with resource support from the BRWSSP.
8.2 Responsibility Allocation Framework
BRWSSP management will ensure sensitivity to environmental aspects of various subprojects among its teams, so that they can provide competent support to the sponsors/CBOs. This will be done by providing training to the relevant PMU staff. Attempts should be made to involve local inhabitants wherever possible to ensure local agreement with appropriateness to ensure effective subproject preparation, implementation, operation and maintenance. Additionally, BRWSSP may maintain a list of consultants from among individuals or organizations who have the full range of expertise to address environmental concerns related to anticipated subprojects. They can be used to address project specific environmental issues as and when necessary for the following:
• Advising BRWSSP on environmental issues;
• Selective review of ER, LEA and other documents from the proponents for quality assessment; and
• Selective monitoring and evaluation of subprojects.
The service of the consultants may also be utilized to undertake the annual sample environmental audit of all BRWSSP financed subprojects.
8.3 Grievance Redress
The PMU should set up a procedure to address complaints and grievances on environmental issues. This can be part of an integrated complaints and grievances redress mechanism in the PMU. The complaints and grievances redress procedure will not pre-empt the aggrieved person’s right to seek redress in the courts of law. All complaints will first be negotiated at the local levels i.e., with the Community Groups/Community Based Organizations (CBOs). If this fails, the complaints can be referred to local authority with the minutes of the hearing that has taken place earlier. A decision agreed with the aggrieved person at any level of hearing will be binding on the subproject sponsor. The DPHE will keep the records of all complaints and grievances including ones that may remain unresolved.
9. Capacity Building and Training
The environmental sustainability of the BRWSSP that involve funding of multiple small-scale piped water supply subprojects, is highly and unavoidably dependent on the capacity of the DPHE staff and sponsors to carry out the associated design, planning, approval and implementation work. Thus, to ensure that capacity, it is important that that BRWSSP allocates sufficient resources to training and capacity building especially in the early years. These efforts will not only benefit the BRWSSP, but will also build local capacity to undertake other development initiatives funded locally or by other donors.
9.1 Institutional Capacity Assessment
An assessment of the existing institutional capacity to implement the EMF is presented in this section. It focuses on the adequacy of the institutions identified in Section- 5 to carry out their EMF responsibilities. It assesses, at a minimum, the adequacy of:
• the institutional structure, and its authorities at all relevant levels, to address environmental management issues;
• the number and qualifications of staff to carry out their EMF responsibilities;
• resources to support staff in their work; and
• knowledge and experience relevant to carrying out environmental analyses and designing mitigation measures for small-scale infrastructure.
Having implemented Bank financed BAMWSP and BWSPP projects, the senior officials of the DPHE are well aware of the environmental management issues. However, once the project is completed, most of the lower level staff with experience is usually unavailable for the subsequent projects. It is thus unlikely that much of the capacity built in the earlier projects will be available for the BRWSPP also. Some of the private project sponsors especially the newcomers may lack environmental orientation. Thus, as a part of the institutional capacity building for the project as a whole, the field level PMU/DPHE Teams and member of sponsoring agencies have to be trained in different aspects of the project, including interpretation and implementation of environmental impact management guidelines.
9.2 Capacity Building
BRWSSP will envisage capacity building at all levels i.e., field level BRWSSP/DPHE staff and project sponsor personnel to ensure that the EMF is effectively operationalized. The BRWSSP personnel will be exposed to formal training in the management of environmental issues. The training program for various role players will include an orientation program on the EMF, Environmental Assessment Processes, Participatory Methodologies and Project Management.
BRWSSP will help to improve the effectiveness of local proponents in the management of environmental and social impacts during planning, implementation and operation of proposed investments. Proposed criteria for capacity building for C and B category subprojects are shown in table 8, which will be used as modules in capacity building at all levels.
Capacity building will enhance the subprojects’ EMF management capacity by allowing real application of the critical practices such as the following:
• Basic practices: screening impacts, scoping assessments, planning mitigation options, public consultation to assess feasibility and acceptability options.
• Environment: site selection and route alignment to minimize environmental impacts and social disruption; restoration of drainage patterns, land use etc; including mitigation measures in contracts; management of impacts during construction; monitoring of effectiveness of measures.
• Monitoring and grievance redress: Transparency and public administration in planning, reporting and supervision responsibilities and formats during implementation, documenting land transactions, complaint response record keeping and procedures.
