SFG3875 V2 GOVERNMENT OF THE PEOPLES' REPUBLIC OF BANGLADESH MINISTRY OF FOOD DIRECTORATE GENERAL OF FOOD MODERN FOOD STORAGE FACILITIES PROJECT (MFSP) IDA Credit # 5265-BD ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT (ESIA) REPORT FOR THE CONSTRUCTION OF GALVANIZED CORRUGATED FLAT BOTTOM STEEL SILO WITH RCC FOUNDATION AND IT'S ANCILLARY WORKS AT MADHUPUR SILO SITE PROJECT DIRECTOR MODERN FOOD STORAGE FACILITIES PROJECT PROBASHI KALLAYAN BHABAN, BHABAN 71-72, ESKATON GARDEN DHAKA RAMNA, DHAKA-1000, BANGLADESH. DECEMBER, 2016 Modern Food Storage Facilities Project (MFSP), Madhupur Table of Contents LIST OF TABLES................................................................................................................... vi EXECUTIVE SUMMARY ...................................................................................................... x 1. INTRODUCTION .......................................................................................................... 1 1.1. Background ............................................................................................................................. 1 1.2. Objectives of the Project ......................................................................................................... 2 1.2.1 Strategic Objectives ........................................................................................................ 2 1.2.2 Specific Objectives ......................................................................................................... 2 1.3. Key Results ............................................................................................................................. 2 1.4. Scope of Study ........................................................................................................................ 3 1.5. Approach and Methodology.................................................................................................... 3 1.6. Structure of the Report ............................................................................................................ 1 1.7. Limitation of the Study ........................................................................................................... 1 1.8. The ESIA Study Team ............................................................................................................ 2 2. LEGISLATION, REGULATION AND POLICY CONSIDERATION ........................ 3 2.1. National Environmental Laws ................................................................................................ 3 2.1.1. General Description ........................................................................................................ 3 2.1.2. Bangladesh Environment Conservation Act, 1995 ......................................................... 4 2.1.3. Environment Conservation Rules, 1997 ......................................................................... 4 2.1.4. Bangladesh Climate Change Strategy and Action Plan (BCCSAP) 2009 ...................... 5 2.1.5. National Environment Action Plan, 1992 ....................................................................... 6 2.1.6. National Water Policy, 1999 ........................................................................................... 6 2.1.7. Standing Orders on Disaster, 2010 ................................................................................. 7 2.1.8. National Integrated Pest Management Policy, 2002 ....................................................... 7 2.1.9. National Fisheries Policy, 1996 ...................................................................................... 7 2.1.10. National Adaption Program of Action (NAPA).............................................................. 8 2.1.11. Bangladesh Labor Act, 2006 ........................................................................................... 9 2.1.12. Bangladesh National Building Code, 2006 ..................................................................... 9 2.1.12.a. Demolition of Structure .......................................................................................... 9 2.1.12.b. Occupational Health & Safety ................................................................................ 9 2.1.13. National Agricultural Policy, 2010 ............................................................................... 11 i Modern Food Storage Facilities Project (MFSP), Madhupur 2.1.14. National Food Policy, 2006 .......................................................................................... 11 2.1.15. National Food Policy Plan of Action, 2008-2015 ......................................................... 12 2.1.16. Bangladesh Country Investment Plan (CIP), 2011 ....................................................... 13 2.2. World Bank’s Environmental Safeguard Policies................................................................. 13 2.2.1 OP/BP 4.01 Environmental Assessment ....................................................................... 14 2.2.2 OP/BP 4.04 Natural Habitats ........................................................................................ 15 2.2.3 OP/BP 4.09 Pest Management ...................................................................................... 15 2.2.4 OP/BP 4.11 Physical Cultural Resources...................................................................... 16 2.2.5 OP/BP 4.36 Forests ....................................................................................................... 16 2.3 Environment, Health & Safety Guidelines............................................................................ 16 2.4 Social Policies & Legislation of Bangladesh ........................................................................ 18 2.4.1 General Description ...................................................................................................... 18 2.4.2 Constitution of Bangladesh ........................................................................................... 18 2.4.3 The Acquisition and Requisition of Immovable Property Ordinance, 1982 ................. 18 2.4.4 The East Bengal State Acquisition and Tenancy Act, 1950 (Revised, 1994) ............... 19 2.4.5 Constitutional Right of the Tribal Peoples Rights ........................................................ 19 2.4.6 The Chittagong Hill Tracts Regulation, 1990 ............................................................... 20 2.4.7 The Chittagong Hill Tracts (Land Acquisition) Regulation, 1958................................ 20 2.4.8 The CHT Regional Council Act, 1998.......................................................................... 20 2.4.9 Ethnic Minority Rights in PRSP, 2005 ......................................................................... 21 2.4.10 GOB Laws and Land Acquisition ................................................................................. 21 2.5 World’s Bank Social Safeguard Policy................................................................................. 22 2.5.1 Involuntary Resettlement (OP 4.12) ............................................................................. 22 2.5.2 Indigenous People (OP 4.10) ........................................................................................ 22 2.6 Implication of National Policies and Legislations on this Project ........................................ 23 2.7 Implication of Environmental Safeguard Policies of WB on the Project ............................. 23 2.8 Implication of Social Safeguard Policies of WB on the Project ........................................... 23 3. PROJECT DESCRIPTION........................................................................................... 25 3.1. Location of the Project .......................................................................................................... 25 3.2. Description of Project Works ................................................................................................ 28 ii Modern Food Storage Facilities Project (MFSP), Madhupur 3.3. Structures in Existing LSD and Silo Site of Madhupur ........................................................ 30 3.4. Construction of Steel Silos.................................................................................................... 30 3.5. Implementation Schedule...................................................................................................... 31 4. DESCRIPTION OF THE ENVIRONMENT ............................................................... 32 4.1 Physical Environment ........................................................................................................... 32 4.1.1 Climate .......................................................................................................................... 32 4.1.1.1. Temperature .......................................................................................................... 34 4.1.1.2. Rainfall .................................................................................................................. 34 4.1.1.3. Humidity ............................................................................................................... 35 4.1.1.4. Wind Speed ........................................................................................................... 35 4.1.1.5. Sunshine ................................................................................................................ 36 4.1.1.6. Cloud Coverage..................................................................................................... 36 4.1.2 Noise Level ................................................................................................................... 37 4.1.3 Physiography................................................................................................................. 38 4.1.4 Topography ................................................................................................................... 41 4.1.5 Geology ......................................................................................................................... 43 4.1.6 Air quality ..................................................................................................................... 45 4.1.7 Water Resources ........................................................................................................... 45 4.1.7.1 Ground Water............................................................................................................ 47 4.1.8 Soil Quality ................................................................................................................... 50 4.1.9 Agro-Ecological Zones within the Project Area ........................................................... 52 4.1.10 Seismicity ...................................................................................................................... 54 4.2 Biological Environment ........................................................................................................ 56 4.2.1 Bio-Ecological Zones.................................................................................................... 56 4.2.2 Terrestrial Ecosystem.................................................................................................... 57 4.2.2.1. Flora ...................................................................................................................... 57 4.2.2.2. Fauna ..................................................................................................................... 58 4.2.3 Aquatic Ecosystem........................................................................................................ 58 4.2.4 Protected Areas & Red Book Species ........................................................................... 58 4.3 Social Environment ............................................................................................................... 60 4.3.1 Demographic Profile ..................................................................................................... 60 iii Modern Food Storage Facilities Project (MFSP), Madhupur 4.3.1.1 Background ............................................................................................................... 60 4.3.1.2 Area and Location ..................................................................................................... 60 4.3.1.3 Administrative/Geographic Unit ............................................................................... 60 4.3.1.4 Housing and Household Characteristics ................................................................... 60 4.3.1.5 Population Characteristics......................................................................................... 61 4.3.1.5.1 Religion Composition ......................................................................................... 61 4.3.1.5.2 Tribal Communities ............................................................................................ 61 4.3.1.6 Literacy and Education ............................................................................................. 61 4.3.1.7 Arts and Culture ........................................................................................................ 63 4.3.1.8 Economy and Occupation ......................................................................................... 63 4.3.1.9 Access to Electricity and Drinking Water ................................................................. 65 4.3.1.10 Health & Sanitation Condition .............................................................................. 66 4.3.1.11 Transportation Link............................................................................................... 66 4.3.2 Survey Finding of Social Impact Assessment............................................................... 67 4.3.3 Environmental & Social Hotspot .................................................................................. 67 4.3.4 Cultural, Religious and Archaeological Sites ............................................................... 68 5. SOCIAL MANAGEMENT AND RESETTLEMENT POLICY FRAMEWORK ...... 70 5.1 Objectives of SMRPF ........................................................................................................... 70 5.2 Basic Planning Principles...................................................................................................... 70 5.3 Social Screening & Impact Assessment................................................................................ 71 5.3.1 Exclusion Criteria ......................................................................................................... 71 5.3.2 Social Impact Assessment Methodology ...................................................................... 71 5.4 Social Management and Resettlement Policy ....................................................................... 73 6. IMPACTS ASSESSMENT AND MITIGATION ........................................................ 75 6.1 Assessment of Environmental Impacts and Mitigation ........................................................ 75 6.1.1 Potential Impacts considered during Pre-construction Phase ....................................... 75 6.1.2 Potential Impacts during Construction Phase ............................................................... 78 6.1.3 Potential Impacts during Operational Phase ................................................................. 84 6.2 Assessment of Social Impacts & Mitigation ......................................................................... 87 6.2.1 Social Screening............................................................................................................ 87 6.2.2 Impacts on Indigenous People ...................................................................................... 88 6.2.3 Social Exclusion............................................................................................................ 88 iv Modern Food Storage Facilities Project (MFSP), Madhupur 6.2.4 Impacts Due to Non-Local Work Force ........................................................................ 88 6.2.5 Impacts on Local Infrastructure .................................................................................... 88 6.2.6 Impacts on Conflict of Labor Influx ............................................................................. 88 6.2.7 Project Benefits ............................................................................................................. 89 6.2.8 Social Welfare Works by the Project Authority ........................................................... 89 7. ARRANGEMENT OF SILO BINS AND ANCILLARY FACILITIES..................... 91 7.1 General .................................................................................................................................. 91 7.2 Safeguard facilities during Construction works .................................................................... 91 7.3 Traffic Management.............................................................................................................. 93 7.4 Residential Arrangement for the Silo Experts ...................................................................... 93 8. ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ................................. 95 8.1 Objectives of the ESMP ........................................................................................................ 95 8.2 Environmental and Social Management and Mitigation Plan............................................... 95 8.3 Environmental and Social Monitoring Plan ........................................................................ 102 8.3.1 General ........................................................................................................................ 102 8.3.2 Objectives of the ESMoP ............................................................................................ 102 8.4 EMP in Bidding Document ................................................................................................. 104 8.5 Grievance Redress Mechanism ........................................................................................... 105 8.6 Institutional Arrangement for Project Implementation ....................................................... 107 8.6.1 Implementation Responsibility ................................................................................... 108 8.6.2 Construction Phase...................................................................................................... 108 8.6.3 Operation Phase .......................................................................................................... 