SUMMARY ENVIRONMENTAL IMPACT ASSESSMENT

JAMUNA-MEGHNA RIVER EROSION MITIGATION PROJECT

IN THE
PEOPLE’S REPUBLIC OF BANGLADESH

July 2002
 CURRENCY EQUIVALENTS
(As of 30 June 2002)
Currency Unit – Taka (Tk)
Tk1.00 – $0.0175
$1.00 – Tk57.2
The exchange rate of the taka is determined by the Bank of the People’s Republic of
Bangladesh. In this report, the rate of $1.00 = Tk57.5 was used. This was the rate prevailing
during the preparation of the draft paper.
ABBREVIATION
ADB Asian Development Bank
BIWTA Bangladesh Inland Water Transport Authority
BWDB Bangladesh Water Development Board
CADP Command Area Development Project
DOE Department of Environment
EIA environmental impact assessment
EMP environmental management plan
FCD&I flood control, drainage and irrigation
FGD focus group discussion
GRC grievance redress committee
HYV high-yielding variety
JMC joint management committee
JMREMP Jamuna-Meghna River Erosion Mitigation Project
M&E monitoring and evaluation
MDIP Meghna-Dhonagoda Irrigation Project
NGO nongovernment organization
PIRDP Pabna Irrigation and Rural Development Project
PMO project management office
RF resettlement framework
RP resettlement plan
RPG Resettlement Procedural Guidelines
SDL secondary defense line
SEIA summary environmental impact assessment
SMO subproject management office
WMA water management association

Weights, Measures and Currency

ha – hectare mm – millimeter
km – kilometer mt – metric ton
L – liter µg – micro gram
m3 – cubic meter yr – year
m – meter

NOTES
(1) The fiscal year (FY) of the Government ends on 30 June. FY before a calendar
year denotes the year in which the fiscal year ends, e.g., FY2002 ends on 30
June 2002.
(2) In this report, “$” refers to US dollars.
 CONTENTS

MAP ii

I. INTRODUCTION 1

II. DESCRIPTION OF THE PROJECT 1

III. DESCRIPTION OF THE ENVIRONMENT 2

A. Physical Environment 2
B. Biological Environment 5
C. Human and Economic Development 6

IV. ALTERNATIVES 9

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION 10

MEASURES
A. Physical Environment 10
B. Biological Environment 13
C. Human and Economic Development 14
D. Impact Identification and Assessment Matrix 17

VI. ECONOMIC ASSESSMENT 18

VII. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL 18

MONITORING PROGRAM

VIII. PUBLIC INVOLVEMENT 20

IX. CONCLUSION 22

APPENDIXES

1 Morphological Trends 24

2 Multicriteria Analysis of Options 26

3 Summary of Resettlement Framework and Short Resettlement Plan 27

4 Impact Evaluation Matrix Showing the Project Impact on Important 31

Environmental Components

5 Project Investment in Environmental and Social Measures 32

6 Environmental Management Plan 33

7 Overall Institutional Framework for Implementation of the Project and 36

Environmental Management Plan

8 Environmental Impacts and Mitigation Measures 37

 I. INTRODUCTION

1. The Bangladesh Water Development Board (BWDB) engaged consultants to undertake

an environmental impact assessment (EIA) of the Jamuna-Meghna River Erosion Mitigation
Project (JMREMP). The Project aims to mitigate the impacts of riverbank erosion threatening
certain sections of flood embankments in the Pabna Irrigation and Rural Development Project
(PIRDP) along the Jamuna River and in the Meghna-Dhonagoda Irrigation Project (MDIP) along
the Meghna River through comprehensive and adaptive structural and nonstructural measures.1
This summary of environmental impact assessment (SEIA) of the JMREMP discusses the likely
significant environmental changes as a result of the implementation of river erosion protection
works. If these changes are found negative, mitigating measures that should be taken to lessen
their impact both during construction and afterwards are identified, where possible. The
implementation of these measures is included in an environmental management plan (EMP).

2. The EIA was carried out in accordance with the Asian Development Bank’s (ADB)
Environmental Assessment Requirements of the Asian Development Bank2 and the guidelines
of the Government of Bangladesh, including Guidelines for Environmental Impact Assessment
(EIA),3 the accompanying manual, Environmental Impact Assessment4 and Guidelines for
Environmental Assessment of Flood Control, Drainage and Irrigation Projects.5 It was of special
relevance to assess the important environmental components in a “without Project” situation
and compare this to a “with Project” situation. The comparison determines the negative and
positive impacts of preserving the present benefits of the flood control, drainage and irrigation
(FCDI) facilities provided by the PIRDP and MDIP. The JMREMP is classified as “Category A”
by ADB and as “Category Red” by the Government. Under both classifications, an EIA is
mandatory. A multidisciplinary team of consultants conducted the EIA during the project
preparatory technical assistance from October 2001 to March 2002 with the utilization of a
range of available data including those on flood flows and morphological changes measured
from July to October 2001. This SEIA was prepared by the Government for review by ADB and
other concerned stakeholders. The EIA will be forwarded to the Department of Environment
(DOE) of the Government of Bangladesh for its approval.

II. DESCRIPTION OF THE PROJECT

3. The Project consists of structural and nonstructural measures for protection of the two
vital irrigation subprojects, the PIRDP in Pabna District and the MDIP in Chandpur District,
where riverbank erosion is threatening the embankments. The two schemes provide flood
protection for a total area of 201,400 hectares (ha), within which irrigation command areas of
18,680 ha in PIRDP and 13,360 ha in MDIP were developed to benefit a total population of
about 440,000. Failure of the embankments would have severe social, economic and
environmental impacts on both the subprojects. Thus, there is a rationale to institute both

1
These project areas are covered under the ongoing Loan No.1399-BAN: Command Area Development Project, for
$30 million, approved on 7 November 1995 for the provision of irrigation canals and other support services. ADB
also assisted the construction of flood control and drainage facilities in these two projects through Loans No. 378-
BAN: PIRDP, for $38.0 million, approved on 12 December 1978, No.833-BAN: MDIP, for $24.0 million, approved
on 15 December 1977, and No. 883-BAN: MDIP (Supplementary), for $8.4 million, approved on 4 February 1988.
2
ADB.1998. Environmental Assessment Requirements of the Asian Development Bank. Manila.
3
Flood Plan Coordination Organisation (FPCO). 1992. Guidelines for Environmental Impact Assessment. Dhaka.
4
FPCO. 1995. Environmental Impact Assessment. Dhaka.
5
Water Resources Planning Organization. 2001. Assessment of Flood Control, Drainage and Irrigation. Dhaka.
2

structural and nonstructural measures to offset the severe socioeconomic and environmental
impacts that would visit the two subprojects if erosion were to proceed unabated.

4. The structural river protection works have been designed in accordance with an
“adaptive approach” to stabilize the two rivers along flat, smooth alignments that are natural to
the respective river systems. Under this approach, the Project will protect a total of 7.0
kilometers (km) and 4.4 km reach of riverbank along the existing bank line of the PIRDP and the
MDIP respectively. The protection works will comprise (i) riverbed revetment aprons using sand-
filled graded geo-bags that launch and cover the eroding bank as they develop, (ii) upper bank
line revetment with concrete blocks, and (iii) grass turfing along a strip of the bank at the crest of
the revetment. The placement of protection works will follow a gradual, phased, and process-
type approach, with the initial 2 years of works undertaken as pilot-cum-implementation phase
to reconfirm the design criteria and implementation approach. This will provide structures based
on the prevailing morphological conditions and opportunities for reducing the cost. The Project
will be implemented over a 6-year period.6 Further to the above protection works, the
Government will construct 1.2 km of secondary defense line of embankment in the PIRDP,
which will be placed behind the critical reach of the embankments and will protect the project
area from inundation in the event of possible breach of the existing embankments.

5. In addition to the structural measures, the Project will further encompass the following
nonstructural measures: (i) riverbank erosion information management including monitoring,
forecasting, and warning through procurement and analysis of satellite imaginary and
mathematical modeling; (ii) disaster preparedness and management support; (iii) social
development support to the vulnerable settlers on and around the embankments displaced by
ongoing river erosion; and (iv) capacity development of institutions related to the Project.

6. During implementation of the Project, land will be required for structural work. A
resettlement plan (RP) is included in the Project following ADB’s involuntary resettlement and
other safeguard policies. The main principles are to (i) minimize negative impacts as much as
possible; (ii) carry out resettlement and social development activities to improve or at least
restore the preproject standards of living of the affected persons; (iii) fully inform and closely
consult the affected people on compensation policy, options, and social development/poverty
reduction designs; (iv) provide compensation for acquired assets at replacement rates; and (v)
pay compensation for acquired lands, structures/immovable properties, and other eligible
benefits prior to ground leveling and demolition of structures.