Table 8: Capacity Building Criteria for managing C and B Category Subprojects
|Issue |Concern |Eligibility Criteria |
| | | |
|1. Environmentally sound |Realistic environmental |Proponents effectively decide questions of what mitigation is needed |
|subprojects, complying with |standards for planning and |to manage risks, who is eligible for what and determining how much is|
|agreed EMF policy |implementation. |enough to achieve the standards, for environmental protection. |
| | | |
| |Effective monitoring of actual|Accuracy and credibility of baseline data and reasonable certainty of|
| |mitigation results. |detecting and correcting any errors or problems during planning and |
| | |implementation. To be able to meet standards, the proponents must |
| | |have sensitive monitoring systems & specific indicators for the |
| | |adequacy of the mitigation delivered and actual results. |
| | | |
| |Clear incentives and |Proponents have clear statements of task assignments, reasonable |
| |accountability for all |corrective consequences for mistakes or failures and unambiguous |
| |partners. |responsibility and sources of financing to correct problems, and |
| | |functioning grievance redress systems. |
| | | |
| |Common awareness and |Communication to ensure common awareness of standards, monitoring and|
| |understanding of the above. |accountability by those affected, contractors, NGOs, independent |
| | |consultants, proponents, government agencies and donors. |
| | | |
|2. Participatory planning and|Sub project prioritization is |Resolution of the proponents in support of the sub – project after |
|implementation and inclusion |based on adequate |public meeting. |
|of the poor in project |consultation. | |
|benefits. | | |
| | | |
| |Effective accountability to |Formal endorsement by the community through public hearings and |
| |citizens. |documented periodic reporting of proponents performance to citizens; |
9.3 Training needs and plans
The training programs will be coordinated and anchored within the BRWSSP management at national level. Local and National Institutions and individuals experienced in environmental aspects of subprojects may be employed to develop and conduct courses on various modules.
The section describes the training needs and plan for the various participants involved in implementing the EMF based, in part, on the institutional assessment described above. The training on EMF may be integrated with social framework and other related training program for cost effectiveness. The objectives of the training under the EMF are to:
• support representatives and leaders of community groups and associations to prioritize their needs, and to identify, prepare, implement and manage the environmental aspects of their subprojects;
• ensure that field level staff have the capacity to assist in preparing subproject proposals, and to appraise, approve and supervise the implementation of subprojects; and
• strengthen the capacity of the local sponsors/NGOs and other stakeholders which may be involved in the public participation in preparing and implementation of subprojects.
Different groups involved in BRWSSP implementation have different training needs in terms of raised awareness, sensitization to the issues, and detailed technical training:
• Awareness-raising for participants who need to appreciate the significance or relevance of environmental issues;
• Sensitization to the issues for participants who need to be familiar enough with the issues that they can make informed and specific requests for technical support; and
• Detailed technical training for participants who will need to analyze potentially adverse environmental impacts, to prescribe mitigation approaches and measures, and to prepare and supervise the implementation of management plans. This training will address such matters as community participation methods; environmental analysis; using the ER checklist, reporting; and subproject supervision and monitoring.
The different training needs that are generally associated with the projects are given in table 9. Based on these needs, a training plan has to be worked out for the life time of the project. The needs for various participants (e.g. government officials, community leaders, extension teams) have to be different of necessity. While some would require training on general awareness building and more specific training would be needed for others. The table shows the initial training needs as well as the needs for further or “refresher” training. It should include mechanisms for periodically bringing trainees together to examine the need for and design of additional training.
Table 9: Outline of different Training Needs
|Group |Participants |Venue |Resource persons|Duration |Frequency |
|BRWSSP/DPHE staff |Staff involved in |DPHE |Experts/ |1- day workshop |Year 1 of the Project|
| |project implementation | |Consultants | | |
| | | | |½-day refresher |After Year 1 as |
| | | | |workshop |needed |
|Sponsor staff |Staff involved in |Any suitable venue |Experts/ |1- day workshop |Year1 of the Project |
| |project implementation | |Consultants | | |
| | | | |½-day refresher |After Year 1 as |
| | | | |workshop |needed |
|Stakeholders |NGO workers, Concerned |Any suitable venue |DPHE staff |1-day workshop per |As needed throughout |
| |individuals | | |community |the project |
The detailed agenda and specification of resource needs (venue, trainers, materials, etc.) for each type of training activity should be worked out before the training activities are undertaken.
9.4 Resources for EM and Capacity Building
The capacity building and training should be considered as an implicit component of BRWSSP management and adequate resources from this component should be allocated to ensure effective implementation of the EMF. The resources are needed to implement the following items.
• Institutional development activities
• The training program for PMU/DPHE and sponsors’ staff to implement their EMP responsibilities
• Preparation of subproject LEAs etc. (The costs of implementing these plans are included in the subproject budgets.)
• Consultants remuneration
• Laboratory fees for collection/testing of water and any other samples
• Annual reviews and audits
10. Conclusions and Recommendations
This EMF is a document to provide guidelines as to how the environmental safeguard issues can be addressed for the BRWSSP. As discussed in the earlier sections, the proposed sub-projects under the project will have rather small scale environmental impacts that can be managed if the procedures given in this EMF are followed. The project staff and other relevant persons should be trained so that they can fully implement the actions needed under the EMP. Provision for adequate funding must be made in the project’s operational budget for the purpose.
