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Semi-annual Environmental Monitoring Report
Project No. 45207-002 June 2019
IRRIGATION MANAGEMENT IMPROVEMENT PROJECT (IMIP)
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.
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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
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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.
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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.
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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.
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(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.
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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.
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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.
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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.
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(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.
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
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
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
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
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
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)
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
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.
19
Figure 11: Soil is borrowed for embankment repair from a stakeholder's land with his consent
20
C Construction impacts
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.
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.
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
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
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.
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.
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.
28
Figure 12: Constructed labor shed in South
Doulotpur regulator in Fulgazi Upazila
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
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.
31
Figure 15: Present condition of top surface and slope of embankment where repair work has
been done.
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.
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.
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.
35
Figure 16: Two houses stand on the bank of khal
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.
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.
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.
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
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).
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.
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.
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).
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.
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.
.
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.
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
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
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
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
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.
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.
53
Figure 21: Houses damaged during khal re-excavation
Figure 22 :Poultry farm and house damaged during khal re-excavation
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
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.
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.
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.
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.
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.
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
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
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
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.
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.
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
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
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
68