Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental...

79
Semi-annual Environmental Monitoring Report Project No. 45207-002 June 2019 IRRIGATION MANAGEMENT IMPROVEMENT PROJECT (IMIP)

Transcript of Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental...

Page 1: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

Semi-annual Environmental Monitoring Report

Project No. 45207-002 June 2019

IRRIGATION MANAGEMENT IMPROVEMENT PROJECT (IMIP)

Page 2: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

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

In preparing any country program or strategy, financing any project, or by making any

designation of or reference to a particular territory or geographic area in this document, the

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

of any territory or area.

Page 3: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

i

GOVERNMENT OF THE PEOPLE’S REPUBLIC OF BANGLADESH

Ministry of Water Resources

Bangladesh Water Development Board

ADB Loan: 3135-BAN (SF)

7th Semi-annual

ENVIRONMENTAL MONITORING REPORT

Period: January-June, 2019

IRRIGATION MANAGEMENT IMPROVEMENT PROJECT (IMIP), BWDB

Dhaka, August, 2019

Page 4: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

ii

ACRONYMS AND ABBREVIATIONS

ADB - Asian Development Bank

BADC - Bangladesh Agriculture Development Corporation

BOD - Biological Oxygen Demand

BOQ - Bill of Quantity

BWDB - Bangladesh Water Development Board

CAS - Catch Assessment Survey

C-IMO - Construction phase Irrigation Management Operator

COD - Chemical Oxygen Demand

DAE - Department of Agricultural Extension

DFR - Draft Final Report

DO - Dissolved Oxygen

DoC - Department of Cooperatives

DOE - Department of Environment

DOF - Department of Fisheries

DoPHE - Department of Public Health Engineering

DTW - Deep Tube Well

EAP - Environmental Action Plan

EC - Electrical Conductivity E

CA - Environment Conservation Act

ECC - Environmental Clearance Certificate

ECR - Environment Conservation Rules

EEC - European Economic Commission

EIA - Environmental Impact Assessment

EIRR - Economic Internal Rate of Return

EMP - Environmental Management Plan

EMR- Environmental Monitoring Report

EMU - Environmental Management Unit

ERP - Environmental Responsible Procurement

FAP - Flood Action Plan

FAO - Food and Agricultural Organization

FCD - Flood Control, Drainage and Irrigation

FD - Forest Department

FGD - Focus Group Discussion

FOM- Field Office Manager (IMO)

FPCO - Flood Planning Coordination Organization

GAP - Gender Action Plan

G - Galvanized Iron

GKIP - Ganges Kobodak Irrigation Project

GRM - Grievance Redress Mechanism

GOB - Government of Bangladesh

GPP - Guidelines for People's Participation

GPWM - Guidelines for Participatory Water Management

GRC - Grievance Redress Centre

ICC - Implementation Coordination Committee

Page 5: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

iii

IDA - International Development Agency

IEC - Important Environmental Components

IEE - Initial Environmental Examination

IMIP - Irrigation Management Improvement Project

IMO - Irrigation Management Operator

IMED - Implementation, Monitoring and Evaluation Division

IPM - Integrated Pest Management

ISPAN - Irrigation Support Project for Asia and Near East

IWM - Institute of Water Modeling

IWRM - Integrated Water Resources Management

IWRMP - Integrated Water Resources Management Plan

JMC - Joint Management Committee

KJDRP - Khulna Jessore Drainage Rehabilitation Project

LLP - Low Lift Pump

LGI - Local Government Institution

M-IMO - Management phase Irrigation Management Operator

MIP - Muhuri Irrigation Project

MOA - Ministry of Agriculture

MOEF - Ministry of Environment and Forest

MOM - Management Operation and Maintenance

MoU - Memorandum of Understanding

MOWR - Ministry of Water Resources

Mt - Metric Ton

NGO - Non Governmental Organization

NWMP - National Water Management Plan

NWPo - National Water Policy

O&M - Operation and Maintenance

PAP - Project Affected Person

PD - Project Director

PH - Hydrogen Ion concentration in a solution

PHE - Public Health Engineering

PIU - Project Implementation Unit

PMDC - Project Management & Design Consultants

PMU - Project Management Unit

PMO - Project Management Office

POPs - Persistent Organic Pollutants

PPP - Public Private Partnership

PPTA - Project Preparation Technical Assistance

PRRA - Participatory Rapid Rural Appraisal

PSC - Project Steering Committee

PVC - Poly Vinyl Chloride

PWD - Public Works Department

RAP - Resettlement Action Plan

RCC - Reinforced Cement Concrete

REB - Rural Electrification Board

RF - Resettlement Framework

RSDP - Resettlement and Social Development Plan

SPS - Safeguard Policy Statement

Page 6: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

iv

SIDA - Swedish International Development Agency

STW - Shallow Tube Well

SWMC - Surface Water Modeling Center

TBIP - Teesta Barrage Irrigation Project

UNDP - United Nations Development Program

WARPO - Water Resources Planning Organization

WUO - Water Users Organization

WUG - Water Users Group

WUA - Water Users Association

WMO - Water Management Organization

WMG - Water Management Group

WMA - Water Management Organization

WHO - World Health Organization

Page 7: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

v

Table of Contents Page No

Executive Summary

Chapter –1 Project Background

1.0 Background of MIP 1

1.1 Project Location

1.2 Project objectives 4

1.3 Proposed intervention of the project 4

1.4 Scope of environment and social safeguard monitoring of MIP 5

1.5 Arrangement for supervision and monitoring of Environment Management Plan 7

Chapter -2 Environmental Management Plan

2.0 Environment Management Plan 9

2.1 Environment Monitoring Plan 9

2.2 Implementation Arrangement of Environmental Monitoring Plan 9

2.3 Monitoring of implementation status of Environmental Health & Safety 46

2.5 Monitoring of implementation status of Grievance Redress Mechanism 52

2.6 Training on safeguard issues 54

Chapter -3 Results of Environmental Monitoring

3.0 Results of Environmental Monitoring and Compliance Measures 57

Chapter -4 Conclusion and Recommendation

4.0 Conclusion 65

4.1 Recommendation 65

Tables

Table- 1

Implementation status of Environmental Monitoring Plan 12

Table- 2 Monitoring of Implementation status of Health and Safety Plan (HSP) 47

Page 8: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

vi

Table- 3 Observation of Monitoring Results /status of implementation of EMP 60

Figures

Figure- 1 Location Maps of Irrigation Management Improvement Project (IMIP) 2

Figure- 2 Location map of Muhuri Irrigation Project (MIP) 3

Page 9: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

vii

Muhuri Irrigation Project

7th Semi-annual Environmental Monitoring Report

Executive Summary

In pursuance of ADB’s concern as outlined in ADB’s Safeguard Policy Statement (SPS-2009) and

reflected in the Environment Management Plan (EMP) for protection of the natural and social

environment from adverse impacts that may occur due to implementation of project activities, IMO

undertakes monitoring of the impacts by using the given parameters to avoid adverse impact on the

natural and social environment. Viewed from environmental protection aspects Muhuri Irrigation

Project (MIP) under IMIP has been classified as Category-B. This 7th semi-annual Environmental

Monitoring Report covering January- June,’19 period is prepared in line with ADB’s requirements by

monitoring EMP implementation in the field.

The main components of MIP project are (a) rehabilitation of coastal embankment of about 17.75 km,

(b) re-excavation/re-sectioning of drainage/irrigation khals (460 km) (c) rehabilitation of 4 sluice gates

(d) construction of 2 sluice gates (e) rehabilitation of 3 water control structures (f) construction of 4

water control structures (g) installation of electricity distribution lines (180 km), (h) installation of

irrigation water distribution underground pipelines (71.45 km) (i) installation of 20 km RCC pipe and (j)

installation of GI pipe of 12 km (k) installing and electrifying 850 Low Lift Pumps (LLP).

Considering the above project activities and the experience of the last few years, it is expected that the

project will make generally positive impacts on the environment including (i) protection from tidal

surge/ flood by construction /rehabilitation of coastal embankments & water control structures, (ii)

protection from salinity intrusion through water regulating structures thereby preventing land

degradation; (iii) increased water use efficiency through retention of surface water by storing in

reservoir and distribution of surface water through a profuse networks of irrigation khals (canals) for

cultivation in the dry season (iv) reduced water logging through drainage khals/structures and control

measures and (v) diversification of cropping patterns, increasing cropping intensity and attaining food

security by providing year round irrigation by modern and efficient prepaid metered pumps.

On the other hand, negative impacts that may occur, include (i) possible exacerbation of downstream

salinity intrusion due to water extraction from the rivers; (ii) obstruction to fish and other aquatic animal

migration between the rivers and internal water bodies by regulators and other structures; (iii) water

quality deterioration due to agriculture intensification; and (iv) temporary impacts on environment and

communities during construction of structures and embankments repair works, such as Air/Sound

pollution by generation of noise, dusts, fumes etc. (v) reduction of vegetation cover and habitats for wild

animals due to removal of trees while re-excavating khals (vi) risk of sliding down of steep canal banks

after re-excavation(vii) disposal of spoil earth from excavation of khals(viii) risk of dying some aquatic

Page 10: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

viii

non-fishery animals due to drying of canals (ix) Reduction of recharge in ground water causing less

availability of ground water for drinking and irrigation due to use of underground pipes for irrigation (x)

land communication by local people /vehicles over the canals hindered due to re-sectioning of canals (xi)

Intensive cultivation causing soil degradation (xii) Indiscriminate application of agrochemicals like

fertilizers and pesticides decreasing soil fertility and causing environmental pollution etc.

In the on going construction phase of implementation, social safeguard issues that are related to

stakeholders and labours are important. Mention may be made of (i) risk of constructing labour shed on

private land and unauthorised obstacles to cultivation (ii) careless operation of machines resulting in

removal of trees which could be saved, if done carefully (iii) dumping of excess spoil earth/construction

materials on private land/crops during re-excavation of khals/construction of sluice gate etc. (iv) social

disquiet or disturbance by imported external manpower breaking peace of local people (v)

accommodation and sanitation of workforce (vi) supply of food and drinking water to labours (vi) risk of

leaving heaps of spoil earth on private agricultural land after installation of underground uPVC pipes(vii)

borrowing soil from private land for re-sectioning of canals/construction of road for movement of

excavating machine .(viii) Arrangement of medical facilities like first aid, emergency transport facilities

for carrying injured personals to hospitals (ix) protection of labours from extreme weather conditions

and pests or insects (x) Safety indication/sign boards in work sites (xi) HIV/AIDS awareness among the

labours & local community to avoid risk of transfer of the HIV virus (xii) discrimination of labourers’

payment between male and female labours (xiii) low/unfair wages paid to labours etc.