References
1. MICS (2009), Multiple Indicator Cluster Survey (MICS) conducted by Bangladesh Bureau of Statistics and UNICEF (BBS/UNICEF, 2009).
2. Bangladesh Environment Conservation Act, 1995.
3. Bangladesh Environment Conservation Rules, 1997.
4. World Bank (1999), Operational Policy OP 4.01 on Environmental Assessment.
5. D. G. Kinniburgh and P. N. Smedley, Arsenic contamination of groundwater in Bangladesh, BGS Technical Report WC/00/19, Vol. 1-4 (2001); UNDP., Groundwater Survey: The Hydrogeological Conditions of Bangladesh, UNDP Technical Report DP/UN/BGD-74-009/1(1982)
Annex I: Environmental Management Forms
Form 1: Environmental/Social Screening Checklist for Sub-Projects
Part A: GENERAL INFORMATION
|Sl |Item |Description |
|1. |Sub-Project |Community Piped Water supply |
|2. |Project Location |Full description |
|3. |Project description |Installation community piped water supply scheme for xx households consisting of xx house |
| | |connections, xx stand posts |
|4. |Population type in the project area |[ ] All mainstream or non-indigenous/tribal peoples |
| | |[ ] All indigenous/tribal peoples |
| | |[ ] Majority mainstream or non-indigenous/tribal peoples |
| | |[ ] Majority indigenous/tribal peoples |
|5. |Brief description of the physical |Tube well and pump installation, Water tank construction, Pipeline laying, Water treatment |
| |works |plant (surface/Iron/arsenic) |
|6. |Sub-project Environmental Category |B |
|7. |Expected Environmental outcome of the |Positive |
| |sub-project | |
Part B: ENVIRONMENTAL SCREENING
|SCREENING QUESTIONS |YES/NO |REMARKS |
|(i) PROJECT SETTING: IS THE PROJECT AREA… | | |
|1. Densely populated? | | |
|2. Heavy with development activities? | | |
|3. Adjacent to or within any environmentally sensitive areas? | | |
|4. Cultural heritage site | | |
|5. Protected area | | |
|6. Wetland | | |
|7. Mangrove | | |
|8. Buffer zone of protected area | | |
|9. Special area for protecting biodiversity | | |
|(ii). POTENTIAL ENVIRONMENTAL IMPACTS (Construction Phase) | | |
|1. Noise and dust from construction activities? |Yes |The impacts are likely to be tolerable enough, so |
| | |that public complaints are not expected. |
|2. Temporary silt runoff due to construction? |Yes |Drill mud and water run off may happen during |
| | |tubewell construction but these are expected to be |
| | |manageable. |
|3. Road blocking and temporary flooding due to land excavation during|Yes |Some temporary problems may arise during pipe |
|rainy season? | |laying and measures will be taken to minimize |
| | |these. |
|4. Solid Waste and construction debris |Yes |Some debris will be generated in the construction |
| | |of water tank and pump house. These will be |
| | |responsively managed. |
|5. Health and safety related to construction activities |Yes |Standard safety procedures in construction industry|
| | |will be followed |
|6. Potential risk that water quality being non-compliant with | |Water quality will be tested and if essential water|
|drinking water quality standards and aesthetically unsuited for | |treatment plant will be established to ensure that |
|drinking. | |water quality is compliant with Bangladesh drinking|
| | |water standard. |
|(iii). POTENTIAL ENVIRONMENTAL IMPACTS (Operation Phase) | | |
|1. Hazards to public health due to drill mud contamination |Yes |Initially water may be contaminated due to residual|
| | |drilling mud which may contain materials like |
| | |cow-dung. It will be ensured that the water is free|
| | |from such contamination before public use. |
|2. Potential hazards to public health due to microbial contamination |Yes |The base of the tubewells will be cemented to avoid|
|of tubewell water | |microbial contamination of tubewells water due to |
| | |seepage. |
|3. Potential hazards to public health due to Arsenic contamination. |Yes |Water quality will be tested and if necessary a |
| | |treatment plant will be set up. |
|4. Potential hazard from sludge from water treatment plant especially|Yes |Sludge will be disposed off in technically and |
|Arsenic contaminated sludge. | |environmentally safe processes using approved |
| | |protocol. |
|5. Water resource problems (e.g. depletion/ degradation of available |No |Water quantity extracted will be small compared to |
|water supply, deterioration of surface and ground water quality, and | |aquifer capacity. So, no problems are anticipated |
|pollution of receiving waters?) | |in the foreseeable future. |
| 6.Degradation of land and ecosystems (e.g. loss of wetlands and wild|No | |
|lands etc) | | |
|7. Overuse of ground water, leading to land subsidence, lowered |No |Only a small quantity of water is involved in the |
|ground water table, and salinity. | |project, so such impacts are highly unlikely. |
Part C: SOCIAL SCREENING
|SCREENING QUESTIONS |YES/NO |REMARKS |
|1. Need for land acquisition |No |Land to be provided by the sponsor |
|2. If ‘Yes’, the required lands presently belong to: | | |
|(a) Government/Public (Lands that are khas and/or belong to the |Not applicable | |
|government ) | | |
| (b) Private landowners |Not applicable | |
|3. Dislocation or involuntary resettlement of people |No |Site selection will ensure this |
|4. Social conflicts between construction workers from other areas and|No |Sponsor will take measures to avoid such issues |
|local workers? | | |
|5, Degradation of cultural property, and loss of cultural heritage |No |Site selection will ensure this |
|and tourism revenues? | | |
Prepared by (Name): …………………………………………………
Signature: ………………………………………...... Date: …………………………
Form 2: Limited Environmental Assessment (LEA) Format for Category ‘B’ Subprojects
(This form should be completed by a qualified specialist)
1. General Description of the Sub-project
Subproject Name and Location: …………….……………….………….... ………..……………….
