E4179 Draft March 30, 2013 Environmental & Social Assessment & Management Framework (ESAMF) Bangladesh Modern Food Storage Facilities Project, Phase I (BMFSFP-I) March 2013 Directorate General of Food Government of Bangladesh Dhaka Table of Contents List of Acronyms .............................................................................................................................. xii LIST of TABLE .................................................................................................................................. xvi LIST OF FIGURES............................................................................................................................ xviii Executive Summary......................................................................................................................... xix SECTION A: General ...........................................................................................................................1 1 INTRODUCTION ..........................................................................................................................2 1.1 Background ................................................................................................................................... 2 1.2 Need of the Report ....................................................................................................................... 3 1.3 Report Structure ........................................................................................................................... 3 2 Project description .....................................................................................................................4 2.1 Project Objectives ......................................................................................................................... 4 2.2 Project Components ..................................................................................................................... 4 2.2.1 Component A – Construction of Modern Grain Storage Silo Facilities ................................. 4 2.2.2 Component B – Support for Food Planning and Monitoring Program ................................. 6 2.2.3 Component C –Project management, construction supervision, technical assistance, training and strategic Studies. .............................................................................................................. 6 2.3 Project Beneficiaries ..................................................................................................................... 6 2.4 Selected Technology Description .................................................................................................. 6 2.4.1 Modern Public Food Grain Storage Silos .............................................................................. 6 2.4.2 Household Silos ..................................................................................................................... 8 2.5 Scope of BMFSP-I Intervention for Environment and Social Study .............................................. 8 2.5.1 Component A1: Construction of Modern Public Food Grain Storage Silos .............................. 8 2.5.2 Component A2: Household Silos............................................................................................... 9 2.5.3 Component A3: Implementation of Social and Environmental Management Plans ................ 9 3 Environmental & Social Policies, Legal and Administrative Framework....................................... 10 3.1 General Description of Environmental Polices and Legislation in Bangladesh ........................... 10 3.1.1 Bangladesh Environment Conservation Act, 1995.............................................................. 10 3.1.2 Environment Conservation Rules, 1997 .............................................................................. 10 3.1.3 Bangladesh Climate Change Strategy and Action Plan (BCCSAP) 2009 .............................. 11 3.1.4 National Environment Action Plan, 1992 ............................................................................ 12 3.1.5 National Water Policy 1999 ................................................................................................ 12 ii 3.1.6 Standing Orders on Disaster, 2010 ..................................................................................... 12 3.1.7 National Integrated Pest Management Policy, 2002 .......................................................... 13 3.1.8 National Fisheries Policy, 1996 ........................................................................................... 13 3.1.9 National Adaptation Programme of Action (NAPA) ............................................................ 14 3.1.10 Bangladesh Labor Act, 2006 ................................................................................................ 14 3.1.11 Bangladesh National Building Code, 2006 .......................................................................... 15 3.1.12 National Agricultural Policy, 2010 ....................................................................................... 16 3.1.13 National Food Policy 2006; ................................................................................................. 16 3.1.14 National Food Policy Plan of Action, 2008-2015................................................................. 18 3.1.15 Bangladesh Country Investment Plan (CIP), 2011 .............................................................. 18 3.2 World Bank’s Environmental Safeguard Policy ........................................................................... 18 3.2.1 OP/BP 4.01 Environmental Assessment ............................................................................. 19 3.2.2 OP/BP 4.04 Natural Habitats............................................................................................... 20 3.2.3 OP/BP 4.09 Pest Management............................................................................................ 20 3.2.4 OP/BP 4.11 Physical Cultural Resources ............................................................................. 20 3.2.5 OP/BP 4.36 Forests ............................................................................................................. 21 3.2.6 OP/BP 4.37 Safety of Dams ................................................................................................. 21 3.2.7 WBG/ IFC Environmental, Health and Safety Guidelines .................................................... 21 3.3 General Description of Social Polices and Legislation in Bangladesh ......................................... 21 3.3.1 Constitution of Bangladesh ................................................................................................. 22 3.3.2 The Acquisition and Requisition of Immovable Property Ordinance, 1982 ....................... 22 3.3.3 The East Bengal State Acquisition and Tenancy Act, 1950 (Revised 1994) ........................ 22 3.3.4 Constitutional Right of the Tribal Peoples Rights ............................................................... 23 3.3.5 The Chittagong Hill Tracts Regulation 1900 ........................................................................ 23 3.3.6 The Chittagong Hill –Tracts (Land Acquisition) Regulation, 1958 ....................................... 23 3.3.7 The CHT Regional Council Act, 1998 ................................................................................... 24 3.3.8 Ethnic Minority Rights in PRSP 2005 ................................................................................... 24 3.3.9 GOB Laws on Land Acquisition............................................................................................ 25 3.4 World Bank’s Social Safeguard Policy ......................................................................................... 25 3.4.1 Involuntary Resettlement (OP 4.12) ................................................................................... 25 3.4.2 Indigenous People (OP 4.10) ............................................................................................... 26 3.5 Implications of National Polices and Legislations on the Project ............................................... 26 iii 3.6 Implication of Environmental Safeguard Policies of WB on the Project..................................... 26 3.7 Implication of Social Safeguard Policies of WB on the Project ................................................... 27 4 Alternative analysis .................................................................................................................. 28 4.1 Introduction ................................................................................................................................ 28 4.2 "No Action" Alternative of the Project ....................................................................................... 28 4.3 Alternative Analysis for Selection of Sites .................................................................................. 29 4.4 Alternative Analysis for Technology Options .............................................................................. 33 SECTION B: EnvironmenTal and social management framework (ESMF) ............................................ 39 5 environmental management Framework (Emf) ......................................................................... 40 5.1 Objectives of the EMF ................................................................................................................. 40 5.2 General Principles of the EMF..................................................................................................... 40 5.3 Environmental Assessment Methodology .................................................................................. 41 5.3.1 Environmental Assessment ................................................................................................. 41 5.3.2 Step 1: Identification of Project Influence Area .................................................................. 42 5.3.3 Step 2: Environmental Screening and Initial Environmental Examination (IEE) ................. 42 5.3.4 Step 3: Environmental Impact Assessment ........................................................................ 42 5.3.5 Environmental Management Plan ...................................................................................... 45 6 Social management & Resettlement Policy Framework (SMRPF) ................................................ 48 6.1 Objectives of SMRPF ................................................................................................................... 48 6.2 Basic Planning Principles ............................................................................................................. 48 6.3 Social Screening and Impact Assessment ................................................................................... 49 6.3.1 Exclusion Criteria................................................................................................................. 49 6.3.2 Social Impact Assessment Methodology ............................................................................ 49 6.4 Project Resettlement Policy ........................................................................................................ 50 6.5 Eligibility and Entitlements Policy ............................................................................................... 52 6.6 Preparation of SMP/RAP ............................................................................................................. 53 6.7 SMP Implementation and Monitoring Arrangement.................................................................. 55 SECTION C: EnvironmenTal and social Assessment (ESA) ................................................................... 56 7 Baseline study of the proposed site ........................................................................................... 57 7.1 Project Locations and Sites ......................................................................................................... 57 7.2 Environmental Aspect of Barisal CSD Campus Silo Site .............................................................. 59 7.2.1 Site Description ....................................................................................................................... 59 iv 7.2.2 Physiography, Geology& Topography..................................................................................... 59 7.2.3 Existing Structure .................................................................................................................... 60 7.2.4 Transportation Link ................................................................................................................. 60 7.2.5 Utility (Power, Water & Gas) Supply at the Site ..................................................................... 61 7.2.6 Status of Food Production in Barisal ....................................................................................... 61 7.2.7 Seismicity ................................................................................................................................ 62 7.2.8 Hydrology and drainage .......................................................................................................... 62 7.2.9 Air quality ................................................................................................................................ 62 7.2.10 Water quality of the nearby river ........................................................................................... 62 7.2.11 Noise quality ........................................................................................................................... 63 7.2.12 Monument/Memorial Structure ............................................................................................. 63 7.2.13 Terrestrial ecology .................................................................................................................. 64 7.2.14 Fisheries .................................................................................................................................. 64 7.2.15 Cyclones and flooding ............................................................................................................. 65 7.3 Environmental Aspect of Narayanganj CSD Campus Silo Site.................................................... 66 7.3.1 Site Description ....................................................................................................................... 66 7.3.2 Physiography, Geology& Topography..................................................................................... 67 7.3.3 Existing Structure .................................................................................................................... 67 7.3.4 Transportation Link ................................................................................................................. 68 7.3.5 Utility (Power, Gas, Water) Supply at the Site ........................................................................ 68 7.3.6 Status of Food Supply in Narayanganj .................................................................................... 68 7.3.7 Seismicity ................................................................................................................................ 69 7.3.8 Hydrology and drainage .......................................................................................................... 69 7.3.9 Air quality ................................................................................................................................ 69 7.3.10 Water quality of the nearby river ........................................................................................... 70 7.3.11 Noise quality ........................................................................................................................... 70 7.3.12 Terrestrial ecology .................................................................................................................. 71 7.3.13 Fisheries .................................................................................................................................. 71 7.3.14 Cyclones and flooding ............................................................................................................. 71 7.4 Environmental Aspect of Dhaka CSD Campus Silo Site ............................................................... 72 7.4.1 Site Description ....................................................................................................................... 72 7.4.2 Physiography, Geology& Topography..................................................................................... 73 v 7.4.3 Existing Structure .................................................................................................................... 73 7.4.4 Transportation Link ................................................................................................................. 74 7.4.5 Utility (Power, water, gas) supply at the site .......................................................................... 74 7.4.6 Status of Food Supply in Dhaka............................................................................................... 74 7.4.7 Seismicity ................................................................................................................................ 75 7.4.8 Hydrology and drainage .......................................................................................................... 75 7.4.9 Air quality ................................................................................................................................ 75 7.4.10 Water quality of the nearby river ........................................................................................... 75 7.4.11 Noise quality ........................................................................................................................... 76 7.4.12 Terrestrial ecology .................................................................................................................. 76 7.4.13 Fisheries .................................................................................................................................. 76 7.4.14 Cyclones and flooding ............................................................................................................. 77 7.5 Environmental Aspect of Ashuganj Concrete Silo Site................................................................ 78 7.5.1 Site Description ....................................................................................................................... 78 7.5.2 Physiography, Geology& Topography..................................................................................... 78 7.5.3 Existing Structure .................................................................................................................... 78 7.5.4 Transportation Link ................................................................................................................. 80 7.5.5 Utility (Power, water, gas) supply at the site .......................................................................... 81 7.5.6 Status of Food Supply in Ashuganj .......................................................................................... 81 7.5.7 Seismicity ................................................................................................................................ 82 7.5.8 Hydrology and drainage .......................................................................................................... 82 7.5.9 Air quality ................................................................................................................................ 82 7.5.10 Water quality of the nearby river ........................................................................................... 83 7.5.11 Noise quality ........................................................................................................................... 83 7.5.12 Terrestrial ecology .................................................................................................................. 84 7.5.13 Fisheries .................................................................................................................................. 84 7.5.14 Cyclones and flooding ............................................................................................................. 84 7.6 Environmental Aspect of Mymensingh CSD Campus Site........................................................... 85 7.6.1 Site Description ....................................................................................................................... 85 7.6.2 Physiography, Geology& Topography..................................................................................... 85 7.6.3 Existing Structure .................................................................................................................... 86 7.6.4 Transportation Link ................................................................................................................. 86 vi 7.6.5 Utility (Power, water, gas) supply at the site .......................................................................... 87 7.6.6 Status of Food Supply in Mymensingh .................................................................................... 87 7.6.8 Seismicity ................................................................................................................................ 87 7.6.9 Hydrology and drainage .......................................................................................................... 87 7.6.10 Air quality ................................................................................................................................ 87 7.6.11 Water quality of the nearby waterbody ................................................................................. 88 7.6.12 Noise quality ........................................................................................................................... 88 7.6.13 Terrestrial ecology .................................................................................................................. 89 7.6.14 Fisheries .................................................................................................................................. 89 7.6.15 Cyclones and flooding ............................................................................................................. 89 7.7 Environmental Aspect of Maheswarpasha CSD Campus Site ..................................................... 90 7.7.1 Site Description ....................................................................................................................... 90 7.7.2 Physiography, Geology& Topography..................................................................................... 90 7.7.3 Existing Structure .................................................................................................................... 90 7.7.4 Transportation Link ................................................................................................................. 91 7.7.5 Utility (Power, water, gas) supply at the site .......................................................................... 92 7.7.6 Status of Food Supply in Maheswarpasha .............................................................................. 92 7.7.7 Seismicity ................................................................................................................................ 92 7.7.8 Hydrology and drainage .......................................................................................................... 92 7.7.9 Air quality ................................................................................................................................ 93 7.7.8 Water quality of the nearby river ........................................................................................... 93 7.7.9 Noise quality ........................................................................................................................... 93 7.7.10 Terrestrial ecology .................................................................................................................. 94 7.7.11 Fisheries .................................................................................................................................. 94 7.7.12 Cyclones and flooding ............................................................................................................. 94 7.8 Environmental Aspect of Chittagong Port Concrete Silo Campus .............................................. 95 7.8.1 Site Description ....................................................................................................................... 95 7.8.2 Physiography, Geology& Topography..................................................................................... 95 7.8.3 Existing Structure .................................................................................................................... 95 7.8.4 Transportation Link ................................................................................................................. 97 7.8.5 Utility (Power, water, gas) supply at the site .......................................................................... 97 7.8.6 Status of Food Supply in Chittagong Silo ................................................................................ 97 vii 7.8.7 Seismicity ................................................................................................................................ 98 7.8.8 Hydrology and drainage .......................................................................................................... 98 7.8.9 Air quality ................................................................................................................................ 98 7.8.10 Water quality of the nearby Karnaphuli river ......................................................................... 98 7.8.11 Noise quality ........................................................................................................................... 99 7.8.12 Terrestrial ecology .................................................................................................................. 99 7.8.13 Fisheries ................................................................................................................................ 100 7.8.14 History of Cyclones and flooding in the Project area............................................................ 100 7.9 Environmental Aspect of Madhupur CSD Campus Site ............................................................ 101 7.9.1 Site Description ..................................................................................................................... 101 7.9.2 Physiography, Geology& Topography................................................................................... 101 7.9.3 Existing Structure .................................................................................................................. 101 7.9.4 Transportation Link ............................................................................................................... 102 7.9.5 Utility (Power, water, gas) supply at the site ........................................................................ 102 7.9.6 Status of Food Supply in Madhupur ..................................................................................... 103 7.9.7 Seismicity .............................................................................................................................. 103 7.9.8 Hydrology and drainage ........................................................................................................ 103 7.9.9 Air quality .............................................................................................................................. 103 7.9.10 Water quality of the nearby river ......................................................................................... 103 7.9.11 Noise quality ......................................................................................................................... 104 7.9.12 Terrestrial ecology ................................................................................................................ 105 7.9.13 Cyclones and flooding ........................................................................................................... 105 7.10 Socioeconomic Baseline of 8 Sites ............................................................................................ 106 7.10.1 Overview ........................................................................................................................... 106 7.10.2 Demographic Profile ......................................................................................................... 106 7.10.3 Economic Profile ............................................................................................................... 108 7.10.4 Education .......................................................................................................................... 111 7.10.5 Literacy .............................................................................................................................. 111 7.10.6 Educational Institutions .................................................................................................... 112 7.10.7 Gender Issues .................................................................................................................... 112 7.10.8 Coastal Population and Food Security .............................................................................. 114 8 Impact Assessment and Mitigation ......................................................................................... 116 viii 8.1 Environmental Impact Assessment and Mitigation ........................................................................ 116 8.1.1 Environmental Impact Screening Snapshot ...................................................................... 116 8.1.2 Potential Impacts during Design Phase................................................................................. 118 8.1.3 Risk of Flooding and Inundation ...................................................................................... 118 8.1.4 Loss to Agriculture and/or Grazing Land........................................................................... 120 8.1.5 Damage to the Existing Infrastructure ............................................................................. 120 8.1.6 Damage due to Waste Disposal ....................................................................................... 121 8.2 Potential Impacts during Construction Phase........................................................................... 122 8.2.1 Loss of Natural Vegetation ................................................................................................ 122 8.2.2 Noise and Vibration .......................................................................................................... 123 8.2.3 Air Quality ......................................................................................................................... 124 8.2.4 Soil and Water Contamination .......................................................................................... 125 8.2.5 Blocked Access Routes ...................................................................................................... 126 8.2.6 Soil Erosion ........................................................................................................................ 127 8.2.7 Vehicular Traffic ................................................................................................................ 128 8.2.8 Safety Hazards and Public Health ..................................................................................... 129 8.2.9 Livestock Grazing .............................................................................................................. 131 8.2.10 Damage to Infrastructure and Monuments ...................................................................... 131 8.2.11 Aesthetic Value ................................................................................................................. 132 8.2.12 Water Availability and Consumption ................................................................................ 132 8.2.13 Social Conflict .................................................................................................................... 132 8.3 Potential Impacts during Operational Phase ............................................................................ 133 8.3.1 Safety Hazards and Public Health ..................................................................................... 133 8.3.2 Impact from Ancilliary Facilities ........................................................................................ 134 8.3.3 Air Quality ......................................................................................................................... 136 8.3.3 Soil and Water Contamination .......................................................................................... 137 8.3.4 Noise and Vibration .......................................................................................................... 137 8.3.5 Vehicular Traffic ................................................................................................................ 138 8.3.6 ElectricityConsumption ..................................................................................................... 138 8.3.7 Damage to Infrastructure and Monuments ...................................................................... 138 8.3.8 Aesthetic Value ................................................................................................................. 139 8.4 Assessment of Social Impacts and Mitigation .......................................................................... 140 ix 8.4.1 Social Screening ................................................................................................................ 140 Land Acquisition and related Issues.................................................................................................. 140 8.4.2 Impacts on Indigenous Peoples ........................................................................................ 141 8.4.3 Involuntary Resettlement ................................................................................................. 141 8.4.4 Social Exclusion ................................................................................................................. 141 8.4.5 Impacts During Construction ............................................................................................ 142 8.4.6 Impacts Due to Non-local Work force............................................................................... 142 8.4.7 Impacts on Local Infrastructure ........................................................................................ 142 8.4.8 Project Benefits ................................................................................................................. 143 8.5 Climate Change Impact on Food Security& Contribution of BMFSFP ...................................... 143 8.5.1 Present Status & Effect of Climate Change of Food Securityin Bangladesh ..................... 143 8.5.2 Impact of BMFSFP to Combat Climate Change Impact ..................................................... 144 SECTION D: EnvironmenTal management Plan (eMP) & Consultation - disclosure ............................ 145 9 Environmental Management Plan ........................................................................................... 146 9.1 Objectives of EMP .................................................................................................................... 146 9.2 EMP Components ..................................................................................................................... 146 9.3 Institutional Arrangements ....................................................................................................... 146 9.3.1 Implementation Responsibility ........................................................................................ 148 9.3.2 Construction Phase .......................................................................................................... 148 9.3.3 Operation Phase................................................................................................................ 149 9.4 Mitigation Plan .......................................................................................................................... 149 9.5 Environmental Monitoring........................................................................................................ 176 9.5.1 Compliance Monitoring .................................................................................................... 176 9.5.2 Effects Monitoring ............................................................................................................ 176 9.6 Capacity Building ....................................................................................................................... 180 9.7 Record Keeping & Database Management ............................................................................... 181 9.7.1. Monitoring Records .......................................................................................................... 181 9.7.2. Complaints Records .......................................................................................................... 182 9.7.3. Information Sources.......................................................................................................... 182 9.7.4. Non-Compliance Report.................................................................................................... 182 9.7.5. Monthly Internal Reports.................................................................................................. 182 9.7.6 External Audits (Third Party Validation)............................................................................ 183 x 9.7.7 Supervision by World Bank ............................................................................................... 183 9.8 Grievance Redress Mechanism ................................................................................................. 183 9.8.1 Grievance Logging ............................................................................................................. 184 9.9 Inclusion of EMP in Contract Documents ................................................................................. 185 9.10 EMP Implementation Cost ........................................................................................................ 186 10. Consultation and Disclosure .................................................................................................... 187 10.1.1 Objectives.............................................................................................................................. 187 10.1.2 Consultation and Participation Framework .......................................................................... 187 10.2 Stakeholder Identification......................................................................................................... 188 10.3 Consultation Process................................................................................................................. 189 10.4 Consultation during Site Identification ..................................................................................... 189 10.5 Community attitude towards the project ............................................................................. 190 10.6 Perceived benefits of the project.......................................................................................... 190 10.7 Anticipated negative impacts ............................................................................................... 190 10.8 Suggestions to mitigate adverse impacts ............................................................................. 191 10.9 Consultation at Eight Selected Sites ......................................................................................... 191 10.10 Consultation at Village Level in Patuakhali ........................................................................... 194 10.11 Disclosure .............................................................................................................................. 196 ANNEXES Annex 1 Steps involved in environmental clearance from DOE ......................................................... A2 Annex 2: Sample checklist for screening for BMFSFP ........................................................................ A3 Annex 3: Site Specific Environmental Screening Checklist ................ …………………………………………………A6 Annex 4: Example Of Traffic Survey Data ....................................................................................... A38 Annex 5 : TRIP Model used in simulating traffic flow: ..................................................................... A49 Annex 6: Fumigation Application Guideline ................................................................................... A51 Annex 7: Site Overview and Environmental Mitigation Measures ................................................... A53 Annex-8 Screening Form For Social Safeguards Issues .................................................................... A81 Annex-9 Eligibility and Entitlement Matrix ..................................................................................... A87 Annex-10 Terms of Reference for Third Party Environmental Audit…………………………………………………A91 Annex-11 List of Participants in Consultation Meetings during January 2013 .................................. A92 xi LIST OF ACRONYMS AC After Construction ADB Asian Development Bank AD Alluvion-Diluvion AIDS Acute Immune Deficiency Syndrome AP Affected Person ARIPO Acquisition and Requisition of Immovable Property Ordinance BADC Bangladesh Agriculture Development Corporation BBS Bangladesh Bureau of Statistics BC Before Construction BCCSAP Bangladesh Climate Change Strategy and Action Plan BDT Bangladesh Taka BECA Bangladesh Environment Conservation Act BFIDC Bangladesh Forest Industries Corporation EHS Environmental, Health and Safety BIWTA Bangladesh Inland Water Transport Authority BMFS Bangladesh Modern Food Storage Facilities BMFSP Bangladesh Modern Food Storage Facilities Project BNBC Bangladesh National Building Code BP Bank Procedures ESA Environmental and Social Assessment ESAMF Environmental and Social Assessment Management Framework BUET Bangladesh University of Engineering Technology CBN Cost of Basic Needs CoP Conference of the Parties CHT Chittagong Hill-Tracts CI Corrugated Iron CIP Country Investment Plan CLAC Central Land Allocation Committee CO Carbon Monoxide CSC Construction Supervision Consultant CSD Central Supply Deport CUL Compensation under Law DC During Construction DC Deputy Commissioner GDP Gross Domestic Product DFID Department for International Development DG Director General, DG-Food Directorate General of Food DOF Department of Forest DoE Department of Environment DPHE Department Of Public Health Engineering EA Environmental Assessment xii EA Executing Agency ES Environmental Supervisor EAP Environmental Action Plan ECCRP Emergency Cyclone Recovery and Restoration Project ECA Environmental Conservation Act ECC Environmental Clearance Certificate ECR Environmental Conservation Rule EIA Environmental Impact Assessment EMF Environmental Management Framework EMO Environmental Management Overview EMP Environmental Management Plan ESA Environment and Social Assessment HSE Health, Safety and Environment ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESAMF Environmental and Social Assessment & Management Framework FD Food Department FFW Food for Works FPMU Food Planning And Monitoring Unit GAAP Governance and Accountability Action Plan GOB Government of Bangladesh GRC Grievances Redress Committee GRM Grievance Redress Mechanism GW Ground Water HDCs Hill District Councils HIES Household Income and expenditure Survey HIV Human Immunodeficiency Virus HQ Head Quarter IDA International Agency, IEE Initial Environmental Examination IFC International Finance Corporation IPM Integrated Pest Management JICA Japan International Cooperation Agency JVS Joint Verification Survey, KV Kilo Volt KVA Kilo Volt Ampere LAP Land Acquisition Plan LSD Local Supply Depots LGED Local Government Engineering Department MC Moisture Content MoEF Ministry of Environment and Forest MoFood Ministry Of Food MOL Ministry of Land MSDS Material Safety Data Sheet xiii MT Metric Ton NAPA National Adaptation Program of Action NCR Non-Compliance Report NEMAP National Environmental Management Action Plan NFP National Food Policy NGO Non-Government Organization NIOSH National Institute for Occupational Safety and Health NTU Nephelometric Turbidity Unit O&M Operation & Maintenance OECD Organisation for Economic Co-operation and Development OMS Open Market Sale OP Operational Policy PAD Project Appraisal Document PAP Project Affected Persons PAVC Property Assessment and Valuation Committee PD Project Director, PFDS Public Food Distribution System PIP Project Implementation Plan PM Particulate Matter PMU Project Management Unit PoA Plan of Action PPE Personal Protective Equipment PRSP Poverty Reduction Strategy Papers PSC Project Steering Committee PVS Property Valuation Survey PWD Public Works Department RAP Resettlement Action Plan RAB Rapid Action Battalion RH Relative Humidity RV Replacement Value SA Social Assessment SMP Social Management Plan SMF Social Management Framework, SMRPF Social Management & Resettlement Policy Framework SPM Suspended Particulate Matter SIA Social Impact Assessment SOD Standing Orders on Disaster TA Transfer Allowance, TCU Total Colour Unit TG Transfer Grant TRG Transfer and Reconstruction Grant TSP Triple Super Phosphate UP Union Parishad US United States xiv USEPA United States Environmental Protection Agency UNFCCC United Nations Framework Convention on Climate Change VDP Village Defence Party VGF Vulnerable Group Feeding VGD Vulnerable Group Development WARPRO Water Resources Planning Organization WB World Bank WBG World Bank Group WFP World Food Program WHO World Health Organization xv LIST OF TABLE Table 4-1 Alternative Analysis for Site Selection Considering Major Environmental and Social Factors to be Impacted ........................................................................................................................................ 30 Table 4-2 Comparative Analysis of Food Grain Storage ............................................................................ 34 Table 5-1: Parameters for Determining Magnitude .................................................................................... 43 Table 5-2: Criteria for Determining Sensitivity .......................................................................................... 44 Table 5-3: Assessment of Potential Impact Significance ............................................................................ 45 Table 5-4 Mitigation Plan Matrix ............................................................................................................... 46 Table 5-5Monitoring and Supervision Plan Matrix .................................................................................... 46 Table 7-1 Potential Sites for Modern Silo Facilities ................................................................................... 57 Table 7-2Summary of Barisal CSD ............................................................................................................ 60 Table 7-3 Barisal Division - Paddy Rice Production (MT) ........................................................................ 61 Table 7-4 Air Quality Monitoring Data ...................................................................................................... 62 Table 7-5 Water Quality Monitoring Data .................................................................................................. 62 Table 7-6 Noise Quality Monitoring Data .................................................................................................. 63 Table 7-7 Summary of Narayanganj CSD .................................................................................................. 67 Table 7-8 Air Quality Monitoring Data ...................................................................................................... 69 Table 7-9 Water Quality Monitoring Data .................................................................................................. 70 Table 7-10 Noise Quality Monitoring Data ................................................................................................ 70 Table 7-11 Summary of Dhaka CSD .......................................................................................................... 73 Table 7-12 Air Quality Monitoring Data .................................................................................................... 75 Table 7-13 Water Quality Monitoring Data ................................................................................................ 75 Table 7-14 Noise Quality Monitoring Data ................................................................................................ 76 Table 7-15 Summary of Ashuganj CSD ..................................................................................................... 79 Table 7-16 Air Quality Monitoring Data .................................................................................................... 83 Table 7-17 Water Quality Monitoring Data ................................................................................................ 83 Table 7-18 Noise Quality Monitoring Data ................................................................................................ 83 Table 7-19 Summary of Mymensingh CSD .............................................................................................. 86 Table 7-20 Air Quality Monitoring Data .................................................................................................... 87 Table 7-21 Water Quality Monitoring Data ................................................................................................ 88 Table 7-22 Noise Quality Monitoring Data ................................................................................................ 88 Table 7-23 Summary of Maheswarpasha CSD ........................................................................................... 91 Table 7-24 Air Quality Monitoring Data .................................................................................................... 93 Table 7-25 Water Quality Monitoring Data ................................................................................................ 93 Table 7-26 Noise Quality Monitoring Data ................................................................................................ 93 Table 7-27 Summary of Chittagong Silo .................................................................................................... 96 Table 7-28 Yearly Receipt & Dispatch Position of Chittagong Silo .......................................................... 97 Table 7-29 Air Quality Monitoring Data .................................................................................................... 98 Table 7-30 Water Quality Monitoring Data ................................................................................................ 98 Table 7-31 Noise Quality Monitoring Data ................................................................................................ 99 Table 7-32 Estimated Food Grains Production in Dhaka Division (mt) .................................................. 103 Table 7-33 Air Quality Monitoring Data .................................................................................................. 103 Table 7-34 Water Quality Monitoring Data .............................................................................................. 104 Table 7-35 Noise Quality Monitoring Data .............................................................................................. 104 Table 7-36: Project Area Districts ............................................................................................................ 106 Table 7-37: Population Characteristics in Project Area ............................................................................ 106 Table 7-38: Population by religion in the Project Area ............................................................................ 107 xvi Table 7-39: Tribal Population in the Project Area .................................................................................... 107 Table 7-40: Ownership of Farm Land in the Project Area....................................................................... 108 Table 7-41: Ownership of Farm Land in the Project Area....................................................................... 109 Table 7-42: Housing Pattern in the Project Area .................................................................................... 109 Table 7-43: Occupation by Male and Female .......................................................................................... 110 Table 7-44: Incidence of Poverty in Project Area .................................................................................... 111 Table 7-45: Literacy rate by district and gender ...................................................................................... 111 Table 7-46: Number of Educational Institutions ...................................................................................... 112 Table 8-1: Environmental and Social Screening Matrix (Unmitigated) .................................................. 117 Table 8-2: Estimated Flood Recurrence Interval ..................................................................................... 118 Table 8-3: Flooding History and Land Elevation Information of the Sites ............................................. 118 Table 8-4 Existence of Important Infrastructure within 500 m from the DG Food Demarcated Area ..... 121 Table 8-5: Trees to be Cut ........................................................................................................................ 122 Table 8-6: Number of Piles to be Driven .................................................................................................. 123 Table 8-7: Pile driving into GW= Pile length – GW depth (m).................................................................. 125 Table 8-8: Allowable Additional Simulated Vehicles................................................................................ 128 Table 8-9: Social Screening of 8 Sites ...................................................................................................... 140 Table 9-1: Mitigation Plan for Design and Construction Phase .............................................................. 150 Table 9-2: Mitigation Plan for Operation and Maintenance Phase .......................................................... 169 Table 9-3: Effects Monitoring ............................................................................................................ 178 Table 9-4: Environmental and Social Trainings ................................................................................. 180 Table .9-5: Grievance Classification Criteria............................................................................................ 184 Table 9-6: Cost Estimates for Environmental Management and Monitoring Activities (Per site) ........... 186 Table 10-1 Consultation and Participation Framework ............................................................................ 187 Table 10-2 Key Issues Discussed during Community Consultations ....................................................... 189 Table 10-3 Community Problems and Needs ........................................................................................... 191 Table 10-4 Storage Practice by Communities in Patuakhali district......................................................... 195 xvii LIST OF FIGURES Figure 2-1: Modern Grain Steel silo .............................................................................................................. 7 Figure 2-2 Popular Household Silo Used for ECCRP ...................................................................................... 8 Figure 4-1 Trend of Storage Need .............................................................................................................. 29 Figure 7-1 Map Showing Possible Silo Locations ...................................................................................... 58 Figure 7-2 Location of Barisal CSD Site .................................................................................................... 59 Figure 7-3 Martyr Monument ..................................................................................................................... 64 Figure 7-4 Location of Narayanganj CSD Site ........................................................................................... 66 Figure 7-5 Location of Dhaka CSD Site ..................................................................................................... 72 Figure 7-6 Location of Ashuganj Silo Site ................................................................................................. 78 Figure 7-7 Snapshot Existing Facilities of Ashuganj concrete Silo Site..................................................... 80 Figure 7-8 Common way of drying rice paddy at a rice mill located at Ashuganj ..................................... 81 Figure 7-9 Packaging of parboiled rice at a rice mill at Ashuganj .............................................................. 82 Figure 7-7-10 Location of Mymensingh Silo Site ...................................................................................... 85 Figure 7-11 Location of Maheswarpasha Silo Site ..................................................................................... 90 Figure 7-12 Location of Chittagong Silo Site ............................................................................................. 95 Figure 7-13 Chittagong – Concrete Silo ..................................................................................................... 96 Figure 7-14 Location of Madhupur Silo Site ............................................................................................ 101 Figure 7-15 East Side of Proposed Madhupur Silo Site ........................................................................... 102 Figure 7-16: Grain Storage at Household Level ....................................................................................... 114 Figure 8-1: Process Grain Chilling ........................................................................................................... 134 Figure 9-1 Implementation Step Up of the Project ................................................................................... 147 xviii EXECUTIVE SUMMARY Introduction 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. This pressure on nutrition and health will be particularly acute for women and children, who face difficulties in the aftermath of a natural disaster event. 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. The recurrence period for a major cyclone and widespread flooding in Bangladesh is around three years, necessitating an improved food storage system that can adequately distribute food aid during emergencies and disasters. This improved system would make use of modernized technologies that could store food grain (rice) for between two and three years, and would limit food storage losses significantly. In consideration to the above facts the Government of Bangladesh (GOB) approached the World Bank to assist in development of modern silo facilities for storage of about one million tons of food grains. The precise amount to be stored will be largely dependent on the projected increasing frequency and intensity of extreme weather events as well as growing variability currently predicted under climate change projections. Thus, a phased approach that addresses improving the storage systems and distribution networks could act as a first step in the projected growing demand for grain stocks. GOB, with this intension, has been preparing the Bangladesh Modern Food Storage Phase – I Project (BMFSP-I). Project Description The objective of the project is to establish facilities for the efficient storage of food grains at the public and household levels to meet post-disaster needs. The objective is also to improve efficacy of the grain storage system, and monitoring and management of the food stock in the country. The project will benefit the whole nation with focus to the disaster prone areas. It targets additional 0.6 million tons of food grains in the proposed 8 sites which will strengthen the food security of the country. This buffer stock may be used during the natural disasters like flood, cyclone and drought, and may be used in open market sale to check price hike. The population in the coastal region, the barind tracts and the flood plains will be benefited at the event of natural disasters. The low income group and vulnerable populations will be specifically benefitted from the buffer stock of food grains. The project components includes (i) construction of modern public food grain storage silos (ii) procurement and distribution of household silos, (iii) implementation of social and environmental management plans, (iv) support for food planning and monitoring program and (v) program management, construction supervision, technical assistance, training and strategic studies. The physical components of the project in Phase I those involve social and environmental impacts includes (1) Public Storage Facilities in the form of modern grain storage silos; and (2) Household level storage facility or family silos particularly in the disaster prone areas of the coastal zone. Of the three main components, all three sub-component of Component A, Component A1: Construction of Modern Public Food Grain Storage Silos and Component A2: Household Silos and Component A3: Implementation of Social and xix Environmental Management Plans are expected to trigger environmental and social impact. Construction of Modern Food Grain Silo will facilitate the steel bolted silos that are used in all climate zones would be used. These types of silos allow for speedy construction, and would have temperature control and fumigation systems, automated mechanical handling, and a central computerized control system. The household silo will involve containers which are made of fiber glass cans with a storage capacity of 70 liters (40 kg). Activities under household silo which may have environmental and social foot print include: (i) choice of drum material which needs to food grain plastic or fiber glass can (ii) gasket material to make the lid air tight (iii) user friendly design to facilitate holding/pulling/carrying in a safe way (iv) social benefit to withstand natural calamity. Under Component A3, the activities will be need based community infrastructure whose environmental and social impact can be addressed only during the small scale need based activities identification. Initially eight sites (Dhaka, Chittagong, Mymensingh, Narayanganj, Ashuganj, Barishal, Madhupur and Maheswarpasha) have been chosen for the construction of Silos. Based on the need the project aims to consider more sites in future. Relevant Government and World Bank Policies The document is prepared as per requirement of the government of Bangladesh and World Bank of Project/Program Financing. The project is aimed to construct modern food grain which will involve demolishing of existing structure and construction of silo during the construction period and use of fumigants during operation period. 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�. 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. According to World Bank OP/BP 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, knocking down of existing godowns, environmental and occupation health and safety and use of low dose of fumigants during project operation. The Project has triggered only one 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. DG Food is already using fumigants in the existing godowns. Fumigants may be needed to be used during the operation phase of the Silo. A fumigant application mechanism should follow the USEPA and WHO guideline. 