Environmental impacts and problems of social issues are identified through on-site monitoring that is, by

observing at the field level. During field trip, in addition to physical observation, the issues are discussed

with community people, labours working in the site and also contractor’s/sub-contractor’s employees

who supervise the works. In the farmers’ training class/consultation sessions, these are discussed. For

mitigating the negative environmental impacts and social issues (i) the contractors’/sub-contractor’s

employees engaged for supervision are requested to take remedial measures. In most cases, they take

corrective actions. (ii) The concerned Field Office Manager(FOM) is requested to keep an eye on the

problems and to talk to the contractor/sub-contractor for solution. Mostly, they can solve the problem

locally. A Grievance Redress Mechanism (GRM) has been established and this was publicised in training

classes and by distributing leaflets (iii) If these measures fail, then it is reported in writing to the

Director, PIU who have control over the contractors officially. (iv) In case no action is taken by the

Director, PIU, the matter is/will be referred to the PMU for action.

Certain environmental issues may occur during operation phase, such as, surface water

availability/quantity; ground water/surface water quality such as, salinity, arsenic contamination,

pesticide effects, siltation of canal beds, soil fertility & bio-diversity loss, wild life habitat loss etc. To

identify the impacts, necessary studies will be conducted by the concerned agencies during operation

phase or at the end of the project and necessary actions will be taken accordingly.

Page 11: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

ix

Training is imparted to the farmers on improved agricultural production techniques, effective soil

nutrient management, social forestry, pisciculture in canal/pond etc. Planning for pisciculture is under

process. Integrated Pest Management (IPM) has been incorporated in farmers’ training curriculum.

At the field level contractors are responsible to implement the EMP. C-IMO, PIU and WMAs are

responsible for monitoring, supervision and enforcing the contractors to comply with the conditions of

EMP, environmental health and safety. Safeguard cell at PMU is responsible to oversee the whole

process and verify the claims and grievances raised by community people/farmers if any, through the

GRM and finally based on these, prepare and submit safeguard reports to ADB regularly for disclosure. ,

As many of the adverse impacts will emerge during operation phase of the project, therefore most of

the environmental parameters /indicators as per EMP are not yet monitored. During the reporting

period, only (a) impacts that occurred during khal re-excavation and construction of pump house and

header tanks, construction/repair of sluice gates, regulators, outlet chambers, embankment

rehabilitation and pipe setting (b) environmental health and safety compliance and (c) felling/cutting of

trees and planting of saplings (d) social issues like labour’s wages and welfare facilities, wage

discrimination to female labours, low wage paid to labours and neighbouring communities’ peaceful

living have been monitored and overall results have been found satisfactory within limited monitoring

arrangements except a few issues stated in the templates.

MIP stakeholders have somewhat basic knowledge of environmental compliance and about safeguard

issues. Proper training on Environmental Monitoring, Environmental Health and Safety compliance,

International Labour law etc. if provided to concerned safeguard personnel working in PMU-safeguard

cell, C-IMO, PIU, WMAs and contractors, will develop their safeguard monitoring, implementation and

reporting capacity to International Standard.

Implementation status of EMP and its monitoring have been stated in table-1 ( a. Impacts on water &

soil resources, wetland habitats and construction, operation and social impacts (as per EMP, in general)

and for all specific project interventions like (b) Coastal Embankment, re-excavation of irrigation canals,

construction of pump houses, header tanks, construction/repair of sluice gates, regulators and buried

pipe setting. Monitoring of implementation status of Health and Safety Plan (HSP) has been shown in

table 2 and Actual Observation of Monitoring Results in table 3. Results of environmental monitoring is

described in chapter-3. Issues like Grievance Redress Mechanism (GRM), training of BWDB and IMO field

staff have been added in this report.

While preparing the report, the key points suggested by ADB (Which proposed mitigation measures

were done, whether the proposed mitigation measures are effective or not, how the mitigation

measures were performed, by who and where) have been followed. The problems faced and the

reasons why the proposed mitigation measures have not been effective in some areas have been

mentioned in the report as well as in recommendation and conclusion.

Page 12: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

1

Muhuri Irrigation Project

CHAPTER 1

1: PROJECT BACKGROUND

1.0 Background of MIP

The Muhuri Irrigation Project (MIP) was completed and commissioned in 1986. Over this long period

the canal beds have become largely silted. Due to sandy soil there has been landslides in many parts

of the canals. This has reduced the volume of water flow in the canals and the command areas of the

schemes. The underground water level is going down every year threatening availability of water for

irrigation and drinking.

Added to this, siltation of the rivers in Bangladesh and diversion of water in the up-streams of the

rivers originating in/flowing through some parts of India, efficient use of water resources with

diversification of crops/changing cropping pattern has become essential for obtaining food security

for 160 million people of Bangladesh.

In MIP at present, the motors for irrigation are mostly owned by rich farmers who run the motors by

diesel and sell water to small and medium farmers. The cost for irrigation is high and fixed per bigha

(33 decimals). As farmers pay a fixed charge per bigha, they use more water than actually required.

Distribution of water through the present field channel system is wasteful, not only because a

substantial amount of land remains outside the cropping area but also due to seepage and

evaporation of water. The overall production cost has gone up and farming has become uneconomic.

In view of the above, Government of Bangladesh, with the financial assistance of ADB, has taken

initiative to modernise 3 large scale old irrigation projects of BWDB under Irrigation Management

Improvement Project (IMIP). Under IMIP the implementation of Muhuri Irrigation Project (MIP) at

Feni & Chittagong districts and feasibility studies for modernization of another two old BWDB

projects named Ganges Kobotak Irrigation Project (GKIP) at Kustia, Meherpur, Chuadanga and

Magura districts and Tista Barrage Irrigation Project (TBIP) at Rangpur, Dinajpur and Nilphamari

districts are supposed to be completed within 6 years, Fy 2015/16 to 2019/20 (Figure-1). After

completion of MIP, modernization process of the other two subprojects GKIP and TBIP will take place

with financial assistance of ADB. Implementation of all the project components of MIP is going on

and the feasibility study of GKIP & TBIP have been completed. This Environmental Monitoring Report

concentrates on the impacts of implementation of MIP with respect to environment and social

issues.

Page 13: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

2

1.1 Project Location The MIP is located between latitude 22.45˚ - 23.09˚ N and longitude

91.21˚- 91.35˚ E in the middle of the south eastern region of Bangladesh, adjacent to coastal belt

of the Bay of Bengal. MIP is situated on the downstream confluence of Muhuri and Feni rivers in

Page 14: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

3

the South-East Bangladesh. These two rivers originate in India and these are the two main water

sources for MIP. The project covers five Upazilas of Feni District (Feni Sadar, Sonagazi,

Chhagalnaiya, Fulgazi, and Porshuram) and part of Mirsarai Upazila in Chittagong District

(Figure-2). The MIP is on the flood plains of 3 flashy rivers Muhuri, Feni and Selonia river

networks between the Indian hills of Tripura state of India to the East and the Bay of Bengal to

the West. So heavy downpour in Indian hills suddenly flashes the area violently and damages

houses and property, submerges the crops and land and reduces the storage and flowing

capacity of the rivers by sand/silt carried with flood water.

Figure-2: Location map of Muhuri Irrigation Project (MIP)

The MIP area experiences natural disasters like tropical storms, cyclones and tidal surges at intervals

of several years. The project area of MIP is also prone to earthquake due to the presence of India-

Myanmar fault to its eastern periphery.

Page 15: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

4

1.2 Project objectives

A. The overall objective of the project is reducing poverty, enhancing food security through

increased yield of crops and reducing irrigation costs of production.

B. The specific objectives of the project are-

i. To ensure dry season irrigation using surface water by installing low lift pumps (LLP) on re-

excavated canal banks, to reduce salt water intrusion from the Bay of Bengal, and to reduce the

extent, depth, and duration of monsoon flooding.

ii. To modernize the irrigation system of MIP focusing on sustainable operation and

maintenance through rehabilitation of the irrigation infrastructures, replacing the existing

drainage /channel system by setting underground pipelines, electrifying the LLPs and

introducing prepaid metering and smart cards with which farmers would irrigate his/her land

whenever s/he needs and gets whatever quantity of water s/he needs, thus reducing waste of

water.

iii. Improvement of irrigation management through innovative approaches for modernization

and cost recovery in full for the Level 2 (Secondary canal systems) and the Level 3 (framers’

canal system) infrastructures’ O&M while the Executing agency will carry out O&M of the Level

1 (Embankment, regulators and primary canal system/rivers) of the MIP with contribution by the

GoB.

iv. Increasing sustainability of MIP through raising farmers’ awareness, institutional

strengthening and effective community participation.

v. Controlling floods, increasing water storage capacity by re-excavating the canals excavated

under MIP in 1986 and using water resources effectively and efficiently.

1.3 Proposed interventions of the project

The following interventions are proposed under the project

a. Rehabilitation of 22.60 km coastal embankment and re-excavation of 460 km khal (canal)

b. Setting buried uPVC pipes under 850 schemes to irrigate 17000 ha of land and to provide

irrigation by installing prepaid meter and Smart Card system so that waste of water is reduced.

Page 16: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

5

c. The project will construct 850 pump houses and header tanks and supporting outlet chambers

and gas pipes.

d. Electrifying all 850 irrigating pumps for reducing irrigation costs.

e. For further reducing irrigation costs, assessing feasibility of using solar energy in fifty LLPs on pilot

basis.

1.4 Scope of environmental and social safeguard monitoring of MIP

Categorization of MIP for different safeguard issues, environmental factors and reporting

requirements for each category are described below.

(a) Environmental Safeguards: According to ADB’s Safeguard Policy Statement (2009) MIP

under IMIP was categorized B for environment and an initial environmental examination (IEE)

was prepared as the negative impacts are typical to any construction activities involving earth

works which can easily be mitigated through adoption of measures described in the

Environmental Management Plan (EMP). But according to Bangladesh Environment Act (1995)

and Environment Conservation Rule-1997, it was categorised-Red as under MIP modernization

process, natural water flow will be controlled by construction of water control structures. To

meet the requirement of DoE (Department of Environment), Bangladesh an Environmental

Impact Assessment (EIA) study was done and Environmental Clearance (EC) from DoE was

obtained on 30.11.2014. Consultations were undertaken with affected stakeholders and a

suitable grievance redress mechanism (GRM) had been proposed to resolve any project related

grievances. The Grievance Redress Mechanism (GRM) was established during the 5th reporting

period and leaflets were distributed in farmers’ training classes and also pasted in public places

to publicize the GRM. Discussion is also held on environmental safeguard and GRM in farmers’

training classes.