III. DESCRIPTION OF THE ENVIRONMENT

A. Physical Environment

1. Climate, Hydrometeorology, and Air

7. The monsoon climate that affects the project areas is part of a system that affects the
whole of the Indian subcontinent. There are four more or less distinct seasons. The monsoon
and the dry season are the main seasons, separated by transition seasons. The southwest

6
From the perspective of a project life of 30 years, additional structural measures were assessed for the medium- to
long-term future as stage II and stage III. The necessity to implement these stages will depend on the
morphological development acting to safeguard the structures implemented under stage I. Stages II and III are
included in the environmental assessment, especially in relation to morphological impacts, and incorporated in the
economic analysis, although they are not considered for implementation under the current Project.
 3

monsoon lasts approximately from June to September, and produces the main rainy season.
More than 90% of the annual rainfall (average 1,700 millimeters per year [mm/yr] in the PIRDP
and 2,100 mm/yr in the MDIP) occurs during this period, when both temperature and relative
humidity are high. In an average year the potential evapotranspiration exceeds rainfall between
the months of October and April. Rainfall in the early and late monsoon periods is highly
variable, however, and irrigation water requirements vary year by year. Basically there is a
requirement for irrigation between the months of November and April, even under average
rainfall conditions. No measurements exist of the air quality at the project sites. However, being
in rural areas away from industry and heavy traffic, the general air quality is considered to be
acceptable according to the Government’s ambient air quality standards.

2. Geology and Soils

8. The Bengal Basin is in the northeastern part of the Indian subcontinent, between the
Indian Shield and the Indo-Burman Range, comprising three geotectonic provinces. The PIRDP
and MDIP are situated in the Central Deep Basin. The area is actively subsiding and impacted
by tectonic movements. With the development of the major river system of the Bengal Basin
dominated by the Ganges-Brahmaputra-Meghna rivers, sedimentation and erosion processes of
these rivers now dominate the project areas. In the MDIP the soils have developed from
Meghna alluvial sediments, and in the PIRDP from young alluvial sediments deposited by the
Ganges and Jamuna rivers and their tributaries in the Holocene Age. With proper drainage and
irrigation the soil of the areas is very suitable for agricultural development.

3. Physiography

9. The PIRDP lies within the floodplain of the Padma-Jamuna rivers, and before the
construction of the embankment most of the area was flooded annually. Under the present
conditions the area is generally flood free. However, the drainage system is managed to
maintain water bodies such as beels during the dry season. Under pre-PIRDP conditions, the
Isamoti River used to flow through the area. At present the Isamoti River is closed and forms an
irrigation and drainage channel. The Hurashagar River flows through the northern part and the
Jamuna River through the eastern side of the PIRDP area. Both these rivers are causing
erosion of flood protection structures. However, it is the erosion by the Jamuna River that has
taken a serious turn in recent years.

10. The MDIP area is situated in the Meghna River and Meghna floodplain, which was
previously flooded annually. The land of the project impact area within the embankment is
almost flat, with some local depressions and has a general mild slope, mainly from the north to
south. It has also a gentle cross slope in the west direction. In the pre-MDIP period, the Meghna
River and the Dhonagoda River, with their numerous tributaries, used to drain the area.
However, the MDIP flood protection embankment and irrigation and drainage channels have
substantially altered the natural drainage pattern of the area, and very few natural water bodies
remain inside the embankment.

4. River Hydrology and Morphology

11. The Jamuna at the PIRDP has a braided river channel pattern, with the river flowing in
multiple channels that divide around chars and sandbars. The river is highly dynamic, being
characterized by rapid changes in channel locations. Analysis of the right bank positions over
the 27-year period for which satellite images are available, reveals that, except for a single
location, all locations along the right bank have been exposed to erosion a number of times. The
4

channel is characterized by having rapid scour and deposition, and by bed material transport of
more than 150 million metric tons (mt)/yr. The present bank erosion attack at the project site
started in the last half of the 1980s. The average annual erosion rate at the attacked area was
up to 130 meters over 1992-2000.

12. A number of new chars are close to the project site. These chars/sand bars have been
deposited recently, have hardly any vegetation and are uninhabited. After the 2000 flood, the
bank line at the PIRDP was attacked by the flow of three separate channels. Since the 2001
flood, the northern of these channels has become clearly dominant, and the erosion area has
shifted further north. This northern channel is not believed to be stable, considering it is a close
to perpendicular offtake from the main channel. At present the morphological situation at the
PIRDP is very complex and unpredictable, both in the short and long term. In the long term
(decades), the erosion/accretion pattern along the PIRDP is expected to be similar to that
experienced in previous decades and in other locations along the right bank. Based on the
experience from previous bank erosion attacks, such attacks are likely to last for a number of
years and subsequently ease off for a number of years till a new attack takes place. (See
Appendix 1 for recent morphological changes around the PIRDP.)

13. After the confluence of the Jamuna and the Ganges, the Padma River is formed, which
flows in a southeasterly course for approximately 100 km until it reaches the junction with the
Upper Meghna River. At this confluence, near the MDIP, the river makes an abrupt turn to the
south. The Padma River has an anabranched7 channel pattern, with two or more prominent
channels dividing around large vegetated chars. The active channel width varies between 13 km
in wide sections where the river divides around the chars to a minimum of about 4 km in narrow,
single channel reaches. Large sandbars appear during the dry season. The bed material
transported is estimated at approximately 200 million tons/yr. Whereas the sediment-laden
Padma flow stays along the right bank, away from the MDIP, it pushes the flow of the Upper
Meghna with its low sediment content, against the right bank at the MDIP. In the early 1970s,
the Padma joined the Meghna as a single channel, and the MDIP was situated along the bank
of the Upper Meghna. In the late 1970s, the Padma developed two channels at the confluence,
which have remained since then. The two channels vary in strength in a cyclic manner, with the
two channels being intermittently dominant. The erosion attack at the MDIP is closely related to
the strength of the north Padma channel. If the north Padma channel flow reduces, the erosion
pressure at the MDIP will be reduced. The balance between the north and the south Padma
channels is governed by strong controls, including major developments in the Padma far
upstream; erosion deposition of very large sediment volumes; and finally, but not least, the
strong influence of natural hardpoints. In other words, the processes controlling the balance
between the north and the south Padma channels are very strong and are not likely to be
affected by any minor interventions in the river system. The morphological conditions at the
MDIP are at least as complex as the conditions at the PIRDP, but very different. (See Appendix
1 for recent morphological changes in the MDIP.)

5. Surface Water Quality

14. Measurements of water quality parameters carried out by the Department of

Environment (DOE) until 1990 and subsequent data show that the oxygen concentrations in the
Meghna and Jamuna are acceptable and will sustain normal aquatic life in the rivers. Due to the
large size of both rivers and the considerable base flow even during the dry season, it is
expected that the oxygen levels are still acceptable. The measurements of coliform bacteria

7
An effluent of a stream that rejoins the main stream, forming an island between the two water sources.
 5

indicate a relatively high impact from human and animal excreta. This would primarily be from
the discharge of untreated sewage and fecal matter from livestock. Based on available
measurements, no problems are identified with respect to the nutrient levels in the Meghna and
Jamuna rivers. Given the size and baseflow of the rivers during the dry season, the situation is
not expected to have changed drastically.

6. Groundwater

15. The groundwater resources of the PIRDP area are reasonably plentiful. There is enough
rainfall in the area, and seepage from irrigation canals and rivers adds to the recharge of good
aquifers created by sandy sediments deposited by the Jamuna and the Ganges rivers.
Groundwater is used in the PIRDP area for irrigation and drinking purposes. Toxicity of
groundwater for irrigation has been noted in the area mainly due to the presence of iron, boron,
molybdenum, and bromide. Arsenic contamination in shallow aquifers has contaminated about
17% of the wells of Pabna District by more than 50 micrograms per liter (µg/L), and about 6% of
the wells show arsenic contamination at more than 200 µg/L.

16. The groundwater resources potential is not uniformly distributed in the MDIP area.
Recharge of groundwater is not considered to be a major problem for a large part of the project
area, as there is sufficient rainfall and the area is inundated for a considerable part of the year.
However, aquifer characteristics and water quality are a major constraint of groundwater
development. It has been found that deeper aquifers contain fresh water and shallow aquifers
above are brackish or saline. The occurrence of fresh water beneath the saline water aquifers
means that the groundwater-based irrigation may not be sustainable in the area. Arsenic
contamination of groundwater is another major constraint for the use of groundwater use in the
MDIP area; 90% of the tubewells in the district are contaminated by more than 50 µg/L arsenic,
and 80% of the wells contain more than 200 µg/L arsenic.

B. Biological Environment

1. Aquatic Ecosystem

17. The PIRDP area within the floodplain of the Padma and Jamuna rivers is a freshwater-
dominated environment inhabited by freshwater plant and animal species. Agricultural and
water resources development has already altered the biological environment of the area. Most
of the former low-lying floodplain wetland areas and beels have been converted into rice fields.
At present there is no wetland in its virgin natural condition within the PIRDP area, and it is
heavily impacted by human activities. The added security provided by the embankment has
encouraged a rapid increase in population and in agricultural activities in the area. These
activities in return have changed the ecology of the area, leaving very little land where the
natural ecosystem could flourish. However, there is some wetland in seminatural condition on
the floodplain of the Hurashagar River and the Jamuna River close to the PIRDP site. A number
of beels remain within the PIRDP area, providing shelter to aquatic species during the dry
season.