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. Alternative Analysis xx The alternative analysis for BMFSFP project has been conducted into the following points (a) "no action" alternative of the project. (b) Alternative Analysis for Selection of Sites and (c) Alternative Analysis for Technology Options. It has been found the current storage capacity of the country is 16 lakh tons. But will be reduced to 13 lakh Tons by 2013 due to further deterioration of the old godowns. It is estimated the requirement of storage capacity for the food grain is 30.5 lakh tons by the end of 2020. If the storage facility is not increased immediately with the increasing frequency of natural disaster, decreasing storage facility due to deteriorated existing godown, the country will face shortage of food during emergency need of food. Initially fourteen sites were taken into account. Considering the above conditions, 8 sites have been selected for the first phase. The site selection criteria are as follows: a. Strategic value of the storage location for distribution of food grain stocks in emergency relief situations or for the pre-positioning of such stocks b. Rationality of increased storage capacity at the site based on existing and anticipated food grain movements by the client for all uses in order to ensure proper rotation of stocks c. Avoidance of land acquisition issues that could delay the start of construction and therefore a focus on existing Food Department storage sites Based on the above listed criteria and environmental and social aspect Barishal CSD, Narayangan CSD, Dhaka CSD, Mymensing CSD, Maheswarpasha CSD, Ashuganj silo, Chittagong Silo and Madhupur site have been selected for modern food grain silo construction. Technological benefits for Steel Silo, concrete silo and conventional godowns were also assessed in this report. It has been found Steel Silo provides the best scenario in terms of temperature and moisture control, space requirement, dust control and rodent control. However, steel silo requires high skill set for construction and operation. Environmental and Social Management Framework Environmental Management Framework has been prepared to provide guideline to DG-Food, the implementing agency about codes of practice and procedures to be taken into consideration for integration of environmental and social aspects into the project design for conducting Environmental Impact Assessment (EIA) at the second phase of BMFSFP. The objectives of the Environmental Management Framework (EMF) are to ensure that Bangladesh Modern Food Storage Facilities project activities will ensure the following aspects:  Ensure that environmental and related social issues are thoroughly evaluated and necessary interventions are incorporated in the planning, designing, implementation and operation phase of project activities through environmental and social impact assessment.;  Ensure compliance and due diligence with World Bank environmental and social safeguard policies as well as with related Government Polices, regulations, guidelines and procedures as applicable to the cold storage and associated infrastructure development of the project;  Preventing and/or mitigating any negative environmental impact that may emerge from any project component;  Enhancement of positive environmental impact;  Protecting human health xxi The EMF also provides the guideline for effective Environmental Management Plan applicable for project design, construction and operation phase. The Social Management and Resettlement Policy Framework (SMRPF) has been prepared in compliance with the OP 4.12. The SMRPF will guide DG-Food to address social safeguard compliance issues arising at project implementation stage and to ensure social inclusion in the process. DG Food will assess social impacts of project interventions and prepare Social Management Plans (SMP) including Resettlement Action Plans (RAP) following the SMRPF. Environmental and Social Assessment (ESA) The baseline environment for the subprojects of phase-I of project components of BMFSFP has been assessed regarding the project activities that relates to the area-specific conditions pertaining to Topography, Physiography and Geology, Seismicity, Hydrology and Drainage, Air Quality, Noise Quality etc. under physical environment and Terrestrial Ecology, Aquatic Ecology, Biodiversity, National Conservation Site of Importance under Biological Environment, Land Use/ownership Pattern, Water Supply and Sanitation, Fisheries, Industries and Commerce, Cultural and Archeological Resources under Socio-economic Environment. The water, air and noise quality were measured at each of the site for creating a strong baseline which will play a strong role for decision making during project monitoring. None of the site shows indication of air, water and noise pollution. Other than Madhupur, all other seven selected sites for the proposed silos are near rivers. Other than Madhupur all other areas have natural drainage system. A number of social establishments have been found within 500 m of Ashugang, Barisal, Dhaka Madhupur Maheswarpasha and Narayanganj. Social assessment comprised of (i) Beneficiary assessment, (ii) Stakeholder analysis, and (iii) Impacts assessments. Beneficiary assessment enabled building baseline socio-economic profiles at the project area; the current status of grain storage facilities at the public and at the household levels and the need for improved storage facilities and distribution mechanisms. The districts where the modern silos facilities are proposed to be constructed have been considered as the project area. While the disaster prone areas are considered for target areas for distribution of family silos. The social assessment identified key stakeholders at different levels in the project area and helped understanding their expectations, issues and concerns. The social assessment also included impact assessments and risk analysis. The results have been used in designing the social management and resettlement policy framework addressing social safeguards, thus ensuring positive and sustainable project benefits. Impact Assessment and Mitigation Environmental Impact The major environmental impacts to be affected are classified in the pre-construction, construction and operational stage. The possible impacts need to be considered during design phase are as follows (1) Risk of flooding and inundation and (2) Loss of agricultural and grazing land. The historical data shows Dhaka, Narayanganj, Ashuganj, Mymensing and Maheshwar Pasha were inundated in last 30 years and Madhupur does not have any natural drainage system. In addition the existing godowns are already higher than the existing ground level. From consultation, it was found, water entered to the Narayanganj Godown during 1988 flood. The significance of this unmitigated impact is assessed as xxii high and long term. Huge losses are likely to take place in case of flooding. Establishment of construction camp, pile driving and other civil works for construction of silo, stock piling of construction material, increasing traffic during construction and operation will impact the existing social infrastructure in the vicinity, if those are not addressed properly during the design phase. The establishment of construction camp will put load on the existing natural drainage and sewerage system. The design consultant will ensure the issues and associate mitigation measures will be addressed during design phase. During construction phase, around 450 trees will be cut from the 8 sites. To address this issue the contractor should prepare a tree plantation plan. The project will create noise and vibration in the surrounding due to a wide number of pile driving, at Dhaka and Mymensing, demolition of structure will cause severe dust pollution. In addition Construction machinery and project vehicles will release exhaust emissions, containing carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOX), and particulate matter (PM). Due to construction work, blocked access routes, stock piling of construction material, soil and water contamination, vehicular traffic increase is other environmental issues. Occupational health and Safety is the major concern for construction and operation of steel silo. The construction activities will involve operation of heavy construction machinery, vehicular traffic, excavation, filling operations and demolition of structures. These activities may pose some safety hazards to the local population. The fuel storage at the camp sites may also pose safety hazards for the construction staff as well as for surrounding population. Stockpiling of construction material in all sites and debris from the demolished structure may cause serious accident to the construction worker and people in the vicinity. Construction of steel silos may pose significant hazards related to the potential fall of materials or tools. The silo will use fumigation. Although DG-food is using fumigants regularly and steel silo is expected to minimize the use of fumigants, use of fumigant should be according to the USEPA and WHO guideline. Environmental Health and Safety measures should strictly be followed for O&M of Silos. Social issues Key social issues relating to project implementation are: (i) avoiding adverse social impacts in site selection, design and implementation; (ii) participation by project functionaries, business groups, NGOs, civil society and local communities; (iii) inclusion, particularly of the poor and vulnerable sections including ethnic minorities; (iii) identification of unavoidable adverse social impacts and mitigation; (iv) social conflicts and grievances during construction; (v) capacity building of key local stakeholders; (vi) addressing gender issues and community needs; and (vii) communication to address these issues. None of the first year sites for civil works will be carried out in private land but within existing land reserve of the DG-Food except in Tangail, where a new site has been selected for construction of the public silo in Madhupur. Given that this land in Madhupur is a khas land (government owned land) no private people will be impacted. However, the project in the subsequent phases and at critical situations in the first phase construction, may not avoid acquisition of private lands or public lands from private uses. Environmental Management Plan xxiii A comprehensive Environmental Management Plan (EMP) which focuses on managing construction and operation phase-related impacts should suffice in managing the potential construction and operation phase impacts. The EMP will be attached with the Bidding Document. The environmental management parameter will be included in the BoQ. Since many contractors do not have clear understanding the need of environmental management, some quoted very low price for implementation of EMP and eventually cannot implement EMP as per design. To avoid this problem, Fixed Budget will be assigned for EMP implementation. The contractors may need orientation on the requirement of the EMP in the pre-bidding meeting. The contractor needs to submit an Environmental Action Plan (EAP) based on the EIA and EMF in line with the construction schedule and guideline. The EAP needs to be reviewed by the supervision consultant and cleared by DG-Food and World Bank. Extensive monitoring of the environmental concerns of the BMFSFP project will be required as per World Bank guideline. The monitoring program will help to evaluate: (i) the extent and severity of the environmental impacts against the predicted impacts and baseline; (ii) trends in impacts; and (iii) overall effectiveness of the project environmental protection measures (iv) effectiveness and promptness of environmental, health and safety measures. The monitoring plans should be included in the EMP for specific sub-projects. Moreover, for all type of monitoring, a comprehensive database of the site specific Environmental Impact and Monitoring information should be created, which will help to evaluate the impacts easily. Institutional Responsibility and Report Requirement The PMU will have a dedicated Senior Environmental Specialist (SES) and Social Specialist to ensure implementation of EMP and other environmental management responsibilities. The SES will maintain liaison with WB safeguards team, regulatory agencies, and other stakeholders during the Project implementation. The Senior Environment Specialist has to be on Board as soon the PMU is set up. S/He will be responsible for ensuring the adequacy of environmental component in the Bidding Document (BOQ) and ensure the quality of Environmental Action Plan (EAP) submitted by the contractor. The field level environmental specialist should be on board before commencement of the field work. 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 Supervision Consultants will have dedicated, properly qualified and experienced, site-based Environment Monitor (EM) at each construction site. The EMs will monitor and supervise the EMP implementation at the field level. 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 then implement the relevant parts of the Operations Manual for ensuring health and safety during project operation. DG-Food will prepare the Half Yearly Progress Report on environmental management and will share with World Bank for review. The contributing development partners may also join the field visit to understand xxiv the environmental compliance of the project. In addition, the effectiveness of screening, monitoring and implementation of EMP will be carried out by the third party monitoring firm along with the project component activity monitoring annually. The Annual Environmental Audit Report prepared by the third party monitoring firm will be shared with the safeguards secretariat. Key Stakeholders and Consultation According to the objectives of the project, the population in the disaster prone areas of Bangladesh is the prime beneficiary of the project and they are spread all over the country, in the coastal zone, in the flood prone areas, and in the drought prone areas. Concentrated to the proposed silo sites, the residents attached to the 8 selected sites will be impacted during construction and operation of the silos facilities. Local leaders, traders, transporters and wage laborers have expressed their interest to the project. Key stakeholders of the project at various levels include: DG-Food and its officials at HQ and in the field offices, local administration (district and upazila level government officials), local government institutions (municipalities, union and upazila parishad), beneficiaries of the project (i.e., farmers, traders, wage laborers, and other villagers) and the likely affected persons, millers, transporters and transport workers. There have been consultations throughout the project preparation by the environmental and social assessment consultants. Disclosures Detailed Environmental and Social Assessment reports, including stakeholder consultation deliberations, are available with the PMU. Impact Assessment checklists and the simple social screening matrix, prepared as a part of the project preparation, are also available with the PMU. Summary of the ESAMF on policy issues and impact mitigation measures will be translated into Bengali language and disseminated locally. In accordance with the Bank’s disclosure policy, the summary of the ESAMF will also be uploaded in the DG-Food’s website and in the Bank InfoShop before appraisal. Any subsequent EMP/SMP/RAP will be discussed locally with the stakeholders and disseminated widely and made available on the project’s portal and in the Bank InfoShop before aware of civil works contract. xxv Draft March 30, 2013 SECTION A: GENERAL 1 INTRODUCTION 1.1 Background 1. Bangladesh is a densely populated country. About 160 million peoples live in land areas of only 144,000 sq km crisscrossed by numerous rivers flowing to the Bay of Bengal. The country is prone to natural disasters and effect of climate change, and therefore facing frequent extreme weather events that cause serious damage to infrastructure, crops, and the overall economy. Bangladesh is exposed to widespread floods, severe droughts and super cyclones, and these are particularly acute for the rural poor. Almost 80% of the country’s population lives in the rural areas, with around 53% of them classified as poor. Reliance to subsistence agriculture for many rural poor means that the impact of climate shocks and stresses are likely to have negative implications for their food and livelihood security, human capital and welfare.1 2. 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. This pressure on nutrition and health will be particularly acute for women and children, who face difficulties in the aftermath of a natural disaster event. 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, on the other hand, not only do losses occur during the cyclone but production is also severally hampered in the following year because saline sea water from storm surges is often deposited on agricultural lands, resulting in food stock shortages for at least two years. 3. The recurrence period for a major cyclone and widespread flooding in Bangladesh is around three years, necessitating an improved food storage system that can adequately distribute food aid during emergencies and disasters. This improved system would make use of modernized technologies that could store food grain (rice) for between two and three years, and would limit food storage losses significantly. This, combined with efforts to improve the efficacy and accountability of the grain distribution systems in post-disaster periods, could serve to significantly address food shortages experienced as a result of natural disaster events. 4. In consideration to the above facts the Government of Bangladesh (GOB) approached the World Bank to assist in development of modern silo facilities for storage of about one million tons of food grains. The precise amount to be stored will be largely dependent on the projected increasing frequency and intensity of extreme weather events as well as growing variability currently predicted under climate change projections. Thus, a phased approach that addresses improving the storage systems and 1 Davies, Mark, Katy Oswalk and Tom Mitchell (2009) “Climate Change Adaptation, Disaster Risk Reduction and Social Protection,� in Promoting Pro-Poor Growth: Social Protection, Organization for Economic Cooperation and Development (OECD) 2009. 2 distribution networks could act as a first step in the projected growing demand for grain stocks. GOB, with this intension, has been preparing the Bangladesh Modern Food Storage Phase – I Project (BMFSP- I). 1.2 Need of the Report 5. Bangladesh Environmental Conservation Act (ECA, 1995) requires the proponents of every development project in the country to obtain Environmental Clearance Certificate (ECC). Environmental Conservation Rule (ECR'97 (Rule 7)) of Bangladesh classifies industrial units and projects into four categories depending on environmental impact and location for the purpose of issuance of ECC. ECR’97 requires the proponents of development project in the country to submit to Department of Environment (DoE) an Initial Environmental Examination (IEE) or an Environmental Impact Assessment (EIA), based on level of environmental impact and categorization. 6. The World Bank Operational Policy 4.01 (OP 4.01) states that “The Bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making�2. 7. The present report has been prepared in line with the requirement of Government of Bangladesh and World Bank. 1.3 Report Structure 8. This report has been prepared by Ministry of Food. The report has been broadly divided into four sections. 9. Section A is termed as “General� which discusses the discusses the legislative, regulatory, and institutional setup that exists in the Country, as well as the World Bank’s safeguard policies relevant to the environmental and social assessment and project description. The section also includes alternative analysis which presents the overall aspect of environmental benefit in terms of site selection and technology selection. 10. Section B presents the Environmental and Social Management Framework which provides an overall guideline for implementation and operation of similar activities in future. 11. Site specific Environment and Social Assessment has been provided in Section C. 12. Environmental and social management plan is presented in Section D. This section also includes institutional assessment and disclosure requirement. 2 Excerpts from OP4.01 – Environmental Assessment. January, 1999. 3 2 PROJECT DESCRIPTION 2.1 Project Objectives 13. The objective of the project is to increase the grain reserve available to households to meet their post-disaster needs and improve the efficiency of grain storage management. The objective is also to improve efficacy of the grain storage system, and monitoring and management of the food stock in the country. The following key results are expected from the project: (i) Increased availability of grain stocks immediately following a major disaster; (ii) Increased number of households whose grain needs can be met immediately after the disaster; (iii) Change in cost per ton in storing grain relative to pre-project cost; (iv) Reduced loss in grain stocks relative to pre-project losses; and (v) Better monitoring, and improved governance and management of food stocks. 2.2 Project Components 14. Improving the food distribution and post-disaster relief timings is a longer term objective that will need to be gradually adjusted as the impacts of increasing climate variability and natural disasters continue to grow. With the existing storage capacity, the Government of Bangladesh will face increasing pressure to ensure the supply of food grains in the country, such as in the case of Cyclone Sidr in 2007. However, the precise amount to be stored will be largely dependent on the projected increasing frequency and intensity of extreme weather events as well as growing variability currently predicted under climate change projections. Thus, a phased approach that addresses improving the storage systems and distribution networks could act as a first step in the projected growing demand for grain stocks. The project, for the first phase construction, has selected suitable sites having lands currently owned by the FD. However, in the subsequent project phases, private lands or public lands from private uses may need to be acquired. The project will avoid sites inhabited by tribal peoples, land acquisition and physical displacement of peoples to the extent feasible. The project will be implemented over a period of 3 years. 15. The project components in the first phase includes (i) construction of modern public food grain storage silos (ii) procurement and distribution of household silos, (iii) implementation of social and environmental management plans, (iv) support for food planning and monitoring program and (v) program management, construction supervision, technical assistance, training and strategic studies. The physical components of the project in Phase I those involve social and environmental impacts includes (1) Public Storage Facilities in the form of modern grain storage silos; and (2) Household level storage facility or family silos particularly in the disaster prone areas of the coastal zone. 2.2.1 Component A – Construction of Modern Grain Storage Silo Facilities 16. This component would have two parts: (A1) Public Storage Facilities in the form of modern grain storage silos; and (A2) Household level storage facility or family silos particularly in the disaster prone areas of the coastal zone. A third part (A3) would focus on the implementation of social and environmental management plans. 17. Component A1: Construction of Modern Public Food Grain Storage Silos. This component would finance an improved storage silo system to store milled rice with a tot1al capacity of around 550,000 tons. The silos would be constructed on about 8 sites all over the country. All sites have land 4 currently owned by the DG-Food or the Government of Bangladesh. No new sites, requiring land acquisition, would be undertaken in the Project. 18. Component A2: Household Silos. Under ECCRP household level silos or grain storage bins have been developed in Bangladesh. These are specially designed 70 liters (about 40 kg) fiber glass cans with a water tight lid. Once rice is stored, the seal tight lid prevents the contents from damage due to water from surges and floods. These silos are being provided to people in Sidr-affected areas and they are extremely popular. People use them to store rice seeds (which is more valuable than rice) for safekeeping of critical inputs for future planting seasons, in the event of floods or storm surges, as well as for rice storage. The cost of such a Silo is about US$50. The project would make this Silo available at a discounted price of US$25 per piece for households. A manufacturer would be encouraged to produce such silos, and eligible households would be able to purchase them at a discounted price through a voucher system, administered by project consultants and contracted NGOs. Selected households would receive a voucher based on agreed criteria (such as in coastal areas, with certain income levels, etc) and would ensure that only one silo is purchased at half price per household. The contracted NGOs will carry out household needs assessment survey and prepare a list of eligible households based on eligibility criteria for location, grain/food storage needs, level of income and vulnerability (social, political, gender, and ethnicity). It is estimated that about one million household silos would be provided under the project, creating about 40,000 tons of storage of rice seed (or rice) in surge-prone areas of the coastal zone. 19. Beneficiary Selection Criteria. Beneficiary selection will be given adequate consideration while distributing such household (HH) Silos. The project would ensure a credible beneficiary list/database with ID numbers, names, sites, locations, and gender. Selected households would receive vouchers based on agreed criteria and would ensure that only one silo is purchased at discounted price per household. The payment procedure is outlined in the agreed Financial Manual that would be updated time to time and at least once every year. Selection of such beneficiaries would be endorsed by Upazila Agriculture Officer and Upazila Agriculture Rehabilitation and Implementation Committees (UAR&ICs). A robust transparent beneficiary selection criterion has been established. Guiding principles for the selection of beneficiaries would take the following priority selection criteria into consideration:  household is located in zone experiencing repeated natural disasters, such as cyclone and floods;  marginal and land-poor farmers (0.02-0.20 Ha);  landless households (less than 0.02 Ha);  members of both formal and informal farmer groups and other production groups (e.g. Union Farmers Associations, CBOs);  female-headed households and youth; and  communities located in remote and in the least accessible areas not receiving any other external support, such as assets from other sources/projects or remittances from outside the district;  not receiving remittances from other sources; 20. The strategy for selection of eligible households for receiving vouchers is discussed in section 6.4.1. 21. Component A3: Implementation of Social and Environmental Management Plans. The sites selected for public silos are already owned by the Government. Therefore, no major social or resettlement issues are expected. However, in order to ensure that, if any such issues arise, they could be addressed. These issues could be, for example, increased traffic congestion, or environmental or social 5 issues that could emerge during construction of silos. Also, the component would support the enhancement of the environment, such as improved landscaping, plantation of trees to improve the aesthetics of tall steel silos, etc.. 2.2.2 Component B – Support for Food Planning and Monitoring Program 22. Improvements are needed in the monitoring and management of food storage/stock and this system needs to be modernized. This component would finance these improvements and introduce a modernized system that would assist the Government of Bangladesh in better planning and monitoring of food stocks. These investments would assist in significantly reducing losses, and would ensure a timely distribution network for grain stocks in the event of an emergency. In general FPMU acts as a central coordinating authority and information clearing house for all food security related policy and program activities. FPMU could intervene more actively to improve the DG-Food's management information systems and reporting of rice and wheat distribution under all the different schemes include those designated for disaster relief. Right now it is apparent that there is no division level data generated for these programs. The information system would help in improve the transparency and accountability of the entire food distribution system. 2.2.3 Component C –Project management, construction supervision, technical assistance, training and strategic Studies. 23. This component would finance costs associated with: (C1) project management of the task, incremental staff and expenditures of the DG Food in implementation of the Project, the costs for implementing the Governance and Accountability Action Plan (GAAP), including a panel of experts, as needed, a procurement panel, audit and other such costs; (C2) cost of consultants for preparation of detailed designs, bidding documents, construction supervision and updating of designs required during the construction. This would include costs for construction supervision, monitoring and evaluation of project impacts; (C3) provision of technical assistance, training, institutional capacity building, preparation of future projects, and any strategic studies needed during project implementation. 24. Detail project description will be found in the Project Appraisal Document (PAD) of the project. 2.3 Project Beneficiaries 25. The Project would provide benefits to a wide range of people. In particular, the vulnerable and poor people in disaster prone areas, affected by floods and cyclones in coastal zone (about 19 districts) would benefit from the project. About 31.5% of the people are considered poor while about 17.6% are ultra-poor. About 21% of the total population is on various safety net program (not all are on food safety net) and about 1.66 million tons of rice and 0.74 million tons of wheat are on feeding program. At least 10 million people would directly or indirectly benefit from the project primarily in coastal and floods zones. About 1.2 million households (5 million people) would directly benefit from distribution of household level Silos. Over half of the beneficiaries would be women and children. 2.4 Selected Technology Description 2.4.1 Modern Public Food Grain Storage Silos 6 26. The silos would allow storage handling of large volumes of food grains particularly rice for 2-3 years. The steel bolted silos that are used in all climate zones would be used. These types of silos allow for speedy construction, and would have temperature control and fumigation systems, automated mechanical handling, and a central computerized control system. These types of silos have highly competitive supply consisting of at least 20 manufacturers active in the Figure 2-1: Modern Grain Steel silo international market. 27. Selection of Bin Size. Large volumes of wheat, soybeans and maize are storage siloes of 100,000 tons usually consist of a bin size of 10,000 to 15,000 tons of grain. In this case, the bin size is optimized considering foundation conditions as well as cooling requirements (described below) and bin size of about 3,000 tons and generally 60 feet diameters and 40 feet height would be used. 28. Drying of Rice before Storage. As the case is in Bangladesh, it is expected that storage sites would receive milled, parboiled rice which has moisture contents of 14%. To ensure efficient chilling for long term storage it would be necessary to reduce the moisture content to 12%. This would be done by drying center installed at the silos site. Two continuous drying systems would be installed at the site with a drying capacity of 600 tons per day which is the targeted rate of receiving milled rice during 4 to 5 months period following the Borro harvest. With circulating type dryer the rice would be dried in three passes at a low temperature of 38oC to 40oC to avoid cracking of and breakage and about 0.75% moisture would be removed in each pass. A higher temperature would be used for paddy. 29. Grain Chillers. With proper control of temperature and humidity it is possible store any grain including milled, parboiled rice almost indefinitely without spoilage. To prevent infestations and rancidity during extended storage periods in a humid climate such as Bangladesh it is essential to lower and maintain the temperature of the grain put into storage to 15oC or below. This is done with the use of a grain chiller, which is a very powerful refrigeration unit consisting of a compressor, condenser, evaporator, high power fan, frequency inverter and electrical controls. The chiller blows cold, dehumidified air through the grain mass cooling it progressively in layers from bottom to top. The warm moist air in the rice mass is steadily pushed upwards by the entering cold dry air until it exits from the top. 30. Bagging. Each storage will have two baggage stations at the discharge area for filling 50 kg bags at a rate of 500 bags per hour per station or 50 tons per hour bagging at the two stations combined. These two bagging stations will be installed in a bagging house with two truck lanes below such that trucks or hand trolleys can be loaded from above my means of a vertically adjustable slide or hoistable belt conveyer ramp. Each bagging station will be fed by a 33 ton capacity surge bin allowing bagging to be continued even during stoppages of the main conveying equipment. A third load out station in each discharge area will be equipped to load trucks with rice in bulk or to fill one ton “jumbo� bags in trucks or on hand trolleys. 31. Packaging Each silo storage facility will have a packaging line for filling 5 and 10 kg packages of rice. One existing warehouse at each site can be converted for this purpose. Packaging capacity at each 7 site will be 10 tons per hour. Three packaging machines per site will be used. The packaged rice can be pre-positioned or held at the storage facility for emergency relief operations and can be rotated when necessary through open market sales. 2.4.2 Household Silos 32. The containers are made of fiber glass cans with a storage capacity of 70 liters (40 kg). The lid is water tight. The sealing ring placed in the mouth lid is made from such durable flexible material as to enable air/water-tightness of the silo. The mouth lid of the drum must have an air tight closing arrangement (gasket in lid) allowing to hermetically seal the seed/grain silo. The lid is threaded in the inner circular part and rubber gasket is provided at the mesh point. 33. There are 2 symmetrical inner grooves on both sides of the silo/drum body to allow and facilitate holding/pulling/carrying by hand. The choice of silo material Figure 2-2 Popular should consider the heat generated from the grain/seed storage. Household Silo Used for ECCRP 2.5 Scope of BMFSP-I Intervention for Environment and Social Study 34. Of the three main components, all three sub-component of Component A, Component A1: Construction of Modern Public Food Grain Storage Silos and Component A2: Household Silos and Component A3: Implementation of Social and Environmental Management Plans are expected to trigger environmental and social impact. 2.5.1 Component A1: Construction of Modern Public Food Grain Storage Silos 35. Additional modern food grain storage facilities of capacity 600,000 tons will be developed across the country at the existing sites. Potential locations for the Modern Grain Silo in the first phase are Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensing, Maheshwar Pasha and Chittagong. No new sites would be undertaken in this first phase project. The sites already possess conventional godowns but enough extra space is available at each site to fit the new silo cluster. Although most of the sites are already developed, new technology construction and deployment may require land filling and put pressure on utility supply like gas and electricity. The drainage and sewerage facility may also need to be enhanced. For the subsequent phases, the specific site locations and their physical characteristics relevant to the safeguard analysis will be known only after finalizing the silo sites. 36. Activities under construction of modern public food grain silo which may have environmental and social foot print include: (i) construction of foundation of Silo with high dead load and live load; (ii) construction of high rise superstructure with prefabricated steel and bolt. The construction method will follow top down approach to reduce occupational risk associated with high rise construction; (iii) a 2 to 3 story elevated bagging house with two to three lanes of truck loading at ground level; (iv) construction and operation of a drying center; (v) construction of a laboratory; (vi) operation of the silo including fumigation. 8 2.5.2 Component A2: Household Silos 37. The cost per ton for household storage proposed under this project is higher than for large silos. However, the ready available stocks in very remote areas immediately following a disaster makes this type of storage the most effective to address nutrition needs. In addition, it also reduces the burden of the government to carry such stocks to fairly distribute in remote areas. Finally, the ability to store rice seeds for the next agricultural season provides an additional value to households. 38. Activities under household silo which may have environmental and social foot print include: (i) choice of drum material which needs to food grain plastic or fiber glass can (ii) gasket material to make the lid air tight (iii) user friendly design to facilitate holding/pulling/carrying in a safe way (iv) social benefit to withstand natural calamity. 2.5.3 Component A3: Implementation of Social and Environmental Management Plans 39. This sub-component will incorporate a wide range of need based activity in the project surrounding area for social and environmental benefit. The component would support the enhancement of the environment, such as improved landscaping, plantation of trees to improve the aesthetics of tall steel silos, etc.. Need based communal structure development under this sub-component can range from public toilet, small structure for community health facilities to widening of the approach road to minimize traffic congestion due to the construction of Silos. In short, the activities will be need based community infrastructure whose environmental and social impact can be addressed only during the small scale need based activities identification. 9 3 ENVIRONMENTAL & SOCIAL POLICIES, LEGAL AND ADMINISTRATIVE FRAMEWORK 3.1 General Description of Environmental Polices and Legislation in Bangladesh 40. 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 (BECA, 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; National Plan for Disaster Management, 2010-2015. Some of these policies and legislations are described in this chapter for reference. 3.1.1 Bangladesh Environment Conservation Act, 1995 41. 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. 42. 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. 3.1.2 Environment Conservation Rules, 1997 43. The Environment Conservation Rules provide a first set of rules under the Environment Conservation Act, 1995. This rules is further amended in 2002 and 2003. 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 10 44. 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, Hakaluki Haor, Yanguar Haor, Marzat Baor and Gulshan-Baridhara Lake as ecologically critical areas and accordingly has prohibited certain activities in those areas. has also declared four rivers surrounding Dhaka city respectively Buriganga, Balu, Turag and Dhaleshwari as ecologically critical area. 45. 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. 46. Green Category projects are considered relatively pollution-free and hence do not require initial environmental examination (IEE) and EIA. An environment clearance certificate (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. 3.1.3 Bangladesh Climate Change Strategy and Action Plan (BCCSAP) 2009 47. 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. 11  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. 3.1.4 National Environment Action Plan, 1992 48. 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 a. 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. b. Proper and regulated use of chemical fertilizers will be ensured. Use of organic fertilizers will be increasingly emphasized. c. Imported seeds, seedlings and plants will be properly quarantined to exercise necessary caution against probable adverse environmental impact. d. Natural methods of pest control will be encouraged through ensuring protection and safety. e. Steps should be taken to establish an agricultural system based on local ecosystem, rate of population growth and demand of national economy. 3.1.5 National Water Policy 1999 49. 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. 3.1.6 Standing Orders on Disaster, 2010 48. 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 12 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. 49. 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, sanitation and shelter space for livestock during such periods should also be considered for future construction of shelters. 50. 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. 3.1.7 National Integrated Pest Management Policy, 2002 51. 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. 3.1.8 National Fisheries Policy, 1996 52. 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:  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 13  Laws will be formulated to ban the disposal of any untreated industrial effluents into the water bodies. 3.1.9 National Adaptation Programme of Action (NAPA) 53. 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 3.1.10 Bangladesh Labor Act, 2006 54. 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; 14 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 3.1.11 Bangladesh National Building Code, 2006 3.1.11a Demolition of Structure 55. BNBC sets guideline for demolition of structure. The highlight 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. 3.1.11b Occupational Health and Safety 56. Part-7, Chapter -1 of the Bangladesh National Building Code (BNBC) 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 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 put in writing. 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). 57. 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 equipments 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�. 58. 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. 15 59. 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�. 60. 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.� 61. 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. 3.1.12 National Agricultural Policy, 2010 62. 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 to create 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. 3.1.13 National Food Policy 2006; 63. 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). 64. Policy 1.2.2.1 of National Food Policy, 2006 states the Development of private sector foodgrain storage and movement system. The storage facilities presently available in the private sector are not 16 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: i. allow unrestricted movement of foodstuff in the country; and ii. ensure credit facilities to develop storage structures in appropriate places. 65. Under the Public foodgrain 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 foodgrains to operate various food-based safety net programs, the Government also maintains a security reserve to cope for emergency needs during disasters. In order to handle uncertainties of import arrival and emergency offtake requirements, the Government has decided to maintain a public stock of 1.0 million tons of foodgrains. 66. 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 foodgrain 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 foodgrain stocks should be reviewed annually considering the changing situations in domestic and global markets coupled with disaster proneness. 67. 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: i. ensure quick distribution of food in affected households in times of disaster; ii. hold enough foodgrain 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; 68. 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: i. formulation of uniform arrangement, development of testing techniques, setting of standards and their application and compulsory enforcement; ii. investment in development of packing or packaging and safe storage facilities; iii. increase laboratory facilities and impart practical knowledge for development of the quality of food and food products; iv. training for concerned officials and institutions in protecting the grades and standards of food products; v. campaign for nutrition enhancing quality and safe food; and 17 vi. 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 3.1.14 National Food Policy Plan of Action, 2008-2015 69. 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 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 foodgrain 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, 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. 3.1.15 Bangladesh Country Investment Plan (CIP), 2011 70. 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. 3.2 World Bank’s Environmental Safeguard Policy 71. 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 18 • 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 • 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 72. 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. 3.2.1 OP/BP 4.01 Environmental Assessment 73. 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. 74. 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, siting, 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 transboundary 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. 75. 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 19 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 mitigatory 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. 3.2.2 OP/BP 4.04 Natural Habitats 76. 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. 3.2.3 OP/BP 4.09 Pest Management 77. 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. 78. 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 Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines to Classification (Geneva: WHO 1994-95). 3.2.4 OP/BP 4.11 Physical Cultural Resources 79. 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. 20 3.2.5 OP/BP 4.36 Forests 80. 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. 3.2.6 OP/BP 4.37 Safety of Dams 81. When the World Bank finances new dams, the Policy Safety on Dams requires that experienced and competent professionals design and supervise construction, and that the borrower adopts and implements dam safety measures through the project cycle. The policy also applies to existing dams where they influence the performance of a project. In this case, a dam safety assessment should be carried out and necessary additional dam safety measures implemented. 3.2.7 WBG/ IFC Environmental, Health and Safety Guidelines 82. The Environmental, Health and Safety (EHS) Guidelines of the World Bank Group (WBG)/International Finance Corporation (IFC), 2008 is the safeguard guidelines for environment, health and safety for the development of the industrial and other projects. They contain performance levels and measures that are considered to be achievable in new facilities at reasonable costs using existing technologies. 3.3 General Description of Social Polices and Legislation in Bangladesh 83. 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. 21 3.3.1 Constitution of Bangladesh 84. 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. 3.3.2 The Acquisition and Requisition of Immovable Property Ordinance, 1982 85. 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). 86. 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. 87. 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 bighas (3.37 ha). 3.3.3 The East Bengal State Acquisition and Tenancy Act, 1950 (Revised 1994) 88. 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 (nadi sikosti) in the country. In legal terms, eroded lands (sikosti) inside the alluvion-diluvion (AD) line (i.e. including 22 submerged land or underwater land) are considered khas land once declared by concerned Deputy Commissioner (DC) demarcating the AD Line.3 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. 3.3.4 Constitutional Right of the Tribal Peoples Rights 89. 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 ar e 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. 3.3.5 The Chittagong Hill Tracts Regulation 1900 90. 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. 3.3.6 The Chittagong Hill –Tracts (Land Acquisition) Regulation, 1958 91. 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 3 The Assistant Commissioner of Lands (AC Land) in respective districts demarcates the AD Line each year in areas where rivers frequently erode their banks. According to law, if the land classified by an AD Line re-appears within 30 years from the date of erosion, the original owner(s) can claim the land. 4 The CHT districts comprise the reserved forests, the circle of the three Chiefs, viz. the Chakmas Chief, the Bohmong Chief and Mogh Chief and the Maini Valley (rule 35). 5 The Circle Chiefs form an Advisory Council to the Deputy Commissioner (DC) for administration of their respective circles and exercise their authority as Chiefs in the prompt enforcement in the mouzas of their circles of all orders of the DC. 23 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. 3.3.7 The CHT Regional Council Act, 1998 92. 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. 93. 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 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. 3.3.8 Ethnic Minority Rights in PRSP 2005 94. 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: i. 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. ii. Proper actions for protecting the rights of ethnic minority people, particularly their rights to land and forests. iii. Transfer of land administration in CHT to the hill districts councils in accordance with the ‘Hill District Councils Acts of 1989’. iv. Provide education to ethnic minority people with a curriculum that allows learning in their own language at the primary level. v. Strengthen their competence in job markets through affirmative actions at higher levels of education and skill training to promote their inclusion in mainstream economic life. vi. 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. 24 vii. Increase and utilize property the fund available in the Prime Minister’s office for the development of the ethnic minority people of the plain lands. viii. Provide wider access to electrification and telecommunications for ethnic minority communities, particularly in the Hill Tracts. 3.3.9 GOB Laws on Land Acquisition 95. 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 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. 3.4 World Bank’s Social Safeguard Policy 3.4.1 Involuntary Resettlement (OP 4.12) 96. 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.6 97. 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. 6 Excerpts from WB OP 4.12. WB Operational Manual. December 2001. 25 � 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. 3.4.2 Indigenous People (OP 4.10) 98. 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; � 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. 3.5 Implications of National Polices and Legislations on the Project 99. 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 which will involve demolishing of existing structure and construction of silo during the construction period and use of fumigants 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. 3.6 Implication of Environmental Safeguard Policies of WB on the Project 100. 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, knocking down of existing godowns, environmental and occupation health and safety and use of low dose of fumigants during project operation. The Project has triggered only one 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 insectides. DG Food is already using fumigants in the existing godowns. Fumigants may be needed to be used during the operation phase of the Silo. A fumigant application mechanism should follow the USEPA and WHO guideline. As per Bank requirement, the 7 Excerpts from the OP 4.10. WB Operational Manual. July 2005. 26 borrower needs to consult project-affected groups and local nongovernmental organizations (NGOs) 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 such groups throughout project implementation as necessary to address EA-related issues that affect them. 3.7 Implication of Social Safeguard Policies of WB on the Project 101. 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). 102. 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. 27 4 ALTERNATIVE ANALYSIS 4.1 Introduction 103. From the environmental safeguard view point, alternative analysis is an important tool for the best selection of the project site, technology to be followed, and operational mechanism in terms of environmental acceptability of the chosen method. Alternative analysis provides information about the advantages and disadvantages, quantifies the environmental impacts to the extent possible, and attaches economic values where feasible for each alternative considered. The alternative analysis for BMFSFP project will be conducted into the following sections. (a) "no action" alternative of the project. (b) Alternative Analysis for Selection of Sites (c) Alternative Analysis for Technology Options 104. The Alternative Analysis for Technology options also include the comparative analysis based on the option during construction and operation. 4.2 "No Action" Alternative of the Project 105. Bangladesh is a disaster prone country. Almost every year this country is devastated by cyclone, flood or drought. In all cases the devastation is on the crop, particularly rice, the main staple of the people. An interval of three years has been observed when shortage of rice occurs in the country, particularly in the coastal area and a major shortfall occurs every ten years. The situation is likely to aggravate due to global warming reflecting its effects on the erratic climatic behavior. Against the backdrop of such emerging issues like the natural calamities and disasters, the increasing food prices and the shortages of food during the times of urgent need develops food insecurity in the country. If Bangladesh Government does not increase food storage capacity, at the time of food shortage, the country will need to import food at a higher price. The current storage capacity of the country is 16 lakh tons. But will be reduced to 13 lakh Tons by 2013 due to further deterioration of the old godowns. It is estimated the requirement of storage capacity for the food grain is 30.5 lakh tons by the end of 2020. If the storage facility is not increased immediate with the increasing frequency of natural disaster, decreasing storage facility due to deteriorated existing godown, the country will face shortage of food during emergency need of food. The trend of storage need is presented in Figure 4.1. 28 Figure 4-1 Trend of Storage Need 4.3 Alternative Analysis for Selection of Sites 106. Several sites were analyzed all over Bangladesh. The site selection criteria are as follows: d. Strategic value of the storage location for distribution of food grain stocks in emergency relief situations or for the pre-positioning of such stocks e. Rationality of increased storage capacity at the site based on existing and anticipated food grain movements by the client for all uses in order to ensure proper rotation of stocks f. Avoidance of land acquisition issues that could delay the start of construction and therefore a focus on existing Food Department storage sites 107. Initially fourteen sites were taken into account. Considering the above conditions, 8 sites have been selected for the first phase. Table 4.1 shows the comparative analysis of the site for environmental consequences. 29 Table 4-1 Alternative Analysis for Site Selection Considering Major Environmental and Social Factors to be Impacted Sites Land Owner Risk Mode of Transportation Strategic Demoliti Pile Total Natur Appar ship Associat Location For on of driving Trees al ent ed with distribution of structur into to be draina Enviro Land grain during e GW= cut ge nment Acquisiti emergency triggerin Pile facility al possib on/ (Number of g dust length – Impac Social Mode of pollution GW ly t Impact transport 1= +, , health depth 2= ++, & safety (m) 3=+++, 4=++++) Barisal CSD DG Food Low The site has both road and river transport. ++ No 30 69 Yes Low The site is linked to the 20’-0� wide pucca road of CSD & the Kirthan khola river. Narayanganj DG Food Low The site is linked the 16’-0� wide a ++ No 19.75 10 Yes Very CSD branch road of Dhaka- Chittagong High Low Way & adjacent to the Shitalakkha river. Facilities for communication are road & river are being used. Dhaka CSD DG Food Low The site is linked to the Farida bad police ++ Yes 29.75 9 Yes Moder station road and Buriganga river ate Ashuganj DG Food Low The site is linked with Dhaka +++ No 19.8 30 Yes Low Silo Bramonbaria, Dhaka sylhet high way, Dhaka Chittagong Railway and adjacent to The Meghna river. Road, railway & river are being used for communication Mymesingh DG Food Low The site is linked to the 20’-0� wide of + Yes 27.73 159 Yes Moder CSD Mymensingh-Tangail High way. ate M'Pasha DG Food Low The access to site is 32’-0� wide pucca +++ No 37.1 97 Yes Moder CSD (Food road of the CSD connected with Khulan- ate grain) Jessore Highway. River and railway are other mode of transport. Chittagong DG Food Low Communications of site are rail, road, air, ++++ No 29.58 16 Yes Low (Food grain) sea etc. The site is linked to Kathghor road-sea beach/Airport road. Madhupur DG Food and Moderate The access to site is 16’-0� wide pucca + No 17.84 60 No Moder (Khas Land) some road which is running beside the ate Government proposed silo site. The site is adjacent to 30 Sites Land Owner Risk Mode of Transportation Strategic Demoliti Pile Total Natur Appar ship Associat Location For on of driving Trees al ent ed with distribution of structur into to be draina Enviro Land grain during e GW= cut ge nment Acquisiti emergency triggerin Pile facility al possib on/ (Number of g dust length – Impac Social Mode of pollution GW ly t Impact transport 1= +, , health depth 2= ++, & safety (m) 3=+++, 4=++++) Khas Land the Mymensingh-Tangail-Jamalpur high- may be way. needed Mongla Silo DG Food Low The site is well connected by the road + No 33. No Concre - (Food grain) ways as the existing concrete silo (on tree or te silo going construction) is in place and doing vegetat is the inbound. The site is at the bank of ion at already Pashur River, but there is no jetty. all under constru ction Gobindaganj Private Land Very The site is attached by Dhaka-Rangpur + No Not - - - (New Site) High high way. checked since silo site will not support acquiring private land Khulna CSD DG Food, Very There are good road connections to the ++ Yes Not - - - Site May High site and no restrictions on movements of checked need to trucks to the site. There is also a railway since silo acquire for connection with the CSD site. The site will Ancillary godowns are so designed and constructed not facilities. that every alternate godown is connected support Existing by rail road and the other alternative is by acquiring godowns are the trucks. land used Save the Children and World Food 31 Sites Land Owner Risk Mode of Transportation Strategic Demoliti Pile Total Natur Appar ship Associat Location For on of driving Trees al ent ed with distribution of structur into to be draina Enviro Land grain during e GW= cut ge nment Acquisiti emergency triggerin Pile facility al possib on/ (Number of g dust length – Impac Social Mode of pollution GW ly t Impact transport 1= +, , health depth 2= ++, & safety (m) 3=+++, 4=++++) Program Dinajpur DG Food, Very The campus is linked with rail and road ++ No Silo site - - - CSD But for silo High connection. The road connection is will not construction maintained through a 12 feet wide pucca support lands need to road which is connected with the wide acquiring acquire station road and then to the high way. land Baghabari BIWTA Land High It has both good road and river ++ No - - - (BIWTA connection Land) Naogaon Government High The site is situated by the side of the + No Silo site - - - (Khas land) Khas Land Rajshahi-Naogaon highway that ensures will not its connectivity with the rest of the support country by using road transports. acquiring land - 32 4.4 Alternative Analysis for Technology Options 108. In Bangladesh, conventional godowns/warehouses and concrete built silos were constructed in different locations of the country and are now being used to store rice and other food grains. On the other hand, steel built silos are widely used in many countries of the world as modern food storage technologies as alternatives of concrete built silos and conventional godowns. The options are: 1) Steel Silo 2) Concrete Silo 3) Conventional Godowns 109. Moisture and Temperature control are the critical aspects for bulk storage of parboiled rice. The optimum temperature for growth of most grain moulds is between 25°C to 30°C and some moulds develop best at around 37°C. The minimum air relative humidity (RH) for mould germination is 65%. Thus to prevent mould growth on food grains at any temperature, the RH of the air in the grain mass must be less than 65%. Insect development is enhanced by high moisture content (MC) conditions (above 14%) and insect activity hardly occurs in food grains at MC contents below 10%. Most insects are dormant below 10°C and are killed at temperature above 38°C. Moreover, presence of dust in food grains facilitates germination of insects inside the food grain. Dust also reduces the nutrition value of the food grains. 110. The outside walls of both concrete and steel silo bins offer thermal insulation and the temperature of the outside air can be transferred to both the grains and the air inside the walls. In this way, the outside temperature variations make the initial grain storage conditions change. When the temperature outside the bin decreases, a temperature gradient is created across the walls8. The air in the silo develops a continuous convection movement. The air near the walls is cooled, raising its RH and resulting in an increase of the MC in the bottom of the silo. This increase in moisture can create a deterioration spot. Then the dry air rises through the central part of the bulk mass and picks up moisture from the grain. When this warm, moist air contacts the cool upper grain surface, the moisture is deposited and another deterioration zone can occur. The inverse air movement pattern may occur if the air outside the bin warms up, causing the MC to increase near the floor of the bin. In the tropics, where seasonal temperature changes are not very large, the main problem occurs with daily temperature changes or day to night temperature variations and high RH of the air. The high daytime temperature heats the inside of the bin causing moisture transport from the grain to the surrounding air. At night, the outside temperature drops very rapidly and the water vapors in the air spaces condense on the internal surface of the bin, mainly on the roof. The grain can act as a condensing surface if its temperature is reduced to below the dew point temperature of the air. This condensation problem may cause deterioration areas on the top of the grain and sometimes on the walls. This will create some hotspots or caking of grains inside the silos. 8 Brooker, D. f., Bakker Arkema, and C. Hall, 1981. Drying cereal grains, AVI published company, Inc., 3 rd printing. 33 Table 4-2 Comparative Analysis of Food Grain Storage Steel Silo Concrete Silo Conventional Godowns View of Super Structure Description The steel Silos are the containers for The Concrete Silos are the containers for The conventional godown/ ware house is storage of bulk volume of grains. The storage of bulk volume of grains. The super made of brick wall and galvanized tin top super structure of steel silo is made of structure of concrete silo is made of concrete. galvanized steel. Space Corrugated steel bins are mainly designed Concrete bins are built in different shapes, The conventional ware-house/godown with Requirement to resist tensile stress and the only efficient the most common being circular, rectangular dimensions 100ft X 80ft X 20ft space will shape is circular bins to counteract and hexagonal. Diameters vary typically make possible storing 1000 mt of rice bending/flexural stresses. Bulk storage in from 5m to 12m and heights from 15m to grains, which is more than 8 times the area silos eliminates the need for pallets and 55m. The wall thickness varies from 15cm to other dunnage on which bags of grain are 20cm. Rectangular concrete bins have than the same of concrete silos considering usually stacked. This reduces use of covered 90.5% area whereas Steel Silos the same capacity. This is not efficient in lumber and saves trees. cover 75% of the area for the same capacity. terms of bulk storage. Concrete silo is also used for bulk storage. Temperature, Grain chilling, grain drying and grain Grain chilling, grain drying and grain Grain chilling, grain drying and grain 34 Steel Silo Concrete Silo Conventional Godowns Moisture and cleaning equipment are used are used for cleaning equipment can be used are used for cleaning are problematic or impossible dust control Steel Silo. Concrete Silo. But in Bangladesh thermal when grain is held in bags in warehouses Technology insulation is provided with very thick (15 to 20 cm) concrete walls of the silos which only consider energy transport by mechanism of conduction without use of any other controlling Alternatives assessment considering impacts during construction Required Foundation = 26 Foundation = 28 Foundation = 4 amount of Superstructure = nil Superstructure = 15 Superstructure = 8 Concrete Foundation of the structure is important Foundation work is equally rigorous like Comparative Simple method to construct Volume and rigorous and requires technical skill steel silo. 3 (m /mt) set for construction. The superstructure will be built in the convention building method bottom up approach. Skillset Required Skilled Manpower for Required Skilled Manpower for Foundation Does not require highly skilled manpower. Foundation = 100 = 100 Unskilled manpower may create significant Required Skilled Manpower for Required Skilled Manpower for delay of work. Superstructure = 2800 Superstructure = 3000 Locally No for superstructure. Yes Yes Available manpower Dust Pollution Superstructure will be built with Constructing concrete silos superstructure Constructing warehouse/godowns also during prefabricated steel. The factory fabricated require large volume of concrete works require large volume of concrete works. Superstructure galvanized steel sections of the silos and where cement, fine and coarse aggregates are Construction other steel structural members will be bolted with the vertical members of the to be mixed to prepare concrete throughout silo bins to form the round outer skin of the construction period. the silo as per the diameter of the bin. The upper cone of the silo will then be placed and constructed on top of this. Once the top cone has been placed on the first 35 Steel Silo Concrete Silo Conventional Godowns section the entire structure will be raised by a battery of special jacks placed at the base of the silo and another circular section added beneath it. The entire construction, till it reaches the required height, will thus be completed. The conveyor belts and other equipment of the silos will be connected with the system as the construction works progress. Dust is not a problem during superstructure construction. Temporary Steel Silos require mainly technically Construction of both concrete silos and Work Camps skilled labors. The waste management and godowns requires many unskilled laborers sanitation facilities can be maintained for which temporary camps for the laborers adequately are needed throughout the construction period. Consequently, the waste management and sanitary facilities are may not be maintained adequately. Hiring of Local labors may be hired during Local labors will be hired at a higher extent. Local labors will be hired at a higher extent. Local Labors foundation construction. Super-structure requires only skilled labors. Local labors will be hired at smaller extent. Safety Issue Top to bottom approach will be followed. Bottom up approach is followed. Concrete Conventional method is followed for Erection of steel silos is done completely silo construction using slipforms is done warehouse construction. at ground level using hydraulic jacks to lift partially with workers high off the ground. the cylindrical structure as each ring of steel panels is bolted together. Therefore there is little risk associated with falling from height. Alternatives assessment considering impacts during operation 36 Steel Silo Concrete Silo Conventional Godowns Dust Control Dust collector can be integrated with the Dust collector can be integrated with Grains are stored in bags in the warehouse. steel silo which can reduce the dust from concrete silo as to control dust from grains. It is difficult to control in the ware house. grains. Insects and Grain chillers used for chilling the grains By providing grain chiller, insects and pests Temperature cannot be controlled in the other pests can be integrated with steel silo which can be controlled in concrete silo. conventional godowns. Insects and pests control keeps the grains at lower temperature. cannot be controlled adequately. Therefore, Mould will not occur and insects will not long term storage of food is difficult in reproduce at the lower temperature. This is conventional warehouse. important to facilitate long term storage of food grains as well. Rodent Both steel and concrete silo structures Grains are protected from rodents and birds Poisons and other measures need to be Control prevent the rodents and birds which are in the concrete silo. adopted for rodent and bird control. often a major problem for grain storage. Infestation due It is expected grain chiller will be used Currently used once in a month. Since the Fumigant is used once in every week with to fumigation properly to control the temperature which grain chiller are not working in the existing the mentioned dosage. (Fumigant will reduce the possibility of infestation. Silo. Aluminum Phosphide 12gm/mt) Power Power consumption is high for steel silo. Concrete silos usually require 5 to 6 kwh/ Warehouse/godowns usually require 0.1 to Consumption The steel silos are operated and monitored month for each mt of rice grains. 0.2 kwh/month for each mt of rice grains. through electronically controlled devices Power consumption is least for conventional and they consist of chiller and dryer. For godowns. the BMFSFP, It is estimated that at an average 10 kwh is required power consumption/month for each mt of rice grains. Fewer plastic The steel silo will be used for bulk storage Concrete silo also reduces the use of jute and Grains are storage in bags in warehouse and jute bags of grains which will eventually reduce the plastic bags. which generates environmental problem due in storage use of plastic and jute bags. to disposal of more worn out bags. 37 Steel Silo Concrete Silo Conventional Godowns Elimination of No use of dunnage and wooden pallets No use of dunnage and wooden pallets In the godowns, bagged grains must be dunnage and stored on dunnage and wooden pallets that wooden pallets wear out and need replacement every few years. This promotes tree cutting. Reuse of rice The steel silos will have dryers that will If dryer is used, good quality briquettes can Briquettes from rice husk cannot be husk make good quality rice husks which may be made. prepared. be also pressed into briquettes. Dust Explosion The possibility of dust explosion is less for The risk of catastrophic collapse of the grain - steel silo. storage due to grain dust explosion are much higher in concrete silos than in steel silos due to the confined area in the basement where dust concentrations can be high and easily ignited by a spark. 