(b) Social Safeguards: The project involves two phases, viz construction phase which is going on

now. After completion of construction phase, operation phase will commence when irrigation

will start. In the construction phase, social issues like labours’ wage, welfare facilities

(accommodation, food, drinking water, first aid and medical facilities), protection against

extreme weather, pest and insect attacks, wage discrimination between male and female

labours, working hours, child labour, forced labour, employment for women and disadvantaged

people, hindrance to community’s movement, community’s safety, disquiet from external

labour, damage caused to privately owned properties etc. have surfaced as more important. In

the operation phase, there may be impact on soil, water and other bio-diversity sectors.

Page 17: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

6

(c) Resettlement framework (RF): The MIP was Categorized as “C” project for involuntary

resettlement in accordance with the ADB’s Safeguard Policy Statement (SPS)- 2009.

Requirement for temporary relocation and resettlement initially envisaged has been avoided

through: (i) modified designs by reducing the cross sections (steeper side slopes) allowing for

some increase in hydraulic in populated area; and (ii) removing the embankment rehabilitation

from the construction program.

A resettlement framework (RF) has been prepared for the entire MFF that would guide the

preparation of resettlement plans for the subsequent tranches, if required. The RF follows the

Government’s laws and regulations and ADB’s SPS (2009), and prescribes for entitlement to

compensation for land acquired and lost assets at replacement cost as well as resettlement

assistances.

During the feasibility study of IMIP in the year 2013/14 most of physical works specially

rehabilitation of coastal embankments, reconstructions /re-sectioning of drainage /irrigation

canal was proposed to be conducted on old/degraded coastal embankment/canals. So there

was no scope of land acquisition or resettlement of houses/structures etc. in MIP area. During

the last few years a number of squatters families settled on the coastal embankments. During

repairing works of the coastal embankment most of them have been resettled locally by the

contractors, the rest of them have resettled themselves on the embankment. Apparently, there

is no resettlement problem now.

(d) Indigenous Peoples Safeguard: The MIP is categorized as C for the Indigenous Peoples

safeguard. There are no Indigenous People as defined for operational purposes by ADB's SPS

(2009) in the Project area and the areas under the subsequent tranche of the Program. As the

subsequent tranche is also categorized as C, an Indigenous Peoples Planning Framework has not

been prepared. So there is no scope of reporting on Indigenous Peoples Safeguard under MIP.

(e) Reporting requirements :To meet ADB’s reporting requirements (a) a semi-annual Social

Safeguard Monitoring Report (in July and December every year) during construction phase and

(b) an annual environmental Social safeguard Monitoring Report (in December) during operation

phase are mandatory to submit to ADB for disclosure. This semi-annual report is submitted to

fulfil the above requirement.

This safeguard monitoring report is the 7th semi-annual report for the period of January to June,

2019. All previous semi-annual reports were submitted to ADB and hoisted to the website of

ADB Bangladesh Mission for disclosure.

Page 18: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

7

1.5 Arrangement for supervision and monitoring of Environment Management Plan (EMP)

implementation.

A Safeguards Desk was specially established on 24 December, 2015 at PMU office for overall

monitoring, verification and reporting to ADB and DoE of the impacts on natural and social

environment. The Safeguard cell consists of 3 members (1 water resources expert, 1 gender and

social compliance expert and 1 environmental monitoring expert, as convener ) as shown below to

support the Monitoring cell with safeguard compliance management.

Composition of the PMU Safeguard Team

Sl

No.

Team members Designation Professional degrees Comments

1 Mr Md. Jahangir

Alam

Mob: O1815006542

Deputy Chief

(Environment &

Forest)

M.Sc. in Forestry,

M.Sc. in

Environmental

Sciences.

Convener

2 Ms. Shahnaz Parvin

Mob: 01712038043

Assistant Chief

(Sociology)

M.Sc. in Sociology, Member

3 Ms. Nusrat Alam

01922527313

Sub-divisional

Engineer

B.Sc. in Civil

Engineering

Member

Project Management and Design Consultant (PMDC): There is a Project Management and

Design Consultant (PMDC) to support the PMU and the PD. PMDC is responsible to support

PMU-Safeguard cell, IMO and PIU for developing capacity to monitoring environmental and

social compliance issues. Contractors are obliged by bid documents/contract agreements to

implement the project EMP, outlined in IEE/EIA report. IMO is responsible for day to day

monitoring and supervising contractor’s activities relating to EMP implementation, recording

any grievances/complaints raised by community/stakeholders/employees/labors and reporting

monthly/quarterly/semi-annually to PMU.

In Feni, there is a PIU. The Executive Engineer (O&M), BWDB, Feni is the Director of the PIU,

responsible to enforce the contractors to implement EMP in the field level and report to PMU

the progress of implementation.

Page 19: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

8

To verify implementation of EMP by the contractors, the Safeguard and Public Relations

Specialist of IMO visits the sites of physical components (khal re-excavation, pump house

construction, sluice gate/regulator construction and repairing, pipe setting, outlet construction,

meter box setting etc.) in the field, speaks to the labours, labours’ leaders, contractors’

supervisors and employees, subcontractors, villagers(Female & male) and others concerned

about the environmental and social safeguard issues and labours’ and villagers’ health and

safety and welfare issues etc. This report reflects status of all those issues going on in the field.

(Details may be seen in table 1 ,2 and 3).

The Safeguard cell in the PMU check up the position during their field visits, consolidates all

reports sent by IMO and PIU and prepare semiannual safeguard report (Construction

period)/annual safeguard report (operation period) and submit to ADB and DoE for disclosure in

their own websites.

Page 20: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

9

CHAPTER 2: ENVIRONMENTAL MANAGEMENT PLAN

2.0 Environment Management Plan

Management of Important Environmental Impacts (IEIs) comprises 3 components like-

(a) Environmental mitigation plan: This part of the plan contains suggestions on mitigation

measures to minimize possible negative impacts,

(b) Compensation plan: Plan suggesting measures required for providing compensation for well

assessed negative impacts which cannot be mitigated,

(c) Environmental monitoring plan: Plan for detecting changes/impacts that may take place due

to the planned interventions in the project.

Environmental Management Plan for MIP as suggested in the concerned EIA report unveils that

during the preconstruction phase there are no adverse impacts, hence no mitigation/monitoring

plan designed for that phase. But during construction and post construction phase there may be

some adverse impacts which need to be mitigated or even compensated. The EIA study was

conducted during the FY 2013-2014 and the report did not show any issues which might be

compensated. But during the implementation period of FY 2016/2017 resettlement of squatter

families on the embankment faced some challenges, but Development Project Plan (DPP) of

IMIP and Bangladesh Environment Act (1995 amended in 2010) do not allow to compensate

squatters. Therefore, the subsequent semi-annual EMRs includes no compensation plan for MIP.

The squatter families who left their dwellings during project implementation in FY 2016/2017

have come back and have managed themselves in re-settling in places which they left before.

The contractors extend possible cooperation.

2.1 Environmental Monitoring Plan

Environmental Monitoring Plan was prepared under Environmental Impact Assessment (EIA)

process of MIP. Before preparation of EIA report BWDB prepared an IEE report which fulfill the

requirements of ADB’s Safeguard Policy Statement(SPS)-2009.According to ADB’s SPS (2009),

meeting the country’s (Borrower) environmental and social compliance is mandatory.

2.2 Implementation Arrangement of Environmental Monitoring Plan

Responsibilities and scope of work of each of the agencies involved in implementation

arrangement are described below.

Page 21: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

10

(a) IMO is responsible to conduct the day to day monitoring and supervising the

implementation of environmental and social safeguard issues and keeping concerned

records of activities like progress, complaints and grievances from labours, community

people, farmers, etc. IMO is also responsible to consolidate those daily records as monthly

and quarterly reports and submit it to PMU-Safeguard cell. The Safeguard and Public

Relations Specialist of IMO has to monitor the contractor’s responsibility(as delineated in

their contract) to comply concerned issues like international labour law, occupational health

and safety measures and social safeguard compliance in respect of labours and employees as

well as community people etc. and report accordingly. Non-compliances observed are first

discussed with contractors/ contractors’ representatives for remedies. If problem continues

due to non-compliance, the matter is reported to Director, PIU with request to take

necessary actions.

(b) PIU : Director, PIU is responsible to ensure the implementation of EMP by contractors and

enforce them to implement EMP and record & report monthly and quarterly to PD, PMU in

case of any grievances raised and breaches made in implementation of EMP by contractors.

(c) PMU (Safeguard cell) is responsible to oversee the entire safeguard implementation process,

consolidate those in monthly and quarterly reports and inform PD, MIP/IMIP for necessary

actions and finally prepare & submit Semi-annual/annual Safeguard Report for ADB and DoE

.

(d) PMDC has the responsibility to strengthen PMU-Safeguard Cell, PIU, IMO, contractors and to

develop their capacity for implementing/monitoring/supervising/reporting of environmental

and social safeguard issues of MIP by providing necessary training, guidance and

demonstrations etc. PMDC was supposed to train and build up capacity both of PMU and PIU

for safeguard monitoring (but so far, they have not taken any such actions). For proper

implementation and monitoring of EMP, more active role of PMDC is desirable.

Page 22: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

11

Table -1 : Implementation Status of Environmental M0nitoring Plan (EMP)

Nr. Actio

n

Resource

impact

Mitigation

measures

Responsibility

Status of implementation

upto June,2019

Implement

ation

Monitor

ing

Cost

A Impacts on Water Resources During Design

A1 Khals

have

adequ

ate

capaci

ty to

meet

long

term

draina

ge

needs

Extreme

rainfall events

including

climate change

may cause

flooding and

damage

Technical

design of the

khal to be

based on 1:25

year return

period

(increased

from 1:10 year

return period)

to incorporate

provision for

climate

change. Over

excavation not

recommended

as this will

increase

sedimentation

rate.

PPTA

design

consultant

during

2013

BWDB

Design cell

PPTA

budget

Khal re-excavation is

supervised in site by IMO

and BWDB to ensure that

technical design is

followed as per plan.

Contractor’s site

engineers, supervisors

and digger operators are

reminded to follow the

design strictly. So far, no

spectacular violation has

been noticed.

A2

Impro

ved

water

The use of pipe

distribution

may reduce

Develop

appropriate

plan for

PMDC will

conduct

ground

PMU and

IMO to

monitor

Loan

fund

After starting irrigation

through underground

pipes which has not yet

Page 23: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

12

efficie

ncy

will

reduc

e the

rechar

ge to

the

groun

d

water.

the ground

water

recharge.

Improved

surface water

management

will, however

reduce

demand from

ground water

conjunctive

ground water

use

studies ground

water use

and levels

commenced, PMDC

would conduct study on

ground water levels.

Based on the findings of

the study necessary

actions will be taken by

BWDB and IMO as per

EMP. Farmers are being

trained/made aware

about better water

management including

W& D method to

reduce demand for

underground water.