109 8.7 Training Plan ....................................................................................................................... 110 9. PUBLIC CONSULTATIONS .................................................................................... 111 9.1General ....................................................................................................................................... 111 9.2 Objectives ........................................................................................................................... 111 9.3 Consultation with various Stakeholders .............................................................................. 112 9.4 Findings of the consultation meetings ................................................................................ 115 10. CONCLUSION & RECOMMENDATIONS ............................................................. 116 10.1 Conclusion .......................................................................................................................... 116 10.2 Recommendation ................................................................................................................ 116 v Modern Food Storage Facilities Project (MFSP), Madhupur APPENDICES ...................................................................................................................... 117 APPENDIX A: Site Clearance Certificate with ToR for EIA ........................................................ 117 APPENDIX B: Noise Level Test Result......................................................................................... 119 APPENDIX C: Test Result for Ground Water (On Site)................................................................ 120 APPENDIX D: Test Result for Ground Water (DPHE Laboratory) .............................................. 121 APPENDIX E: List of Plants in the Project Area ........................................................................... 122 APPENDIX F: List of Fauna Identified in the Project Area ........................................................... 125 APPENDIX G: Important Sensitive Locations in the PIA ............................................................. 128 APPENDIX H: Socio-Economic Survey Template ........................................................................ 133 APPENDIX I: Focus Group Discussion (FGD) Participants List .................................................. 140 APPENDIX J: Study References .................................................................................................... 144 Annex-K: Sample Environmental Action Plan for MFSP Sub-projects ............................................ 145 LIST OF TABLES Table 1.1: The ESIA Study Team ........................................................................................................... 2 Table 2.1 EHS Guidelines of World Bank............................................................................................ 17 Table 4.1: Noise Level at Different Locations of Project Area (11 October 2016) .............................. 38 Table 4.2: Air Quality Monitoring Data .............................................................................................. 45 Table 4.3: Results for Groundwater Sample ......................................................................................... 48 Table 4.4: Seismic Zone of Bangladesh................................................................................................ 54 Table 4.5: Decadal Growth Rate of Population .................................................................................... 61 Table 4.6: Religion Composition of Madhupur Upazila....................................................................... 61 Table 4.7: Literacy Rate by Sex ............................................................................................................ 62 Table 4.8: School Attendance Rate by Sex, 2011 ................................................................................. 62 Table 4.9: Educational Institutions in Madhupur Upazila .................................................................... 63 Table 4.10: Cultural Institutions of Madhupur ..................................................................................... 63 Table 4.11: Income Sources of Madhupur ............................................................................................ 64 Table 4.12: Manufactories .................................................................................................................... 64 Table 4.13: List of cottage industries, hat bazaars and fairs ................................................................. 65 Table 4.14: Drinking water Source ....................................................................................................... 66 Table 4.15: Health institution ............................................................................................................... 66 Table 6.1: Social Screening .................................................................................................................. 87 Table 6.2: Social Impact Assessment (SIA) ......................................................................................... 90 Table 8.1: Environmental and Social Management /Mitigation Plan (Design & Construction Phase) 96 Table 8.2: Environmental and Social Monitoring Plan....................................................................... 103 Table 8.3: Cost of ESMP .................................................................................................................... 104 Table 8.4: Environmental and Social Training Plan ............................................................................. 110 Table 9.1: Details of FGDs ................................................................................................................. 112 Table 9.2: Summary of the FGD......................................................................................................... 113 vi Modern Food Storage Facilities Project (MFSP), Madhupur LIST OF FIGURES Figure 1.1: Location of Sample Collection ............................................................................................. 1 Figure 3.1: Location Map of Madhupur Silo Site in Google earth ....................................................... 26 Figure 3.2: Location Map of Madhupur Silo Site in GIS ..................................................................... 27 Figure 3.3: Preliminary Layout Plan of Madhupur Silo Site ................................................................ 29 Figure 3.4: Proposed Silo Site (Open Land) ......................................................................................... 30 Figure 3.5: Preliminary design of steel silos ......................................................................................... 31 Figure 4.1: Climatic Zones of Bangladesh............................................................................................ 33 Figure 4.2: Average Monthly Maximum & Minimum Temperature .................................................... 34 Figure 4.3: Average Monthly Total Rainfall in Tangail Station ........................................................... 34 Figure 4.4: Average Monthly Relative Humidity in Tangail Station.................................................... 35 Figure 4.5: Average Monthly Maximum Wind Speed in Tangail Station ............................................ 35 Figure 4.6: Average Monthly Sunshine in Tangail Station................................................................... 36 Figure 4.7: Average Monthly Cloud Coverage in Tangail Station ....................................................... 37 Figure 4.8: Noise Level Monitoring in the Project Area ...................................................................... 37 Figure 4.9: Physiographic Units of project area ................................................................................... 40 Figure 4.10: Topographic Map of project area ..................................................................................... 42 Figure 4.11: Geology of project area .................................................................................................... 44 Figure 4.12: Water Bodies and River Network Map ............................................................................ 46 Figure 4.13: Water Sampling and On-site Testing in the Project Location .......................................... 47 Figure 4.14: Arsenic Contaminated Zones of Bangladesh.................................................................... 49 Figure 4.15: Soil Types of project area ................................................................................................. 51 Figure 4.16: Agro-Ecological Zones of project area............................................................................. 53 Figure 4.17: Seismic Zones of Bangladesh ........................................................................................... 55 Figure 4.18: Bio-Ecological Zones of Bangladesh ............................................................................... 56 Figure 4.19: Flora in the Project Area................................................................................................... 57 Figure 4.20: Environmental Protected Areas of Bangladesh ................................................................ 59 Figure 4.21: Existing Tangail-Mymensingh Highway.......................................................................... 67 Figure 4.22: Sensitive Locations in Madhupur ..................................................................................... 69 Figure 7.1: Arrangement of labor camp, stockpiles, water source, latrines etc. ................................... 92 Figure 7.2: Transportation arrangement around silo area during construction period .......................... 94 Figure 8-1 Implementation Step Up of the Project ............................................................................. 107 vii Modern Food Storage Facilities Project (MFSP), Madhupur ACRONYMS & ABBREVIATIONS ADB Asian Development Bank AEZ Agro-Ecological Zones ARIPO African Regional Intellectual Property Organization AP Affected Person AD Alluvion Dilluvion BP Bank Procedure BECA Bangladesh Environmental Conservation Act BBS Bangladesh Bureau of Statistics BMD Bangladesh Meteorological Department BCCSAP Bangladesh Climate Change Strategy and Action Plan BoQ Bill of Quantities BNBC Bangladesh National Building Code BFIDC Bangladesh Forest Industries Development Corporation BADC Bangladesh Agriculture Development Corporation CHT Chittagong Hill Tracts CoP Conference of the Parties CIP Country Investment Plan CLAC Central Land Allocation Committee DPHE Department of Public Health Engineering DG Directorate General DoE Department of Environment DC Deputy Commissioner EIA Environmental Impact Assessment ECA Environmental Conservation Act ECR Environmental Conservation Rules EA Environmental Assessment ESIA Environmental and Social Impact Assessment ECC Environmental Clearance Certificate EMP Environmental Management Plan EHS Environment, Health & Safety EMF Environmental Management Framework ESMP Environmental and Social Management Plan ESMoP Environmental and Social Monitoring Plan GIIP Good International Industry Practice GoB Government of Bangladesh viii Modern Food Storage Facilities Project (MFSP), Madhupur GIS Geographic Information System GW Ground Water HDC Hill District Councils HSE Health, Safety and Environment HQ Headquarter IEE Initial Environmental Examination IPM Integrated Pest Management IDA International Development Association IUCN International Union for Conservation of Nature LSD Least Significant Difference MoEF Ministry of Environment and Forest MFSFP Modern Food Storage Facilities Project MDG Millennium Development Goal MoL Ministry of Land NFP National Food Policy NAPA National Adaption Program of Action NIOSH National Institute of Occupational Safety and Health NGO Non-Governmental Organization OP Operational Plan O&M Operation and Maintenance PPE Personal Protective Equipment PoA Plan of Action PRSP Property Reduction Strategy Papers PIA Project Influenced Area RAP Resettlement Action Plan SIA Social Impact Assessment SRDI Soil Resources Development Institute SOD Standing Orders on Disaster SMPRF Social Management and Resettlement Policy Framework SPM Suspended Particular Matter USEPA United States Environmental Protection Agency UNFCC United Nations Framework Convention on Climate Change UNDP United Nations Development Program WHO World Health Organization WB World Bank ix Modern Food Storage Facilities Project (MFSP), Madhupur EXECUTIVE SUMMARY INTRODUCTION Bangladesh is the most vulnerable country in the world to natural disasters that are likely to be exacerbated due to climate changes, and 60% of the world-wide deaths, caused by natural disasters during the last 20 years, were in Bangladesh. Climate change is anticipated to lead to more intense and frequent cyclones, floods, and droughts, as well as sea level rise and associated salinity intrusion in the coastal areas leading to growing pressure on ensuring adequate food security and nutrition. The Directorate General of Food (DG Food) estimates that, by 2020, grain storage requirements would be about 3 million tons for a population of about 170 million people. Based on current and project storage availability, it is expected to result in estimated shortages of grain storage space of about 1.7 million tons by 2020. The modern food storage facilities proposed for construction under this project could considerably improve the efficacy of the government’s emergency response and recovery efforts in disaster-prone areas, and could enhance the efficiency of its Public Food Distribution System. In response to the above challenges, GoB seeks to improve its capacity to respond to short and longer term post-disaster food and nutrition security needs by enhancing its network of food grain storage facilities and building modern food storage facilities; at the same time, it aims to improve the efficacy and accountability of the public food grain system. METHODOLOGY The study is based on both primary and secondary data and information. The primary data includes data collected from field observations, survey and secondary data includes review of the Bangladesh statistical and relevant information from Government Departments. Discussions were held with stakeholders including community representatives and local people. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK Legislative bases for Environmental Impact Assessment (EIA) in Bangladesh are the Environmental Conservation Act 1995 (ECA’95) and the Environmental Conservation Rules 1997 (ECR’97). Department of Environment (DoE), under the Ministry of Environment and Forests (MoEF) is the regulatory body responsible for enforcing the ECA’95 and ECR’97. It is the responsibility of the project proponent to conduct an Environmental and Social Impact Assessment (ESIA) of development proposal and the responsibility to review ESIAs for the purpose of issuing Environmental Clearance Certificate (ECC) rests on the DOE and fulfill the world bank social safe guard issues. The project authority already got the site clearance certificate (SCC) from the DoE. x Modern Food Storage Facilities Project (MFSP), Madhupur DESCRIPTION OF THE PROPOSED PROJECT Madhupur is one of the 12 Upazila in Tangail District of Dhaka Division. The Upazila is a part of the Madhupur highland of the greater Mymensingh area. Madhupur has a Government khas land area of 5.81 acre which is 3.5 km away towards north from the Madhupur Upazila road. The proposed site is located at the coordinate of N24°37΄43΄΄ and E90°03΄39΄΄. The site is adjacent to Mymensingh-Tangail-Jamalpur high-way. Total project activities were considered in two phases. In the first phase, the sub-project preparation works like; the boundary wall, site development by earth filling, office building etc. has been done. In the second phase; main construction works like 16 nos. flat bottom prefabricated steel silo bins and silo related ancillary works as well as interventions will be constructed/ installed. Design and estimates of the silo bins and ancillary works has been completed and awaiting for the engagement of contractors of the construction works. There are sixteen nos. of steel silo bins will be constructed under this project. Each silo bin capacity for storage is 3000 T. There are lot of equipment will be used during silos operation like belt conveyor, bagging station, chiller etc. The speed control time is 60 t/h. The total capacity of storage will be 48000 T. DESCRIPTION OF THE BASELINE ENVIRONMENT The project area is, under Dhaka Division, located in the South-central climatic zone. The region has a tropical climate with three main seasons–the hot and humid summer, the rainy season and the mild and relatively dry winter. The highest average recorded temperature in this weather station was 33.8°C in April. The lowest average recorded temperature was found in the month of January which was 11.3°C. Statistical data of 1987 to 2013 shows that Tangail station experiences almost 320 mm rainfall during monsoon. In the month of December and January of winter season around 10 mm rainfall occurred in the region of Tangail weather station. Humidity in the above area maximized in June to September in the year which ranges from 83% to 85%. On the other hand, humidity falls around 70% in February, March and April during the winter season in the Tangail station area. Average wind speed maximum value is 1.85 mps in June. The minimum wind speed was 0.68mps in the month of December. Noise level has been monitored at inside and outside of the project location during day time. Results of the noise level monitored were within the standard limit of Bangladesh. The project area falls in the Jamuna (Young Brahmaputra) River Floodplain physiographic unit. On 11th October 2016, groundwater sample was collected by environmental team from a tube well depth about 120 ft near the project area. The Department of Public Health Engineering (DPHE) analyzed the sample. From the result it is found that all the quality parameters were well within the Bangladesh ground water quality standard set by Department of Environment (The ground water quality result is attached in Appendix D). No surface water was found nearby to the project site and surface water quality test was not done. The soil near the project area is Non-Calcareous Alluvium soils and Deep Red Brown Terrace soils. As per the seismic zone map, project area falls in the zone II of low seismic xi Modern Food Storage Facilities Project (MFSP), Madhupur intensity. According to the bioecological map zones the project area falls in Madhupur Sal Tract and Brahmaputra-Jamuna Floodplain ecological zone. No endangered/ critically endangered or threatened terrestrial or aquatic species were found in the project area. No archaeological or culturally protected areas were found that would have anticipated impact. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES Environmental impacts assessment was carried out considering present environmental setting of the project area, and nature and extent of the proposed activities. Potential environmental impacts associated with the proposed project activities are classified as: (i) impacts during pre-construction phase, (ii) impacts during construction phase and (iii) impacts during operation phase. Here the project has no land acquisition and involuntary resettlement impact. Most of the impact will occur duing construction activities of the silos. Some anticipated impacts will have to be considered, especially, during construction and operation periods and those are to be well managed, to minimize environmental and social impacts and hazards, as the means of mitigation measures to the probable impacts. For the sustainable development as well as to maintain environmental friendly infrastructure, measures start from design phase. Madhupur silo site, with 5.81acres of land, is now well protected by boundary wall. Before starting the construction works, an well planning is required to place the laborers' shed, drinking water facility, sanitary latrines, equipment and materials yards, lubricant and fuel keeping facility, temporary drainage facilities, solid waste management facilities etc. The traffic and machineries' movement routes etc. are to be established in the construction site. Essential facilities like; labor-shed with proper living, lighting and cooking arrangement, waste water drainage arrangement from the kitchen area, waste bins and solid waste management facilities, and adequate drinking water supply, sanitary latrine facilities, personal protection equipments and first aid box etc. are to be provided before starting the construction works. The construction materials' yard and place for keeping the prefabricated steel sheets will be fixed in ahead of starting the silo bins' super-structure setting. As, the area is not so large (5.81 acres only), no stone/ brick crushing will be allowed within the silo site. Only pre- fabricated steel sheet will be carried to the construction site and separate areas/ yards will have to be maintained for that. For carrying the construction materials, care should be taken on traffic management. Safety measures will be taken for the local pedestrians, school children, local Madhupur-Mymensingh bound traffic. ARRANGEMENT OF SILO BINS AND ANCILLARY FACILITIES For the environmental and social safeguard compliances, the construction and installation of water supply and sanitation facilities, along with the labor-camp placement, will have to be done with precaution. The areas, along the western boundary wall, will be suitable for setting the workers' facilities like labor-shed, toilet and solid waste management. Cleaning of labor- camp site, toilets etc. will have to be done cautiously, because; the west boundary wall is just by the side of Madhupur-Mymensingh highway. Also, the toilet facilities may be accommodated at the north-west corner of the silo campus. Precaution will have to be taken xii Modern Food Storage Facilities Project (MFSP), Madhupur on cleaning the toiletry facilities, because, the office building is with the north boundary wall. The Supervision Consultant's Engineer and the Contractor will take a careful decision for setting the workers' facilities, material stocking yard etc. within the limited area. Proper traffic management is necessary during carrying construction materials. The environmental and social safeguard issues have been accommodated with the engagement of people for traffic management during construction and operation periods. ENVIRONMENTAL MANAGEMENT AND MONITORING PLAN Environmental Management Plan has been developed to address all adverse impacts pertaining to the implementation of the project. The plan presented in tabular form includes impacts, their sources of occurrence, their mitigation measures, actors responsible for implementation of mitigation measures and their responsibilities. Environmental Monitoring Plan has been incorporated key environmental components and parameters to be monitored their indicators, frequency, timing and locations of monitoring and also the actors responsible for carrying out such monitoring. Grievance Redress Mechanism, Institutional Arrangement, Environmental Safeguard Compliance cost etc. has been incorporated in the Environmental Management and Monitoring chapter. GRIEVANCE REDRESS MECHANISM A grievance can be defined as an actual or perceived problem that might give grounds for complaint. As a general policy, DG-Food along with the MFSP will work proactively towards arising and minimizing grievances through the implementation of impact mitigation measures and community liaison activities that anticipate and address potential issues before they become grievances. The Grievance redress mechanism (GRM) sets out the information and communications strategy to ensure that PAPs and communities are fully informed about their rights to offer suggestions and make complaints, and the different mechanisms through which they can do so, including grievances through creating more sounds during construction, pollution through improper solid waste management, traffic disturbance during the movement of more vehicles during construction and operation phases etc. This will be the responsibility of the PMU, CSC, and contractors and persons designated to be responsible for stakeholder liaison. INSTITUTIONAL ARRANGEMENT FOR PROJECT IMPLEMENTATION AND OPERATION PHASES A Project Management Unit (PMU) has been established under the DG Food for day–to-day implementation and monitoring of the project activities. The PMU is headed by a Project Director who is assisted by; (i) Deputy-Project Director; (ii) technical specialists (Civil, Mechanical and Electrical); (ii) Senior Procurement Specialist, and Procurement Analyst; (iii) Senior Financial Management Specialist, and accountant and a book keeper; (iv) Senior Environmental Specialist, (v) Senior Social Specialist, and (vi) Senior Communication Specialist. Each Silo site is headed by the Project Coordinator for coordination with the xiii Modern Food Storage Facilities Project (MFSP), Madhupur contractors, consultants and local administration as well as with communities, along with a Technical Specialist. The PMU has a Senior Environmental Specialist (SES) to ensure implementation of EMP and other environmental management responsibilities. The SES is maintaining liaison with WB safeguards team, regulatory agencies, and other stakeholders during the Project implementation. The SES will also coordinate with the environmental staff of the Construction Supervision Consultants. The Supervision Consultants will have dedicated, properly qualified and experienced, site- based Environment Monitor (EM) at each construction site (before starting the construction works). The EMs will monitor and supervise the EMP implementation at the field level. The EMs will maintain coordination with SES at the PMU level and supervise and monitor the construction contractor. The EMs need to be a graduate preferably in environmental science/engineering with at least 5 years’ experience in the related field. The construction contractors will have dedicated, properly qualified and experienced, site- based Environment Supervisors (ESs) at each construction site. The ESs will be responsible to implement various aspects of the EMP particularly the mitigation measures to ensure that the environmental impacts of the construction works remain within acceptable limits. The Contractor will prepare the Environmental Action Plan (EAP) prior to start working and will submit the same to the Engineer in Charge of MFSP for approval. The ESs will maintain coordination with the EMs at the field level. The ESs will also be responsible to conduct environmental trainings for the construction crews. The EM needs to be a graduate preferably in environmental science/engineering with at least 3 years’ experience in the related field. The (Health, Safety and Environment) HSE function will be a key element of the operation and maintenance arrangements at each of the silo facility. Dedicated HSE personnel will be part of the O&M staff and will be responsible to prepare and implement the relevant parts of the Operations Manual for ensuring health and safety during project operation. TRAINING PLAN A series of training programs has been proposed under the MFSP Silo project to enhance the skills of the MFSP as well as contractor staff in environmental aspects especially Environmental Management Plan (EMP) and Environmental Safeguard arrangements. The Environmental and Social consultants (PMU and D&S consultants) will be responsible for imparting training to the engineers and supervisors engaged in construction and operation works. The following training programs are to be included for effective implementation of environmental safeguard issues during construction period and operation stages:  Implementation of Environmental Management Plan (EMP) and auditing of Environmental Management System (EMS)  Documentation requirements of ISO 14001 2004  Internal and external communications  Internal audit xiv Modern Food Storage Facilities Project (MFSP), Madhupur PUBLIC CONSULTATIONS Four consultation meetings were held during October 2016 at the project areas. The consultation meetings were conducted with different level of local people. Total 60 (sixty) participants, different level of people like; local representatives, businessmen, day laborers, farmers, shop keepers etc, were in the meetings. In consultation meetings; environmental and social issues were examined. The main focus was to dig out the mental supports from different level of stakeholders regarding the new concept of food storage facilities, i.e. the silo construction works in lieu of the traditional food storage facilities. The issue on potential impact of construction works has also been raised. Most of participants appreciated because of the benefit from the proposed project. They also discussed about noise, water and soil pollution issue that are evolving because of existing project and the future possibilities. They expect improved technology to minimize the problem. The outcome of the consultation meetings were as follows.  There should be effective mitigation measures in order to reduce noise pollution during construction period. Improved technology and proper management plan would help to mitigate the noise pollution.  Surface water and soil pollution should be controlled by monitoring the runoff of waste materials to the surroundings.  Air pollution from the construction materials and emission from machineries might create problem. Contractor should spray water during material transportation and use cover for air pollution sources if possible.  It will generate more employment in terms of using more laborers, more rice mills will be established, transport business will boost, poultry farming will enrich further and so on. The local people requested that local labor should be used during construction and operation. CONCLUSION AND RECOMMENDATION On the basis of the analysis, it may be concluded that the project stands environmentally sound and sustainable when the recommended mitigation measure and environmental management processes are adopted properly. Seasonal weather conditions would have an impact on the construction activities. The construction activities may even have to be stopped during these periods. So it is recommended that commencing construction in early winter season may help to reap the benefit of full dry spell of the season. In order to enhance the occupational health and worker safety during the construction period, construction equipment would have to be kept in good order. Adequate safety measures should be taken and safety related equipment including personal protective and safety equipments (PPE), firefighting equipment etc. must be provided in order to reduce the potential accidents. xv Modern Food Storage Facilities Project (MFSP), Madhupur Solid waste will be generated during the construction period from excavation and refuse from construction camps and that would be under control management. The major issue is the need to minimize disturbance to the local population in the areas of construction. A positive policy of employing local people during the construction phase should be adopted. Since, the implementation of the proposed project will bring benefit through helping to meet the food security, certain minor environmental impacts of the associated project will have to be compromised for the better interest of the country. However, the anticipated impacts are mostly of short duration and relatively minor in nature. To ensure compliance with the EMP the contractor should deploy an environmental specialist to monitor and report project activities throughout the project construction phase. In view of the above considerations and the fact that the executing agency will maintain standard quality of implementation of the program with due consideration to other standing rules and regulations including but not limited to the ECA 1995 (amended 2010) and ECR 1997 the project is recommended for implementation. xvi 1. INTRODUCTION 1.1. Background Bangladesh is the most vulnerable country in the world to natural disasters that are likely to be exacerbated due to climate changes, and 60% of the world-wide deaths caused by natural disasters during the last 20 years were in Bangladesh. Climate change is anticipated to lead to more intense and frequent cyclones, floods, and droughts, as well as sea level rise and associated salinity intrusion in the coastal areas leading to growing pressure on ensuring adequate food security and nutrition. Growing climate variability and natural disaster risks is anticipated to increase pressure on the Government of Bangladesh to effectively distribute food packets and food aid as a part of its post-disaster recovery programs. During the 2007 floods and the subsequent Cyclones Sidr and Aila (in 2007 and 2009, respectively), crop losses were estimated to be over one million tons each. However, while floods typically cause damage to crops and food stocks (both household and government stocks), post-flood crop yields are typically higher than average (“bumper crops”) because of rich silt deposited on the topsoil, leading to high production that has often served to replace stock shortages. In the case of cyclones, it is not only the losses during the cyclone but production is also severely hampered in the years to follow because saline sea water from storm surges is often deposited on agricultural lands, resulting in food stock shortages for at least two years. The Directorate General of Food (DG Food) estimates that, by 2020, grain storage requirements would be about 3 million tons for a population of about 170 million people. Based on current and project storage availability, this is expected to result in estimated shortages of grain storage space of about 1.7 million tons by the year 2020. However, given the current implementation capacity of the DG Food, and in order to avoid overstocking, it is recommended that the expansion of storage facilities occur in a phased approach. Government of The People’s Republic of Bangladesh has received an IDA credit toward the costs of the Modern Food Storage Facilities Project (MFSP), being implemented by the Directorate General of Food, Ministry of Food. Bangladesh experiences frequent catastrophic weather events resulting in heavy losses in lives and property. Because of these weather related challenges, the Government of Bangladesh is implementing programs aimed at minimizing loss and expediting recovery from these events. The modern food storage facilities proposed for construction under this project could considerably improve the efficacy of the government’s emergency response and recovery efforts in disaster-prone areas, and could enhance the efficiency of its Public Food Distribution System. To respond to the above challenges, GoB seeks to improve its capacity to respond to short and longer term post-disaster food and nutrition security needs by enhancing its network of food grain storage facilities and building modern food storage facilities; at the same time, it aims to improve the efficacy and accountability of the public food grain system. 1 Modern Food Storage Facilities Project (MFSP), Madhupur 1.2. Objectives of the Project 1.2.1 Strategic Objectives Modern storage facilities proposed for construction under this project in different strategic locations across the country will allow grain to be kept in bulk for up to two to three years in better conditions relative to the godowns used currently, with reduced grain losses and enhanced nutritional value of the grain distributed. With strengthened capacity for improving dern silos, and comprehensive analyses for enhancing the overall stock management in the modern policy framework on strategic grain reserves, GoB will be in a position to make sound and informed decisions as it reconciles the three strategic objectives that impact the domestic food market: 1.2.2 Specific Objectives The specific objectives of this project are: 1.3. Key Results The key results are expected from the project as follows: disaster Increased availability of grain stocks immediately after a major disaster, Increased food grain facilities to more disaster prone households, pre Change in cost per ton in storing grain relative to pre-project cost, 2 Modern Food Storage Facilities Project (MFSP), Madhupur Reduced loss in grain stocks relative to pre-project losses, Better monitoring, and improved governance and management of food stocks. 