38 SECTION B: ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK (ESMF) 39 5 ENVIRONMENTAL MANAGEMENT FRAMEWORK (EMF) 5.1 Objectives of the EMF 111. The purpose of the EMF is to prepare an outline for Environmental Assessment and Management describing brief details of potential Environmental issues typically associated with the planning, designing, implementation and operational activities envisaged under the Bangladesh Modern Food Storage Facilities project and provide guidelines on how to carry out Initial Environmental Examinations (IEE), Environmental Impact Assessment (EIA) and prepare Environmental Management (Mitigation and Monitoring) Plan to mitigate project induced negative environmental impacts and enhance positive environmental and social impacts due to the project interventions. 112. An EMF is needed for the ancillary facilities which will be decided during project implementation and the tasks to address under component A3. Food silos will be established at 8 locations with a total capacity of around 600,000 tons. Environmental Impact Assessment (EIA) for 8 locations have already been conducted and are presented in Section C of this report. This EMF presents the guideline to conduct Environmental Impact Assessment (EIA) of the undecided tasks and the preparing the Environmental Management Plan. 113. The EMF highlights the guidelines, codes of practice and procedure to be taken into consideration for integration of environmental and social aspects into the project design. Adhering to the principles and guidelines and using the potential environmental issues layout in EMF will help the implementing agencies (viz. PMUs) to ensure compliance with the related Government Policies and associated rules regulations and also with the environmental safeguard polices of World Bank. The EMF is only applicable to Component A, as the other components do not require infrastructure interventions. The project will be considered as “Category B� project. 114. The objectives of the EMF is to ensure that Bangladesh Modern Food Storage Facilities project activities will ensure the following aspects:  Ensure that environmental and related social issues are thoroughly evaluated and necessary interventions are incorporated in the planning, designing, implementation and operation phase of project activities through environmental and social impact assessment.;  Ensure compliance and due diligence with World Bank environmental and social safeguard policies as well as with related Government Polices, regulations, guidelines and procedures as applicable to the cold storage and associated infrastructure development of the project;  Preventing and/or mitigating any negative environmental impact that may emerge from any project component;  Enhancement of positive environmental impact;  Protecting human health 5.2 General Principles of the EMF 115. The project will have positive environmental and socio-economic benefits, as its objective is to provide facilities for efficient food storage which will ensure supply of adequate food supply during the natural disaster period. The technology will also ensure prolonged time of rice storage for 2-3 years which is generally 3-6 months in the conventional method. However, some of the physical investments will have construction-related environmental and social issues that will impact the neighborhood. These impacts are not expected to be significant and irreversible. With appropriate management (mitigation and 40 monitoring) measures, these impacts can be mitigated as set about in this EMF. General principles are as follows:  The Project Director of the implementing agency shall be responsible for the environmental and social compliance in their respective components and the Sr. Environmental Specialist & Senior Social Specialist of PMU will be responsible for monitoring and seeing oversight in order to ensure overall project environmental and social compliance.  The Sr. Environmental and Sr. Social Specialist shall be on board before awarding the contract. They will review the Environment Action Plan submitted by the Contractor.  The Contractor will submit an Environmental Action Plan prepared in line with this EMF and construction schedule.  The executing agencies and involved sectors, if any, shall follow the related Government rules (laws, ordinances, acts, etc) and the World Bank operational policies and guidelines. This EMF will serve as the basis for ensuring their compliance.  Implementing agencies shall ensure the participation of local community in planning and execution of the sub-projects and document it.  Implementing agencies shall be responsible for ensuring clearance from the DOE, local government agencies/ local committee as necessary.  No project activities shall be carried in any disputed lands or land restricted for development.  The project will ensure that environmental considerations are given sufficient attention, weight and influence over design decisions of Silos. To this end, it will carry out Initial Environmental Examination (IEE) for all Silos.  The implementing agency will ensure that environmental screening/assessment of subprojects addresses all potential environmental and social direct and indirect impacts of the project (and any potential sub-project) throughout its life: pre-construction, construction and operation stages and mitigation measures have been taken to mitigate negative consequences and enhance positive impacts.  The environmental assessment of the subprojects under Component A will require Bank clearance before implementation. 5.3 Environmental Assessment Methodology 5.3.1 Environmental Assessment 116. The Environmental Assessment (EA) process makes sure that environmental issues are raised when a project or plan is first discussed and that all concerns are addressed as a project gains momentum through to implementation. It is essential that an environmental assessment is carried out to determine significant impacts early in the project cycle so that recommendations can be built into the design and cost-benefit analysis without causing major delays or increased design costs. Once implementation has commenced, the EA should lead to a mechanism whereby adequate monitoring is undertaken to realize environmental management. An important output from the EIA process should be the delineation of enabling mechanisms for such effective 41 management. An EA is a process comprising a series of steps. The key steps for environmental assessment are:  Environmental Screening and Initial Environmental Examination (IEE)  Environmental Impact Assessment (EIA)  Environmental Management (Mitigation and Monitoring) Plan 5.3.2 Step 1: Identification of Project Influence Area 117. The project influence area spreads over four levels to justifiably defining the safeguard boundaries. The four tiers of project influence area are (i) immediate area of impacts (footprint) (ii) direct project influence, where project is key impact factor (iii) area where direct project impact is less intensive and (iv) induced, indirect (or perceived impacts), often reputation risk. The proponent needs to identify the impact zones clearly during project location identification as the first step of environmental assessment. The baseline analysis and impacts identification should be carried out in the direct and indirect impact zones. The project area of influence should also consider all its ancillary aspects. Potential for cumulative impacts needs to be considered both in “direct� and “indirect� areas of influence. However, perceived impacts and associated potential for reputational risk need to be considered as appropriate but should not dictate the boundaries of EIA. 5.3.3 Step 2: Environmental Screening and Initial Environmental Examination (IEE) 118. The purpose of the environmental screening is to get relevant concerns addressed early on before further design of a project and to ensure that actions to mitigate environmental impacts or enhance environmental opportunities are budgeted for. The environmental screening is about taking stock in time and to avoid losing later opportunities. The participation and consultation with local communities are important to identifying the potential impacts of the project interventions. Environmental screening is part of the Initial Environment Examination (IEE). IEE is considered as the first level of assessment applied project identification and pre-feasibility stage. The IEE addresses the issues at project (sub-project) identification and pre-feasibility planning stage. The main objective at this stage is to help define the project (sub-project) in terms of locations, components and designs. Projects with potential impacts will require environmental impact assessment as per DOE act and rules. Small projects or those with little impact will not require Environmental Impact Assessment (EIA). An environmental screening matrix is attached in Annex 2. The main activities of environmental screening and IEE are to:  assess regional resources and the effects of past interventions;  examine the likely project-environment interactions;  establish an effective people’s participation program;  identify the key environmental issues and the range and potential severity of impacts;  compare the environmental consequences of project alternatives;  prepare an initial Environmental Management Plan (EMP) 5.3.4 Step 3: Environmental Impact Assessment 119. EIA will be used by the implementing agencies as a decision-making tool to ensure that the project design and implementation of activities such as construction of foundation and superstructure for silo are environmentally sound and sustainable. During the preparation phase, the objective of the EIA is to provide inputs to the feasibility study; preliminary and detailed design of the project including institutional capacity needs and barriers to be addressed. During the implementation phase, environmental management plans (developed as a part of the EIA during the preparation phase) serve 42 as a framework for strengthening the mitigation, enhancement and environmental monitoring measures and system in the food storage and silo sector. In the preparation phase, the EIA shall achieve the following objectives:  To establish the environmental baseline in the study area, and to identify any significant environmental issue;  To assess these impacts and provide for measures to address the adverse impacts by the provision of the requisite avoidance, mitigation and compensation measures;  To integrate the environmental issues in the project planning and design;  To develop appropriate management plans for implementing, monitoring and reporting of the environmental mitigation and enhancement measures suggested. 5.3.4.1 Assessment Methodology 120. The assessment of effects and identification of residual impacts takes account of any incorporated mitigation measures adopted due to any potential impact of Project activities, and will be largely dependent on the extent and duration of change, the number of people or size of the resource affected and their sensitivity to the change. Potential impacts can be both negative and positive (beneficial), and the methodology defined below will be applied to define both beneficial and adverse potential impacts. 121. The criteria for determining significance are generally specific for each environmental and social aspect but generally the magnitude of each potential impact is defined along with the sensitivity of the receptor. Generic criteria for defining magnitude and sensitivity are summarized below. 122. Magnitude: The assessment of magnitude has been undertaken in two steps. Firstly the key issues associated with the Project are categorized as beneficial or adverse. Secondly, potential impacts have been categorized as major, moderate, minor or negligible based on consideration of the parameters such as:  Duration of the potential impact;  Spatial extent of the potential impact;  Reversibility;  Likelihood; and  Legal standards and established professional criteria. 123. The magnitude of potential impacts has generally been identified according to the categories outlined in Table 5.1. Table 5-1: Parameters for Determining Magnitude Parameter Major Moderate Minor Negligible/Nil Duration of Long term Medium Term Less than project Temporary with no potential (more than 35 years) Lifespan of the lifespan detectable potential impact project impact (5 to 15 years) Spatial extent Widespread far Beyond immediate Within project Specific location within of the beyond project project boundary project component or potential boundaries components, site site boundaries with no impact boundaries or local detectable potential area impact 43 Parameter Major Moderate Minor Negligible/Nil Reversibility Potential impact is Baseline requires a Baseline returns Baseline remains of potential effectively year or so with naturally or with constant impacts permanent, requiring some interventions limited considerable to return to intervention intervention to return baseline within a few to baseline months Legal Breaches national Complies with Meets minimum Not applicable standards and standards and or limits given in national standard established international national standards limits or professional guidelines/obligation but breaches international criteria s international lender guidelines guidelines in one or more parameters Likelihood of Occurs under typical Occurs under worst Occurs under Unlikely to occur potential operating or case (negative abnormal, impacts construction potential impact) or exceptional or occurring conditions best case (positive emergency potential impact) conditions operating conditions 124. Sensitivity: The sensitivity of a receptor has been determined based on review of the population (including proximity / numbers / vulnerability) and presence of features on the site or the surrounding area. Criteria for determining sensitivity of receptors are outlined in Table 5.2. Table 5-2: Criteria for Determining Sensitivity Sensitivity Determination Definition Very High Vulnerable receptor (human or terrestrial) with little or no capacity to absorb proposed changes or minimal opportunities for mitigation. High Vulnerable receptor (human or terrestrial) with little or no capacity to absorb proposed changes or limited opportunities for mitigation. Medium Vulnerable receptor (human or terrestrial) with some capacity to absorb proposed changes or moderate opportunities for mitigation Low / Negligible Vulnerable receptor (human or terrestrial) with good capacity to absorb proposed changes or/and good opportunities for mitigation 125. Assigning Significance: Following the assessment of magnitude, the quality and sensitivity of the receiving environment or potential receptor has been determined and the significance of each potential impact established using the potential impact significance matrix shown in Table 5.3 44 Table 5-3: Assessment of Potential Negative Impact Significance Sensitivity of Receptors Magnitude of Potential Low / Very High High Medium impact Negligible Major Critical H M 0 Moderate H H M 0 Minor M M L 0 Negligible 0 0 0 0 5.3.5 Environmental Management Plan 126. The Environment Management Plan (EMP) outlines the environmental management procedures that will be implemented during the project period and also in the operation & maintenance period to minimize the negative impacts and implementation of enhancement measures. An Environmental Management Plan (EMP) should be drawn up as part of the EA at both IEE and EIA stages, to deal with follow-up activities during subsequent stages of project development: detailed design, construction, implementation, maintenance and decommissioning. The EMP should be developed with full people's participation, with the aim of achieving consensus between the EA practitioners, project design and planning engineers, local government agencies, NGOs and local communities. The main contents of an EMP are: a. Developing a Mitigation Plan b. Monitoring, Supervision and inspection Plan c. Plan for Institutional Strengthening d. Schedule e. Institutional Arrangements 5.3.5.1 Developing a Mitigation Plan 127. Once the impacts have been analyzed, their significance will be determined, i.e., whether they are acceptable, require mitigation, or are unacceptable. Subsequently, measures will be devised to mitigate anticipated environmental changes and consequential impacts during project implementation and operation, or further reduce the residual environmental changes inherent in the selected project design. They normally include technical, social, and institutional measures to be implemented as integral elements of the project. 128. The Environmental Management Plan (EMP) sets about the mitigation measures, and needs to not only include clear recommendations for action and the procedures for their implementation but must also define a program and costs. Different environmental impacts require mitigation measures and approaches. The same impact may require multiple mitigation measures and also mitigation measures of one activity can help to mitigate other activity. In designing the mitigation measures, the following factor should be taken into consideration: The feasibility of mitigation measures should be evaluated in terms of practicality, manageability and cost. Cost effective structural mitigation activities should be incorporated in the design and should be estimated and both activities and associated technical specifications will be incorporated in the bidding document. 45 129. A sample mitigation plan matrix is presented below. Table 5-4 Mitigation Plan Matrix Phase Issue Mitigating Applicable Mitigation Responsibility Schedule Measures Standard Cost (To be specified (Country, in the Bid Start End WB etc) Document) Date Date Design Construction Operation Decommissioning 5.3.5.2 Monitoring, Supervision and inspection Plan 130. Monitoring requires laboratory facilities, equipment, and technicians. As a general principle, measure only parameters necessary for managing the system, safeguarding its staff and equipment, and protecting the environment. These measures are usually set out in a plan, which covers all phases of the project from preconstruction through decommissioning, and outlines mitigation and other measures that will be undertaken to ensure compliance with environmental regulations and reduce or eliminate adverse impacts. The monitoring activities (i) measures the incremental impacts due to various project activities in the “Life cycle of the project�; (ii) analyzes the incremental impacts to find any issues of concern and takes necessary actions accordingly and (iii) keeps a record for learning, informing stakeholders, comparing for the next steps and resolving disputes. A sample monitoring and supervision plan matrix is presented below. Table 5-5Monitoring and Supervision Plan Matrix Phase Parameter Location Method of Time of Monito Responsibility Schedule s to be of the Monitorin Monitoring ring monitored parameter g Cost Start End s to be Date Date monitored Construction Operation Decommissi oning 5.3.5.3 Institutional Strengthening Plan 131. Institutional Strengthening Plan describes institutional needs to assure successful implementation of the mitigation and monitoring plans. Institutional strengthening plan identifies the need for the environmental and social specialists in the Project Implementation Unit for supervision and successful implementation, the training requirement for the EMP implementation including supervision, redesign and conflict resolution etc. 5.3.5.4 Schedule 132. Schedule establishes the links among mitigation, monitoring and institutional strengthening plan with the overall Project Implementation Plan (PIP). The contractor should provide the Environmental Action Plan (EAP) in line with the EMF, EMP and construction schedule. 46 5.3.5.5 Institutional Arrangment 133. The institutional arrangement describes the roles and responsibilities of the borrower, construction contractors, supervision consultants, stakeholders, third party monitoring and the Banks role for seamless implementation and supervision of the Environmental Management Plan. 47 6 SOCIAL MANAGEMENT & RESETTLEMENT POLICY FRAMEWORK (SMRPF) 6.1 Objectives of SMRPF 134. The SMRPF is intended to provide general policies, guidelines, and procedures to DG-Food for social inclusion and integration of required mitigation measures of possible safeguard impacts into the selection, design and construction of silos facilities in phases. The objectives of the SMRPF is to help DG-Food to achieve the following:  Enhance the social development outcomes of development of modern silos facilities at strategic locations and provide home silos to targeted families in disaster prone areas;  Identify and mitigate adverse impacts that the selected sites might cause on people (men & women), including protection against loss of livelihood activities, with culturally, socially and economically appropriate measures;  Develop necessary safeguard mitigation measures to adequately disclose and consult with affected people on draft action plans, to replace their lost assets and to improve (or at least restore) their incomes and livelihoods, and  Ensure compliance with the relevant GOB policies and those of the World Bank on social safeguards and other social issues, including those with gender implications. 135. To achieve the objectives, social management plans (SMP) will be prepared for each phase following the principles, guidelines and procedures outlined in this SMRPF and implemented before construction of civil works. The SMPs may include resettlement action plan (RAP) where private lands or public land from private uses are taken for sites. 6.2 Basic Planning Principles 136. In consideration of the potential adverse impacts associated with land acquisition and displacement of authorized and unauthorized private activities from its own (and other public) lands, DG-Food will select, design and implement all activities in accordance with the following principles: (1) Prior to selection of specific site, DG-Food will undertake community and stakeholder consultations about their objectives, scopes, and social safeguard implications, especially with respect to land acquisition and displacement of businesses, trading and other activities from its own lands (and other public lands, if they are also likely to be used by the project). Consultations will inter alia include, - All formal/informal local entities, such as Municipal Committees, Union Parishads, local women’s groups and others with direct and indirect stakes in the project who are deemed key actors to influence project design and implementation. - The persons, such as landowners, business owners, traders, embankment settlers (squatters on embankment) and the like, who would be directly affected by the project. - The persons who would be affected in terms of loss of livelihood and/or loss of access to common property resources. (2) Unless absolutely required, the project will avoid private land acquisition and limit its activities, to the extent feasible, within the existing land of DG-Food to minimize displacement of economic and other activities from private and public lands. 48 (3) DG-Food will avoid, to the extent feasible, project activities that will threaten the cultural way of life of tribal peoples; severely restrict their access to common property resources and livelihood activities; and affect places/objects of cultural and religious significance (places of worship, ancestral burial grounds, etc.). (4) DG-Food will undertake social screening of all sites to identify potential social safeguard issues, and adopt and implement impact mitigation measures consistent with the Bank’s OP 4.12. (5) Special attention will be given to female affected persons in the resettlement process and to the vulnerability of women and children in the project areas to social exclusion, trafficking, risks of HIV/AIDS infection following the policy guidelines of the World Bank on gender. (6) Special attention will be given to the vulnerable communities and destitute groups including poor, women, ethnic minorities, small and marginal farmers, and tenant contract farmers, in selection of beneficiaries and making available family silos based on needs. 6.3 Social Screening and Impact Assessment 137. DG-Food will screen each site under each phase to identify potential safeguards compliance issues and social impacts associated with the construction of silos facilities, in order to determine applicability of the OP 4.12 and the required Social Management Plan (a screening format is provided in Annex 8). Where adverse impacts cannot be avoided entirely, DG-Food will select, design and implement the project in accordance with the following guidelines: 6.3.1 Exclusion Criteria 138. To ensure that the project meets its overall objectives, and that the national legal as well as Bank’s safeguard requirements are met, the following will constitute criteria for the exclusion of silo sites from project finance:  Require involuntary land acquisition that affects private homesteads those cannot be relocated in available lands;  Affect mosques, temples, graveyards, cremation grounds, and other places/objects that are of religious and cultural significance;  May significantly restrict access to common property resources and livelihood activities of groups and communities;  Threatens cultural/traditional way of life of tribal peoples, restrict their access to common property resources (forests, water bodies, etc) and livelihood activities, and affect their places/objects of cultural and religious significance (places of worship, ancestral burial grounds, etc.). 6.3.2 Social Impact Assessment Methodology 139. Social impacts and risks including land acquisition, resettlement and other social impacts will primarily be identified during the initial social screening of silo sites. Once social impacts are noted, census of affected persons and assets will be conducted following the site boundary and where applicable land acquisition plan in compliance with the SMRPF guidelines. The affected persons and their communities will be consulted during the census survey to understand the risks and options and devising mitigation of social impacts. Land acquisition process will be initiated by DG-Food well 49 ahead of time so that assessment of social impacts and risks can be done for preparation and approval of RAPs before award of civil works contract and implementation of the same before displacement of people. The screening of social/resettlement impacts will be done using the format in Annex-8. Land acquisition proposal for respective sites will provide information on land and the census (by DG- Food) and joint verification (jointly by DC and DG-Food) will provide data on inventory of losses and risks recognized in the SMRPF. 140. Land acquisition plan will be prepared following the site boundary and the ownership of land (if not owned by the DG-Food/Ministry of Food). Land acquisition proposal for respective sites will provide information on land and the census (by DG-Food) and joint verification (jointly by DC and DG-Food) will provide data on inventory of losses and risks recognized in the SMRPF. 141. With this SMRPF in place, when sites for construction of silo facilities are determined, detailed social impact assessment (SIA) following the initial social screening, will be undertaken to identify all project beneficiaries, impacted people and other relevant stakeholders. The SIA will utilize a well-planned and all-inclusive communication and consultation strategy and survey methodology to lay out a detailed socioeconomic survey covering the prevailing status of income, employment, education, age, skills and other socioeconomic aspects along with cultural and community aspects in the areas. The following methodology may be adopted. (a) The SIA will be carried out for the first phase and subsequent works packages in accordance with the civil works time table. (b) Community/stakeholder consultations at locations with habitations and documentation of such consultation. (c) Focus group discussions with beneficiaries, key affected persons and their community. (d) Census and socioeconomic survey among the project affected households. (e) Assimilation and analysis of data and information to address key issues following SMRPF. (f) The information gathered shall be recorded on strip maps and computerized, and photography/ video-graph will be used to document existing structures and land holding and other impacts in the corridor of impact. (g) Update the final alignment on the Mauza maps and finalize the land acquisition plans. (h) All data will be disaggregated by gender, age and ethnicity where necessary. A gender analysis will also be undertaken. 142. Deputy Commissioner at respective districts, where a site will involve land acquisition, will process land acquisition on behalf of DG-Food under the provision of the ARIPO 1982 and make payment of compensation under law to legalize land acquisition. However, DG-Food will make additional payment where needed to ensure replacement cost of land and other property acquired for any silo site following the provision of RAP prepared in compliance with this SMRPF. 6.4 Social Management and Resettlement Policy 6.4.1 Social Inclusion and Equity Management 143. The project includes provision of household silo bins for grain/seed storage at family level to meet emergencies and needs at post disaster situations in the surge-prone areas of the coastal zone in the country. The project would make this Silo bins available at a discounted price to households in the 50 coastal zone including landless, small and marginal farmers, socially excluded groups, and religious and ethnic minorities. The project is expected to ensure their food security, nutritional status and general welfare through improved storage and safe stock of food grains and seeds to withstand the shock of disasters. It was understood at the community consultation meeting that farmers preserve own seeds and also purchase seeds from the neighboring farmers at low cost. Cost of farm inputs will be higher when they are forced to purchase imported seeds due to disaster or any other form of calamities. 144. All the poor and vulnerable families will be in the need of food grain stock and those having farm lands under their cultivation will need safe stock of seeds during disaster. The DG Food will contract in local NGOs for selection of beneficiaries of household silo bins. The NGOs will adopt all inclusive consultative process in carrying out surveys for identification of target group beneficiaries as per selection criteria given by the DG Food in agreement with communities. The selection procedure will first screen out those who are economically able to have safe grain/seed storage against shocks of disasters like cyclonic surges. The remaining households in the selected coastal villages will be classified into various groups for ethnicity, gender and age of household heads, farm size (own and rented in), storage needs for food grain and seeds and ability and willingness to pay the reduced price of silo bins. 145. DG Food will develop a strategy for distribution of the household silo bins in consultation with the target communities, local public administration and local government institutions. The contracted NGO will assist DG Food in development of inclusive distribution strategy. The selection criteria will be finalized through discussion with the beneficiary communities to avoid elite capture and exclusion of households with potential needs and willingness to pay. DG-Food will share the strategy with the Bank for review and concurrence before distribution of the household silo bins. 6.4.2 Resettlement Policy Guidelines 146. The ARIPO 1982 is not adequate to deal with the adverse impacts associated with land acquisition and involuntary displacement in compliance with the Bank's OP 4.12 on Involuntary Resettlement. The Ordinance has no provisions for resettlement of the affected households/businesses or any assistance for restoration of livelihoods of the affected persons. Land acquisition, therefore potentially diminishes productive base of affected farm families and infringe impoverishment risks to those physically or economically displaced due to undertaking of infrastructure projects. As the legal framework falls short of the provisions of the World Bank OP 4.12 on Involuntary Resettlement, the project will apply the following added mechanisms to meet the Bank's requirements:  Avoid or minimize resettlement: The law only implicitly discourages unnecessary acquisition, as lands acquired for one purpose cannot be used for a different purpose. However, there are no mechanisms to monitor if this condition is actually adhered to.  Eligibility for compensation: The law stipulates compensation only for the persons who appear in the land administration records as the owners. It does not recognize the rights of those, such as squatters, who do not possess legal title to the lands they live in or make a living from.  Compensation: The law provides compensation for lands and other objects built and grown on them (structures, trees and orchards, crops and any other developments like ponds, built amenities, etc.). No provisions are there to assess and restore lost income stream or income 51 sources that acquisition causes to the affected persons, be they legal titleholders or others like squatters, tenants and employees of affected businesses.  Compensation standards: Although the law stipulates 'market prices' of the acquired lands as the just compensation, the legal assessment method almost always results in prices that are far below the actual market prices9. Certain pricing standards, which are regarded as unrealistic, are used to assess other losses like structures and various built amenities, trees, crops and the like.  Relocation of households and other establishments: No legal obligation is there to relocate, or assist with relocation of, those whose homesteads have been acquired or whose place of residence or livelihoods has been affected. Such persons/households, be they titleholders or squatters, are left on their own.  Ensuring payment of compensation: Lands are legally acquired and handed over to the project execution agency as soon as the acquisition authority identifies the owners (or 'awardees'), by examining the records, and sends a legal notice advising them to claim the compensation (or 'awards'). It is the obligation of the affected landowners to prove, by producing an array of documents that the acquired lands legally belong to them. As gathering these documents is a long, expensive and cumbersome process, many landowners may remain unable to claim their awards10.  Socioeconomic rehabilitation: The law shows no concern whatsoever about the long-term socioeconomic changes the affected persons and households might undergo in the post- acquisition period. There is no provision in the law except compensation for ensure economic rehabilitation and social reintegration of the displaced persons. 6.5 Eligibility and Entitlements Policy 147. Under project resettlement policy framework, the affected persons and groups eligible for compensation and assistance will include: (i) owners with legal titles/agreements to the affected lands and other properties (tenants, share-croppers); (ii) squatters/encroachers 11 and others using public/khas lands; (iii) sponsors/beneficiaries of development programs using public/khas lands (e.g., social/community forestation and other land-based income generation programs for socioeconomically vulnerable groups); (iv) persons with usufruct rights; and (v) communities/groups where impacts are community-wide. Eligibility of project affected persons for compensation and assistance recognized under the project include the following: 9 According to the law, the 'market price' is calculated by averaging the sales prices recorded in the previousone year, in terms of land characteristics by land administration units or mauzas. But it is a widely acceptedfact that prices determined as such hardly reflect the true market value of the lands. As the sale/acquisitionprices are grossly under-reported to evade on sale taxes, assessment of legal compensation almost always fallfar too short of the real market prices. 10 In the present land administration system, which is widely accepted as antiquated, land transactions, especially in the rural areas, often remain incomplete. Even after the sale/purchase deeds are legally executed, the sellers continue to remain as owners in the legal records until mutations are completed. As the transaction process is cumbersome and involves costs beyond those mandated by the law, and the practice that lands can be used with the deeds alone, most land transactions do not follow the process beyond deed execution. Many land purchasers are even not aware of the mutation or its significance. 11 Household or person occupying public lands without legal arrangements with the GoB or any of its concerned agencies is a squatter to the lands. Households/persons those displaced by riverbank erosion, cyclones or landlessness squat embankment slopes for residential, commercial and community purposes. In this project, many embankment squatters have their own land elsewhere inside the polder but they took refuge on the embankment during a natural disaster. Squatters having land of their own attached to the public land/embankment or elsewhere are defined as encroacher. 52 a) Compensation for the acquired private lands, which includes homesteads, agricultural and other lands, including ponds and similar developments, will be paid at 'replacement costs' to be determined through market surveys. b) All affected non-land properties, such as houses and other structures, trees, seasonal and perennial crops, orchards and other immovable items of value will be compensated at replacement costs at the time of dispossession. c) Eligibility for compensation and assistance will be governed by Cut-Off Dates. These are the dates on which census of the affected persons and their assets will be taken. Assets such as houses/structures and others which are created, and the persons or groups claiming to be affected, after the cut-off dates will be ineligible for compensation. d) Where acquisition causes displacement from homesteads where the affected persons may or may not have title to the land, the project will encourage, compensate for and assist with self- relocation. Where self-relocation is infeasible, the project will arrange for lands to relocate to, and provide for basic social and physical infrastructure. e) Where project interventions cause to displace squatters on the executing agency’s own land (DG - Food’s land), compensation will be provide for any physical assets (structure, trees, crops, & perennials) on the land owned by them. f) Assets like equipment, machinery and parts/components thereof which can be dismantled and moved away, will not be eligible for compensation. But the owners will be paid a reasonable amount to cover the dismantling and moving costs. g) Owners of the affected businesses will be compensated for temporary loss of income for a reasonable period of time. However, if a business, which is recorded in the census, closes down or moves away for reasons unrelated to the project, it will not be eligible for this compensation. h) Employees of the affected businesses will be compensated for temporary loss of income for a reasonable period of time. However, an employee, who is recorded in the census to be employed with a business, will not be eligible for this compensation if (i) the person leaves the business because of personal reasons, or (ii) if the employee is a minor member of the business owner's household and helps him/her on a part-time basis, or (iii) the business closes down or moves away for reasons unrelated to the project. i) Compensations/entitlements due to the PAPs will be paid in full before they are evicted from the acquired private and public lands. j) The project will identify and implement policies to mitigate any adverse impacts that are unique to the project and have so far remained unknown. 148. The eligibility and entitlement matrixes under the provisions of national law (ARIPO 1982) and the Bank policy on Involuntary Resettlement (OP 4.12) are given at Annex-9. 6.6 Preparation of SMP/RAP 149. The results of the census, socioeconomic survey and community consultation will be decisive element in selection of the design, size and location of the sites. Once the sites are selected and boundaries finalized, inventory of assets and PAP census will be carried out to identify the impacts for 53 mitigation measures in line with the SMRPF. Resettlement Action Plan (RAP) will be prepared for each phase having any site requiring land acquisition and/or population displacement using the data from the SIA and consultation with PAPs and all other relevant stakeholders. In case the sites for silos facilities under a phase of civil works construction affect less than 200 people an abbreviated RAP may be prepared. Contents of a RAP or an Abbreviated RAP will include the following: Contents of RAP  Brief description of the improvement and rehabilitation works undertaken on the individual site (or contract in cases of multiple contracts) with location of major impact spots, .;  Results of census survey and summary of impact details (PAP/household level raw data will be computerized to prepare the entitlement files);  An account of the alternatives considered to avoid and/or minimize the adverse impacts;  An account of the consultations with the affected persons/households about the mitigation measures and implementation procedure;  Specific compensation rates and standard of entitlements and entitled persons/households for different types of losses as per the principles and guidelines adopted in this SMRPF;  An account of impacts by gender and vulnerability due to site development and construction of silo facilities in each phase and the special assistance that is to be provided;  Description of resettlement sites and programs for improvement or restoration of livelihoods and standards of living;  Grievance redress mechanism;  Resettlement budget with breakdowns by loss categories and the number of persons entitled to compensation/assistance, and a RAP implementation schedule; and  Monitoring and evaluation. Contents of abbreviated RAP  Documentation of the private and public lands, including DG-Food’s own, required for the civil works in each phase, a census survey of affected persons, and valuation of the affected assets;  Description of compensation and other resettlement assistance that will be provided according to the principles and guidelines adopted in this SMRPF;  An account of the consultations with the displaced persons/households about acceptable alternatives;  Grievance redress mechanism;  A resettlement budget with breakdowns by loss categories and the number of persons entitled to compensation/assistance, and an Abbreviated RAP implementation schedule;  Monitoring and evaluation. 150. DG-Food will prepare and submit to the Bank for safeguards review, clearance and public disclosure of SIA including RAP for each phase of civil works program. A social screening report will be prepared for all specific sites based on the SMRPF. All project’ SIA and RAP will be disclosed locally and in Bank InfoShop in due course for finalization of the documents before award of civil works contracts. 54 6.7 SMP Implementation and Monitoring Arrangement 151. The Project Management Unit (PMU) in DG-Food’s office will include a Senior Social Specialist and Senior Communication Specialist for community engagement, social screening of silo sites and preparation and implementation of social management plans. The Project Director, with assistance from the Senior Social Specialist, will carry out the following specific tasks related to land acquisition and resettlement, where applicable: (i) liaison with district administration to support land acquisition; (ii) day-to-day management, supervision, monitoring of resettlement work; (iii) ensure timely availability of budget for all activities; (iv) synchronize resettlement activity and handover land as per the construction schedule; (v) initiate to form necessary participatory bodies including Property Assessment and Valuation Committee (PAVC) for assessment and valuation of affected assets. A grievance redress mechanism (GRM) will be available for the communities and affected persons to address their complaints related to resettlement and quality of construction and provide suggestions on implementation (as described in section 9.8). 152. The first phase construction will not involve any land acquisition or population displacement. Given that there is likelihood of land acquisition and population displacement in some of the sites for construction of silos facilities in subsequent project phases, DG-Food has kept a provision for land acquisition, resettlement and other social mitigation measures for the project. An estimated amount BDT 172.40 million has been proposed for land acquisition and resettlement measures and implementation of SMPs including any RAP. All funds for land acquisition, resettlement and social actions will be provided from counterpart financing from the Government of Bangladesh. 153. The local level staff of DG-Food will be provided with capacity building training on social safeguards compliance as per Bank policy on Involuntary Resettlement (OP 4.12). 154. The PMU, DG-Food will carry out monitoring of community engagement, social impact assessment, land acquisition (if any), and preparation and implementation of any RAP with assistance from the Senior Social Specialist and the local level staff. The activities on social management will be included in the project progress reports, will be reviewed under third party monitoring also at periodic Bank missions. 55 SECTION C: ENVIRONMENTAL AND SOCIAL ASSESSMENT (ESA) 56 7 BASELINE STUDY OF THE PROPOSED SITE 7.1 Project Locations and Sites 155. Locating the storage and logistics is extremely important to minimize cost, causing minimum environmental disturbance, losses, to reach target beneficiaries and to ensure effective and timely distribution. Use of food stocks in the case of emergencies and disasters would require that distribution can be done promptly, leaving more time available for transporting or for restocking. In order to locate the public silos at the best location considering, logistics, availability of rice, distribution and constructability, etc., several sites were examined all over Bangladesh. Out of these sites detailed site analysis was carried out in the 8 potential sites listed in Table 7.1. The locations of the possible sites are shown in Figure 7.1. Table 7-1 Potential Sites for Modern Silo Facilities No. Site Bin Size (Feet) Number of Capacity Bins (Tons) 1. Barisal 60 D X 40 H 16 50,000 2. Narayanganj Central Supply Depot (CSD) 60 D X 40 H 16 50,000 3. Dhaka CSD 60 D X 40 H 19 57,000 4. Ashuganj 60 D X 40 H 33 100,000 5. Mymensingh 60 D X 40 H 16 50,000 6. Maheshwar Pasha (Wheat) 90 D X 78 H 6 76,200 7. Chittagong (Wheat) 90 D X 78 H 9 114,300 8. Madhupur 60 D X 40 H 24 72,000 Sub-Total 139 569,500 Source: Draft Feasibility Report, BMFSP, September 2012 156. About 569,500 tons of modern grains storage capacity would be constructed on 8 sites under the first phase. Two sites are expected to be for wheat storage or paddy storage-- Maheshwar Pasha and Chittagong-- and the remaining six would be for milled rice. 157. Annex 3,1 to 3.8 presents the environmental screening checklist. 57 Figure 7-1 Map Showing Possible Silo Locations 58 7.2 Environmental Aspect of Barisal CSD Campus Silo Site 7.2.1 Site Description 158. The proposed Barisal CSD Campus Silo Site belongs to the Barisal Division of Bangladesh, constituting the south central coastal area of the country. The location of the Barisal CSD is well known as “Tris Godown� for having its 30 go-downs in it. It is about 2 km away from the city center near the Barisal Medical College and attached to the Armed Police Battalion Center. The site is located at a distance of about 300 km from Dhaka in the city corporation area of Barisal City. The CSD area is situated in tidal (high & low tide) area but it is free from usual flood or high tide level. The whole CSD area is surrounded by private land owners housing in the southern side, government offices (e.g. Bangladesh police) on the northern side, the Kittonkhola River on the eastern side and South Alekhanda road on the western side. The total CSD area is divided into two parts, one is surrounded by a boundary wall and the remaining part is an open land constituted mostly by a water- filled low lying area and a connecting road. A Martyr monument is also situated near the bank of Krintonkhola adjacent to the CSD jetty. A freedom-fighter’s grave is also situated along the road leading towards the river. The site location is shown is Figure 7.2. Figure 7-2 Location of Barisal CSD Site 7.2.2 Physiography, Geology& Topography 159. The subproject area falls within active Ganges Flood Plain area of southern region of Bangladesh. The CSD site having a total area of 10.55 hectares (26.08 acres) was acquired by the 59 Government for use by the CSD in three installments in 1961, 1962 and 1963. Out of the total land, about 13 acre is surrounded by a protection wall and the remaining land of about 5.29 hectares (13.08 acre) consisting of the connecting road (0.11 hectares) between the surrounded place and the river and a shallow marshy land ( in total 3.78 hectares/ 9.34 acre) and other marginal lands. The location of the site is at the coordinate of N22°40΄50΄΄ and E90°21΄41΄΄. The pontoon of the CSD is very close to the place. This rectangular open area is targeted to be used as the construction of Food Grain Silo. The soil of proposed site was found to be alluvial in nature. 160. The natural drainage pattern is from the low-lying/ditch land towards the Kittonkhola River within the CSD premise area, which is connected to a concrete pipe. The overall topography is flat in the sub-project area. 161. The marshy land at the proposed site was created as a result of taking off soil from the area for different uses inside the surrounded go-down area. When water penetrates from the river during the high tide to this land through a concrete drain, it looks like a pond; but it is not pond from any technical aspect. At least 0.3m depth of water always logged at that area (about 120m X 180m). This particular area may have been designated for construction of a modern steel silo storage facility with for long term storage of food grains. 7.2.3 Existing Structure 162. The existing CSD campus has a total of 28 go-downs for food grain storage. The two salt go- downs are in a dilapidated condition. Beside this, the campus has an office building, managers’ quarter, 8 other residential quarters for officials and staff members, 6 guard sheds, one barrack, one garage, one pump house and one mosque. Table 7-2Summary of Barisal CSD CSD area 10.55 hectares 26.08 acres Covered with go-downs 5.3 hectares 13.08 acres Inside boundary walls Open area (contiguous) 5.26 hectares 13.0 acres Contiguous area 3.78 hectares 9.34 acres Existing Structures Total Godowns 28 7 recently repaired Storage capacity 22,700 tons Residential units 9 7.2.4 Transportation Link 163. There are interior roads and also a link road (6m width) from the Kittonkhola River up to the entry of the surrounded campus. At the river bank, there are two jetties (one big and one small) and one pontoon owned by the BIWTA. 164. The lane width (one way-two lanes) of the road outside of the CSD that connects the highway is 4.9 m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike and 60 bicycle. An initial traffic survey was carried out at this road in the daytime of the weekday. The identified peak rate of traffic flow was 196 vehicles/hour, where 14% of them are trucks. The example of traffic data from this survey is presented in the Annex 2.1 7.2.5 Utility (Power, Water & Gas) Supply at the Site 165. The sources of power supply are western zone electric power supply. 11KV transformer was seen at gate of Barisal CSD which is 500’-0� away from the proposed site. Frequent power cuts have been a continuous problem for the CSD. City corporation water supply is available for the existing CSD & staff Quarter & no gas supply at CSD. 7.2.6 Status of Food Production in Barisal 166. The Division is comparatively a new one, created by dividing former Khulna Division in to Khulna and Barisal Divisions. The Division is subdivided into 06 districts (zilas) and thence into 39 upazila (sub-districts) level administrative areas are 353 Union Parishad (Union Council). At the bottom level, there are 4,273 villages. The Division has an estimated population of 8,147,000 as per 2011 Population Census. Barisal Division’s population has increased by only 9% in the last 20 years compared to 34% overall population growth for Bangladesh in the same period. This low rate of growth has much to do with the abandonment of rice farming in many areas due to soil Salinization, and continued outward migration to Dhaka, other large cities and abroad for employment opportunities. Rice 167. Rice production is at around 2 million tons per year for the last five years. Salinization is an issue in Barishal. However, these production losses have been offset to some extent by introduction of new varieties that have increased yields on the remaining land. If there is continued success with development of new varieties, particularly those resistant to saline soils and flooding, Barisal has the potential to regain its status as a zone of surplus production. Table 7-3 Barisal Division - Paddy Rice Production (MT) Crop Year Boro Aman Total 2007-08 489,754 1,421,891 1,911,645 2008-09 573,693 1,457,809 2,031,502 2009-10 607,458 1,452,600 2,060,058 2010-11 581,554 1,591,387 2,172,941 2011-12 597,390 1,375,908 1,973,298 Source: Regional Controller of Food, Barisal Rice milling 168. There are now 42 rice mills in Barisal Division according to the DGF Divisional Controller. Of these the Food Department contracts with 18 for the milling of paddy which it buys locally. There are 11 husking mills and 9 semi-automated mills in the district according to a Food Department Report 2006. Wheat milling 169. There are four wheat flour mills in Barisal city. These are the only wheat mills in the entire division. All four mills produce atta flour for the Food Department. Flour is distributed by FD only in Barisal city. 61 7.2.7 Seismicity 170. Bangladesh itself is divided into three seismic zones, based on the ranges of the seismic coefficient. The seismic coefficient is a measure of how strong an earthquake has the potential to be based on a combination of the mass of the plate and the seismic forces acting on it, as well as how frequently these quakes are likely to occur. Zone 3 is in the most seismically active area with a seismic coefficient on 0.25, and Zone 1 is the least active with a significantly lower seismic coefficient of 0.075. The subproject area, Barisal CSD, is located in Zone 1, the least vulnerable to earthquake disaster. 7.2.8 Hydrology and drainage 171. Water usually accumulates up to 0.5m (average) in the low land area/ditch during monsoon. The location of the proposed silo is situated in the tidal zone but tidal water is 0.3m below the bank of the river. Existing CSD food grain storage facilities have 28 godowns which are well protected from flood and constructed on high land (sand fill). The new proposed silo construction site is mainly on ditch land and connected with natural drainage system by CC pipe drain. Therefore, when tidy water enters from the river to the ditch land, fish and flora species migrate to the site from the river through this connectivity and moves with the flow of tidal water. The groundwater depth is 0.5 m below the existing ground. 172. There is no sewerage and drainage system. Natural drainage system was found. 7.2.9 Air quality 173. 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 main sources of air pollutant emissions are the dust from food grains while handling, limited number of heavy trucks that carry food grains in the CSD. Air quality was measured under this project. The samples were collected at the boundary of the north and south side of the site. The present condition of the air quality is presented in Table 7.4. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-4 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 09/12/12 North end 8 hours 265 675 27 38 09/12/12 South end 8 hours 235 625 35 44 Bangladesh Standard for Industrial & Mixed 500 5000 120 100 7.2.10 Water quality of the nearby river 174. The CSD area is located near the bank of Kittankhola River and in order to test the quality of the water of the river, water samples were collected from one sampling points in the Kittankhola River near the proposed site. The present situation of the water quality is presented in the following Table. The samples were collected on 09 December, 2012 Table 7-5 Water Quality Monitoring Data 62 Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 22.3 20-30 Ok Turbidity NTU 10 <10 Not ok Color TCU 18 <15 Not ok pH -- 6.8 6.5-8.5 Ok TDS mg/l 650 <1000 Ok DO mg/l 7.2 >5 Ok BOD mg/l 3.2 <6 Ok Fe mg/l 0.2 0.3-1 Ok Zn mg/l 2.5 5 Ok Al mg/l 0.1 0.2 Ok 7.2.11 Noise quality 175. Noise pollution in the subproject area occurs mainly from the movement of heavy trucks/vehicles that carry food grains to and from the CSD. It is found from the initial screening that the place is very calm. The construction work may create noise pollution. For the baseline environmental data, noise levels were measured at the center of the sub project area which is presented at the following Table 7.5. Table 7-6 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 45 42 9:30 am 48 44 10:00 am 42 40 10:30 am 48 45 09/12/12 Centre of the CSD 11:00 am 40 36 11:30 am 38 34 1:00 pm 35 32 1:30 pm 38 34 2:00 pm 32 30 2:30 pm 36 32 3:00 pm 38 36 3:30 pm 35 32 Bangladesh standard: 70dBA 7.2.12 Monument/Memorial Structure 176. During the 1971 Liberation War the occupation army and their local collaborators made their camp in this campus. They reportedly killed here many such people here, in memory of whom a monument was constructed by the Government at one side of the river bank. Since operations of the CSD, particularly by river transport are currently minimal; many unauthorized people loiter here neglecting the sign indicating the place as a restricted area. Recently, the Barisal City Corporation has constructed a road across the unused CSD land, outside the boundary wall. This road is used publicly. The monument is shown below: 63 Figure 7-3 Martyr Monument 7.2.13 Terrestrial ecology 177. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the CSD premise and in open spaces. The tree species within the CSD area include: banana (Musa sapientum), mahogany (Swieteniamahogoni), banyan tree (F. religiosa), coconut (Cosos nucifera), betel nut (Areca catechu), jackfruit (Artocarpus heterophyllus) etc. Natural vegetations occurring in the subproject site areas include: grasses (Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). In total, there are 100 of the above tree species can be found in this sub- project area but due to construction of silos, 69 trees including mahogany will be affected directly. 178. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, dove, cuckoo, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.2.14 Fisheries 179. The ditch situated in the sub-project area may have some wild fish like puti, tengra, carp, koi, taki, bain etc. Since this ditch is connected with a concrete pipe with the Kittonkhola River to facilitate drainage of the CSD premise, the fish always move in and out from the river with the tidal flow. 64 7.2.15 Cyclones and flooding 180. Barisal Division constitutes the Middle Coastal Zone of the country and along with the other coastal zones is highly vulnerable to cyclones originating in the Bay of Bengal during the months either preceding or following the summer monsoons. Since 1960 about 28 events categorized by the Bangladesh Meteorological Department as either “severe cyclonic storm� or “cyclonic storm� have occurred. 181. On November 15, 2007 the Khulna – Barisal coastal area was struck by SIDR, a “severe cyclonic storm with core of hurricane winds�. Atmospheric pressure was recorded at 942 mbs. The highest windspeed was 223 km per hour. The tidal surge reached 5m to 7m (15 ft – 20 ft). Loss of life from this event is reported at 3447, and the livelihoods of millions of people were affected. 182. In late May 2009 Cyclone Ayla, also category 1, struck the same coastal zone bringing another storm surge of 7 m (20 feet). While loss of life was not high, press reports indicated that 2 million to 3 million persons were affected. 183. The site is not affected by flood water. The proposed site is located on the western bank of the river kirtthan khola. The highest tidal water level is 1ft below the top of the river bank. 65 7.3 Environmental Aspect of Narayanganj CSD Campus Silo Site 7.3.1 Site Description 184. The proposed Narayangong CSD Campus Silo site administratively belongs to Dhaka Division of Bangladesh. It stands on the bank of Shitalakhya River connected to the Meghna and the Padma River. The river port of Narayanganj is one of the oldest in Bangladesh. It is also a center of business and industry, especially the jute trade and processing plants, and the textile sector of the country. Narayanganj District is bounded by Gazipur and Narsingdi Districts on the north, Brahmanbaria and Comilla Districts on the east, Munshiganj District on the south, and Dhaka District on the west. Geologically, the area lies on the edge of the Madhupur Tract and Holocene floodplain deposits from the aquifer. The total area of the district is 759.57 km², of which 48.56 km² is reverie and 0.60 km² is under forest. The district lies between 23°33´and 23°57´ north latitude and between 90°26´ and 90°45´ east longitude. The population of the District is 2.9million with density of 3,80012 per sqkm. The site location is shown in the figure below. Figure 7-4 Location of Narayanganj CSD Site 185. The city of Narayanganj has a population of 1.5 million and is located some twenty kilometers southeast of Dhaka, on the flat Ganges Delta and alluvial plain. The Shitalakshya River divides the town into two parts, the Narayanganj Municipal Area and Kadam Rasul Municipal Area. Our CSD lies in Kadam Rasul Municipal Area, on the other side of the river. 12 Source: Wikipedia, Narayanganj 66 7.3.2 Physiography, Geology& Topography 186. The subproject area located at the edge of the Madhupur tract at the bank of the Shitalakkha River. The Soil condition of the proposed site is clayey in nature. The total CSD area is about 17.1 acre land falls under mostly flat and ditch land. There is no agricultural land or forest area in its premise. A large area is located outside the boundary wall of the CSD, which was constructed basically as a flood protection wall. There are two ponds inside the campus and a big ditch outside the boundary wall. All other areas, excepting some by the side of the river bank are raised land. There is a big vacant area outside the protection wall and between the wall and the river bank. 187. The road from the jetty passed through the middle of this vacant land. The land to the left side of the divider road (about 100 meterx100 meter) road is completely vacant and currently used as a play ground. The land to the right side has some trees primarily planted to continue the possession of the CSD authority. The whole combined land, adjacent to the river bank may be used for constructing a rice silo and other facilities for long term storage. 188. The subproject location is situated at the north-east side of kalirbazar, kadam Rasolpur; west side is Shitalakkha River. The natural drainage pattern is from the CSD premise area towards the Shitalakhha River through soils. The soil condition of the proposed site is clay in nature. The overall topography is rather flat in the whole sub-project area. 7.3.3 Existing Structure 189. Out of the 17.1 acre of the total CSD campus area, less than a half (about 6.0 acre to the eastern side is surrounded by the food storage facilities and the ancillary structures. The remaining area (about 11.1 acre) is vacant and outside the boundary wall. Out of the vacant area about one third is a ditch and rest is a filled in plain surface high land above the flood level. This area is recommended for construction of the steel silo for storage of 50,000 mt rice. 190. The whole CSD area is surrounded by private land and structures on north and south sides The Madanpur-Madangonj road passes by the eastern side of the CASD campus and the river Sitalakhya flows by the western side of the campus. 191. The existing CSD campus has a total of 35 go-downs for food grain storage. Of those 18 godowns are usable. The campus has two apartment buildings of 48 units in total, two houses for management staff, a mosque and a guardroom. The summary of Narayanganj CSD area is presented in Table 7.7 Table 7-7 Summary of Narayanganj CSD CSD area 17.0966 acres Divided in to two parts Covered with go-downs About 6.00 acres Inside boundary walls Open area (contiguous) About 11.1 acres Outside boundary walls Contiguous area About 1.0 acres Ditch area- to be developed Existing Structures Total Godowns 35 18 are now usable Total godowns 20,630 mt (of all 35 17 godowns are not usable any godowns) more. Storage capacity 9,000 mt now Many unusable ones are currently in dilapidated 67 condition and under a process of demolision Useable capacity 48 units in 02 Two more houses for apartment buildings management staff Residential units Mosque, guard The ditch land remains rooms, Jetty at the unprotected without effective river bank demarcation lines. 7.3.4 Transportation Link 192. Interior roads: A public road runs from the north-south towards the river bank in the CSD’s own land at the right lane. But this was separated by a wall for the CSD campus. But it goes up to the half way. For construction of the new silo in the vacant land, the wall will have to be extended up to the river bank. Another walk way is there from the Jetty of the CSD to the CSD exit way, but it is a way only for the CSD Staff including workers who carry the food grains to the godowns or godown to the jetty. 193. River: The Narayangonj CSD Campus site is well facilitated for river transport. There is a medium size Jetty and a pontoon owned by the CSD on the river bank. In addition there are two more approach ghats by the two sides of the jetty for use by the small river transports. There are many industries like cement factory, oil refinery, salt refinery, etc in upstream of the river. Small and medium lighters/barges up to the capacity of 2000 mt are found in using the river all the seasons. 194. Rail: Previously there was a railway connection with Narayangonj from Norshingdi and from there to Chittagong/Dhaka. This was extended up to the CSD campus for food grain transportation. Finding the rail link uneconomic, the authority uprooted the rail connection and transformed it into road. 195. Road The existing roads are not very much in good road condition to the site. The roads pass through highly densely populated areas. However, there is no restrictions on movements of trucks from or to outside road network. 196. The lane width of the road outside of the CSD that connects the branch of Dhaka-Chittagong highway is 4.5 m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike and bicycle. An initial traffic survey was carried out at this road in the daytime of the weekday, when the traffic volume was expected to be high. The identified peak rate of traffic flow was 224 vehicles/hour, where 10% of them are trucks. The example of traffic data from this survey is presented in the Annex 4. 7.3.5 Utility (Power, Gas, Water) Supply at the Site 197. The power supply to the Narayanganj CSD is ensured through the national grid under the Power Development Board with 440V, 3 phase, 50Hz overhead line. Frequent power cuts have been a continuous problem for the CSD. Gas line is available there. Deep tube-well is the sources of water supply for CSD’s staff. 