B Impact on soil resources during design

B1 Re-

excav

ation

of

khal

includi

ng

remov

al of

vegeta

tion or

felling

of

trees

Re-

excavati

on of

khal

includin

g

removal

of

vegetati

on may

increase

instabili

ty of

khal

banks

Khal side slopes

to be kept a

1V:15H in order

to ensure

stability. Contract

document to

specify correct

cutting

procedures

Khal re-

excavation by

Contractrors

Tree

plantation by

DoF

IMO Included in

construction

contract

-Design instructions

with respect of slope of

canals and depth are

followed. In spite of

that land slide

sometimes occur in

some canals after re-

excavation apparently

due to sandy nature of

soil. (Photos were given

in previous reports). In

the reporting period, no

landslide have been

noticed or reported.

(Photo 1 &2 of re-

excavated canal may be

seen below).

-Vegetation including

bamboo clusters

Page 24: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

13

standing on the canal

bank is removed/cut if

absolutely unavoidable.

- For planting new

saplings by Department

of Forest(DOF) in the

ratio of 3:1 as per EMP,

the Project Director,

MIP has been

requested to arrange

with DOF. As per EMP,

DOF will plant saplings

and C-IMO will monitor.

PMU/IMO have planted

2000 saplings on the

bank of NC31F canal in

Chhagalnaiya Upazila in

2018. The condition of

the saplings is good.

(Photo No. 5 & 6 below

may be seen). IMO

sent a proposal to plant

another 10,000 (Ten

thousand) saplings on

the bank of re-

excavated canals in

2019 under “Pilot Cost

Recovery Programme”

by employing

contractors as in last

year. PMU has

instructed IMO to

implement the plan

with the help of

stakeholder groups.

Due to heavy workload

of IMO field staff, PD

Page 25: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

14

has been requested to

consider the present

workload of the field

staff. If they are

engaged in tree

plantation, other

project works will

suffer.

Figure 1 : No land slide in re-excavated canal Figure 2: No land slide in re-excavated canal

Page 26: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

15

Figure 3 : A little land slide due to sandy soil

Figure 5 : Plants on NC31F khal bank

Figure 4 : A lit land slide due to sandy soil

Figure 6 : Plants on NC31F khal bank

Page 27: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

16

B2 Placing/di

sposal of

soil

material

from khal

re-

excavatio

n/

construct

ion of

sluice

gates,

pump

houses,

header

tanks,

and

buried

pipe

setting,

etc.

Soil

material

not

properly

manage

d can

slip back

into khal

or

encroac

h onto

farmers

fields

Spoil

managemen

t will be

decided by

the IMO

during the

implementa

tion period

depending

on the

availability

of land for

placing the

spoil. Most

spoil will be

placed on

the banks

but

uncontamin

ated spoil

with the

correct

constituency

can be used

for fill for

housing or

spread on

the fields.

Contractor IMO Included in

construction

contract

The excess spoil generated

from excavation of khal is

reshaped by contractors as

canal bank cum walking road.

In most of the places earth is

used by the nearby farmers

for heightening their

homestead and cultivable

lands. (Photo no. 7 & 8 Spoil

earth generated temporarily

while setting underground

pipes are used to re-fill the

trenches after completion of

pipe setting. Spoil generated

is not much.(Photo no. 11

may be seen below). If there

is any excess spoil earth after

re-filling of trenches, the

farmers use them to raise

their land. During site visit,

the Safeguard Specialist

watches the management of

spoil earth and enquires with

the community people. If

there is any crop damage or

temporary interruption on

cropping, it is locally solved.

So far, only one complain was

received from Madhuai sluice

gate. (GRM section may be

seen)

Page 28: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

17

Figure 7: A woman says, she needs the spoil for a new house

Figure 9: Safeguard Spl. discusses khal re-excavation matters

Figure 8: Spoil piled up near a house according to request

of the stakeholder

Figure 10: No excess spoil piled up on the bank of same

khal

Page 29: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

18

B3 Soil

borrow

areas for

rehabilitat

ion of

coastal

embankm

ent /re-

sectionin

g of

canals

/construc

ting road

for

moveme

nt of

machines

/ for

heighteni

ng the

land for

pump

house &

header

tank

construct

ion etc.

Soil

borrow

areas

for the

coastal

embank

ment

can

cause

instabilit

y of

embank

ment

resultin

g areas

of

excavati

on will

be filled

with

water

and can

be

breedin

g

location

for

mosquit

oes etc.

Soil to be

sourced

from the

existing land

adjoining

the coastal

embankmen

t.

Soil borrow

areas will

have set

back not

less than

8 m from

the toe of

the

embankmen

t.

Borrow

areas to be

from

existing

BWDB land

along the

coastal

embankmen

t and where

appropriate

to be used

as fish

ponds

Contractor IMO Included in

construction

contract

Social

forestry

from loan

funds

Soil is normally sourced from the

existing land of BWDB adjoining

the coastal embankment.

It has been noticed that

stakeholders sometimes, allow

such borrowing of soil from their

land wilfully. If any case of

borrowing soil from stakeholders’

land without their consent is

noticed, they are advised to

lodge complain to the Upazila

Grievance Redress Committee.

In farmers’ training

class/consultation session the

matter is discussed and they are

advised to submit their complain,

if any, to the GRM Upazila

committee.

The matter of soil borrowing

areas of becoming breeding

location for mosquitoes, is being

observed. Necessary actions will

be taken, when needed.

Page 30: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

19

Figure 11: Soil is borrowed for embankment repair from a stakeholder's land with his consent

Page 31: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

20

C Construction impacts

Page 32: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

21

C1

Excavati

on, re-

excavati

on,

filling,

and

finishing

of

earthwo

rks

The

implement

ation work

will involve

a mix of

manual

labor and

machinery.

Dust,

fumes and

noise in

the vicinity

of the

works.

Reduce

ambient

dust levels

by spraying

water.

Remove

constructio

n debris

and

dispose of

in an

approved

location

Contract

or

IMO

Included in

Construction

contract

The canal beds are wet, quite

often it rains and resultantly dust

was not noticed significantly

during any site visits. Also in the

embankment site, no significant

dust was noticed.

As per instruction machines are

not operated at night near

human habitats.

During field visit the Safeguard

Specialist checks with

community people about

air/sound/smoke pollution

through generation of noise,

smoke emission and sound due

to operation of machines/running

of project vehicles. They replied

that they face no such problem.

Page 33: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

22

C2 Constru

ction

activitie

s near

and

inside

the

commu

nity

areas

Constructio

n vehicles

and

machines

can disturb

the local

community

Select

machinery

and vehicle

transport

routes

away from

communiti

es.

Avoid

operation/r

unning

machine in

the night

close to

community

households

.

Contract

or

IMO Included in

construction

contract

Excavating machines are not

operated at night near

community households.

The canal beds are wet, quite

often it rains and resultantly

dust was not noticed

significantly during any site

visits.

During field visit by the

Safeguard Specialist,

air/sound pollution through

generation of noise and

dust/smoke emission is

checked by enquiring with

community people. They

replied that they face no such

problem.

Page 34: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

23

C3 Operati

on of

constru

ction

vehicles

/machin

es

Air and

noise

pollution

Adequate

maintenan

ce of

vehicles/

machines

Contract

or

IMO Included in

construction

contract

Contractor’s employees have

been made aware of this with

request to maintain machines

and vehicles properly to avoid

air, smoke and noise pollution.

The instructions are followed.

The contractors’ employees

(including one contractor)have

been given training on

environment and social issues

and related matters.

C4 Impacts

on

archaeo

logical

sites,

graveya

rds or

other

commu

nity

heritage

and

artifacts

Not

envisaged

Ensure the

constructio

n

companies

have

understand

ing. If

archaeologi

cal

remains

are found

work has

to

23immedia

Contract

or

IMO,

BWDB

Included in

construction

contract

No such archaeological sites,

graveyards or any community

heritage and artifacts have so

far, been noticed. Necessary

actions as per plan will be taken,

when needed.

IMO has been informed that re-

excavation of khals with

machine may damage two

Christian prayer houses. The

concerned FOM has been

requested to inform the details.

Necessary actions will be taken

Page 35: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

24

tely stop

until

impact

verified by

Departmen

t of

Archaeolog

y

on receipt of detail information.

D1

Drainag

e may

remove

wetland

areas

There are a

few low

lying areas

of

wetlands

Very low

land will

not be

connected

to drainage

facility

PPTA

Design

consulta

nt

BWDB

Desig

n

office

PPTA Budget

Till now no such

wetlands/pockets likely to be

removed due to drainage has

been noticed. This will be done

as per plan with the help of

PPTA and BWDB design offices

Page 36: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

25

D2 Re-

excavati

on and

removal

of

vegetati

on from

khal

may

affect

fish

breedin

g

The

vegetation

along the

khal

provides a

refuge for

fish

Secondary

vegetation

will quickly

regenerate

Only

strictly

unavoidabl

e

vegetation

and trees

should be

removed.

Contract

or

IMO Budget

provided in

IMO contract

Removal of vegetation and trees

during canal re-excavation is

made only when it is

unavoidable.

No adverse effect on fish

breeding has so far, been

noticed or reported. Necessary

actions will be taken, when

needed.

Page 37: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

26

E1 Soil

degra

dation

due to

poor

on-

farm

mana

geme

nt

Intensive

agriculture

may cause

soil

exhaustion

and soil

toxicity due

to chemical

usage and

lack of

knowledge

among

farmers.

Appropriate

soil

management

and soil

testing

systems and

educate

farmers on it.

Repeated

information

sharing on

good

agriculture

and soil

management

practices.

IMO will

provide

agricultur

al

support

P

M

U

Include

d in

IMO

contrac

t

Farmers are being made aware of

the risks of Soil degradation due to

poor on-farm management during

training/ consultation session. The

curriculum includes soil fertility,

land productivity, social forestry,

integrated pest management etc.

During operation phase, soil testing

will be done, if situation so

demands.

E2 Increa

sed

agrich

emical

s in

surfac

e and

groun

d

water

syste

ms

and

reduc

ed

qualit

y of

return

flows

Increased

use of

agrichemic

als

envisaged

to meet

target of

intensificati

on and

increasing

yields

Farmer’s

education on

proper use

and

management

of

agrichemicals

including

their waste.

Ensuring a

farmer-

friendly

method for

disposal of

agrichemical

waste as

indentified

during

project

design

IMO will

provide

agricultur

al

support

PMU Include

d in

IMO

contrac

t

Farmers’ training curriculum

includes Integrated Pest

Management (IPM) and topics on

adverse impacts of excessive

agrochemical use with a view to

reducing the adverse impacts of

using excess agrochemicals, and

pesticides.