Name of Upazila: ……..………………….. Name of District: …………..................….
Names of Persons Participating in the report preparation with job title : ……………
…………………………..…………………………………………………………..…………………………………………………………………………………………………….
Sub-project Objectives: …………………………………………………………………………..……………………………………………………………………………………………………..…………………………………………………………………………………………………….
Sub-project Components: ……………………………………………………………………….…………………………………………………………………………………………………………………………………………………………………………………………………………
2. Baseline Description of the Affected Environment
• Description of the Physical/Chemical Environment (Soil, Water Air etc):
• Description of the Biological Environment (Habitat, Flora, Fauna etc):
• Description of the Socio-economic Environment (Public health, historical sites, infrastructure etc):
3. Specification of Expected Negative Environmental Impacts
Impact on the Physical/Chemical Environment (Soil, Water Air etc):
Impact on the Biological Environment (Habitat, Flora, Fauna etc):
Impact on the Socio-economic Environment (Public health, historical sites, infrastructure etc):
4. Mitigation Measures
Cost effective mitigation measures should be identified and measures for their integration into the project design including implementation and monitoring should be recommended.
Report Prepared by (Name & Designation): ……………………………........................
Signature: ………………………………………...... Date: …………………..……….
Telephone Number:………………………………………..
Report Approved by (Name & Designation): ……………………………........................
Signature: ………………………………………...... Date: …………………..……….
Telephone Number:………………………………………..
Annex-II: Arsenic Rich Sludge Disposal from Fe/Mn/As Removal Plants
1. Introduction
Removal of Arsenic from contaminated groundwater to the level less than the current Bangladesh standard of 0.05 mg/L can be achieved using proven methods and technologies. There is a considerable body of local experience on groundwater Fe/Mn removal plants under the BAMWSP and also in other projects in Bangladesh. Prefabricated packaged plants for Fe/Mn removal are now commercially available. This process is most likely to be used in projects under BRWSSP. In the process of removal of iron and manganese, arsenic is also removed as it binds to Fe. If the naturally occurring amount of iron and manganese is not enough to get the desired arsenic removal, more iron salt may be added. Pre-oxidation using aeration is employed to convert arsenide to the more precipitable arsenate form. However, other methods such as potassium permanganate or hydrogen peroxide addition can also be used if required.
Waste generation by Arsenic removal treatment plants is an important issue of public concern often with high emotional overtones in Bangladesh. This issue, therefore, needs careful considerations. The activities required in this connection may include preparation of sludge management plans, sludge thickening, dewatering, drying, stabilization, sanitary landfill, land application, identification of disposal sites, demobilization in stable matrices and environmental risk assessment. It should be realized that sludge from groundwater treatment is different from waste water treatment sludge being mostly inorganic in nature. The problems are both scale and technology dependent.
2. Process Performance
In general, the Fe/Mn removal processes have been found to be significantly more effective in removal of As(V) than in removal of As(III). As (III) can be converted through pre-oxidation to As(V). In the currently available packaged plants, pre-oxidation is achieved by simple aeration.
The Iron-Manganese Removal System is based on flocculation of oxidized iron and manganese and subsequent co-precipitation of Arsenic including both arsenate and arsenide. In a typical iron-manganese filtration system aerated feed water is passed through a greensand (or simple sand) media bed for removal of oxidized iron and manganese flocks. Naturally occurring amount of iron and manganese may not always be enough to get the desired arsenic removal. In such cases, Iron may be added to make Iron to Arsenic ratio 20:1 to ensure Arsenic removal reasonably efficient. Periodic backwashing of the sand media is required to remove excess iron and manganese, as well as other particulate contaminants removed from the feed water. Backwashing is accomplished by reversing the flow of water through the filter bed to flush out particulates. The backwash waste contains elevated concentrations of Fe and Mn as well as Arsenic and other contaminants.