18. The Meghna Flood Plain is a dominant freshwater environment inhabited by freshwater
plant and animal species. Before the implementation of the MDIP, the low-lying area with a
saucer- shaped depression used to remain submerged under floodwater for about 9 months in a
year. The project area consisting of the Meghna and Dhonagoda rivers, and their floodplain
once formed a special freshwater ecosystem supporting high fish production, and many species
are now endangered. Native waterfowl and migratory birds depended on this system, and the
6

area was rich in biodiversity. The construction of embankments entirely changed the ecosystem.
The free migration patterns of fish from the floodplain to the Meghna River and vice versa was
disrupted, and fish production in the MDIP area fell after the implementation of the project.
Intensive agriculture and reduction in wetland areas have affected the habitat of migratory birds.
The pressure from the increasing human population on the natural resources has affected the
ecosystem. Very few areas are left, and only outside the embankments, where the natural
ecosystem remains. At present there is no natural wetland remaining within the MDIP area.

2. Terrestrial Ecosystem

19. The area covered by natural vegetation in the project areas is marginal and consists only
of some small patches covered by mostly grass and bushes. The major terrestrial vegetation of
the area includes human-influenced vegetation that grows in homestead gardens, orchards,
plantations, cropland, at roadsides, and on other cultivated land. In fact, homestead vegetation
is the most important group of vegetation present in the project areas. Selected species of
homestead vegetation are also planted on the roadside and grown in very small orchards.
Homestead vegetation includes two types of plants; those cultivated for economic value and
those that are self-propagating.

20. Wild mammals are relatively scarce in the project area; all bigger wild mammals have
disappeared. Small mammals such as Bengal fox, common mongoose, and fishing cat remain
along with smaller animals like lizards, mice, rats and bats. In addition, a number of terrestrial
birds and waterfowl are found.

3. Endangered Species

21. Several species attributable to the project area appear on the World Conservation
Union’s (IUCN) Red List of Threatened Animals,8 including the Ganges river dolphin, Bengal
fox, fishing cat, jungle cat, Bengal monitor, ring lizard, Pallas's fish eagles, brown fish owl, and
Asian fairy bluebird.

C. Human and Economic Development

1. Land Use and Settlement

22. The estimated population of the PIRDP irrigation command area is about 233,000, with
approximately 50,000 households. About 2,500 households are located between the present
embankment and the river and are directly exposed to flooding and erosion. The total land area
between the embankment and the bank line under erosion is estimated to be 550 ha, of which
about 110 ha is used for settlement, roads, etc. Hundreds of erosion-affected people in recent
years have shifted their households in and around the embankment. An estimated 1,400
squatter families live on the embankment near the erosion-prone area. The estimated
population of the MDIP area is 210,000, who live in about 45,000 households.

2. Water Supply and Sanitation

23. In the PIRDP and the MDIP, 98% and 95% of the people, respectively, depend on tube
wells for drinking water. The remaining population uses river water and ponds. The high content
of arsenic, especially in the MDIP area, constitutes a massive drinking water quality and health

8
IUCN. 1990. Red List of Threatened Animals.
 7

problem. Sanitation facilities in the PIRDP area are poor. About 25% of households have
sanitary latrines, 65% use katcha9 latrines and about 10% use open places. People living in
squatter areas have even more problems with latrine facilities. The sanitation facilities of the
MDIP area are relatively better in the PIRDP area: About 45% households have sanitary
latrines, about 50% use katcha latrines, and about 5% use open places. Sanitation and the
living conditions of people in squatter areas are generally very poor.

3. Agricultural Productivity

24. The net cultivatable area of the PIRDP is 21,850 ha. Prior to the PIRDP/Command Area
Development Project (CADP), most of the land was non-irrigated, and the cropping intensity
was about 128%. At present 13,720 ha land is irrigated and the cropping intensity has reached
177%. Major crops grown are aman, boro and aus rice10; wheat; oilseeds; and pulses. Total rice
production from the PIRDP area in 2001 was 85,295 mt, which includes 39,024 mt of high-
yielding variety (HYV) boro, 6,550 mt of HYV aman, 5,965 mt of HYV aus, and 33,756 mt of
other rice. For comparison total rice production in the PIRDP was 47,065 mt in 1996.

25. FCD&I facilities provided by MDIP/CADP helped to increase agricultural production in

the area. There was very little irrigated land during the pre- MDIP period. As of June 2001, there
was about 12,300 ha of irrigated land in the project area. Irrigation water is mainly used to
cultivate boro crops in the dry season. Aman and late aus crops are cultivated using rainwater.
The net cultivatable land of the project area is 14,500 ha, and the cropping intensity is 214%.
Total rice production increased from 83,408 mt in 1996 to 118,060 mt in 2001. Major varities of
rice produced in the area are HYV aman, HYV boro, HYV aus. Other crops include oilseeds,
pulses, wheat, jute, sugarcane, and vegetables.

4. Fish Culture

26. Although there has been a decrease in capture fisheries resources, there has been an
increase in production from fish culture that in both the PIRDP and MDIP areas is estimated to
more or less make up for the loss of capture fisheries at present. The potential for culture fish
production is still not fully developed in both schemes.

5. Navigation

27. Water transport is an important means of travel for the people living in the PIRDP and
MDIP areas. Motorized and manually operated boats carry agricultural goods, including
livestock, to other markets and bring commodities for the local population. There are relatively
important river ports at both project sites. The oil terminal area in the Hurashagar River north of
the PIRDP area is an important ship terminal. The navigability of the river is hampered during
the dry season due to sedimentation at the confluence with the Jamuna and narrowing of the
western main channel in the Jamuna. The Bangladesh Inland Water Transport Authority
(BIWTA) carries out dredging regularly during the dry season to maintain the access to and
navigability of the Hurashagar River. The planned volume of dredging in 2002 is 100,000 cubic
meters.

9
Earthen.
10
Aman, boro, and aus rice means rice grown in the monsoon, dry season, and pre-monsoon seasons respectively.
 8

6. Quality of Life Values

a. Way of Life and Equity

28. The people of the two areas generally live in small towns and villages. In comparison to
the MIDP area, the PIRDP area is less densely populated. However, the area threatened by
river erosion at PIRDP is more densely populated than that of MIDP. People of the project area
are mostly engaged in agriculture, fishing, and weaving. Some of them are also engaged in
trading and transportation. Some are involved in both agriculture and fishing, the latter
especially during the monsoon. Some of the farmers have also fishponds. Cattle ranching is
fairly common among the people living in villages. Especially the PIRDP area is famous for its
milk and milk products. Members of households often work and live in the major cities, or
overseas, supporting their families, especially in the MDIP area.

b. Income and Poverty

29. People in both project sites are generally poor, and large populations live below the
poverty line. According to the World Health Organization/United Nations International Children’s
Fund standard for Bangladesh, the absolute poor (below the poverty line) are defined as those
who cannot afford an intake of 2,122 calories per day, and the hardcore poor are those who
cannot afford a daily intake of 1,805 calories. The most hardcore poor are found in the areas
outside the embankment and affected by river erosion at both project sites, as shown in Table 1.

Table 1: Income and Poverty Status

Item Annual Income Population below Hardcore Poor
Poverty Line
PRIDP MDIP PIRDP MDIP PIRDP MDIP
Outside Embankment Tk 44,200 Tk 43,600 67.0% 53.0% 46.7% 40.0%
Inside Embankment Tk 70,500 Tk 55,600 45.0% 43.3% 28.3% 28.3%
Outside Project Area Tk 55,800 Tk 55,100 57.0% 45.8% 34.5% 33.2%
MDIP = Meghna-Dhonagoda Irrigation Project, PIRDP = Pabna Irrigation and Rural Development Project.

c. Health and Education

30. In the PIRDP and MDIP areas, waterborne diseases are relatively common. However,
the situation has improved compared with the period before the provision of the FCD&I facilities,
when diarrhea was widespread, especially during the flood season. Another health factor is the
increasing number of people affected by arsenic. In addition, malaria is fairly common in both
areas. Health care facilities are slightly better in the MDIP area than in the PIRDP area. In both
areas thana (upazila) health complexes provide basic health care facilities. Family planning and
immunization programs are also carried out through these health complexes. For the PIRDP
area, the overall literacy rate is about 52%, and for the MDIP area about 50%.

d. Cultural and Heritage Sites

31. There are no archaeological sites of national interest in the project areas. The
mosques, temples, and bazars of historical interest are situated far from the Project sites and
are not likely to be affected by project activities.
 9

IV. ALTERNATIVES

32. The River Erosion Prevention and Morphology Study (REPMS),11 prepared in November
2000, comprised a prefeasibility study for several bank protection and mitigation measures.
Under the current study, a further options assessment was undertaken. Conventional structures
such as revetments with deep setting level with hard and/or interconnected materials and high
spurs were found to be far more expensive than other options and had low economic return and
high maintenance costs. While low permeable spurs were identified as a potential alternative,
the piling alone would cost three times more than the low solid spurs and was consequently
dropped. The following options were taken forward for the feasibility study:

(i) without project,

(ii) embankment retirement,

(iii) riverbank protection by revetment, and

(iv) riverbank protection by low solid spurs

33. In the without project scenario, river erosion will continue. The estimated loss of land by
river erosion over the last 10 years is 1,430 ha at PIRDP and 222 ha at MDIP. With the
expected average erosion rate over the next 30 years it is estimated that 3,000 ha will be
eroded at PIRDP and 2,300 ha at MDIP. It is expected that some of the erosion of land at the
project sites will cause sediment deposition and generation of new land elsewhere. However,
the newly accreted land is of low value, and it generally takes up to 20 years before such land
has good productive capacity.