Page 38: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

27

F Social Impacts

F1 Work

ers/la

bor

camps

and

faciliti

es

with

drinki

ng

water

and

sanita

tion

External

labor can

cause

disruption

and

disturbanc

e

Provide

appropriate

shelter and

other facility

for labor

brought

from

outside.

Ensure no

conflict with

local

population

due to labor

camp.

Provide

sanitation

and waste

managemen

t facilities

Contract

or

IMO Include

d in

IMO

contrac

t

For accommodation of external

labours, in some work sites

temporary labour sheds with toilet

and drinking water facilities (Tube

wells) are constructed in work sites

at safe distance from the

community. (Photo No. 13 & 14,15

16 below).

In some work sites, normally in the

vicinity of town or market place,

accommodation for labour is hired

by the contractor with these

facilities.

Talk to labours about these

arrangements during site visits, if

there is any complain, the

contractors are requested to solve

the problems and the requests are

complied.

The labours are kept under strict

supervision and advised not to

create any disturbance/social

disquiet for the local community.

During site visit by the Safeguard

Specialist, this matter is enquired

with the local community. There was

no complain in the reporting period.

Page 39: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

28

Figure 12: Constructed labor shed in South

Doulotpur regulator in Fulgazi Upazila

Page 40: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

29

Figure 13 : Tube well sunk for drinking water of labors Figure 14: Labors' toilet built at safe distance from

In South Doulotpur sluice gate site community

Page 41: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

30

b) Impacts and management plan implementation status with specific reference to canal re-excavation

/repair of coastal embankment/construction of pump house/header tanks/underground pipe setting etc.

1 C

on

stru

ctio

n P

ha

se

Construction of cross

bundh (dam) across

khals/for sluice gate

construction/re-

excavation of canals

Temporar

y

obstructio

n of water

flow in

some

khals.

Mitigation measures

not needed as the

Impacts are temporary

& insignificant.

Co

ntr

act

or,

IM

O,

BW

DB

N

ot

ap

pli

cab

le

The problem of temporary

obstruction of water flow due

to construction of cross bund

(dam) is minimized locally. In

some cases, the water flow of

canals is diverted, where

possible. Progress in sluice

gate construction is slow.

There were some over flow of

water resulting inundation of

roads and surrounding areas.

Quick action was taken to

solve the problems. The site

engineers have instructions

to remain careful about this

in future.

2

Co

nst

ruct

ion

Ph

ase

Re-sectioning of

coastal embankment

as per design

Risk of

sliding

down of

steep

slope of

embankm

ents and

loss of

communit

y people

and

properties

Strictly maintenance of

design instructions to

avoid such situations.

Co

ntr

act

or,

IM

O,

BW

DB

Contractors maintain the

designed slope. Side slope will

be maintained strictly before

completion of construction

work.

Page 42: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

31

Figure 15: Present condition of top surface and slope of embankment where repair work has

been done.

Page 43: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

32

3 P

ost

co

nst

ructi

on

ph

ase

Risk

of

dryin

g out

of

wetla

nds

throu

gh

drain

age

khals

.

Loss

of

wet

lands

with

aqua

tic

lives

Pos

sibl

e

wet

lan

ds/

poc

ket

s

will

be

disc

on

nec

ted

fro

m

the

dra

ina

ge

kha

ls

IMO

, B

WD

B

No

t a

pp

lica

ble

Till now no such wetlands/pockets

having aquatic lives with risk of

drying out due to re-excavation of

khals have been noticed. Necessary

measures will be taken, if such

problem arises.

Page 44: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

33

4

Keeping

the khal

dry about 3

months for

excavation

Risk of

dying some

aquatic

non fishery

animals

though the

residual

impact is

non

significant.

No

feasible

mitigatio

n

measures

are

applicabl

e but any

ecologica

lly

importan

t species

spotted

during

the

operatio

n should

be

released

safely to

nearby

water

bodies

Con

trac

tors

/

IM

O

Not

app

lica

ble.

.

No important species of wild life/aquatic

non-fishery animals under threat have

been noticed during re-excavation of

khals . In most cases, the khals are not

fully dried before re-excavation.

IMO field staff and contractor’s

employees have been made more aware

of the matter in their training.

Page 45: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

34

5 Re-

excavation

of canal

where

houses

have been

constructe

d just on

the bank of

canals.

Due to

operation

of the long

boom

excavating

machine

the houses

are likely

to be

partially or

fully

damaged

or it may

fall on the

canal,

making the

residents

homeless

To save

the

houses

contracto

r’s

employe

es are

asked to

excavate

that

portion

of the

khal

manually.

The contractor’s employees are advised

to re-excavate the canal manually, where

possible, and that is done accordingly

(where possible) causing no damage to

the house.

Two women whose houses stand on the

bank of khal applied to save their houses

while re-excavating khals. (Photos shown

below). Director, PIU has been requested

to advise contractors to re-excavate the

canal manually. Copy of letter has been

given to FOM who says he can do the

needful by showing the letter to the

contractors.

Recently, some applications have been

received with request to save their

residential houses/prayer houses from

likely damage.

Concerned FOM has been requested to

inform IMO with photographs/papers for

taking necessary actions.

Page 46: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

35

Figure 16: Two houses stand on the bank of khal

Page 47: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

36

6 Careless

operation

of

machines,

disregard

to labour’s

rights and

rights of

the

community

people by

the

contractors

/sub-

contractors

and to

environme

ntal factors

Stake

holde

rs &

com

munit

y

peopl

e may

suffer

loss/d

amag

e,

adver

se

effect

on

envir

onme

nt

and

violat

ion of

rights

of

labou

rs,

wom

en

and

disad

vanta

ged

class

may

occur

Establish

ment of

GRM,

informing

stakehold

ers and

communit

y people

and

others of

their

rights and

the

remedial

measures

available

in the

project

through

GRM IMO

/BW

DB

The GRM has been established in all

project Upazilas with detail instructions

to the FOMs.

Leaflets on GRM were distributed among

the stakeholders in training classes and

also were pasted on various public places.

In farmers’ training classes/consultation

sessions /individual interviews, the

establishment of GRM is shared with the

trainees.

During site visit, the Safeguard Specialist

enquires with community people about

their inconveniences, if any and the

labours and contractor’s employees

about wage level, labour’s rights and

facilities and takes necessary actions

accordingly.

Page 48: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

37

7 P

ost

co

nst

ructi

on

ph

ase

Indiscrimin

ate

application

of

agrochemic

als like

fertilizers

and

pesticides

by farmers.

Redu

ction

of

land

fertili

ty

follo

wed

by

land

produ

ctivity

and

loss

of

biodi

versit

y

Conductin

g

integrated

farming

training to

farmers to

reduce

such

adverse

impacts.

IMO

, B

WD

B &

DA

E

Incl

ud

ed

in

th

e I

MO

co

ntr

act

Farmers are being made aware of the

associated risks during

training/consultation session. The

curriculum includes soil fertility, land

productivity, social forestry etc.

Integrated Pest Management(IPM) has

been incorporated in farmers’ training

curriculum to reduce the adverse impacts

of using excess agrochemicals and

pesticides.

8

Po

st c

on

stru

cti

on

ph

ase

Promoting

crop

intensificat

ion/

diversificati

on

Non

divers

ificati

on

may

impac

t

proje

ct

target

negat

ively.

Training

of

stakehold

ers on

modern

farming

practices/

crop

diversifica

tion shall

be

ensured

IMO

, B

WD

B,

DA

E

To

be

in

clu

de

d in

IM

Os

con

tra

ct

Training of stakeholders on modern

farming practices, cropping intensity,

crop diversification to high value crops is

going on and will continue. Agriculture

extension services will be given more

emphasis and demonstration plots will be

established with diversified crops in

cooperation with Department of Agriculture

Extension.

Page 49: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

38

9 C

on

stru

ctio

n P

ha

se

Re-

excavation

of

canals/con

struction of

sluice gate

etc.

Land

com

muni

catio

n by

local

peopl

e

/vehi

cles

over

the

canal

s will

be

hinde

red.

Impact is

temporary

The foot

over

bridges

should be

re-

sectioned

/rebuilt to

ensure

the

proper

sectioned

of canals. C

on

tra

cto

r, I

MO

, B

WD

B,

Incl

ud

ed

in

th

e B

oQ

est

ima

te

Existing foot over bridges constructed

over the canals by other government /

private agencies have been kept intact ,

so far.

Small foot bridges have also been

constructed by the contractor to facilitate

walking of the villagers. (Photos below)

While constructing sluice gate No.7,

temporary inconvenience has been

caused to movement of small traffic. Cost

of concreting was not included in the

original estimate. A project variation

proposal incorporating the cost was

submitted. The budget has been

approved. Work of concreting will start

soon.

Page 50: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

39

Figure 17: Existing foot bridge kept in tact

Figure 19 : Small temporary bridge bridge built for

community people

Figure 18: Existing foot bridge kept in tact

Figure 20 : Small temporary bamboo bridge built for

community people

Page 51: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

40

10 Earth work

and structural

works during

implementati

on of the

project

Increa

sed

opport

unity

for

emplo

yment

special

ly for

sociall

y

disadv

antage

d class

Social safeguard

measures

provided for

enhancement

program.

Co

ntr

act

or,

BW

DB

, IM

O,

WM

G

Incl

ud

ed

in

th

e B

oQ

- Contractor’s part of re-

excavation is done by long boom

excavators as manual excavation

is not suitable in watery canal and

excavation by manual labour is

expensive.

- Twenty five percent of labour

intensive part of works i.e., earth

work/khal re-excavation are

allocated to WMGs with

instruction to perform the works

by the LCS of disadvantaged class

of people. But WMGs prefer to

re-excavate with excavating

machine because of the reasons

explained above(Photos given in

the previous report).

Page 52: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

41

11 Establishment

of brick field

within the

command

area of

schemes.

Establi

shing

brick

field in

agricul

tural

land is

agains

t

enviro

nment

al

laws.

This

also

reduce

s

comm

and

area

of the

schem

e,

hampe

rs

produ

ction

and

causes

waste

of

Govt.

money

.

Stop

manufacturing

of bricks of the

said brick field

and keep watch

to stop

establishing new

brick fields.

IMO

, B

WD

B

Director, IPU has been requested(

with copy to PD )to suggest /take

necessary actions. In the second

ICC meeting, this was given as an

agenda. Till now no action is

visible. The matter has been

reported to PD.

Page 53: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

42

12 Obtaining

0.86 decimal

of land from

farmers on

donation

basis.

Land

may

be

obtain

ed

forcibl

y or

volunt

arily

witho

ut

conse

nt of

family

memb

ers or

from

margi

nal

and

small

farmer

s

violati

ng

ADB’s

SPS-

2009.

Signature on a

land donation

agreement is

obtained from

the donor. This

document

contains all the

necessary

protective

conditions as per

SPS-2009.