1.4. Scope of Study The scope of environmental and social impact assessment (ESIA) study associated with the silo construction and ancillary facilities comprise with the acts like; to present a general description of the project activities, describing the baseline environment, outlining the socio- economic environment around, suggesting the plan for managing the socio-environmental impacts during implementation and operation, and finally estimating the cost for environmental and social safeguard compliance issues involved during construction and operation phases. The scope of the ESIA included:  Identify the activities are to be done under Madhupur Silo sub-project, with ancillary works associated in Madhupur silo site,  Explore the present environment and socio-economic condition of Madhupur and surrounding areas,  Finding the probable socio-economic and environmental impacts associated with Madhupur silo and surrounding areas,  Investigating the future benefits of the people around Madhupur or grievances among them if any, due to the implementation of such new storage facilities like silo,  Investigating the public opinion of Madhupur areas, on the issues of silo construction,  Categorize the pollutions, may come out during construction and operation phases, in Madhupur and surrounding areas,  Come across the solutions to the probable evolved problems and impacts during implementation and operation phases in the Madhupur silo areas (both in the silo campus and surrounding areas),  Finding the optimum solutions to every impact during implementation and operation phases at Madhupur silo site,  Assessment of institutional aspects, and development of Environmental Management and Monitoring Plan,  Estimating the environmental and social safeguard costs o be involved with the construction cost of Madhupur silo and ancillary works. 1.5. Approach and Methodology The ESIA study was carried out using reconnaissance survey, field visits, consultation with stakeholders, household survey, review of existing data, assessment to identify adverse impacts and preparation of EMP and post-project Environmental Monitoring Program. Physical assessments were made for entire project site with respect to terrestrial and aquatic aspects. 3 Modern Food Storage Facilities Project (MFSP), Madhupur The task of preparing the ESIA report consisted of the following sequential components:  Identification and screening of the environmental parameters relevant to the proposed project through a scoping process;  Assessment of the magnitude of the potential negative impacts for relevant environmental parameters;  Formulation of avoidance/mitigation measures to address the potential negative impacts, and preparation of a monitoring program during the period of project implementation; Scoping and field visits to the project sites identified the environmental parameters/ components (relevant to the project actions) which are susceptible to be affected. The field visit also included participatory approach, which involved discussions with local people in order to determine the perceptions and priorities of the stakeholders in the Project area. Apart from the local people, information were also obtained from the local school teacher and local government. Information were also derived from secondary sources like different reports, journals, Satellite Image Analysis, research papers, NGO, government officials etc. The Location of Sample Collection Map is shown in Figure 1.1. 4 Figure 1.1: Location of Sample Collection 1 1.6. Structure of the Report The report fulfills the requirements of ESIA under ECR, 1997 and has been prepared in accordance with the TOR provided by the Department of Environment (DOE). The report contains ten chapters and the chapter details are discussed below:  Chapter 1 describes the background information of Madhupur silo site and selection of silo site (strategic location), objectives of the sub-project (silo bins and ancillary works to be done), key results to be achieved after silo construction at Madhupur site, scope of ESIA study and approach and methodology for the ESIA study associated with the Madhupur silo and ancillary works,  Chapter 2 is on policy, legal and administrative framework describing the relevant policy and legal frameworks for the ESIA process, including the process of obtaining environmental clearance from the competent authorities.  Chapter 3 contains detailed project description along with all the sub-project interventions are to be constructed and implemented.  Chapter 4 describes environmental and social baseline condition with details on physical environment, land resources, agricultural resources, fisheries, ecosystem, socio-economic condition and social characteristics of the area.  Chapter 5 describes Social Management and resettlement policy framework, emphasizing the inclusion and integration of society people in all activities.  Chapter 6 presents the impacts assessment and mitigation measures for minimizing the adverse impacts and enhancing the benefits of the project and specific works to be done during design, construction and operation phases.  Chapter 7 describes the arrangements for setting different type of interventions (silo bins, office, residential arrangement etc.) associated with the sub-project within the specified allocated area.  Chapter 8 describes the environmental and social management plan (ESMP) and monitoring plan along with the monitoring indicators.  Chapter 9 describes public consultation discussion with local stakeholders with their ideas, views about the project through knowledge sharing  Chapter 10 concluding the ESIA report along with the recommendations. 1.7. Limitation of the Study The present ESIA Report has been prepared based on the primary field investigations / assessment, and secondary data collected from various government departments, climatic data has been used from Bangladesh Meteorological Department (BMD), Department of Environment, Bangladesh (DoE) and published journals, and books, public consultation with local stakeholders and site observations. The environmental and social assessment is based on 1 Modern Food Storage Facilities Project (MFSP), Madhupur the information collected from the various Agencies, community consultations and observations. Professional judgment and subjective interpretation of facts and observations has been applied for the preparation of the ESIA Report. 1.8. The ESIA Study Team A multidisciplinary team of ESIA experts having experience of conducting Environmental and Social Impact Assessment of large scale industrial and infrastructural development projects. Table 1.1 presents the professionals’ names with their positions. Table 1.1: The ESIA Study Team No. Name Position 1 Mr. S. M. Sanaul Kafi Environmental Specialist 2 Mr. Md. Shafiqur Rahman Social Safeguard Specialist 3 Ms. Tanzia Sharmin Junior Environmental Engineer-1 4 Mr. Masfiq Bashir Junior Environmental Specialist-1 5 Ms. Mafia Mostafa Junior Environmental Specialist-2 6 Md. Atiqur Rahman Junior Social safeguard Specialist-2 7 Mr. Madhu Shudan Das GIS Expert 8 Mr. Abdul Malek Surveyor-1 9 Mr. Liton Surveyor-2 10 Mr. Shahidul Islam Surveyor-3 11 Mr. Bappy Rahman Surveyor-4 2 Modern Food Storage Facilities Project (MFSP), Madhupur 2. LEGISLATION, REGULATION AND POLICY CONSIDERATION The Environmental and Social Impact Study (ESIA) has been performed in accordance with the rules, laws and regulations governed by the Bangladesh Government and according to the operation policy of the World Bank. The laws, rules and regulations, adapted by the government of Bangladesh, for overall environmental improvement and to provide environmental and social safeguards, during implementation and operation of any physical infrastructure, considered during the ESIA study for Madhupur Silo site, are; National Environment Action Plan, 1992, Bangladesh Environment Conservation Act, 1995, Environment Conservation Rules, 1997, National Water Policy, 1999, National Fisheries Policy, 1996, Standing Orders on Disaster, 2010, National Integrated Pest Management Policy, 2002, National Adaption Program of Action (NAPA), Bangladesh Country Investment Plan (CIP), 2011, Bangladesh Climate Change Strategy and Action Plan (BCCSAP) 2009, Bangladesh Labor Act, 2006, Bangladesh National Building Code, 2006 (for demolition of Structure and for Occupational Health & Safety), National Agricultural Policy, 2010, National Food Policy, 2006 etc. As per criterion set forth in the ECR 1997, Madhupur silo sub-project is under Orange-B category. On the other hand, as the sub-project is associated with the World Bank' s investment, the Bank's Operation Policy (OP)/ Bank Procedure (BP) are involved with the ESIA study, and those are; Environmental Policies like, (OP/BP 4.01-Environmental Assessment, OP/BP 4.04-Natural Habitats, OP/BP 4.09-Pest Management, OP/BP 4.11-Physical Cultural Resources, OP/BP 4.36-Forests and OP/BP 4.37-Safety of Dams, Social Policies like, OP/BP 4.10-Indigenous Peoples and OP/BP 4.12-Involuntary Resettlement and the Legal Policies like, OP/BP 7.50-International Waterways and OP/BP 7.60-Disputed Areas, were carefully observed during the study. According to World Bank OP/BP the project has been considered as a Category B project. 2.1. National Environmental Laws 2.1.1. General Description A wide range of laws and regulations related to environmental issues are in place in Bangladesh. Many of these are cross-sectoral and partially related to environmental issues. The most important of these are the Bangladesh Environment Conservation Act, 1995 (ECA, 1995), and the Environment Conservation Rules (ECR, 1997). In addition to the Bangladesh Environmental Conservation Act and Rules, there are a number of other policies, plans and strategies which deal with the water sector, agricultural development, coastal area, protected area disaster management and climate change. These are the National Water Policy, 1999; the Forest Act 1927 (last modified 30th April 2000); National Forest Policy, 1994; the National Conservation Strategy1992; National Environmental Management Action Plan (NEMAP), 1995; National Agricultural Policy, 2010; National Food Policy 2006; National Food Policy Plan of Action, 2008-2015; Food Grain Movement Policy, 2008; Bangladesh Country Investment Plan (CIP), 2011; National Fisheries Policy, 1996; Standing Orders on Disaster, 1999 (revised in 2010); Bangladesh Climate Change Strategy and Action Plan, 2009; 3 Modern Food Storage Facilities Project (MFSP), Madhupur National Plan for Disaster Management, 2010-2015. Some of these policies and legislations are described in this chapter for reference. 2.1.2. Bangladesh Environment Conservation Act, 1995 The national environmental legislation known as Environmental Conservation Act, 1995 (ECA'95) is currently the main legislative document relating to environmental protection in Bangladesh, which replaced the earlier environment pollution control ordinance of 1992 and has been promulgated in Environmental Conservation Rules, 1997 (ECR’97). This Act is amended in 2000, 2002 and 2010. The main objectives of ECA’95 are: i) conservation of the natural environment and improvement of environmental standards; and ii) control and mitigation of environmental pollution. Department of Environment (DoE) implements the Act. DoE is under the Ministry of Environment and Forest and is headed by a Director General (DG). The Act states that before beginning new development project, the project proponent must obtain Environmental Clearance from DoE. The procedures to obtain such clearance are in place. Failure to comply with any part of ECA'95 may result in punishment by a maximum of 10 years imprisonment or a maximum fine of BDT. 1000,000 or both. 2.1.3. Environment Conservation Rules, 1997 The Environment Conservation Rules, ECR 1997, provide a first set of rules under the Environment Conservation Act 1995, further amended in 2002 and 2010. These provide, amongst others items, standards and guidelines for:  Categorization of industries and development projects  Procedure for obtaining environmental clearance  Environmental quality standards in relation to water pollution, air pollution and noise, as well as permitted discharge/emission levels of water and air pollutants and noise by projects The Rules incorporate "inclusion lists" of projects requiring varying degrees of environmental investigation. The Government is also empowered to specify which activities are permissible and which restricted in the ecologically critical area. Under this mandate, MoEF has declared Sunderban, Cox's Bazar-Tekhnaf Sea Shore, Saint Martin Island, Sonadia Island, HakalukiHaor, Tanguar Haor, Marzat Baor and Gulshan-Baridhara Lake as ecologically critical areas and accordingly has prohibited certain activities in those areas. Four rivers respectively Buriganga, Balu, Turag and Dhaleshwari of surrounding Dhaka city have also declared as ecologically critical area. Environmental Conservation Rules (1997) classifies industrial units and development projects into four categories for the purpose of issuance of Environmental Clearance Certificate (ECC). These categories are: (i) Green (ii) Orange-A (iii) Orange-B and (iv) Red. Green Category projects are considered relatively pollution-free and hence do not require initial environmental examination (IEE) and EIA. An environment clearance certificate 4 Modern Food Storage Facilities Project (MFSP), Madhupur (ECC) from the Department of Environment (DoE) is adequate. Orange Category projects fall into two categories. Orange A projects are required to submit general information, a feasibility report, a process flow diagram and schematic diagrams of waste treatment facilities along with their application for obtaining DoE environmental clearance. Orange B projects are required to submit an Initial Environmental Examination (IEE) report, along with their application and the information and papers specified for Orange B projects. Red Category projects are those which may cause ‘significant adverse’ environmental impacts and are, therefore, required to submit an EIA report. It should be noted that they may obtain an initial site clearance on the basis of an IEE report, and subsequently submit an EIA report for obtaining environmental clearance along with other necessary papers, such as feasibility study reports and no objections from local authorities. As per ECR ’97 all existing industries and projects in Orange B and Red category require an Environmental Management Plan (EMP) to be prepared and submitted along with other necessary papers while applying for environmental clearance. 2.1.4. Bangladesh Climate Change Strategy and Action Plan (BCCSAP) 2009 The Government of Bangladesh prepared the Bangladesh Climate Change Strategy and Action Plan (BCCSAP) in 2008 and revised in 2009. This is a comprehensive strategy to address climate change challenges in Bangladesh. It is built around the following six themes:  Food security, social protection and health to ensure that the poorest and most vulnerable in society, including women and children, are protected from climate change. All programs focus on the needs of this group for food security, safe housing, employment and access to basic services, including health.  Comprehensive disaster management to further strengthen the country’s already proven disaster management systems to deal with increasingly frequent and severe natural calamities.  Infrastructure to ensure that existing assets (e.g., coastal and river embankments) are well maintained and fit for purpose and that urgently needed infrastructures (cyclone shelters and urban drainage) is put in place to deal with the likely impacts of climate change.  Research and Knowledge management to predict that the likely scale and timing of climate change impacts on different sectors of economy and socioeconomic groups; to underpin future investment strategies; and to ensure that Bangladesh is networked into the latest global thinking on climate change. Mitigation and low carbon development to evolve low carbon development options and implement these as the country’s economy grows over the coming decades. Capacity building and Institutional strengthening to enhance the capacity government ministries, civil society and private sector to meet the challenge of climate change. 5 Modern Food Storage Facilities Project (MFSP), Madhupur 2.1.5. National Environment Action Plan, 1992 The National Environment Action Plan recommended sector specific action plan to achieve the objectives and implement the policy recommendations of the National Environment Policy. The followings are sector relevant key recommended actions: Agriculture  Use of chemical insecticides and pesticides has to be regulated. Production, import and use of those chemical insecticides and pesticides, which have a long-term residue and keep on accumulating in the environment, have to be phased out gradually.  Proper and regulated use of chemical fertilizers will be ensured. Use of organic fertilizers will be increasingly emphasized.  Imported seeds, seedlings and plants will be properly quarantined to exercise necessary caution against probable adverse environmental impact.  Natural methods of pest control will be encouraged through ensuring protection and safety. Steps should be taken to establish an agricultural system based on local ecosystem, rate of population growth and demand of national economy. 2.1.6. National Water Policy, 1999 The National Water Policy was promulgated in 1999 with the intention of guiding both public and private actions to ensure optimal development and management of water in order to benefit both individuals and the society at large. The policy aims to ensure progress towards fulfilling national goals of economic development, poverty alleviation, food security, public health and safety, a decent standard of living for the people and protection of the natural environment. According to the policy, all agencies and departments entrusted with water resource management responsibilities (regulation, planning, construction, operation and maintenance) will have to enhance environmental amenities and ensure that environmental resources are protected and restored while executing their activities. Environmental needs and objectives will be treated equally with the resources management needs. The policy has several clauses related to the protection and conservation of the natural environment to ensure sustainable development. The strategy of the policy to conserve environment and resource can be summarized as:  Promoting modern eco-friendly technology and infrastructure for a safe and sustainable future;  Biodiversity conservation and sustainable land & water management;  Restricting the conversion of agricultural land for non-agricultural purposes. 