34. Further, in the without project condition, the embankment would be breached to inundate
the project area, creating a considerable impact on the terrestrial and aquatic environment.
Parts of the agricultural land in the PIRDP and MDIP would be flooded annually, causing a
reduction in agricultural production of approximately 11% in the PIRDP and 39% in the MDIP. In
addition, flooding would a have a negative impact on water supply, sanitation, and health during
the flood season. The floodplains would reverse to their former function, supporting aquatic life
during the flood season. This would have a significant impact on fisheries and culture fish
production. A considerable part of the production capacity in the pond culture would be lost,
while the capture fishery could be reinstated. However, on the whole the increase in fisheries
production in the project area would be minimal.

35. Under an embankment retirement scenario (as well as the without project scenario)
continued river erosion will have a significant impact on the terrestrial environment. It will
accelerate the present negative cycle of environmental degradation in the project area where
people displaced by erosion move to remaining marginal land. This will cause a further
deterioration of the existing natural resources and further reduction in the terrestrial biodiversity
in the MDIP and PIRDP areas.

36. At PIRDP, it is estimated that over the past 15 years at least 2,500 households have lost
their homestead lands to river erosion. These households have therefore been forced to
relocate their homes to an alternative location including along the embankment. The number of

11
BWDB. 2000. River Erosion and Morphology Study. Dhaka
10

households that could be lost in the retirement scenario at PIRDP as a result of erosion attacks
in the next 30 years is estimated at 7,000, which includes the 2,500 now existing outside the
embankment and others just on and behind it. In MDIP it is estimated that about 4,000
households have lost their homesteads over the past 15 years, of which, about 300 are at
present squatting on and along the embankment. Another 2,900 households (approximately)
have migrated inside the project area, and the remaining households have migrated to the
opposite side of the rivers. The number of households that could be lost due to bank retreat at
MDIP as a result of erosion attacks in the next 30 years is estimated at 5,400.

37. The alternative without project and embankment retirement scenarios were evaluated
and compared with the recommended protection and alternative approach works using
multicriteria analysis that summarized economic, social, and environmental consequences. (See
summary analysis in Appendix 2.) The overall economic analysis shows that embankment
retirement costs less and has a higher economic viability than riverbank protection by revetment
selected under the Project. However, the severe environmental impacts and significant social
disruption under the embankment retirement scenario, associated with continued loss of
agriculture and homestead land and dislocation of 28,000 people in the next 10 years, made
this choice highly unattractive, and opposed by the stakeholders. There was a consensus
among the stakeholders and the Government that embankment retirement should be avoided
as long as there is an economically feasible alternative, given its highly disruptive social
impacts. Nevertheless, the retirement option would need to be considered if other appropriate
cost effective and sustainable measures are not found to be feasible.

V. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

A. Physical Environment

1. Air

38. During construction, 80-100 boatloads of sand need to be transported to each of the
sites daily. This may cause dust, noise, and air pollution. Storage of sand and sand-filled geo-
bags at the project site may generate dust emission. Impacts during the transportation and
storage of sand will be minimized by covering the sand or by keeping the surface wet. Work will
be restricted to the daytime, reducing nuisance from noise. Boat owners will be required to keep
their engines properly maintained to reduce air pollution from exhausts. Vehicles will be similarly
maintained to minimize exhaust.

2. Soils

39. Establishment of working areas and storage of sand and sand-filled geo-bags at the
project site may cause damage to local vegetation and degrade the topsoil. During these
activities topsoil may be covered by sand, seriously affecting its productivity. Removing the
topsoil from the storage site and storing it in a secure place for later use will mitigate these
impacts. After the completion of the construction, the topsoil will be returned to its original place.
In areas with no topsoil (sandy areas), sand can be stored directly on the ground. However,
after the construction, the area will be turfed and trees planted.
 11

3. Physiography

40. The general physiography of the project areas will not be altered by the Project, and in
general the existing situation will be maintained. Works will be carried out in limited areas, and
the structures will be situated at the river embankments with no apparent changes.

4. River Hydrology and Morphology

a. Design Impacts

41. The riverbank protection works will have significant positive impacts by protecting the
productive agricultural and homestead land from progressive river erosion, without which about
5,300 ha of land would be eroded, displacing about 12,400 households over the next 30 years.
However, structures built on the riverbank will also cause morphological impacts. The
morphological impact will occur when the structure becomes effective. It will affect the river flow
and thereby to a certain extent affect the shaping of the riverbed and the river course. A
structure will become effective when it is being attacked by the flow, protecting the riverbank
against erosion. There are two main categories of structures: active structures built into the
river, intended to influence the river flow (groins, spurs, guide bunds, etc.); and passive
structures that are well aligned with the existing flow and ideally are intended to remain like that
(bank protection structures, revetments, etc.).

42. The bank protection structures planned for the PIRDP and MDIP are passive structures,
intended to stay out of attack as long as possible. Being well aligned with the direction of the
flow, they may not be exposed to any significant attack for some time. In the attempt to erode its
banks, it is likely that the Jamuna will attack the structures. Based on the experience from
previous bank erosion attacks, such attacks are likely to last for a number of years and
subsequently ease off for a number of years until a new attack takes place. The structures will
not prevent these attacks from taking place, but they are designed to stand up against the river
attack and will prevent bank erosion at the location where they have been built. In this situation,
when under erosion attack, the structures will cause morphological impacts.

43. River reaches upstream and downstream of the structure may, if they remain
unprotected, continue to erode, and the protected riverbank will then represent a protrusion into
the river. This will cause local scouring of the riverbed adjacent to the structure, and it may
increase erosion along the opposite side of the channel. This erosion is, however, expected to
be considerably less than the prevented erosion along the protected bank. A number of factors
will tend to delay and limit the morphological impacts at the PIRDP and further to limit any
consequences of these impacts:
(i) Protection work will be along the alignment natural to the river channel
(at least initially and during the coming years, as long as there is no major
morphological change at that location).

(ii) Large areas of uneroded land exist upstream of the Hurashagar River. This will
prevent the protected riverbank from protruding into the river at least over the
short to medium term.

(iii) The impacts further downstream from the protection structure will be reduced
due to joining of the major anabranch (footnote 7).
12

(iv) If any erosion occurs, this will be on the sandbars and the char closest to the
protected portion. These are uninhabited and largely without vegetation.

44. At the MDIP, the naturally occurring erosion rates are smaller than the corresponding
erosion rates at the PIRDP. Thus, the morphological impacts due to prevented erosion will be
even less. It is expected that this effect will not be significant, but rather that impacts will be
minimal and occur mainly locally, close to the intervention. A number of factors will tend to delay
and limit the morphological impacts and further limit any consequences of these impacts:

(i) The existence of erosion-resistant clay deposits along the left bank of the north
Padma channel will prevent further northwards shifts of this channel, thereby
limiting the risk of erosion attack from upstream of the structure.

(ii) The south Padma channel is hydraulically more efficient than the north Padma
channel, and there are signs that this difference will be further enhanced in the
coming years according to recent flow measurements, bathymetric surveys, and
satellite images. This will reduce the erosion attack in the MDIP.

(iii) The impacts further downstream will be further reduced and made insignificant
due to the joining of the South Padma channel just below the protected sections.

(iv) The morphological impact, if any, will initially be in the form of prevented
deposition rather than erosion. Should erosion occur, it will be at sandbars
opposite the protected bank. These are uninhabited.