IMO

,BW

DB

A bi-annual Due Diligence Report

(DDR) is prepared following ADB’s

guidelines and submitted to ADB

on the land donation agreements

(LDA) received during the period

of reporting. Third DDR has been

submitted to PMU.

The process of obtaining land

donation agreements as per rule

is continuing for construction of

new pump houses. While

obtaining the LDA, ADB’s

guidelines are followed. In most

cases the land owner allows

construction of pump house on

his land but refuse to sign the

LDA, this may lead to some

problems (Dominance by land

owner) in operation phase. So far,

81 pump houses have been

constructed. Of these 52 on

Govt./BWDB land and 29 on

private land. Out of 29 private

plots, 14 LDAs have been

received.

Page 54: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

43

13 Installation of

pumps on big

farmer’s land

mostly on the

land of

previous

pump

owners/

water sellers

(and they are

refusing to

sign the LDA)

Domin

ance

of the

farmer

s on

whose

land

the

pumps

are

being

install

ed, is

appre

hende

d.

Small

farmer

s are

habitu

ated

to pay

after

harves

t. It

may

happe

n in

many

cases

that

the

farmer

on

whose

land(P

reviou

s

water

seller)

the

pump

is

being

install

ed and

pump

Strong extension

and motivation

work reaching

beyond WMGs

and the (big

farmers’ is

suggested.

During operation

phase, the

supervising

personnel have

to guard against

such profit

mongering

activities of big

farmers.

BW

DB

/IM

O

This problem is now

apprehended. Authorities may

think over the matter. Actions as

suggested here will be taken

during operation phase. But this

may not solve the problem.(If big

farmers’ dominance cannot be

controlled, reaching the goal of

poverty reduction will be

hampered).

Page 55: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

44

14 Ingress of

imported

external

labour force.

Social

disqui

et or

distur

bance

by

extern

al

manp

ower

breaki

ng

peace

of

local

people

.

External labour

force are kept

under strict

supervision and

compelled to

obey local

customs and

disciplines of the

state.

Co

ntr

act

or

(be

en

forc

ed

by I

MO

, B

WD

B)

Incl

ud

ed

in

th

e c

on

tra

cto

r’s

bil

l For construction of sluice gates,

regulators, pump house, header

tanks, outlets, and pump/pipeline

setting, external labours are also

employed in addition to local

labours. They are kept under

strict supervision and advised not

to create any disturbance for the

local community or social

disquiet.

During site visit by the Safeguard

Specialist, this matter is enquired

with the local community. So far,

there was no complain except in

one case, occurred more than a

year ago, which was solved locally

by the contractor.

Page 56: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

45

15 P

ost

co

nst

ructi

on

ph

ase

Implementati

on of planned

activities in

the project

Incom

e

genera

ting

activiti

es of

agricul

ture

etc.

will be

increa

sed,

povert

y will

be

reduce

d

Impact is

positive. Access

to micro

credit/Agricultur

e support

services

provided by

IMO.

Do

C,

NG

Os

two

No

t A

pp

lica

ble

Canal re-excavation, pump house

construction, electrification

works etc. is going on. After

installation of pumps and

connection of electricity,

agricultural support services will

be made available. Where

needed, IMO will provide

necessary assistance to link with

micro credit sources.

The present training curriculum

includes fish culture in ponds and

canals/duck farming/growing

vegetables & fruits on bamboo

fences over the canal, social

forestry etc.

FOMs of all the project upazilas

were instructed to submit two

schemes per upazila for fish

cultivation in re-excavated khals.

Necessary guidelines, formats

were given. Ultimately, only on

scheme has been received. Other

FOMs have informed that

stakeholders are not interested in

cultivating fish in re-excavated

khals.

.

Page 57: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

46

2.3 Monitoring of implementation status of Environmental Health and

Safety Plan(HSP)

During field visits of Safeguard & Public Relation Specialist all concerned parties like male (and

female labours if any,) labour-leaders, contractors & their supervisors, sub- contractors and

community people are contacted and discussed about these issues. The findings of monitoring of

implementation status of HSP are stated below (Table-2)

Table 2: Monitoring of Implementation Status of Environmental Health and Safety Plan

Sl

No

HSP

Parameters

to be

Monitored

Methods Frequency Respo

nsibilit

y

Monitoring Status upto December June,2019

1 Safety

indication/sig

n boards in

work sites

Physical

observation,

testing

fitness of

equipments

and

discussion

with the

laborers /

Workers.

Once at the

beginning of

construction

works

Contra

ctor/

IMO

Safety indication is hardly found in the

site during field visits.

The matter has been reported to the

Director, PIU for requesting the

contractors to put safety indication

/signboard in the work site.

During site visit, this is pointed out to the

contractor’s employees.

In the recent training of contractors and

their employees this was discussed and

they have been requested to put safety

indication/sign boards in work sites

However, no complaint was raised by

local people in this matter.

2 Safety

measures for

labours in

their work

Accidents

may occur

Making

labours

aware of the

danger and

taking

precautionar

y measures

by the

Co

ntr

act

or

No visible safety measures for labors in

the work site is noticed. It seems, neither

labors nor their employers are concerned

about it. The matter of labors’ safety was

discussed in training of contractors’

employees.

During site visit, labors are cautioned

about possible dangers, when noticed.

Page 58: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

47

contractors

3 Temporary

accommodati

on for

workers/

personals of

contractors

Physical

observation

Once in every

site during

working

Contractor

/ IMO Labour sheds are constructed in some

sites. Accommodation of labors are

also hired by the contractors/sub-

contractors These are physically

observed by the Safeguard Specialist

and Field Office Managers during site

visit. The issues of accommodation,

drinking water facilities etc. are also

discussed with the labors. At present,

they have no complain. (Photos may be

seen under item F1 in table-1 of

Implementation Status of EMP) .

4 Sanitation

facilities like

temporary

toilets,

Physical

observation and

discussion with

the laborers /

Workers

Weekly

or

monthly

Contractor

/ IMO During his site visit, the Safeguard

Specialist physically observe

sanitation facilities like temporary

toilets and also enquire with the

labors about toilet and drinking water

facilities etc. In some sites, temporary

toilets are made, tube wells are

installed or drinking water from

nearby hand tube wells is arranged.

Labors have no complain.(Photos of

toilet and tube well may be seen

under item F1 in table-1 of

Implementation Status of EMP). ).

5 Medical

facilities like

first aid,

emergency

transport

facilities for

carrying

injured

personals to

Physical

observation and

discussion with

the laborers /

Workers

Day to

day

monitor

ing

Contractor

/ IMO No first aid box or emergency

transports are maintained in the

construction sites. In the training

class of contractors’ employees, the

matter was discussed. In general,

they agreed to do it.

Labors are not aware of the medical

facilities that would be available to

them in case of sickness. They expect

Page 59: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

48

hospitals etc. that the contractor/sub-contractor

will arrange treatment if there is any

accident. Some minor accidents

occurred in the past and the

contractor/sub-contractor took the

labor to the doctor for treatment.

These matters have been reported to

the Director, PIU for requesting the

contractors to provide these things as

per contract. Discussion was also

made in training of contractors’

employees/contractors.

6 Protection

from extreme

weather

conditions

and pests or

insects

Physical

observation,

inspection and

discussion with

the laborers /

Workers

Day to

day

monitor

ing

Contractor

/ IMO During site visit, these are discussed

with the labors and contractors/sub-

contractors and they are requested to

solve the problems like lack of fans in

labor sheds in extreme hot weather,

dropping rain water through roofs

etc. On request, contractors solved

the problems, so far.

The matter of pests or insect attack is

also discussed with labours. So far, no

complain has been received.

7 HIV/AIDS

awareness

among the

labors & local

community to

avoid risk of

transfer of

the HIV virus

between and

among the

Contractors’

personnel and

*Conducting

HIV/AIDS

awareness

program by the

Contractor via an

approved service

provider.

*Discussion with

labors and the

local community.

Awaren

ess

progra

m

should

be

organiz

ed once

in all

sites for

all

labors.

Contractor

s to

organize

awareness

program

- BWDB to

enforce

the

Contractor

s to

perform

C-IMO to

HIV/AIDS awareness program not yet

organized by contractors as per

contract.

The Director, PIU has been

approached for requesting the

contractors to organize this as per

contract.

Observing the real situation,

contractors employees have been

given training on HIV/AIDS

awareness. They have been

requested to make their labors & the

Page 60: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

49

local

community

If new

labors

are

importe

d from

outside,

this

progra

m

should

be

repeate

d.

monitor

holding of

awareness

program

and to

assess the

result by

discussing

with the

labors and

the local

communit

y

local community aware of this.

8 Child labors

/Forced

labors

Physical

observation and

discussion with

the laborers /

Workers

Day to

day

monitor

ing

Contractor

/ IMO Only in one case (In sluice gate No. 9),

a boy engaged in earth work seemed

under aged. However, contractor’s

employees have been made aware of

this and requested not to employ any

child labor.

No instance of forced labor has so far,

been noticed or reported.

9 Discriminatio

n of laborers’

payment and

low wage

paid to some

labors.

Discussion with

the laborers /

Workers

Daily or

weekly

Contractor

/ IMO In three work sites female labors

were employed, in two sites low

wage was paid compared to male

labors. Also low wage was given to

male labors in several different work

sites (Tk.350.00 was paid against

reasonable was of Tk.450.00 or

more).

Director, PIU was requested to ask

the contractor/sub-contractor to

make no such wage discrimination

between male and female labors and

to pay a reasonable rate of wage to

all labors.

Safeguard Specialist requested the

Page 61: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

50

contractors/sub-contractors to raise

the wage level and monitored it. Now

the amount of wage given is

reasonable(Tk. 500.00 or more) and

labors are satisfied/have no complain.

10 Working

hours

Discussion with

the laborers /

Workers

daily or

weekly

Contractor

/ IMO Labors work normally 8 hours from

08.00 A. M. to 05.00 P.M. This

includes lunch and prayer break (For

about an hour). If labors work

overtime, they are paid. There is no

complain of working overtime

without payment.

11 Engagement

of local

laborers

Discussion with

local laborers /

Workers

daily or

weekly

Contractor

/ IMO

Both local and external labors are

employed.

In training/consultation sessions,

trainees/participants are requested

to inform their distressed neighbors,

male or female of the employment

opportunity in implementation of

MIP. Local female labors are not so

interested in this kind of job outside

homes. Local male labors have better

opportunity in agriculture.

12 Tube well for

drinking and

washing,

bathing etc.

Physical

observation and

discussion with

the laborers

Once in

every

site

during

working

Contractor

/ IMO

In some sites, contractors have

installed tube wells for supplying

water to labors(Photo under F1 in

table-1).

In some other sites, labors drink

water from tube wells of nearby

mosques. Accommodation hired by

contractors have arrangements of

water for washing/bathing/drinking.