3. Process waste characteristics[5]
The Arsenic treatment plants produce two different types of wastes: sludge and spent media. Depending upon arsenic concentration and the characteristics of the waste, each of these wastes can pose disposal challenges and has the potential for being classified as hazardous. The problems are both scale and technology dependent.
Arsenic wastes (i.e., liquids) are defined as hazardous if their toxicity characteristic (TC) exceeded 0.05 mg/l of arsenic according to USEPA. The Toxicity Characteristic Leaching Procedure (TCLP) is a method by which solid waste is evaluated to determine if it is hazardous. If waste contains less than 0.5% dry-weight solids, then the liquid is defined as the TCLP extract and concentrations in it are compared against the TC level to determine if it is hazardous. It is to be noted that there is no Bangladesh standard for TCLP.
If the waste contains more than 0.5 % dry-weight solids, then a TCLP that conservatively simulates leaching from a landfill is used to determine if the TC level would be exceeded. TC and TCLP results from residuals produced by the treatment technologies under consideration have to be evaluated. The TCLP test, as most solid waste demands, are performed at pH 4 and 7 is deionized water. In Bangladesh, the leaching of solid waste would be due to rain water which has pH value in the prescribed range.
Quantitative information on the different kinds of residuals produced by various treatment processes per million liter of drinking water produced are available in literature ( Chwirka 1999)[6]. For the Fe/Mn removal plants, the reported values of dry solid is about 22kg per million liter and concentration of As is about 1900 mg/kg. These are only indicative values and the numbers would of course vary according to Fe and As content of the source water.
TCLP characteristics of the dry solids are reported to be around .04(mg/L) which is much below the TCLP standard limits and hence can be disposed of in landfills. The solids can also be immobilized by burial in unused land (e.g., homesteads/roads etc) which is recommended in a protocol in Bangladesh.
The backwash water containing Fe rich flocks may be temporarily stored in a lined tank until the flocks settle. The supernatant liquid can then be discharged to land or water bodies as the As concentration is estimated to be less than 0.2 mg/L (see table below). The settled flock removed periodically can be dried and disposed in landfills or according to protocol prescribed from time to time. Exhausted filter media can also be disposed off in landfills as Arsenic content in the media is expected to be low.
Table- AII : National Standards – Waste Water Discharge Quality Standards for Industrial Units and Projects: Quality at Discharge Point (From ECR Schedule-10)
| | |Location of Final Disposal |
| | | |
|Parameter |Unit | |
| | |Inland Surface |Public |Irrigated |
| | |Water1 |Sewer1 |Land1 |
|Ammonia(free ammonia) |mg/L |5 |5 |15 |
|Ammoniacal Nitrogen(as N) |mg/L |50 |75 |75 |
|Arsenic(As) |mg/L |0.2 |0.5 |0.2 |
|BOD5 20oC |mg/L |50 |250 |100 |
|Boron(B) |mg/L |2 |2 |2 |
|Cadmium(Cd) |mg/L |0.05 |0.5 |0.5 |
|Chloride(Cl-) |mg/L |600 |600 |600 |
|Chromium (hexavalent Cr) |mg/L |0.1 |1.0 |1.0 |
|Chromium(total Cr) |mg/L |0.5 |1.0 |1.0 |
|COD |mg/L |200 |400 |400 |
|Copper(Cu) |mg/L |0.5 |3.0 |3.0 |
|Cyanide(CN) |mg/L |0.1 |2.0 |0.2 |
|Dissolved Oxygen(DO) |mg/L |4.5-8 |4.5-8 |4.5-8 |
|Dissolved Phosphorus(P) |mg/L |8 |8 |10 |
|Electrical Conductivity |μMho/cm |1200 |1200 |1200 |
|Fluoride(F) |mg/L |7 |15 |10 |
|Iron(Fe) |mg/L |2 |2 |2 |
|Lead(Pb) |mg/L |0.1 |0.1 |0.1 |
|Manganese(Mn) |mg/L |5 |5 |5 |
|Mercury(Hg) |mg/L |0.01 |0.01 |0.01 |
|Nickel(Ni) |mg/L |1.0 |1.0 |1.0 |
|Nitrate(N molecule) |mg/L |10.0 |Undetermined |10.0 |
|Oil and Grease |mg/L |10 |20 |10 |
|pH |- |6-9 |6-9 |6-9 |
|Phenol Compounds(C6H5OH) |mg/L |1.0 |5 |1 |
|Radioactive Materials | |As determined by Bangladesh Atomic Energy Commission |
| |- | |
|Selenium(Se) |mg/L |0.05 |0.05 |0.05 |
|Sulfide(S) |mg/L |1 |2 |2 |
|Temperature– Summer |oC |40 |40 |40 |
|Temperature– Winter |oC |45 |45 |45 |
|Total Dissolved Solids(TDS) |mg/L |2100 |2100 |2100 |
|Total Kjeldahl Nitrogen(N) |mg/L |100 |100 |100 |
|Total Suspended Solids(TSS) |mg/L |150 |500 |200 |
|Zinc(Zn) |mg/L |5.0 |10.0 |10.0 |
Notes: (1) Land Surface Water refers to any pond, tank, water body, water hole, canal, river, spring or estuary.