45. Monitoring of the morphological situation is essential so that mitigation measures can be
planned and implemented in time. The Project will collect all necessary data relating to
hydrology, morphology, hydrodynamics, sedimentation, and other aspects of behavior of the
rivers. The information will be collected, collated, interpreted, and analyzed for the purpose of
making the necessary and timely interventions, if and when erosion upstream of the existing
structures will start to threaten these. In case unexpected morphological changes are detected
that affect areas away from the project sites, these will be analyzed as part of the permanent
monitoring program. If such morphological changes are significant and can be prescribed to
originate from the structures implemented by the Project, a compensation program will be
implemented.

b. Construction Impacts

46. Large-scale sand mining may have some negative impact on the environment. The
present plan is to extract sand by dredging from boats at Gazaria for the MDIP site and from the
confluence of the Hurashagar River and the Jamuna and from chars in the Jamuna River for the
PIRDP site. The amount of sand required for the construction is about 600,000 cubic meters,
equivalent to approximately 1 million mt for both sites together. Construction will take place in
phases over a 6-year period. Compared with the annual bed load transport of the Jamuna and
Ganges of 150 million mt and more than 200 million mt in the Padma, the dredged volume of
sand will be very small, and no impact is expected on river morphology and erosion.
 13

5. Surface Water Quality

a. Design Impacts

47. The Project will protect the pump-operated surface water irrigation and drainage system
to draw in river water for irrigation and drain out any polluted or stagnant water from the project
area. This in turn will reduce local water pollution problems. The overall impact of the project on
water pollution is expected to be positive.

b. Construction Impacts

48. During the implementation phase there may be some water pollution from the
construction site, labor camps, etc. There may be up to 3,000 laborers at each construction site
during peak construction period. To mitigate this, the following measures will be taken:

(i) Maintain all construction sites in a clean and safe condition, and provide and
maintain appropriate facilities for temporary storage of all wastes before
transportation and disposal.

(ii) Organize disposal of all wastes generated during construction in an

environmentally acceptable manner. This will include consideration of the nature
and location of disposal sites, so as to cause least environmental impact.

(iii) Take all precautionary measures when handling and storing fuels and lubricants,
to avoid causing environmental pollution. This is to include establishment of
contingency plans for cleanup in the event of spillage.

(iv) During site inspections a trial sand dredging was observed. No direct impacts
were identified except the overflow from the barge where the sand is separated.
The silt and clay contents in the overflow were found to increase the turbidity of
the water in the vicinity of the operation.

49. As part of the EMP, the dredging operations will be monitored to ensure that water
quality standards are not violated with respect to turbidity. If this is observed, the site of
dredging will be shifted to places where the clay and silt content is low enough to maintain the
turbidity within the water quality standards.

6. Groundwater

50. Continued supply of irrigation water is considered to improve the recharge and
availability of groundwater in the project areas during the dry season. The Project is not
foreseen to have any impact on the groundwater resource during construction.

B. Biological Environment

1. Aquatic Ecosystem

51. The Project is foreseen to have a limited positive impact on the aquatic ecosystem by
providing shelter for aquatic organisms at the revetment. During construction, sediments may
reach the aquatic habitat from sand mining, transport, storing, filling of sandbags, and dumping.
Slope preparation at some stretches, especially at the PIRDP, may be necessary, which would
14

create spreading of sediment. However, the expected increase in sediment concentration is not
considered to be higher than generated at present by river erosion, and the effect is considered
negligible.

2. Terrestrial Ecosystem

52. The Project will not encroach into any terrestrial habitats of any significance. It will
prevent the ongoing erosion of the present terrestrial habitats, however human-impacted these
may be, thereby having an overall positive impact. During construction, noise may disturb the
(scarce) wildlife and birds in the vicinity of the project sites, thereby having a slight negative
impact. Sand mining close to existing uninhabited areas such as sandbars used by birds for
resting will be avoided. Boat owners will be required to keep their engines properly maintained
to reduce noise. Vehicles will also be maintained to minimize noise.

3. Endangered Species

53. Disturbances during construction may have a temporary effect on endangered species.
However, no permanent negative impact is foreseen.

C. Human and Economic Development

1. Resettlement

54. The Project will involve a total of (i) 11.4 km of revetment works in the PIRDP and MDIP
and (ii) 1.2 km of secondary defense line (SDL) of embankments in the PIRDP, which will
require the acquisition of land, removal of buildings, and resettlement of affected people. The
total amount of land acquired for revetment is estimated at 35 hectare (ha) in PIRDP and 22 ha
in the MDIP. This will displace 89 households including 9 small business enterprises. These
have to be further reviewed during the final design stage, when the alignments for the protection
works will be decided upon based on the morphological development at that time. On the other
hand, the SDL will require the acquisition of 10 ha of land, for which 3 households (18 people)
will be relocated and an additional 30 households will experience some loss of agricultural
lands. This does not include land for construction camps or storage areas, as the number, size,
and location of these have yet to be determined. The land taken for these facilities will be kept
to a minimum and will be leased temporarily.

55. The resettlement activities will be implemented in accordance with ADB’s involuntary
resettlement and other social safeguard policies. In the context of the Project, a resettlement
framework (RF) was prepared for the PIRDP and MDIP to cover the riverbank protection work,
for which specific sites will be finalized at the final design stage in response to the shifting of the
riverine environment. The established RF requires the following procedures: (i) BWDB will carry
out impact assessment surveys once the scope of each year’s work is identified, based on
preliminary technical designs; (ii) if impacts are found to be “significant,” BWDB will prepare full
RPs for each subproject; and (iii) if subproject impacts are less than significant, short RPs will
be sufficient for project preparation. Experienced consultants and NGOs will be recruited to
assist the process. The short RPs must, however, comply with ADB’s policy on involuntary
resettlement and other social safeguard guidelines. In addition to the above, a short RP was
prepared for the SDL. The summary of RF and short RP are given in Appendix 3.
 15

2. Land Use and Settlement

a. Design Impacts

56. It is expected that 12,400 households in the project areas will be protected from losing
their land over the 30-year lifetime of the Project. An additional 91,000 will be protected from
annual flooding of the project areas. This will have a large positive impact on households and
settlement.

b. Construction Impacts

57. Apart from the resettlement impacts described in para. 54, during construction the
presence of construction camps may stress the existing settlement resources and infrastructure.
This may lead to antagonism between locals and migrant workers. To prevent this, the
contractor will be required to prioritize the use of local labor. In addition, the contractor will
provide camps with facilities such as health care clinics and places of worship, and a
mechanism will be established that allows local people to raise grievances arising from the
construction process.

3. Water Supply and Sanitation

a. Design Impacts

58. Implementation of the Project will protect the present infrastructure of the area including
tubewells, dugwells, and latrines from flooding. This will have very positive impact on securing a
hygienic drinking water supply and maintaining sanitation facilities in the areas inside the
embankments during the wet season.

b. Construction Impacts

59. During the construction phase some tubewells may have to be relocated and some
people using the river as their source of drinking water may face inconvenience. This may have
a minor local negative impact. To mitigate any such impact the contractor will be required to
establish an alternative water supply.

4. Agricultural Productivity

Design Impacts

60. A small amount of agricultural land may be permanently needed for sloping of the
revetment, especially in the PIRDP. However, the Project will prevent the further erosion of
much larger areas of agricultural land. In addition, the Project will preserve the FCD&I facilities.
Without these it is estimated that cropping intensity in the PIRDP area will be reduced from the
present 177% to 167% and in the MIDP area from 214% to 169%. Not only will the Project
preserve the present, increased agricultural production, but it will also provide the potential for
further increase in both schemes. The project will have a long-term, very positive impact on
agricultural productivity.
16

b. Construction Impacts

61. Agricultural production may be slightly reduced during the implementation of the Project
because of construction of labor camps, approach roads, storage sites for construction
materials, sites for preparation of geo-bags and concrete blocks, transportation of construction
material, etc. It is expected that the contractor will establish camps for laborers and permanent
staff supervising, directing, and controlling the works. These camps are anticipated to house up
to around 1,300 people during construction work, which will typically last about 4-6 months. The
area needed for each camp is from 2-3 ha. The land for these camps will be hired, owners
compensated, and the land restored after demobilization. After construction the agricultural land
will be reinstated to its former state, wherever possible. Any longer term damage to the
productivity of rented land will be compensated for through the RP.

5. Fish Culture

62. The Project will preserve the existing flood protection facilities. Fish production from
ponds protected against flooding is generally more than double the productivity in unprotected
ponds. The Project will ensure the basis for the present, high fish culture productivity, with even
the potential for further increase in the future. During construction, the project will be
implemented along the riverbank, where there are no fishponds or other water bodies.

6. Navigation
a. Design Impacts

63. One of the major navigation routes maintained by BIWTA is the channel outside the
PIRDP leading into the Hurashagar River. Especially at the confluence with the Jamuna,
sedimentation occurs. Dredging is carried out to ensure navigability and access to the oil
terminal in the Hurashagar River. The dredging works may have to consider the safety of the
riverbank protection and not be carried out in the immediate vicinity. Coordination between
BWDB and BIWTA on this issue has to be effected in the joint management committee (JMC)
formed in the project area and the project steering committee formed at the central level. River
ports and ghats (boat landing facilities) and access roads should be incorporated in the
revetment design to ensure people's mobility.

b. Construction Impacts

64. Easy access to the river may be somewhat obstructed during construction. In many
places the river is a major means of transportation of goods and people. During implementation
of the works, proper planning should ensure that the inconvenience to people is minimized by
leaving access to the river at given, required sites along the riverbank.