The Safeguard Specialist enquires

about this with the labors during site

visits. In Madhuai sluice gate site, the

tube well first installed went down

Page 62: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

51

huge quantity of soil when canal was

re-excavated. On request of

Safeguard Specialist, the contractors

installed another tube well to supply

drinking water because drinking

water was not available within half

kilometer.

Page 63: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

52

2.4 Monitoring implementation status of Grievance Redress Mechanism

In pursuance of ADB’s Safeguard Policy Statement(SPS)-2009, a Grievance Redress

Mechanism(GRM) detailing the objectives (Needs and benefits), scope (aspects or areas to be

covered e.g. excessive dust, noise, smoke, spoil, debris, solid waste etc. and social safeguards

regarding wages and welfare facilities etc. of labors), coverage of different stakeholders (Affected

community people, labors, other employees, women, children, other vulnerable

groups/disadvantage class of people), procedures for receiving complains, committee structures,

disposal of complains, provision for appeal etc., forms of registers to be maintained was sent to

Field Office Managers (FOMs) with detail instructions to establish the GRM. Accordingly, GRM was

established in all project Upazilas.

For publicity of the GRM, 6000 leaflets containing the messages about the GRM and the main

project activities were printed and these were distributed among the stakeholders in training

classes and also displayed in public places .

A Bangla translated version of the GRM in brief was sent to the offices of FOMs. If stakeholders

want to know the GRM procedure, they can get a photo copy of this.

Besides, in almost all farmers’ training classes/consultation sessions, GRM is discussed by the

Safeguard Specialist with advice to submit application to the FOM of concerned upazilas and inform

the Safeguard Specialist for pursuing.

Complains received and pending for resolution

One stakeholder has submitted a complain stating that his poultry farm built on his private land has

been damaged during khal re-excavation (Photo may be seen below). A number of stakeholders,

mostly women complained that their houses built on their private land have been partly demolished

during khal re-excavation. Concerned FOM has been requested to come to IMO with necessary

information for discussion.

Page 64: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

53

Figure 21: Houses damaged during khal re-excavation

Figure 22 :Poultry farm and house damaged during khal re-excavation

Page 65: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

54

Figure 23: A woman complains about damaging her house during kahl re-excavation

Pending cases for compensation

i. In Madhuai sluice gate site huge construction materials were kept on the crop land of a farmer

who could not cultivate his land. FOM, Feni Sadar Upazila was instructed to take action on this

application. The contractor first agreed to pay compensation. After several months of waiting, he

refused to give any compensation.

This contractor participated in the recent training of contractors’ employees. After long discussion

with him by the Safeguard Spl. he agreed to give some compensation, the amount would be

determined in consultation with the Safeguard Spl. The matter is being pursued.

ii. Electricity in a labour shed was brought from a neighbouring stakeholder. The labour shed has

been abandoned, but the stakeholder’s bill has not yet been paid by the contractor. When

contacted, the contractor agreed to pay. The matter will be followed up.

2.6 Training on safeguard issues

a. Training of BWDB and C-IMO field staff

The TOR of the Safeguards and Public Relations Specialist requires imparting training to the BWDB

and C-IMO staff for capacity building on environmental management, supervision, reporting and

monitoring of implementation of Environmental Management Plan(EMP) and Grievance Redress

Mechanism (GRM)so that the field staff can supervise, monitor and report on compliance of the

Page 66: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

55

stipulations by the Contractor as set forth in the Contract with regard to natural and social

environment including GRM etc.

For this purpose, a manual was prepared. Training was given to 12 BWDB staff and 11 IMO field

staff on the above in the month of January,2019.

Another training was given to 12 field staff of C-IMO on “customer relation skills” in June, 2019 in

pursuance of the TOR of the Safeguards and Public Relations Specialist, to enable them to better

deal with affected stakeholders.

Figure 24: Mr. Sukumar Saha of the Deptt. Environment is speaking as trainer in the training class on environmental safeguards for

the field staff of BWDB and C-IMO.

b. Training of Contractor’s employees on safeguard issues/customer relation skills

Contractors are responsible for protection of environment and implementation of Environmental

Management Plan(EMP). It was therefore, necessary to train the contractors’ employees on their

responsibilities with regard to stipulations contained in the tender documents/contracts. Director, PIU was

requested several times to ask contractors for submitting the list of their employees for training. No names

of contractors’ employees were received from him. IMO then requested the contractors to give the names of

their employees for this training.

Page 67: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

56

Training was given to 24 employees and one contractor on the above. The topics also included GRM,

customer relation skills, HIV/AIDS. A training manual was prepared for this training.

Figure 25:Contractors’ employees are receiving training on safeguard issues, GRM, HIV/AIDS and customer

relation skills

c. Training/session on Communication and Consultation program

Under this program, farmers’ meetings/FGDs/workshops etc. were proposed. Considering the

practical situation Mr. David Mole, ADB’s consultant suggested to amalgamate these with farmers’

training that was being organized under extension and training program. IMO supported this

suggestion. The Safeguard Specialist is invited to speak in almost all training programs of farmers on

improved agriculture production techniques. Discussion is held on environmental and safeguard

issues(environmental and social), GRM, ADB’s SPS-2009 etc.

Page 68: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

57

CHAPTER 3: RESULTS OF ENVIRONMENTAL MONITORING

3.0 Results of environmental monitoring and compliance measures

a. Environmental factors

Implementation of all the project activities (Including electrification of LLPs) is going on. This is

construction phase. Adverse environmental impact due to implementation of project components

and sub-components is monitored through observation in the field and by enquiring with the local

community. Actions are taken accordingly. So far no major impact has occurred except inundating

canal banks as mentioned below. There has been no complain, so far. The main indicators used for

environmental impact monitoring and steps taken for remedies/results achieved are mentioned

below:

i. Noise pollution due to movement of vehicles, running of excavating machines, concrete mixture

machine.

For this, vehicle users are asked to maintain the vehicles properly, running of re-excavating

machines(diggers) are not permitted after dusk.

ii. Generation of dust, smoke due to construction works, movement of vehicles and running of

machines.

Concerned persons have been made aware of this. In case of excessive dust, spraying of water on

the road has been advised. For controlling smoke, timely and proper maintenance of vehicles and

machines are ensured through motivation/requests.

iii. Disposal/management of spoil generated while re-excavating khals and construction works.

Contacting and requesting the contractors or their employees, these are done as per plan. Photos

given in table-1, B2(Implementation of EMP) may be seen.

iv. Land slide due to re-excavation of khals/re-sectioning of embankment

Contractors are instructed to strictly follow the design. Safeguard Spl./ Field staff check on the spot.

Due to sandy soil, some minor land slide occurs in khal re-excavation. (Photo may be seen in table -

1,B1(EMP).

v. Loss of aquatic animals due to keeping the khals dried for several months.

Concerned persons have been advised to release the said animals in near by water bodies. Actually,

khals are not fully dried during re-excavation. So far, no such case has been noticed.

vi. Removal of vegetation due to khal re-excavation.

Page 69: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

58

As per EMP, Dept. of Forest(DOF) will plant new saplings and IMO will monitor it. Letter has been

written to PD to request DOF for starting sapling as per EMP. In the meantime, 2000 saplings have

been planted on re-excavated canal bank by IMO/PMU under National Tree Plantation Program.

vii. Obstruction of water flow and problems caused in land communication/vehicle movement etc.

Overflow of water inundating the near by land due to cross bundh occurred in two places. Problems

were solved by IMO quickly in cooperation of the contractors.

For land communication, small bridges(iron/bamboo) are constructed by contractors, where

needed.(Photos –table-1(b),9.

During operation phase, environmental impact on soil(reduction of fertility due to indiscriminate

application of agrochemicals, intensive cultivation), ground and surface water(arsenic

contamination, increased salinity), loss of bio-diversity etc. may occur. Necessary test/research will

be conducted and remedial actions will be taken.

b. Social issues

At present, monitoring is being done by Safeguard Specialist, of the social issues like keeping the

generated spoil or construction materials (stones, sand, cement etc.) on private land, borrowing soil

from private land, obtaining land for construction of pump house/header tank with consent of the

land donors (following ADB’s guidelines), wage discrimination between male and female labours,

low wages paid to labours, ensuring arrangement for food and providing accommodation,

sanitation, drinking water facilities, medical/first aid facilities etc. to the labours, creating awareness

of the labours about HIV/AIDS by the contractors/sub-sub-contractors, controlling possible disquiet

of labours to the communities (is very important and requires close monitoring) etc.

The results of monitoring of the social issues in brief are as follows:

a. Labours are provided accommodation by the contractors free of cost in all work sites either by

hiring or building sheds in the sites. Standard is reasonable. There were complains of dropping rain

water through tin roofs. On request, the contractor made necessary repair.

b. In one work site, labours had to bring water from a distance of about one kilo meter. The tube

well sunk went under huge quantity of earth while re-excavating khals. On request of Safeguard

Specialist, the contractor sunk another tube well.

c. In one worksite, labours were suffering from extreme hot weather conditions and requested for a

fan. On request of the Safeguard Spl. contractor provided two fans in the labour shed.

d. Toilets are built temporarily or accommodation hired with toilets (Photos given in table-1 fig. 15

&16) .

e. Previously, unskilled labours and female labours were paid very low wages. After persuasion, the

wage level has been raised to satisfactory level.

Page 70: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

59

f. No child labour is seen in these days/no case of forced labour noticed/reported.

g. Labours are kept under supervision to guard against any kind of social disquiet.

h. Community people have no complain of any adverse environmental impact/social disquiet.

i. Contractors try to save dwelling houses of stakeholders by employing manual labours instead of

re-excavating with machine. (Photos given table -1(b), figure-18).But a few houses and a poultry

farm established in privately owned land have been damaged. The matter is being investigated for

taking necessary actions .

j. A case of compensation for keeping construction materials (blocks, stones, cement) and

constructing labour shed in a private agricultural land is pending.

k. Unauthorised borrowing of soil from private land has not been reported/noticed in the reporting

period.

Problems/Issues yet to be solved

No visible safety measures for labours in the work site is noticed yet. There is no complain

from labours.

Safety indication/sign boards in work sites are hardly seen. No complain from

community/labours.

No first aid box, emergency medicines/ transport facilities are kept in work sites. Labours are

taken to doctors when required by public transports.

HIV/AIDS awareness program not yet started by contractors. Their employees have been

given training on this. The matter will be pursued.

Quantitative environmental monitoring parameters

The quantitative environmental monitoring parameters specially surface water quality

parameters(arsenic, salinity etc.), ground water quantity and quality, soil fertility and intoxication ,

vegetation coverage, wild life habitats and biodiversity loss etc. according to the items mentioned in

the Table: 3 below is yet to take place. Study and actions of these will be very much necessary

during the operation phase. The specific parameters as well as responsibilities for testing all these

should be fixed.