7.3.6 Status of Food Supply in Narayanganj Rice supply and distribution 198. The sources of rice supply for distribution was the local procurement particularly from the middle and northern districts of the Division and trans-loaded at Baghabari ghat in barges for delivery to Narayangonj silo and other storage facilities. In addition, rice import from outside countries is supplied through the food storage facilities (including Narayangonj silo, Dhaka and Narayangonj 68 CSDs) in the Division. These facilities together with other CSDs and LSDs distributed the rice for use under monetized schemes including essential priorities (e.g. Army, police, RAB, Ansar-VDP), other priorities (e.g. fire service, prisoners and Open Market Sale – OMS for price stabilization) and non- monitized schemes under varied food safety programmes like Vulnerable Group Feeding (VGF), Vulnerable Group Development (VGD), Test Relief , Food for Works FFW), etc Rice milling 199. Dhaka and North zone is one of them that has about 1500 (37%) rice mills. Narayangonj district that includes one of the probable steel silo site area, is included in this zone. For local procurement of rice by the Food Department (FD) offices, required number of rice mills are engaged on competitive basis for milling paddy for producing rice and supply it to the relevant FD office. The same practice is also being followed in Narayangonj district. Mir Kadim is a hub of more than 200 big and medium size rice mills in the nearby Munshigonj district, just on the other side of the proposed steel silo site in the Narayangonj CSD campus. Wheat Milling 200. Narayanganj is also a hub of about 100 big and small flour mills. In the absence of operation of FD’s own mill, out of the private sector mills, 285 have been enlisted with the FD for wheat milling. Required number of enlisted mills is selected on competitive basis for producing the atta for the FD in lieu of wheat allocated to them. The mills in and around the city of wheat allocation gives back to the FD 77 % of the allocated wheat as atta and the mills located outside this area gives back 70% as atta (because of higher transport cost). 7.3.7 Seismicity 201. Narayanganj CSD, is located in Zone 2 is the medium vulnerable to earthquake disaster. 7.3.8 Hydrology and drainage 202. Water usually accumulates in the ponds inside the compound and natural flow towards the river. Existing CSD food grain storage facilities are well protected from flood and constructed on paved high land. Deep tube-well is the sources of water supply for CSD’s staff. The groundwater depth is 0.5m below the existing ground level. 203. Soak well & septic tank is used as sewerage system natural slope are working as drainage system. 7.3.9 Air quality 204. 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 samples collection points are located at the ¼ th and ¾ th crossed points of the centerlines of the proposed site. The present condition of the air quality is presented in Table 7.8. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-8 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 05/12/12 ¼ th CL 8 hours 185 380 21 36 69 05/12/12 ¾ th CL 8 hours 172 355 24 41 Bangladesh Standard for Industrial 500 5000 120 100 and Mixed 7.3.10 Water quality of the nearby river 205. The CSD area is located near the bank of Shitalakhya River and in order to test the quality of the water of the river, water samples were collected from one sampling points in the Shitalakhya River near the proposed site. The present situation of the water quality is presented in the following Table. The samples were collected on 05 December, 2012 Table 7-9 Water Quality Monitoring Data Parameter Unit Test value of the Bangladesh Remark Temperature °C 25 sample 20-30 Standard Ok Turbidity NTU 26 <10 Not ok Color TCU 24 <15 Not ok pH -- 7.1 6.5-8.5 Ok TDS mg/l 1750 <1000 Not ok DO mg/l 6.5 >5 Ok BOD mg/l 4.8 <6 Ok Fe mg/l 0.2 0.3-1 Ok Zn mg/l 2.5 5 Ok Al mg/l 0.1 0.2 Ok 7.3.11 Noise quality 206. Noise pollution in the subproject area occurs mainly from the movement of heavy trucks/vehicles that carry food grains to and from the CSD. The construction work may create noise pollution. For the baseline environmental data, noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-10 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 21 28 9:30 am 24 26 10:00 am 35 37 10:30 am 26 32 11:00 am 35 38 11:30 am 38 42 1:00 pm 45 45 06/12/12 Centre of the area 1:30 pm 36 40 2:00 pm 28 35 2:30 pm 26 28 3:00 pm 35 38 3:30 pm 26 30 70 Bangladesh standard: 70dBA 7.3.12 Terrestrial ecology 207. The tree species within the CSD area include: banana ( Musa sapientum), mahogany (Swieteniamahogoni), mango tree (M. indica) etc. Natural vegetations occurring in the subproject site areas include: grasses (Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). In total, there are 100 of the above species can be found in this sub-project area but due to constructing silos at the open land, very few trees may be affected directly. 208. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, doel, shalik, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.3.13 Fisheries 209. The ponds situated in the sub-project area should have some natural fishes like puti, tengra, boal, carp, koi, taki, bain etc. But, these ponds are located near the existing residential area and are expected not to be affected, if the silos are constructed in the designated open field and inside the boundary CSD premise. 7.3.14 Cyclones and flooding 210. Dhaka Division constitutes the northern high land, haors and rivers in the eastern side and riverine south west flood prone areas covering several districts. The rivers, their erosion, seasonal cyclones damage the assets, property and crops creating sufferings of the rural people pushing them down to the poverty line. Severe cyclones or tornados are not frequent in this region. But localized areas like Demra, Manikgonj, Faridpur Narayangonj and Gazipur experienced devastating cyclones at least once in a decade causing loss of property and lives. Highest flood water level was two feet above the internal road level in 1998. 71 7.4 Environmental Aspect of Dhaka CSD Campus Silo Site 7.4.1 Site Description 211. The Public Food Distribution System (PFDS) was introduced by the British rulers in the undivided Indian sub-continent for storage and distribution food materials, especially grains. Bangladesh after its independence inherited the system and the Dhaka Central Storage Depot (CSD) is such an old establishment of the Food Department of the Government of Bangladesh that has been catering to the needs of food storage and distribution under various food related government programmes in the city of Dhaka and around. The Dhaka CSD is located at the Mill Barrack area by the side of the river Buriganga under Gandaria thana of the Dhaka Metropolitan city in Dhaka district. It is one of the oldest CSDs situated just by the side of the left bank of the river Buriganga. The location of the site is at the coordinate of N23°41΄49΄΄ and E90°25΄10΄΄. The CSD campus is surrounded by a security wall though its condition is very poor showing the symptoms of very less maintenance. Being located by the side of the river, previously its river way connection was used largely for which a jetty was constructed connecting the river with the CSD for taking in and delivery of the grains from the CSD. Siltation of the river, low flow of water and construction of a number of bridges across the river for improving land transportation with the Dhaka city have restricted the river transport of the food grains to and from the CSD overtime. The location of Dhaka CSD is shown in figure below. Figure 7-5 Location of Dhaka CSD Site 212. Dhaka CSD Campus is a very strategic and potential location. It has the tremendous need for meeting the food needs of the distressed people in the Dhaka city slums, dwellers of which are the migrated poor people who left their original village homes after being affected by river erosion, flood and landlessness. Hence, current CSD campus occupied by the old dilapidated godowns having poor effective capacity may be demolished and utilized for construction of a steel silo for rice storage. 213. The site is situated within the area of the Sutrapur thana of the metropolitan area and the river Buriganga flows just by the southern side of the depot. The road and the main entry to the site are at 72 the north side. From two other sides, the CSD is surrounded by private establishments. The whole site is designated by the Government as a restricted area, prohibiting entry and stay of the general public. 7.4.2 Physiography, Geology& Topography 214. The proposed site falls at the northern boundary of active Ganges Flood Plain area of Bangladesh. The sub-project site is located at the bank of the Buriganga River. The total CSD area is around 4 acres land falls under mostly flat and high paved-land. There is no agricultural land or forest area in its premise. Soil of proposed site is found to be clayey in nature. 215. The road from the jetty passed through the middle of this vacant land. The land to the left side of the divider road (about 100 meterx100 meter) road is completely vacant and currently used as a play ground. The land to the right side has some trees primarily planted to continue the possession of the CSD authority. The whole combined land, adjacent to the river bank may be used for constructing a rice silo and other facilities for long term storage. 216. The subproject location is situated at the north-east side of kalirbazar, kadam Rasolpur; west side is Shitalakkha River. The natural drainage pattern is from the CSD premise area towards the Shitalakhha River through soils. The soil condition of the proposed site is clay in nature. The overall topography is rather flat in the whole sub-project area. 7.4.3 Existing Structure 217. The size of the CSD campus is 4 acre. The campus has 15 (fifteen) almost similar tin-shed godowns with pucca floor and walls. The structures are constructed in the campus in two rows. Physical condition of all of them is very poor. At least two godowns are not usable at all because of the damage of roof, wall and floor. Another 5 to 6 godowns are being used for food storage after partial repair. But since the joints of the old-day tin sheets could not be repaired, polythene sheets are used on the grain bags to protect them from rain water. The remaining ones also have various types of problems that need to be addressed soon. 218. As the godowns are tin-sheds, food grains are heated very much during the summer time. Since tins of roofs in many cases are perforated, water leaks in to the godowns during the rainy season causing damage of grains and walls, and creating holes in the floor. A protection wall has been erected by the side of the river bank road to protect the godowns from on rush of flood water that was experienced in 1988. Temporary protection walls also have been made in several entry points to the godowns also for protection purpose. 219. At the corner of the road connecting the jetty, a Pneumatic Unloading Plant (PUP) known as a small silo of the capacity of 200 MT was constructed to ease the loading system. But much earlier it went out of operation and now exists as a dilapidated structure, not fit for any use. 220. The CSD exists in its location in an engulfed situation surrounded by privately owned structures leaving no scope for any sort of horizontal expansion. The summary of Dhaka CSD area is presented in Table 7.11. Table 7-11 Summary of Dhaka CSD CSD area 04.00 acres Surrounded by protection wall Covered with go-downs More than 3.0 acres The rest is covered by ancillary 73 structures Open area (contiguous) Almost nil Office and weighing bridge are also congested Contiguous area Marginal Located between jetty and main entrance from river bank Existing Structures Total Godowns 15 02 are now not usable at all Total godowns Hardly 6,000 mt 02 godowns are not usable any (though originally it more. was 6,500 mt) Storage capacity Hardly 6,00 mt now 11 godowns that are called usable have undergone many times repair. The present storage after covering the bags with polythene sheets during raining is not acceptable. Useable capacity Nil Because of paucity of land inside Residential units Guard rooms, Jetty at Though land in the site is very small, the river bank but bin capacities may be big to accommodate more quantity of rice. 7.4.4 Transportation Link 221. Interior roads: The proposed Dhaka CSD Campus for rice storage is connected by a semi paved 8 m wide road, which is connected at a distance with the high ways through both ends. The connecting road is however, is not very wide and has characteristic traffic congestion of old Dhaka. In order to avoid traffic congestion, road vehicles like trucks and other heavy vehicles are not allowed to commute in the area from morning to 9:00 pm. The interior space for transport parking and the interior roads are adequate for transports. 222. River: The main strength of communication with the site is the riverside road and the river that has a jetty owned by the FD. Barges and other river vehicles can transport the food grains to and from the site any time. There are many industries or establishments on both sides of the river, both in the up and down streams, who use the river for transportation of their commodities and the personnel. Small and medium lighters/barges up to the capacity of 2000 mt are found in using the river all the seasons. 223. Road There are road connections to the site from the north and the south (river side road) sides, worth for truck movement with 15 to 20 mt load in each direction 7.4.5 Utility (Power, water, gas) supply at the site 224. The power supply to the Dhaka CSD is ensured through 11KV power supply line passing along property line of CSD. Dhaka WASA is being used as main sources of water supply. Gas supply line is running along the adjacent road. 7.4.6 Status of Food Supply in Dhaka 225. Grain supply and distribution: Wheat comes here from Naryanganj and Chittagong by road and river and dispatched to other LSD’s of the country in the same way. Rice comes to Dhaka CSD from the northern districts and dispatched to the others districts and LSDs. The Dhaka CSD is the 74 main supplier of open market sale operations in Dhaka City and for the huge local consumptions for police and other departments. 7.4.7 Seismicity 226. Dhaka CSD, is located in Zone 2 is the medium vulnerable to earthquake disaster. 7.4.8 Hydrology and drainage 227. The natural drainage pattern is from the CSD premise land towards the Buriganga River. The overall topography is almost flat in the area. The site has no experience of water logging during monsoon as it is located 1.0 m above of maximum water level of the river. The groundwater depth is 0.75 m from the existing ground level. 228. The site has existing sewerage and drainage facilities. However, those are not well maintained. 7.4.9 Air quality 229. Severe odor problem persists in the area. 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 samples were collected from the boundary of the north and south side of the proposed area. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-12 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 06/12/12 North end 8 hours 212 410 23 42 06/12/12 South end 8 hours 230 465 28 37 Bangladesh Standard for Industrial and 500 5000 120 100 Mixed 7.4.10 Water quality of the nearby river 230. The CSD area is located near the bank of Buriganga. Water samples were collected from one sampling points in the Buriganga River near the sub project site. The present situation of the water quality is presented in the following Table. Buriganga River water near to the project site at Dhaka CSD is already polluted. The water quality will be regularly monitored during project construction and operation phase to oversee the impact of the project. Table 7-13 Water Quality Monitoring Data Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 23 20-30 Ok Turbidity NTU 65 <10 Not ok Color TCU 35 <15 Not ok pH -- 7.4 6.5-8.5 Ok 75 TDS mg/l 2600 <1000 Not ok DO mg/l 3.1 >5 Not ok BOD mg/l 12 <6 Not ok Fe mg/l 0.2 0.3-1 Ok Zn mg/l 4.5 5 Ok Al mg/l 0.35 0.2 Not ok 7.4.11 Noise quality 231. The construction work may create noise pollution. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-14 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 32 27 9:30 am 35 32 10:00 am 35 28 10:30 am 38 30 11:00 am 35 28 11:30 am 35 30 06/12/12 Centre of the 1:00 pm 28 27 CSD 1:30 pm 30 26 2:00 pm 35 32 2:30 pm 33 32 3:00 pm 40 32 3:30 pm 35 28 Bangladesh standard: 70dBA 7.4.12 Terrestrial ecology 232. Since the whole area is paved, no such endangered species of matured trees are identified. However, the site has three jackfruit (Artocarpus heterophyllus) and some guava (Psidium guajava) trees. 233. The terrestrial common faunal species: field mouse (Musboodga), common cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow and pigeon. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exists in the potential site. 7.4.13 Fisheries 234. There is no waterbody inside the project area, the river is also at a safer distance from the impact of the construction work. 76 7.4.14 Cyclones and flooding 235. Severe cyclones or tornados are not frequent in this region. The site is above flood level. However, the site was inundated by 3’-6� during 1988 flood. 77 7.5 Environmental Aspect of Ashuganj Concrete Silo Site 7.5.1 Site Description 236. The Ashugonj Concrete Silo Campus Site for construction of a steel silo for rice storage is situated within the administrative division (extreme north point) of Chittagong Division of Bangladesh. The Ashugonj Silo is located about 75 km north-east of Dhaka and near the eastern bank of the river Meghna. The site is situated parallel to the railway that passes over the river Meghna. There is a railway land with planned tree plantation between the railway and the Silo structure. The silo and the ancillary facilities are surrounded by boundary wall. At the back side of the wall, private lands are there cultivated by the owners. To the left side of the campus, the river Meghna flows down. The campus is protected from all sides. The silo was constructed in the sight taking in to consideration the advantage of its linkage with other parts of the country, particularly Dhaka, Chittagong and north east part of the country through river and rail transport. The location of Ashuganj Silo is shown in Figure below. Figure 7-6 Location of Ashuganj Silo Site 7.5.2 Physiography, Geology& Topography 237. The soil condition of the proposed site is sandy in nature. The overall topography is rather flat with some undulated land outside the boundary at near the bank of the river. The proposed land for construction of silo is 3’-0� below the plinth level of exiting silo.The uneven surface of the site will require land development. The maximum annual average temperature is 33.3°C, minimum 12.1°C; annual rainfall 1698 mm with 90-95% rainfall between May and October. 7.5.3 Existing Structure 238. As per record, the total area of land under the ownership and control of the Directorate General of Food and Ashugonj Silo authority is 39.00 acre, out of which 23.50 acre is located within the boundary wall The land area outside the wall is about 15.50 acre – divided into four different locations e.g. (a) long strip outside the south wall : 3.29 acre (150 feet wide), (b) outside the east wall : 1.62 acre (ditch/pond), (c) Outside the north wall : 2.49 acre (a non-straight area, 320 ft away from an embankment) and (d) a sandy land near the west wall and the river : 8.06 acre (nearest distance of the wall from the river is 160 feet, though a considerable area inside the wall and in continuity with the outside land remains empty and unutilized). 78 239. The site has concrete silo, office, residential buildings and the road connection passing through the site from east to west. Inside the boundary wall, there is a designated block called garden where planned plantation was made. Close to the entry gate of the campus, there is almost a vacant space which is 400 feet long and 96 feet wide. The space has a dilapidated and unused structure (possibly used for accommodation of laborers during initial construction) and few haphazardly grown timber trees. The summary of Ashuganj CSD area is presented in Table 7.15. Table 7-15 Summary of Ashuganj CSD Total Silo Campus Area 39. acres –whole area 15.50 acre in 04 slots are outside the existing owned by FD & its silo’s boundary wall possession established Coverage of existing Silo 23.50 acre occupied by The biggest slot of 8.06 acre outside the wall and its ancillary facilities the existing silo, its and near to the river seems appropriate as a ancillary facilities and suitable site for steel silo. If needed, the area planned plantation of trees may be extended by adding two more acres vacant land inside the wall. Open area readymade area Almost nil - Contiguous area 7.44 acres in three Located between jetty and main entrance different locations without from river bank good access road Existing Structures Total units of Storage 01 An integrated structure Structure Storage capacity 50,000 mt Usable capacity Full 50,0000 mt Types of Grain Stored :Wheat Staff Residential unit 02 For Silo Manager and Assistant Manager Other structures Guard rooms, Jetty at Some of the ancillary structures are out of the river bank, bagging order unit, conveyer belt, etc 240. The existing facility of Ashuganj site is presented in the next figure. 79 (a) Conveyer gallery to receive food grains from river (b) Receiving point of dropping wheat grains after vessels (presently not in operation) opening the bags of wheat (in operation at present) (d) Bagging unit of food grains at Ashuganj silo (c) Receiving unit of food grain baggage (not in operation at present) Figure 7-7 Snapshot Existing Facilities of Ashuganj concrete Silo Site 7.5.4 Transportation Link 241. Interior roads: The campus has wide interior roads from the entry gate up to the rear exit gate. There are also other internal connecting roads. The entry/exit roads are also connected with the outside road network. 242. River: The Ashugonj Concrete Silo Site site has good links for river transport. There is a medium size Jetty with conveyor belt for transporting the food grain mechanically from the river vessel to the silo. At the river bank there is a pontoon. But the system is not working now. 243. Rail: There is a railway connection of the silo, through which wheat is transported by special wagons from Chittagong concrete silo. The movement of food grains by train is, however, slow and irregular. For this reason, most of the food grains are transported by road. 244. Road There are good road connections to the site and no restrictions on movements of trucks from or to outside road network. 245. The lane width of the road outside of the Silo site that connects the branch of Dhaka-Sylhet highway is 4.5 m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike 80 and bicycle. An initial traffic survey was carried out at this road in the daytime of the weekday, when the traffic volume was expected to be high. The identified peak rate of traffic flow was 256 vehicles/hour. The traffic data from this survey is presented in the Annex 4. 7.5.5 Utility (Power, water, gas) supply at the site 246. The power supply to the Ashuganj Silo site is ensured through Ashuganj Power Station with 11KV overhead line. However, 33 KV power line will have to be ensured in this site for construction and uninterrupted operation of steel silo to store food grains. 247. Deep tube-well is being used as sources of water. Gas line is available adjacent to the site. 7.5.6 Status of Food Supply in Ashuganj 248. Grain supply and distribution: The sources of rice supply for distribution was the local procurement particularly rice from the non-hilly districts and supply from imports through Chittagong port and supplied , often directly to Ashugonj concrete Silo. 249. Rice Milling: Ashugonj river port is a hub of about 300 rice mills owned by the members of an Association. The hinterland that supplies the paddy to these rice mills consist of all the surplus (particularly the haor areas) of Sylhet Division and other districts namely Netrakona, Mymensing, Jamalpur, Narshingdi and Kishoregonj. Most of the paddy are transported by the engine operated boats like those used for transporting wheat from the Silo. Some are transported by trucks. Within a period of 11 months in a year, all these mills process more than one million MT paddy to produce about 660,000 MT of rice. The usual process of rice drying and packaging at a rice mill is shown in the following figure. Figure 7-8 Common way of drying rice paddy at a rice mill located at Ashuganj 81 Figure 7-9 Packaging of parboiled rice at a rice mill at Ashuganj 250. Wheat Milling: The production and local procurement of wheat in Chttagong Division is very marginal. Imported wheat mostly comes through Chittagong port usually directly after being lightered from ocean vessels and then to Chittagong concrete silo and Ashugonj Concrete Silo. 7.5.7 Seismicity 251. The subproject area, Ashuganj Silo site, is located in Zone 3 which is the most vulnerable to earthquake disaster. Therefore, the designer needs to consider high standard of design in foundation work against seismic affect following BNBC standard. 7.5.8 Hydrology and drainage 252. The natural drainage pattern is from the Silo Site premise towards the Meghna River. Soak well & septic tank is used as sewerage system and natural slope is working as drainage system. Water logging is usually not a problem during monsoon. Deep tube-well is the main sources of water supply for Silo’s staff. The ground water depth is 0.5 m. 7.5.9 Air quality 253. 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 samples were collected from the boundary of the north and south side of the proposed area. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. 82 Table 7-16 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 12/12/12 North end 8 hours 350 650 20 48 12/12/12 South end 8 hours 380 635 24 45 Bangladesh Standard for Industrial and 500 5000 120 100 Mixed 7.5.10 Water quality of the nearby river 254. The CSD area is located near the bank of Meghna. Water samples were collected from one sampling points in the Meghna River near the sub project site. The present situation of the water quality is presented in the following Table. The water has very high turbidity and total dissolved solid, the color is also more than the acceptable limit. The water quality will be regularly monitored during project construction and operation phase to oversee the impact of the project. Table 7-17 Water Quality Monitoring Data Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 21.5 20-30 Ok Turbidity NTU 30 <10 Not ok Color TCU 25 <15 Not ok pH -- 7.1 6.5-8.5 Ok TDS mg/l 1250 <1000 Not ok DO mg/l 6.4 >5 Ok BOD mg/l 4.8 <6 Ok Fe mg/l 0.15 0.3-1 Ok Zn mg/l 2.5 5 Ok Al mg/l 0.15 0.2 Ok 7.5.11 Noise quality 255. The construction work may create noise pollution to the surrounding area. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-18 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 35 30 9:30 am 38 34 10:00 am 35 32 10:30 am 35 32 11:00 am 38 34 11:30 am 40 35 12/12/12 Centre of the 1:00 pm 45 40 1:30 pm 40 36 83 site 2:00 pm 38 35 2:30 pm 36 31 3:00 pm 38 35 3:30 pm 38 31 Bangladesh standard: 70dBA 7.5.12 Terrestrial ecology 256. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the Silo premise and in open spaces. The total number of such trees in the campus is 480, out of which 280 are mahogany (Swieteniamahogoni), 60 are teak (Tecktona grandis), 40 are eucalyptus (Eucalyptus) and the remaining 100 are various types of fruits including banana (Musa sapientum), , mango tree (M. indica) etc trees. Natural vegetations occurring in the subproject site areas include: grasses (Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). 257. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, doel, shalik, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.5.13 Fisheries 258. There is no waterbody inside the project area, the river is also at a safer distance from the impact of the construction work. 7.5.14 Cyclones and flooding 259. Chittagong Division includes depressed and flood prone areas in the north-east and the southern coastal areas. Hence there are localized flood and tidal charge some times that cause damage to crop, assets and sometimes human life. The site is above flood level. However, the site was inundated by 1ft during 1998 flood. 84 7.6 Environmental Aspect of Mymensingh CSD Campus Site 7.6.1 Site Description 260. The proposed Mymensingh CSD Campus Silo site administratively belongs to Dhaka Division of Bangladesh. Mymensingh, one of the oldest districts of Bangldesh, is located in the central_north part of Bangladesh stands on the bank of the Bramhputra River. Mymensingh is bounded by the Garo Hills and Meghalya State of India in the north, Gazipur District in the south, Netrokona and Kishorganj District in the east and Sherpur, Jamalpur and Tangail District in the west. The present Mymensingh CSD is situated on Tangail to Mymensingh Highway connected to road and rail way line built in 1959. The river Bramhaputra flows by the eastern side of the Mymensingh city. The Mymensingh CSD site is situated on the western bank of the river. It is situated very close to the zero point of Mymensingh town. The location of the site is at the coordinate of N24°46΄39΄΄ and E90°21΄48΄΄. The location of Mymensingh CSD campus site is shown in Figure below. Figure 7-7-10 Location of Mymensingh Silo Site 7.6.2 Physiography, Geology& Topography 261. The subproject area falls within active Brahmaputra-Jamuna Flood Plain area of northernregion of Bangladesh. The sub-project site is located at the bank of the Brahmaputra River. The soil condition of the proposed site is sandyclay in nature. The site is situated near the Brahmaputra River at Mymensingh district. The natural drainage pattern is from the low- lying/ditch land towards the Brahmaputra River within the CSD premise area. The overall topography is flat in the surrounding of the sub-project area. The maximum annual average temperature is 35.1°C, minimum 14.8°C. 262. The CSD area is surrounded by private land owners at two sides, on side by the road and the other by the Office of the Bangladesh Border Guard, a para-military force. 85 7.6.3 Existing Structure 263. Out of the 21.0 acre of the total CSD campus, about 6.0 acre is vacant inside the boundary wall. There is a pond/waterbody inside the boundary area, which is 116m X 93m that occupies about 2.66 acre of land. The average depth of the pond is 3.1 m. This ditch area including the waterbody/pond will be used as the project site. There are 54 Gudown of which are: a) Dhaka type: 24x500=12000 MT b) Calcatta type : 8x750=6000 MT c) Danish type : 6x500=3000 MT d) Salt Godown: 4x640=2560 MT e) Japan type : 4x1000=4000 MT f) New Godown: 2x1000=2000 MT g) New Godown: 6x500=3000 MT. 264. There are also an Office, one Manager’s Quarter ,one Asst.Manager’s Quarter & 2 Darawan’s Quarters and a Mosque. The summary of Mymensingh CSD area is presented in Table 7.19. Table 7-19 Summary of Mymensingh CSD Mymensing CSD area 21.00 acres Surrounded by a wall from all sides Covered with go-downs About 15.00 acres Besides the open area Open area About 6.0 acres A ditch like waterbody inside the boundary wall Contiguous area Very minimum The CSD is constructing some new godowns in an outside area newly taken up. Existing Structures Total godowns 54 08 are under construction Storage capacity 35,000 mt (including the 10 godowns are not usable any more. unusable godowns) Useable capacity 27,560 mt now Unusable ones are currently in dilapidated condition and need demolition Residential units 02 residential units for Two more houses for management staff, but management staff and one not in good shape. dormitory. Other buildings Mosque, guard rooms. The ditch land created through lifting soil during construction of various godowns remains unprotected without effective demarcation lines. 7.6.4 Transportation Link 265. Interior roads: Interior roads for the present requirement of the CSD are enough, though they need repair. For construction of the new silo in the vacant land, new connecting roads need to be constructed. 266. River: The Mymensing CSD Campus is sitiuated by the side of the Brahmaputra river, but it is not navigable at that point. Hence there is no opportunity for river transport for the food grains. 267. Road There are good road connections to the site as it is located in the corner of two inter district roads. There is no restrictions on movements of trucks from or to outside road network. 268. The lane width of the road outside of the CSD that connects the Mymensingh-Tangail highway is 6.1m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike 86 and bicycle. An initial traffic survey was carried out at this road in the daytime of the weekday, when the traffic volume was expected to be high. The identified peak rate of traffic flow was 244 vehicles/hour, where less than 10% of them are trucks. The traffic data from this survey is presented in the Annex 4 7.6.5 Utility (Power, water, gas) supply at the site 269. The power supply to the Mymensingh Silo site is ensured through the national grid with 11KV overhead line. However, 33 KV power line will have to be ensured in this site for construction and uninterrupted operation of steel silo to store food grains. Transformer is available near CSD Compound. 7.6.6 Status of Food Supply in Mymensingh 270. The sources of rice supply for distribution, rice milling and wheat milling facilities are same as the Dhaka and Narayanganj CSD. 7.6.8 Seismicity 271. The subproject area, Mymensingh Silo site, is located in Zone 3 which is the most vulnerable to earthquake disaster. Therefore, the designer needs to consider high standard of design in foundation work against seismic affect following BNBC standard. 7.6.9 Hydrology and drainage 272. Water usually accumulates in the monsoon up to 0.5m (average) in the low land area/ditch/waterbody. The new proposed silo construction site is mainly on ditch land. The whole CSD area experienced 0.15m (6 inch) inundation during 1988 flood. 273. The main Source of water is Deep tubewell water which is supplied by electric pump to Staff Quarters & Office building of CSD. Groundwater is 2.75 m below the surface. 7.6.10 Air quality 274. 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 samples were collected from the boundary of the north and south side of the proposed area. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-20 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m3 μg/m3 μg/m3 μg/m3 19/12/12 North end 8 hours 310 475 48 38 19/12/12 South end 8 hours 325 510 44 36 Bangladesh Standard for Industrial and 500 5000 120 100 Mixed 87 7.6.11 Water quality of the nearby waterbody 275. Water samples were collected from the pond located at the site to assess baseline environmental data. The present situation of the water quality is presented in the following Table. The samples were collected on 19 December, 2012. Other than turbidity and color, other parameters meet the Bangladesh standard. Table 7-21 Water Quality Monitoring Data Parameter Unit Test value of Bangladesh Remark the sample Standard Temperature °C 23.1 20-30 Ok Turbidity NTU 12 <10 Not ok Color TCU 16 <15 Not ok pH -- 7.1 6.5-8.5 Ok TDS mg/l 715 <1000 Ok DO mg/l 6.6 >5 Ok BOD mg/l 2.9 <6 Ok Fe mg/l Nil 0.3-1 Ok Zn mg/l Nil 5 Ok Al mg/l Nil 0.2 Ok 7.6.12 Noise quality 276. The construction work may create noise pollution to the surrounding area. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-22 Noise Quality Monitoring Data Date Location Time dBA Highest Lowest dd/mm/yy 5:00 am 15 14 5:30 am 16 16 amamam 6:00 am 20 18 7:30 am 24 22 8:00 am 28 26 8:30 am 35 30 9:00 am 32 30 19/12/12 Centre of 9:30 am 35 34 the site 10:00 am 36 35 10:30 am 38 36 11:00 am 45 43 11:30 am 40 36 1:00 pm 48 45 1:30 pm 38 35 2:00 pm 38 34 2:30 pm 40 36 3:00 pm 38 35 3:30 pm 42 38 6:00 pm 30 28 88 Date Location Time dBA Highest Lowest dd/mm/yy 6:30 pm 28 27 7:00 pm 26 24 9:00 pm 24 22 9:30 pm 26 20 11:00 18 17 11:30 pm 16 16 00:00 pm am 15 15 00:30 am 17 15 1:00 am 16 15 2:00 am 14 14 20/12/12 Centre of 3:00 am 16 15 the site 4:00 am 20 18 Bangladesh standard: 70dBA 7.6.13 Terrestrial ecology 277. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the CSD premise and in open spaces. There are about 500 trees in the whole CSD area. The tree species within the CSD area include: eucalyptus (eucalyptus), banana (Musa sapientum), mahogany (Swieteniamahogoni), banyan tree (F. religiosa), coconut (Cocos nucifera) etc. Natural vegetations occurring in the subproject site areas include: grasses ( Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). 278. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, dove, cuckoo, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.6.14 Fisheries 279. The pond situated in the sub-project area have some common fish like puti, tengra, carp, koi, taki, bain etc. It is found from the discussion with the local people that no endangered/rare species of fishes were identified so far by the local people. 7.6.15 Cyclones and flooding 280. Severe cyclones or tornados are not frequent in this region. However, the location of the Mymensing CSD Campus is very strategic as it is located at a place surrounded by a number of districts and other upazilas of Mymensingh district that are known as surplus rice production areas. Construction of the silo will enable the FD to procure a substantial amount of surplus rice and thereby ensure fair price to the farmers. 89 7.7 Environmental Aspect of Maheswarpasha CSD Campus Site 7.7.1 Site Description 281. Maheshwarpasha is situated in the south-west part of Bangladesh in Khulna Metropolitan Area under the Daulatpur Police station. The site is located on The western Bank of the River Bhairab and Eastern side of Khulna & Jessore High way & railway Line. The location of the site is at the coordinate of N22°53΄03΄΄ and E89°30΄53΄΄. The location of Maheswarpasha Silo is shown in figure below. Figure 7-11 Location of Maheswarpasha Silo Site 7.7.2 Physiography, Geology& Topography 282. The subproject area falls within active Ganges Flood Plain area of southern region of Bangladesh. The sub-project site is located at the bank of the Bhairab River. The total area of the CSD/silo is 58.14 acres but the prospective steel silo will be constructed at the northern portion of the site taking about 6 acres of land. The Northern Portion of the proposed Silo site is low laying area. The dimension of the ditch is 25m X 20m at the north-eastern side of the site. Water accumulates in this ditch of 0.5m height. There is no agricultural land or forest area in its premise. The plinth level of Northern side godown is 4’-6� high from the existing G.L. 7.7.3 Existing Structure 283. The location of the site is at the coordinate of N22°53΄03΄΄ and E89°30΄53΄΄. Though the Maheshwarpasha campus is a big one, the number of structures including unused godowns, unused silo and administration building has occupied most of the areas. Still, inside the campus there are two almost vacant sites for probable construction of a steel silo for storage of food grains. The priority 90 area is situated to the right side of the exit gate towards the jetty, which is very near to the Jetty in the bank of the river for river connectivity. Rail road is also very close just to the right side of the area for ensuring rail connectivity. The road connectivity is ensured through movement of trucks. For smooth entrance of trucks, some work for improving the quality of the road will have to be made. The size of the area is about 06 acres, but inside the area it has the dilapidated administration (very old) building and two other dilapidated unused godowns. These will have to be demolished for construction of the silo. Also, it has a small shallow ditchland of height 0.5m water, which will have to be filled up. 284. There are 3 Nos Calcutta type godown, 3 nos japan types godown in the western side but the 3 nos Calcutta types godowns are dilapidated and there is an abandoned building in the north-east side. The summary of Maheshwarpasha CSD area is presented in Table 7.23. Table 7-23 Summary of Maheswarpasha CSD Total Silo Campus Area 58.14 acres Existing Structures Total units of Storage CSD : 59 The only concrete silo is non-functional Structure Silo (small): 01 Storage capacity 58,827 mt (including the 12 godowns are not usable any more. unusable godowns) Usable capacity 27,560 mt now 47 godowns are functional Staff Residential unit 02 residential units for The physical condition is very poor management staff and one dormitory. Other structures Dilapidated office The shallow water body in the site was building, guard room created through lifting soil during construction of various structures earlier. 7.7.4 Transportation Link 285. Interior roads: Interior roads of the present CSD are enough, though they need repair. For construction of the new silo in the vacant land, new connecting roads need to be constructed. 286. River: The site has good links for river transport. There is a wide river frontage at the site with two jetties, one large and one small, and a pontoon dock belonging to the BIWTA. Most of the food grains received at Moheeshwarpasha CSD arrives by river barge. Vessels sizes average 600 tons for food grains, but the river can accommodate vessels up to 2000 tons. Wheat is transported by river barge from Mongla or Chittagong. Rice arrives from Baghabari where it is tran-sloaded from trucks to barges at Baghabari LSD usually without intermediary storage. There is only about one meter of tidal variation. 287. Rail: There is a railway connection with the CSD site. The godowns are so designed and constructed that every alternate godown is connected by rail road and the other alternative is by the trucks. 288. Road There are good road connections to the site and no restrictions on movements of trucks from or to outside road network. 91 289. The lane width of the road outside of the CSD is 10.0 m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike and bianncycle. An initial traffic survey was carried out at this road in the daytime of the weekday, when the traffic volume was expected to be high. The identified peak rate of traffic flow was 244 vehicles/hour, where less than 10% of them are trucks.The traffic data from this survey is presented in the Annex 4 7.7.5 Utility (Power, water, gas) supply at the site 290. The power supply to the Maheshwarpasha campus is supplied by western zone of electric power supply through two separate 11 KV lines, each for CSD and silo. For continuous power supply on priority basis through the 33 KV power line will have to be ensured in the probable site at Maheshwarpasha CSD/silo for construction and uninterrupted operation of a silo. 291. There is no connection of city corporation water supplied. Shallow tube-well water is supplied by electric pump to staff quarter of CSD. 7.7.6 Status of Food Supply in Maheswarpasha 292. Grain supply and distribution: The sources of rice supply for distribution was the local procurement particularly from the middle and northern districts of the Division and trans-loaded at Baghabari ghat in barges for delivery to various storage facilities. These facilities distributed the rice for use under monetized schemes including essential priorities (e.g. Army, police, RAB, Ansar- VDP), other priorities (e.g. fire service, prisoners and Open Market Sale – OMS for price stabilization) and non-monitized schemes under varied food safety programmes like Vulnerable Group Feeding (VGF), Vulnerable Group Development (VGD), Test Relief , Food for Works FFW), etc. Khulna zone has about 2540 (62%) rice mills. 293. The proportion of local procurement of wheat is small and is usually transported to the local storage facilities in the Division using the similar mode of transports as used in rice transportation. Imported wheat mostly comes through Mongla port usually directly after being lightered from ocean vessels. Only if no wheat deliveries are available in Mongla port, wheat is supplied to Khulna Division from Chittagong port either directly lightered from ocean vessels or from CSDs in Khulna Division. 7.7.7 Seismicity 294. Maheswarpasha CSD, is located in Zone 1 is minimum vulnerable to earthquake disaster. 7.7.8 Hydrology and drainage 295. Water usually does not accumulate in the monsoon, but the site is located at the tidal zone. During the tidal period, tidy water level reached 0.3m below of the existing concrete jetty. Existing CSD /silo food grain storage facilities are well protected from flood and constructed on high land (sand fill). The new proposed silo construction site is at the northern portion of the site which is mostly flat in nature but associated with some undulation and ditch land. The groundwater depth of the site is 1m below surface. Public sewerage and drainage system is available at the site. 92 7.7.9 Air quality 296. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-24 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 10/12/12 North end 8 hours 275 550 30 36 10/12/12 South end 8 hours 260 575 34 38 Bangladesh Standard for Industrial and 500 5000 120 100 Mixed 7.7.8 Water quality of the nearby river 297. The CSD area is located near the bank of Bhairab. Water samples were collected from one sampling points in the Bhairab River near the sub project site. The present situation of the water quality is presented in the following Table. The water has very high turbidity and total dissolved solid, the color is also more than the acceptable limit. The water quality will be regularly monitored during project construction and operation phase to oversee the impact of the project. Table 7-25 Water Quality Monitoring Data Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 22.2 20-30 Ok Turbidity NTU 26 <10 Not ok Color TCU 21 <15 Not ok pH -- 7.6 6.5-8.5 Ok TDS mg/l 1460 <1000 Not ok DO mg/l 6.8 >5 Ok BOD mg/l 3.8 <6 Ok Fe mg/l 0.1 0.3-1 Ok Zn mg/l 2.7 5 Ok Al mg/l 0.11 0.2 Ok 7.7.9 Noise quality 298. The construction work may create noise pollution to the surrounding area. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-26 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 40 36 9:30 am 37 34 10:00 am 36 32 10:30 am 35 30 93 11:00 am 38 36 11:30 am 42 38 1:00 pm 46 42 1:30 pm 42 38 10/12/12 Centre of the 2:00 pm 38 34 site 2:30 pm 40 37 3:00 pm 38 36 3:30 pm 36 32 Bangladesh standard: 70dBA 7.7.10 Terrestrial ecology 299. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the CSD premise and in open spaces. The tree species within the CSD area include: banana (Musa sapientum), mahogany (Swieteniamahogoni), banyan tree (F. religiosa) etc. Natural vegetations occurring in the subproject site areas include: grasses ( Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). 300. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, dove, cuckoo, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.7.11 Fisheries 301. But there is no rare/endangered species of fishes located at that ditch land. 7.7.12 Cyclones and flooding 302. Khulna Division was severely affected by Cyclone Sidr in November 2007 and by Cyclone Ayla in May 2009. Khulna division is prone to be affected by tropical storm. In case of incidence of disasters like flood, cyclone, tidal charge in and around the area, food supply from the Maheshwarpasha silo will be of much benefit to ensure the food security of the affected people. 94 7.8 Environmental Aspect of Chittagong Port Concrete Silo Campus 7.8.1 Site Description 303. The silo facility project of Chittagong falls in Chittagong City Corporation Area near the Karnafully River in Patenga. The present Chittagong Silo is situated in between Karnafully Export Processing Zone and TSP complex in North Patenga, in a land of 25.00 acre and linked with the Airport Road. The site has communication network rail too. The location of the site is at the coordinate of N22°16΄36΄΄ and E91°47΄36΄΄. The location of Chittagong Silo is shown in figure below. Figure 7-12 Location of Chittagong Silo Site 7.8.2 Physiography, Geology& Topography 304. The subproject area falls within Chittagong Hilltrack zone of the country. The sub-project site is located at the ocean area at the close proximity of Patenga road. The soil is sandy in nature. The topography of the land is mostly flat with some ditches. There is no agricultural land or forest area in its premise. 7.8.3 Existing Structure 305. Chittagong Silo is the country’s only grain terminal at an ocean port. The existing concrete grain elevator holds 100,000 tons of wheat received from vessels making it the largest grain storage facility of the Food Department. There are four pneumatic ship unloaders on the jetty. Two 200 ton per hour unloaders were installed in 2010. The remaining two unloaders are original equipment at the silo installed 40 years ago. Though nominally 200 mt per hour capacity the older ones can only function at a top rate of 125 mt per hour due to a decline in their water column pressure. One is in the 95 process of being dismantled, leaving only 3 operational. These old unloaders have much higher energy consumption than the newer ones. Figure 7-13 Chittagong – Concrete Silo 306. The conveyer gallery houses three 200 mt/hour belt conveyers that bring wheat from the jetty to the existing silo. One of these is a two-way conveyer that can be used to fill coasters with wheat from the silo. The effective conveying capacity from the jetty to the silo is about 275 mt/ hour. The silo cells can be filled from three top conveyers simultaneously. 307. The proposed site for the steel silos is on the northeast corner of the site with bagging house and truck staging to the east of the existing grain elevator. The existing conveyer gallery sits on a band of land that is 200 ft wide at the river but narrow to 160 wide at the silo boundary wall. 308. As per record, the total area of land under the ownership and control of the Directorate General of Food and Chittagong Silo authority is 25 acre. 309. Existing Structure description area is presented in Table 7.27. Table 7-27 Summary of Chittagong Silo Total Silo Campus Area 13.73 Acres The biggest slot of 8.06 acre outside the wall and near to the river seems appropriate as a suitable site for steel silo. If needed, the area may be extended by adding two more acres vacant land inside the wall. Coverage of existing Silo 6.88 Acres - and its ancillary facilities Open area readymade area 9 Acres Located between jetty and main entrance from river bank Contiguous area 29.613 Acres 15.50 acre in 04 slots are outside the existing silo’s boundary wall Total Silo Campus Area 15.50 acre in 04 slots are outside the existing silo’s boundary wall Existing Structures Total units of Storage Round bin: 88 nos Round bin capacity: 1000 ton/bin Structure Star bins: 54 nos Star bin capacity: 225 tons/bin Storage capacity 100150 tons Usable capacity 100150 tons 96 Staff Residential unit 6 units Other structures - - 7.8.4 Transportation Link 310. Interior roads: About 1.25 km of internal road exists within the silo area. The road is 20 feet wide. 311. River: River Karnaphuly flows about 200 yards from the silo site and is the main route of transportation for water transport by which the grains arrive at the silos. 312. Rail: A railway track enters inside the silo site from New Mooring rail point thus connecting the Silo with the railway system also. 313. Road: Two roads connect the silo from outside. These roads ultimately connect the national Highway system. 314. The lane width of the road outside of the CSD is 10.0 m. The vehicles that ply over this road are trucks, human hauler, rickshaw, motorbike and bicycle. An initial traffic survey was carried out at this road in the daytime of the weekday, when the traffic volume was expected to be high. The identified peak rate of traffic flow was 264 vehicles/hour, where less than 10% are trucks and cargos. The traffic data from this survey is presented in the Annex 2.4 7.8.5 Utility (Power, water, gas) supply at the site 315. The power supply to the Chittagong silo campus is supplied by power development board with 11 KV line. 316. Chittagong silo has its own deep tube well but the water is saline and as such mostly used for washing purpose. The campus has its own underground water reservoir which is supplied by WASA. Gas is available inside the silo. 7.8.6 Status of Food Supply in Chittagong Silo 317. Grain supply and distribution: Average annual grain volumes received at the silo has been 300,000 tons since 1999 for an annual throughput of 3 times the storage capacity or grain held just an average of 4 months. The Chittagong Silo is the main unloading point for wheat imported by the Food Department as shown below: Table 7-28 Yearly Receipt & Dispatch Position of Chittagong Silo Year Receipt (MT) Dispatch (MT) 1999 466,561 433,806 2000 149,218 237,633 2001 403,604 321,416 2002 164,892 242,413 2003 185,086 161,161 2004 220,679 177,276 2005 248,475 245,651 97 2006 98,091 168,521 2007 257,925 221,084 2008 319,691 330,336 2009 209,629 206,858 2010 496,990 461,837 2011 650,554 648,954 2012 122,959 206,551 (Till May' 12) 7.8.7 Seismicity 318. The subproject area, Chittagong Silo site, is located in Zone 2 which is moderately vulnerable to earthquake disaster. 7.8.8 Hydrology and drainage 319. Existing silo food grain storage facilities are well protected from flood and constructed on high land (sandy soil). The groundwater depth is 1m below from the existing ground. Internal drainage system for the silo exists. The sewerage is dependent on the septic tanks within the silo campus. 7.8.9 Air quality 320. 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 main sources of air pollutant emissions are the dust from food grains during shipment with heavy trucks from Chittagong to Ashuganj or Shantahar DGF silos that carry food grains/wheat. The samples were collected from the boundary of the north and south side of the proposed area. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. . However, relatively high concentration of SOx at the Chittagong silo site comparing to other sub project locations is due to mainly presence of TSP complex located near to sub project area. Table 7-29 Air Quality Monitoring Data Date Sampling Duration SPM CO SOx NOx dd/mm/yy point μg/m 3 μg/m3 μg/m3 μg/m3 12/12/12 North end 8 hours 410 460 120 50 12/12/12 South end 8 hours 425 475 112 48 Bangladesh Standard for Industrial and Mixed 500 5000 120 100 7.8.10 Water quality of the nearby Karnaphuli river 321. The CSD area is located near the bank of Karnaphuli. Water samples were collected from one sampling points in the River near the sub project site. The present situation of the water quality is presented in the following Table. The water has very high turbidity and total dissolved solid, the color is also more than the acceptable limit. The water already contains high Aluminum. The water quality will be regularly monitored during project construction and operation phase to oversee the impact of the project. Table 7-30 Water Quality Monitoring Data 98 Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 21 20-30 Ok Turbidity NTU 22 <10 Not ok Color TCU 24 <15 Not ok pH -- 7.1 6.5-8.5 Ok TDS mg/l 1200 <1000 Not ok DO mg/l 6.2 >5 Not ok BOD mg/l 4.4 <6 Not ok Fe mg/l 0.15 0.3-1 Ok Zn mg/l 3.4 5 Ok Al mg/l 0.15 0.2 Not ok 7.8.11 Noise quality 322. The construction work may create noise pollution to the surrounding area. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-31 Noise Quality Monitoring Data Date Location Time dBA dd/mm/yy Highest Lowest 9:00 am 55 52 9:30 am 50 48 10:00 am 48 45 10:30 am 54 50 11:00 am 60 56 11:30 am 62 56 1:00 pm 52 50 12/12/12 Centre of the 1:30 pm 46 45 site 2:00 pm 44 42 2:30 pm 50 46 3:00 pm 52 48 3:30 pm 45 42 Bangladesh standard: 70dBA 7.8.12 Terrestrial ecology 323. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the Silo premise and in open spaces. The tree species within the sub project area include: banana (Musa sapientum), betel nut tree (Areca catech) etc. Natural vegetations occurring in the subproject site areas include: grasses (Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). 99 324. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, doel, shalik, owl, etc. no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.8.13 Fisheries 325. There is no waterbody inside the project area, the river is also at a 200 yards distance from the impact of the construction work. 7.8.14 History of Cyclones and flooding in the Project area 326. As informed by the silo superintendent the silo campus area was never flooded but occasional cyclones generated in the Bay of Bengal would be of concern in the future. 100 7.9 Environmental Aspect of Madhupur CSD Campus Site 7.9.1 Site Description 327. Modhupur is one of the 12 upazilas in Tagail District of Dhaka Division. The upazila is a part of the Modhupur highland of the greater Mymensing area. Modhupur has a Government khas land area of 7.80 acre which is 3.5 km away towards north from the Modhupur 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 location of Madhupur Silo is shown in the figure below. Figure 7-14 Location of Madhupur Silo Site 7.9.2 Physiography, Geology& Topography 328. Madhupur site is located in the high land of Madhupur Tract. The site is located about 13.5 km away towards north from Madhupur Upazilla Sadar of Tangail district. The overall topography is rather flat, located in high land. The soil of proposed site was found to be clay in nature. The maximum annual average temperature is 33.3°C, minimum 12.°C; annual rainfall 1467 mm with 90% rainfall between May and October. 7.9.3 Existing Structure 329. The present Madhupur LSD has 4 go-downs in all, out of which 1 is unworkable and rest are workable having its maximum capacity of 3,250 tons. All the working go-downs are fully loaded with rice. Rice comes from the northern districts and distributed locally. To the east of the plot, Government khas lands under District Commissioner are used to cultivate for production of banana and pineapple as shown in the following figure. 101 Figure 7-15 East Side of Proposed Madhupur Silo Site 330. The office of the Bangladesh Forest Industries Corporation (BFIDC) is in the north, 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 Banana & Pine apple. Other than the LSDs, there is no other existing structure in the Madhupur campus. 7.9.4 Transportation Link 331. Interior roads: The site is currently a vacant land with no structure or underground installation. For construction of the new silo in the vacant land, new connecting roads need to be constructed. 332. Road: Road is the only mode of transportation. The lane width of the road of the site that connects the branch of Mymensingh-Tangail-Jamalpur highway is 4.5 m. There are very few bicycles and motor cycles run regularly but large vehicles like trucks and cars ply occasionally. New traffic is expected, as a result of new silo construction. 7.9.5 Utility (Power, water, gas) supply at the site 333. 11 KVA Electric line of palli bidyut is running along the adjacent road and there is no water and gas supply. 102 7.9.6 Status of Food Supply in Madhupur 334. Grain supply and distribution: Madhupur upazila and Tangail district are the administrative units in Mymensing upland belonging to Dhaka administrative Division of the country. Almost the full upland is a flood free area. Introduction of irrigated agriculture system has made most of the upland area a new rice surplus area. Wheat is also produced in a limited scale. The estimated annual production of these two major food grains during the period is presented in the table below: Table 7-32 Estimated Food Grains Production in Dhaka Division (mt) Sl Agriculture Region Rice Varieties Total Rice Total Total No Aus Amon Boro Wheat Food Grains 1. Dhaka Ag. Region 9,359 2,68,366 10,65,615 13,43,340 15,732 13,,59,072 2. Faridpur Ag. Region 40,517 2,82,742 8,63,262 11,86,521 1,30,494 13,,17,015 3. Jamalpur Ag. Region 17,175 3,62,476 7,25,244 11,04,895 11,709 11,16,604 4. Kishoregonj Ag. 40,458 3,73,126 13,31,254 17,44,838 9,154 17,53,992 Region 5. Mymensing Ag. 1,06,457 5,50,642 8,01,190 14,58,289 4,055 14,62,344 Region 6. Tangail Ag. Region 1,163 2,32,731 6,37,268 8,71,162 13,341 8,84,503 Grand Total 77,09,045 1,84,485 78,93,530 Source: BBS, Year Book of Agricultural Statistics of Bangladesh, 2010 7.9.7 Seismicity 335. Madhupur Silo Site, is located in Zone 2 which is minimum vulnerable to earthquake disaster. 7.9.8 Hydrology and drainage 336. The site is located in the Madhupur high land. Being a high land long term flood is not an issue for the project site. During monsoon, rain water does not accumulate for long time. The area is fairly level. However, there is no sewerage and drainage system in the area. Tubewell is the only source of water. The groundwater depth of the site is 3.5m below surface. 7.9.9 Air quality 337. The present condition of the air quality is presented in the following Table. From the test results, it is found that SPM, CO, SOx and NOx of the ambient air in the sampling points are far below the atmospheric environmental standards for the industrial and mixed. Table 7-33 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 and 500 5000 120 100 Mixed 7.9.10 Water quality of the nearby river 338. Since, there is no surface water body near to the sub project area; water samples were collected from the tube-well of the site to assess baseline environmental data. Tube-wells are not 103 marked with red color for which they are considered as arsenic free tube-wells. The present situation of the water quality is presented in the following Table. The samples were collected on 21 December, 2012 Table 7-34 Water Quality Monitoring Data Parameter Unit Test value of the Bangladesh Remark sample Standard Temperature °C 21.1 20-30 Ok Turbidity NTU 3.5 <10 Ok Color TCU 3.8 <15 Ok pH -- 6.8 6.5-8.5 Ok TDS mg/l 820 <1000 Ok DO mg/l 7.5 >5 Ok BOD mg/l 1.8 <6 Ok Fe mg/l 0.1 0.3-1 Ok Zn mg/l 0.2 5 Ok Al mg/l Nil 0.2 Ok 7.9.11 Noise quality 339. The construction work may create noise pollution to the surrounding area. The site was found very foggy and extremely calm after 11:30 pm on the day of experimentation that the noise data after 11:30 pm was not possible to be taken. For the baseline environmental data, the current noise levels were measured at the center of the sub project area which is presented at the following Table. Table 7-35 Noise Quality Monitoring Data Date Location Time dBA Highest Lowest dd/mm/yy 5:00 am 20 18 5:30 am 22 20 6:00 am 25 24 7:30 am 26 22 8:00 am 30 26 8:30 am 38 35 9:00 am 32 31 21/12/12 Centre of the site 9:30 am 36 34 10:00 am 36 35 10:30 am 42 40 11:00 am 40 38 11:30 am 46 42 1:00 pm 50 45 1:30 pm 38 35 2:00 pm 32 30 2:30 pm 34 32 3:00 pm 38 36 3:30 pm 36 35 6:00 pm 38 35 6:30 pm 32 28 7:00 pm 25 24 104 Date Location Time dBA Highest Lowest dd/mm/yy 9:00 pm 24 20 9:30 pm 26 25 11:00 pm 22 20 11:30 pm 23 22 Bangladesh standard: 70dBA 7.9.12 Terrestrial ecology 340. The terrestrial floral habitats in the project area include various types of trees and natural vegetation in common, fairly common and frequent distributions in and around homesteads, along inside roads of the Khas land premise. The total number of matured trees in the area is surveyed to 60, which are at the edge of the boundary of the site. Out of 60 trees, 47 are Akashmoni (Acacia auriculiformis). Natural vegetations occurring in the subproject site areas include: grasses (Axonopuscompressus, Cynodondactylon, Dicanthiumannulatum, Digitariasanguinalis, Eleusineindica, Oplismenusburminii, Veteveriazizanioides, etc.). 341. The terrestrial common faunal species: field mouse (Musboodga), wild cat (Felischaus), frog (Ranacyanophyctis), etc. Bird species include crow, pigeon, dove, cuckoo, owl, etc. Therefore, no rare, threatened or endangered species of flora, wildlife habitat, and population exist in the potential site. 7.9.13 Cyclones and flooding 342. Tangail district as a whole and Madhupur is not a disaster prone area in general. Rather it is a surplus area in production of food grains in the country. Locally procured food grains and some imported grains from outside needs to be stored and taken off for distribution to the disaster prone/food deficit areas, both to the north-east and southern parts of the country. Hence, storage and handling of these food grains are also a part of supply chain for serving the disaster affected population and to be used as a reserve. 105 7.10 Socioeconomic Baseline of 8 Sites 343. This Section presents an analysis of the socioeconomic baseline of Project area developed based on data from secondary sources and from community consultations at the local level. The analysis presents the socioeconomic profile of the Project area, population, and communities. 7.10.1 Overview 344. The districts where the modern silos facilities are proposed to be constructed have been considered as the project area or project districts. The project districts have a total population of 38.80 million which is 27% of the national population (144.043 million) according to the 2011 Census. Table 7.36 provides the project area districts. Table 7-36: Project Area Districts Proposed Sites Project District Beneficiary Population (Million) People) 1. Ashuganj Brahmanbaria 2.84 2. Barisal Barisal 2.324 3. Chittagong Chittagong 7.616 4. Dhaka Dhaka 12.044 5. Maheshwarpasha Khulna 2.318 6. Modhupur Tangail 3.605 7. Mymensingh Mymensingh 5.11 8. Narayanganj Narayanganj 2.948 Total 38.805 7.10.2 Demographic Profile 7.10.2.1Population 345. The project area comprising the eight districts has a total population of 38.8 million peoples (27% of national population in 2011). Male population is higher in the project area on an average giving the male female ratio of 1.016 (number of male per female), higher than the national average of 1.003. The female population is higher in Barisal, Brahmanbaria, Mymensingh and Tangail districts and male female ratio is the lowest in Brahmanbaria (0.927 male against one female). Following the national average, male population is higher in all other districts and it is the highest in Dhaka district. Table 7.37 shows that average household size in the project area is 4.5 (persons per household) which is a higher than the national average of 4.4. Other than Barisal, Brahmanbaria Mymensingh and Chittagong districts, average household size in the project districts is less than the national average. 346. The project areas has an average population density of 2384 persons per squatter kilometer, more than double the national average (2.35 times the national average of 1015 persons per sq km). Density of population in Brahmanbaria, Chittagong, Dhaka, Mymensingh, Narayanganj and Tangail is high (more than national average) because those include the densely populated city areas. Even with a metropolitan city, population density in Khulna and Barisal districts is low due to climate vulnerability. Table 7-37: Population Characteristics in Project Area District Total Male/Female Ratio Household Size Density Barisal Population( 2.324 0.958 (Person/Household) 4.5 (No./sqkm) 835 million) (No. male per female) 106 District Total Male/Female Ratio Household Size Density Bramhanbaria Population( 2.840 0.927 (Person/Household) 5.3 (No./sqkm) 1,510 million) (No. male per female) Chittagong 7.616 1.016 4.9 1,442 Dhaka 12.044 1.195 4.2 8,229 Khulna 2.318 1.029 4.2 528 Mymensingh 5.110 0.987 4.4 1,163 Narayanganj 2.948 1.066 4.3 4,308 Tangail 3.605 0.951 4.1 1,056 Total PA 38.805 1.016 4.5 2,384 Bangladesh 144.043 1.003 4.4 1,015 Source: BBS Population and Housing Census, 2011 7.10.2.2Religions Composition 347. Communities in Bangladesh are largely Muslim by religion and more than 90% of its population is Muslim. Hinduism is the religion for the second largest population in the country and constitutes 8.39% of the total population. The rest are communities under Christianity, Buddhism and other religion/faiths. Compared to the national average, proportion of Muslims in the project area is similar but Hindu population is higher. People in other religions are smaller in the area compared to the national average. Table 7.38 shows distribution of project area population by religion. Table 7-38: Population by religion in the Project Area District Population by Religion (%) Muslim Hindu Christian Buddhist Others Barisal 87.77 11.69 0.526 0.010 0.003 Brahmanbaria 92.51 7.46 0.014 0.004 0.010 Chittagong 86.90 11.31 0.098 1.591 0.099 Dhaka 94.65 4.70 0.515 0.110 0.018 Khulna 76.63 22.68 0.657 0.004 0.031 Mymensingh 95.79 3.58 0.557 0.002 0.067 Narayanganj 95.06 4.89 0.033 0.013 0.007 Tangail 92.72 6.83 0.392 0.003 0.056 Total 90.25 9.14 0.349 0.217 0.036 National 90.43 8.39 0.56 0.37 0.25 7.10.2.3Tribal Communities 348. About 1.6 million of the national population in Bangladesh (144.04 million) belongs to 45 different small ethnic groups. These peoples are concentrated in the north, and in the Chittagong Hill Tracts (CHT) in the south-east of the country commonly known as tribal peoples. However, tribal peoples are also scattered in small proportion all over Bangladesh. A total of 116,926 tribal peoples are living in the 8 project districts of which only 35.72% are living in the urban areas. Half of the tribal communities in Barisal, 70% in Brahmanbaria, and 76% in Dhaka are living in the urban areas. In rest of the districts, tribal peoples are mainly living in the rural areas. Table 7.39 provides the concentration of tribal peoples in the project districts. Barman, Chakma, Coach, Garo, Hajong, Lusai, Manda, and Marma are the major tribes living in the project districts. Tribal concentration in the project districts is higher in Chittagong, Dhaka, and Mymensingh compared to the other districts. Table 7-39: Tribal Population in the Project Area 107 District Tribal Living in Ethnic Groups Barisal Population 76 Urban Areas 50.00 Chakma, Garo, Tripura and others Brahmanbaria 118 (%) 70.34 Chakma, Marma, Lusai and others Chittagong 32,165 33.31 Chakma, Tripura, Marma and others Dhaka 20,123 76.12 Chakma, Garo, Marma and others Khulna 2,054 11.98 Chakma, Barman, Manda and others' Mymensingh 35,907 5.44 Garo, Barman, Hajong and others Narayanganj 899 35.82 Chakma, Barman, Marma and others Tangail 25,584 2.73 Garo, Barman, Coach and others Total 116,926 35.72 Barman, Chakma, Coach, Garo, Hajong, % of total tribal population in Bangladesh Lusai, Manda, Marma and others 20.67 Source: BBS Population and Housing Census, 2011 7.10.3 Economic Profile 349. Bangladesh is a poor and overpopulated country (1015 persons per sq km) and 31.5% of its population is living in poverty. Despite numerous difficulties, Bangladesh economy has grown 5-6% per year since 1996. Although more than half of GDP is generated through the service sector, 45% of the country’s population is employed in the agriculture sector with rice as the single -most-important product. The project area largely represents the country in terms of industry, trade and agriculture production. About 52% of the employed population in the project area is engaged in agriculture and half of them own agriculture land. About 50% of the lands in the project area is under grain cultivation. Only 30% of the population has residential structures made of cement concrete materials representing the richer segment of the project area population. 