6 Modern Food Storage Facilities Project (MFSP), Madhupur 2.1.7. Standing Orders on Disaster, 2010 The 'Standing Orders on Disaster, 2010' is a substantial improvement over the previous edition (English 1999) New features introduced in this edition include, among others, the following: i) an outline of disaster management regulative framework, ii) an introduction of core groups for emergency response at various levels, iii) multi-agency disaster incident management system, iv) risk reduction roles and responsibilities for all committees and agencies, v) new outlines for local level plans, vi) revised storm warning signals, vii) a report on cyclone shelter design. Conceptually, this edition follows a comprehensive approach emphasizing risk reduction as well as emergency responses relating to all hazards and all sectors. The Standing Order is designed to enhance capacity at all tiers of government administrative and social structures for coping with and recovering from disasters. Provision of emergency water, food, and sanitation and shelter space for livestock during such periods should also be considered for future construction of shelters. The Standing Orders on Disaster (SOD) specifically focuses on community vulnerability and capacity development of the community to adapt disaster (cyclone, tidal surge, tsunami, earthquake, tornado, flood, water logging, salinity, high tide, cold wave) resistant features like disaster resistant agriculture and other livelihood options. The SOD also delineates the activity of different administration at pre, during and post disaster period. 2.1.8. National Integrated Pest Management Policy, 2002 The objective of the policy is to enable farmers to grow healthy crops in an increased manner and thereby increase their income on a sustainable basis while improving the environment and community health. Maintaining ecological balance is the first priority of the IPM policy. In order to reduce misuse of agro-chemicals that could easily lead to ecological disturbance threatening the sustainability of agricultural production, the policy suggests for the following measurers:  Efforts will be made to conserve and augment populations of bio-control agents in crop fields through the adoption of the principles and practices of IPM; and  Priorities will be given to the management of pests through the use of parasitoids, predators, insect pathogens, appropriate cultivation techniques, pest tolerant varieties, mechanical control measures, crop diversification, botanical products and bio- pesticides. 2.1.9. National Fisheries Policy, 1996 The National Fisheries Policy, 1996 recognizes that fish production has declined due to environmental imbalances, adverse environmental impact and improper implementation of fish culture and management programs. The policy suggests following actions: 7 Modern Food Storage Facilities Project (MFSP), Madhupur  To conserve fish habitats from damage, appropriate care should be taken during the implementation of all development activities such as flood control, irrigation and drainage projects, agriculture, industries, road and development projects.  Shrimp and fish culture will not be expanded to the areas which damage mangrove forest in the coastal region  Biodiversity will be maintained in all natural water bodies and in marine environment. Chemicals harmful to the environment will not be used in fish and shrimp farms  Breeding ground of fish and fresh water giant prawn will be conserved  Environment friendly shrimp culture technology will be used  Control measures will be taken against activities that have a negative impact on fisheries, resources and vice-versa  Laws will be formulated to ban the disposal of any untreated industrial effluents into the water bodies 2.1.10. National Adaption Program of Action (NAPA) In 2005, the Ministry of Environment and Forest (MoEF), Government of the People’s Republic of Bangladesh has prepared the National Adaptation Program of Action (NAPA) for Bangladesh, as a response to the decision of the Seventh Session of the Conference of the Parties (CoP7) of the United Nations Framework Convention on Climate Change (UNFCCC). The basic approach to NAPA preparation was along with the sustainable development goals and objectives of the country where it has recognized necessity of addressing climate change and environmental issue and natural resource management. The NAPA is the beginning of a long journey to address adverse impacts of climate change including variability and extreme events and to promote sustainable development of the country. There are 15 adaptation strategies have been suggested for Bangladesh to address adverse effects of climate change. Among the 15 adaptation strategies the following strategies have taken for the coastal region for reducing climate change induced vulnerability.  Reduction of climate change hazards through coastal afforestation with community participation  Providing drinking water to coastal communities to combat enhanced salinity due to sea level rise  Construction of flood shelter, and information and assistance centre to cope with enhanced recurrent floods in major floodplains  Promotion of research on drought, flood and saline tolerant varieties of crops to facilitate adaptation in future  Promoting adaptation to coastal crop agriculture to combat increased salinity  Promoting adaptation to coastal fisheries through culture of salt tolerant fish special in coastal areas of Bangladesh 8 Modern Food Storage Facilities Project (MFSP), Madhupur 2.1.11. Bangladesh Labor Act, 2006 The Bangladesh Labor Act, 2006 provides the guidance of employer’s extent of responsibility and workmen’s extent of right to get compensation in case of injury by accident while working. Some of the relevant Sections are:  Section 150. Employer’s Liability for Compensation: (1) If personal injury is caused to a workman by accident arising out of and in the course of his employment, his employer shall be liable to pay compensation in accordance with the provisions of this Act; and (2) Provided that the employer shall not be so liable - (a) in respect of any injury which does not result in the total or partial disablement of the workman for a period exceeding three days; (b) in respect of any injury, not resulting in death or permanent total disablement, caused by an accident which is directly attributable to - (i) the workman having been at the time thereof under the influence of drink or drugs, or (ii) the willful disobedience of the workman to an order expressly given, or to a rule expressly framed, for the purpose of securing the safety of workmen, or (iii) the willful removal or disregard by the workman of any safety guard or other device which he knew to have been provided for the purpose of securing the safety of workmen.  Section 151. (1) Amount of Compensation: Subject to the provisions of this Act, the amount of compensation shall be as follows, namely :- (a) where death results an amount equal to fifty from the injury cent of the monthly wages of the deceased workman multiplied by the relevant factor; or an amount of fifty thousand rupees, whichever is more; (b) where permanent total an amount equal to disablement results from sixty the injury per cent of the monthly wages of the injured workman multiplied by the relevant. 2.1.12. Bangladesh National Building Code, 2006 2.1.12.a. Demolition of Structure BNBC sets guideline for demolition of structure. The highlights of the guideline are as follows:  At planning stage, detailed survey and study shall be carried out before demolishing the structure.  A written notice will be delivered to the adjoining property holder.  Required pedestrian precaution should be taken into account before commencing the demolition  All utility lines will be disconnected and the sequence of demolition will be maintained as mentioned in the BNBC  The owner will provide compensation for all damages and loss of life. 2.1.12.b. Occupational Health & Safety Bangladesh National Building Code-BNBC (Part-7, Chapter-1) clearly sets out the constructional responsibilities according to which the relevant authority of a particular construction site shall adopt some precautionary measures to ensure the safety of the 9 Modern Food Storage Facilities Project (MFSP), Madhupur workmen. According to section 1.2.1 of chapter 1 of part 7, “In a construction or demolition work, the terms of contract between the owner and the contractor and between a consultant and the owner shall be clearly defined and make written document. These however will not absolve the owner from any of his responsibilities under the various provisions of this Code and other applicable regulations and bye-laws. The terms of contract between the owner and the contractor will determine the responsibilities and liabilities of either party in the concerned matters, within the provisions of the relevant Acts and Codes (e.g.) the Employers' Liability Act, 1938, the Factories Act 1965, the Fatal Accident Act, 1955 and Workmen's Compensation Act 1923”. (After the introduction of the Bangladesh Labor Act, 2006, these Acts have been repealed). Section 1.4.1 of chapter-1, part-7 of the BNBC, states the general duties of the employer to the public as well as workers. According to this section, “All equipment and safeguards required for the construction work such as temporary stair, ladder, ramp, scaffold, hoist, run way, barricade, chute, lift etc shall be substantially constructed and erected so as not to create any unsafe situation for the workmen using them or the workmen and general public passing under, on or near them”. Part-7, Chapter-3 of the Code has clarified the issue of safety of workmen during construction and with relation to this, set out the details about the different safety tools of specified standard. In relation with the health hazards of the workers during construction, this chapter describes the nature of the different health hazards that normally occur in the site during construction and at the same time specifies the specific measures to be taken to prevent such health hazards. According to this chapter, exhaust ventilation, use of protective devices, medical checkups etc. are the measures to be taken by the particular employer to ensure a healthy workplace for the workers. To prevent workers falling from heights, the Code in section 3.7.1 to 3.7.6 of chapter 3 of part 7 sets out the detailed requirements on the formation and use of scaffolding. According to section 3.9.2 of the same chapter, “every temporary floor openings shall either have railing of at least 900 mm height or shall be constantly attended. Every floor hole shall be guarded by either a railing with toe board or a hinged cover. Alternatively, the hole may be constantly attended or protected by a removable railing. Every stairway floor opening shall be guarded by railing at least 900 mm high on the exposed sides except at entrance to stairway. Every ladder way floor opening or platform shall be guarded by a guard railing with toe board except at entrance to opening. Every open sided floor or platform 1.2 meters or more above adjacent ground level shall be guarded by a railing on all open sides except where there is entrance to ramp, stairway or fixed ladder the above precautions shall also be taken near the open edges of the floors and the roofs”. The major challenge is the proper implementation of the Code as section 2.1 of chapter 2 of part 1 duly states that, “The Government shall establish a new or designate an existing agency responsible for the enforcement of this Code with a given area of jurisdiction. For the purpose of administering and enforcing the provisions of the Code, the enforcing agency shall have the authority of the Government and shall herein be referred to as the Authority.” 10 Modern Food Storage Facilities Project (MFSP), Madhupur Part 9, 1.2.1 states that if the land is changed and the occupants of the area are against the change, no change in use of an existing building will be allowed. 2.1.13. National Agricultural Policy, 2010 The overall objective of the National Agriculture Policy is to make the nation self-sufficient in food through increasing production of all crops including cereals and ensure a dependable food security system for all. One of the specific objectives of National Agricultural Policy is to take necessary steps to ensure environmental protection as well as ‘environment-friendly sustainable agriculture’ through increased use of organic manure and strengthening of the integrated pest management program. The policy identifies that the available technologies for agricultural production is not sufficient to cope with the unfavorable environment (climate change, flood, drought, storm, salinity, pest and diseases, river erosion). The policy also suggests creating awareness so that the chemical fertilizers and pesticides used for increased crop production do not turn out to be responsible for environmental pollution. Water logging and salinity are identified as one of the serious problem in some parts of the country including the coastal areas for agricultural activities and environmental damage. The policy recommends for crop rotation and salt tolerant crop varieties. 2.1.14. National Food Policy, 2006 The goal of the food policy is to ensure a dependable food security system for all people of the country at all times. The objectives of the food policy are: Objective-1: to ensure adequate and stable supply of safe and nutritious food; Objective-2: to enhance purchasing power of the people for increased food accessibility; and Objective-3: to ensure adequate nutrition for all (especially women and children). Policy 1.2.2.1 of National Food Policy, 2006 states the Development of private sector food grain storage and movement system. The storage facilities presently available in the private sector are not suitable for long-term storage of grain and other food commodities. For this, construction of warehouses of scientific standard specifications is necessary. The government policy should be to encourage the process by amending and simplifying banking regulations on credit facilities to private sector entrepreneurs for construction of appropriate commodity specific warehouses, cold storages and acquiring transportation vehicles for freightage. To promote development of storage and movement system of food commodities in the private sector, the Government will:  allow unrestricted movement of foodstuff in the country; and  ensure credit facilities to develop storage structures in appropriate places. Under the Public food grain stock (Policy 1.3.2) the stated major objective of the public food distribution system is to supply required quantity of grain to the food-assisted development and income transfer programs for the poor, who are unable to purchase minimum required quantity of food from the market at prevailing market prices. In addition to maintaining working stock of food grains to operate various food-based safety net programs, the 11 Modern Food Storage Facilities Project (MFSP), Madhupur Government also maintains a security reserve to cope for emergency needs during disasters. In order to handle uncertainties of import arrival and emergency off take requirements, the Government has decided to maintain a public stock of 1.0 million tons of food grains. Policy 2.1 Transitory shock management highlights on emergency preparedness. Emergency preparedness is needed to alleviate the transitory food insecurity caused by floods, cyclones and other natural disasters that often occur in Bangladesh. Emergency relief programs are operated to mitigate the distress of the affected people. To satisfy the emergency distribution needs public food grain stocks equal to three months of emergency demand along with a relief system to distribute food, clean water, medicines and other essentials are being maintained. In addition, the required level of minimum public food grain stocks should be reviewed annually considering the changing situations in domestic and global markets coupled with disaster proneness. According to 2.1.2, Emergency distribution from public stock, to provide for the emergency food needs of households in the disaster-affected areas, the policy of the Government is to:  ensure quick distribution of food in affected households in times of disaster;  hold enough food grain stocks to cover at least three months of emergency distribution need in addition to its normal working stock needed for the regular food-based programs; Strategy 3.5: Safe, quality food supply focuses on ensuring the quality of food at all levels of marketing (e.g. assembling, cleaning, sorting, processing and packaging). The following programs will be undertaken to ensure supply of safe and quality food through formulating new regulations by proper amendments of the existing ones and through encouraging the private sector initiatives:  formulation of uniform arrangement, development of testing techniques, setting of standards and their application and compulsory enforcement;  investment in development of packing or packaging and safe storage facilities;  increase laboratory facilities and impart practical knowledge for development of the quality of food and food products;  training for concerned officials and institutions in protecting the grades and standards of food products;  campaign for nutrition enhancing quality and safe food; and  develop and enforce appropriate regulatory mechanism to control indiscriminate use of harmful additives, preservatives and toxic elements in production and in the marketing chain for foodstuffs 2.1.15. National Food Policy Plan of Action, 2008-2015 The National Food Policy Plan of Action (PoA) translated the provisions of the National Food Policy, 2006 towards achieving its three core objectives into 26 strategic area of 12 Modern Food Storage Facilities Project (MFSP), Madhupur intervention, priority actions to be undertaken in the short, medium and long term over the period 2008-2015. The policy mentioned that strengthened efforts to raise productivity and efficiency in food grain production, to support agricultural commercialization and diversification, in due consideration of environmental impacts (agricultural conservation), will be paramount. Actions are needed on many fronts, including agricultural technology development, input (seeds, fertilizers, irrigation, and machinery) supply and access expansion, and, critically, rural financing, which currently stands far below rural producers’ needs, especially those of small and marginal farmers. In line with MDG7 (Ensure environmental sustainability), environmental sustainability has been effectively mainstreamed into the NFP agricultural policy agenda for enhancing food supply and also biodiversity. 2.1.16. Bangladesh Country Investment Plan (CIP), 2011 The Bangladesh Country Investment Plan provides a coherent set of priority investment programs to improve food security and nutrition in an integrated way. It is a comprehensive plan, builds on the existing framework, reflects the Government’s investment priorities and aims to: (i) plan and invest resources in a coordinated way; (ii) increase convergence and alignment of budget and external sources of funding, and; (iii) to mobilize additional resources. Proposed investments relate to strengthening physical, institutional and human capacities in the field of agriculture, water management, fisheries, livestock, agricultural marketing, food management, safety nets, and nutrition and food safety. 