Public Sewer refers to any sewer connected with fully combined processing plant including primary and secondary treatment.
Irrigated Land refers to an appropriately irrigated plantation area of specified crops based on quantity and quality of wastewater
Annex-III: Bangladesh Drinking Water Quality Standards
Schedule – 3 (ECR 97)
Standard for Water (Rule 12)
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Annex-IV: Stakeholders’ Consultation and Disclosure
Proceedings of the stakeholder consultation workshop on
‘Environmental Management Framework (EMF)’ and ‘Social Management Framework (SMF)’
of
Bangladesh Rural Water Supply and Sanitation Project (BRWSSP)
|[pic] |[pic] |
A Report on the Workshop Proceedings
A total of 45 invited participants from the concerned Agencies/Organization participated in the workshop held on October 10, 2011. The participation list and the invitation are appended with this report.
The Opening Session :
The beginning : Mr. Moniruzzamn, Assistant Chief, DPHE extended welcome to all at the participants at the workshop in which Mr. S.M. Ihtishamul Huq, Chairman, PPT of BRWSSP and Mr. Nuruzzaman, Chief Engineer, DPHE were also present. The Workshop started through self introduction.
Welcome speech of Chairman, PPT of BRWSSP: The workshop started with the welcome speech by the Chairman, PPT of BRWSSP. In the opening speech, Mr. S.M. Ihtishamul Huq briefed the participants on the background of upcoming BRWSSP. He noted that the implementation of ‘Rural piped water supply scheme’ through Public private partnership (PPP) model for safe water delivery in the rural Bangladesh under completed Bangladsh water supply program project (BWSPP) was one of the most challenging attempts on the part of DPHE. In total 21 Rural piped water supply schemes were commissioned all over the country under BWSPP. The obstacles faced and the challenges in terms of social, economic, financial and technical issues were formidable. He also acknowledged the commitment and support from DPHE field level Officials and dedication of the concerned sponsors, LGIs that made the piloting successful. He opined that during planning to implementation stage a lot of ‘social and environmental’ issues should be solved through well organized effort and valid documentary evidences both the from the point of view of Government and the development partner. He stated that this workshop is organized to present and share the key documents on ‘social and environmental management framework. to the concerned stakeholders.
He welcomed the participants for active participation in the workshop to make it worthwhile through sharing of their practical experience and learnt lessons including the piloting under BWSPP. He also stated that input provided by the participants can l make a positive contribution to the upcoming project.
Mr. Motaleb, Sr. Water Supply Engineer, the World Bank, Dhaka Office :
Mr. Motaleb appreciated the well done performance of the sponsors those involved under BWSPP for implementation of ‘Rural piped water supply scheme’ in the rural areas of Bangladesh. He drew the notice of all participants to participate very actively on the presentable documents of BRWSSP on policy of ‘Social and Environmental Safe Guard’.
Chief Guest, Chief Engineer, DPHE:
Mr. Nuruzzaman, Chief Engineer, DPHE, as a Chief Guest of the workshop welcomed the participants in the workshop and made their attention on these two important issues under upcoming BRWSSP. He strongly informed the participants that the Government of Bangladesh through DPHE is interested for early implementation of the upcoming ‘Bangladesh Rural Water supply and Sanitation Project (BRWSSP)’.
He also expressed his joys that through the labor intensive but result oriented documentary support provided both by the World Bank Country Office and PPT, BRWSSP under DPHE and hope that this will accelerate the quality implementation of BRWSSP. He also thanked the World Bank for providing support for conducting this workshop in the World Bank premises as well as to make funding for the upcoming project. He welcomed the participants for active participation in the workshop.
Mr. Arif Ahmed, Task Team Leader, BRWSSP : Mr. Arif requested the participants that the participants to go through the key issues during the discussion and sharing of their ideas on the relevant specific issues lying under the discussion. He also noted that the participants are welcome to put comments on the presentation.
Key presentation of the said two documents: 10.25 -12.00
Environmental Management Framework (EMF)
Dr. M. Khaliquzzaman, Environmental Specialist, WB briefed the audience on the World Bank’s safeguards requirements especially on the OP 4.01 for Environmental Assessment (EA).