7. Quality of Life Values

a. Way of Life and Equity

65. All strata of the population will benefit from the Project protecting agricultural land,
homesteads, markets, hospitals, schools, roads, irrigation systems, etc. Increased agricultural
production and the construction works of the Project will generate more employment
opportunities for the poor and landless, including destitute women. To maximize these benefits,
contractors will be required to recruit laborers among the poor and landless with a preference
for destitute women.
 17

b. Income and Poverty

66. The Project will have a very positive impact in preventing a substantial part of the people
in the project area from becoming landless and thereby from being thrown directly into poverty.
In addition the Project will preserve the potential for further improvement in agricultural
production. Especially in the PIRDP there is potential for further increase, as the present
production is substantially lower than in the MDIP. It is expected that all levels of society will
benefit from increased agricultural production, although large landowners will be relatively more
benefited than others.

Health and Education

(i) Design Impacts

67. As the bank protection measure will help increase the agricultural productivity of the
area, this will create employment opportunities for the poor. An increase in household income
will directly contribute to overall improvement in living conditions, particularly through better
health and nutritional status of people. It is likely that per capita expenditure on food, sanitation,
and health care will increase, which will have positive impacts on health.

68. The Project will provide improved income opportunities, which in turn will encourage
people to send their children to school more regularly. This will be a positive impact on
education. The bank protection measures will prevent erosion of schools and colleges in the
area and provide flood-free areas for normal economic, social, and academic activities.
Infrastructure protected by the bank protection measures will provide easy access to schools
and colleges.

(ii) Construction Impacts

69. It is anticipated that around 3,000 workers will be employed at each project site, of whom
more than half would be hired locally. Any impacts on the health of workers employed on the
Project will be mitigated by provision of adequate water supply and sanitation facilities, proper
waste collection and disposal systems, health clinics, etc. at both sites.

70. There is a general risk of accidental injury to workers. Implementation of adequate safety
procedures and provision of first aid facilities will mitigate this to the extent possible. The risk of
possible health hazards from handling of geotextiles will be small. Following appropriate
construction techniques and safety procedures will mitigate or reduce these negative impacts on
workers. High-grade geotextiles will be used in the construction, and manufacturers’ instructions
for the handling and use of geotextiles will be followed.

71, During the implementation phase, schools in the vicinity may experience temporary
disturbance due to noise and dust. The timing and placing of construction activities should seek
to avoid any unnecessary disturbances during school hours.

D. Impact Identification and Assessment Matrix

72. The important environmental components and their potential interaction with the major
project activities are presented in a matrix (Appendix 4) following the methodology described in
the full EIA report. National guidelines require this matrix be considered in order to be able to
evaluate the impact of the Project in a rational manner.
18

VI. ECONOMIC ASSESSMENT

73. The total cost of the Project is estimated at $61.3 million for the 6-year project period.
The foreign exchange component is calculated at $19.5 million (32%) and the local component
at $41.8 million (68%). Taxes and duties account for $9.7 million of the local component.

74. The economic assessment of the Project shows an economic internal rate of return of
17% and 31% for the PIRDP and MDIP areas, respectively. The analysis indicates that there is
no significant difference in the economic viability indicators between geo-bag revetment and low
spurs. Geo-bag revetment was selected in consideration of technical and managerial criteria
including the prospects of economizing the costs by providing the structures adaptively in
response to prevailing morphological conditions.

75. The costs associated with the environmental mitigation measures identified relate to the
resettlement, environmental costs to be covered under the civil works contract, disaster
preparedness, riverbank management monitoring and information, environmental monitoring
and capacity development. The total costs, amounting to $5.22 million, are outlined in Appendix
5. Resettlement amounts to $2.00 million, detailed in the RF.

76. For the PIRDP, the likely morphological impacts are slightly increased erosion of nearby
chars. These chars are newly developed, uninhabited, and unutilized. For the MDIP, the likely
morphological impact would be a reduction of the deposition at the inner bend of the Padma
north channel, opposite the project area. The costs of these morphological impacts cannot be
quantified at present. The information management subcomponent of the Project will be
designed and implemented to detect any such identifiable impacts. Contingencies in the
environmental cost budget will cover unforeseen morphological impacts and ensuing
compensation, if required.

77. Other nonquantifiable costs include effects from air pollution; disturbances to wildlife,
birds, and fish; and water pollution during construction work. Such effects, though minimized
through mitigation efforts, are non-avoidable, and are considered small. By protecting land from
further erosion and preserving the FCD&I facilities in the PIRDP and MDIP, the project is
expected to have nonquantifiable positive effects on income generation, poverty, equity, health
and education for the total population of 440,000 in the irrigation command area.

78. The Project will preserve the PIRDP and MDIP areas and reverse the negative impact
these schemes have had on capture fisheries through increased culture fisheries. It is not
possible to accurately estimate the present day costs of the reduction in capture fisheries, as
this has declined all over Bangladesh during the last decade. However, the increase in culture
fisheries has, since the implementation of the PIRDP and MDIP, made up for the loss in capture
fisheries. Total fish production today is considered to be at more or less the same level of 3,000
tons per year in the MDIP and 1,500 tons in the PIRDP.

VII. INSTITUTIONAL REQUIREMENTS AND ENVIRONMENTAL MONITORING

PROGRAM

79. The institutional requirements for mitigation of the adverse effects of the Project and the
associated environmental monitoring program have been incorporated into the EMP (Appendix
6). The EMP outlines the environmental management system that will be implemented during
the detailed design and protection works of the Project to minimize deleterious effects and
implement enhancement measures. The EMP also embraces environmental management
 19

issues following the implementation of the riverbank protection measures, to maximize the
beneficial effects of the Project, and to detect and ameliorate adverse long-term effects.
Environmental management of the Project will involve the following national level agencies:

(i) BWDB, under the control of the Ministry of Water Resources with the guidance
and supervision of the Governing Council of the Board, as the executing agency
of the project; and

(ii) Department of the Environment (DOE), under the Ministry of Environment and
Forest, responsible for environmental clearance of the Project and enforcement
of other environmental legislation.

80. At the BWDB headquarters levels, a project management office (PMO) will be set up
with a senior director or additional chief engineer as full-time project director. Overall
responsibility for the environmental management of the Project and liaison with DOE will lie with
the PMO, with the engagement of an executive engineer having environmental management
experience and assisted by consultants. At the level of the PIRDP and MDIP, subproject
management offices (SMOs) will be established, each with a superintending engineer as
subproject director, under the newly established JMC comprising representatives of line
agencies, local governments, and stakeholder institutions. The PMO in association with the
Hydrology Department of BWDB will be responsible for morphological information management
at the national level. These organizations will form and operate a riverbank management system
focusing on the project area and relevant reaches of the Jamuna and the Meghna rivers.

81. For proper monitoring and evaluation (M&E) of the proposed interventions including
environmental management, an M&E subdivision will be created in each SMO. An
environmental specialist will be placed to carry out environmental monitoring and reporting with
the assistance of the PMO and consultants. (See Appendix 7 for the organizational setup for
environmental management.) A section officer experienced in resettlement and social
development will be posted in the construction subdivision of each SMO to undertake
concerned activities with the assistance of consultants and engagement of nongovernment
organizations (NGOs). Training programs in these disciplines for BWDB professionals will also
be provided to enhance their capacity.

82. The responsibilities for undertaking specific required activities at the design,
construction, and operational stages are listed in Table 2.

83. The contractor’s environmental responsibilities will be prescribed in the tender

documents and later on in the contract. They will include the need to adhere to environmental
clauses in the contract and the guidelines provided. The contractor’s responsibilities will include
ensuring occupational health and security for workers, minimizing disturbances, and adhering to
existing environmental legislation, including avoiding water pollution and following proper waste
handling and deposition procedures.

84. The M&E subdivisions, with the assistance of the PMO, will supervise and enforce
contractual requirements and monitor compliance. The M&E subdivisions will be supplied with
necessary equipment for sampling and measurement of dissolved oxygen, turbidity, and other
relevant parameters. The M&E subdivisions will submit quarterly and annual reports to the PMO
and JMC. All reports will be forwarded to DOE for review. See Appendix 8 for a summary of
environmental impacts and mitigation measures.
20

Table 2: Institutional Responsibilities for Environmental Management

Project Responsible Responsibilities

Stage Organization
Detailed DOE Review project EIA and provide environmental clearance for Project.
Design
PMO/ Consultants Minimize non-avoidable losses; incorporate mitigation measures and
enhancement activities into engineering design and specifications.
PMO/ Review and approve environmental mitigation measures
Consultants Review and forward EMP for DOE approval.
Review and forward RP for ADB approval.
SMO/ NGOs/ Implement RP.
Consultants
Construction Contractor Implement required environmental measures.
SMO – M&E/ SC Supervise contractor's implementation of environmental measures.
Enforce contractual requirements.
SC Audit construction activities through inspections and environmental
monitoring. Submit quarterly/annual reports.
DOE Monitor compliance with legal requirements during construction.
Operational BWDB Provide budget to undertake environmental monitoring.
Operational SMO – M&E Carry out environmental monitoring and submission of quarterly/annual
reports.
Operational PMO/JMC/DOE Review monitoring reports.
ADB=Asian Development Bank, BWDB=Bangladesh Water Development Board, DOE=Department of Environment,
EIA=environmental impact assessment, EMP=environmental management plan, JMC=joint mamangement
committee, NGOs=nongovernment organizations, M&E=monitoring and evaluation, PMO=project management office,
RP=resettlement plan, SC=supervision consultant, SMO=subproject management office.