2.2. World Bank’s Environmental Safeguard Policies The World Bank's environmental and social safeguard policies are a cornerstone of its support to sustainable poverty reduction. The objective of these policies is to prevent and mitigate undue harm to people and their environment in the development process. Safeguard policies provide a platform for the participation of stakeholders in project design, and act as an important instrument for building ownership among local populations. The effectiveness and development impact of projects and programs supported by the Bank has substantially increased as a result of attention to these policies. The World Bank has ten environmental, social, and legal safeguard policies. The World Bank's environmental assessment policy and recommended processing are described in Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment. This policy is considered to be the umbrella policy for the Bank's environmental "safeguard policies" which among others include: Natural Habitats (OP 4.04), Forests (OP 4.36), Pest Management (OP 4.09), Physical Cultural Resources (OP 4.11), and Safety of Dams (OP 4.37). Operational Policies (OP) are the statement of policy objectives and operational principles including the roles and obligations of the Borrower and the Bank, whereas Bank Procedures (BP) is the mandatory procedures to be followed by the Borrower and the Bank. The complete list of policies is given below and the Environment and Social policies are discussed. Environmental Policies  OP/BP 4.01 Environmental Assessment 13 Modern Food Storage Facilities Project (MFSP), Madhupur  OP/BP 4.04 Natural Habitats  OP/BP 4.09 Pest Management  OP/BP 4.11 Physical Cultural Resources  OP/BP 4.36 Forests  OP/BP 4.37 Safety of Dams Social Policies  OP/BP 4.10 Indigenous Peoples  OP/BP 4.12 Involuntary Resettlement Legal Policies  OP/BP 7.50 International Waterways  OP/BP 7.60 Disputed Areas In addition to the 10 safeguard policies, BP 17.5 exists as the Bank Disclosure Policy, which also relates to safeguards. Bank disclosure Policy supports decision making by the Borrower and Bank by allowing the public access to information on environmental and social aspects of projects. The policy requires disclosure in both English and Local language before project appraisal and must meet the World Bank standards. 2.2.1 OP/BP 4.01 Environmental Assessment Environmental Assessment is the umbrella safeguard policy to identify, avoid, and mitigate the potential negative environmental and social impacts associated with Bank lending operations. In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. EA is a process whose breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, sitting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. EA takes into account the natural environment (air, water and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples and physical cultural resources); and trans-boundary and global environmental aspects. The borrower is responsible for carrying out the EA and the Bank advises the borrower on the Bank's EA requirements. 14 Modern Food Storage Facilities Project (MFSP), Madhupur The Bank classifies the proposed project into three major categories, depending on the type, location, sensitivity, and scale of the project and the nature and magnitude of its potential environmental impacts. Category A: The proposed project is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities subject to physical works. Category B: The proposed project’s potential adverse environmental impacts on human population or environmentally important areas-including wetlands, forests, grasslands, or other natural habitats- are less adverse than those of Category A projects. These impacts are site specific; few if any of them are irreversible; and in most cases mitigation measures can be designed more readily than Category A projects. Category C: The proposed project is likely to have minimal or no adverse environmental impacts. 2.2.2 OP/BP 4.04 Natural Habitats The conservation of natural habitats is essential for long-term sustainable development. The Bank therefore supports the protection, maintenance, and rehabilitation of natural habitats and their functions in its economic and sector work, project financing, and policy dialogue. The Bank supports, and expects borrowers to apply, a precautionary approach to natural resource management to ensure opportunities for environmentally sustainable development. The Bank does not support projects that involve the significant conversion or degradation of critical natural habitats. 2.2.3 OP/BP 4.09 Pest Management To manage pests that affect either agriculture or public health, the Bank supports a strategy that promotes the use of biological or environmental control methods and reduces reliance on synthetic chemical pesticides. In Bank- financed projects, the borrower addresses pest management issues in the context of the project's environmental assessment. In appraising a project that will involve pest management, the Bank assesses the capacity of the country's regulatory framework and institutions to promote and support safe, effective, and environmentally sound pest management. As necessary, the Bank and the borrower incorporate in the project components to strengthen such capacity. The Bank uses various means to assess pest management in the country and support integrated pest management and the safe use of agricultural pesticides: economic and sector work, sectoral or project-specific environmental assessments, participatory IPM assessments, and investment projects and components aimed specifically at supporting the adoption and use of IPM. In Bank-financed agriculture operations, pest populations are normally controlled through IPM approaches, such as biological control, cultural practices, and the development and use of crop varieties that are resistant or tolerant to the pest. The procurement of any pesticide in a Bank-financed project is contingent on an assessment of the nature and degree of associated risks, taking into account the proposed use and the intended user. With respect to the classification of pesticides and their specific formulations, the Bank refers to the World 15 Modern Food Storage Facilities Project (MFSP), Madhupur Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines to Classification (Geneva: WHO 1994-95). 2.2.4 OP/BP 4.11 Physical Cultural Resources Physical cultural resources are defined as movable or immovable objects, sites, structures, groups of structures, and natural features and landscapes that have archaeological, paleontological, historical, architectural, religious, aesthetic, or other cultural significance. Their cultural interest may be at the local, provincial or national level, or within the international community. Physical cultural resources are important as sources of valuable scientific and historical information, as assets for economic and social development, and as integral parts of a people's cultural identity and practices. The Bank assists countries to avoid or mitigate adverse impacts on physical cultural resources from development projects that it finances. The impacts on physical cultural resources resulting from project activities, including mitigating measures, may not contravene either the borrower's national legislation, or its obligations under relevant international environmental treaties and agreements. The borrower addresses impacts on physical cultural resources in projects proposed for Bank financing, as an integral part of the environmental assessment (EA) process. 2.2.5 OP/BP 4.36 Forests Forest is defined as an area of land of not less than 1.0 hectare with tree crown cover (or equivalent stocking level) of more than 10 percent that have trees with the potential to reach a minimum height of 2 meters at maturity in situ. A forest may consist of either closed forest formations, where trees of various stories and undergrowth cover a high proportion of the ground, or open forest. The definition includes forests dedicated to forest production, protection, multiple uses, or conservation, whether formally recognized or not. The definition excludes areas where other land uses not dependent on tree cover predominate, such as agriculture, grazing or settlements. In countries with low forest cover, the definition may be expanded to include areas covered by trees that fall below the 10 percent threshold for canopy density, but are considered forest under local conditions. The Bank's forests policy aims to reduce deforestation, enhance the environmental contribution of forested areas, promote afforestation, reduce poverty, and encourage economic development. The Bank assists borrowers with the establishment and sustainable management of environmentally appropriate, socially beneficial, and economically viable forest plantations to help meet growing demands for forest goods and services. 2.3 Environment, Health & Safety Guidelines The Environment, Health, and Safety (EHS) Guidelines contain the performance levels and measures that are generally considered to be achievable in new facilities or project by existing technology at reasonable costs. These Guidelines will be applicable to the Project particularly with respect to air emissions, ambient air and noise quality standards, waste water quality, hazardous material and waste management, and occupational and community health and safety management. They contain performance levels and measures that are considered to be achievable in new facilities at reasonable costs using existing technologies. Table 2.1 shows the EHS guidelines of World Bank. 16 Modern Food Storage Facilities Project (MFSP), Madhupur Table 2.1 EHS Guidelines of World Bank Environmental The Environment, Health, and Safety (EHS) These Guidelines will be Health and Safety Guidelines contain the performance levels and applicable to the Project Guidelines measures that are generally considered to be particularly with respect to air achievable in new facilities or project by existing emissions, ambient air and technology at reasonable costs. noise quality standards, waste water quality, hazardous material and waste management, and occupational and community health and safety management. Environmental, The Environmental, Health, and Safety (EHS) Relevant as the project Health, and Guidelines are technical reference documents includes provision of Safety Guidelines with general and industry-specific examples of improved navigation routes PORTS, Good International Industry Practice (GIIP). and terminal facilities. MP HARBORS, and When one or more members of the World Bank section of the ESIA report has TERMINALS Group are involved in a project, these EHS been dedicated to mitigate Guidelines are applied as required by their adverse impact due to the respective policies and standards. These industry proposed intervention. sector EHS guidelines are designed to be used together with the General EHS Guidelines document, which provides guidance to users on common EHS issues potentially applicable to all industry sectors. For complex projects, use of multiple industry- sector guidelines may be necessary. The EHS Guidelines for Ports, Harbors, and Terminals are applicable to commercial ports, harbors, and terminals for cargo and passengers transfer. Shipping (including repair and maintenance of ships), fuel terminals, or railways are addressed in separate industry sector EHS Guidelines, specifically the EHS Guidelines for Shipping, Crude Oil and Petroleum Product Storage, Railways, respectively. The EHS The EHS Guidelines for Shipping include Broadly applicable as the Guidelines for information relevant to the operation and project provides improved Shipping maintenance of ships used for the transport of navigation routes and bulk cargo, and goods. Cargo handling, vessel terminal facilities. The EMP maintenance, and other in-port activities are is prepared to address covered under the EHS Guidelines for Ports and mitigation measures due to Harbors while issues specific to the transfer and proposed interventions. storage of bulk fuels are covered in the EHS Guidelines for Crude Oil and Petroleum Product Terminals. 17 Modern Food Storage Facilities Project (MFSP), Madhupur 2.4 Social Policies & Legislation of Bangladesh 2.4.1 General Description Infrastructure development projects using lands in Bangladesh is designed and implemented under the legislative and regulatory framework to compensate the affected persons due to land acquisition using the power of eminent domain. Whenever it appears to the Government that any property in any locality is needed or is likely to be needed for any public purpose or in the public interest, the property is acquired using power of eminent domain. Land acquisition is governed by the Acquisition and Requisition of Immovable Property Ordinance, 1982 (Ordinance II of 1982). The ordinance supersedes earlier laws including the Land Acquisition Law of 1894 and others that have been in force between 1947 and 1982. In addition to the Ordinance, acquisition of any land or forest area, in Chittagong Hill-Tracts (CHT) districts require consent under the Chittagong Hill-Tracts (Land Acquisition) Regulation 1958, the CHT Regional Council Act 1998 and the Forest Act (1927). There is no national policy in Bangladesh governing social effects of infrastructure development projects on the project area communities. However, the Constitution of Bangladesh and the national development strategy (Poverty Reduction Strategy Paper 2005-2009) provides some rights to the affected persons, communities and groups those are not upheld in the Ordinance II of 1982, the instrument followed for land acquisition. The active instruments under the legislative and regulatory framework in Bangladesh are discussed hereunder. 2.4.2 Constitution of Bangladesh The fundamental rights under the Constitution indicate the general guidelines for a policy on resettlement/rehabilitation of citizens adversely affected (whatever be the mechanism) due to any activity of the State. Article 40 of the constitution states categorically that every citizen has the right to practice any lawful occupation which implies that anything that impedes such right (a) should not be done or (b) there should be supplementary measures to make good the losses incurred by the citizen. Resettlement and rehabilitation of adversely affected people due to infrastructure projects very clearly falls within this requirement for supplementary measures. However, as per Article 42, sub-clause 2, no law with provision of compensation for acquisition of land can be challenged in a court on the ground that such compensation has been inadequate. 2.4.3 The Acquisition and Requisition of Immovable Property Ordinance, 1982 This Ordinance is the basic instrument governing land acquisition in Bangladesh. It is restricted to “legal” owners of property as supported by records of ownership such as deeds, title or agreements to compensating for land as well as any business, structure, trees and crops on the land. The owners of acquired land receive cash compensation at market value with a premium of 50 per cent on the assessed price. The law specifies methods for calculation of market value of property based on recorded prices obtained from relevant Government departments such as Registrar (land), Public Works Department (structures), Department of Forest (trees), Department of Agriculture (crops) and Department of Fisheries (fish stock). 18 Modern Food Storage Facilities Project (MFSP), Madhupur The Ministry of Land (MOL) is authorized to deal with land acquisition. The MOL delegates some of its authority to the Commissioner at Divisional level and to the Deputy Commissioner at the District level. The Deputy Commissioners (DCs) are empowered by the MOL to process land acquisition under the Ordinance and pay compensation to the legal owners of the acquired property. Khas (government owned land) lands should be acquired first when a project requires both khas and private land. If a project requires only khas land, the land will be transferred through an inter-ministerial meeting following the acquisition proposal submitted to DC or MOL as the case may be. The DC is empowered to acquire a maximum of 50 standard bigha (6.75 ha) of land without any litigation where the Divisional Commissioner is involved for approval. Acquisition of land more than 50 standard bigha is approved from the central land allocation committee (CLAC) headed by the chief executive of the Government of Bangladesh proposed by the MOL. The land owner needs to establish ownership by producing record-of-rights in order to be eligible for compensation under the law. The record of rights prepared under Section 143 or 144 of the State Acquisition and Tenancy Act 1950 (revised 1994) are not always updated and as a result legal land owners have faced difficulties trying to “prove” ownership. The affected person (AP) has also to produce rent receipt or receipt of land development tax, but this does not assist in some situations as a person is exempted from payment of rent if the area of land is less than 25 bigha (3.37 ha). 2.4.4 The East Bengal State Acquisition and Tenancy Act, 1950 (Revised, 1994) The State Acquisition and Tenancy Act (Sections 86 & 87) also define the ownership and use right of alluvion (payosti or reformation in situ or original site) and diluvion land (nadisikosti) in the country. In legal terms, eroded lands (sikosti) inside the alluvion-diluvion (AD) line (i.e. including submerged land or underwater land) are considered khas land once declared by concerned Deputy Commissioner (DC) demarcating the AD Line. However, the "original" owner(s) can claim the land if it reappears through natural process within 30 years. The original private owners cannot claim any eroded land if developed by the government through land filling for use in public purpose. 2.4.5 Constitutional Right of the Tribal Peoples Rights In the context of People’s Republic of Bangladesh, the Constitution of Bangladesh does not mention the existence of the cultural and ethnic minorities in Bangladesh. The only protective provision for the ethnic minorities that the policy makers often refer to in the context is Article 28 (4) which states that: Nothing shall prevent the state from making special provision in favour of women and children or for the advancement of any backward section of the citizens. The above provision is an ambiguous one and it does not define who or what constitutes "backward". However, the Government recognizes existence of “tribal peoples” and the need for special attention and in general tribal people are essentially viewed as backward, poor and socio-economically & culturally inferior. Towards this end a special program was initiated in 1996-97 by the Prime Minister’s Secretariat aimed at improving the socio-economic situation of the indigenous people of Bangladesh, resident outside the Chittagong Hill Tracts. 