Discussion on EMF are described below:
The project components have environmental safeguard issues which are addressed by the EMF. As per World Bank guidelines, the projects components are to be designed and implemented by integrating the national policies, guidelines, codes of practice and procedures proposed in this EMF. The objectives are to ensure that the activities undertaken in the project:
➢ Enhance positive environmental outcomes;
➢ Prevent negative environmental impacts;
➢ Identify and mitigate with appropriate measures, the adverse impacts that might arise;
➢ Obtain Environmental Clearance form DOE; and
➢ Ensure compliance with the World Bank’s environmental safeguards policies.
The present Policies, Acts, Rules & Regulations with respect to the Environmental issues in the country are under the custodianship of the Ministry of Environment and Forest (MOEF)/Department of Environment (DoE). The activities under the project are covered by the Policies, Acts, Rules & Regulations under ECA 95 and ECR 97.
The main purpose of the Bank’s safeguard policies are to (i) avoid harm to the environment and affected people and provide affected people an opportunity to participate in the development process; (ii) improve project design and performance; and (iii) protect the reputation of the Bank. The current set of safeguard policies cover a broad range of topics from environmental assessment to natural habitats, forests, resettlement, and Indigenous Peoples and others. The policies are the reflection of international conventions and internationally accepted principles of good practice in project preparation and implementation. Similar principles, supporting the aspirations for sustainable development, are generally reflected in policies in most client countries; however, implementation is often weak and variable. Out of Bank’s safeguards policies only OP 4.01 related to environment is triggered in the Project. Considering the environmental impacts according to WB policy, the project has been classified in the B category.
Mr. Naveed Ahmed, presented the key Social safeguard policies that are likely to be triggered in the project which are related to The World Bank Operational Policies on
➢ Involuntary Resettlement (OP 4.12)
➢ Indigenous Peoples (OP 4.10) and
➢ Gender (OP 4.20).
The Social Management Framework (SMF) is proposed to deal with social safeguard issues that are likely to arise under the proposed Bangladesh Rural Water Supply and Sanitation Project (BRWSSP). This project will implement by the Department of Public Health Engineering DPHE under the Ministry of Local Government Rural Development & Cooperatives (LGRD & C) of Government Bangladesh (GOB). The activities under this multi-component project will be implemented over a five-year period across Bangladesh.
The operational policies will provide guidance on mitigation and minimization of negative impacts due to land acquisition requisition etc .The nature and magnitude of impacts will be determined on a continuing basis with finalization of facility location and engineering designs. However it is expected that the project will have low severity of impact in terms of negative social outcomes. As the impact details become available, the proposed SMF will provide the basis to prepare and implement Resettlement Plans (RPs), Indigenous Peoples Plans (IPPs) and Gender Action Plan, as and when required to mitigate adverse impacts due to the physical facilities development. The SMF will be applicable to the activities financed by the World Bank
The SMF is intended to provide the necessary bases to determine applicability of the World Bank safeguard policies, identify the safeguards impacts, and prepare and implement RPs, IPPs and GAP as and when required. The core principle behind the SMF is to avoid, minimize and mitigate issues relating to land acquisition/resettlement, impacts on indigenous people, and ensure that the negative impacts of the projects on women are minimized. As proposed here, it also provides general policies, guidelines, and procedures for integration of social safeguard issues into selection, design and implementation of the civil works..The objective of the SMF is to help ‘DPHE’ to ensure that the project:
o Enhances social outcomes of the activities implemented for the physical facilities development under the project.
o Identifies and mitigates adverse impacts that the selected development interventions might cause on people, including protection against loss of livelihood activities, with culturally, socially and economically appropriate measures; and
o To ensure the implementation of the project in complience with the World Bank’s social safeguard policies.
Requirements On Environmental Clearance In Bangladesh
In Bangladesh, the EA procedure has three tiers which are; (i) Screening; (ii) Initial Environmental Examination (lEE); and (iii) Detailed EIA. The rural piped water supply subprojects in BRWSSP can be classified in the Orange-B category (ECA97, Schedule-1, item-28), need to obtain the clearance from the DOE in two stages i.e., (i) Initial Stage in which a Site Clearance Certificate (SCC) is obtained and (ii) an advanced Stage in which an Environmental Clearance Certificate (ECC) is obtained. However DOE may provide clearance to EMF for projects with multiple sub-projects with small environmental footprints. If the clearance is obtained for the EMF, then clearance for individual subprojects may not be necessary.
Discussions: 12.10 -12.50
As per the presentation by the concerned two subject matter specialist of The World Bank, Country Office, Bangladesh an explicit, issue based clear cut discussion was made by the ‘attendance and presenters’ through open ‘question and answering’ method.