7.10.3.1Ownership of Farm Land 350. In Bangladesh an average 53% of the total households own farm land and 18% of the total farm households are living in the project area. The proportion of farm households is 36% with respect total households in the project area. By district, farm households are less in Dhaka and Narayanganj due to its metropolitan characteristics. Majority of the farm households (88%) are small holders having farm lands from 0.05 acres to 2.49 acres. Less than one percent of the farm households (0.94%) are large holders having 7.50 acres or more lands and the rest 11% are medium land holders having land between 2.50 acres to 7.50 acres. See Table 7.40 for details. Table 7-40: Ownership of Farm Land in the Project Area Total HHs Farm Households Small (0.05- Medium (2.50- Large (7.50+ PA Districts No. No. % 2.49 Acres) No. 7.49 Acres) No. Acres) No. Barisal 482,075 322,054 66.81 290,408 29,899 1,747 Brahmanbaria 465,720 257,490 55.29 229,014 26,813 1,663 Chittagong 1,298,834 365,173 28.12 334,285 26,171 4,717 Dhaka 2,266,479 241,452 10.65 218,887 20,404 2,161 Khulna 502,835 207,743 41.31 167,904 35,146 4,693 Mymensingh 1,103,260 652,612 59.15 559,053 87,352 6,207 Narayanganj 532,415 119,479 22.44 113,340 5,675 464 Tangail 801,637 501,032 62.50 442,937 54,569 3,526 Total 7,453,255 2,667,035 35.78 2,355,828 286,029 25,178 % of farm households 88.33 10.73 0.94 Bangladesh 28,695,763 15,183,183 52.91 12,812,372 2136415 234,396 108 Source: BBS, Bangladesh Agriculture Census 2008 7.10.3.2Land Area and Use 351. Total land area in the project districts is 4.2 million acres (1.7 million ha). The lands as per their use pattern can be classified under fallow, cultivated, forest, irrigated and river. Except in Chittagong and Khulna, more than 50% of the land in the PA is under cultivation. About 25% land in Chittagong and 56% land in Khulna is under forest area. On an average 29% land is under irrigation and 4% is under rivers. Table 7.41 gives the land use pattern in the project area. The differences in land-use pattern have also other implications such as occupation and livelihood sources of the affected households and business. Table 7-41: Ownership of Farm Land in the Project Area Project Total Area Proportion of land by type (%) District (Acres) Fallow Cultivated Forest Irrigated Under Barisal 658,859 land 5.64 Land58.15 Area 11.99 Area18.47 River 5.75 Bramhanbaria 250,745 2.10 60.13 0.16 33.73 3.88 Chittagong 564,288 1.77 45.12 25.14 22.05 5.92 Dhaka 1,100,369 0.93 57.44 3.30 32.75 5.57 Khulna 464,756 1.32 33.34 56.18 7.64 1.52 Mymensingh 651,965 0.05 56.33 3.99 38.89 0.73 Narayanganj 69,492 2.01 51.52 0.20 38.41 7.87 Tangail 443,621 0.82 52.33 8.42 36.54 1.89 Total PA 4,204,095 1.83 51.80 13.67 28.56 4.14 Source: BBS, Bangladesh Agriculture Census 2008 7.10.3.3Housing Status 352. Housing demonstrates the living standard and social status of peoples in Bangladesh. Pucca houses (constructed with bricks and mortar) indicate richness while jhupri type structures are used by the poor and vulnerable section of the people. Majority of the population in the project area are using kutcha structures made of corrugated iron (CI) sheets, wood and bamboo and the middle class people are using semi-pucca houses with CI sheet in roof and bricked walls. Around 80% of the population in Barisal, Brahmanbaria, Mymensingh and Tangail are using kutcha houses which are the least in Dhaka (16%). On an average, 16% of the project area peoples use pucca structures and another 20% use semi-pucca structures. Users of pucca and semi-pucca houses are higher in Dhaka, Chittagong, Narayanganj and Khulna and proportions of households using pucca structures are 45.6%, 25.0%, 20.7% and 18.3% respectively and those of semi-pucca structures are 36.6%, 20.6%, 33.6% and 23.0% respectively. Users of Jhupri houses are the highest in Chittagong – 6% and the lowest in Brahmanbaria – 1.1%. Table 7.42 shows the details of housing status of the project area population. Table 7-42: Housing Pattern in the Project Area Proportion of households by Housing type (%) Project Districts Pucca Semi-Pucca Kutcha Jhupri Barisal 7.3 10.9 80.0 1.8 Brahmanbaria 8.2 13.7 77.0 1.1 Chittagong 25.0 20.6 48.3 6.1 Dhaka 45.6 36.6 15.9 1.9 Khulna 18.3 23.0 56.6 2.1 109 Proportion of households by Housing type (%) Project Districts Pucca Semi-Pucca Kutcha Jhupri Mymensingh 3.6 12.4 80.3 3.7 Narayanganj 20.7 33.6 44.5 1.2 Tangail 2.8 6.5 89.1 1.6 Total project Area 16.4 19.7 61.5 2.4 Source: BBS, Population and Housing Census 2011 7.10.3.4Employed Population 353. The project area has a population of 38.805 million and only 10% of the population is employed in various sectors including agriculture (43%), industry (17%) and service (40%). Employed population is the highest in Mymensingh with respect to total district population and the lowest in Barisal. About 14% of the population in Mymensingh is employed followed by Tangail (14%), Narayanganj (11%), and Brahmanbaria (10%). Only 9% of the population in Dhaka, 8% in Khulna and 7% in Barisal are employed. See Table 7.43 for details. Table 7-43: Occupation by Male and Female District Employed Agriculture Industry Service population against Male Female Male Female Male Female Barisal total population 6.61 107383 3737 8840 993 27342 5383 (%) Brahmanbaria 10.33 192082 8330 18132 2822 61806 10080 Chittagong 7.56 188033 10294 69862 36073 221082 50246 Dhaka 9.35 109595 4999 174498 105486 521772 209959 Khulna 7.72 89334 5872 17842 4715 47159 13995 Mymensingh 13.59 493383 13030 36896 8800 122466 19843 Narayanganj 11.03 54278 1987 83773 41164 116044 28027 Tangail 13.55 342522 7526 35499 7431 84536 10904 Total PA 9.88 1576610 55775 445342 207484 1202207 348437 % by sex 96.58 3.42 68.22 31.78 77.53 22.47 % by Sector 42.56 17.02 40.42 Source: BBS, Population and Housing Census 2011 7.10.3.5Poverty 354. Poverty is the state of poorness. It refers to various forms of economic, social and psychological deprivation among the people who lack adequate resources, control or access to power for achieving a minimum level of living. It can be earmarked by income level of the household. The concept of absolute poverty is the minimum level of income that is needed for physical survival. Thus a poverty line can be defined as the minimum level of household income that can be able to purchase a bundle of goods and services to satisfy the basic needs of the household. The Household Income and expenditure Survey (HIES) 2010 used the Cost of Basic Needs (CBN) method to measure poverty incidence. The HIES 2010 have been measured two types of poverty: moderate poverty and extreme poverty. Extreme poverty line is the minimum income to support basic foods and the moderate poverty line is the income to support basic food and non-food expenses. 355. Poverty in the national level has been reduced over the 5 years since HIES 2005 to 31.5% in 2010 from 40% in 2005. Table 7.44 indicates that incidence of poverty is the highest in Barisal division and the lowest in Chittagong division. Poverty persists in both urban and rural areas in Barisal and Khulna divisions while urban poverty is much less in Chittagong and Dhaka divisions. 110 Incidence of extreme poverty is also the highest in Barisal division, almost double the other divisions. Extreme poverty in the project area is close to the national average due to the higher incidence in the Barisal division. In other areas, the incidence is lower than the national average. Incidence of moderate poverty in the project area is 32.1% again due to higher rate of poverty in the Barisal division. Table 7-44: Incidence of Poverty in Project Area PA Division Extreme poverty Moderate poverty National Rural Urban National Rural Urban Barisal 26.7 27.3 24.2 39.4 39.2 39.9 Chittagong 13.1 16.2 4.0 26.2 31.0 11.8 Dhaka 15.6 23.5 3.8 30.5 38.8 18.0 Khulna 15.4 15.2 16.4 32.1 31.0 35.8 Total PA 17.7 20.6 12.1 32.1 35.0 26.4 Bangladesh 17.6 21.1 7.7 31.5 35.2 21.3 Source: BBS HIES 2010 7.10.4 Education 356. Education plays an important role in eradication of poverty and enhancing social wellbeing. Poverty is negatively correlated with the level of education. The Poverty Monitoring Survey 2004 showed that poverty incidences of the literate were much lower than the illiterates. This was true for both semi-urban and rural areas, but the difference in poverty incidence between literates and illiterates were well pronounced in case of urban areas. Overall, literacy among the project area population is 55.43% which is higher than the national average (51.8%). Student – institution ratio is also higher, meaning more students are enrolled in the educational institutions in the project area. 7.10.5 Literacy 357. According to the population and housing census 2011 (PHC 2011), the project area population has a literacy level of 55.43% which is higher than national average. Literacy rate is the highest in Dhaka (70.50%) followed by Barisal (61.2%), Khulna (60.1%), Chittagong (58.9% and Narayanganj (57.1%). Literacy rate remained below average in Brahmanbaria, Mymensingh and Tangail districts. Although Bangladesh has advanced in female education through various interventions, there is still discrimination between genders in education. Literacy rate among male is still higher than the female populations. Except in Tangail, literacy rate is higher in the male population in all the project districts. . See Table 7.45 for details. Table 7-45: Literacy rate by district and gender District Total Male Female Barisal 61.20 61.90 60.00 Brahmanbaria 45.30 45.70 44.90 Chittagong 58.90 59.80 50.80 Dhaka 70.50 73.60 66.90 Khulna 60.10 64.30 55.95 Mymensingh 43.50 44.90 42.20 Narayanganj 57.10 59.50 54.60 Tangail’ 46.80 50.00 51.00 Total PA 55.43 57.46 53.29 National 51.80 54.10 49.40 111 7.10.6 Educational Institutions 358. Almost all the universities in Bangladesh are located in the project area as it includes the major cities of the country. About 17% of the primary schools, 57% of the secondary schools, 27% of the colleges and 92% of the universities in the country are located in the project area. Number of students in these institutions is also much higher than the national average. Number of students in primary schools is 1.8 times the national average, which is 1.4 times for secondary schools and 1.8 times for colleges. Table 7.46 shows the details of educational facilities in the project area. There is no university in Brahmanbaria and Narayanganj districts. Table 7-46: Number of Educational Institutions District Primary Schools Secondary Schools Colleges Universities No. Student/ No. Student/ No. Student/ No. Barisal 3,060 School 760 743 School 3,128 111 College 103,003 1 Brahmanbaria 1,040 2,731 194 14,642 35 15,473 Chittagong 3,106 2,452 866 8,795 181 184,094 14 Dhaka 1,464 8,227 802 15,017 300 202,066 56 Khulna 1,249 1,856 404 5,739 82 35,244 2 Mymensingh 1,798 2,842 453 11,281 72 46,080 6 Narayanganj 519 5,681 131 22,505 23 30,330 Tangail’ 1,561 2,309 380 9,487 61 34,454 1 Total PA 13,797 3,357 10,546 11,324 865 81,343 80 Bangladesh 80,397 1,792 18,500 7,786 3,150 45,728 87 % in PA 17.16 187.35 57.01 145.44 27.46 177.88 91.9 Source: Bangladesh Bureau of Statistics, Zila Profile, 2007 7.10.7 Gender Issues 7.10.7.1General 359. Gender, according to the World Bank definition, refers to culturally based expectations of the roles and behaviors of males and females. The term distinguishes the socially constructed from the biologically determined aspects of being male and female. Unlike the biology of sex, gender roles and behaviors can change historically, sometimes relatively quickly, even if aspects of these roles originated in the biological differences between the sexes. Because the religious or cultural traditions that define and justify the distinct roles and expected behaviors of males and females are strongly cherished and socially enforced, change in gender systems often is contested. 7.10.7.2Gender Discrimination 360. Women in Bangladesh are gradually coming forward in national development endeavors getting pace in social sector in terms of equity and empowerment. Despite credible successes in poverty reduction and gender equity, significant gender disparity still exists in income-poverty. First, there is the general incidence of extreme poverty for women headed, women-managed and women- supported households. Second, women workers earn considerably less than men workers. Third, lower average consumption for women is also evident from persistent gender inequality in severe malnutrition, mortality and morbidity. In Bangladesh 20–30 per cent of households are headed by women, and 95 per cent of these are considered to fall below the poverty line. 361. The women folks are continuously fighting against poverty and patriarchy, along with malnutrition, high maternal mortality rate, lack of access to resources, environmental degradation, lack of access to health, lack of paid employment, discriminatory wage rates, strict gender division of 112 labor, and lack of scope to exercise political rights. Poor women suffer more than men (and than better-off women) from poverty, hunger, malnutrition, economic crises, illiteracy, environmental degradation and disaster-related problems and become victims of violence and political instability. They are also exposed to exploitation and gender-based violence, excluded from decision making and education and deprived of their right to adequate health and nutrition. 362. Women do not enjoy land and property rights, have lower levels of education than men, work in the informal sectors and experience restricted mobility. The continuing fragmentation of holdings is leading to a loss of security for women from the family network and their normative entitlements to social support beyond the family are weakening. Thus women are becoming more vulnerable to extreme poverty and destitution. Women’s work possibilities outside the household have reduced as household asset base has been declined. Women’s involvement in field wage labor is outweighed by technological displacement of paddy husking, rice milling and other work (Bridge, 1994). Despite state interventions for women empowerment and gender equality, women are lagging behind in case of education, employment and other social development sectors. 7.10.7.3Gender Status in Project Area 363. Gender roles and relations between male and female in the project areas are typical of the Bangladesh society at large. Women constitute 49.6% of the total population in the project area. Compared to men, women are lagging by 4.17% in literacy achievements and they constitute 15.94% of the total employed population. In the traditional male dominant society in Bangladesh, men have easy access to livelihood earnings. Interactions and simple assessment by consultation brought forth the gender inequality with employed women earning about 15% less than their male counterparts. The gender gap in education at present is drawing to a close at an impressive rate at primary and secondary levels. But the gap still persists at higher secondary and tertiary levels. At all secondary levels of education, the drop-out rates are higher for girls than boys. Women in the impact area villages in general have no access over leadership in village and also in their families. In recent years, some of the women got access to the local leadership and they are now members of Union Parishad and municipalities. Poor women have little control over family resources unless it is women headed or have access to micro-credit. Recent developments indicate that women are being gradually regarded instrumental in family economy and decision-making. 7.10.7.4Women and Food Security 364. Women play a major and crucial role in food production in Bangladesh. Women constitute of 45.6% of the total farming population. They maintain the dual responsibility of farm and household production. Despite their routine domestic work, women are actively involved in agricultural production. Women in rural areas are generally responsible for most of the agricultural work in the homestead which ranges from selection of seeds to harvesting and storing of crops. About 60-70% of women from landless and near-landless households work as agricultural wage laborers. The role of women in rice production is already substantial and expanding further. Despite impressive gains in public participation over the last two decades, women in Bangladesh remain particularly vulnerable to poverty and food insecurity. It is women who primarily bear the brunt of household food insecurity. Over 95% of women headed households, which account for 8% of rural households, fall below the poverty line.13 13 Oxfam International, Food Insecurity of Women in Bangladesh- The Causes, Effects and Solution, posted at Oxfam website: http://oiyp.oxfam.org.au/blog/food-justice/ accessed on 14 November 2012 113 7.10.8 Coastal Population and Food Security 7.10.8.1Coastal Population 365. Bangladesh has a coastline of 710 km along the Bay of Bengal. About 1/3rd of the land area of the country along the coastline is categorized as coastal zone is at the risk of cyclone, tidal surge and salinity intrusion. The coastal zone covers 19 districts14, together account 32% of the area and 28% of the population of the country. The principal means of livelihood of the coastal population is agriculture farming. According to a WFP study in the Sidr hit area in December 2007 (60 sample villages), nearly one third (32.5%) of the households were involved in farming either in their own land (15.6%), in leased in land (5%), share cropping (4.2%) or work as an agricultural wage labourer (7.7%). Nearly one quarter of the households (24.7%) were earning their primary livelihood by casual labour. Fishing was the third most common livelihood, representing approximately 16% of households. Nearly ten percent (9.7%) of families were engaged in providing transport services (Rickshaw/van/boat) as their principal livelihood. All these occupations cumulatively provide livelihoods to 83.2% of households. The remaining 17% included primarily trade or own business, salaried employment, remittances, and others. 366. Food security in Bangladesh is characterized by considerable regional variations. Exposure to natural disasters is one of the major factors of food insecurity. According to poverty map 2005, there is a similarity between levels of poverty and levels of food insecurity. Poverty persists in the coastal belt due to frequent disasters and lack of infrastructures. According to a WFP survey in 2007, the coastal population largely represents the poor as 47% consider them extreme poor, 41% poor, 11% middle and less than one percent well-off. According to the Household Income and Expenditure (HIES) survey 2005, about 52% of the households in Barisal division were poor in 2005. Within the 52%, an estimated 36% were below the lower poverty line, and described as extreme poor. HIES 2010 assessed that poverty incidence in the coastal area has been reduced to 39% in 2010. 7.10.8.2Grain Storage at Household Level 367. The major cereal grains in Bangladesh (rice, wheat and maize) are often kept in storage for a considerable period. Cereal grains are stored by farmers to meet their own consumption and for seeds. The produce thus retained is estimated to vary from 10 to 100% of the production. The average retention is about 70% of the produce. Cereal grains are stored either in containers or in bulk. The containers in Bangladesh include matka or large earthen pots, and gunny bags (See Figure 7.16). Figure 7-16: Grain Storage at Household Level 14 Bagerhat, Barguna, Barisal, Bhola, Chandpur, Chittagong, Cox;s Bazar, Feni, Gopalganj, Jessore, Jhalokati, Khulna, Lakshmipur, Narail, Noakhali, Potuakhali, Pirojpur, Satkhira and Shariatpur. – WARPRO, 2004, Living in the Coast, Problems, Opportunities and Challenges. 114 368. Rural storage of cereal grains accounts for about 80% of the produce and is accomplished in traditional storage systems. The techniques used in traditional storage are embedded in custom and has passed down through generations. The type of foodstuff and size of the crops determine the design and capacity of these facilities. There are about eight different types of storage systems used at the farm level in Bangladesh. Among these, dhangola (medium and large sized cylindrical or rectangular bin), bed (cylindrical medium capacity bin), and dole (small capacity cylindrical bamboo-made structure) are common types of storage systems. Among bamboo structures, the most commonly used ones are dole and bed. The dole has a bottom as an integral part of it, but the bed and dhangola do not. The common size of dole is about 0.6 m in diameter and 1 m in height, and the capacity is 240 to 450 kg. The bed is about 1.5 m in height and 1.5 m in diameter, and its capacity is 700 to 1200 kg. The rectangular dhangola is about 7 m in length, 3.5 m in width and 3 m in height, and its capacity is 4000 to 40,000 kg. The dhangola is stronger in construction and more costly than either bed or dole. Experimental studies show that all these three types of bins are suitable for storage of seeds of paddy from harvesting to sowing and that the dole is the best among the three. The optimum capacity of the bed and dole are 2450 kg and 750 kg, respectively. 7.10.8.3Loss of Cereal Grain and Crop Seeds 369. The level of avoidable post-harvest losses of stored cereal grain in Bangladesh is still unacceptably high and varies from 10 to 25% (Banglapedia 2006). The loss occurs partly due to insect and fungal attack during storage. Reducing post-harvest losses depends on proper threshing, cleaning, drying, and storage. Drying is the removal of excess moisture content from the grains to an appropriate level, usually 13-15% (wet basis). Cereal grains in Bangladesh are dried through traditional method of sun drying. In this method, moist crops are spread on a flat surface, commonly of beaten earth, directly in the sun's rays for a certain time. 370. Various assessments after the Cyclone Sidr 2007 provide the information that many of the affected households in the coastal area lost their food and crop seed stocks in the disaster. The WFP study indicates that about 25% of the households in the coastal zone had crop seed stock before the cyclone. The cyclone made complete damage to the seed stock of 10.5% of these households and another 11.5% experienced partial loss15. 15 WFP, Food Security Assessment after Sidr Cyclone, December 2007 115 8 IMPACT ASSESSMENT AND MITIGATION 371. This Chapter presents the assessment of the potential environmental and social impacts and recommends appropriate mitigation measures to address these potential impacts. 8.1 Environmental Impact Assessment and Mitigation 8.1.1 Environmental Impact Screening Snapshot 372. As part of the environmental impact assessment process, a screening matrix was used tailored specifically to the proposed Project, focusing the potential environmental impacts during the design, construction and operation phases. The matrix examined the interaction of project activities with various components of the environment. The impacts were broadly classified as physical, biological and social, and then each of these broad categories further divided into different aspects. The potential impacts thus predicted were characterized as follows:  High negative (adverse) impact;  Low negative impact,  Insignificant impact,  High positive (beneficial) impact,  Low positive impact, and  No impact. 373. The matrix is provided in Table 8.1 (next page). 374. The negative impacts predicted in this manner were the ‘unmitigated’ impacts. Appropriate mitigation measures were recommended as part of this EIA, thus reducing the occurrence possibility and severity of the potentially adverse impacts. The potentially negative impacts identified through this process are discussed in the subsequent sections. 116 Table 8-1: Environmental and Social Screening Matrix (Unmitigated) Physical Biological Social and Socioeconomic Impacts on Agriculture and Damage to Infrastructure Erosion/Contamination Water Availability and Surface Water Quality Blocked Access Routes Groundwater Quality Noise and Vibration Natural Vegetation Vehicular Traffic Land Acquisition Aesthetic Value Cultural Issues Project Phases and Activities Safety Hazard Gender Issues Public Health Consumption Air Quality Flooding Wildlife grazing Soil Design Phase Site Selection N N N N N N N H N N H H N N N N N N N Construction Phase Contractor Mobilization 0 H 0 0 0 0 0 0 L H 0 0 H H L H 0 L L Equipment / Material 0 H 0 0 0 0 0 0 L H 0 0 H H L H 0 0 0 Transportation Construction Camp Establishment L L L 0 0 L 0 L L H 0 L L H L H L L L Operation of Construction Camp H H H H H 0 0 0 0 H 0 0 H H H H 0 H L Site Clearance H H L 0 0 H 0 0 H H 0 0 H H H H L 0 L Borrow and disposal area H L L 0 0 H 0 0 H H H 0 H H H 0 H 0 L management Excavations H H L L 0 0 0 0 H H 0 0 H H H H L 0 L Foundations H H L L L 0 0 0 H H 0 0 H H H H L 0 L Fabrication of Silos H H L L 0 0 0 0 H H 0 0 H H H H L 0 L Installation of Machinery and H H L L 0 0 0 0 H H 0 0 H H H H L 0 L Equipment Demobilization 0 H 0 0 0 L 0 0 L H 0 0 H H L H 0 L L Operation Phase Operation of Machinery and H H H 0 L 0 0 0 0 H 0 0 0 H 0 H 0 0 0 Equipment Fumigation H H 0 0 0 0 0 0 0 0 0 0 0 H 0 H 0 0 0 Repair and Maintenance H H H 0 0 0 0 0 0 H 0 0 L H 0 H 0 0 0 Grain Transportation 0 H 0 0 0 0 0 0 H H 0 0 H H H H 0 0 0 Key: H: High negative impact; L: Low negative impact; 0: insignificant/negligible impact; +L: low positive impact; +H: High positive impact, N: no impact. 117 8.1.2 Potential Impacts during Design Phase 375. The potentially significant negative impacts associated with the decisions made during the design phase. The possible impacts need to be considered during design phase are as follows:  Risk of flooding and inundation.  Loss of agricultural and grazing land; These potential impacts are discussed below. 8.1.3 Risk of Flooding and Inundation 376. Any flooding and inundation will altogether undermine and negate the very purpose of these silos. Flooding normally occurs in Bangladesh during the monsoon season from June to September. The catastrophic floods of 1987 occurred throughout July and August and affected 57,300 km2 of land, (about 40% of the total area of the country). The flood of 1988 was also of catastrophic consequence, occurred throughout August and September. The waters inundated about 82,000 km2 of land, (about 60% of the area). In 1998, over 75% of the total area of the country was flooded. The 2004 flood was very similar to the 1988 and 1998 floods with two thirds of the country under water. The peak water depth and maximum discharge data at four different locations of Bangladesh (Aricha, Bahadurabad, Bhairab Bazar, Hardinge Bridge) are collected for the period 1975 to 2009 from the database of Bangladesh Water Development Board and Institute of Water Modeling (IWM) of Bangldesh. From the analyses of flood frequency, it is found that the country’s worst flood of 1988 has the recurrence interval of 40 to 100 years and the 2004 flood has the recurrence interval of 20 to 100 years. The following table shows the different historical floods with its estimated recurrence interval in years. Table 8-2: Estimated Flood Recurrence Interval Flood reference year Recurrence interval of flood (year) 1975 9.99 1990 2.33 1988 40-100 1998 10-100 2004 20-100 377. Other than Madhupur, all other seven selected sites for the proposed silos are near the rivers. The historical data of flooding for the sites are as follows. Table 8-3: Flooding History and Land Elevation Information of the Sites Average GL of sites Location with Type of above/below of Drainage Silo Site respect to the land plinth level of Flooding Status system river existing godowns Low The highest tidal Western Bank marshy Natural drainage. water level is 1ft of the River Below of 3 ft There is no Barisal land/ditch below the top of Kirtankhola land sewerage system. the river bank. 118 Average GL of sites Location with Type of above/below of Drainage Silo Site respect to the land plinth level of Flooding Status system river existing godowns Low Water are The site is not undulated accumulates in affected by flood land the pond inside water. Highest Narayanganj Shitalakkha Below of 3 ft the compound flood water level Central Supply river is in the and natural flow was 2’-0� above Depot (CSD) west towards the internal road level river. Sewerage in 1998. system exists. Flat low Natural drainage. The proposed land land Sewerage system is 2�-6� below Buriganga exists plinth level of river is in Below of 2.5 ft exiting go down. Dhaka CSD South The site was flooded by 3’-6� in 1988 flood. Low Natural drainage. Highest flood Site is located undulated Sewerage system water level was on the east side Below of 3 ft Ashuganj land exists 1’-0� above of river internal road level Meghna in 1998. Low Natural drainage. The site is not marshy Sewerage system affected by flood Site is Situated land/ditch exists water. Water level on the land is 1’-0� below the Southern bank Below of 2.5 ft top of Mymensingh of the river Mymensingh – Brohmaputra Tangail high way during monsoon period. Low Natural drainage. The proposed site undulated Sewerage system is located on the The site is land exists western bank of located on The the river Bhairab. Maheshwar western Bank Below of 4.5 ft Water level is 1’- Pasha (Wheat) of the River 0� below the top Bhairab of concrete jetty during the tidal period. Low Natural drainage. Not affected by Chittagong No river undulated Below of 1.5 ft Sewerage system flood (Wheat) land exists High land No sewerage and The site is not drainage system affected by flood No existing water. The Madhupur No river godowns proposed site is located on the Modhupur high land. 119 378. The historical data shows Dhaka, Narayanganj, Ashuganj, Mymensing and Maheshwar Pasha were inundated in last 30 years and Madhupur does not have any natural drainage system. In addition the existing godowns are already higher than the existing ground level. From consultation, it was found, water entered to the Narayanganj Godown during 1988 flood. The significance of this unmitigated impact is assessed as high and long term. Huge losses are likely to take place in case of flooding 379. Mitigation Measures. The following measures will address the flooding and inundation risks:  The design will ensure that facilities remain safe from flooding and inundation.  The site selected for the facilities will be sufficiently higher than the maximum water level during high tides and storm surges.  Appropriate raising of the foundations will be carried out if the available sites are not currently at the appropriate level.  Appropriate drainage system will be included in the facility design. 380. Residual Impacts. With the help of the above measures, the impact due to flooding and inundation will be adequately reduced. Therefore the significance of the residual impacts will be low to medium. 8.1.4 Loss to Agriculture and/or Grazing Land 381. The proposed silos will be constructed either within the existing facilities or at the government- owned vacant land. Table 8.3 shows other than Madhupur each of the sites may need to raise to meet the minimum height to avoid flood level. Each of the site will need soil. There is paddy field at the south of Ashuganj site, and to the east of the Madhupur site, Government khas lands under District Commissioner are used to cultivate for production of banana and pineapple. Collecting top soil from the existing agricultural land will cause loss of agricultural production. Storage of construction material on the agricultural land, disposal of debris from the Dhaka CSD, Maheswarpasha CSD and possibly Narayanganj will cause loss of agriculture and grazing land for short time. Mitigation Measures  The possible sources of material should be identified at the design phase. The contractor needs to comply with the identified sources. If necessary the contractor will identify the sources of material which will not impact the existing agricultural land and grazing land.  If the adjacent agriculture land is used for collecting earth, the contractor will ensure the topsoil are put aside during collection and put back to the earlier place after collection.  The location of stockpiling of construction material, construction camp and debris from the demolished structure should be identified. The locations will neither the agricultural/grazing land nor the location which will create problem to the adjacent areas including residential, school, mosque etc and local people. 8.1.5 Damage to the Existing Infrastructure 382. Establishment of construction camp, pile driving and other civil works for construction of silo, stock piling of construction material, increasing traffic during construction and operation will impact the existing social infrastructure in the vicinity, if those are not addressed properly during the design phase. The list of structures within the vicinity of 500m of the sites are as follows: 120 Table 8-4 Existence of Important Infrastructure within 500 m from the DG Food Demarcated Area Ashuganj Barisal Chittagong Dhaka Madhupur Moheswarp Mymensin Narayanga asha gh nj 2 schools, 1 Four schools KEPZ, TSP Three Boundary 4 mosques, 3 1 river 1 mosque madrasa, 4 and 2 colleges, Complex mosques wall of madrasa, 1 crossing and Strip of mosques, 1 4 mosques and and mazars, BFIC, school for public river bank community 2 churches, 6 residential Governmen use (for public graveyard private clubs, area, police t Khas land recreation) and Eidhah Martyrs’ station, one used for mausoleum school is pinepapple under and banana construction cultivation Mitigation Measures  The design will ensure location of stockpiling of construction material, construction camp and debris from the demolished structure has been identified. The locations will not create problem to the adjacent areas including residential, school, mosque etc and local people.  The contractor will come with the workplan which will identify the sources of material, the route of transportation to the site and construction time.  At the design period, a traffic management plan with the existing traffic and projection of increased traffic volume during the construction and operational phase should be developed to minimizing the noise pollution during construction and operation phase. 8.1.6 Damage due to Waste Disposal 383. Table 8.3 shows Barishal and Madhupur site has no sewerage system. However, other than Madhupur other sites have natural drainage system. Even though Dhaka, Narayanganj, Chittagong, Maheshwarpasha, Mymensing and Ashuganj have existing sewerage system, temporary establishment of construction camp may supersede the capacity of the existing system. If proper and adequate drainage and sewerage system and proper waste collection method is not provided that will create overflow of existing system, odor issue, public nuisance and pollution of river. Mitigation Measures  Proper waste management and disposal system should be considered during design period and done construction period for all sites.  Temporary workers camp and sanitary toilets for the workers should be installed before starting the work.  Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work.  The waste should not be disposed in near-by river at any mean. Responsibility  The Design Consultant will ensure the above environmental mitigation measures have been considered in the project design.  The contractor needs to comply with the identified measures and come up with the workplan addressing the environmental issues and mitigation measures with Environmental Action Plan (EAP) and submit with BoQ  DG Food will endorse the adequacy of the 121 EAP 8.2 Potential Impacts during Construction Phase 384. The potentially negative impacts likely to be caused by the construction activities include the following:  Loss of natural vegetation  Noise and vibration  Air quality deterioration including dust pollution  Soil and water contamination  Blocked access routes  Soil erosion  Safety hazard and public health  Loss of livestock grazing area  Damage to infrastructure  Aesthetic value  Social Conflict due to labor from outside  Water availability and consumption These potential impacts are discussed below. 8.2.1 Loss of Natural Vegetation 385. 450 trees will need to be felled to clear the land for constructing silos at the proposed sites, as shown in the Table 8.5 below. Table 8-5: Trees to be Cut Sl Name of Name of the Scientific name No. of Total no. of No the Sites tree matured trees trees directly affected 1. Barisal CSD Mahagony Swieteniamahogoni 44 69 Campus Koroi Albizzia lebbek 09 Dates (Khejur) Phoenix dactylifera 03 2. Narayangonj Mango M. indica 04 10 CSD Jackfruit Artocarpus heterophyllus 06 3. Dhaka CampusCSD Jackfruit Artocarpus heterophyllus 3 9 Campus guava 6 4. Ashgonj Silo eucalyptus PSIDIUM guajava 23 30 Campus Koroi lebbek tetrapleura EUCALYPTUS Albizzia 07 5. Mymensing Betel nut Areca catechu 5 159 CSD Coconut Cosos nucifera 106 Campus Koroi Albizzia lebbek 4 Mahogany Swieteniamahogoni 24 Jackfruit Artocarpus heterophyllus 6 Mango M. indica 4 Guava 1 PSIDIUM guajava 122 Banyan F. religiosa 1 Plum (Boroi) Ziziphus mauritiana 4 Krishnochura Caesalpinia pulcherrima 4 6. M. Pasha Mahogany Swieteniamahogoni 51 97 CSD Koroi Albizzia lebbek 17 Campus Coconut Cosos nucifera 28 7. Chittagong Mahogany Swieteniamahogoni 3 16 Silo Campus Mango M. indica 5 Jackfruit Artocarpus heterophyllus 1 Neem 1 Gamari AZADIRACHTA Gmelina Arborea 2 Rubber INDICA Hevea brasiliensis 2 Betel nut Areca catechu 1 Banyan F. religiosa 1 8. Madhupur Koroi Albizzia lebbek 01 60 Highland Akashmoni Acacia auriculiformis 47 mango M. indica 01 Banana Musa sapientum 04 Jackfruit Artocarpus heterophyllus 07 Grand 450 Total 386. The above table shows a number of vital species of trees will be cut. Specially in Mymensingh CSD the impacts due to tree cutting is major. The duration of the impact is long-term, irreversible and certain. The trees to be cut may not be all matured. Compensatory measures are possible but will take time to be effective. 387. Mitigation Measures. Compensatory tree plantation will be carried out within the facility and saplings five times the trees felled will be planted. Before starting the construction works, the contractor will prepare an inventory of the trees to be felled. The contractor will then prepare a tree plantation plan and the species to be planted and obtain approval from the Supervision Consultants. The plantation of trees will most likely take place towards the end of the construction phase. Appropriate maintenance and monitoring will need to be carried out to ensure survival and growth of the planted trees. 8.2.2 Noise and Vibration 388. The construction activities and increased vehicular traffic will generate noise and vibration which are likely to affect the nearby communities. Table 8-6: Number of Piles to be Driven Ashuganj Barisal Chittagong Dhaka Madhupur Moheswarp Mymensin Narayanga asha gh nj 1980 1040 2520 1140 1440 1590 1200 640 389. The above information shows the maximum noise and vibration for pile driving will be at Chittagong. As mentioned in the Table 8.4 Dhaka, Ashuganj, Maheswarpasa and Barisal have number of 123 social infrastructures within 500 m of contour. Barishal has a Martyr Monument in the vicinity of the silo site. The construction workers will be affected most due to the noise of pile driving. 390. Mitigation Measures. The following measures will address the potentially negative impacts of the Project associated with noise and vibration:  The contractors will ensure that the noise from the construction sites and camps complies with the national and WB standards.  Vehicular traffic through the communities will be avoided as far as possible. Project routes will be authorized by the Supervision Consultants.  Vehicle speeds will be kept low, and horns will not be used while passing through or near the communities.  Vehicles will have exhaust silencers to minimize noise generation.  Nighttime traffic will be avoided near the communities.  Movement of all project vehicles and personnel will be restricted to within work areas, to avoid noise pollution.  Working hours for construction activities within/near the communities will be limited to between 8 am and 6 pm.  Liaison with the community will be maintained. Grievance redress mechanism will be put in place to address the community complaints.  Proper scaffolding is needed to protect the Martyr Monument in Barishal. The contractor needs to observe regularly to check if there is any crack in the monument due to pile driving. If so, they immediately need to stop the work and inform the archeological department through the implementing agency.  The construction workers need to be provide The workers will use safety device for protection of ears (earmuffs and ear-plugs etc.) following IFC guideline  Silo facility foundation shall be designed to minimize vibration effect. 8.2.3 Air Quality 391. Construction machinery and project vehicles will release exhaust emissions, containing carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOX), and particulate matter (PM). These emissions can deteriorate the ambient air quality in the immediate vicinity of the project sites. Furthermore, construction activities such as excavation, leveling, filling and vehicular movement on unpaved tracks may also cause fugitive dust emissions. These emissions pose health hazards for the nearby communities. This unmitigated potential impact is characterized and assessed as follows: Impact Parameter Nature of Project Impact Characterization of Project Impact Duration of impact Medium term (during construction phase Moderate only) Spatial extent May extend beyond Project boundary Moderate (silo sites and access routes) Reversibility Reversible in short term Minor 124 Impact Parameter Nature of Project Impact Characterization of Project Impact Legal standards Unmitigated emissions will breach the Major national standards Likelihood of impact Certain Major Sensitivity Moderate impacts on nearby Medium Impact Significance communities Moderate Residual Impact if Construction related air pollution Low to Negligible mitigated 392. Mitigation Measures. The following measures will address the potentially negative impacts of the Project associated with air quality deterioration:  The vehicular and equipment exhaust will comply with the national standards.  Contractor to ensure compliance with the standard for ambient air quality.  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities.  Liaison will be maintained particularly with the communities near the camps and work sites. 8.2.4 Soil and Water Contamination 393. Wastes particularly effluents from the works sites may contaminate the soil and water. The contractors’ camps will generate domestic solid waste and waste water including sewage. The contractors’ workshops will generate oily water, waste oils, oily rags, and other similar wastes. The stores and warehouse will generate solid waste such as empty cement bags, cardboards, and wooden crates. Improper disposal of these waste streams can potentially contaminate the soils and water resources of the area. Soil and water contamination can potentially have negative impacts on the local community, natural vegetation, agriculture, and biological resources of the area including aquatic flora and fauna. 394. Table 8.3 shows Barishal and Madhupur site has no sewerage system. Even though Dhaka, Narayanganj, Chittagong, Maheshwarpasha, Mymensing and Ashuganj have existing sewerage system, temporary establishment of construction camp may supersede the capacity of the existing system. If proper and adequate drainage and sewerage system and proper waste collection method is not provided that will create overflow of existing system, odor issue, public nuisance and pollution of river. 395. Deep foundation will be needed for the silo construction. The pile will be driven through the groundwater in all sites. The groundwater quality may be affected. Table 8-7: Pile driving into GW= Pile length – GW depth (m) Ashuganj Barisal Chittagong Dhaka Madhupur Moheswarp Mymensin Narayanga asha gh nj 19.8 30 29.58 29.75 17.84 37.1 27.73 19.75 396. Mitigation measures. The following measures will address the potentially negative impacts of the Project associated with soil and water contamination: 125  The contractors will prepare separate waste management plans for each site in accordance with international best practice.  No untreated waste effluents will be released to ground or water.  Vehicles and equipment will not be repaired in the field. If unavoidable, impervious sheathing will be used to avoid soil and water contamination.  For the domestic sewage from the construction camps and offices, appropriate treatment and disposal system, such as septic tanks and soaking pits, will be constructed having adequate capacity. The contractors will submit to the Supervision Consultants the plans for the camp layout and waste disposal system, and obtain approval. As stated above, the camps will preferably be established inside the existing CSD facilities as far as possible.  Waste oils will be collected in drums and sold to the recycling contractors.  The inert recyclable waste from the site (such as card board, drums, broken/used parts, etc.) will be sold to recycling contractors. The hazardous waste will be kept separate and handled according to the nature of the waste.  Domestic solid waste from the construction camps will be disposed in a manner that does not cause soil contamination. The waste disposal plan submitted by the contractor(s) will also address the solid waste. 397. Residual Impacts. With the help of the above measures, the potential impacts associated with soil and water contamination are likely to be adequately addressed, and hence the significance of the residual impact will be low. 8.2.5 Blocked Access Routes 398. The silo site of Dhaka, Mahaeshwarpasha, Ashuganj and Barishal are in congested area. The construction camps, construction activities and stock-piling of construction material can potentially block the access routes and roads inside and in the vicinity of the silo sites. In Dhaka and Maheshwarpasha and possibly in Narayanganj, the debris of the demolished structure may block the access routes. 399. Mitigation measures. The following mitigation measures will be implemented to address the potential impacts associated with the blocked routes:  The contractor will prepare traffic management plan prior to commencing mobilization and obtain approval from the Supervision Consultants.  The construction facilities (work areas, camp sites, workshops, others) will be established after obtaining approval from the Supervision consultants and ensuring that no roads or routes are blocked.  In case of the blockage of the existing routes, alternate routes will be identified in consultation with affected communities. 400. Residual Measures. With the help of above measures, the potential impacts associated with blocked routes are likely to be adequately addressed. Therefore the significance of the residual impact is expected to be low. 126 8.2.6 Soil Erosion 401. The proposed all sites are located in generally flat areas and existing site is not prone to soil erosion. However, certain construction activities can potentially soil erosion at the proposed sites particularly during the rainy season. Soil erosion can potentially affect the integrity of the existing and proposed buildings at the sites, can cause water ponding particularly during rainy season, and can also affect the trees and natural vegetation of the area. The construction activities which could potentially cause soil erosion include the following:  Construction camp establishment  Site clearance  Excavation  Obtaining material from borrow sites  Construction of silo foundations. 402. Mitigation Measures. The following mitigation measures will help avoid/mitigate any soil erosion at the proposed silo sites:  Material borrowing and disposal plan will be prepared and approval obtained from the Supervision Consultants. .  Cultivation fields will be avoided for borrowing material to the extent possible.  Written consent of the land owner will be obtained for material (soil) borrowing. A standard form should be prepared and used for this purpose.  The borrow and disposal areas will be re-contoured to avoid deep ditches or high mounds.  Photographic record (before, during and after) will be kept for the borrow and disposal areas.  Leveling and re-contouring borrow sites will be carried out.  Cut and fill at the proposed sites will be carefully designed, and ideally should balance each other. The surplus soil, if any, will be disposed at places approved by the Supervision Consultants (“Engineer�). Such sites will be selected after surveying the area and ensuring that soil deposition will not have any significant impacts, such as loss of productive land, blocked access, natural vegetation and disturbance to drainage.  If necessary, fill material for silo sites will be obtained from appropriate locations approved by Supervision Consultants. Such locations will be selected after surveying the area and ensuring that soil extraction will not have any significant impacts, such as soil erosion, loss of natural vegetation and disturbance to drainage.  Where the use of cultivated land is unavoidable for obtaining the fill material, the top 30 cm soil layer will be removed and stockpiled for redressing the land after removal of the borrow material. The excavation in such areas will be limited to 50 cm depth.  The fill material will not be obtained from any cultivation fields or orchards, unless the consent of the owner is obtained.  Areas from where the fill material is obtained or surplus soil deposited, will be landscaped to minimize erosion and hazard for people and livestock. 127  Construction camps will be located in a stable and flat area, requiring minimal devegetation and leveling. The contractor(s) will obtain approval from the Supervision Consultants for this purpose. The camps will preferably be located inside the existing CSD facilities.  Embankments and excavated slopes will not be left untreated/unattended for long durations. Appropriate slope stabilization measures will be taken per the design (eg, stone pitching).  Vehicular traffic on unpaved roads will be avoided as far as possible. Operation of vehicles and machinery close to the water bodies will be minimized.  After the completion of the construction works, the construction sites, campsites and other work areas will be completely restored. No debris, surplus construction material or any garbage will be left behind.  Photographic record will be maintained for pre-project, during-construction and post-construction condition of the sites. 8.2.7 Vehicular Traffic 403. The construction activities will cause an increase in the vehicular traffic on the local roads. Similarly, transportation of silo equipment and materials will also cause additional traffic on the access routes (roads and water ways). This increased traffic can potentially cause traffic congestions on roads and in waterways and also pose safety hazards for the nearby population particularly children. 404. Sensitivity study will reveal the anticipated traffic volume to assess the impact of traffic congestion. An example of sensitivity analyses are presented (used TRIP model is presented in the Annex 3) considering 10 tons/truck loading to identify the maximum allowable traffic loads for all the 08 sub project sites of phase-I using traffic survey data outside the sub project sites. The results of the sensitivity analyses are presented in the following Table. Table 8-8: Allowable Additional Simulated Vehicles Sl Sub project Site Present peak Allowable additional No rate of traffic simulated vehicles 1. Barisal CSD Campus 196 50 (vehicles/h) (trucks/h) 2. Narayangonj CSD Campus 224 25 3. Dhaka CSD Campus Not surveyed --- 4. Ashgonj Silo Campus 256 30 5. Mymensing CSD Campus 244 50 6. Maheshwarpasha CSD Campus 244 35 7. Chittagong Silo Campus 264 25 8. Madhupur Highland Not surveyed --- 405. And it is quiet anticipated that, the number of trucks carrying construction materials including cement, reinforcing bars, sand and stone chips should not exceed this rate of truck flow limit during construction. 128 406. Moreover, 40 ocean containers with silo equipments will be transported from Chittagong/Mongla port to all other sub project areas of the BMFSFP. According to the sensitivity example (Annex 5), there should not be any regular traffic congestion due to movement of these container vehicles. 407. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  The contractors will prepare a traffic management plan for each site and obtain approval from the Supervision Consultants. In particular, transportation and equipment and material will be astutely planned to avoid traffic congestion and other associated problems.  Project drivers will be trained on defensive driving practices.  Speed limits will be enforced for the Project vehicles.  Reduced speed near/through communities.  Liaison should be maintained particularly with the communities near the camps and work sites.  Safety signage should be placed at the work sites. 8.2.8 Safety Hazards and Public Health 408. The steel silo will be constructed on the base of the silo mentioned above. The factory fabricated galvanized steel sections of the silos and other steel structural members will be bolted with the vertical members of the silo bins to form the round outer skin of the silo as per the diameter of the bin. The upper cone of the silo will then be placed and constructed on top of this. Once the top cone has been placed on the first section the entire structure will be raised by a battery of special jacks placed at the base of the silo and another circular section added beneath it. The entire construction, till it reaches the required height, will thus be completed. The conveyor belts and other equipment of the silos will be connected with the system as the construction works progress. 409. The construction activities will involve operation of heavy construction machinery, vehicular traffic, excavation, filling operations and demolition of structures. These activities may pose some safety hazards to the local population. The fuel storage at the camp sites may also pose safety hazards for the construction staff as well as for surrounding population. Stockpiling of construction material in all sites and debris from the demolished structure may cause serious accident to the construction worker and people in the vicinity. 410. Slips and falls on the same elevation associated with poor housekeeping, such as excessive waste debris, fall of bolts during assembling of steel frames, loose construction materials/bolst, and uncontrolled use of electrical cords and ropes on the ground, are also among the most frequent cause of lost time accidents at construction sites. 411. Construction of steel silos may pose significant hazards related to the potential fall of materials or tools, as well as ejection of solid particles from abrasive or other types of power tools during assembling of the steel frames from height which can result in injury to the head, eyes, and extremities. 412. Vehicle traffic and use of lifting equipment in the movement of machinery and materials on a silo construction site may pose temporary hazards, such as physical contact, dust, emissions, and noise. Equipment operators have limited fields of view close to their equipment and may not see pedestrians 129 close to the vehicle. Center-articulated vehicles create a significant impact or crush hazard zone on the outboard side of a turn while moving. 413. Inappropriate waste disposal at the camps and construction sites, and air quality deterioration caused by the Project’s vehicular traffic and construction activities potentially pose health hazards for the construction staff and nearby population. 414. Unhygienic condition and unavailability of safe drinking water for the construction staff will expose them to health risks. In addition, influx of construction staff can potentially expose the nearby population to communicable diseases. The unmitigated potential impact is characterized and assessed below. Impact Parameter Nature of Project Impact Characterization of Project Impact Duration of impact Short term (during construction phase only) Minor Spatial extent May extend beyond Project boundary (silo sites Moderate and access routes) Reversibility Reversible Minor Legal standards - Minor Likelihood of impact Likely Moderate Sensitivity Severe impacts on nearby communities and along Major road/waterway traffic Impact Significance Major 415. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  The contractors will prepare site specific Health, Safety and Environment (HSE) Plan and obtain approval from the Supervision Consultants. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS.  The contractor will provide personal protective equipment (PPE) to the construction staff and will ensure its appropriate usage.  The construction staff will be screened for communicable diseases.  Availability of safe drinking water will be ensured for the construction staff.  First aid boxes will be made available at each construction site. Emergency phone numbers (including hospitals, Fire Department, and Police) will be displayed at key locations within the site. Each site will have an ambulance available.  The WBG’s EHS Guidelines will be included in the contract documents.  The construction sites will have protective fencing to avoid any unauthorized entry.  The project drivers will be trained for defensive driving skills.  Vehicular speeds near/within communities will be kept low to minimize safety hazards. 130  Camp sites will be selected with approval of the Supervision Consultants, as mentioned earlier. The camps will have periphery fencing to avoid any unauthorized entry.  Firefighting equipment will be made available at the camps and worksites.  The camp staff will be provided safety including fire fighting training.  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Waste management plan to be prepared and implemented in accordance with international best practice.  The contractor will prepare Demolition Work Plan for each site when necessary and obtain approval from the Supervision Consultants. The Demolition Work Plan should be prepared following BNBC.  Liaison with the community will be maintained.  An Engineer should be consulted before modifying a silo because a simple can drastically alter its structural ability. Equipment attached to a silo can impose dangerous loads. 416. Residual Impacts. Despite the implementation of the above measures, some safety hazards and risks are still likely to exist. Therefore the significance of residual impacts has been assessed as medium. 8.2.9 Livestock Grazing 417. Seven of the eight proposed sites for the silos are already inside the Food Department’s facilities. However, some livestock grazing was observed even inside some of these facilities. The construction activities are likely to negatively affect this grazing particularly at and in the immediate vicinity of the construction sites, construction camps and other Project facilities. 418. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Consultations will be carried out with the communities to be affected to identify alternate grazing areas.  The affected communities will be offered employment at the construction sites to compensate for any loss of grazing areas. 8.2.10 Damage to Infrastructure and Monuments 419. The construction activities may require removal of some existing infrastructure in Dhaka, Maheswarpasha and Narayanganj within the CSDs. In addition, there could be some inadvertent damage to the roads, electricity lines, water channels, jetties, and other structures during the construction activities, transportation of equipment and material, and associated vehicular traffic. The Barishal site has a Martyr Monument. Dhaka, Maheswarpasha, Barishal and Ashuganj in an area with number of infrastructure around. A number of 5-6 storied buildings are in close vicinity of the boundary wall of Dhaka site. These area will be affected by the deep pile driving. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  The condition of the infrastructure in the vicinity will be regularly monitored. 131  It will be ensured that no damage is caused to the monument at Barisal site.  Appropriately sized vehicles will be used to transport the material construction , minimizing the wear and tear of the transportation routes.  Proper scaffolding is needed to protect the Martyr Monument in Barishal. The contractor needs to observe regularly to check if there is any crack in the monument due to pile driving. If so, they immediately need to stop the work and inform the archeological department through the implementing agency.  All damaged infrastructure will be restored to original or better condition. 8.2.11 Aesthetic Value 420. Site clearance, tree felling, presence of construction material/machinery, and construction activities may potentially affect the aesthetic value of the area. 421. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Screens will be used at the site periphery  Landscaping and tree plantation will be carried out at the site and camps where possible.  Proper housekeeping will be regularly carried out at the site and camps. 8.2.12 Water Availability and Consumption 422. Water consumption during the construction phase (camp operation and construction activities) can potentially cause conflict with the existing water users particularly nearby communities. 423. Mitigation measures. The following mitigation measures will address the negative impacts of the Project associated with the water consumption:  Astute planning will be employed to conserve water at the construction sites and camps. Water will be procured in a manner that least affects the existing water users and local communities.  The contractors will submit the plan to procure and consume water for their construction as well as camp needs, and obtain approval from the Supervision consultants.  Extreme care will be taken when working close to wells and other water sources. Any damage caused by the project activities will be repaired. 8.2.13 Social Conflict 424. The presence of a large workforce, establishment of construction camps, Project-related traffic and construction activities may potentially cause conflicts with the nearby communities, privacy issues for the women and other similar problems. 425. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Liaison with the communities will be maintained throughout the construction phase.  Grievance redress mechanism will be established at each site (details are provided later in the document). 132 Responsibility  The contractor will execute the mitigation measures as mentioned in the Environmental Action Plan (EAP  The Supervision Consultant will regular monitor the activity  DG Food with the Sr. Environmental Specialist in PMU will ensure that al environmental mitigation measures are adequately addressed. 8.3 Potential Impacts during Operational Phase 426. The potentially negative impacts likely to be caused by the operation and maintenance (O&M) activities include the following:  Safety hazards and public health  Impact from Ancillary Facilities  Air quality  Soil and water contamination  Water consumption  Noise and vibration.  Vehicular traffic  Damage to the infrastructure  Aesthetic value. These potential impacts are discussed below. 8.3.1 Safety Hazards and Public Health 427. The O&M activities may pose some safety hazards particularly to the O&M staff. These may include electrocution, fall, burns, cuts and other body injuries, asphyxiation, and exposure to phosphine gas. The fuel storage at the silo facilities may also pose safety hazards for the O&M staff as well as for surrounding population. 428. Inappropriate waste disposal and air quality deterioration caused by the O&M activities potentially pose health hazards for the O&M staff and nearby population. Unhygienic condition and unavailability of safe drinking water for the O&M staff will also expose them to health risks. 429. O&M staffs are particularly exposed to the fumigants which may cause severe respiratory irritation. 430. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Each facility will prepare a site specific Health, Safety and Environment (HSE) Plan. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS. The HSE Plan will be made an integral part of 133 the Operational Manual of each facility. The Plan will particularly address procedures to handle aluminum phosphide and to prevent exposure to phosphine gas.  Material safety data sheet (MSDS) will be followed to handle aluminum sulphide and other hazardous chemicals.  PPE will be provided to the O&M staff.  HSE trainings will be provided to the O&M staff on a regular basis.  Availability of safe drinking water will be ensured at each facility.  First aid boxes will be made available at each construction site. Emergency phone numbers (including hospitals, Fire Department, and Police) will be displayed at key locations within the facility.  Firefighting equipment will be made available at the facilities.  The O&M staff will be provided safety including fire fighting training.  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Waste management plan to be prepared and implemented in accordance with international best practice.  Liaison with the community will be maintained. 8.3.2 Impact from Ancilliary Facilities 431. The silos will be equipped with several ancillary facilities like commercial scale grain chiller and dryer; commercial scale fumigation system; fuel storage; mechanical handling system; generator as power back up system. Air pollution and electricity consumption are the main problem due to commercialized refrigeration. Figure 8.1 shows an example of typical grain chilling procedure. Carbon di Oxide (CO2), Nitrogen Oxide (NOx) and Sulfur di Oxide (SOx), Suspended Particulate Matter (SPM) are the typical pollutants which are expected from the exhaust emission from silo and refrigerators. Figure 8-1: Process Grain Chilling Source: Frigortech Technial Manual 134 432. The drying facility, mechanical handling system will cause dust pollution and electricity consumption. Fuel storage for macines, Generator for electricity back up will cause air pollution or accidental hazard. If fumigation is necessary special attention and guideline needs to be followed for fumigant application. 433. Mitigation Measures. The following measures will address the potentially negative impacts of the Project associated ancillary facilities: Fumigation Application Guideline 434. In storage of food grains during operation of silos, aluminium phosphide (AP), will be used as a fumigant to prevent infestation so that the silo complex will not be cross contaminated. Phosphine gas from aluminum phosphine granules and the gas is bio degradable. It does not have any kind of residual effect on the food grains. AP is safe and well accepted all over the world as only a certified agency involved in the Pest Management would carry out this duty. The DGF has its own dose limit of using AP (12 gm/mt) in food grains and this dose will be followed also as guideline of fumigation in BMFSFP. DGF is authorized to use the indicative dose of fumigant agent in food grains. PHOSPHINE(hydrogen phosphide) (Phostoxin, Detia, Fumitoxin, Phostek, Gastoxin, etc.)  