VIII. PUBLIC INVOLVEMENT

85. Public involvement has been a substantial part of the process. During the study phase
the people’s consultation process was initiated to obtain stakeholders’ views on the
consumptive and nonconsumptive use of natural resources, and their demands for protecting
and enhancing the environment. The process was carried out in two rounds, the first one
through focus group discussions (FGDs) with smaller groups of homogeneous stakeholders in
selected (i) areas inside and outside the embankments directly threatened by riverbank erosion,
(ii) areas outside the embankment not threatened by riverbank erosion, and (iii) areas inside the
embankment benefiting from FCD&I facilities. In total, 42 FGDs were held. On the basis of FGD
consultations, the second round of consultations was held in the form of local workshops
involving local and regional officials, union parishad12 chairpersons, elected people in the water
management associations (WMAs), civil society representatives, as well as representatives
from the FGDs to discuss potential options and stakeholder views, which are summarized as
follows:

(i) The consulted people pointed at traditional river erosion protection designs as
construction of hardpoints, e.g., groins at Eklaspur, and revetments.

(ii) Nonstructural measures such as planting of grass and trees for stabilizing the
embankments were identified as beneficial.

12
Refers to village union assembly.
 21

(iii) For participation in the implementation of proposed mitigation measures against

river erosion, the union parishads and BDWB were considered to have a role
along with local committees formed with the involvement of NGOs.

(iv) People’s representation in WMA and union parishad, and involvement of NGOs
was considered important as well.

(v) Collection of taxes on land supplied with irrigation was identified as a primary
possible source of financial contribution to mitigate river erosion. Taxes on
fishculture were seen as another funding possibility. Tolls on traffic and on
marketplaces were identified as well.

(vi) Local people offered support in kind as physical labor, supply of food, shelter,
and necessary materials (bamboo, sacks, etc.).

86. A national workshop was held in December 2001 with 120 participants focusing on the
design options. Important feedback was provided, including that (i) the Project should be
integrated with a comprehensive national strategy and plan for riverbank management; (ii) the
feasibility and long-term sustainability of proposed cost-effective structural solutions needs to be
confirmed in light of the highly dynamic morphological processes; (iii) their effectiveness should
be verified in the context of the major rivers in Bangladesh; (iv) nonstructural measures for flood
and erosion mitigation should also be explored and adopted, including floodplain management
and support to existing erosion victims; (v) effective monitoring arrangements for the erosion
process and the performance of protection works need to be established; (vi) environmental
impacts on char lands and other river processes need assessment; and (vii) further options for
institutional setup could be explored with a long-term vision for river management that requires
a system-wide approach. It was remarked that the guidelines of ADB as well as the Government
should be followed. These issues were consequently addressed in the design of structural and
nonstructural measures, impact assessments, and the institutional and project implementation
plans.

87. During February 2002, surveys on people’s perception of the environmental issues in the
PIRDP and MDIP were carried out. A total of 10 FGDs were carried out in both the PIRDP and
MDIP involving in all nearly 160 people. The FGDs revealed that there is little conflict between
fishermen and farmers. Overall, people’s perception of the existing embankments is positive. If
embankments were decommissioned or destroyed, the following problems would occur
according to the people consulted: (i) Bera and Matlab upazilas would go under water; (ii) the
total project area will be destroyed; (iii) crops, livestock, and homes would be damaged during
floods; (iv) rice would be produced only once a year, which would result in a food shortage; (v)
fish cultivation would be disrupted; (vi) out-migration problems would occur; (vii) acute
sanitation, fuel wood, and drinking water problems would be created; (viii) people would become
shelterless; (ix) communications would be disrupted; (x) income of people would be reduced;
(xi) waterlogging might occur and remain a problem in the PIRDP; and (xii) fishermen during
times of low catch opportunity would have to revert to other temporary occupations as day
laborers, rickshaw pullers, etc.

88. As a part of the public involvement process, a consultative meeting was held in March
2002 to present and discuss the preliminary results of the EIA to 12 leading NGOs, and
government institutions, and institutions active in the environment sector, as well as BWDB. The
participants generally supported the choice of the geo-bag revetment against other alternatives
such as retiring the embankments, in view of the extreme social and economic hardship of the
22

large number of people who would have to be displaced as river erosion proceeds. However, its
cost effectiveness and long-term sustainability against the highly dynamic morphological
process in Bangladesh were pointed out as critical concerns. On this account, it was explained
that the Project will take a passive and adaptive approach, under which the revetment will be
designed and provided where the protected bank line can be aligned along lines natural to the
river system cost effectively, and where such alignment can be expected to remain natural over
a reasonable period. This will minimize the risk of structural failure and will contain high
maintenance requirements.

89. Regarding the environmental impacts of the selected design option, it was generally
noted that the impacts should be insignificant, and confined to the vicinity of the project areas.
While morphological impacts on erosion and sand deposition in the nearby areas drew some
attention, it was explained that (i) nearby char lands and sand bars on which the revetment may
cause direct impacts are uninhabited and unutilized; and (ii) overall impacts should be small as
long as the revetment remains passive and adaptive to the natural river course, with any
morphological changes upstream and downstream regarded as statistically neutral.

IX. CONCLUSION

90. The proposed Project aims to mitigate the effects of riverbank erosion, which is currently
threatening critical sections of the flood embankments in the PIRDP and MDIP, through cost-
effective, sustainable, and comprehensive structural and nonstructural measures to cope with
the highly dynamic morphological process of the Jamuna and the Meghna rivers. With the
placement of revetments using sand-filled geo-bags following an adaptive approach along the
alignments natural to the river system, it will protect and enhance the livelihoods of the
beneficiary people totalling about 440,000 within its irrigation command, and about 2 million in
the overall area protected by the flood embankments.

91. The major benefits from the Project therefore will come directly from the environmental
and socioeconomic resources preserved by erosion protection, and indirectly from the losses
prevented. Therefore, the impacts, benefits, and disbenefits of the Project have been assessed
comparing the present situation with a without-project situation during its expected 30-year
lifetime. The impacts during construction works have been addressed as well.

92. The major positive impacts resulting from the Project will be to

(i) arrest river bank erosion, thereby protecting existing homesteads, infrastructure,
and agricultural land;

(ii) bring an end to people rendered landless in the project areas;

(iii) safeguard FCD&I facilities; and

(iv) maintain the present level of and the potential for future increases in agricultural
production.

93. The EIA did not identify any environmentally sensitive areas that may require particular
attention. The project area, including both the riverbank and the river itself, are heavily
impacted by human activities. The project intervention will encourage limiting human activities
within remaining sensitive areas outside the embankments and thus help to protect the
environment and ecology.
 23

94. The potential morphological impacts of the structures and the risk of increased
riverbank erosion elsewhere have been studied. For the PIRDP, the likely morphological impact
will be slightly increased erosion of nearby chars. These chars are newly developed,
uninhabited, and unutilized. For the MDIP, the likely morphological impact will be a reduction of
the deposition at the inner bend of the north Padma channel, opposite the project area. These
assessments, however conclusive, may be considered qualitative.

95. In general the planned implementation of mitigation measures during the design,
construction, and maintenance periods of the Project will minimize negative environmental
impacts to satisfactory low levels. The mitigation measures will be included as part of the project
design. Monitoring of morphological and other environmental impacts is essential so that
mitigation measures can be implemented in time. This monitoring will be carried out as an
important element in the riverbank management system, which will continue for the lifetime of
the Project.