19 Modern Food Storage Facilities Project (MFSP), Madhupur 2.4.6 The Chittagong Hill Tracts Regulation, 1990 The Chittagong Hill Tracts Regulation, 1900 (Regulation I of 1900) is the regulatory framework for State sovereignty over the traditional rights of the tribal peoples living in the Chittagong Hill Tracts (CHTs) region.4 They are governed through Revenue Circle Chiefs5 who are local revenue collectors vide an amalnama (authorization by the Government). The Deputy Commissioner and the Commissioner from the Central Government reserve the authority to settle land to the hill-men or non-hill residents or lease out land (non- transferable) for rubber plantation or establishing industries in the CHTs. The regulation provides the right to possessing plough cultivable land up to 5 acres by hill men or non-hill residents. The headman is responsible for the conservation of the resources of his mouza through exercising his authority to (i) prohibit the removal of forest produces by residents of respective mouzas other than for their domestic purposes or by non-residents for any purpose, (ii) exclude any area or areas in his mouzas from the jhuming (shifting cultivation), (iii) prevent new comers from cutting jhums in his mouza, and (iv) prevent a person from grazing cattle in his mouza. 2.4.7 The Chittagong Hill Tracts (Land Acquisition) Regulation, 1958 The Chittagong Hill Tracts (CHT) region has been enjoying the status of a special region since British period. Most of the land in CHT belongs to the Government either as reserve forest or as unclassified state forest. The CHT Regulation I of 1900 was the sole legal instrument for the governance and administration of the Hill Tracts. Under the regulation, the DC could resume land even though settlement of the same might have been given earlier. The rule prescribed payment of compensation for various interests as in the case of land acquisition. It was expedient to provide for the acquisition of land in CHT the Government made the Chittagong Hill-Tracts (Land Acquisition) Regulation, 1958. This regulation has provision for payment of compensation for requisitioned property. The compensation may be fixed by agreement or by rules framed on this behalf. 2.4.8 The CHT Regional Council Act, 1998 The National Parliament of Bangladesh in 24 May 1998 passed the Peach Accord 1997 as the “Chittagong Hill Tracts Regional Council Act, 1998 (Act 12 of 1998). In addition to re- establishing peace, the Accord recognized the ethnic people’s right to land, culture, language, and religion. The Accord set out detailed provisions for strengthening the system of self- governance in the CHT, and redressing the most urgent land-related problems including resolution of land disputes by a commission on land, the transfer of authority for land administration to the hill district councils (HDCs), the cancellation of lease granted to non- residents during the conflict period, the distribution of land to ethnic or “tribal” villages, and the strengthening of customary land rights. Within the meaning of the Act 12 of 1998, no lands, hills and forests within the control and jurisdiction of the HDCs shall be acquired or transferred by the government without consultation and consent of the Regional Council. No law will be executed in the region which is not developed and enacted in consultation and agreement with the tribal peoples in 20 Modern Food Storage Facilities Project (MFSP), Madhupur CHT. A ministry on CHT Affairs was established by appointing a Minister from among the tribal communities of hill districts. An Advisory Council from the CHT region assists this ministry. However, there is a demand for extending the scope of the CHT Affairs Ministry to include the tribal peoples in other areas of the country. 2.4.9 Ethnic Minority Rights in PRSP, 2005 Relevant strategic suggestions in the PRSP 2005 to preserve the cultural, social and economic identity and interests of the ethnic populations in and outside CHT are as follows:  Effective recognition of ethnic minority communities and their specific needs in all relevant government policies and programs towards improving the socio-economic conditions of these communities.  Proper actions for protecting the rights of ethnic minority people, particularly their rights to land and forests.  Transfer of land administration in CHT to the hill districts councils in accordance with the ‘Hill District Councils Acts of 1989’.  Provide education to ethnic minority people with a curriculum that allows learning in their own language at the primary level.  Strengthen their competence in job markets through affirmative action's at higher levels of education and skill training to promote their inclusion in mainstream economic life.  Scale-up efforts to provide health care, clean water and sanitation facilities to ethnic minority areas in general and to the more disadvantaged groups among them in particular.  Increase and utilize property the fund available in the Prime Minister’s office for the development of the ethnic minority people of the plane lands.  Provide wider access to electrification and telecommunications for ethnic minority communities, particularly in the Hill Tracts. 2.4.10 GOB Laws and Land Acquisition The principle legal instrument governing land acquisition in Bangladesh is the Acquisition and Requisition of Immovable Property Ordinance, 1982(Ordinance II of 1982 with amendments up to 1994) and other land laws and administrative manuals relevant to land administration in Bangladesh. According to the Ordinance, whenever it appears to the Government of Bangladesh that any property in any locality is needed or is likely to be needed for any public purpose or in the public interest, the Government can acquire the land provided that no property used by the public for the purpose of religious worship, graveyard and cremation ground. The 1982 Ordinance requires that compensation be paid for (i) land and assets permanently acquired (including standing crops, trees, houses); and (ii) any other damages caused by such acquisition. The Deputy Commissioner (DC) determines (a) market 21 Modern Food Storage Facilities Project (MFSP), Madhupur value of acquired assets on the date of notice of acquisition (based on the registered value of similar property bought and/or sold in the area over the preceding 12 months), and (b) 50% premium on the assessed value (other than crops) due to compulsory acquisition. The 1994 amendment made provisions for payment of crop compensation to tenant cultivators. Given that people devalue land during title transfer to minimize tax payment, compensation for land paid by DC including premium largely remains less than the actual market price. 2.5 World’s Bank Social Safeguard Policy 2.5.1 Involuntary Resettlement (OP 4.12) The WB’s experience indicates that involuntary resettlement under development projects, if unmitigated, often gives rise to severe economic, social, and environmental risks: production systems are dismantled; people face impoverishment when their productive assets or income sources are lost; people are relocated to environments where their productive skills may be less applicable and the competition for resources greater; community institutions and social networks are weakened; kin groups are dispersed; and cultural identity, traditional authority, and the potential for mutual help are diminished or lost. This policy includes safeguards to address and mitigate these impoverishment risks. The overall objectives of the Policy are given below.  Involuntary resettlement should be avoided where feasible, or minimized, exploring all viable alternative project designs.  Where it is not feasible to avoid resettlement, resettlement activities should be conceived and executed as sustainable development programs, providing sufficient investment resources to enable the persons displaced by the project to share in project benefits. Displaced persons should be meaningfully consulted and should have opportunities to participate in planning and implementing resettlement programs. Displaced persons should be assisted in their efforts to improve their livelihoods and standards of living or at least to restore them, in real terms, to pre-displacement levels or to levels prevailing prior to the beginning of project implementation, whichever is higher. 2.5.2 Indigenous People (OP 4.10) For purposes of this policy, the term “Indigenous Peoples” is used in a generic sense to refer to a distinct, vulnerable, social and cultural group possessing the following characteristics in varying degrees:7 The tribal peoples living in the Chittagong Hill Tract districts and some scattered in the plain districts as well are indigenous peoples as per their cultural distinction. The OP defines the process to be followed if the project affects the tribal people. The tribal peoples are indigenous as they have  self-identification as members of a distinct indigenous cultural group and recognition of this identity by others;  collective attachment to geographically distinct habitats or ancestral territories in the project area and to the natural resources in these habitats and territories; 22 Modern Food Storage Facilities Project (MFSP), Madhupur  customary cultural, economic, social, or political institutions that are separate from those of the dominant society and culture; and  an indigenous language, often different from the official language of the country or region. 2.6 Implication of National Policies and Legislations on this Project The Categorization list mentioned in ECR’97 is performed based on the activity. There is no direct mention of the category for Modern Food Grain Silo in ECR’97. However, cold storage is categorized as “Orange B” under ECR’97. Therefore the project is considered as “Orange B”. The project is aimed to construct modern food grain storage silo which will not involve demolishing of any structure and use of modern Chiller system and use of Nitrogen for disinfection during operation period. DG Food is responsible for carrying out Initial Environmental Examination, developing Environmental Management Plan and obtaining No Objection Certificate, site clearance and environmental clearance certificate. 2.7 Implication of Environmental Safeguard Policies of WB on the Project The project has been considered as a Category B project, due to the risk associated with the extent of foundation construction, construction of super structure from prefabricated steel sheet, environmental and occupation health and safety during project operation. The Project has triggered the environmental safeguard policy for environmental assessment (OP/BP 4.01). The Silo will introduce modern cooling facilities which will reduce the existence of rodents and insecticides. Chiller system will be used during the operation phase of the Silo for temperature control and Nitrogen gas for disinfection. The use of nitrogen will be through mechanised and automated system. As per Bank requirement, the borrower needs to consult project-affected groups and local nongovernmental organizations about the project's environmental aspects and takes their views into account. The borrower initiates such consultations as early as possible. In addition, the borrower consults with the community people around throughout project implementation as necessary to address EA-related issues that affect them. 2.8 Implication of Social Safeguard Policies of WB on the Project The legislatives and regulatory framework is not adequate to deal with the adverse impacts associated with land acquisition and involuntary displacement of peoples for project purpose. The law does not cover project-affected persons without title and does not ensure replacement value of the property acquired. The law does not initiate any measure for restoration of livelihoods of the affected persons. As a result, land acquisition potentially diminishes productive base of affected farm families which is against the spirit of the Bank policy on involuntary resettlement (OP 4.12). 23 Modern Food Storage Facilities Project (MFSP), Madhupur Specific to the project, no land will need to be acquired and no resettlement will need to be carried out in the first phase construction. However, in subsequent construction phase(s), the government may like to acquire private land and/or public land from private uses. The acts therefore, trigger the Bank OP 4.12 on involuntary resettlement. No tribal people are existent in and around the sites reviewed for the project. Therefore the Bank OP 4.10 is not triggered to the project. However, if such groups are identified during the detailed engineering design, the proponents will select to drop the site from construction. 24 Modern Food Storage Facilities Project (MFSP), Madhupur 3. PROJECT DESCRIPTION 3.1. Location of the Project Madhupur is one of the 12 Upazilas in Tangail District of Dhaka Division. The Upazila is a part of the Madhupur highland of the greater Mymensingh area. Madhupur has a Government khas land area of 5.81 acre which is 3.5 km away towards north from the Madhupur Upazila road. The proposed site is located at the coordinate of N24°37΄43΄΄ and E90°03΄39΄΄. The site is adjacent to Mymensingh-Tangail-Jamalpur high-way. The Madhupur Silo sub Project located in Madhupur Upazila, at about 3.5 km from the Upazila HQ, into the north, in Ramkrishnabari Mouza, near Kakraid Bazar. Again, Madhupur Upazila HQ is at about 150 km away into the north from Dhaka City and 50 km away from the Tangail District HQ. Madhupur is bounded by Jamalpur Sadar Upazila in the north, Gopalpur and Ghatail Upazilas in the south, Muktagachha and Fulbaria Upazilas in the east and Sarishabari and Gopalpur Upazilas in the west. Its coordinate is at 24°37’00”N90°01’30”E (24.6167°N 90.0250°E). The total area of the Upazila or Sub District is 500 sq km. The population of the District is 375,295 (1991) with density of 750 per sq km. Main rivers are Jhinai, Bangshi, Banar and Atrai. The present Madhupur LSD is situated on the Tangail to Mymensingh Highway, in Madhupur Upazila HQ, connected to road, has 4 godowns in all, out of which one is unworkable and rest are workable having its maximum capacity of 3,250 tons. All the working godowns are fully loaded with rice and have no space at all. Rice comes from the northern districts and distributed locally and sometimes to other LSDs. The mode of transport is truck. The location of proposed Madhupur silo site in Google earth is shown in Figure –3.1.The location map of proposed Madhupur silo site in GIS is shown in Figure –3.2. The Madhupur BFIDC (Rubber Division) office is at east side of Silo boundary where there is a small mosque for the BFIDC official people. On the western side, there is a primary school and UP office building. All these physical infrastructures (primary school and mosque) are outside the Silo boundary wall. There is no other physical and cultural resources near the silo campus. 25 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 3.1: Location Map of Madhupur Silo Site in Google earth 26 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 3.2: Location Map of Madhupur Silo Site in GIS 27 Modern Food Storage Facilities Project (MFSP), Madhupur 3.2. Description of Project Works Total project works has been considered in two phases. In the first phase, the sub-project preparation works like; the boundary wall, site development by earth filling, office building etc. has been done. In the second phase; main construction works like 16 nos. flat bottom prefabricated steel silo bins and silo related ancillary works as well as interventions will be constructed/ installed. Design and estimates of the silo bins and ancillary works has been completed and awaiting for the engagement of contractors of the construction works. A preliminary layout plan is given in Figure 3.3.The following interventions will be constructed under Madhupur sub-project: 1. Gate 2. Guardroomandgate4.4m x6m. 3. Truck scale 4. Sampling house 5. Laboratoryhouse+weightcontrol15.6x6m. 6. Truck parking 7. Bulktruckreceiving26x16m. 8. Control room 9x10m. 9. Bulkelevatortower8.9x6m. 10. 16steelsilo bins 11. Surges bin tower 12. Bulkhouse12x15m. 13. Bagginghouse30x18m. 14. Emptygunnybaggodown7.5x24m. 15. Workshopcumstore12.6x15.4m. 16. Substation17x10m. 17. Inspection bungalow 18. Silo office 19. Car parking 20. Public toilet for drivers and other 4.8x7.8m. 21. Canteen 22. Fence 23. 4storieddormitoryforsupportstaff 24. 3storiedofficersdormitory 25. Fortifiedricebagsreceiving6x18m. 28 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 3.3: Preliminary Layout Plan of Madhupur Silo Site 29 Modern Food Storage Facilities Project (MFSP), Madhupur 3.3. Structures in Existing LSD and Silo Site of Madhupur The present Madhupur LSD has four godown buildings, out of which one godown is not in good condition and the LSD is running with its maximum capacity of 3,250 tons. All the working godowns are fully loaded with rice. Rice comes from the northern districts and distributed locally. About 2 km from Madhupur LSD to east along Tangail - Mymensingh highway Government khas land has been allotted to DG Food and now this land is unused and open are proposed silo site as shown in the Figure-3.3. The office of the Bangladesh Forest Industries Development Corporation, BFIDC (Rubber Division) is in the east, and the land at the south side, leased from Government, is used for seed production for Bangladesh Agriculture Development Corporation (BADC), at the west Dhaka-Tangail high-way & at the east Government land are using for producing Rubber garden. There is no other existing structure in the Madhupur silo site (Figure 3.4) Figure 3.4: Proposed Silo Site (Open Land) 3.4. Construction of Steel Silos There are sixteen nos. of steel silos will be constructed under this proposed project. Each silos capacity for storage is 3000 MT. There are lot of equipment will be used during silos operation like belt conveyor, bagging station, chain conveyor, chiller etc. The speed control time is 60 t/h. The total capacity of storage will be 48000 MT. A preliminary steel silos design is shown in Figure 3.5. 