Most of the participants were participated in this session and could able to gain their ‘clear understanding’ on the key issues that discussed through the key documents of BRWSSP. They also opined that in selecting the site, topmost priority will be given so that negative impact on environmental and social is minimum and amppropriate measures will be taken to mitigate the impact.
Recommendation and Closing Remarks (12.45-1.00 pm) : The following recommendation was made through the workshop :
Disclosure of the documents : The PMU will disclose the SMF and EMF documents on the DPHE website. The PMU will ensure that copies of the documents and their executive summaries in Bangla will be made available at the project sites, DPHE local offices and DPHE Head Office in Dhaka, so that the document is accessible to the general public. The PMU will inform the people through notification in two local newspapers about the stakeholders’ consultation on the SMF and EMF and their availability.
Following persons put their closing remarks thanking all for their fruitful and result oriented participation in the workshop :
▪ Mr. Nuruzzaman, Chief Engineer, DPHE.
▪ Mr. S.M. Ihtishamul Huq, the Chairman, PPT of BRWSSP.
The workshop was ended by vote of thanks by Mr. Arif Ahmed, Task Team Leader, BRWSSP.
The Invitation Card of Workshop
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Invitation for stakeholder consultation workshop on exposure of ‘Environmental Management Framework (EMF)’ and ‘Social Management Framework (SMF)’ of BRWSSP
I have the pleasure to inform you that a stakeholder consultation workshop is going to be held on ‘Environmental Management Framework (EMF)’ and ‘Social Management Framework (SMF)’ of BRWSSP those prepared by the ‘Project Preparation Team (PPT)’ of DPHE on Monday, October 10, 2011 at 10:00 am at the Conference room ‘Jamuna’ of The World Bank Office at E-32 Agargaon, Sher-e-Bangla Nagar, Dhaka-1207.
Engr. Md. Nuruzzaman, Chief Engineer, Department of Public Health Engineering (DPHE) has kindly consented to be the Chief Guest on the Occasion.
You are cordially invited to attend the workshop.
S.M. Ihtishamul Huq
Project Director
Bangladesh Rural Water Supply and Sanitation Project [Proposed]
Department of Public Health Engineering
Program Schedule
|Date : Monday, October 10, 2011 |Venue : Conference Room ‘Jamuna’ |
| |The World Bank Office |
| |E-32 Agargaon, Sher-e-Bangla Nagar, Dhaka. |
|09:30 – 09:45 |Registration |
|09:45 – 10:00 |Guest /Participants take their seat |
|10:00 – 10:05 |Recitation from the Holy Quran |
|10:05 – 10:15 |Welcome Address and introduction of the Workshop |
|10:15 – 10:25 |Address by Chief Guest |
|10:25 – 10:35 |Understanding of The World Bank’s OP 4.01 for Environmental Assessment (EA) |
|10:35 – 10:45 |Understanding of The World Bank’s OP 4.12 for land acquisition and displacement |
|10:45 – 11:00 |Tea Break |
|11:00 – 11:30 |Presentation of Environmental Management Framework (EMF) |
|11:30 – 12:00 |Presentation of Social Management Framework (SMF) |
|12:00 – 12:45 |Open Discussion on EMF & SMF |
|12:45 – 01:30 |Lunch and Prayer |
| | |
List of participants
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Note : The attendance list of the participants is attached in the Annexure as a ready reference.
Documentation on Disclosure
The scanned copy of the advertisement in two daily newspapers published on December 22, 2011is given below. Although, the advertisement is in Bangla, the keywords (i.e., BRWSSP, EMF, website link address etc) are also given in English.
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[1]
[2]
[3] Bangladesh standard for Arsenic in drinking water is 50 ppb compared to US EPA standard and WHO guideline of 10ppb. It may be noted that cost-benefit analysis is also involved in setting standards.
[4] M. Khaliquzzaman, (URL: NAMIC%2037%20upzillas.doc)
1. MacPhee, M. J., Charles, G. E., Cornwell, D. A., Treatment of Arsenic Residuals from Drinking Water Removal Processes, EPA/600/R-01/033 (2001)
2. C[5];RSdfmnostxyz{|}€¨ÍíâÞÐźÅÐÅЯ¤–Þ‹{k]WSG;hÎU¶hÇ]ƒ5?CJ$aJ$hÎU¶hËt^5?CJ$aJ$hËt^hÇ]ƒCJ(hÇ]ƒhÇ]ƒ5?CJ \?aJ hËt^5?6?CJ aJ mHnHu[pic]h°xf5?6?CJ aJ mHnHu[pic]hÇ]ƒ5?6?CJ aJ hÇ]ƒhhwirka, J., Residuals Generation, Handling and Disposal. In Arsenic Treatment Options and Residuals Handling Issues. Draft Final Report. AWWA, Denver (1999).
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