Widely used on stored grain.  Good sealing is critical.  Time is critical.  Probing greatly improves results.  Recirculation or modified technique for grain depths greater than 30 feet.  EPA exposure limit of 0.3 ppm.  Gas reading(s) required on each fumigation except in some situations.  SCBA above 0.3 ppm (gas mask okay to 15 ppm or escape). Fumigation Guidelines  Effective fumigations result from following several recommended guidelines including the following:  Level the grain below the vertical wall of the bins.  Remove or break up any crust on the grain surface.  Seal all cracks, making the bin as airtight as possible.  Fumigate when the grain temperature is between 70 and 90° F.  Keep the bin closed and post warning signs until the gas concentration is below 0.3 ppm.  DO NOT ENTERthe bin during or after fumigation until gases have been reduced to safe concentrations. (0.3 ppm). 135 435. Regular air quality for CO2, SPM, Sox and NOx should be measured. If any new facility is built associated with the silo operation, the implementing agency has to inform Bank for no objection. 436. Fire safety needs to be addressed at each site during construction and operation. The contractor should come up with a fire safety plan. DG food will ensure fire safety measure is appropriately addressed during operation phase. The fire safety should be according to the IFC Environmental Health and Safety Guideline for community. 8.3.3 Air Quality 437. Emergency diesel generator and vehicles transporting grains will release exhaust emissions, containing carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOX), and particulate matter (PM). Emissions and leakage from the bag filters may also release PM. These emissions can deteriorate the ambient air quality in the immediate vicinity of the project sites. These emissions pose health hazards for the O&M staff and nearby communities. 438. In addition, phosphine gas may be released from the aluminum phosphide, which would be used as a fumigant in the facility. Phospine gas is toxic and is denser than air and hence may collect in low- lying areas. It can form explosive mixtures with air and also self-ignite. When phosphine burns it produces a dense white cloud of phosphorus pentoxide – a severe respiratory irritant. Primarily the O&M staff may be exposed to phosphine. 439. Mitigation Measures. The following measures will address the potentially negative impacts of the Project associated with air quality deterioration:  The vehicular and equipment exhaust should comply with the national standards.  The bag filters will be maintained regularly, ensuring that there is no excessive leakage and release of PM. The emissions from these filters will comply with the national standards for air quality.  Compliance with the standard for ambient air quality will be ensured.  The steel silos to be constructed under BMFS project has the duct at the dust collection point, which will be attached to a reverse jet bag filter and then to the fan which will vacuum the duct and extract the dust. These suction ducts will be suitably installed at the dump pit of the grain collection point, to the bucket elevator and chain conveyors also to collect dust during operation of silos.  Standard operating procedures will be followed to handle and use aluminum phosphide, and to prevent exposure to phosphine gas. For this purpose, international sources such as National Institute for Occupational Safety and Health (NIOSH) will be utilized. Guideline to be followed during fumigation is presented in Article 8.3.2. Annex 6includes the waiver certificate for DGF to use AP as fumigants.  The O&M staff will be provided HSE trainings on regular basis; these trainings will address the issues related to phosphine gas. 136 8.3.3 Soil and Water Contamination 440. Inappropriate waste disposal from the O&M activities as well as from offices and residential facilities may potentially contaminate soil and water thus negatively affecting nearby communities and biological resources of the area. 441. Mitigation measures. The following measures will address the potentially negative impacts of the Project associated with soil and water contamination:  Each facility will have waste management plan as part of its Operations Manual. No untreated waste effluents will be released to the environment.  For the domestic sewage from the offices and residential areas, appropriate treatment and disposal system, such as septic tanks and soaking pits, will be constructed having adequate capacity.  Waste oils will be collected in drums and sold to the recycling contractors.  The inert recyclable waste from the site (such as card board, drums, and broken/used parts) will be sold to recycling contractors. The hazardous waste will be kept separate and handled according to the nature of the waste.  Domestic solid waste from the offices and residential areas will be disposed in a manner that does not cause soil contamination. 8.3.4 Noise and Vibration 442. The O&M activities (running of motors, conveyor belts, bag filters, chilling plant, dryers, and others) at the silos and vehicular traffic will generate noise and vibration which are likely to affect the O&M staff and nearby communities. 443. Mitigation Measures. The following measures will address the potentially negative impacts of the Project associated with noise and vibration:  It will ensure that the noise from the facility complies with the national and WB standards.  PPE (ear muffs or air plugs) will be provided to the O&M staff  Vehicular traffic through the communities will be avoided as far as possible. Project routes will be authorized by the Supervision Consultants.  Vehicle speeds will be kept low, and horns will not be used while passing through or near the communities.  Vehicles will have exhaust silencers to minimize noise generation.  Nighttime traffic will be avoided near the communities.  Movement of all project vehicles and personnel will be restricted to within work areas, to  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 137 8.3.5 Vehicular Traffic 444. Transportation of food grain to and from silos will cause additional traffic on the access routes (roads and water ways). This increased traffic can potentially cause traffic congestions on roads and in waterways and also pose safety hazards for the nearby population particularly children. 445. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  The Department will prepare a traffic management plan for each silo facility. This plan will be a part of the Operational Manual of each facility.  Liaison will be maintained with the relevant authorities (such as traffic police, BIWTA) regarding the wheat transportation particularly during emergencies. 8.3.6 ElectricityConsumption 446. For continuous power supply on priority basis through the 33 KV power line will have to be ensured at the Silo for uninterrupted operation of a silo. If chilling system is interrupted the soil will not meet the required temperature and infestation of soil will be expedited. 447. Mitigation measures. The following mitigation measures will address the negative impacts of the Project associated with the electricity consumption:  Ensure electricity connection from multiple grid.  Keep the provision for back up generator 8.3.7 Damage to Infrastructure and Monuments 448. During the food grain transportation, there could be some inadvertent damage to the roads, jetties, and other structures. This unmitigated potential impact is characterized and assessed below. Impact Parameter Nature of Project Impact Characterization of Project Impact Duration of impact Long term (during entire O&M Major phase) Spatial extent May extend beyond Project boundary Moderate (silo sites and access routes) Reversibility Reversible (after mitigation) Moderate Legal standards - Minor Likelihood of impact Likely Moderate Sensitivity Moderate impacts on infrastructure Moderate Impact Significance Medium 138 449. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Appropriately sized vehicles will be used to transport the food grain, minimizing the wear and tear of the transportation routes.  The Food Department will maintain close liaison with the relevant authorities such as Highway Department and BIWTA for any damages caused by the food grain transportation. 8.3.8 Aesthetic Value 450. Presence of silos may potentially affect the aesthetic value of the area. 451. Mitigation measures. The following mitigation measures will be implemented to address the above potential impacts:  Landscaping and tree plantation will be carried out at each facility.  Proper housekeeping will be regularly maintained at the facilities. Responsibility  DG Food with the help of Environment, Health and Safety Specialist will ensure the safety of the workers and environmental mitigation. 139 8.4 Assessment of Social Impacts and Mitigation 8.4.1 Social Screening 452. This Chapter assesses the potential impacts of the proposed project on environment and people in and around the silos facilities and the target areas where household silos will be distributed. Social screening of all the 8 sites for construction of modern public silo infrastructures was carried out during initial visit to the sites. A rapid social checklist was used for the screening. Screening results are given at Table below. Table 8-9: Social Screening of 8 Sites Site Name Availability of Current Use Land acquisition Impact on Land and population tribal displacement population Barisal DG-Food’s land Vacant None None DG-Food’s land Existing damaged sheds will be None None Narayanganj knocked down for new construction DG-Food’s land Existing damaged sheds will be None None Dhaka knocked down for new construction Ashuganj DG-Food’s land Vacant None None Government khas Current users are tenant as per Land will be None land agreement with the informal transferred through occupants of the land. The inter-ministerial agreement will expire on transfer method. harvest of the crops by May DG-Food has 2013. The local administration reviewed the status Madhupur has taken possession of the land of current under due procedure and started occupancy and the process to transfer it to the found that there is DG-Food. no issue of compensation as per law or as per Bank’ OP 4.12. Mymensingh DG-Food’s land Vacant None None Maheshwar Pasha DG-Food’s land Vacant None None Chittagong DG-Food’s land Vacant None None 8.4.2 Land Acquisition and related Issues 453. The construction of storage silos is not likely to involve significant land acquisition issues, as most of the proposed public silos will be constructed on DG-Food’s existing land or on vacant public lands. At least the proposed sites in the first phase will largely be limited on existing Government sites for grain storage. The sites for subsequent phases and in case of any of the first year sites cannot accommodate the silo facilities within designated lands, additional land or displacement of people may be required during design and construction. Since many of these existing sites are in cities and towns, and some of them are in congested areas, movement of stocks in and out of the silos may add disruptions to existing traffic for sites which are linked by road, and which would use trucks as means of stocking and distribution. However, the project in the subsequent phases and at critical situations in the first phase construction, may not avoid acquisition of private lands or public lands from private uses. The project will cover the entire country and tribal peoples (indigenous peoples) and communities are dispersed in small 140 proportions in most of the plain districts. It is very likely that there are tribal peoples in the project districts. The World Bank is expected to finance the project, and certain procedural requirements based on World Bank operational policies (OP) apply. These OPs include social safeguard policies related to Indigenous Peoples (OP 4.10) and Involuntary Resettlement (OP 4.12). In addition, the communities may experience temporary inconveniences during construction due to influx of non-local population and increased traffic and demolition of existing structures. 8.4.3 Impacts on Indigenous Peoples 454. Although the project will cover the entire country, it is agreed that DG-Food will select to drop any site for construction of silo facilities, if tribal peoples (indigenous peoples) are likely to be affected due to the construction. The modern public storage facilities and family silos will, however equally benefit the tribal peoples like the mainstream population. The silos sites for the first year construction, as agreed, did not affect any people from the tribal communities. The World Bank's OP 4.10 on Indigenous Peoples therefore, does not apply to the project as a whole. The OP 4.10 ensures that (i) no adverse impacts on indigenous groups will take place as a result of the project; (ii) project benefits are culturally compatible with local customs and traditions; and (iii) indigenous groups, if affected by the project, participate in project preparations and implementation through a process of informed consultation. Measures to benefit indigenous groups and avoid adverse impacts are integrated into the overall project design and implementation process. 8.4.4 Involuntary Resettlement 455. Public storage silos facilities are proposed on sites having a land area from 7 to 20 acres (1 acre = 0.405 ha) each to accommodate 6 to 33 silo bins of 60 to 90 ft diameter each. These lands are mostly owned by the DG-Food itself and where unavailable, public lands will be used as much as feasible. In only critical cases, private lands can be acquired. The World Bank's Operational Policy 4.12 makes it a requirement that people who are forced to lose land or land based assets, or who lose access to livelihoods as a result of land acquisition are entitled to compensation and assistance, in order to improve or at least regain their previous standard of living. In this project infrastructure investments could potentially affect some people negatively through physical or economic displacement. DG-Food will, however, avoid acquiring private lands and public lands from private uses, unless it is absolutely required. Based on this approach, the World Bank's Operational Policy on Involuntary Resettlement applies in the project. Resettlement Policy Framework for the project and Resettlement Action Plan for subsequent annual works phases will be required. 8.4.5 Social Exclusion 456. The objectives of the project are to improve food stock and supply of food grains during emergencies and at the events of disaster. The project is expected to benefit the communities in the target areas. Although the project intends to benefit communities from all strata, there is a risk that gender, ethnicity and other social stratification of beneficiaries may lead to disproportionate distribution of project benefits. The disadvantaged groups like the small ethnic and other minorities, women, disabled and very poor populations are at the risk of exclusion for distribution of family silos. All the poor and vulnerable families will be in the need of food grain stock and those having farm lands under their cultivation will need safe stock of seeds during disaster. Social management plans will be required for inclusive 141 implementation of the project especially the components for distribution of family silos and community incentives around the public silo sites. 8.4.6 Impacts During Construction 457. The project, for clearing sites for construction of new public silo facilities will demolish a huge number of existing traditional out of work storage buildings. Where the sites are located within a congested area with residential setup, high rise building, schools, and mosques, stacking of debris and demolition activity may affect the residents temporarily. 8.4.7 Impacts Due to Non-local Work force 458. Increased number of non-local peoples on site during construction may pose a risk to public health and to some extent spread of STDs including HIV/AIDS. Social and environmental management plans will be required for public participation and to mitigate non-safeguard social impacts including community grievances during construction. 8.4.8 Impacts on Local Infrastructure 459. Construction of public silo infrastructures at some locations has community and public infrastructures like roads, mosques, and sites of importance of national integrity like war mausoleums and sites of commemoration. The project will avoid these sites with alternative layout plan and if feasible consider improvement of these infrastructures along with other community benefits. The project also identified a number of social institutions and community infrastructure within 500-m periphery of the proposed public silo sites to consider improvement of some of them as per community interest and needs. The social institutions and community infrastructures at the sites are as follows: Ashuganj 4 Alal Shah High School at Chor Char Tola. 5 Chor Char Tola Islamia Aliya Madrasha. 6 Community graveyard and Eidgah. 7 Chor Char Tola Uttar Para Jamee Mosque. 8 Mohoram Para Jamee Mosque. 9 Rowshonara Girls High School. 10 Rail Station Waktia Mosque. 11 Hazi Abdul Jalil Jamee Mosque. Barisal 12 Five schools and 2 colleges. 13 Four mosques and 2 churches 14 Six private clubs. 15 Martyrs’ mausoleum Chittagong 16 Water supply network 17 Drainage system 18 Approach road to the site Dhaka 19 Approach road to the highway 20 Access road around the site 21 Three mosques and mazars Madhupur 22 One kilometer road connecting Ramkrisna Bari village with Mymensingh-Tangail highway by the side of boundary wall of BFIC Moheswarpash, Khulna 23 Masjidul Aksha Jame Mosque (Senpara) 142 24 Mohammadia Forkania Madrasha (Senpara) 25 Shaebpara Girls high school 26 Shaebpara Baitul Elahi Mosque 27 Mosjudul Meraj Maniktola 28 Maniktola Darul ulum Hafizea Madrasha 29 Shaebpara Baitul Jame Mosque 30 Darul Quaran Islamia Madrasha Mymensingh 31 Gudara ghat (river crossing) 32 Connecting road between the Gudara Ghat and the Mymensingh Station Road Narayanganj 33 CSD Jame Mosque 34 Strip of river bank (for public recreation) 8.4.9 Project Benefits 460. Modernizing the current food storage system in the country will result in improved storage capacity at national and at community levels to make available food stock in case of emergency and disasters. The project will help ensure food and nutritional security to the communities, particularly in the disaster prone areas. By enhancing the post-disaster food distribution system, the project will serve to safeguard livelihood, human capital and welfare of the poor and vulnerable populations. Family silos will safeguard the household food stock for the coastal population at the events of disasters. The women and children will be more benefited as any shock on food stock directly affects the women and the children suffers from delayed and skewed food supply during disasters and the aftermath. 8.5 Climate Change Impact on Food Security& Contribution of BMFSFP 461. Climate change is a long-term change in the statistics of weather expressed as a probable change in mean or extreme weather conditions. The United Nations de�nition speci�cally refers to climate change as the influence of human activity that alters the composition of the global atmosphere, which is in addition to natural climate variability. Climate variability refers to variations in the climate on all temporal and spatial scales beyond that of individual weather events. 462. Climate change in Bangladesh is an extremely crucial issue as the country is one of the most vulnerable nation to the impacts of climate change in the coming decades. Located at the bottom of the mighty Ganges-Brahmaputra-Meghna river system, there are a total of 57 trans-boundary rivers coming down to it; 54 from neighbouring India and 3 from Myanmar. 8.5.1 Present Status & Effect of Climate Change of Food Securityin Bangladesh 463. The country which has merely control of the water flow and volume drains to the Bay of Bengal over 90% of the total run-off generated annually. Coupled with the high level of widespread poverty and increasing population density and limited adaptive capacity and poorly funded has made the region one of the most adversely affected in the planet. 464. In Bangladesh, yields from rain fed agriculture could be reduced to 50% by 2020. And for a country with increasing population and hunger, this will have an extremely adverse effect on food security. Although effects of climate change are highly variable, by 2030, South Asia could lose 10% of rice and maize yields. As a result of all this, Bangladesh would need to prepare for long term 143 adaptation, which could be as drastic as changed sowing dates due to seasonal variations, introducing different varieties and species, to practising novel water supply and irrigation systems and long term storages. 465. Although the country has managed to increase the production of rice since the nation’s birth, from 10 metric tons (mt) to over 30 mt, around 30% of the population is still malnourished. Now more than 5 million hectares of land are irrigated, almost fourfold than that in 1990. Even though modern rice varieties have been introduced in three-fourths of the total rice irrigation area, the sudden shift in population increase is putting strains on the production. Climate change threatens the agricultural economy which although counts for just 20% of GDP, contributes to over half the population’s labor force. As pointed out before in the book, in 2007 after a series of floods and cyclone Sidr, food security was severely threatened. Given the country’s infrastructure and disaster response mechanisms, the food yield situation got worse. The loss of rice production was estimated at around 2 million mt which could potentially feed 10 million people. This was the single most important catalyst in the 2008 price increase which led to around 15 million people going without much food. This was further worsened by cyclone Allia. However, the rice production during the last one and a half decade from 1996-97 has steadily increased from 18.882 million tons to 33.500 million tons in 2010-11 respectively. Though rice production continues to increase, but wheat production shows a declining trend from 1.454 million ton in 1996-97 to 0.990 million ton in 2011-12. 8.5.2 Impact of BMFSFP to Combat Climate Change Impact 466. At present GoB’s Public Food Distribution System (PFDS), has an effective storage capacity of about 1.6 million mt. With the increase in population and some GoB priority intervention for strengthening of public food procurement and expansion of safety net programs for ensuring food security of the poor section of population, the effective capacity of food grain storage has to be increased to a significant extent. The sixth Five Year Plan of the country has a projection of increasing the storage capacity by about 784,000 mt by the year 2011-2015 16 . The GoB/FAO/USAID-sponsored Country Investment Plan (CIP) 17 also has put emphasis on increase and modernization of public storage and handling facilities particularly in disaster prone areas. Priority interventions suggested include building of more modern storage facilities that are better equipped to adapt to the climate change impacts, minimize disaster shocks and ensure quality and safety of the commodities in the storage. The suggestions also include repair/upgrade and modernization of the existing facilities and the process of monitoring and quality assurance. 467. Parboiled rice is the staple food for Bangladesh which cannot be stored more than 2 to 3 months in the existing storage facilities. Steel Silo can store parboiled rice for more than 2.5 years. The long time storage capacity of parboiled rice will provide DG Food the increased storage capacity of surplus rice every year and will increase the disaster preparedness of GoB in terms of enough food security to combat the aftermath of shortage of food during any natural calamity. 16 Sixth Five Year Plan, Ministry of Planning, Government of the People’s Republic of Bangladesh 17 Bangladesh Country Investment Plan (CIP), GoB/FAO/USAID, June 2011 144 SECTION D: ENVIRONMENTAL MANAGEMENT PLAN (EMP) & CONSULTATION - DISCLOSURE 145 9 ENVIRONMENTAL MANAGEMENT PLAN 468. This Chapter presents the Environmental Management Plan (EMP) of the Project. The EMP essentially provides the implementation mechanism for the environmental and social mitigation measures discussed in Chapter 9. 9.1 Objectives of EMP 469. The basic objective of the EMP is to manage, prevent, and mitigate potentially adverse impacts of project interventions in a way that minimizes the adverse impact on the environment and people of the Project area of the each silo facility. The specific objectives of the EMP are to:  Facilitate the implementation of the environmental and social mitigation measures identified during the present EIA and discussed in Chapter 8.  Assign responsibilities for project proponent, contractors, consultants, and other members of the Project team for the environmental and social management of the Project;  Define a monitoring mechanism and identify monitoring parameters to ensure effective implementation of the mitigation measures.  Assess environmental training requirements for different stakeholders at various levels.  Describe communication and documentation requirements. 9.2 EMP Components 470. The EMP components are listed below.  Institutional Arrangement  Mitigation Plan  Monitoring Plan  Capacity Building  Documentation and reporting  Grievance redress mechanism  Contractual arrangements for EMO implementation  EMP implementation cost 471. These components are discussed in Sections 8.3 to 8.10 below. 9.3 Institutional Arrangements 472. The institutional arrangements required for implementation of the EMP are discussed below. A flow chart for implementation arrangement is added in Figure 9.1 146 Project Steering Committee (PSC) Secretaries of Planning, Agriculture, Forestry, Environment, Finance, and Disaster Management; BADC, Deputy Commissioners of Districts, DG Food and Secretary to PSC Ministry of Food Overall Implementation Responsibility Occupational Health and Directorate General, Food Directorate General, Food Safety Specialist Planning and Monitoring Unit (Component A, B2, C) (FPMU), (Component B1) Project Management Unit Sr. Environment (PMU) Specialist, Sr. Social Specialist Project Coordinators at Each Site Figure 9-1 Implementation Step Up of the Project 147 9.3.1 Implementation Responsibility 473. The Project proponent (DG Food) will be overall responsible for the implementation of EMP through consultants and contractors. The staff of the proponent, consultants and contractors who are responsible for ensuring the implementation of the EMP needs to have the capability to handle the complexities and spirit of management strategies. Training and workshops will need to be arranged involving proponent, consultants and contractors to share the issues of environmental and social protection. 474. A Project Management Unit (PMU) would be established in the DG Food’s office for day–to- day implementation and monitoring of the project activities. The PMU would be headed by a Project Director and consist of: (i) Deputy-Project Director; (ii) two technical specialists; (ii) once Senior Procurement Specialist, and one Procurement Analyst; (iii) One Senior Financial Management specialist, one Financial Management Specialist and one accountant and a book keeper; (iv) Senior Environmental Specialist, Senior Social Specialist, and Senior Communication Specialist; (v) at each site in the field PMU would have one Project Coordinator for coordination with the contractors, consultants and local administration as well as with communities, one Technical Specialist and one Social and Environment Specialist and support staff. The Senior Environment Specialist has to be on Board as soon the PMU is set up. S/He will be responsible for ensuring the adequacy of environmental component in the Bidding Document (BOQ) and ensure the quality of Environmental Action Plan (EAP) submitted by the contractor. The field level environmental specialist should be on board before commencement of the field work. 9.3.2 Construction Phase 475. Environment Specialist in PMU. The PMU will have a dedicated Senior Environmental Specialist (SES) to ensure implementation of EMP and other environmental management responsibilities. The SES will maintain 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 (discussed below). 476. Supervision Consultant’s Environment Monitor. The Supervision Consultants will have dedicated, properly qualified and experienced, site-based Environment Monitor (EM) at each construction site. 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 EM needs to be a graduate preferably in environmental science/engineering with at least 5 years’ experience in the related field. 477. Contractor’s Environment Supervisor. 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 ESs will maintain coordination with the EMs at the site level. The ESs will also be responsible to conduct environmental trainings for the construction crew. The EM needs to be a graduate preferably in environmental science/engineering with at least 3 years’ experience in the related field. 148 9.3.3 Operation Phase 478. 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 then implement the relevant parts of the Operations Manual for ensuring health and safety during project operation. 9.4 Mitigation Plan 479. The mitigation plan is a key component of the EMP. It lists all the potential effects of each activity of the Project and their associated mitigation measures identified in the EIA. For each project activity, the following information is presented in the plan:  A listing of the potential impact associated with that project activity,  A comprehensive listing of mitigation measures (actions),  The person(s) responsible for ensuring the full implementation of the action,  The person(s) responsible for monitoring the action,  The timing of the implementation of the action to ensure that the objectives of mitigation are fully met. Separate mitigation plans for the construction and O&M phases of the proposed Project are presented in Tables 9.1 and 9.2, respectively. 149 Table 9-1: Mitigation Plan for Design and Construction Phase Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring Design Phase 1 Site selection 1.1 Involuntary  Government-owned land to be selected to DG Food - Before resettlement avoid involuntary resettlement. construction (BC):  Resettlement Policy Framework prepared to during detailed address any acquisition of private land designing of the during subsequent Project phases project 2 Design considerations 2.1 Risk of flooding  The design will ensure that facilities remain Design DG Food BC and inundation safe from flooding and inundation. consultants  The site selected for the facilities will be sufficiently higher than the maximum water level during high tides and storm surges.  Appropriate raising of the foundations will be carried out if the available sites are not currently at the appropriate level.  Appropriate drainage system will be included in the facility design. 2.2 Soil and water  Appropriate waste collection and disposal Design DG Food BC contamination systems will be included in the design of consultants the silo facilities and ancillaries.  Appropriate waste including sewage disposal facilities such as septic tanks and soaking pits of adequate size and capacity will be included in the design of the office and housing facilities 150 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring Construction Phase 3 Contractor Mobilization 3.1 Air Quality  The vehicular and equipment exhaust Contractors CSC BC; and Demobilization Deterioration should comply with the national standards. AC  Contractor to ensure compliance with the standard for ambient air quality.  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities. 3.2 Noise  The contractors will ensure that the noise Contractors CSC BC; from the construction sites complies with AC the national and WB standards.  Vehicular traffic through the communities will be avoided as far as possible. Project routes will be authorized by the Supervision Consultants.  Vehicle speeds will be kept low, and horns will not be used while passing through or near the communities.  Vehicles will have exhaust silencers to minimize noise generation.  Nighttime traffic will be avoided near the communities.  Movement of all project vehicles and personnel will be restricted to within work areas, to avoid noise disturbance.  Working hours for construction activities within the communities will be limited to between 8 am and 6 pm.  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 3.3 Vehicular Traffic  Project drivers will be trained on defensive Contractors CSC BC; 151 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring driving practices. AC  Speed limits will be enforced for the Project vehicles.  Reduced speed near/through communities.  Liaison should be maintained particularly with the communities near the camps and work sites.  Safety signage should be placed at the work sites. 3.4 Safety Hazards and  The contractors will prepare site specific Contractors CSC BC; Public Health Health, Safety and Environment (HSE) AC Plan and obtain approval from the Supervision Consultants. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS.  The construction staff will be screened for communicable diseases.  The WBG’s EHS Guidelines will be included in the contract documents.  The project drivers will be trained for defensive driving skills.  Vehicular speeds near/within communities will be kept low to minimize safety hazards.  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Liaison with the community will be maintained. 3.5 Blocked access  The contractor will prepare traffic Contractors CSC BC; routes management plan prior to commencing AC mobilization and obtain approval from the 152 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring Supervision Consultants.  In case of the blockage of the existing routes, alternate routes will be identified in consultation with affected communities. 3.6 Damage to  All damaged infrastructure will be restored Contractors CSC BC; Infrastructure to original or better condition. AC 3.7 Cultural and  Liaison with the communities will be Contractors CSC BC; gender issues maintained throughout the construction AC phase.  Grievance redress mechanism will be established at each site. 4 Construction Camp 4.1 Involuntary  Location of construction camp will be Contractors CSC BC Establishment resettlement finalized after consultation with nearby communities and after obtaining approval from Supervision Consultants.  Camps will be established within the CSD facilities as far as possible.  If private land is needed, appropriate rent to be paid to the land owner after completing all documentation requirements. 4.2 Air Quality  The equipment exhaust will comply with Contractors CSC BC Deterioration the national standards.  Contractor to ensure compliance with the standard for ambient air quality.  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities.  Liaison will be maintained particularly with the communities near the camps. 4.3 Noise  Generators will have exhaust mufflers Contractors CSC BC; (silencers) to minimize noise generation. DC 4.4 Soil Erosion  Construction camps will be located in a Contractors CSC DC 153 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring stable and flat area, requiring minimal devegetation and leveling.  After the completion of the construction works, campsites will be completely restored. No debris, surplus construction material or any garbage will be left behind.  Photographic record will be maintained for pre-project, during-construction and post- construction condition of the sites. 4.5 Risk of flooding  The site selected for the camps will be Contractors CSC BC sufficiently higher than the maximum water level during high tides and storm surges.  Appropriate raising of the camp foundations will be carried out if the available sites are not currently at the appropriate level.  Appropriate drainage system will be included in the camp design. 4.6 Surface Water  Contractor will prepare camp management Contractors CSC BC; Contamination plan and waste management plan and DC obtain approval from CSC  For the domestic sewage from the construction camps, appropriate treatment and disposal system, such as septic tanks and soaking pits, will be constructed having adequate capacity. 4.7 Loss of Vegetation  Clearing natural vegetation will be avoided Contractors CSC BC; as far as possible. DC  The camp will be established in a natural clearing as far as possible  Complete record will be maintained for any tree cutting. Compensatory tree plantation will be carried out. 4.8 Increased  The contractors will prepare a traffic Contractors CSC BC; 154 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring vehicular traffic management plan for each site and obtain DC approval from the Supervision Consultants. Project drivers will be trained on defensive driving practices.  Speed limits will be enforced for the Project vehicles.  Liaison should be maintained particularly with the communities near the camps.  Safety signage should be placed where appropriate. 4.9 Safety Hazards and  The contractors will prepare site specific Contractors CSC BC; public health Health, Safety and Environment (HSE) DC Plan and obtain approval from the Supervision Consultants. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS.  Availability of safe drinking water will be ensured for the construction staff.  First aid boxes will be made available at each construction site. Emergency phone numbers (including hospitals, Fire Department, and Police) will be displayed at key locations within the site. Each site will have an ambulance available.  The WBG’s EHS Guidelines will be included in the contract documents.  The camps will have protective fencing to avoid any unauthorized entry.  Firefighting equipment will be made available at the camps.  The camp staff will be provided safety including fire fighting training. 155 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Liaison with the community will be maintained. 4.10 Social and Gender  Liaison with the communities will be Contractors CSC BC Issues maintained throughout the construction DC phase.  Grievance redress mechanism will be established at each site (details are provided later in the document). 4.11 Blocked access  Camps will be located ensuring that no Contractors CSC BC; routes routes are blocked.  In case of the blockage of the existing routes, alternate routes will be identified in consultation with affected communities. 4.12 Damage to  All damaged infrastructure will be restored Contractors CSC DC infrastructure to original or better condition. 4.13 Aesthetic aspects  Proper landscaping and plantation will be Contractors CSC BC; carried out at the camps. 5 Camp operation 5.1 Air quality  The equipment exhaust will comply with Contractors CSC DC deterioration the national standards.  Contractor to ensure compliance with the standard for ambient air quality.  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities.  Liaison will be maintained particularly with the communities near the camps. 5.2 Noise  The contractors will ensure that the noise Contractors CSC DC from the camps complies with the national and WB standards.  Liaison with the community will be 156 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring maintained. Grievance redressal mechanism will be put in place to address the community complaints. 5.3 Soil and water  Adequate implementation of waste Contractors CSC DC contamination management plan will be ensured.  Waste oils will be collected in drums and sold to the recycling contractors.  The inert recyclable waste from the camp (such as card board, drums, broken/used parts) will be sold to recycling contractors. The hazardous waste will be kept separate and handled according to the nature of the waste.  Domestic solid waste from the construction camps will be disposed in a manner that does not cause soil contamination. 5.4 Water  Astute planning will be employed to Contractors CSC DC consumption conserve water at the camps. Water will be procured in a manner that least affects the existing water users and local communities.  The contractors will submit the plan to procure and consume water for their camp needs, and obtain approval from the Supervision consultants. 5.5 Vehicular traffic  Speed limits will be enforced for the Project Contractors CSC DC vehicles.  Liaison should be maintained particularly with the communities near the camps.  Safety signage should be placed where appropriate. 5.6 Safety hazards and o The contractor will provide personal Contractors CSC DC public health protective equipment (PPE) to the construction staff and will ensure its appropriate usage. 157 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring o Availability of safe drinking water will be ensured at the camps. o First aid boxes will be made available at each camp. Emergency phone numbers (including hospitals, Fire Department, and Police) will be displayed at key locations within the site. o The WBG’s EHS Guidelines will be included in the contract documents. o The camp sites will have protective fencing to avoid any unauthorized entry. o The project drivers will be trained for defensive driving skills. o Firefighting equipment will be made available at the camps and worksites. o The camp staff will be provided safety including fire fighting training. o All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Liaison with the community will be maintained. 5.7 Damage to  All damaged infrastructure will be restored Contractors CSC DC infrastructure to original or better condition. 5.8 Social and Gender  Liaison with the communities will be Contractors CSC DC Issues maintained throughout the construction phase.  Grievance redress mechanism will be established at each site (details are provided later in the document). 6 Transportation of 6.1 Air Quality  The vehicular and equipment exhaust Contractors CSC DC Equipment and Deterioration should comply with the national standards. Construction Materials  Contractor to ensure compliance with the standard for ambient air quality. 158 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities. 6.2 Noise  The contractors will ensure that the noise Contractors CSC DC from the construction sites complies with the national and WB standards.  Vehicular traffic through the communities will be avoided as far as possible. Project routes will be authorized by the Supervision Consultants.  Vehicle speeds will be kept low, and horns will not be used while passing through or near the communities.  Vehicles will have exhaust silencers to minimize noise generation.  Nighttime traffic will be avoided near the communities.  Movement of all project vehicles and personnel will be restricted to within work areas, to avoid noise disturbance.  Working hours for construction activities within the communities will be limited to between 8 am and 6 pm.  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 6.3 Vehicular Traffic  Project drivers will be trained on defensive Contractors CSC DC driving practices.  Speed limits will be enforced for the Project vehicles.  Reduced speed near/through communities.  Liaison should be maintained particularly with the communities near the camps and 159 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring work sites.  Safety signage should be placed at the work sites. 6.4 Safety Hazards and  The contractors will prepare site specific Contractors CSC DC Public Health Health, Safety and Environment (HSE) Plan and obtain approval from the Supervision Consultants. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS.  The construction staff will be screened for communicable diseases.  The WBG’s EHS Guidelines will be included in the contract documents.  The project drivers will be trained for defensive driving skills.  Vehicular speeds near/within communities will be kept low to minimize safety hazards.  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Liaison with the community will be maintained. 6.5 Blocked access  The contractor will prepare traffic Contractors CSC DC routes management plan prior to commencing mobilization and obtain approval from the Supervision Consultants.  In case of the blockage of the existing routes, alternate routes will be identified in consultation with affected communities. 6.6 Damage to  All damaged infrastructure will be restored Contractors CSC DC Infrastructure to original or better condition. 160 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 6.7 Cultural and  Liaison with the communities will be Contractors CSC DC gender issues maintained throughout the construction phase.  Grievance redress mechanism will be established at each site. 7 Site Clearance 7.1 Air quality  The vehicular and equipment exhaust Contractors CSC DC deterioration will comply with the national standards.  Contractor to ensure compliance with the standard for ambient air quality.  Water will be sprinkled where needed and appropriate, particularly at work sites near the communities.  Liaison will be maintained particularly with the communities near the camps and work sites. 7.2 Noise and  The contractors will ensure that the noise Contractors CSC DC vibration from the construction sites complies with the national and WB standards.  Movement of all project vehicles and personnel will be restricted to within work areas, to avoid noise pollution.  Working hours for construction activities within/near the communities will be limited to between 8 am and 6 pm.  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 7.3 Soil erosion  Cut and fill at the proposed sites will be Contractors CSC DC carefully designed, and ideally should balance each other.  Embankments and excavated slopes will not be left untreated/unattended for long 161 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring durations. Appropriate slope stabilization measures will be taken per the design (eg, stone pitching).  Vehicular traffic on unpaved roads will be avoided as far as possible. Operation of vehicles and machinery close to the water bodies will be minimized.  After the completion of the construction works, the construction sites and other work areas will be completely restored. No debris, surplus construction material or any garbage will be left behind.  Photographic record will be maintained for pre-project, during-construction and post- construction condition of the sites. 7.4 Surface water  No untreated waste effluents will be Contractors CSC DC contamination released to ground or water.  Vehicles and equipment will not be repaired in the field. If unavoidable, impervious sheathing will be used to avoid soil and water contamination. 7.5 Loss of natural  Clearing natural vegetation will be avoided Contractors CSC DC vegetation as far as possible.  Tree plantation plan will be prepared and implemented.  Complete record will be maintained for any tree cutting. Compensatory tree plantation will be carried out and five saplings will be planted for each tree felled.. 7.6 Blocked access  In case of the blockage of the existing Contractors CSC DC routes routes, alternate routes will be identified in consultation with affected communities. 7.7 Vehicular traffic  The contractors will prepare a traffic Contractors CSC DC management plan for each site and obtain 162 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring approval from the Supervision Consultants.  Project drivers will be trained on defensive driving practices.  Speed limits will be enforced for the Project vehicles.  Reduced speed near/through communities.  Liaison should be maintained particularly with the communities near the camps and work sites.  Safety signage should be placed at the work sites. 7.8 Safety hazards and o The contractors will prepare site specific Contractors CSC DC public health Health, Safety and Environment (HSE) Plan and obtain approval from the Supervision Consultants. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS. o The contractor will provide personal protective equipment (PPE) to the construction staff and will ensure its appropriate usage. o The construction staff will be screened for communicable diseases. o Availability of safe drinking water will be ensured for the construction staff. o First aid boxes will be made available at each construction site. Emergency phone numbers (including hospitals, Fire Department, and Police) will be displayed at key locations within the site. Each site will have an ambulance available. o The WBG’s EHS Guidelines will be included in the contract documents. 163 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring o The construction sites will have protective fencing to avoid any unauthorized entry. o The project drivers will be trained for defensive driving skills. o Vehicular speeds near/within communities will be kept low to minimize safety hazards. o Firefighting equipment will be made available at the worksites. o The site staff will be provided safety including fire fighting training. o All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Liaison with the community will be maintained. 7.9 Damage to  All damaged infrastructure will be restored Contractors CSC DC infrastructure to original or better condition. 7.10 Aesthetic value  Screens will be used at the site periphery Contractors CSC DC  Landscaping and tree plantation will be carried out at the site after completion of the works.  Proper housekeeping will be regularly carried out at the site and camps. 7.11 Gender and social  Liaison with the communities will be Contractors CSC DC issues maintained throughout the construction phase.  Grievance redress mechanism will be established at each site (details are provided later in the document). 8 Borrow and Disposal Area 8.1 Air quality  Same as 7.1 Contractors CSC DC Management deterioration 164 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 8.2 Noise and  Same as 7.2. Contractors CSC DC vibration 8.3 Soil erosion  Material borrowing and disposal plan will Contractors CSC DC be prepared and approval obtained from the Supervision Consultants. .  Cultivation fields will be avoided for borrowing material to the extent possible.  Written consent of the land owner should be obtained for material (soil) borrowing. A standard form should be prepared and used for this purpose.  Borrow and disposal areas will be re- contoured to avoid deep ditches or high mounds.  Photographic record (before, during and after) will be kept for the borrow and disposal areas.  Leveling and re-contouring borrow sites should be carried out.  The surplus soil, if any, will be disposed at places approved by the Supervision Consultants (“Engineer�). Such sites will be selected after surveying the area and ensuring that soil deposition will not have any significant impacts, such as loss of productive land, blocked access, natural vegetation and disturbance to drainage.  If necessary, fill material for silo sites will be obtained from appropriate locations approved by Supervision Consultants. Such locations will be selected after surveying the area and ensuring that soil extraction will not have any significant impacts, such as soil erosion, loss of natural 165 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring vegetation and disturbance to drainage.  Where the use of cultivated land is unavoidable for obtaining the fill material, the top 30 cm soil layer will be removed and stockpiled for redressing the land after removal of the borrow material. The excavation in such areas will be limited to 50 cm depth.  The fill material will not be obtained from any cultivation fields or orchards, unless the consent of the owner is obtained.  Areas from where the fill material is obtained or surplus soil deposited, will be landscaped to minimize erosion and hazard for people and livestock. 8.4 Soil and water  Same as 7.4. Contractors CSC DC contamination 8.5 Blocked access  Borrow/disposal areas will be selected Contractors CSC DC routes avoiding existing routes.  In case of the blockage of the existing routes, alternate routes will be identified in consultation with affected communities. 8.6 Loss of natural  Loss of vegetation will be minimized at Contractors CSC DC vegetation borrow/disposal areas  Compensatory tree plantation will be carried out for any tree felling. 8.7 Loss of agriculture  Borrow/disposal areas will be selected Contractors CSC DC avoiding agricultural/cultivation areas.  Compensation will be paid to the owner/grower in case of any loss to agriculture. 8.8 Vehicular traffic  Same as 7.7. Contractors CSC DC 8.9 Safety hazards and  Same as 7.8. Contractors CSC DC 166 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring public health 8.10 Damage to  All damaged infrastructure will be Contractors CSC DC infrastructure repaired/restored to original or better condition. 8.11 Aesthetic value  Screens will be used around the Contractors CSC DC borrow/disposal areas if needed.  The borrow and disposal areas will be re- contoured. 9 Excavation 9.1 Air pollution  Same as 7.1 Contractors CSC DC 9.2 Noise and  Same as 7.2 Contractors CSC DC vibration 9.3 Soil erosion  Same as 7.3. Contractors CSC DC 9.4 Soil/water  Same as 7.4. Contractors CSC DC contamination 9.5 Blocked access  Same as 7.6. Contractors CSC DC 9.6 Vehicular traffic  Same as 7.7. Contractors CSC DC 9.7 Safety hazards and  Same as 7.8. Contractors CSC DC public health 9.8 Damage to  Same as 7.9. Contractors CSC DC infrastructure 9.9 Aesthetic value  Same as 7.10. Contractors CSC DC 10 Construction of 10.1 Air quality  Same as 7.1 Contractors CSC DC foundations deterioration 10.2 Noise and  Same as 7.2 Contractors CSC DC vibration 10.3 Soil erosion  Same as 7.3. Contractors CSC DC 10.4 Soil/water  Same as 7.4. Contractors CSC DC contamination 167 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 10.5 Water availability  Astute planning will be employed to Contractors CSC DC and consumption conserve water at the construction sites. Water will be procured in a manner that least affects the existing water users and local communities.  The contractors will submit the plan to procure and consume water for their construction needs, and obtain approval from the Supervision consultants.  Extreme care will be taken when working close to wells and other water sources. Any damage caused by the project activities will be repaired. 10.6 Blocked access  Same as 7.6. Contractors CSC DC 10.7 Vehicular traffic  Same as 7.7. Contractors CSC DC 10.8 Safety hazards and  Same as 7.8. Contractors CSC DC public health 10.9 Damage to  Same as 7.9. Contractors CSC DC infrastructure 10.10 Aesthetic value  Same as 7.10. Contractors CSC DC 11 Fabrication of Silos 11.1 Air quality  Same as 7.1 Contractors CSC DC deterioration 11.2 Noise and  Same as 7.2 Contractors CSC DC vibration 11.3 Soil erosion  Same as 7.3. Contractors CSC DC 11.4 Soil/water  Same as 7.4. Contractors CSC DC contamination 11.5 Blocked access  Same as 7.6. Contractors CSC DC 168 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 11.6 Vehicular traffic  Same as 7.7. Contractors CSC DC 11.7 Safety hazards and  Same as 7.8. Contractors CSC DC public health 11.8 Damage to  Same as 7.9. Contractors CSC DC infrastructure 11.9 Aesthetic value  Same as 7.10. Contractors CSC DC 12 Installation of machinery 12.1 Air quality  Same as 7.1 Contractors CSC DC and equipment deterioration 12.2 Noise and  Same as 7.2 Contractors CSC DC vibration 12.3 Soil erosion  Same as 7.3. Contractors CSC DC 12.4 Soil/water  Same as 7.4. Contractors CSC DC contamination 12.5 Blocked access  Same as 7.6. Contractors CSC DC 12.6 Vehicular traffic  Same as 7.7. Contractors CSC DC 12.7 Safety hazards and  Same as 7.8. Contractors CSC DC public health 12.8 Damage to  Same as 7.9. Contractors CSC DC infrastructure 12.9 Aesthetic value  Same as 7.10. Contractors CSC DC Table 9-2: Mitigation Plan for Operation and Maintenance Phase Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 1 Operation of Machinery 1.1 Air quality  The vehicular and equipment exhaust O&M staff HSE Staff During O&M and Equipment deterioration should comply with the national 169 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring standards.  The bag filters will be maintained regularly, ensuring that there is no excessive leakage and release of PM. The emissions from these filters will comply with the national standards for air quality.  Compliance with the standard for ambient air quality will be ensured.  Standard operating procedures will be followed to handle and use aluminum phosphide, and to prevent exposure to phosphine gas. For this purpose, international sources such as National Institute for Occupational Safety and Health (NIOSH) will be utilized.  The O&M staff will be provided HSE trainings on regular basis; these trainings will address the issues related to phosphine gas. 1.2 Noise and  It will ensure that the noise from the O&M staff HSE Staff During O&M vibration facility complies with the national and WB standards.  PPE (ear muffs or air plugs) will be provided to the O&M staff  Vehicular traffic through the communities will be avoided as far as possible. Project routes will be authorized by the Supervision Consultants.  Vehicle speeds will be kept low, and horns will not be used while passing through or near the communities.  Vehicles will have exhaust silencers to minimize noise generation. 170 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring  Nighttime traffic will be avoided near the communities.  Movement of all project vehicles and personnel will be restricted to within work areas, to  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 1.3 Soil/water  Each facility will have waste O&M staff HSE Staff During O&M contamination management plan as part of its Operations Manual. No untreated waste effluents will be released to the environment.  For the domestic sewage from the offices and residential areas, appropriate treatment and disposal system, such as septic tanks and soaking pits, will be constructed having adequate capacity.  Waste oils will be collected in drums and sold to the recycling contractors.  The inert recyclable waste from the site (such as card board, drums, and broken/used parts) will be sold to recycling contractors. The hazardous waste will be kept separate and handled according to the nature of the waste.  Domestic solid waste from the offices and residential areas will be disposed in a manner that does not cause soil contamination. 1.4 Water  Astute planning will be employed to O&M staff HSE Staff During O&M consumption conserve water at the plant, offices and 171 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring residential area.  Water will be procured in a manner that least affects the existing water users and local communities. Preferably, the facility will have its own dedicated water source such as a deep tube-well. 1.5 Safety hazards and  Each facility will prepare a site specific During O&M public health Health, Safety and Environment (HSE) Plan. The Plan should also include awareness raising and prevention measures for particularly for communicable diseases such as hepatitis B and C, and HIV/AIDS. The HSE Plan will be made an integral part of the Operational Manual of each facility. The Plan will particularly address procedures to handle aluminum phosphide and to prevent exposure to phosphine gas.  Material safety data sheet (MSDS) will be followed to handle aluminum sulphide and other hazardous chemicals.  Complete inventory and chain of custody record will be maintained for aluminum phosphide.  PPE will be provided to the O&M staff.  HSE trainings will be provided to the O&M staff on a regular basis.  Availability of safe drinking water will be ensured at each facility.  First aid boxes will be made available at each construction site. Emergency phone numbers (including hospitals, 172 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring Fire Department, and Police) will be displayed at key locations within the facility.  Firefighting equipment will be made available at the facilities.  The O&M staff will be provided safety including fire fighting training.  All safety precautions will be taken to transport, handle and store hazardous substances, such as fuel.  Waste management plan to be prepared and implemented in accordance with international best practice.  Liaison with the community will be maintained. 2 Fumigation 2.1 Air quality  Compliance with the standard for O&M staff HSE Staff During O&M deterioration ambient air quality will be ensured.  Standard operating procedures will be followed to handle and use aluminum phosphide, and to prevent exposure to phosphine gas. For this purpose, international sources such as National Institute for Occupational Safety and Health (NIOSH) will be utilized.  The O&M staff will be provided HSE trainings on regular basis; these trainings will address the issues related to phosphine gas. 2.2 Soil/water  Handling, storage, and disposal of O&M staff HSE Staff During O&M contamination aluminum phosphide will be carried out in accordance with the approved procedures. No uncontrolled release to environment (soil, water) will be carried out. 173 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring  MSDS will be followed to handle aluminum sulphide and other hazardous chemicals. 2.3 Safety hazards and  Same as 1.5 O&M staff HSE Staff During O&M public health 3 Repair and Maintenance 3.1 Air quality  Same as 1.1. O&M staff HSE Staff During O&M deterioration 3.2 Noise and  It will ensure that the noise from the O&M staff HSE Staff During O&M vibration facility complies with the national and WB standards.  PPE (ear muffs or air plugs) will be provided to the O&M staff  Vehicles will have exhaust silencers to minimize noise generation.  Liaison with the community will be maintained. Grievance redressal mechanism will be put in place to address the community complaints. 3.3 Soil/water  Each facility will have waste O&M staff HSE Staff During O&M contamination management plan as part of its Operations Manual. No untreated waste effluents will be released to the environment.  Waste oils will be collected in drums and sold to the recycling contractors.  The inert recyclable waste from the site (such as card board, drums, and broken/used parts) will be sold to recycling contractors. Hazardous waste will be kept separate and handled according to its nature. 3.4 Water  Same as 1.4. O&M staff HSE Staff During O&M consumption 174 Responsibility Project Activities Potential Impacts Mitigation Actions Timing Execution Monitoring 3.5 Safety hazards and  Same as 1.5. O&M staff HSE Staff During O&M public health 4 Grain Transportation 4.1 Air quality  The vehicular should comply with the O&M staff HSE Staff During O&M deterioration national standards. 4.2 Noise and  The vehicular should comply with the O&M staff HSE Staff During O&M vibration national standards. 4.3 Vehicular traffic  The Department will prepare a traffic O&M staff HSE Staff During O&M management plan for each silo facility. This plan will be a part of the Operational Manual of each facility.  Liaison will be maintained with the relevant authorities (such as traffic police, BIWTA) regarding the wheat transportation particularly during emergencies. 4.4 Safety hazards and o The project drivers will be trained for O&M staff HSE Staff During O&M public health defensive driving skills. o Vehicular speeds near/within communities will be kept low to minimize safety hazards. 4.5 Damage to  Appropriately sized vehicles will be O&M staff HSE Staff During O&M infrastructure used to transport the food grain, minimizing the wear and tear of the transportation routes.  The Food Department will maintain close liaison with the relevant authorities such as Highway Department and BIWTA for any damages caused by the food grain transportation. 175 9.5 Environmental Monitoring 480. Two distinct types of environmental monitoring will be carried out during the Project construction and O&M phases. These are discussed below. 9.5.1 Compliance Monitoring 481. The compliance monitoring of the project activities is principally a tool to ensure that the environmental and social control measures identified during the EIA are strictly adhered to during the Project execution. 482. Various aspects of the EIA compliance monitoring will be to:  Systematically observe the activities undertaken by the contractors or any other persons associated with the Project.  Verify that the activities are undertaken in compliance with the EIA and EMP.  Document and communicate the observations to the concerned person(s) of the contractors, PMU and Supervision Consultants, so that any corrective measures, if required, can be taken in a timely fashion.  Maintain a record of all incidents of environmental and social significance and related actions and corrective measures.  Maintain contact with the communities, solicit their views and concerns, and discuss them during the fortnightly meetings.  Prepare periodic reports of the environmental and social performance of Project. 483. The mitigation plan discussed in Section 9.4 above will be used as a management and monitoring tool for compliance monitoring. Inspections will be carried out using checklists prepared by the contractors, on the basis of the Table 9.1, during the construction phase, and by the O&M staff on the basis of Table 9.2 during the O&M phase of each facility. 9.5.2 Effects Monitoring 484. The EIA predicts the impacts of the proposed Project on the basis of information available at the time of conducting the assessment and the natural processes that link various environmental and social parameters. Based on this prediction, mitigation measures are introduced such that the predicted residual effects do not exceed acceptable levels. However, there can be an element of uncertainty in such predictions, for example, due to an insufficient grasp of the processes, limitations in prediction techniques, or inadequate data on the environment. This is true for the physical, biological, as well as socioeconomic environment. Consequently, it is possible that even if the mitigation measures are implemented fully, the negative impacts of the Project could exceed predicted levels or acceptable limits. 485. In order to address the above concerns, effects monitoring will be undertaken during the Project activities, with the overall objective of proper management of environmental and social risks and uncertainties. Broadly, effects monitoring has the following objectives:  To verify that the impacts of the proposed project are within acceptable limits, thus establishing credibility (public assurance); 176  To immediately warn the Project proponents (and the regulatory agencies, if required) of unanticipated adverse impact or sudden changes in impact trends so that corrective actions can be undertaken, which may include modifications in the proposed activities, or the inclusion of modified or additional mitigation measures;  To provide information to plan and control the timing, location, and level of certain project activities so that the effects are minimized; and  To facilitate research and development by documenting the effects of the proposed project that can be used to validate impact-prediction techniques and provide a basis for more accurate predictions of future projects. 486. The effects monitoring plan is provided in Table 9.3. The detailed methodologies will be developed by the contractor before commencing the construction activities. The effects monitoring will comprise the following:  Soil erosion;  Water quality;  Oil spills;  Waste management;  Air quality;  Noise;  Socioeconomic aspects; and  Grievance monitoring. 487. PMU may revise the effects monitoring plan during the project implementation as required. 