Page 71: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

60

Table-3 : Observation of Monitoring Results /status of implementation of EMP

Monitoring

parameter

Method of

monitoring

Location Frequency

of

monitorin

g

Baseline results Monitoring

Results

National

Standard

Surface

Water

Quality

DO,

pH,

BOD,

EC,

Salinity

(CaCO3, -

SO4, NO3,

Cl-, Ca, Fe,

Mg, K, Na,

Zn, B)

Arsenic

etc.

Sampling

and testing

canals,

wetlands

and ponds

within

project area

Annually

after

completio

n of

physical

works

Baseline of

Surface water

Quality of MIP

is attached in

Appendix- III

Will be

monitored

during

operation

phase

Stated in

Appendix-IV

Ground

Water

Quality

-Salinity

(CaCO3, -

SO4, NO3,

Cl-, Ca, Fe,

Mg, K, Na,

Zn, B),

-Arsenic

etc.

Sampling

and Testing

Tube wells

within

project area

Annually

after

completio

n of

physical

works

Baseline of

Surface water

Quality of MIP

is attached in

Appendix- III

Will be

monitored

during

operation

phase

Stated in

Appendix-IV

Page 72: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

61

Soil

Fertility

Sampling

and Testing

Top soils of

crop field

within the

project

area.

Annually

after

completio

n of

physical

works

Will be

monitored

during

operation

phase.

No

t sp

eci

fie

d

Vegetation

Coverage

Quadrate &

review of

FD

plantation

records.

Homestead

s, village

groves,

cropland

forest and

plantation

on canal

banks and

coastal

embankme

nt within

project

area.

Annually

after

completio

n of

physical

works

Baseline Land

use of MIP is

attached in

Appendix- V

Quite a

large

number of

trees have

been cut

away by

the owners

of those

tress to

facilitate

canal re-

excavation.

Actions

taken to

plant new

tree has

been

mentioned

under item

B1 of

Table: 1

Implement

ation

Status of

EMP

No

t A

pp

lica

ble

Page 73: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

62

Wildlife

habitat

Loss

-Wetland

-Terrestrial

Physical

observation

and

estimation

Wetlands,

Village

groves,

Plantations

on canal

banks and

Coastal

embanks

within the

project area

Biannually

after

completio

n of

physical

works

Baseline Land

use of MIP is

attached in

Appendix- V

Will be

duly

monitored

during

operation.

The

situation is

being

observed

now also.

No

t A

pp

lica

ble

Biodiversit

y loss

-Aquatic

-Terrestrial

Sampling

and

estimating

Wetlands,

Village

groves,

Plantations

on canal

banks and

Coastal

embanks

within the

project area

Biannually

after

completio

n of

physical

works

Baseline

Biodiversity of

MIP is attached

in Appendix- VI

Will be

assessed/

verified/

monitored

during

operation

phase. The

situation is

being

observed

now also.

No

t A

pp

lica

ble

Complianc

e of Labor

laws

(National

and

Internation

al)

Physical

observation

&

Questionnai

re and

Contractors

records

Constructio

n and

operation

site within

the project

area

Day to

day

during

constructi

on works

and

monthly

during

operation

Poor and

destitute

women are

present in the

MIP area but

Religious

norms prohibit

them to work

outdoor

Labors are

ignorant

about the

labor laws

and

somewhat

reluctant

to raise

any

complaint

lest they

are thrown

out of

employme

Child labor

are prohi-

bited,

Minimum age

18 years.

During site

visits only one

such labour

was noticed

in sluice gate

No. 9

construction

works. The

contractor’s

Page 74: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

63

nt. representativ

e has been

asked not to

appoint such

under aged

labor

henceforth.

Deviations

from norms

have been

mentioned in

other places.

Environme

ntal Health

& Safety

complianc

e

Physical

observation

&

Questionnai

re and

Contractors

records

Constructio

n and

operation

site within

the project

area

Day to

day

during

constructi

on works

and

monthly

during

operation

No health &

safety

measures (first

aid, blankets,

mosquito nets

etc.) are found

to be provided

by contractors

specially in

labor sheds.

Temporary

toilets,

constructed or

hired, tube

wells sunk or

tube well water

arranged with

rented

accommodatio

n.

Labors are

ignorant

about the

health and

Safety

compliance

and

reluctant

to use

safety

measures

like helmet

& gloves

etc. but

interested

in

sanitation

and first

aid

measures

which are

not

provided

on the

constructio

Contractors

have to

ensure

laborer’s

health and

safety issues ,

sanitation,

health and

medical

facilities, like

first aid,

drinking

water,

blankets and

mosquito

nets etc.

These are

enquired with

the labors, so

far no

complain was

received.

Page 75: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

64

n site.

Social

safety

Complianc

e

Physical

observation

&

Questionnai

re and

Contractors

records

Constructio

n and

operation

site within

the project

area

Day to

day

during

constructi

on works

and

monthly

during

operation

Labors are

mainly

construction

workers,

excavator

operators,

work

assistants,

helpers etc.

Both local and

external labors

are recruited.

They are kept

under strict

supervision.

Labors and

contractor’s

employees

have been

made aware of

this by

discussing

during site visit

/training.

Except one

case of social

disquiet more

than a year

ago, no

conflicts or

noise ,dust,

smoke

pollution were

reported.

Women

are not

willing to

work

outdoor.

No social

safety

measures

found in

the

constructio

n site.

Abuse of

labor, forced

laboring,

unauthorized

over time

laboring,

sexual harass-

ment/ assault

were not

reported , any

where.

Separate

latrine for

female labor

will be

arranged, if

female labors

work. These

are being

pursued. .

Note: All appendix was added on all previous report.

Page 76: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

65

CHAPTER 4: CONCLUSION AND RECOMMENDATION

4.0 Conclusion

PMU/IMO is monitoring the implementation of EMP following the monitoring plan and using

parameters as given in EMP. The supervision and monitoring of EMP implementation /compliance

by contractor at the field level is done mainly by the Safeguard and Public Relation Specialist of IMO.

IMO field staff is yet to shoulder the responsibility to the desired extent. In preparing this report and

giving views/making comments, the proposed mitigation measures as contained in EMP have been

applied. The Safeguard Specialist speak to the contractors’ employees in the field if available, and

normally have a solution. If the problem cannot be solved on the spot, the matter is reported to

Director, PIU for taking necessary actions. But no response is received from PIU.

Effectiveness of proposed mitigation measures depends on the willingness of the contractors to

fulfil their obligations of the contract. The contractors , as per their contract, are responsible to

take reasonable steps to protect the environment and to limit damages and nuisance to people and

property resulting from pollution, noise, emissions, surface discharges and other results of their

operations. The contractors are also under obligation to pay fair wages to labors and provide

accommodation, sanitation facilities, drinking water and other welfare facilities including health,

medical facilities and safety.

In case of non-compliance by the contractors of requests made by IMO, the matter is referred to

Director, PIU,MIP to instruct the contractors for compliance as per contract. But no response from

Director, PIU is received. IMO on the other hand, has no authority to compel the contractors to fulfil

their obligations.

To make the mitigation measures effective, more active role and quick action of the Director, PIU is

considered very much necessary.

4.1 Recommendation

The safeguard team of PMU and IMO’s Safeguard Specialist recommend the following

measures/corrective actions to overcome the present non-compliance/limited compliance issues of

MIP and other related problems.

i. The qualitative and quantitative parameters like water quality and quantity, biodiversity, soil

fertility, occupational health and safety as well as social safety compliance are stated in the EIA

report of MIP. The mandatory parameters and their methods, frequencies and standards on the

Page 77: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

66

above mentioned indicators, are yet to be fixed. Fixing the responsibilities of the involved agencies

for performance is also needed.

ii. BWDB and C-IMO should hold a briefing session with the contractors to remind them of their

obligations with respect to EMP and social requirements. BWDB should compel the contractors to

carry out all of the monitoring and mitigation measures set forth in the EMP and to take necessary

actions with regard to labour’s wage, health, safety, sanitation and other welfare facilities including

residence, food and drinking water, HIV/AIDS awareness etc. and rights of stakeholders and

community people as per contract with BWDB. For causing loss to the stakeholders by

using/damaging private land or damaging houses built on private land/private properties, due

compensation to the stakeholders should be given by the contractors. The matter should be clearly

spelt.

iii. Every month/quarter there should be a face-to face discussion between the PMU’s Safeguard

team and C-IMO on the progress and problems of EMP implementation and safeguard activities of

the project . The safeguard team of PMU should visit the project before holding such meeting so

that IMO receives feed back and guidance for further improvement.

iv. Though the adverse environmental impacts due to implementation of project components and

sub-components is not so noticeable now, there may be noticeable adverse environmental impact

during operation phase. MoU between BWDB and the other project partners like DoE, DAE, FD, and

DoPHE etc. who will also monitor environmental parameters, has not been signed. Though there is a

general MOU between BWDB and DoF for planting saplings on canal banks, no action of DoF in this

regard in the MIP area is seen. IMO has drawn the notice of PD to this issue by a letter. PD has also

been requested to consider whether stakeholders can be permitted following Govt. rules and

procedures, to plant the trees which they cut and took away before re-excavation. This would be

cheaper and quicker.

vi. The effectiveness of mitigation measures is largely dependent on the willingness of the

contractors particularly with respect to labors’ wage and welfare facilities, health and safety

compliance, on site medical aids(first aid kits), awareness raising program on HIV/AIDS,

compensation to stakeholders etc. and more importantly on an active role of PIU Director. The

contractors are likely to fulfill the contractual obligations if Director, PIU requests them. A number

of issues have been reported to Director, PIU, actions on which are awaited. Director, PIU may be

requested to take necessary actions as per request of IMO.

vi. Monitoring of social safeguard issues as mentioned under chapter 3,(Results of environmental

monitoring and compliance measures) has become important in the present construction phase

though environmental impacts due to implementation of the project components in this

construction phase, is not so noticeable. It is very likely that environmental impacts will take place

Page 78: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

67

in the operation phase causing damage to environment particularly with respect soil, water and bio-

diversity and threatening human health and lives. Therefore, the specific parameters as well as

responsibilities for testing all these should be fixed by holding a meeting with the responsible

agencies such as, PMU, IMO, PMDC, DoF, DoE and others concerned.

vii. Transport facilities for field visit of Safeguard Consultant should be made available. Monitoring

of safeguard issues in the field is very much hindered due to lack of vehicles in IMO.

End

Page 79: Semi-annual Environmental Monitoring Report · 2019-10-31 · This Semi-annual Environmental Monitoring Report is a document of the borrower. The views expressed herein do not necessarily

68