30 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 3.5: Preliminary design of steel silos 3.5. Implementation Schedule Sl. Year-1 (months) Year-2 Activities no. 1-4 5-8 9-12 1-4 5-8 9-12 Design, drawing, bid 1 documents tendering, contractor selection etc. Foundation works for 2 silos and ancillary works Superstructures and all 3 other ancillary works Post operation testing 4 and commissioning 31 Modern Food Storage Facilities Project (MFSP), Madhupur 4. DESCRIPTION OF THE ENVIRONMENT 4.1 Physical Environment 4.1.1 Climate Although less than half of Bangladesh lies within the tropics, the presence of the Himalaya mountain range has created a tropical macroclimate across most of the east Bengal land mass. Bangladesh can be divided into seven climatic zones (Rashid 1991). According to the classification, the project area is located in the South-central climatic zone (Figure 4.1). South-Central Zone:In this zone rainfall is abundant, being above 1,900 mm. The range of temperature is, as can be expected, much less than to the west, but somewhat more than in South-eastern zone. This is a transitory zone between the South-eastern, North-western and South-western zones and most of the severe hail storms, nor'westers and tornadoes are recorded in this area. Like other parts of the country, the project area is heavily influenced by the Asiatic monsoon, and it has these three distinct seasons:  Pre-monsoon hot season (from March to May),  Rainy monsoon season (from June to October), and  Cool dry winter season (from November to February). The pre-monsoon hot season is characterized by high temperatures and thunderstorms. April is the hottest month in the country with mean temperatures ranging from 27°C in the east and south, to 31°C in the west-central part of the country. After April, increasing cloud-cover reduces the temperature. Wind direction is variable during this season, especially during the early part. Rainfall, mostly caused by thunderstorms, at this time can account for 10 to 25 percent of the annual total. The rainy monsoon season is characterized by southerly or south-westerly winds, very high humidity, heavy rainfall and long periods of consecutive days of rainfall. The monsoon rain is caused by a tropical depression that enters the country from the Bay of Bengal. About 80% of the annual precipitation occurs during the five-month monsoon season from May to September. The cool dry season is characterized by low temperatures, cool air blowing from the west or northwest, clear skies and meager rainfall. The average temperature in January varies from 17°C in the northwest and north-eastern parts of the country to 20°C to 21°C in the coastal areas. Minimum temperatures in the extreme northwest in late December and early January reach between 3°C to 4°C. 32 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.1: Climatic Zones of Bangladesh 33 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.1.1. Temperature term average monthly temperature data (1987-2013) Long-term (198 2013) collected at Tangail weather station of Bangladesh Meteorological Department. The highest average recorded temperature in this weather station was 33.8 . The lowest average recorded temperature was 8°C in April. found in the month of January which was 11.3°C.°C. Both of the average monthly temperature graphs show that this area faces high temperature from March to June and lowest temperature during winter remains from December to February in the year. Average Monthly Maximum and Minimum (1987 Temperature in Tangail Station (1987-2013) 40 Temperature °C 35 30 25 20 15 10 5 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Min. Temp. 11.3 14.3 18.9 22.7 24.0 25.7 26.1 26.2 25.7 23.4 18.3 13.4 Max. Temp. 23.8 27.5 31.7 33.8 33.4 32.8 32.0 32.1 32.1 31.7 29.4 25.7 Figure 4.2: Average Monthly Maximum & Minimum Temperature 4.1.1.2. Rainfall The rainfall data collected from Tangail Meteorological station represents that maximum rainfall occurs during June to September and the lowest rainfall occurs in November to February during winter season. Statistical data of 1987 to 2013 shows that Tangail station experiences almost 3200 mm rainfall during monsoon. In the month of December and January of winter season around 10 mm rainfall occurred in the region of Tangail weather station. Figure 4.3: Average Monthly Total Rainfall in Tangail Station 34 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.1.3. Humidity Humidity remains high in summer and comparatively low in winter season. The statistical 2013 indicates that humidity in the above area maximize data of humidity from 1987 to 201 maximized in 85 On the June to September in the year which ranges from 83% to 85%. he other hand, humidity falls around 70% % in February, March and April during the winter season in the Tangail station area (Figure 4.4). Figure 4.4: Average Monthly Relative Humidity in Tangail Station 4.1.1.4. Wind Speed The statistical wind speed data from 1987 to 2013 (Figure 4.5)) shows that average wind speed remained maximum with 1.85 mps in June. . The minimum wind speed was 0.68mps in the month of December in the area of Tangail weather station. Average Monthly Maximum WInd Speed in Tangail Station (1987-2013) Wind Speed (mps) 2 1.8 1.6 1.4 1.2 1 0.8 0.6 0.4 0.2 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Wind Speed (meter per 0.86 1 1.31 1.80 1.77 1.85 1.80 1.51 1.27 0.85 0.72 0.68 second) Figure 4.5: Average Monthly Maximum Wind Speed in Tangail Station 35 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.1.5. Sunshine The statistical sunshine data from 1987 to 2013 (Figure 4.6) ) shows that average sunshine remained maximum with 7.7 hours in March. The minimum sunshine was 4.13 hours in the month of July in the area of Tangail weather station. Once a crop is harvested, it may have to be stored for a periodd of time before it can be marketed or used as feed. The length of time crop can be safely stored will depend on the condition it was harvested and the type of storage facility being utilized. The sunshine is very much required for crop drying. Lower ure content and lower temperature can be kept food in storage for longer periods of moisture time.. This impact is related with the operation of silos. Figure 4.6: Average Monthly Sunshine in Tangail Station 4.1.1.6. Cloud Coverage ) shows that average cloud The statistical cloud coverage data from 1987 to 2013 (Figure 4.7) coverage remained maximum from 5 octas to 6octas during June to August. . The minimum octas in the month of December in the area of Tangail weather cloud coverage was 1.04octas station. 36 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.7: Average Monthly Cloud Coverage in Tangail Station 4.1.2 Noise Level Excessive noise is a potential issue for both human and biological receivers and can nge of negative issues, from mild annoyance and moderately elevated potentially cause a range levels of aggression to significant disturbance of behavioral patterns and in severe cases temporary or permanent hearing loss. According to World Health Organization’s Guidelines unity Noise (1999), daily sound pressure levels of 50 decibels (dB) or above can for Community create discomfort amongst humans, while ongoing exposure to sound pressure levels over 85 dB is usually considered the critical level for temporary hearing damage. Results of the noise level monitored along with details of the sampling locations have been showed in Table 4.1. . The results show that time weighted average value of the sound monitored at inside and outside of the project area did not exceed the standard fixed for the respective areas. Figure 4.8: Noise Level Monitoring in the Project Area 37 Modern Food Storage Facilities Project (MFSP), Madhupur Table 4.1: Noise Level at Different Locations of Project Area (11 October 2016) ID Sampling GPS Zone* Noise Bangladesh Remarks Location Location Level Day Standard at dB (A) Day dB (A)** NM-01 Project Site 24.62982°N Commercia 49.30 70 Good (East) 90.06440°E l Area NM-02 Project Site 24.62925°N Commercia 46.22 70 Good (South) 90.06445°E l Area NM-03 Project Site 24.62892°N Commercia 46.68 70 Good (Centre) 90.06396°E l Area NM-04 Project Site 24.62842°N Commercia 48.14 70 Good (South- 90.06284°E l Area West) NM-05 Project Site 24.62910°N Commercia 47.01 70 Good (North) 90.06312°E l Area Note: * According to Environmental Quality Standard 1997 and subsequent amendment in 2006. ** Bangladesh Standard for Noise Level at different types of areas (as per Noise Pollution (Control) Rules, 2006). The sound level standards for residential area are 55 dBA, for silent area 50 dBA and for commercial area 70 dBA at day time. The sound level standards for residential area are 45 dBA, for silent area 40 dBA and for commercial area 60 dBA at night time. Abbreviation: NM- Noise Measurement, dB- decibel 4.1.3 Physiography In the context of physiography, Bangladesh can be divided into three broad categories based on topography, physical features, and geological history (Brammer, 1996): 1. Floodplains 2. Terraces 3. Hills Within these 3 broad categories, a number of authors have further divided the land surface into a series of Physiographic Units based on a combination of topographical/landscape features, underlying geology and surface soils (Brammer, 1996, Rashid, 1991, Morgan and McIntyre, 1959). The most recent study was undertaken by the Soil Resource Development Institute (SRDI) who further refined the previous classifications into 26 Physiographic Units (20 primary units and 6 sub-units) based on an assessment of more recent and detailed data (SRDI, 1997). The project area falls in the Madhupur Tract physiographic unit (Figure 4.9) 38 Modern Food Storage Facilities Project (MFSP), Madhupur Madhupur Tract Another Pleistocene upland block in the Bengal Basin is located in the central part of Bangladesh comprising greater Dhaka and Mymensingh districts, between the courses of the Old Brahmaputra and the Jamuna rivers. Towards the south, this physiographic sub-region extends to as far as Dhaka, the capital of the country. Madhupur Tract measures about 4,105 sq km. Comparable to the Barind Tract, the area belongs to a Pleistocene terrace consisting mainly of red coloured and mottled clays. It is characterised by plateau-like hillocks varying in height from 9 to 18.5m, and a dendritic drainage pattern, typical of all Pleistocene terraces in Bangladesh. The valleys, mostly flat, are cultivated. The Madhupur jungle contains Shal trees (Shorearobusta), the hardwood which is second to teak in value. 39 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.9: Physiographic Units of project area 40 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.4 Topography Topography configuration of a land surface including its relief and contours, the distribution of mountains and valleys, the patterns of rivers, and all other features, natural and artificial, that produce the landscape. Although Bangladesh is a small country, it has considerable topographic diversity. It has three distinctive features: (i) a broad alluvial plain subject to frequent flooding, (ii) a slightly elevated relatively older plain, and (iii) a small hill region drained by flashy rivers. On the south, a highly irregular deltaic coastline of about 600 km featured by many estuarine rivers and channels flowing into the Bay of Bengal. The alluvial plain is part of the larger plain of Bengal, which is sometimes called the Lower Gangetic Plain. Elevations of the plains are less than 10m above the sea level; elevation furthers decline to a near sea level in the coastal south. The general topography of the project area is relatively flat. The topography of the specific project location is 10.85 – 14.94 m a.m.s.l (Figure 4.10). 41 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.10: Topographic Map of project area 42 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.5 Geology Bangladesh is situated to the east of the Indian sub-continental plate. Nearly 85% of Bangladesh is underlain by deltaic and alluvial deposits of the Ganges, Brahmaputra, and Meghna river systems. The Hinge Zone is a narrow strip of about 25 km wide complex flexure zone, which separates the Bengal Fore deep from the shelf zone. It trends approximately N 30' E along the Calcutta-Pabna-Mymensingh gravity high and extends upto the western tip of Dauki fault. This zone is characterized by the sharp change in the dip of the basement rocks associated with deep-seated displacements in faults and is reflected on the gravity and magnetic anomalies. The Eocene limestone dips at about 20 in this zone as compared to 2-3 in the shelf zone. The seismic interpretation shows that the depth of the Sylhet Limestone - a strong seismic reflector - increases from 4000m to 9000m within a narrow zone of 25-km. During the subsurface interpretation of the south-eastern part of the West Bengal in India, a zone of flexure in the top of the Sylhet limestone was recognized which is the extension of the Hinge Zone in India. Hinge Zone is connected with Bengal Fore deep by deep basement faults that probably started with the breakup of Gondwanaland. Since then they have been repeatedly reactivated. In the northeast of Bangladesh the Hinge Zone turns to the east and seems to be connected with the Dauki Fault, probably by a series of east-west trending faults. [ASM Woobaidullah] Bengal Fore deep occupies the vast area between Hinge Line and ArakanYoma Folded System and plays the most important role in the tectonic history of Bengal Basin. Tectonically, Bengal Fore deep can be divided into two major regions- (a) Western Platform Flank and (b) Eastern Folded Flank. The Western Platform flank is further subdivided into (a) Faridpur Trough (b) Barisal-Chandpur High (c) Hatiya Trough (d) Madhupur High and (e) Sylhet Trough. Faridpur Trough situated adjacent to Hinge Zone is characterized by a general gravity low with development of Neogene sequence. Sylhet Limestone is 6500 m deep in area south of the confluence of the Padma and the Jamuna. Chalna and Bagerhat are the notable structural highs of very low amplitude. The generalized geological feature of the project area is shown in the geological map of Bangladesh (Figures 4.11). 43 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.11: Geology of project area 44 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.6 Air quality There is no official record of secondary air quality data due to non-availability of a regular air quality monitoring program for ambient conditions or emissions. The present condition of the air quality is presented in the following Table 4.2 (Source ESAMF of MFSP). From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are within the atmospheric environmental standards for the industrial and mixed. Table 4.2: Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m3 μg/m3 μg/m3 μg/m3 21/12/12 North end 8 hours 220 390 30 32 21/12/12 South end 8 hours 210 410 28 30 Bangladesh Standard for Industrial 500 5000 120 100 and Mixed Source: Environmental Screening Report, Madhupur, April 2015 4.1.7 Water Resources Bangladesh is located over a subsiding basin of tectonic origin overlain with a great thickness of sedimentary strata. This sedimentary stratum is an unconsolidated alluvial deposit of recent age overlaying marine sediments. The recent delta and alluvial plains of the Ganges, Brahmaputra and the Meghna Rivers constitute the upper formation. The near surface Quaternary alluvium contains good aquifer characteristics (transmission and storage coefficients). The groundwater (GW) storage reservoir has three divisions: upper clay and silt layer, a middle composite aquifer (fine to very fine sand) and a main aquifer consisting of medium to coarse sand. Drinking water is generally taken from deep tube wells with strainers set between depths of 200 meters to around 400 meters (DPHE, 2011). The Ground water level is at or very close to the surface during the monsoon; whereas, it is at maximum depth during the months of April and May (Banglapedia, 2014). There are no remarkable surface water resources in the project site. One khal named Gula and Bangshi River is far away from the proposed site. During dry season Gulakhal is almost dry carrying low water level. 45 Modern Food Storage Facilities Project (MFSP), Madhupur Figure 4.12: Water Bodies and River Network Map 46 Modern Food Storage Facilities Project (MFSP), Madhupur 4.1.7.1 Ground Water Though, arsenic is a problem in large part of Bangladesh ground water. The project area has no Arsenic problem in ground water. During consultation meeting with the local people, no arsenic affected person was identified. Arsenic contained in the soil as soluble form, it may contaminant any time in the ground water. That’s why the consultant addressed arsenic for this project. The acceptable quantity of arsenic in potable water is 0.05 mg per liter under the Department of Environment standard and 0.01 mg per liter under the WHO standards. Figure 4.13 shows the water sample collection of ground water from an installed deep tube well about 120 ft’ in the project area. Figure 4.14 shows (the map showing the arsenic contaminated areas throughout) that the Arsenic contamination is there in the project area. On 11thOctober 2016, groundwater sample was collected by environmental team from a tube well depth about 120 ft near the project area. The Department of Public Health Engineering (DPHE) analyzed the sample. From the result it is found that all the quality parameters were well within the Bangladesh ground water quality standard set by Department of Environment. (The ground water quality result is attached in Appendix D).No surface water was found nearby to the project site and surface water quality test was not done. The result of the groundwater sample and the GoB standards for drinking water (ECR, 1997) are shown in Table 4.3. Figure 4.13: Water Sampling and On-site Testing in the Project Location 47 Modern Food Storage Facilities Project (MFSP), Madhupur Table 4.3: Results for Groundwater Sample Parameter Unit Test value of Test value of Bangladesh Remark the sample the sample Standard collected dated collected dated on December, on 11 October, 2012 2016 Temperature °C 21.1 28.6 20-30 Ok Turbidity NTU 3.5 1.2 10 Ok Color TCU 3.8 1.0 15 Ok pH -- 6.8 6.7 6.5-8.5 Ok TDS mg/l 820 30 <1000 Ok DO mg/l 7.5 6.34 >6 Ok BOD mg/l 1.8 1 November 2017 at 17:13 Dear Mr. Gazi, PDMFSFP: Based on the documents received and information provided I am pleased to inform you that IDA has no- objection to the Madhupur and Mymensing Sites EIA reports. You should insure that: (i) these reports are disclosed on the DG Food website, and (ii) the World Bank is informed from DG-Food of the disclosure information. Best regards. Manievel (Emmanuel) Sene Senior Agricultural Specialist Agriculture Global Practice - GFA12 T. +8809604404315 M. +8801758526796 E. msene@worldbank.org A. E-32, Agargaon, Sher-e-Bangla Nagar, Dhaka - 1207, Bangladesh 151 Modern Food Storage Facilities Project (MFSP), Madhupur Annex-M: Environmental Clearance Certificate from the Department of Environment (DOE) 152 Modern Food Storage Facilities Project (MFSP), Madhupur 153