177 Table 9-3: Effects Monitoring Methodology/ Monitoring Monitoring Frequency 18 Responsibility Resource Documentation Parameter Locations Requirement 1 Soil erosion Construction sites, During routine CSC Visual observation, Record of visual labor campsites, monitoring digital camera observation and borrow areas, photographs disposal sites 3 Water quality At wells and surface Before mobilization Contractor Laboratory Record of sampling water bodies near analysis/sampling and analysis work sites and labor bottles campsites Selected local wells Quarterly Contractor Laboratory Record of sampling analysis/Sampling and analysis bottles Selected locations at Quarterly Contractor Laboratory Record of sampling nearby surface water analysis/Sampling and analysis bodies bottles 4 Damage to Construction site During routine Contractor Visual observations, Record of visual groundwater wells monitoring digital camera observation/photogra phs 5 Oil spill Construction sites During routine CSC Visual observations, Record of visual workshops and oil monitoring digital camera observations/ storage areas photographs 6 Solid waste Construction sites, During routine CSC Visual observations, Record of visual labor campsites monitoring digital camera observations/ photographs 7 Wastewater Work sites; labor During routine CSC Sampling bottles Record of sampling campsites monitoring and analysis 18 The frequency of effects monitoring can be adjusted per the site conditions/requirements. 178 Methodology/ Monitoring Monitoring 18 Frequency Responsibility Resource Documentation Parameter Locations Requirement 8 Ambient air quality Construction sites, Before mobilization Contractor Ambient air quality Record of sampling labor campsites monitoring and analysis equipment Construction site, Quarterly Contractor Ambient air quality Record of sampling labor campsite monitoring and analysis equipment 9 Exhaust emissions Construction sites, During routine CSC Visual observations, Record of visual camp site monitoring digital camera observations/ photographs 10 Dust emissions Construction sites, During routine CSC Visual observations, Record of visual labor camp site, monitoring digital camera observations/ project roads photographs 11 Noise Construction sites, Fortnightly or during Contractor Noise meter Complete record of labor camp site, construction activities noise measurement project roads; nearby causing noise and location communities 12 Public grievance Nearby communities Throughout CSC and PMU Complaints register Complete record of construction work any complaints 179 9.6 Capacity Building 488. Environmental and social trainings will help ensure that the requirements of the EIA and EMP are clearly understood and followed by all project personnel throughout the project period. The EMs of the CSC will ensure, in collaboration with the SES of PMU, that these trainings are provided to all Project personnel. The environmental and social training program will be finalized before the commencement of the project. The trainings will be provided to the DG-Food staff, the CSC staff, the construction contractors, and other staff engaged for the Project. Training will cover all staff levels, ranging from the management and supervisory to the skilled and unskilled categories. The scope of the training will cover general environmental awareness and the requirements of the EIA and the EMP, with special emphasis on sensitizing the project staff to the environmental and social aspects of the area. Table 9.4 provides a summary of various aspects of the environmental and social trainings to be conducted at each silo construction site separately. PMU may revise the plan during the Project implementation as required. 489. During the O&M phase of the Project, these trainings will continue to be conducted by HSE staff for all relevant O&M personnel at each facility. Table 9-4: Environmental and Social Trainings Contents Participants Responsibility Schedule General environmental and Selected DG- CSC Prior to the start of the socioeconomic awareness; Food staff; Project activities. Environmental and social sensitivity PMU; (To be repeated as of the project area; CSC staff needed.) Key findings of the EIA; Mitigation measures; EMP; Social and cultural values of the area. General environmental and PMU; CSC Prior to the start of the socioeconomic awareness; CSC; selected field activities. Environmental and social sensitivity contractors’ crew (To be repeated as of the project area; needed.) Mitigation measures; Community issues; Awareness of transmissible diseases Social and cultural values. EMP; Construction Contractors Prior to the start of the Waste disposal; crew construction activities. HSE (To be repeated as needed.) Road safety; Drivers Contractors Before and during the Defensive driving; field operations. Waste disposal; (To be repeated as Cultural values and social sensitivity. needed.) Camp operation; Camp staff Contractors Before and during the 180 Contents Participants Responsibility Schedule Waste disposal; field operations. HSE (To be repeated as Natural resource conservation; needed.) Housekeeping. Restoration requirements; Restoration teams Contractors Before the start of the restoration activities. Waste disposal. HSE during Operation Phase Selected DG- DG Food Prior to the Start of the Food staff; Project Operation and when required during the operation phase 9.7 Record Keeping & Database Management 490. Database will be created and synchronized with the main project database for recording, disseminating and responding to information which emerges from the various environmental monitoring and management programs. They are also necessary for rendering the environmental management system “auditable�. SES will be in charge of the database. 9.7.1. Monitoring Records 9.7.1.1. Quantitative Physical Monitoring 491. The objective of quantitative physical monitoring is to ensure that the mitigation measures designed to prevent, reduce and where possible offset any significant adverse impacts on the environment are being implemented throughout the Project lifecycle. 492. A database would be developed by CSC with the assistance of PMU for storing the results of the quantitative monitoring. The facility would be capable of producing tabulated weekly and monthly reports that provide the following information:  Sampling points;  Dates and times of sample collection;  Test results;  Control limits;  “Action limits� (circa 80 percent of the control limits) at which steps must be taken to prevent the impending breach of the control limit; and  Any breaches of the control limits, including explanations if available. 493. The monitoring data would be continually processed as it is received, so as to avoid a buildup of unprocessed data. 9.7.1.2. General Site Inspections and Monitoring 494. A Site Inspection Checklist for recording the findings of the general site condition surveys would be developed by the respective contractors, on the basis of the Environmental Mitigation Plan described 181 in Section 9.4, during the construction phase. The Site Inspection Checklist would be supported by sketches, as necessary. 9.7.2. Complaints Records 495. A tabulated standard form would be prepared for recording any environmental complaints that are received from the public or government organizations by whatever medium i.e. visits to the Plant, telephone calls or correspondence. The form would concisely list the following information:  Date of the complaint;  Name and contact address of the complainant;  Brief description of the complaint, with a file reference to any correspondence from the complainant;  Brief description of the action taken by the Plant Management to investigate the cause of the complaint and bring about corrective action, if justified; and  Date of reply to the complainant, with a file reference to any correspondence. 496. All complaints received by the PMU would be handled in this way 9.7.3. Information Sources 497. A complete and up-to-date file of all relevant sources of information should be maintained by the PMU. This file would be readily accessible and include, as a minimum, copies of the following documents:  Current environmental permits and consents;  All relevant national regulations, international guidelines and codes of practice;  Manufacturers’ MSDSs for all hazardous substances used on the plant;  Manufacturers’ operating manuals for all the environmental monitoring equipment;  Current calibration certificates for all the equipment that requires calibration by an external organization; and  The latest version of this Environmental Management and Monitoring Manual. 9.7.4. Non-Compliance Report 498. Any breaches of the acceptable standards specified, would be reported to the PMU using a standard form, i.e. a Non-Compliance Report (NCR). 499. A copy of each completed NCR would be held on file by CSC, to be replaced by the reply copy when it is received. A record of corrective actions would also be made and tracked to their completion. 9.7.5. Monthly Internal Reports 500. The CSC will prepare a monthly report for issue to the PMU. These reports will summarize the following:  Progress in implementing this EMP; 182  Findings of the monitoring programs, with emphasis on any breaches of the control standards, action levels or standards of general site management;  Any emerging issues where information or data collected is substantially different from the baseline data reported in the Environmental Assessment;  Outstanding NCRs;  Summary of any complaints by external bodies and actions taken / to be taken; and  Relevant changes or possible changes in legislation, regulations and international practices. 9.7.6 External Audits (Third Party Validation) 501. Arrangements will be made for an independent audit of the existing practices against the requirements of the EMP, on an annual basis. The following aspects will be covered under the external audit:  the EMP is being adequately implemented,  mitigation measures are being implemented and their effectiveness,  the compliance and effects monitoring are being conducted,  environmental and social trainings are being conducted, and  complete documentation is being maintained. 502. These audits would be used to re-examine the continued appropriateness of the EMP and to provide advice on any up-dates required. Attention would be given to lessons learnt in the light of experience. In particular, consideration would be given to the monitoring programs in place to determine whether their purpose has been served and they can therefore be terminated or reduced in frequency. A ToR is added in Annex 10. 9.7.7 Supervision by World Bank 503. DG Food with the help of SES will prepare the half yearly progress report on environmental management and will submit to the World Bank for review. The World Bank will review the screening report, environmental management plan, monitoring reports on random basis and will carry out field visit to cross-check. The contributing development partners may also join in the field visit to understand the environmental compliance of the project. 504. The Annual Environmental Audit Report prepared by the third party monitoring firm will be shared with the safeguards secretariat. 9.8 Grievance Redress Mechanism 505. A grievance can be defined as an actual or perceived problem that might give grounds for complaint. As a general policy, DG-Food and PMU will work proactively towards 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 183 different mechanisms through which they can do so, including grievances related to the land acquisition, resettlement process and environmental management. This will be the responsibility of the PMU, CSC, and contractors and persons designated to be responsible for stakeholder liaison. 506. Potential impacts and effects that are most likely to give rise to grievances for this Project are related to:  Compensation and resettlement of affected persons (if any)  Distribution of employment opportunities;  Construction noise; and,  Presence of a construction labor force and the effects on neighboring villages, local services and infrastructure. 507. Any stakeholder (individual or organization) will be able to submit a grievance to the Project if they believe a practice is having a detrimental impact on their community, the environment, or on their quality of life. They may also submit comments and suggestions. Grievances could include:  Negative impacts on a person or a community (e.g. financial loss, physical harm, nuisance);  Dangers to health and safety or the environment;  Failure of DG-Food, its contractors and their workers or drivers to comply with standards or legal obligations;  Harassment of any nature;  Criminal activity;  Improper conduct or unethical behavior;  Financial malpractice or impropriety or fraud; and  Attempts to conceal any of the above. 9.8.1 Grievance Logging 508. The CSC will be required to log grievances as received directly and have a formal logging system. The CSC will prepare a standard form to record complaints that are received from individuals or organizations by any means including site visits, telephone calls or written correspondence. In addition to the contact information and complaint details, the logging system needs to track the action taken by the contractor and Project staff to investigate the cause of the complaint and bring about corrective action if justified, as well as the date of reply to the complainant, with a file reference to any correspondence. 509. Grievances during construction phase will be investigated to review validity and responsibility. In the first instance, grievances will be directed to the CSC to classify according to Table 9.5 below. Table .9-5: Grievance Classification Criteria Grievance Risk Level Validity Response Classification Low None or low Unsubstantiated CSC will conduct investigation, document findings and provide a response Medium Possible risk Possible CSC and an appropriate investigation and likely a one off substantiation team will conduct investigation. The event CSC PMU may decide to stop work during the investigation to allow the corrective preventive actions to be 184 Grievance Risk Level Validity Response Classification determined. The CSC will provide a response. High Probable risk Probable CSC will get the contractor to and could reoccur substantiation organize a Major Investigation Team for prompt investigation and resolution. Work will be stopped in the affected area. The CSC will provide a response. 510. The CSC will log the receipt of a comment, formally acknowledge it, track progress on its investigation and resolution, and respond in writing with feedback to the aggrieved party. A response time of 10 working days, unless there are exceptional circumstances, would be the aim. 511. The CSC will identify an appropriate investigation team with the correct skills to review the issue raised and to decide whether it is Project related or whether it is more appropriately addressed by a relevant authority outside the Project. PMU will play a role in investigating the validity and responsibility for some grievances. Project staff, and outside authorities as appropriate, will also contribute to investigations as required. The investigation will aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities. In some cases it will be appropriate for the CSC to follow up at a later date to see if the person or organization is satisfied with the resolution or remedial actions. 512. The SC will explain in writing (or where literacy is an issue, orally) the manner in which the review was carried out, the results of the review, any changes to activities that will be undertaken to address the grievance or how the issue is being managed to meet appropriate environmental and social management systems and requirements. 513. The CSC will summarize grievances in project performance reports, at least bi-annually during construction and annually during operation. 514. The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in annual reporting. Individuals will be asked permission to disclose their identity. Investigations will be undertaken in a manner that is respectful of the aggrieved party and the principle of confidentiality. The aggrieved party will need to recognize that there may be situations when disclosure of identity is required and the Project will identify these situations to see whether the aggrieved party wishes to continue with the investigation and resolution activities. 9.9 Inclusion of EMP in Contract Documents 515. In order to make contractors fully aware and responsible of the implications of the EMP and to ensure its compliance, it will be ensured that environmental measures are treated appropriately and separately in the tender documentation and that payment milestones are linked to environmental performance, measured by execution of the prescribed environmental mitigation measures. Such a procedure would help ensure adequate assessments of project impacts are carried out during Project construction and operation phases, where a consistent approach will be expected on behalf of contractors 185 that warrant data and information collected from monitoring programs are compared to baseline conditions. 516. The contractors would be made accountable through contract documents and/or other agreements of the obligations and importance of the environmental and social components of the Project. They would be prepared to co-operate with the executing agency, project management unit, supervising consultants and local population for the mitigation of adverse impacts. After the EMP’s addition in the contract documents, the contractors will become bound to implement the EMP and to hire trained environmental management staff for implementation and effectiveness of the mitigation measures. 517. The contractor is to bid for executing the EMP, including the recommended mitigation measures and monitoring programs, as part of their Bill of Quantities. Since many contractors do not have clear understanding the need of environmental management, some quoted very low price for implementation of EMP and eventually cannot implement EMP as per design. To avoid this problem, Fixed Budget will be assigned for EMP implementation. The contractors may need orientation on the requirement of the EMP in the pre-bidding meeting. The contractor needs to submit an Environmental Action Plan (EAP) based on the EIA and EMF in line with the construction schedule and guideline. The EAP needs to be reviewed by the supervision consultant and cleared by BWDB and World Bank. 9.10 EMP Implementation Cost 518. The estimated costs for the environmental management and monitoring activities are set out in Table 9.6 below. Table 9-6: Cost Estimates for Environmental Management and Monitoring Activities (Per site) Tentative Basis Cost Description Cost US$ BDT Environmental Management Plan (EMP) 1 Environment Specialist in 50000 610 Market Value PMU/month 2 Environmental Supervisor/ 25000 Market Value 305 environment Specialist in Field 3 Tree Plantation/sapling 2000 24.5 Forest Department Pollution Prevention Plan (Water, Air 300000*) 610 BUET 4 laboratoryof Provision noise checking facility of testing) 200000*) 610 BUET 5 Waste silos Disposal 100000*) 1220 Market Value 6 Drinking Water Management 100000*) 1220 Market 7 Borrow Area Restoration 50000*) 1220 Market Value Value/LGED/DPHE 8 Traffic Management Plan 100000*) 2440 Market Value 9 Provision of safety measures to 500000*) 2440 Market Value 10 Demolition workers Work Plan 50000 2440 Market Value 11 Establishment of Construction Camp 200000 3660 Market Value 12 Monitoring & Evaluation, 200000*) 6100 Market Value 13 Training and Capacity Environmental Managementbuilding (10 500,000*) 6100 workshops) Total EMP (Item 3 to 7, 12 and 13) 1,80,000 22000 186 *) included in contractors’ costs and Environmental Action Plan developed in line with construction schedule 10. CONSULTATION AND DISCLOSURE 519. This Chapter provides the objectives, process and outcome of the community consultations conducted as part of the ESA study. 10.1.1 Objectives 520. Community consultation has been conducted as an integral part of the social assessment (SA) of the project. The SA aims to provide a two-way communication between the communities and the project proponents. The consultation process was adopted to identify key stakeholders, and help assess the current practice of grain storage at family level, community interests and needs in the vicinity of the proposed silo sites, and identify impacts of the project interventions to the communities. In line with this aim, the objectives of the communmity consultation and participation were to: � develop and maintain communication links between the project proponents and other communities including the beneficiaries and affected persons, � provide key project information to the stakeholders and communities, and to solicit their views on the project and its potential or perceived impacts, and � ensure that views and concerns of the communities and other stakeholders are incorporated into the project design and implementation with the objectives of reducing or offsetting negative impacts and enhancing benefits of the proposed project. 10.1.2 Consultation and Participation Framework 521. The stakeholder consultation is a continuous process, and should be carried out throughout the life of project. The consultations carried out during the social assessment and reported in this Chapter are essentially among the initial steps in this process. Participation of the project stakeholders need to be ensured during the subsequent project phases as well. Table 5.1 provides the consultation and participation framework for stakeholder consultation and participation in the subsequent project phases from detail design to civil works construction. Table 10-1 Consultation and Participation Framework Project Stage Proposed Tool Stakeholders Responsibility Project Design Phase Meetings with institutional Institutional ESA consultant. stakeholders (carried out stakeholders; during the present ESA); Local stakeholders, Meetings with grass root including the stakeholders (carried out communities to be during the present ESA) affected/benefitted during the project implementation. Project Construction Sharing of the project Institutional Site level executives of 187 Project Stage Proposed Tool Stakeholders Responsibility / implementation objectives, project stakeholders; the DG-Food under the Phase components, major benefits, Local stakeholders, PMU potential impacts, and including the mitigation measures with communities to be the affected communities affected/benefitted (and other stakeholders). during the project implementation. Grievance Redressal The communities to be GRCs at local and Mechanism (discussed in affected/benefitted central levels for the SMF). project Consultations with the The communities to be SA consultant. communities during affected/benefitted Environmental and Social Monitoring (discussed in EMF/SMF). Consultations with the The communities to be External monitoring project affectees / affected/benefitted consultant. beneficiaries and communities during the external monitoring (EMF/SMF). Consultations with the The communities to be WB monitoring project affectees / affected/benefitted; mission. beneficiaries, and District government communities during the site officers visits by the WB monitoring mission. Project Operation Liaison with the The communities to be Silo Manager/Regional Phase communities affected/benefitted Controller of Food under the DG-Food 10.2 Stakeholder Identification 522. DG-Food under the Ministry of Food has been preparing the project and will be responsible to implement it with financing from the International Developemnt Association (IDA) of the World Bank Group. According to the objectives of the project, the population in the disaster prone areas of Bangaldesh are the prime beneficiary of the project and they are spread all over the country, in the coastal zone, in the flood prone areas, and in the drought prone areas. Concentrated to the proposed silo sites, the residents attached to the sites will be impacted during construction and operation of the silos. Local leaders, traders, transporters and wage labourers have expressed their interest to the project. Key stakeholders of the project at various levels include: � DG-Food and its officials at HQ and in the field offices. � local administration – district and upazila level government officials. � local government institutions – municipalities, union and upazila parishads. 188 � beneficiaries of the project (i.e., farmers, traders, wage labourers, and other villagers) and the likely affected persons. � millers, transporters and transport workers. � the broader interested community. 10.3 Consultation Process 523. The consultations with the project stakeholders were carried out at two steps; once during identification of the sites for construction of silo facilitiesand again after finalization of the eitht selected sites. Community meetings and consultation with local peoples at the sites were conducted. The consuiltants and the DG-Food staff at the local level organized and conducted the community meetings and the consultant discussed various partinent issues with the local community representatives during site selection. Outside the silo sites, communities in two villages in Barisal were also consulted on current practice of grain storage at the family level and need for interventions for improved and safe storage facilities. The process of consultation was conceived to interact with the communities and other stakeholders on the project concept, objectives, design and likely impacts. Communities were consulted during site survey for selection of potential sites in Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensingh, Maheshwar Pasha, Chittagong, Mongla, Dinajpur, Naogaon, Bhaghabari, Khulna, and Govindaganj. However, the consultation during January was concentrated in Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensingh, Maheshwar Pasha, and Chittagong. The consultations helped understand local knowledge with respect to project objectives, current practices, problems and various other issues and concerns, and integrate these into the project design and social impact management. The participants of the consultation meetings at the eight selected sites and in the two villages in Patuakhali have been given at Annex-10. 10.4 Consultation during Site Identification 524. Consultation with local communities and institutional stakeholders were carried out at all potential sites in Barisal, Narayanganj, Dhaka, Ashuganj, Madhupur, Mymensingh, Maheshwar Pasha, Chittagong, Mongla, Dinajpur, Naogaon, Bhaghabari, Khulna, and Govindaganj. Key issues discussed in the community level during site identification were as presented in the Table 10.2. Table 10-2 Key Issues Discussed during Community Consultations Sl. Stakeholders consulted Major issues and Concerns No. 1. Local communities attached to the  Project objectives and benefits proposed silo sites (farmers, traders,  Project components related to silo facilities transporters, laborers, women, and  Need for participation of the communities in site others) selection and project design  Criteria for site selection 2. Likely affected households (likely to  Likely impacts on assets and income losing land, structures, income sources  Community attitude to the project – and livelihoods and those experiencing compensation measures and recommendations inconveniences during construction)  Community severance issues resulting from 189 displacement 3. Women and vulnerable groups  Relocation options and site locations  Livelihood restoration and enhancement. 4. District and upazila level government  Issues related to project impacts officials (land acquisition officers,  Process of resettlement planning physicians, forest officer, agriculture  Health safety and other social issues during officer) and local chairmen and union construction parishad members 10.5 Community attitude towards the project 525. As an infrastructure project, the Silo projects will have several impacts of varied significance. These impacts were shared with the communities and their views and inputs were sought to mitigate them. The consultations brought forth that despite some adverse impacts of the project, the communities and likely affected households (few sites) were very positive towards the project. They feel proud of having a project of national importance in their area. 10.6 Perceived benefits of the project 526. Each community recognized the benefits of the silos in terms of improved food security, price control, enhancement of transport business and increase in procurement encouraging more production and more employment. The community peoples believe that the project will create new employment and mobility of women enhancing family income. 10.7 Anticipated negative impacts 527. Consultation at the 14 sites indicate that the communities also perceive some adverse impacts of the project along with the intended benefits. The community perceived adverse social impacts of the Project interventions specific to proposed sites includes the following: (i) The Project will cause decrease of farm land and thereby farm products due to acquisition of agricultural land in Govindaganj and taking over khas lands in Manda and Modhupur . (ii) The acquisition and Project interventions will involve additional work and money for shifting the structures of the affected persons, though very small, in Govindaganj and in Baghabari . (iii) Safety of women and children may be endangered in the construction sites. Various types of crime can take place during the construction. (iv) The construction will eventually impact on the price and availability of land in the area for replacement land purchase by the affected persons. (v) The persons to be displaced from their residence and business or employment may suffer from diminishing income and loss of employment. (vi) Compensation for loss of assets can be inadequate and people will suffer alarmingly in collecting compensation from the government. (vii) Risks of infectious diseases may increase due to influx of non-local workers during construction. 190 10.8 Suggestions to mitigate adverse impacts 528. These likely adverse impacts can largely be mitigated with appropriate social and resettlement management. Well-planned and well managed social actions will check impoverishment of affected community and induce higher social facilities and livelihood opportunities. The Project should have awareness program to avoid the risk of infectious diseases during construction. The community people were involved through consultation on project design and anticipated consequences. The recommendations of the consultation process were:  All possible alternatives should be examined to minimize land acquisition for the silo facilities. Compensation for all losses – land, structure, trees – should be at replacement cost, where acquisition and displacement of people cannot be avoided.  During construction the local labors including women should be employed and adequate measures should be taken for safe work environment. 10.9 Consultation at Eight Selected Sites 529. Site level consultation was carried out after final selection of sites for eight silo facilities during January 2013 in Dhaka, Narayanganj, Comilla, Chittagong, Tangail, Mymensingh, Khulna and Barisal sites. The communities at all the eight sites were found enthusiast about the public silo facilities of modern technology. They have expressed all out supports from their part for construction of the silo facilities. They perceive that the modern silo facilities will ensure food security of the country during emergencies and natural disasters like flood and cyclones. They expect that new employment will be generated for local communities during and after construction. They also identified community institutions within 500-m periphery of the proposed silo sites. The community problems and needs for development and rehabilitation of the community institutions identified by the communities in the meetings at each site have been presented in Table 10.3. Table 10-3 Community Problems and Needs Consultation Site and Participants Community Problems and Needs 1. Consultation at Dhaka CSD Site The site is connected the highways with a A total of 38 local road along the bank of the river Buriganga. peoples participated There are a number of mazaars and in the meeting mosques run by the communities around including traders, the site. The local people demanded transport workers, development of the road running around transport the boundary of the CSD. The DG-Food businessmen, and suggests improvement of the road wage labourers. A alongside the Buriganga River to facilitate section is seen in the movement of food stock. picture. There is a mosque run by the DG-Food 2. Consultation at Narayanganj CSD Site within the CSD complex. However, the 191 Consultation Site and Participants Community Problems and Needs local people requested an school and a 42 local people health centre with special services to the participated in the female population of the area. meeting including labourers, traders, men and women ( a section is seen in the picture) 3. Consultation at Ashuganj Site There are a number of sociocultural institutions within the periphery of the silo According to the site including the Alal Shah High School, consultation the Islamia Aliya Madrasa, Uttara Para records, 106 Jame Mosque, Moharam Para Jame persons including Mosque, Rowshonary Girls High School, farmers, traders the Rail Station Mosque, Hazi Abdul Jalil wage labourers, Jame Mosque, the Graveyard and the unemployed Eidgah those needs immediate youths, men and rehabilitation. women The local communities further demanded participated in the that a mosque, a madrasa, a primary meeting. A section school, and a children’s park can be is seen in the established within the silo compound in picture. available vacant lands. 4. Consultation at Madhupur Site 47 persons including The communities around the silo site feel transport that an School, a Health Centre, a operators, recreation centre are necessary in the area. transport They demanded reconstruction of existing workers, farmers 1-km road by the side of boundary wall of millers, teachers, BFIC which connected Ramkrisna Bari religious leaders, Village with the Mymensingh -Tangail and traders road. participated in the meeting. The communities demanded construcirton 5. Consultation at Mymensingh Site of a River Jetty at the Gudara Ghat (ferry crossing site) for local boats at the river in 192 Consultation Site and Participants Community Problems and Needs front of CSD gate and to develop the road (approx. 150 yards) connecting the gate Participants (39) and the ‘Gudara Ghat’. include farmers, They also feels that a school, a health labour leaders, centre, and a recreation centre can be labourers, elected established around the site. The representatives, millers, dealers, communities also demanded development religious leader, of the 1-km road connecting Mymensingh- and the like. Tangail Road with the small railway station named ‘Mymensingh Road Station’. 6. Consultation at Chittagang Site A total of 37 persons The local communities are interested in including service development of water supply, holders, students, environmental improvement, development traders, mechanics, of drainage system, development of the rickshaw pullers and approach road to minimize traffic jam, autorickshaw drivers, establishment of a new school and a housewives, men and hospital in the area. women participated in the meeting. 7. Consultation at Barisal CSD Site There are 5 schools, 2 colleges, 7 private A total of 28 hospitals, one government hospital, 4 persons including mosques, 2 girzas, 6 private clubs and 4 DG-food staff, NGOs operating within 500m periphery of local farmers, the silo site. traders wage labourers, The local people demanded development unemployed of the Boddho Bhumi (site of mass killing youths, men and by the occupation force during the women liberation war) and construction of a mini participated in Park. the meeting. 8. Consultation at Maheswarpasha Site, Khulna There are a number of religious and 193 Consultation Site and Participants Community Problems and Needs general educational institutions including Thirty (30) local Shaebpara Girls high school, Maniktola persons Darul ulum Hafizea Madrasha and islamic including mosques includding Mohammadia labourers, local Forkania Madrasha (Senpara), Shaebpara residents, trade Baitul Elahi Mosque, Mosjidul Meraj union leaders, Maniktola those needs extension and port traders rehabilitation. participated. 530. The communities at the eight selected sites understand that construction for civil works may involve sudden increase of migrant labourers at the construction sites. The influx of the non-local workers may pose a threat to the local public health environment if safe work environment cannot be maintained. Employment of local labourers will be more safe on health concerns. 10.10 Consultation at Village Level in Patuakhali 531. The coastal zone including Khulna, Barisal and Patuakhali districts are prone to natural disasters like cyclones and tidal inundations. Communities in two different villages in two unions in Patuakhali were consulted during January 2013 to understand the current practice and problems with family level grain storage. The villages were visited by the local DG-Food officials and consultants on 3 January 2013 and had a meeting with the communities there. A total 143 persons (61 in Tinghoria and 83 iin Balakathi) including local elected representatives, farmers and women participated in the consultation meetings. Consultation at vilage Tinghoria, Amkora Union Consultation at vilage Balaikathi, Awliapur Union 532. The two villages (Balaikathi in Awliapur Union and Tinghuria in Amkora Union in Sadar Upazila) constitute 1850 households and 80% of these households are agriculture land holders. The communities in the meetings provided the information that about 78% of the households in these two villages store milled rice, 23% store paddy and other grains, and only 14% keeps crop seeds for their use. About 19% of the households keep grain storage up to 30 kg, 22% keeps 31-50 kg, 29% keeps 51-70 kg, 194 26% keeps 71-100 kg and only 19% stores above 100 kg. Table 10.4 provides details of the storage practice by communities in the coastal districts. Table 10-4 Storage Practice by Communities in Patuakhali district Type of Grains No. of households by size of storage (multiple response) Upto 30 kg 31-50 kg 51-70 kg 71-100 kg 100 kg + Total % Milled Rice 350 300 400 300 100 1450 78 Paddy 50 60 100 100 310 17 Other grain 12 22 31 45 110 6 Crop seeds 45 60 55 100 260 14 Total 350 407 542 486 345 1850 100 % 19 22 29 26 19 100 Source: Consultation at Balakathi and Tinghoria villages in Patuakhali, January 2013 533. The communities generally use plastic and metal containers for milled rice storage available in the market out of emptied chemical or fuel/oil containers. Prices of these empty plastic containers range from BDT 200 to BDT 800. For paddy and other grain storage, the farmers use gunny bags, dole (bamboo mat container) and Matka (pottery). Crop seeds are always stored in Matka. Dole is for storage of paddy and other grains of larger volume. Gunny Bags Metaled/tin Container Pottery (matka) 534. In these conventional storage bins, 10-12% of grains are damaged due to decay, insects and rodents. Besides, these storage facilities are not safe during disaster. The communities understand that they should gradually shift to more modern methods of storing of food grains and seeds for a longer period at household level. Large plastic containers capable of storing 60- 80 kg food grains should be made available all over the country at an affordable price. Plastic bin silos will be helpful if the size is between 70 to 80 kg and there should be provision for anchorage so that silos are secured during disaster. 535. The farmers are generally in the need for grain storage especially crop seeds. There may be others who have cultivable land and those who procure rice, paddy, wheat etc. for local sale. The communities opine that the price of the proposed plastic silos will be affordable to the poor 195 farmers if the price is kept within BDT 200 to BDT 500. However, the non-poor farmers may be able to pay a bit higher prices. 536. The communities have identified common amenities including service roads, educational and religions institutions and common cultural properties and facilities in the peripheries of the eight sites. These facilities will not be affected by the project interventions. However, they expect that these facilities can be improved for socioeconomic development of the areas. Due attention will be given to the community expectations for detailed engineering design during implementation of the project. The project will support the enhancement of the environment, such as improved landscaping, plantation of trees to improve the aesthetics of tall steel silos, etc. 10.11 Disclosure 537. DG Food will follow the disclosure requirement of the World Bank on environmental documentation. After the clearance from the World Bank, the draft final version of the ESAMF will be posted in the website of DG Food along with a Bangla summary version and will be kept in the offices for further comments and inputs from non-governmental organization, civil society and general public. Newspaper advertisement will be published in two national dailies (English and Bangla) about the disclosure and request for comments the documents. It will be disclosed in English by World Bank and it will also be made available at the World Bank’s Info Shop. The ESAMF will be finalized taking into consideration of the comments received on draft version and will be available in DG Food websites. The final version of the ESAMF along with the Bangla will be available at Silo Site office. 196 Contents Annex 1 Steps involved in environmental clearance from DOE ..................................... A2 Annex 2: Sample checklist for screening for BMFSFP ................................................... A3 Annex 3: Site Specific Environmental Screening Checklist............................................ A6 Annex 4: Example Of Traffic Survey Data ................................................................... A38 Annex 5 : TRIP Model used in simulating traffic flow: ................................................ A49 Annex 6: Fumigation Application Guideline ................................................................. A51 Annex 7: Site Overview and Environmental Mitigation Measures ............................... A53 Annex-8 Screening Form For Social Safeguards Issues ................................................ A81 Annex-9 Eligibility and Entitlement Matrix .................................................................. A87 Annex-10 List of Participants in Consultation Meetings during January 2013 ............. A90 Annex 1 Steps involved in environmental clearance from DOE APPLICATION TO DOE GREEN AMBER A AMBER B RED The application should be The application should be The application should be The application should be enclosed: enclosed: enclosed: enclosed: i. General i. General information: i. Feasibility Study Report (for i. Feasibility Study Report (for information; ii. Description of raw materials proposed industry/ project); proposed industry/project); ii. Description of raw & finished products: ii. Initial environmental ii. Initial environmental materials & finished iii. An NOC examination (IEE)( for examination (EEE) Report products; iv. Process flow diagram, proposed industry/project); and Environmental Impact iii. An NOC Layout plan, Effluent iii. Environmental management Assessment (EIA) Report (for disposal system, etc; plan(EMP) report (for proposed industry/project); existing industry/ project ); iii. Environmental management iv. An NOC; plan (EMP) Report (for v. Pollution minimization plan; existing industry/project) vi. Outshine of relocation plan; iv. An NOC; Obtaining Environmental Obtaining Site Clearance etc v. Pollution minimization plan; Clearance vi. Outshine of relocation plan; etc Such a clearance will be Applying for Environmental subjecte to renewwal after Obtaining site clearance Obtaining site clearance Clearance each three year period Obtaining Environmental Applying for Environmental Applying for Environmental Clearance Clearance Clearance Such a clearnce will be Obtaining Environmental Obtaining Environmental subject to renewal after each Clearance Clearance one year period Such a clearnce will be Such a clearnce will be subject to renewal after each subject to renewal after each one year period one year period A-2 Annex 2: Sample checklist for screening for BMFSFP Name and Location of the sub-project: Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage?  Water logging in the site or flood experience?  Destruction of trees and vegetation?  Negative effect on wildlife habitat, populations, corridors or movement?  Breeding place for any endangered, threatened species?  Air pollution especially particulate matter?  Transportation linkage of roadway?  Need any improvement?  Transportation linkage of railway?  Need any improvement?  Transportation linkage of waterway?  Need any dredging?  Need land acquisition?  Contaminated land at the site?  Degradation or disturbance of historical or culturally important sites (mosque, graveyards, monuments etc.)?  Negative effect on locally important or valued ecosystems i,e., ecologically protected area?  Need demolishing of any structure?  Require land filling? A-3  Source of land filling material/soil? Assessment during Construction  Impacts on sustainability of associated construction waste disposal or emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos?  Increased noise due to transportation of equipment and construction materials?  Increased noise due to day-to-day construction activities?  Increased wind-blown dust from material (e.g. fine aggregate) storage areas?  Health risks to labors involve in activities?  Traffic disturbance due to construction material transport and wastes?  Time restriction of construction?  Negative effect due to disposal of slurry and sludge for foundation work  Negative impacts on food grain with inert dust or residual chemicals?  Need fumigation in the food grain? If so, level of pollution due to using CO2  Possibility of any odour release to air due to movement of Insect or mould activity through the grain?  Food contamination due to dust explosion?  Possibility of spoilage of the food grain? If so, possibility of food contamination?  Need further pest management in the grains? A-4  Equipment troubleshooting *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact Medium Impact High Impact A-5 Annex 3: Site Specific Environmental Screening Checklist Annex 3.1: Screening checklist example for the sub project site at Barisal CSD Name and Location of the sub-project: Barisal CSD Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable  Water logging in the site or flood experience? √ Never affected 27 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √ Lined roads need to  Transportation linkage of roadway? √ improve by some patch  Need any improvement? works  Transportation linkage of railway? √  Need any improvement? There are two jetties and one pontoon (owned by  Transportation linkage of waterway? BIWTA) currently in the √  Need any dredging? sub-project area. At present, maximum 1000 mt barge can be A-6 loaded/ unloaded. Therefore, dredging is not required for this capacity barges at present.  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √ The 1971 memorial  Degradation or disturbance of historical or culturally important sites √ √ (1) monument needs (mosque, graveyards, monuments etc.)? protection  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area?  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of CSD area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do A-7 Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile work will have natural evaporation and not  Negative effect due to disposal of slurry and sludge for foundation √ required to be separate work disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the  Need fumigation in the food grain? If so, level of pollution due to phosphine gas is using CO2 √ biodegradable. Moreover, no such cross infestation because of A-8 controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below 12% and the grains are  Food contamination due to dust explosion? √ chilled as well; thereby eliminating the chances of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-9 Annex 3.2: Screening checklist example for the sub project site at Dhaka CSD Name and Location of the sub-project: Dhaka CSD Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable In 1988, the site was  Water logging in the site or flood experience? √ flooded for 1 m depth of water 9 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? Lined roads need to √  Need any improvement? improve  Transportation linkage of railway? √  Need any improvement? There is a jetty in the  Transportation linkage of waterway? √ sub-project area, but it is  Need any dredging? not in operation.  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ A-10 (mosque, graveyards, monuments etc.)?  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area? All 15 godowns need to  Need demolishing of any structure? √ √ (1) demolish Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of CSD area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences.  Negative effect due to disposal of slurry and sludge for foundation √ The slurry from the pile A-11 work work will have natural evaporation and not required to be separate disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is  Food contamination due to dust explosion? √ maintained at below 12% and the grains are A-12 chilled as well; thereby eliminating the chances of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-13 Annex 3.3: Screening checklist example for the sub project site at Mymensingh CSD Name and Location of the sub-project: Mymensingh CSD Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable In 1988, the site was  Water logging in the site or flood experience? √ flooded for 6 inch depth of water 232 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? √  Need any dredging?  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)? A-14  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area?  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile  Negative effect due to disposal of slurry and sludge for foundation √ work will have natural work evaporation and not A-15 required to be separate disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below  Food contamination due to dust explosion? √ 12% and the grains are chilled as well; thereby eliminating the chances A-16 of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-17 Annex 3.4: Screening checklist example for the sub project site at Narayanganj CSD Name and Location of the sub-project: Narayanganj CSD Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable In 1988, the site was  Water logging in the site or flood experience? √ flooded for 2ft depth of water 10 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? √  Need any dredging?  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)? A-18  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area? 17 out of order godowns  Need demolishing of any structure? √ need to demolish Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences.  Negative effect due to disposal of slurry and sludge for foundation The slurry from the pile √ work work will have natural A-19 evaporation and not required to be separate disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below  Food contamination due to dust explosion? √ 12% and the grains are chilled as well; thereby A-20 eliminating the chances of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-21 Annex 3.5: Screening checklist example for the sub project site at Ashuganj silo Name and Location of the sub-project: Ashuganj silo Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable Worst flood in 1988, the  Water logging in the site or flood experience? √ site was flooded for 1ft depth of water 118 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? √  Need any dredging?  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)? A-22  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area?  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile  Negative effect due to disposal of slurry and sludge for foundation √ work will have natural work evaporation and not A-23 required to be separate disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below  Food contamination due to dust explosion? √ 12% and the grains are chilled as well; thereby eliminating the chances A-24 of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-25 Annex 3.6: Screening checklist example for the sub project site at Madhupur high land Name and Location of the sub-project: Madhupur high land Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable  Water logging in the site or flood experience? √ Never experienced 690 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? √  Need any dredging? Land is owned by DC  Need land acquisition? √ food and need to acquire by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)? A-26  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area?  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile  Negative effect due to disposal of slurry and sludge for foundation √ work will have natural work evaporation and not A-27 required to be separate disposal. Using Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below  Food contamination due to dust explosion? √ 12% and the grains are chilled as well; thereby eliminating the chances A-28 of any kind of dust explosion There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-29 Annex 3.7: Screening checklist example for the sub project site at Maheshwarpasha CSD/Silo Name and Location of the sub-project: Maheshwarpasha CSD/Silo Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable  Water logging in the site or flood experience? √ Never experienced 75 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? √  Need any dredging?  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)?  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area? A-30  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile work will have natural  Negative effect due to disposal of slurry and sludge for foundation √ evaporation and not work required to be separate disposal. Using A-31 Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below 12% and the grains are  Food contamination due to dust explosion? √ chilled as well; thereby eliminating the chances of any kind of dust explosion A-32 There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-33 Annex 3.8: Screening checklist example for the sub project site at Chittagong silo Name and Location of the sub-project: Chittagong silo Scale of Impact* Screening Questions Yes No High Medium Low Remarks (5) (3 or 4) (1 or 2) Location Assessment  Site has insufficient drainage? √ Not applicable  Water logging in the site or flood experience? √ Never experienced 23 mature trees will be  Destruction of trees and vegetation? √ √ (1) directly affected during construction No such species  Negative effect on wildlife habitat, populations, corridors or anticipated to be √ movement? affected by the intervention  Breeding place for any endangered, threatened species? √ Do  Air pollution especially particulate matter? √  Transportation linkage of roadway? √  Need any improvement?  Transportation linkage of railway? √  Need any improvement?  Transportation linkage of waterway? Port city silo. No √  Need any dredging? dredging is required  Need land acquisition? √ Land is owned by DGF  Contaminated land at the site? √  Degradation or disturbance of historical or culturally important sites √ (mosque, graveyards, monuments etc.)?  Negative effect on locally important or valued ecosystems i,e., √ ecologically protected area? A-34  Need demolishing of any structure? √ Sandy clayey soil need to  Require land filling? fill √ √ (1)  Source of land filling material/soil? Source: outside of sub project area Assessment during Construction  Impacts on sustainability of associated construction waste disposal or √ emission of spill of oil/lubricant  Negative impacts on sources of raw materials of constructing silos? √ Need to control  Increased noise due to transportation of equipment and construction √ √ (1) following mitigation materials? measures  Increased noise due to day-to-day construction activities? √ √ (1) Do  Increased wind-blown dust from material (e.g. fine aggregate) storage √ √ (1) Do areas?  Health risks to labors involve in activities? √ √ (1) Do Need to control following mitigation measures.  Traffic disturbance due to construction material transport and Construction will not be wastes? √ √ (1) done at night to avoid  Time restriction of construction? disturbing the neighborhood residences. The slurry from the pile work will have natural  Negative effect due to disposal of slurry and sludge for foundation √ evaporation and not work required to be separate disposal. Using A-35 Bentonite in piling is necessary Assessment during operating phase Phosphine gas from using aluminum phosphine granules is √ biodegradable and would  Negative impacts on food grain with inert dust or residual chemicals? not have any kind of residual effect on the food grains Aluminum phosphine is used as fumigant but the phosphine gas is  Need fumigation in the food grain? If so, level of pollution due to biodegradable. using CO2 √ Moreover, no such cross infestation because of controlled dryer and chiller No such movement of  Possibility of any odour release to air due to movement of Insect or √ insects through the food mould activity through the grain? grain moisture of the rice is maintained at below 12% and the grains are  Food contamination due to dust explosion? √ chilled as well; thereby eliminating the chances of any kind of dust explosion A-36 There is little possibility  Possibility of spoilage of the food grain? If so, possibility of food √ of spoilage during contamination? storage.  Need further pest management in the grains? √ Periodic monitoring and  Equipment troubleshooting √ √ (1) maintenance of the devices are needed *Scale of 1-2 for low, 3-4 for Medium and 5 for High impact. Categorization: Category Action Required Low Impact The sub-project needs limited environmental study and indicative mitigation measures Medium Impact High Impact A-37 Annex 4: Example Of Traffic Survey Data Annex 4.1: Example of traffic survey data at outside of Barisal CSD Vehicles Number of Total Number of Time period Rate of flow composition Vehicles Vehicles Day time vehicles/hr Trucks 4 Human hauler 8 32 9:00-9:15 128 Rickshaw 10 Motor cycle 10 Trucks 3 Human hauler 9 36 9:15-9:30 144 Rickshaw 13 Motor cycle 11 Trucks 2 Human hauler 3 Rickshaw 16 30 10:00-10:15 120 Motor cycle 6 Bicycle 3 Trucks 0 Human hauler 7 Rickshaw 16 37 10:15-10:30 148 Motor cycle 6 Bicycle 8 Trucks 2 Human hauler 10 Rickshaw 26 49 11:00-11:15 196 Motor cycle 8 Bicycle 3 Trucks 6 Human hauler 12 Rickshaw 10 46 11:15-11:30 184 Motor cycle 9 Bicycle 9 Trucks 7 Human hauler 11 Rickshaw 8 41 12:00-12:15 164 Motor cycle 7 Bicycle 8 Trucks 3 Human hauler 9 Rickshaw 8 26 12:15-12:30 104 Motor cycle 6 Bicycle 0 A-38 Annex 4.2: Example of traffic survey data at outside of Mymensingh CSD Number of Total Number Time period Rate of flow Vehicles composition Vehicles of Vehicles Day time vehicles/hr Trucks 7 Bus 15 Human hauler 8 52 9:00-9:15 212 Rickshaw 9 Motorize Rickshaw 8 Motor cycle 5 Trucks 9 Bus 3 Human hauler 9 49 9:15-9:30 224 Rickshaw 12 Motorize Rickshaw 9 Motor cycle 7 Trucks 7 Bus 17 Human hauler 5 Rickshaw 3 46 10:00-10:15 228 Motorize Rickshaw 5 Motor cycle 6 Bicycle 3 Trucks 8 Bus 12 Human hauler 7 Rickshaw 7 50 10:15-10:30 200 Motorize Rickshaw 8 Motor cycle 6 Bicycle 2 Trucks 9 Bus 9 Human hauler 10 Rickshaw 9 56 11:00-11:15 224 Motorize Rickshaw 6 Motor cycle 8 Bicycle 5 Trucks 10 Bus 12 Human hauler 10 Rickshaw 7 59 11:15-11:30 244 Motorize Rickshaw 9 Motor cycle 7 Bicycle 4 Trucks 7 52 12:00-12:15 208 A-39 Number of Total Number Time period Rate of flow Vehicles composition Vehicles of Vehicles Day time vehicles/hr Bus 8 Human hauler 11 Rickshaw 8 Motorize Rickshaw 9 Motor cycle 7 Bicycle 2 Trucks 3 Bus 8 Human hauler 9 Rickshaw 8 49 12:15-12:30 196 Motorize Rickshaw 16 Motor cycle 5 Bicycle 0 A-40 Annex 4.3: Example of traffic survey data at outside of Narayanganj CSD Rate of Total Number Time period Number of flow of Vehicles Day time Vehicles composition Vehicles vehicles/hr Motorcycle 6 Autorickshaw 7 Autotempo 4 Car 7 Jeep 2 39 9:00-9:15 156 Microbus 4 Pickup 3 Bus/Minibus 6 Truck/Cargo 10 Motorcycle 6 Autorickshaw 6 Autotempo 7 Car 7 Jeep 3 55 9:15-9:30 220 Microbus 4 Pickup 7 Bus/Minibus 6 Truck/Cargo 9 Motorcycle 8 Autorickshaw 2 Autotempo 4 Car 7 Jeep 2 42 10:00-10:15 168 Microbus 3 Pickup 5 Bus/Minibus 3 Truck/Cargo 8 Motorcycle 6 Autorickshaw 4 Autotempo 3 Car 7 Jeep 2 44 10:15-10:30 176 Microbus 2 Pickup 4 Bus/Minibus 3 Truck/Cargo 13 Motorcycle 5 Autorickshaw 7 46 11:00-11:15 184 Autotempo 4 Car 1 A-41 Rate of Total Number Time period Number of flow of Vehicles Day time Vehicles composition Vehicles vehicles/hr Jeep 2 Microbus 2 Pickup 5 Bus/Minibus 6 Truck/Cargo 14 Motorcycle 2 Autorickshaw 5 Autotempo 4 Car 8 Jeep 2 51 11:15-11:30 204 Microbus 11 Pickup 5 Bus/Minibus 3 Truck/Cargo 11 Motorcycle 3 Autorickshaw 7 Autotempo 6 Car 9 Jeep 2 45 12:00-12:15 180 Microbus 3 Pickup 5 Bus/Minibus 3 Truck/Cargo 7 Motorcycle 8 Autorickshaw 5 Autotempo 5 Car 7 Jeep 5 56 12:15-12:30 224 Microbus 8 Pickup 3 Bus/Minibus 3 Truck/Cargo 12 A-42 Annex 4.4: Example of traffic survey data at outside of Ashuganj silo Number of Total Number Time period Day Rate of flow Vehicles composition Vehicles of Vehicles time vehicles/hr Motorcycle 13 Autorickshaw 6 Autotempo 4 Car 10 Jeep 2 57 9:00-9:15 228 Microbus 7 Pickup 3 Bus/Minibus 5 Truck 7 Motorcycle 10 Autorickshaw 6 Autotempo 4 Car 9 Jeep 2 53 9:15-9:30 212 Microbus 7 Pickup 3 Bus/Minibus 5 Truck 7 Motorcycle 10 Autorickshaw 6 Autotempo 4 Car 9 Jeep 3 54 10:00-10:15 216 Microbus 7 Pickup 3 Bus/Minibus 5 Truck 7 Motorcycle 9 Autorickshaw 9 Autotempo 4 Car 7 Jeep 2 54 10:15-10:30 216 Microbus 9 Pickup 4 Bus/Minibus 3 Truck 16 Motorcycle 9 Autorickshaw 7 Autotempo 10 64 11:00-11:15 256 Car 8 Jeep 2 A-43 Number of Total Number Time period Day Rate of flow Vehicles composition Vehicles of Vehicles time vehicles/hr Microbus 6 Pickup 5 Bus/Minibus 7 Truck 10 Motorcycle 5 Autorickshaw 4 Autotempo 7 Car 2 Jeep 4 56 11:15-11:30 224 Microbus 4 Pickup 3 Bus/Minibus 16 Truck 11 Motorcycle 9 Autorickshaw 4 Autotempo 7 Car 2 Jeep 8 57 12:00-12:15 228 Microbus 4 Pickup 3 Bus/Minibus 13 Truck 7 Motorcycle 7 Autorickshaw 9 Autotempo 5 Car 6 Jeep 7 55 12:15-12:30 220 Microbus 4 Pickup 3 Bus/Minibus 8 Truck 6 A-44 Annex 4.5: Example of traffic survey data at outside of Maheshwerpasha CSD/silo Vehicles Number of Total Number of Time period Rate of flow composition Vehicles Vehicles Day time vehicles/hr Trucks 7 Bus 16 Human hauler 8 53 9:00-9:15 212 Rickshaw 9 Motorize Rickshaw 8 Motor cycle 5 Trucks 9 Bus 10 Human hauler 9 56 9:15-9:30 224 Rickshaw 12 Motorize Rickshaw 9 Motor cycle 7 Trucks 10 Bus 17 Human hauler 5 Rickshaw 3 57 10:00-10:15 228 Motorize Rickshaw 13 Motor cycle 6 Bicycle 3 Trucks 8 Bus 12 Human hauler 7 Rickshaw 7 50 10:15-10:30 200 Motorize Rickshaw 8 Motor cycle 6 Bicycle 2 Trucks 9 Bus 9 Human hauler 10 Rickshaw 9 56 11:00-11:15 224 Motorize Rickshaw 6 Motor cycle 8 Bicycle 5 Trucks 12 Bus 13 Human hauler 10 Rickshaw 6 61 11:15-11:30 244 Motorize Rickshaw 9 Motor cycle 7 Bicycle 4 Trucks 7 Bus 8 52 12:00-12:15 208 Human hauler 11 Rickshaw 8 A-45 Motorize Rickshaw 9 Motor cycle 7 Bicycle 2 Trucks 3 Bus 8 Human hauler 9 Rickshaw 8 49 12:15-12:30 196 Motorize Rickshaw 16 Motor cycle 5 Bicycle 0 A-46 Annex 4.6: Example of traffic survey data at outside of Chittagong silo Number of Total Number of Time period Day Rate of flow Vehicles composition Vehicles Vehicles time vehicles/hr Motorcycle 13 Autorickshaw 10 Autotempo 4 Car 12 Jeep 2 64 9:00-9:15 256 Microbus 4 Pickup 3 Bus/Minibus 6 Truck/Cargo 10 Motorcycle 10 Autorickshaw 12 Autotempo 4 Car 7 Jeep 3 66 9:15-9:30 264 Microbus 4 Pickup 7 Bus/Minibus 6 Truck/Cargo 13 Motorcycle 8 Autorickshaw 10 Autotempo 4 Car 10 Jeep 2 61 10:00-10:15 244 Microbus 5 Pickup 5 Bus/Minibus 3 Truck/Cargo 14 Motorcycle 11 Autorickshaw 9 Autotempo 4 Car 7 Jeep 2 65 10:15-10:30 260 Microbus 9 Pickup 4 Bus/Minibus 3 Truck/Cargo 16 Motorcycle 9 Autorickshaw 7 Autotempo 4 Car 6 Jeep 2 58 11:00-11:15 232 Microbus 2 Pickup 5 Bus/Minibus 6 Truck/Cargo 17 Motorcycle 9 Autorickshaw 10 63 11:15-11:30 252 Autotempo 4 A-47 Number of Total Number of Time period Day Rate of flow Vehicles composition Vehicles Vehicles time vehicles/hr Car 8 Jeep 2 Microbus 11 Pickup 5 Bus/Minibus 3 Truck/Cargo 11 Motorcycle 12 Autorickshaw 7 Autotempo 6 Car 15 Jeep 2 60 12:00-12:15 240 Microbus 3 Pickup 5 Bus/Minibus 3 Truck/Cargo 7 Motorcycle 7 Autorickshaw 9 Autotempo 5 Car 6 Jeep 7 65 12:15-12:30 260 Microbus 4 Pickup 3 Bus/Minibus 8 Truck/Cargo 16 A-48 Annex 5 : TRIP Model used in simulating traffic flow: The capacity of a two lane urban road can be calculated using above formula: g CA  1900 Nf w f HV PHF C C A = intersection approach capacity N = number of lanes on the segment (one direction) = Number of Peak Lanes W  12 f w = adjustment factor for lane width  1  30 Where: W = lane width in ft; minimum of 8, maximum of 16 100 f HV adjustment factor for heavy vehicles  100  HV ( ET  1) Where: HV = percent of heavy vehicles and ET = 2.0 passenger car equivalents, Here for outside street of the sub project sites located outside of city traffic, it is assumed that HV =50% to simulate the congestion effect of heavy vehicles/trucks and low speed vehicles PHF = Peak Hour Factor = 0.88 is considered for sub urban area considering semi urban condition g = effective green time-to-cycle length ratio = 0.55 is considered for sub urban arterials C A-49 Example of sensitivity analyses of traffic simulation at outside of Barisal CSD  Peak rate of traffic flow: 196 vehicles/h  Allowable maximum 60% use of road capacity is assumed for roads outside of Barisal CSD  Considering the peak flow rate the following scenario was extrapolated to see the probability of traffic congestion: i ii iii=i+ii iv= C A v=(iii/iv)100 Remarks Present Number New traffic % use road Change in Road peak rate of of flow rate capacity capacity for traffic additional (vehicles/h) additional trucks (vehicles/h) (trucks/h) (vehicles/h) 50 246 522 47.0 Recommended 75 271 491 55.0 Maximum allowable 100 296 473 62.5 Anticipated traffic 196 congestion 150 346 451 73.0 Anticipated traffic congestion 200 396 440 90.0 Anticipated traffic congestion Using the TRIP model to calculate traffic flow at outside street of Barisal CSD, maximum additional 50 trucks/h is allowable without traffic congestion. A-50 Annex 6: Fumigation Application Guideline In storage of food grains during operation of silos, aluminium phosphide (AP), will be used as a fumigant to prevent infestation so that the silo complex will not be cross contaminated. Phosphine gas from aluminum phosphine granules and the gas is bio degradable. It does not have any kind of residual effect on the food grains. AP is safe and well accepted all over the world as only a certified agency involved in the Pest Management would carry out this duty. The DGF has its own dose limit of using AP (12 gm/mt) in food grains and this dose will be followed also as guideline of fumigation in BMFSFP. DGF is authorized to use the indicative dose of fumigant agent in food grains PHOSPHINE(hydrogen phosphide) (Phostoxin, Detia, Fumitoxin, Phostek, Gastoxin, etc.) Widely used on stored grain. Good sealing is critical. Time is critical. Probing greatly improves results. Recirculation or modified technique for grain depths greater than 30 feet. EPA exposure limit of 0.3 ppm. Gas reading(s) required on each fumigation except in some situations. SCBA above 0.3 ppm (gas mask okay to 15 ppm or escape). Fumigation Guidelines Effective fumigations result from following several recommended guidelines including the following: Level the grain below the vertical wall of the bins. Remove or break up any crust on the grain surface. Seal all cracks, making the bin as airtight as possible. Fumigate when the graintemperature is between 70 and 90° F. Keep the bin closed and post warning signs until the gas concentration is below 0.3 ppm. DO NOT ENTERthe bin during or after fumigation until gases have been reduced to safe concentrations. (0.3 ppm). A-51 A-52 Annex 7: Site Overview and Environmental Mitigation Measures Table: Environmental impacts at sub project site at Barisal CSD under BMFSFP Parameter Features Natural drainage The site will be above road level. All storm water will drain to facility/flooding the river. There is no history of flooding at the site Vegetation There is not much vegetation. About 30 trees will be removed Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation Roadway, waterway (If water way dredging required or not): linkage The site is well connected by the road ways as the existing CSD is in place and doing the in bound and out bound cargo transportation by road and river barges. Regular dredging of the river takes place. Land acquisition The land belongs to the FD of GOB and there is no settlement at /resettlement the existing site Contaminated Not at all contaminated land or not Physical and A martyr memorial structure for the memory of 1971 Liberation cultural important war is between the river jetty and the prospective sub-project establishment site Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No structure is required to be decommissioned or demolished demolishing of any structure Filling required or Filling is required for about 3m. The source will be soil from not (If fill outside the CSD area or river dredging. required, then sources of fill material) A-53 Table: Environmental impacts during construction phase under BMFSFP Parameter Features Use of Construction machines like concrete mixers, fork lifts, hydraulic equipment- lifts etc. would be required. The machines would not have any emission and kind of oil or lubricant spills spill of oil, lubricant Sources of raw Most of the steel will be imported. Cement concrete for materials foundations will be locally sourced Dust, noise There will be some of noise pollution which can be mitigated by water pollution the use of the ear plugs on the site by the workers and the noise from equipment levels reduces with the distance to normal level. However, this and material effect is local and temporary. Health and Safety precautions need to be taken while working at the height safety during and all the workers need to wear helmets and safe uniforms construction following mitigation measures. Traffic About 40 ocean shipping containers (40 ft) holding about 700 mt congestion of silo and other equipment will be delivered to the site via truck from Chittagong port Timing of The construction will take place in day light construction Pile work- The slurry from the pile work will have natural evaporation and disposal will not require separate disposal. Using bentonite will improve management of workability. The site workers will use ear plugs at the time when slurry and noise noisy machines are working control A-54 Table: Environmental impacts during operation phase under BMFSFP Parameter Features Grain with inert The grains will not have any kind of inert dust but still it will be dusts or residual cleaned in a vibratory cleaner with the dust is collected in a bag chemicals filters. The aluminium phosphide residue is biodegradable. Atmosphere Only back up diesel generator will have exhaust of CO2, which polluted (e.g. shall have chimney as per the DOE’s norm carbon dioxide) Insect or mould The grain mass will be chilled to prevent mould. Insects indeed activity gives a not reproduce at this temperature distinct odour to air moved through the grain Dust explosion The silo technology controls the moisture of the rice below 12% and food and the grains are chilled as well there by eliminating the chances contamination of any kind of dust explosion. Moreover the dust is screened by the cleaners and all the conveying equipment have exhaust. Phosphine gas from aluminum phosphine granules and the gas is bio degradable and would not have any kind of contamination effect on the food grains. Rotten and waste There is no rotten or waste happening during the storage generation Pest Only as agency certified from pest management would carry out management and the fumigation using aluminum phosphine WB policy Equipment The equipment is lubricated for life and will be of top class troubleshooting design. Therefore it is not expected that a lot of break downs will occur. Repairs will be on the site without any lubricant leakage. Proper technical training is suggested as a mitigation measure. A-55 Table: Mitigation measures pre-construction phase at Barisal CSD under BMFSFP Parameter Mitigation features Mitigation As it is mentioned that only about 30 trees of non-endangered against removal species will be removed at the site of the sub-project area. In of trees order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation As the sub-project site require sandy-clayey fill (or prescribed by against soil design engineers), the properties of the soil is critical in this filling of mitigation issue. Engineering properties including consolidation marshy/ditch rates, and shear strength of the soil to be filled should be land complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. Mitigation to There is a monument in memory of the martyrs of the 1971 preserve Liberation War situated in the sub-project area which needs historical fencing to demarcate undisturbed area in the pre-construction monument phase. However, it is important to keep equipment and vehicles within the limits of the initially disturbed areas during all phases of the project. Moreover, building awareness to workers and the public about preserving the history of the country is very important to protect historical monument. Mitigation Proper waste management and disposal system should be done against solid during construction period Temporary workers camp and sanitary waste and toilets for the workers should be installed before starting the disposal work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. A-56 Table: Mitigation measures during construction phase under BMFSFP Parameter Mitigation features Mitigation The following mitigation measures will be carried out while against pollution transporting construction material at the sub-project site. during  All vehicles delivering material to the site will be covered to transportation of avoid spoilage of material construction  All haul roads will be kept clean and clear of all dust or mud material or other extraneous material dropped by such vehicles.  All vehicles used on site for this purpose will carry currently valid fitness certificates issued by the BRTA at all times copies of the same should be submitted to the Project Director.  All vehicles used on site for this purpose should comply with the pollution norms of ECR 1997  In dry weather conditions, any haul roads or roads used through the CSD’s residential area will be sprayed as necessary to suppress dust. Mitigation As it is mentioned in the article 6.2.1 that the air and dust against air/dust pollution during construction phase is temporary and will last for pollution the construction period only, the following mitigation measures will be carried out at the sub-project site to mitigate air and dust pollution while construction of silo will be carried on.  Use dust abatement techniques on unpaved, unvegetated surfaces to minimize airborne fugitive dust and during earthmoving activities, prior to clearing, before excavating, backfilling, compacting and grading of soils, especially at the specified marshy land of the site.  Post and enforce speed limits (20 kph) to reduce airborne fugitive dust from vehicular traffic.  Limit site access to authorized vehicles.  When possible, schedule surface-disturbing or dust- generating activities during periods of low winds to reduce fugitive dust.  Cover construction materials and stockpiled soils if they are a source of fugitive dust.  Train workers to handle construction materials and debris during construction and dismantlement to reduce fugitive emissions.  Keep soil moist while loading into dump trucks.  Keep soil loads below the freeboard of the truck.  Minimize drop heights when loaders dump soil into trucks. A-57  Tighten gate seals on dump trucks.  Cover dump trucks before traveling on public roads.  When feasible, shut down idling vehicles and equipment. Power compressors and pumps by electric motors where strict air emission rules would preclude the use of fuel. Mitigation Noise induced during construction may have some impacts to the against noise workers but very limited to the local residents. The following mitigation measures will need to follow during construction of the silo.  Locate permanent sound-generating facilities (i.e., generators) away from residences and other sensitive receptors.  Limit noisy activities to the least noise-sensitive times of day (weekdays only between 7 a.m. and 6 p.m.).  To the extent feasible, route heavy-truck and rail traffic away from residences and other sensitive receptors.  Equipment and machinery used for the project will comply with the relevant ECR norms and the relevant BRTA rules. Construction workers operating equipment that generates noise should be equipped with noise protection. It is recommended that workers operating equipment generating noise of ≥70 dB per hour should use ear muffs following the guidelines of International Finance Corporation (IFC). Mitigation In order to mitigate the issue of traffic disturbance inside the sub- against traffic project area, the following measures will be taken care of. disturbance  Limit traffic to roads indicated specifically for the project.  Develop a traffic management plan for site access roads and for use of main public roads. The plan should incorporate consultation with local CSD authority regarding traffic, in general, and specific issues, such as existing trucks loading and unloading schedule of the CSD premise.  Limit use of unimproved roads to emergency use only.  Instruct and require all personnel and contractors to adhere to speed limits (20 Kph) to ensure safe and efficient traffic flow.  There should be stand-by guards with shifting duties to check and control traffic during construction work. Mitigation Safety to the workers during construction period is a vital thing. against To safe guard the workers from injuries during construction time, occupational adequate safety equipment should be given to them. The hard health and safety cover helmets, gloves, boots, earplugs and earmuffs are some of the essential goods needed. Adequate amount of first aid A-58 medicine should be provided in construction site. A stretcher and other safety equipment should be on hand at all times. However, construction of steel silos is associated with risks of work from heights so the safeguards below should be followed during construction phase. Work at heights Falls from elevation associated with working with ladders, scaffolding, and partially built structures are among the most common cause of fatal or permanent disabling injury at construction sites. If fall hazards exist, a fall protection plan should be in place which includes one or more of the following aspects, depending on the nature of the fall hazard  Training and use of temporary fall prevention devices, such as rails or other barriers able to support a weight of 90 kilograms, when working at heights equal or greater than two meters (according to IFC)  Training and use of personal fall arrest systems, such as full body harnesses and energy absorbing lanyards able to support 2000 kilograms, as well as fall rescue procedures to deal with workers whose fall has been successfully arrested. The tie in point of the fall arresting system should also be able to support 2000 kiograms (according to IFC) Use of control zones and safety monitoring systems to warn workers of their proximity to fall hazard zones at the vicinity of silo construction area, as well as securing, marking, and labeling covers for on surfaces of steel frames of the silos Slips and falls Slips and falls on the same elevation associated with poor housekeeping, such as excessive waste debris, fall of bolts during assembling of steel frames, loose construction materials/bolst, and uncontrolled use of electrical cords and ropes on the ground, are also among the most frequent cause of lost time accidents at construction sites. Recommended methods for the prevention of slips and falls from, or on, the same elevation include:  Implementing good house-keeping practices, such as the sorting and placing loose construction materials or debris in established areas away from foot paths  Cleaning up excessive waste debris regularly at the end of the day’s work  Locating electrical cords and ropes in common areas and marked corridors  Use of slip retardant footwear Struck by objects Construction of steel silos may pose significant hazards related to the potential fall of materials or tools, as well as ejection of solid A-59 particles from abrasive or other types of power tools during assembling of the steel frames from height which can result in injury to the head, eyes, and extremities. Techniques for the prevention and control of these hazards include:  Using a designated and restricted waste drop or discharge zones, and/or a chute for safe movement of wastes from upper to lower levels  Maintaining clear traffic ways to avoid driving of heavy equipment over loose scrap  Use of temporary fall protection measures in scaffolds and out edges of elevated work surfaces, such as hand rails and toe boards to prevent materials from being dislodged Wearing appropriate personal protective equipment (PPE), such as safety glasses with side shields, face shields, hard hats, and safety shoes Moving Vehicle traffic and use of lifting equipment in the movement of machinery machinery and materials on a silo construction site may pose temporary hazards, such as physical contact, dust, emissions, and noise. Equipment operators have limited fields of view close to their equipment and may not see pedestrians close to the vehicle. Center-articulated vehicles create a significant impact or crush hazard zone on the outboard side of a turn while moving. Techniques for the prevention and control of these impacts include:  Planning and segregating the location of vehicle traffic, machine operation, and walking areas, and controlling vehicle traffic through the use of one-way traffic routes, establishment of speed limits, and on-site trained flag- people wearing high-visibility vests or outer clothing covering to direct traffic  Ensuring the visibility of personnel through their use of high visibility vests when working in or walking through equipment operating areas, and training of workers to verify eye contact with equipment operators before approaching the operating vehicle  Ensuring moving equipment is outfitted with audible back-up alarms  Using inspected and well-maintained lifting devices that are appropriate for the load, such as cranes, and securing loads when lifting them to higher job-site elevations. Over-exertion Over-exertion, and ergonomic injuries and illnesses, such as repetitive motion, over-exertion, and manual handling, are among the most common causes of anticipated injuries in silos A-60 construction sites. Recommendations for their prevention and control include:  Training of workers in lifting and materials handling techniques in construction projects, including the placement of weight limits above which mechanical assists or two-person lifts are necessary (according to IFC)  Planning work site layout to minimize the need for manual transfer of heavy loads, especially assembling the steel frames of the silos  Selecting tools and designing work stations that reduce force requirements and holding times  Implementing administrative controls into work processes, such as job rotations and rest or stretch breaks Confined spaces The ditch/marshy land at Barisal CSD is considered a confined and excavations space when access or egress will be limited during construction. The occupational hazards associated with confined spaces and excavations in silos construction site should be prevented according to the following recommendations:  Controlling site-specific factors which may contribute to excavation slope instability including, for example, the use of excavation dewatering, side-walls support, and slope gradient adjustments that eliminate or minimize the risk of collapse, entrapment, or drowning  Providing safe means of access and egress from excavations, such as graded slopes, graded access route, or stairs and ladders Prioritize Priority should be given to local people while employing laborers employment to for the project works. The use of children as laborers should be local people completely checked. Only adults (age of 18 or above) will be employed. For the up liftmen of economic level of local people, some vocational training as per the need and desire of the people should be organized. Such activities will enhance the skill of local people, which will finally help to improve the living standard of society. Once the living standard of the people is improved, the adverse impact on natural environment decreases. A-61 Table: Mitigation measures during operation phase under BMFSFP Parameter Mitigation features Mitigation of The following mitigation measures against noise will be carried noise during out during operation of silos as food grain storage. operation of silos  The noise level at the steel silo while loading will be reduced by putting baffle type silencers in both inlet ducts and exhaust ducts to arrest noise due to flow of air. The noise due to running of the machine will be arrested by acoustic enclosures.  Noise reduction is to be integrated in the plant building design to meet the regulatory standards during operation (maximum limit: 70 dB/hour).  All vehicles will be maintained properly and scheduled during day activities.  Provision of silencers for generators.  Routine maintenance of plant  The workers will use safety device for protection of ears (earmuffs and ear-plugs etc.) following IFC guideline  Silo facility foundation shall be designed to minimize vibration effect.  Periodic monitoring of noise in the silos site will be monitored using International Electrotechnical Commission (IEC) standard portable noise meter. Mitigation The steel silos to be constructed under BMFS project has the duct against dust at the dust collection point, which will be attached to a reverse jet during operation bag filter and then to the fan which will vacuum the duct and of silos extract the dust. These suction ducts will be suitably installed at the dump pit of the grain collection point, to the bucket elevator and chain conveyors also to collect dust during operation of silos. Mitigation In storage of food grains during operation of silos, aluminium against phosphide (AP), will be used as a fumigant to prevent infestation infestation of so that the silo complex will not be cross contaminated. food during Phosphine gas from aluminum phosphine granules and the gas is grains silo bio degradable. It does not have any kind of residual effect on the operations food grains. AP is safe and well accepted all over the world as only a certified agency involved in the Pest Management would carry out this duty. A-62 The chilling (mechanism is described in the article 6.3.1) is used in the silos will not allow the insects to reproduce or grow. Moreover, the low temperature (article 6.3.1) is mainly used for long term shelf stability for the rice and incidentally the low temperature inhibits any kind of insect propagation in the food grains. Mitigation The equipments used are lubricated for life and would be of top against class design. Breakdowns are not expected but it occurring just be troubleshooting done on the site with professionals with technical knowledge of equipments without any kind of lubricant leakage. during operation Mitigation Backup diesel generators would have exhaust of low emission of against CO2. They shall have chimneys as per the DOE’s norms. atmospheric pollution (CO2) during operation A-63 Table : Monitoring indicators for physical conditions Predicted Mitigation measure Indicators Methods Period of Responsible impacts for of monitoring authority monitoring monitoring /frequency Higher Moisture content is Rice sample Direct During Client/DGF moisture controlled at 12% in the and cross observation operation/ content of silo using dryer checking and weekly parboiled with the data measuring rice of automatic moisture control unit content of silo sample Presence Good quality parboiled Rice sample Direct During Client/DGF of brokens rice should be as same observation operation/ in rice quality at time of weekly grains loading and unloading Presence As the grain mass is Rice sample Direct During Client/DGF of insects chilled mould does not observation operation/ in rice occur and inspects weekly grains hibernate. Infestation Phosphine gas from Rice sample Testing During Client/DGF due to aluminum phosphine according operation/ fumigation granules. The gas is bio to BSTI half-yearly degradable and would standard not have any kind of residual effect on the food grains. Erosion Excavated soil placed Soil properly Direct During DGF/ and land safely against erosion placed and observation construction/ contractor stability and reuse of excavated reusing of weekly soil excavated soil Noise and Provisions of restriction Monitoring Direct During Client/DGF/ vibration on horns, equipment of observation construction contractor maintenance, mufflers the said and fitting to noise provision operation/ equipment, speed weekly restriction, etc. A-64 Table : Monitoring indicators for biological environment Predicted Mitigation measure Indicators Methods Period of Responsible impacts for of monitoring authority monitoring monitoring /frequency Loss of Provisions of Monitoring of Direct During Client/DGF vegetation minimization of the said observation construction /contractor vegetation clearance by provision and pegging, afforestation, operation/ restriction on the use of weekly fuel wood at the camps etc. A-65 Table: Monitoring indicators for social environment Predicted Mitigation measure Indicators Methods Period of Responsi impacts for of monitoring ble monitoring monitoring /frequency authority Social Instruction to all Checking Direct Construction Client/D structures workers to act in a of observation and GF/ and cultural responsible manner and options operation contractor practices prohibition of alcohol, and gambling alcohol and gambling Water Awareness campaign on Awareness Direct Construction Client/D supply sanitation and health Campaign observation and GF/ sanitation education to public and of operation/ contractor and health workers such daily campaign Occupation Employment of Safety Direct Construction Client/D al occupational safety and measures observation and GF/ health and health measures adopted operation/ contractor safety and first aid Once in kits are at three hand in the months working areas Aesthetic Development of land Final Direct Construction Client/D impacts with pleasant landscape observation and GF/ landscaping operation contractor A-66 Table: Environmental impacts at sub project site at Dhaka CSD under BMFSFP Parameter Features Natural drainage The site will be above road level. All storm water will drain to the river. facility/flooding The peak flood level occurred in 1988 when the CSD area was flooded to about 1 m water depth. But apart from this extreme flood situation of the country, there is no history of flooding at the site Vegetation There are 6 trees will need to cut Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation Roadway, waterway (If water way dredging required or not): The site is linkage well connected by the road ways as the existing CSD is in place. There is a pontoon for waterway transportation, but which is not used at present.. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ Existing CSD warehouses/godowns are required to decommission or demolishing of demolish any structure Filling required or Filling is not required. not (If fill required, then sources of fill material) A-67 Table: Mitigation measures pre-construction phase at Dhaka CSD under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 30 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against  Apply water every 4 hours to the area within 30m of structures demolishing being demolished, to reduce vehicle trackout. structure  Use a gravel apron, 25 feet long by road width, to reduce mud/dirt trackout from unpaved truck exit routes.  Apply dust suppressants (e.g., polymer emulsion) to disturbed areas upon completion of demolition.  Apply water to disturbed soils after demolition is completed or at the end of each day of cleanup.  Prohibit demolition activities when wind speeds exceed 30kph.  For scraper loading and unloading, it requires minimum soil moisture of 12% for earthmoving by use of a moveable sprinkler system or a water truck. Moisture content can be verified by lab sample or moisture probe.  Limit on-site vehicle speeds (on unpaved roads) to 20kph. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. A-68 Table: Environmental impacts at sub project site at Mymensingh CSD under BMFSFP Parameter Features Natural drainage Water usually accumulates in the monsoon up to 0.5 m at average in the facility/flooding low land area and water inundated the CSD area in the year of 1998 flood at 0.6 inch. Vegetation There are about 500 trees of which are coconut, mehagani, eukaliptus, karai, akashmoni, mangoes etc, which need to cut. Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation Communication of the site is by road way. The site is linked to the linkage 3.5m wide of Mymensingh-Tangail High way. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No demolishing of structure is required demolishing of any structure Filling required or Filling is required for about 3m. The source will be soil from outside not (If fill the CSD area or river dredging. required, then sources of fill material) A-69 Table: Mitigation measures pre-construction phase at Mymensingh CSD under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 500 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. A-70 Table: Environmental impacts at sub project site at Mymensingh CSD under BMFSFP Parameter Features Natural drainage The site will be above road level. All storm water will drain to the facility/flooding river. The peak flood level occurred in 1988 when the CSD area was flooded to about 1 m water depth. But apart from this extreme flood situation of the country, there is no history of flooding at the site Vegetation There are about 25 trees need to cut Corridor of wild life There is no wild life around the area Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation Roadway, waterway (If water way dredging required or not): The site linkage is well connected by the road ways as the existing CSD is in place. The access to the site is 16ft wide road coming from Dhaka- Chittagong highway via Kutubpur bazzr. There is a jetty for waterway transportation which is also used by 1000 tons barges.. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated land Not at all contaminated or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ Some of the existing CSD warehouses/godowns those are out of order demolishing of any require to decommission or demolish structure Filling required or Soil filling is required. And the source of the soil is from outside of not (If fill required, the CSD area. then sources of fill material) A-71 Table: Mitigation measures pre-construction phase at Narayanganj CSD under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 25 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against  Apply water every 4 hours to the area within 30m of structures demolishing being demolished, to reduce vehicle trackout. structure  Use a gravel apron, 25 feet long by road width, to reduce mud/dirt trackout from unpaved truck exit routes.  Apply dust suppressants (e.g., polymer emulsion) to disturbed areas upon completion of demolition.  Apply water to disturbed soils after demolition is completed or at the end of each day of cleanup.  Prohibit demolition activities when wind speeds exceed 30kph.  For scraper loading and unloading, it requires minimum soil moisture of 12% for earthmoving by use of a moveable sprinkler system or a water truck. Moisture content can be verified by lab sample or moisture probe.  Limit on-site vehicle speeds (on unpaved roads) to 20kph. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. A-72 Table: Environmental impacts at sub project site at Ashuganj Silo under BMFSFP Parameter Features Natural drainage The site is situated at above the road level. There is no history of facility/flooding flooding at the site. Vegetation There are about 20 trees need to cut Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation Roadway, waterway (If water way dredging required or not): The site is linkage well connected by the road ways at the existing CSD is in place. The access to the site is 15ft wide road coming from Dhaka-Sylhethighway. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No demolish of structure is required. demolishing of any structure Filling required or Some parts of the area needs soil filling. And the source of the soil is not (If fill from outside of the CSD area. required, then sources of fill material) A-73 Table: Mitigation measures pre-construction phase at Ashuganj Silo under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 20 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. A-74 Table: Environmental impacts at sub project site at Madhupur under BMFSFP Parameter Features Natural drainage The site is situated at 0.5m below the existing road level. There is no facility/flooding history of flooding at the site. Vegetation There are more than 200 matured trees and cultivated pineapples/banana are situated in this khas land, mostly irregularly planted to confirm ownership of the land owned by DC land. But, this land is out of the local forestry and the predicted negative impacts are local in nature and low in magnitude. Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation The site is connected by the road way. The access to the site is 16ft linkage wide road. Land acquisition The Khas land belongs to the DC land of GOB. /resettlement Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No demolish of structure is required. demolishing of any structure Filling required or About 1 m of soil filling is required. And the source of the soil is from not (If fill outside of the area. required, then sources of fill material) A-75 Table: Mitigation measures pre-construction phase at Madhupur under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 200 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. A-76 Table: Environmental impacts at sub project site at M.pasha, Khulna under BMFSFP Parameter Features Natural drainage Water does not accumulate in the monsoon but the site is located in the facility/flooding tidal zone. During the tidal period highest water level comes 1ft below the top of the concrete jetty. Vegetation There are more than 25 matured trees need to cut. Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation The site is connected by the road way. The access to the site is 16ft linkage wide road. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No demolish of structure is required. demolishing of any structure Filling required or About 0.5 m of soil filling is required to make the land level. And the not (If fill source of the soil is from outside of the area. required, then sources of fill material) A-77 Table: Mitigation measures pre-construction phase at M.pasha under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 25 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. A-78 Table: Environmental impacts at sub project site at Chittagong port silo under BMFSFP Parameter Features Natural drainage The land is almost level and water does not accumulate during facility/flooding monsoon. There is no history of flood at this site. Vegetation There are more than 10 matured trees need to cut. Corridor of wild There is no wild life around the area life Breeding place for There is no breeding area of any species any species Air pollution There will be no air pollution at the site especially PM Transportation The site is connected by the road way. The access to the site is 16ft linkage wide road. Land acquisition The land belongs to the FD of GOB and there is no settlement at the /resettlement existing site Contaminated Not at all contaminated land or not Physical and No such structure is present cultural important establishment Ecological critical It is not an ecologically protected area area/Protected area Decommissioning/ No demolish of structure is required. demolishing of any structure Filling required or About 0.5 m of soil filling is required to make the land level. And the not (If fill source of the soil is from outside of the area. required, then sources of fill material) A-79 Table: Mitigation measures pre-construction phase at Chittagong port silo under BMFSFP Parameter Mitigation features Mitigation against As it is mentioned that only about 10 trees of non-endangered species removal of trees will be removed at the site of the sub-project area. In order to minimize the effect of removal of trees, it is recommended to replant the uprooted trees in at least 1:5 ratios (05 re-plantation against 01 cut-tree) as per DOE’s norms. A landscaping plan will be needed so that the aesthetic quality of the site will be ensured. Mitigation against Proper waste management and disposal system should be done during solid waste and construction period Temporary workers camp and sanitary toilets for disposal the workers should be installed before starting the work. Mechanism for the safe disposal of solid waste and other construction waste should be developed in project site before the actual commencement of work. The waste should not be disposed in near-by river at any mean. Mitigation against As the sub-project site require sandy-clayey fill (or prescribed by soil filling of design engineers), the properties of the soil is critical in this mitigation marshy/ditch land issue. Engineering properties including consolidation rates, and shear strength of the soil to be filled should be complying according to BNBC code for the successful project. It is mentioned that the consolidation rates influence the final elevation of marsh back-fill soils, and shear strength may be important for determining the size and/or type of foundation for steel silo structures. A-80 Annex-8 Screening Form For Social Safeguards Issues [The filled out forms will be reviewed and evaluated by the Resettlement Specialist of the Detail Design Consultant. The consultant will include a summary estimate of the impacts and mitigation requirements for each site in the Screening Report. Impacts identification and the mitigation eligibility and requirements should follow the principles adopted in this SMF.] REVIEW and EVALUATION Name of site: ……………………..……………… Name of District: …..…………... Union/Municipality: …………………………………………… Upazila: …………………… I. Resettlement Impacts In respect of the social impacts and community concerns, is there a need to, Undertake an in-depth social impact assessment study? [ ] Yes [ ] No Prepare a Resettlement Plan? [ ] Yes [ ] No II. Impacts on Indigenous Peoples In respect of the social impacts on IPs and their concerns, is there a need to, Undertake an in-depth impact assessment study? [ ] Yes [ ] No Prepare an Indigenous Peoples Plan? [ ] Yes [ ] No On behalf of the consultant, the attached filled out format has been reviewed and evaluated by: Name: …………………………………………….. Designation: ……………..……..…... Signature: ………………………………………… Date: …………………... SOCIAL SAFEGUARDS SCREENING OF SUBPROJECT [To be filled in for each site jointly, DG-Food and Consultants and NGO (if engaged). Where private lands are to be acquired or public lands (including DG- Food’s own) are to be resumed from authorized and unauthorized private users, census of affected persons and inventory of losses to be carried out.] A. Identification A-81 1. Name of site: ……………………..……………… Name of District: …..…………... Union/Municipality: …………………………………………… Upazila: …………………… 2. Embankment section screened: .………….…...…………………..……………..................... ………………………………………………………………………………………………………… 3. Project component: .......................................................................................................... 4. Brief description of the physical works: …………………………................................................. ……………………………………………………………………………………………………………... …………………………………………………………………………………………………………….... ……………………………………………………………………………………………………………… 5. Screening Date(s): ………………………………………………………………………………...... B. Participation in Screening 6. Names of Consultants’ representatives who screened the subproject: ....…………………………………………………………………………….................................... ……………………………………..……………………………………………………………………..... 7. Names of DG-Food officials participated in screening: .……….…………………………….......... …………………………………………………..……………………………………………………….... ………………………………………………………………………………...…………………………... 8. Local Government representatives and community members & organizations participated in screening: List them in separate pages with names and addresses, in terms of embankment sections/spots and any other information to identify them during preparation of impact mitigation plans. 9. Would-be affected persons participated in screening: List them in separate pages with names, addresses in terms of embankment sections/spots where they would be affected, and any other information to identify them during preparation of impact mitigation plans. C. Land Requirements & Ownership 10. Will there be a need for additional lands* to carry out the intended works under this contract? [ ] Yes [ ] No (* ‘Additional lands’ mean lands beyond the existing right of way) 11. If ‘Yes’, the required lands presently belong to (Indicate all that apply): A-82 [ ] DG- [ ] Government – khas& other GOB agencies [ ] Private citizens Food [ ] Others (Mention): …………………………………………….......................................... D. Current Land Use & Potential Impacts 12. If the required lands belong to Private Citizens, they are currently used for (Indicate all that apply): [ ] Agriculture # of households using the lands: …………................................. [ ] Residential purposes # of households living on them: …………................................... [ ] Commercial purposes # of persons using them: …………............. # of shops: ...... [ ] Other Uses (Mention): ..………………………………..………………… # of users: …… 13. If the required lands belong to DG-Food and/or other Government agencies, they are currently used for (Indicate all that apply): [ ] Agriculture # of persons/households using the lands: …….……..................... [ ] Residential purposes # of households living on them: …………….................................. [ ] Commercial purposes # of persons using them: …………… # of shops: …… [ ] Other Uses (Mention): ……………………………….………..………...... # of users: .…… 14. How many of the present users have lease agreements with any government agencies? …………………………………………………………………............................................................ 15. Number of private homesteads that would be affected on private lands: Entirely, requiring relocation: …….. Partially, but can still live on present homestead: ...... 16. Number of business premises/buildings that would be affected on private lands: ………….. Entirely and will require relocation: …………......... # of businesses housed in them: ….... Partially, but can still use the premises: ...……… # of businesses housed in them: ….... 17. Residential households will be affected on DG-Food’s own and & public lands: ………….. Entirely affected and will require relocation: # of these structures: …………. # of structures built with brick, RCC, & other expensive and durable materials: ………….. # of structures built with inexpensive salvageable materials (bamboo, GI sheets, etc: .… Partially affected, but can still live on the present homestead: # of structures: …….……. # of structures built with brick, RCC, & other expensive and durable materials: ………….. # of structures built with inexpensive salvageable materials (bamboo, GI sheets, etc): .… 18. # of business premises that would be affected on DG-Food’s own & other public lands: A-83 Entirely affected and will require relocation: # of these structures: …………. # of businesses housed in these structures: …………… # of persons presently employed in the above businesses: …………… # of these structures built with brick, RCC, & other durable materials: …………… # of structure built with inexpensive salvageable materials (bamboo, GI sheets, etc): …… Partially affected, but can still stay in the present premises: # of these structures: ...………. # of businesses housed in these structures: ……………. # of persons presently employed in these businesses: …………… # of these structures built with brick, RCC, & other durable materials: …………… # of structure built with inexpensive salvageable materials (bamboo, GI sheets, etc): …… 19. # of businesses/trading activities that would be displaced from make-shift structures on the embankment, and other areas/spots: …………….. 20. Do the proposed project works affect any community groups’ access to any resources that are used for livelihood purposes? [ ] Yes [ ] No 21.If ‘Yes’, description of the resources: ……………………………………………….……............ ………………………………………………………………………………………..………………… …………………………………………………………………………………………………………… ………………………………………………………………………………………..………………… …………………………………………………………………………………………………..……… 22. Do the proposed works affect community facilities like school, cemetery, mosque, temple, or others that are of religious, cultural and historical significance? [ ] Yes [ ] No 23. If ‘Yes’, description of the facilities: ……………………………….……………………………… ……………………………………………..………………………………………………………..……… …………………………………………………………..………………………………………………… ……………………………………………………………………………………………………………… …………………………………………………………………………..………………………………… …………………………………………………………………………..………………………………… 24. Describe any other impacts that have not been covered in this questionnaire? …………………………………………………………………………..………………………………… ……………………………………………………………………………..………………….…………… ………………………………………………………………………..…………………………….…… A-84 …………………………………………………………………………………………………………… 25. Describe alternatives, if any, to avoid or minimize use of additional lands: ……………………………………………………………………..………………………….………… ………………………………………………………………………………………..………………… ………………………………………………………………………………………..………………… …………………………………………………………………………………………………………… ………………………………………………………………………………………….……………… E. ADDITIONAL INFORMATION ON INDIGENOUS PEOPLES (IPs) (This section must be filled in if sites are located in areas that are also inhabited by indigenous peoples or tribal peoples.) 26. Is the site located in an area inhabited by indigenous or tribal peoples? [ ] Yes [ ] No If the answer is no, skip this section of the form. 27. If the answer is Yes, is there any IPs outside the site are exposed to flood inundation and other natural calamities? [ ] Yes [ ] No 28. If the answer is Yes to question no. 27, is there any IPs likely to be benefited from the subproject? [ ] Yes [ ] No 29. If the answer is Yes to question no. 27, is there any IPs likely to be affected by the subproject? [ ] Yes [ ] No If the answers to questions 28, 29 and/or 30 are no, skip the following sections of the form. 30. Have the IP community and the would-be affected IPs been made aware of the potential positive and negative impacts and consulted for their feedback and inputs? [ ] Yes [ ] No Has there been a broad-based community consensus on the proposed works? [ ] Yes [ ] No 31. Total number of would-be affected IP households: .....…………………………………………. 32. The would-be affected IP households have the following forms of rights to the required lands: [ ] Legal: # of households: ………… [ ] Customary: # of households: ………… [ ] Lease agreements with any GOB agencies: # of households: …..…..… [ ] Others (Mention): .………………………………….………… # of households: ...……… A-85 33. Does the project affect any objects that are of religious and cultural significance to the IPs? [ ] Yes [ ] No 34. If ‘Yes’, description of the objects: ………………………………………..…………………….. ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… 35. The following are the three main economic activities of the would-be affected IP households: a. .……………………………………………………………………………………………… b. ……………………………………………………….……………………………………… c. …………………………………………………….………………………………………… 36. Social concerns expressed by IP communities/organizations about the works proposed under the subproject: .……………………………………................ ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… ………………………………………………………………………………………………………… 37. The IP community and organizations perceive the social outcomes of the subproject: [ ] Positive [ ] Negative [ ] Neither positive nor negative 38. Names of IP community members and organizations who participated in screening: ……………………………………………………….……………………………………………..…. ……………………………………………………….………………..………………………………. ………………………………………………………….…………..…………………………….…… On behalf of the consultant, this Screening Form has been filled in by: Name: …………………………………………….. Designation: ……………..……..…... Signature: ………………………………………… Date: …………………... A-86 Annex-9 Eligibility and Entitlement Matrix The following matrixes provide eligibility and entitlements under various categories of impacts recognized in compliance of the OP 4.12 and good practices in several Bank financed projects in Bangladesh. Any other impacts that might be identified during social screening of the individual sites and PAP census, as well as those that might be encountered during implementation of the civil works, will be recorded under additional categories and mitigated according to the principles and guidelines stated in this framework. Category - 1 LOSS OF LANDS Ownership Entitled Entitlement Responsibility Type Person Private Legal owners, Compensation-under-law (CUL) or replacement  CUL paid as determined cost1, whichever is higher. by DCs by DCs, or by  Top-up equal to the difference between CUL courts in cases and replacement value, if replacement value is  Top-up & of legal higher than CUL. TA paid by disputes  Transition allowance (TA) for income loss (see DG-Food Loss Category 4). Public lands Leaseholders Three-month advance notice and contractual Paid by DCs under lease obligations with the public agencies, as determined by DCs. Public lands Squatters and Three-month advance notice or rental allowance Paid by DG- under private occupiers of equivalent to 3 months rental of similar housing in Food use without residential the vicinity. lease land Squatters and Transition allowance for income loss (see Loss Paid by DG- occupiers of Category 4). Food non-residential lands Category 2 LOSS OF HOUSES/STRUCTURES USED FOR LIVING, BUSINESS & OTHER ACTIVITIES Type & Entitled Person Entitlement Responsibility Location All houses/ Legal owners, as  Compensation-under-law (CUL) or CUL paid by DCs structures on determined by replacement cost, whichever is higher. and Top-Up paid by acquired DCs, or by courts  Transfer Grant (TG) @ 7% of the DG-Food in case private lands in cases of legal replacement value (RV) of non-shiftable replacement cost is disputes. structure and 10% of RV of shiftable higher than CUL. structure, in cases where a house is to be 1 Replacement cost include current market price of land plus the expenditure for legalizing the land transfer including cost of stamp purchase and other duties. A-87 Category 2 LOSS OF HOUSES/STRUCTURES USED FOR LIVING, BUSINESS & OTHER ACTIVITIES Type & Entitled Person Entitlement Responsibility Location removed and constructed elsewhere.  Restoration of pre-acquisition level basic TG paid by DG- utilities (water supply, sanitation, Food electricity, etc.) at relocated sites.  Allowed to keep the salvaged materials. Structures on Squatters  Replacement value of structures to be Paid by DG-Food acquired determined by PAVC. public lands or  Transfer and Reconstruction Grant on DG-Food (TRG) @ 10%of the RV of the affected lands structure.  Assistance for finding out alternative lands for housing with water supply, sanitation, and other basic amenities.  Allowed to keep the salvageable materials. Category 3 LOSS OF TREES AND CROPS ON ACQUIRED PRIVATE & PUBLIC LANDS Location Entitled Person Entitlement Responsibility On private lands Legal owners as  Current market value of trees, based on DCs (included in determined by species, size and maturity. the CUL) and/or DCs, or by courts  Current market prices of fruits on trees, DG-Food in cases of legal if they are felled before harvest. (included in the disputes top-up)  Current market price of crops based on Current variety cultivator of  Owners are allowed to fall the trees and agricultural harvest the crops, and keep them. lands (including tenants) On public lands  Squatters As those stipulated above for trees and DG-Food  Private fruits. groups, NGOs, etc.* * Vacant public lands are sometimes leased out to private groups and NGOs for tree plantation under social forestation program under the department of forest. A-88 Category 4 LOSS OF AGRICULTURAL, BUSINESS, EMPLOYMENT & RENTAL INCOME Impact Type Entitled Person Entitlement Responsibility Agricultural:  If acquisition Legal owners, as Transition allowance @ BDT 100/00 per DG-Food amounts to 20% determined by decimal of acquired agricultural land. or more of the DCs, or by courts total productive in cases of legal land holding disputes. Business: Temporary Business Compensation, based on daily net income, DG-Food closure of Owners(premise/ for the actual number of days the businesses businesses in land owners & remain closed or needed to complete the existing premises tenants) civil works, whichever is smaller.  Partially Business Owners Compensation, calculated as above, for the DG-Food affected (premise/land number of days needed to repair and reopen businesses owners & the individual businesses, or complete the tenants) civil works, whichever is smaller.  Businesses Business Owners Compensation, calculated as above, for the DG-Food requiring (premise/land number of days the business owners need to removal from owners & find alternative locations themselves, which the existing tenants) will be paid for a maximum of 90 days. premises and lands Loss of Business Compensation at current daily wage rate for DG-Food employment Employees the period needed to reopen the businesses, income which will be for a maximum of 30 days. Loss of income Legal Owners Three months’ rent at the current rates to the DG-Food from rented-out owners of the premises. premises Category 5 UNFORESEEN LOSSES Impact Type Entitled Person Entitlement Responsibility As may be identified during As identified As determined in consultation By DG-Food site selection, design and with IDA and the stakeholders. implementation A-89 Annex-10 List of Participants in Consultation Meetings during January 2013 LIST OF PARTICIPANTS IN THE MEETING ON 02 JAN 2013 ASHUGANJ SILO SITE SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Md. Kamal Uddin Silo Supervisor /Food Department 01716 488152 2 Md. Mostafizur Rahaman Silo Supervisor /Food Department 01712 588631 3 Md. Shohidullah Silo Supervisor /Food Department 01912 891934 4 Md. Abdul Karim Electrical Foreman/ Food Department 01744 832123 5 Md. Rais Uddin Mechenical Foreman/ Food Department 01191147382 6 Md. Bachhu Miah Agriculture 7 Md. Zakir Hossain Agriculture 8 Md. Abul Kashem Agriculture 9 Md. Babul Miah Trader 10 Md. Shadat Hossain Trader 11 Md. Zakir Labouer 12 Md. Rouf Unemployed 13 Md. Alluddin Sarder Unemployed 14 Md. Kajul Miah Unemployed 15 Md. Zakir Unemployed 16 Md. Faruk Unemployed 17 Md. Firuz Miah Unemployed 18 Md. Abu Kalam Unemployed 19 Md. Javed Unemployed 20 Md. Badul Unemployed 21 Md. Ainul Unemployed 22 Md. Alam Agriculture 23 Md. Mazu Miah Unemployed 24 Md. Habib Unemployed 25 Md. Swapan Unemployed 26 Md. Murshid Unemployed 27 Md. Abul khayer Unemployed 28 Md. Dulal Unemployed 29 Md. Ripon Unemployed 30 Md. Liton Unemployed 31 Md. Shawkat Unemployed 32 Md. Almus Unemployed A-90 33 Md. Jalal Unemployed 34 Md. Dulal Unemployed 35 Md. Harish Unemployed 36 Md. Asad Agriculture 37 Md. Sohel Miah Unemployed 38 Md. Lalu Unemployed 39 Md. Aunish Unemployed 40 Md. Nur Islam Unemployed 41 Md. Muhiddun Unemployed 42 Md. Ramzan Unemployed 43 Md. Sohel Miah Unemployed 44 Md. Mahram Unemployed 45 Md. Zakir Unemployed 46 Md. Hossain Miah Unemployed 47 Md. Shohag Unemployed 48 Mrs. Sufiya Begum Housewife 49 Mrs. Jharna Begum Labouer 50 Mrs. Beauty Akhter Labouer 51 Mrs. Suma Begum Labouer 52 Mrs. Mina Labouer 53 Mrs. Helena Housewife 54 Mrs. Anowera begum Labouer 55 Mrs. Rahima Begum Labouer 56 Mrs. Parvin Akhter Labouer 57 Mrs. Alladi Bewya Housewife 58 Mrs. Runa Begum Housewife 59 Mrs. Komola Begum Labouer 60 Mrs. Sufiya Begum Labouer 61 Mrs. Samina Begum Labouer 62 Mrs. Chunni Bewa Housewife 63 Mrs. Rokeya Housewife 64 Mrs. Hazera Begum Labouer 65 Mrs. Shirin Begum Labouer 66 Mrs. Majeda Begum Labouer 67 Mrs. Rehana Akhter Labouer 68 Mrs. Farida Begum Labouer 69 Mrs. Majeda Begum Labouer 70 Mrs. Nazma Bewya Housewife 71 Mrs. Gokla Begum Housewife 72 Mrs. Zamila khatun Labouer 73 Mrs. Gul Bahar Labouer A-91 74 Mrs. Hanufa Begum Labouer 75 Mrs. Shara Begum Housewife 76 Mrs. Asiya Begum Housewife 77 Mrs. Halima khatun Housewife 78 Mrs. Rubina Begum Labouer 79 Mrs. Shiuli Begum Labouer 80 mrs. Jarina Begum Labouer 81 Mrs. Rina Akhter Labouer 82 Mrs. Rahima Begum Housewife 83 Mrs. Mahmuda Begum Housewife 84 Mrs. Anowra Begum Housewife 85 Mrs. Farida Begum Housewife 86 Mrs. Rowshanara Begum Housewife 87 Mr. Dulal Unemployed 88 Mr. Hasan Unemployed 89 Md. Zakir Hossain Unemployed 90 Md. Latif Miah Unemployed 91 Md. Mohorrom Ali Unemployed 92 Md. shohag Unemployed 93 Md. Bu Dhai Khan Unemployed 94 Md. Zahangir Alam Unemployed 95 Md. Jamal Hosan Unemployed 96 Md. Mashid Unemployed 97 Md. Fazlul haque Unemployed 98 Md. Juru Miahh Unemployed 99 Md. Tarikul Unemployed 100 Md. Bacchu Miah Unemployed 101 Md. Anowar Miah Unemployed 102 Md. Ismail Unemployed 103 Md. Ramzan Unemployed 104 Md. Mozibur Rahaman Unemployed 105 Md. Khokon Unemployed 106 Md. Dulal Unemployed LIST OF PARTICIPANTS OF THE MEETING ON 02 JAN 2013 BARISHAL CSD SITE SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Md. Shohidullah Ward Councillor/Ward-12 01711 709606 2 Mrs. Ayesha Touhid (Luna) Female ward Councillor/Ward-10,11 & 12 01711 030901 A-92 3 Mrs. Kanan Rani 4 Mrs. Happy 5 Mrs. Selina Begum 6 Mrs. Rokeya 7 Mrs. Shaniur 8 Mrs. Afroza Begum 9 Mrs. Farida Begum 10 Mrs. Rozina Begum 11 Mrs. Kajul Begum 12 Md. Nizam 13 Md. Selim Haque 14 Md. Sohel 15 Md. Joynal 16 Md. Abu Bokor 17 Mr. Nilhil 18 Mr. Shubash Chandra 19 Mr. Sunil 20 Md. Yunus District Controller of Food, Barishal 01718 434172 21 Md. Abdul Mannan R.M.O Dc Food office, Barishal 22 Md. Jashim Uddin ASI Food, Barishal CSD 23 Md. Usif Ali Khan Suf-insfector of Food 24 Md. Abdul Latif Khan ASI Food 25 Md. Abdul Wahab Khan Asst. Operator 26 Mrs. Rubina Parvin Insfector of Food 27 Mrs. Feroza begum 28 Mrs. Ayesha Khatun Insfector of Food 29 Md. Sohrab 30 Md. Syed Mojibur Rahaman 31 Md. Lalon Fakir 32 Md. Minto 33 Md. Siddik 34 Md. Jalal 35 Md. Samsu 36 Md. Babul Monshi 37 Md. Abul 38 Md. Salam 39 Md. Kalam 40 Md. Titu 41 Md. Jahangir 42 Md. Sattar 43 Md. Chan Miah A-93 44 Md. Mostofa 45 Md. Jakir 46 Md. Alamgir 47 Md. Habib Sikder 48 Md. Soyed Ali 49 Md. Anyet 50 Md. Muzibur 51 Md. Keramot 52 Md. Nizam Howlader 53 Md. Jalil 54 Md. Uttam Babu 55 Mrs. Selina Begum 56 Mrs. Happy 57 Mrs. Kajal 58 Mrs. Selina Akhter 59 Mrs. Afroza Begum 60 Mrs. Rokeya 61 Mrs. Kakon Rani 62 Mrs. Rozina Begum 63 Mrs. Beuti 64 Mrs. Piyara Begum 65 Mrs. Shahinur 66 Mrs. Farida Begum 67 Mrs. Koli 68 Mrs. Shova Rani 69 Mrs. Fatema 70 Mrs. Farida Begum 71 Mrs. Nilufa 72 Mrs. Kabita Rani 73 Mrs. Tulshi Rani 74 Mrs. Sabina 75 Mrs. Tamanna 76 Mrs. Lakkhi 77 Mrs. Begum 78 Mrs. Banu LIST OF PARTICIPANTS OF THE MEETING ON 02 JAN 2013 CHITTAGONG SILO SITE SL NAME TELEPHONE DESIGNATION/PROFESSION A-94 1 Mrs. Parvin, Hadi Para Housewife 2 Mrs. Golseher, Hadi Para Housewife 3 Mrs. Nirmala, Free Boat Housewife 4 Mrs. Sweety, Mohazon Ghat, Housewife Chittagong 5 Mrs. Aklima Akter Akhi, Steel Mills, Housewife Bazar. 6 Mrs. Ayesha Siddeka, Khal Para, Service Holder Moon Bakarir Goli. 7 Mrs. Nazma Akter Munni, Steel Mills, Service Holder Bazar. 8 Mrs. Moni akhter, Owyles Coloni Service Holder 9 Mrs, anjuman Ara, Steel Mill Silo gate Student 10 Mrs. Ferdoushi Aman, Steel Mill Bazar Housewife 11 Mrs. Asma Akhter, Hadi Para Housewife 12 Md. Ripon Mondol, CEPZ, Chittagong Service Holder 13 Mrs. Choyonika Ray, CEPZ, Chittagong Housewife 14 Md. Khorshed Alam, Hadi Para, Traders North Potenga, Chittagong. 15 Md. Akber Ali, Hadi Para, North potenga, Traders TSP Bank Gate, Ctg. 16 Md. Omer Faruk,Hadi Para, Contractor North Potenga, Chittagong. 17 Md. Imran Hossain, C/o: Arif Ali, S.Bari, Traders North Patenga. 18 Md. Hashem , Babu Hosen Ahar para, Traders North Chittagong 19 Md. Syed Alam, Hosen Ahar para, Traders North Chittagong 20 Md. Abdul Mottalib, Khal par North, potenga. Traders 21 Md. Abul Barat Sumon, Dail Para, South Traders Patenga. 22 Md. Abdullah Al Saleh Zahur, Gafur manshon, /a Love Lane, Chittagong 23 Md. Nazim , 139 Agrabad, Chittagong Traders 24 Md. Nazimuddin, West Bakuliya, Chittagong Driver 25 Md. Nasir, East Hossen Hossen para, Chittagong A-95 26 Md. Yusuf Miah, Hazi Para, Patenga Rickshaw Puller chittagong 27 Mrs. Parvin Akhter, Hossen para, Traders Chittagong 28 Md. Saiful Islam, Hazi Para, Patenga CNG Driver chittagong LIST OF PARTICIPANTS OF THE MEETING ON 01 JAN 2013 DHAKA CSD SITE SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Md. Mizan, Local People Father's Name: Abdul Roshid Howlader 2 Md. Chunnu Local People Father's Name: Md. Yunus 3 Md. Mubarak Site Labourer Father's name: Samsuddin 4 Md. Siraz Site Labourer Father's Name: Late Owaz Uddin 5 Md. Shahajahan, Neighbour 6 Md. Abdur Rob Site Labourer 7 Md. Abdul Barek Local People 8 Md. Boshu Miah Site Lobourer 9 Md. Tota Site Labourer 10 Md. Mali Site Labourer 11 Md. Alamgir Small Traders 12 Md. Yunus Site Labourer 13 Md. Alim Miah Local People 14 Md. Mosharaf Molla Small Traders 15 Md. Delowar Neighbour 16 Md. Rahaman Site Labourer 17 Md. Borhan Site Labourer 18 Md. Shahjahan Site Labourer 19 Md. Hashem Sarder Neighbour 20 Md. Jakir Neighbour 21 Md. Monu Site Labourer 22 Md. Abul kalam Transport Traders 23 Md. Abdul malek Transport Traders 24 Md. Jalil Small Traders 25 Md. Jalal Neighbour A-96 26 Md. Malek Local People 27 Md. Nurul Hoque Local People 28 Md. Nesar Ali Site Labourer 29 Md. Sattar Transport worker 30 Md. Adam Ali Transport worker 31 Md. Delowar Small Traders 32 Md. Amir Local People 33 Md. Mofiz Transport worker 34 Mr. Dewan Ali Ahmed Manager, Dhaka CSD 35 Mr. Mahafulul Alam Food inspector, Dhaka CSD 36 Mr. sultan Ahmed Accountant Cum Head Assistant. 37 Mr. Mozammel Hossain Technical Inspector, Dhaka CSD 38 Mr. SK. Md. Musa Food inspector, Dhaka CSD LIST OF PARTICIPANTS OF THE MEETING ON 02 JAN 2013 MADHUPUR PROPOSED SILO SITE SL NAME TELEPHONE DESIGNATION/PROFESSION 1 Rovindro Chandro Devnath Upazilla Food Controller 01715085087 2 Md. Mostafizur Rahman OCL SD 01712061973 3 Md. Abdul Khalak ASI 01719089933 4 Md. Obidur Rahman Security Guard 01725446475 5 Md. Milton Security Guard 01714789123 6 Md. Habibur Rahman Security Guard 01917327013 7 Md. Rohul Amin (Manik) Dealer Transport Owner 01728174639 8 Md. Harun or Rashid Lobourer 01725156575 9 Md. Habibur Rahman Cultivator 01770389179 10 Khandokar Shah Mokdul Hassan Miller 01710763213 11 Md. Aminul Islam Teacher - 12 Mrs. Howa Khatun Lobourer 13 Mrs. Minara Lobourer 14 Mrs. Joymon Lobourer 15 Mrs. Jarina Lobourer 16 Mrs. Momota Lobourer 01963865900 17 Mrs. Rehana Local People 18 Mrs. Shomi Begum Local People 19 Mrs. Bilkis Begum Local People 20 Mrs. Safiya Local People 21 Mrs. Nimu Local People 22 Mrs. Salina Local People A-97 23 Mrs. Hazera Begum Local People 24 Mrs. Romesha Local People 25 Mrs. Samida Local People 26 Mrs. Noyaj Ali Khan Imam 01811787654 27 Md. Ainal Haque Elected Member 01711517954 28 Md. Minhazul Rahman Local People 01922945064 29 Md. Hassan Imam Treader 01712727111 30 Md. Saker Ahmed Local People 01717173919 31 Md. Antaz Ali Local People 32 Md. Rafiqul Islam Local People 01712350737 33 Md. Abdur Rahim Local People 01712350738 34 Md. Rubel Local People 35 Md. Abul Hossain Diploma Engineer 01725708801 36 Md. Abdul Malek Local People (Diploma Engr.) 01716018136 37 Md. Lal Miah Local People 38 Md. Raju Ahmed Local People (Diploma Engr.) 01721522331 39 Md. Anser Ali Driver 01724372756 40 Md. Shahidul Islam Pharmacist 01740903453 41 Md. Mojibor Rahman Driver 42 Md. Kabir Hossain Student 43 Md. Alhaz Miah Driver 01729854357 44 Md. Rubel Khan Student 01929844150 45 Md. Abdul Barek Ex- Member 01744414816 46 Khan Mohammad Najmul Shoheb A C Land Madhupur 01712784423 47 Md. Habib Ullah UNO Madhupur LIST OF PARTICIPANTS OF THE MEETING ON 02 JAN 2013 MAHESHWAR PASHA PROPOSED SILO SITE SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Md. Shek Yunus Ali Ward Councellor, KCC Ward-3 2 Md. Arif Hossain President Labour Union 3 Md. Amir Secretary 4 Md. Rafiq Asstt. Secretary Labour Union 5 Md. Habib Asstt. Secretary Labour Union 6 Md. Shahadat Miah Lobourer 01712190220 7 Md. Alauddin Labour Leader 01760368858 8 Md. Harun Lobourer 01735037034 9 Md. Sagor Hossain Petty Traders 01915900536 A-98 10 Md. Milton Hossain Local People 01725040383 11 Md. Kamal Hassain Local People 12 Md. Jaherul Local People 01719028779 13 Md. Abul Local People 01925196383 14 Md. Feroz Local People 01963690617 15 Md. Fajel Rahman Labour Leader 01915313917 16 Md. Rubel Sheali Local People 01929088144 17 Mrs. Salena Lobourer 18 Mrs. Shahida Lobourer 19 Mrs. Bokul Lobourer 20 Mrs. Anowara Lobourer 01917281761 21 Mrs. Hasina Lobourer 22 Md. Mainul Local People 01925543937 23 Md. Shahin Secretary of Transport Labour Union 01712656480 24 Md. Azizur Rahman Imam 01913046975 25 Mrs. Satara Begum Local Labour Leader 01966258476 26 Mrs. Sokhina Begum Local Labour Leader 27 Mrs. Nashu Local People 28 Md. Lal Miah Asstt. General Secretary Truck Labour Union 29 Mrs. Tania Khatun Women Leader 01917675292 30 Md. Zahangir Alam Local People LIST OF PARTICIPANTS OF THE MEETING ON 01 JAN 2013 MYMENSINGH CSD SITE SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Md. Abul Bashar Chowdhury Manager CSD 01712147186 2 Md. Lutfor Rahman I.F CSD 01711101378 3 Md. Bozlur Rashid SI CSD 01716000122 4 Md. Ismail Hossain SI CSD 01727535297 5 Md. Oyahedul Alam SI CSD 01710108421 6 Md. Abdul Halim ASI CSD 01736919755 7 Md. Tayez Uddin ASI CSD 01737619711 8 Miss. Halima Khatun ASI CSD 01716507391 9 Md. Tara Miah Labour Leader 01739854457 10 Md. Jamal Miah Lobourer 01671050506 11 Md. Sultan Miah Farmer 0193406091 12 Md. Habibur Rahman Lobourer 01835979687 13 Md. Molasur Rahman Elected Commissionar A-99 14 Md. Abdul Hakim Elected Commissionar 01732252785 15 Md. Imam Ali Local People 16 Md. Faruk Miah Lobourer 17 Md. Babul Miah Lobourer 01723477152 18 Md. Liton Miah Farmer 01948296396 19 Md. Yakub Ali Farmer 20 Mrs. Kajuli Begum Lobourer 01946880482 21 Md. Fajlul Haque (Talu) Dealer 01712544873 22 Md. Abdul Hai (Sekendar) Rice Miller 01711367307 23 Md. Dulal Uddin Lobourer 01749606533 24 Mrs. Kajuli Begum Lobourer 25 Mrs. Nazma Begum Member 01717785371 26 Mrs. Aklima Begum Lobourer 27 Md. Alauddin Petty Trader 28 Mrs. Nazma Akhter House Wife 29 Mrs. Aklima Begum House Wife 30 Mrs. Aysa Khatun Lobourer 31 Mrs. Shirin Begum Lobourer 32 Mr. Rajes Chandra Das Dealer 33 Md. Rasel Miah Cultivator 34 Md. Abdul Karim Cultivator 35 Md. Naim Uddin Imam 36 Mr. Sanjid Das Sweeper 37 Md. Abdul Barek Miah CSD Darwan 38 Md. A. Hakim Neighbour & Respected Person 39 Mr. Siraj Miah Farmer/ Millar LIST OF PARTICIPANTS OF THE MEETING ON 02 JAN 2013 NARAYANGANJ CSD SL NAME DESIGNATION/PROFESSION TELEPHONE 1 Mr. Tahmidul Haque Manager Nanaryangonj CSD 01711889656 2 Md. Montajir Mamun Food Inspector N. gonj CSD 01839486607 3 Mr. Arif Mohammad Food Inspector N. gonj CSD 01912238809 4 Mr. Asadus Zamam Food Inspector N. gonj CSD 5 Mr. Abi Abdulah Sub-Inspector N. gonj CSd 01934355624 6 Md. Rafiqul Islam ASI N. gonj CSD 01818290972 7 Md. Gias Uddin SI N. gonj CSD 01716809735 8 Md. Delowar Hossain 01683483930 9 Md. Saidul Islam 01756310462 A-100 10 Md. Jakir Hossian 01965600198 11 Md. Abdur Rahman UCF Bandar N. gonj 01919442620 12 Mr. Saifuddin Ahmed Dulal Councillor, Ward-23, N.C.C 01919711234 13 Mr. Nabi awal Dewan Local Contractor, N.C.C 14 Md. Ketab Ali Representative, Local CSD 15 Md. Jashimuddin Prodan Ist Class Contractor 16 Md. Sarif hasan Cisty Local Reapestable Man. 17 Md. Jashim uddin Local Business Man 18 Md. Abdul Khaled Dhaly Local People 19 Md. Atiqur Rahaman Local Business Man 20 Md. Jakir Hossian Local Business Man 21 Md. Nurul Local Business Man 22 Junaba Israt Jahan Howlader Ward Councillor, 22,23,24, NCC 01913381498 23 Mir Ahmed Shamim Contractor, NCC 24 Sujan prodhan NCC & Food/ Contractor 25 Md. Samsul Hasan Prosh Architect Engr. 26 Md. Sumon Rodhu Local Business Man 27 Md. Rana Prodhan Local Business Man 28 Md. Sohel Khan Local Business Man 29 Md. Kamrul Hasan Hardware Engineer 30 Md. Atiqur Rahaman Somal School Teacher 31 Md. Emran Dewan Local Business Man 32 Md. Nazmul Ahsan Minto Local Business Man 33 Md. Khan masud Local Business Man 34 Md. Billal Labourer Leader 35 Md. Allauddin Labourer Leader 36 Md. Bahadur Labourer Leader 37 Md. Amir Ali Labourer 38 Md. Khalil Lobourer 39 Md. Mostofa Lobourer 40 Md. Awolad Lobourer 41 Md. Illias Lobourer 42 Md. Sumon Rodhu Lobourer LIST OF PARTICIPANTS OF THE MEETING ON 03 JAN 2013 VILLAGE: TINGHORIA, AMKORA, PATUAKHALI SL NAME DESIGNATION/PROFESSION TELEPHONE DG FOOD 1 Md. Mahabubar Rahaman Sikdar, DC Food A-101 2 Md. Mojibur Rahaman UCF, Golachipa 3 Md. Mezbah Uddin Khan Food Inspector, Patuyakhali Sadar COMMUNITY 4 Md. Anowar Hossain Union Council chairman. 5 Md. Abul kalam Azad 6 Md. Hanif Gazi Member UP 7 Md. Siddikur Rahaman Local people 8 Md. Panu Midha Local people 9 Md. Idrish Maghi Local people 10 Md. Tofazzal Local people 11 Md. Humayan Gazi Local people 12 Md. Lal Miah Molla Local people 13 Md. A. Mannan Sorkar Local people 14 Md. Azad Local people 15 Md. Fazlu Local people 16 Md. Rezaul Karim Labourer 17 Md. Anowar Hossain Labourer 18 Md. Abu Jafor Labourer 19 Md. Mosharof Labourer 20 Md. Mostofa Labourer 21 Md. Arman Labourer 22 Md. Abul Mridha Labourer 23 Md. Shah Alom Mollah Local people 24 Md. Kashem Local people 25 Md. Jafor Gazi Local people 26 Mrs. Maleka Local people 27 Mrs. Roshida Local people 28 Mrs. Shanior Local people 29 Md. Sekal Fisherman 30 Md. Shorow Fisherman 31 Md. Golam Fisherman 32 Mrs. Ambiya Fisherman 33 Mrs. Kohinur Fisherman 34 mrs. Moriyam Fisherman 35 Mrs. Champa Fisherman 36 mrs. Aleya Fisherman 37 Mrs. Hareza Fisherman 38 Mrs. Monira Local people 39 Mrs. Honofa Local people 40 Mrs. Khadiza Local people 41 Md. Polash Lobourer A-102 42 Mrs. Shilpi Lobourer 43 Mrs. Peyara Lobourer 44 Mrs. Halima Lobourer 45 Mrs. Shefali Lobourer 46 Mrs. Chokina Lobourer 47 Mrs. Aleya Lobourer 48 Mrs. Johora Lobourer 49 Mrs. Hafiza Lobourer 50 Mrs. Rehana Lobourer 51 Mrs. Komola Lobourer 52 Mrs. Atahara Lobourer 53 Md. Kamal Lobourer 54 Md. Ismail Lobourer 55 Md. Jamal Lobourer 56 Mrs. Hanoifa Housewife 57 Mrs. Rahima Housewife 58 Mrs. Horepa Housewife 59 Md. Ab. Roshid Lobourer 60 Mrs. Piyara. Housewife 61 Md. Monir Lobourer LIST OF PARTICIPANTS OF THE MEETING ON 03 JAN 2013 VILLAGE: BALAIKATHI, AWLIAPUR, PATUAKHALI SL NAME DESIGNATION/PROFESSION TELEPHONE DG FOOD 1 Md. Mahabubar Rahaman Sikdar, DC Food 2 Md. Mojibur Rahaman UCF, Golachipa 3 Md. Mezbah Uddin Khan Food Inspector, Patuyakhali Sadar COMMUNITY 4 Md. Altaf Hossain Union Council Chairman, Awaliyapur. 5 Md. Siddikur Rahaman Member, Awaliyapur, Union Council 6 Md. Motaleb Villager 7 Md. Kurban miah Villager 8 Md. Siddikh Khan Villager 9 Md. Motahar Ali Villager 10 Md. Abdul Salam Villager 11 Md. Ab. Jafor Villager 12 Md. Fazjul rahaman Villager 13 Md. Abdul Salam Villager A-103 14 Md. Abdul Haque Villager 15 Md. Abdur Rob Bari Villager 16 Md. Badul Haque Villager 17 Md. Jahiudillah Islam Bari Villager 18 Md. Abdul Khalek Villager 19 Md. Nasir Haque Fisherman 20 Md. Ibrahim Ali Fisherman 21 Md. Kashem Fisherman 22 Md. Harun Fisherman 23 Md. Razzak Fisherman 24 Md. Shahazan Fisherman 25 Md. Jashim Fisherman 26 Md. Sultan Fisherman 27 Md. Ashraf Fisherman 28 Md. Jahangir Khan Fisherman 29 Md. Ruhul Amin Fisherman 30 Md. Khokon Fisherman 31 Md. Moklesh Fisherman 32 Md. Dhiren maghi Fisherman 33 Md. Nurummaman Khan Fisherman 34 Md. Babul Haque Fisherman 35 Md. Malek Fisherman 36 Md. Noyan Fisherman 37 Md. Harun Fisherman 38 Md. Nazrul Fisherman 39 Md. Nurul Haque Fisherman 40 Md. Abdul salek Labourer 41 Md. Habibur Labourer 42 Md. Jazlu Labourer 43 Md. Rahman Labourer 44 Md. Kabir Labourer 45 Md. Fazle Jazikir Labourer 46 Md. Latihar Labourer 47 Md. Rahaman Labourer 48 Md. Mamun Labourer 49 Md. Jahangir Khan Labourer 50 Md. Boshir Labourer 51 Md. Khalilur Rahaman Labourer 52 Mrs. Khadiza Housewife 53 Mrs. Rekha Housewife 54 Mrs. Aletya Housewife A-104 55 Mrs. Sehenesa Housewife 56 Mrs. Nasima Housewife 57 Mrs. Shirin Housewife 58 Mrs. Fatema Housewife 59 Mrs. Hanufa Housewife 60 Mrs. Lutfa Housewife 61 Mrs. Saleya Housewife 62 Mrs. Rokeya Housewife 63 Mrs. Golenur Housewife 64 Mrs. Taslima Housewife 65 Mrs. Nilufa Housewife 66 Mrs. Howya Bibi Housewife 67 Mrs. Taslima Housewife 68 Mrs. Lutfa Housewife 69 Mrs. Mageda Housewife 70 Mrs. Minora Housewife 71 Mrs. Korfola Housewife 72 Mrs. Laili Housewife 73 Mrs. Kulsum Housewife 74 Mrs. Hanufa Housewife 75 Mrs. Begum Housewife 76 Mrs. Surjunu Housewife 77 Mrs. Taslima Housewife 78 Mrs. Latiful Housewife 79 Mrs. Riziya Housewife 80 Mrs. Begum Nesa Housewife 81 Mrs. Jibon Nesa Housewife 82 Mrs. Begum Nesa Housewife A-105