96. In conclusion, the Project will have overall beneficial impacts preserving the existing and
potential benefits of the existing PIRDP and MDIP schemes, as well as protecting the livelihood
of the population living outside the embankments in the erosion prone Project areas. Negative
impacts are expected to be insignificant, but nevertheless will be carefully monitored and
mitigated.
26 Appendix 2

MULTICRITERIA ANALYSIS OF OPTIONS

Pabna Irrigation and Rural Development Meghna Dhonagoda Irrigation Project

Project
Do Riverbank Protection Embankment Do Riverbank Protection Embankment
Nothing Retirement* Nothing Retirement*
Revetment Low Solid Revetment Low Solid
Spur Spur
Financial Capital Cost Over 30 Years ($ million) - 47.6 48.2 23.7 - 31.3 34.7 20.4
Economic Economic Net Present Value ($ million) -26.0 3.65 3.00 9.3 -44.9 13.2 10.7 15.4
Criteria EIRR - 16.7% 16.7% 30.9% - 31.4% 23.4% 72.0%
Physical Air 0 0 0 0 0 0 0 0
Environment Soil 0 0 0 0 0 0 0 0
Physiography -3 0 0 -2 -3 0 0 -2
River Hydrology and Morphology 0 -1 -1 0 0 -1 -1 0
Surface Water Quality -2 -1 -1 -1 -2 -1 +1 -1
Groundwater 0 0 0 0 0 0 0 0
Biological Aquatic Ecosystem +2 -1 -1 0 +2 -1 -1 0
Environment Terrestrial Ecosystem -2 +2 +2 -2 -2 +2 +2 -2
Endangered Species 0 0 0 0 0 0 0 0
Human and Land Use and Settlement -3 +2 +2 -2 -3 +2 +2 -2
Economic Water Supply and Sanitation -3 +1 +1 -1 -3 +1 +1 -1
Development
Agricultural Productivity -3 +2 +2 -1 -3 +2 +2 -1
Fish Culture -3 +2 +2 -1 -3 +2 +2 -1
Navigation -1 0 0 0 -1 0 0 0
Quality of Life Way of Life and Equity -3 +2 +2 -1 -3 +2 +2 -1
Values Income and Poverty -3 +2 +2 -1 -3 +2 +2 -1
Health and Education -2 +1 +1 -1 -2 +1 +1 -1
Resettlement Cost of Land Acquisition ($ million) - 1.18 0.59 5.4 - 0.64 0.32 5.2
Criteria
Relocation of Household (no.) 7,000 86 26 7,000 5,400 3 1 5,400
Market Price of Eroded Land ($ million) – 26.0 - - 26.0 26.7 - - 26.7
excluded from financial/ economic cost
Erosion-and-flood Affected People (no.) 540,000 86 26 35,000 210,000 3 1 27,000
EIRR=economic internal rate of return.
*Cost of embankment retirement option does not include the cost of safety net for those who will be displaced by river erosion.
Note 0= not significant , +1= small benefit, -2= moderate negative impact,
-1= small negative impact, +2= moderate benefit, -3 = major negative impact.
 Appendix 3 27

SUMMARY OF RESETTLEMENT FRAMEWORK AND SHORT RESETTLEMENT PLAN

A. Resettlement Framework for the Riverbank Protection Works

1. Scope: The resettlement framework (RF) includes the framework for the proposed 7.0
kilometer (km) and 4.4 km of protection work along the flood embankments of the Jamuna and
the Meghna rivers in the Padma Irrigation and Rural Development Project (PIRDP) and
Meghna-Dhonagoda Irrigation Project, respectively, to protect the project areas from
progressive river erosion. The revetment works will be implemented over a 6-year period.
During that time, an estimated 57 hectares (ha) of land will be acquired for revetment work.
Implementation of the Project is expected to start in the first quarter of 2003. The Bangladesh
Water Development Board (BWDB) is the executing agency of the Project.

2. Resettlement Policy Framework: The current legislation governing land acquisition for
the Project includes: (i) Acquisition and Requisition of Immovable Property Ordinance of 1982,
and (ii) East Bengal State Acquisition and Tenancy Act (1951, revised 1994). While the 1982
Ordinance is the only law that provides clearly defined compensation for land acquisition, it does
not cover project-affected persons without titles or ownership records such as informal
settlers/squatters. Further, the compensation paid does not constitute market or replacement
value of the property acquired. The East Bengal State Acquisition and Tenancy Act (Section 7)
defines the ownership and use right of alluvial (nadi sikosti) and diluvion land (payosti,
reformation in situ or original site) in the country. Legally, the Government owns the bank lines
and eroded land in the river. However, the “original” owner(s) can claim the land if it reappears
as a natural process with the 30 years from the date of erosion.

3. In the absence of a policy consistent with the Asian Development Bank’s (ADB) policies
on involuntary resettlement and poverty reduction, a project-specific resettlement policy
framework (RPF) and resettlement procedural guidelines (RPGs) will be adopted. The RPF and
RPG stipulations in line with ADB policy will apply to all riverbank protection works to be
prepared and approved under the loan project. This will ensure that persons affected by land
acquisition – whether it is floodplain, bank line, or eroded land – will be eligible for appropriate
compensation in this Project.

4. The RPF stipulates eligibility and provisions for all types of losses (land, crops/trees,
structures, business/employment, and workdays/wages). Since land-for-land would not be a
feasible option due to the ongoing erosion in the floodplain, the owners of land acquired for
protection work, including bank line/eroded land within the 50 meter right-of-way acquisition
(from the revetment toe in the river to the floodplain on the bankline), will be compensated at full
replacement cost. Affected households compensated by the deputy commissioner for lost
assets will receive (i) an additional cash grant to match the replacement value; and (ii) other
resettlement assistance, such as shifting allowance and compensation for loss of
workdays/income due to dislocation. Female-headed households and other vulnerable
households will be eligible for further cash assistance for relocation and house reconstruction.

5. Resettlement Procedural Guidelines: The established RPGs require the following

procedures: (i) BWDB to carry out impact assessment surveys after the bank lines to be
protected under each year’s work are defined, based on preliminary technical designs; (ii) if
impacts are found to be “significant,” BWDB will prepare a full resettlement plan (RP) for each
subproject; and (iii) if subproject impacts are less than significant, short RPs would be sufficient
for project preparation. The short RPs must, however, comply with ADB’s policy on involuntary
resettlement and other social safeguard guidelines.
28 Appendix 3

6. Disclosure, Consultation, and Grievances: Each RP will be prepared and

implemented in close consultation with the stakeholders and will involve focus group
discussions and meetings, particularly with the project-affected people. Copies of draft RPs will
be distributed among nongovernment organizations (NGOs)/community groups. A grievance
redress committee (GRC) will be established with representation from BWDB, affected persons,
women/vulnerable groups, local government, and NGOs. The resettlement coordinator will chair
the GRC. Other than disputes relating to ownership rights under the court of law, the GRC will
review grievances involving all resettlement benefits, relocation, and other assistance. Any
grievances submitted to the GRC will be resolved within a period of 2-3 weeks.

7. Institutional Responsibilities and Resettlement Cost: The Ministry of Water

Resources through BWDB has overall coordination, planning, implementation, and financing
responsibilities. BWDB fully recognizes the complexity of the resettlement and social
development programs under the Project. Therefore, an experienced NGO will be hired for RP
implementation. A senior BWDB staff member with the rank of executive engineer will be
appointed as chief resettlement officer to supervise the implementation work. BWDB will further
ensure that resettlement funds are delivered on time to the deputy commissioner’s office and
the implementing NGOs for timely RP implementation. The cost of land acquisition and
resettlement is estimated at Tk104.0 million ($1.81 million) including contingencies. The
Government of Bangladesh will provide the entire fund for land acquisition and resettlement.

8. Monitoring and Evanluation: BWDB will establish a monthly monitoring system

involving BWDB and implementing NGO staff, and will prepare progress reports on all aspects
of land acquisition/resettlement and social development activities. External monitoring will be
assigned to an independent local expert/agency. BWDB will report to ADB on land acquisition
and resettlement/social development in the quarterly progress report.

B Short Resettlement Plan for the Secondary Defense Line of Embankments

9. Scope: The short RP is associated with the construction of a 1.2 km secondary defense
line (SDL) embankments to protect some critical sections of the existing embankments in the
PIRDP. It will be implemented in 2003.

10. Impacts: The construction of the SDL will require acquisition of an estimated 10 ha of
land. The proposed alignment consists largely of low-lying agricultural land. As a result, the
project impact is limited to three households only (total affected persons, 18). In addition to this,
an estimated 30 households will experience some loss of agricultural lands. However, the
severity of impact will still be limited due to strip acquisition. The affected households requiring
resettlement own their house plots as well as structures to be relocated; they typically combine
agriculture with wage labor, fishing, and/or small businesses as sources of livelihood. Two of the
three households reported incomes, that translate into less than a dollar per day per person.

11. Resettlement Plan Objectives and Policy Framework: This short RP is designed to
deal with the limited impacts of the SDL. Major types of losses include loss of
agricultural/homestead land, crops/trees, other immovable assets, residential structures, and
work days/income due to dislocation and relocation. BWDB is keen to minimize land acquisition
and will take all measures to reduce the amount of land acquisition to the absolute minimum,
taking into account the need for the SDL.
 Appendix 3 29

12. The current legislation governing land acquisition for public purposes is the 1982
Ordinance, in accordance with which the legal process is initiated by an application by the
executing agency to the deputy commissioner of the district. In determining the amount of
compensation, the deputy commissioner takes into consideration land transaction cases for the
preceding 12 months to determine the average value, plus a 50% premium for compulsory
acquisition. The 1982 Ordinance, however, does not cover project-affected persons without
titles or ownership records such as squatters or roadside encroachers, nor indirectly affected
people. At present there is no national policy for resettlement of project-affected people in
Bangladesh. As a result, ADB’s policy on involuntary resettlement1 will be used as the
framework for this RP. The framework has been designed to cover compensation for lost assets
and to restore or enhance the livelihoods of all categories (direct, indirect, titleholders, and
nontitleholders) of affected people. The entitlement matrix recognizes seven types of losses to
cover all potential cases, including loss of access by tenants/sharecroppers due to acquisition of
agricultural land (Table A3.1).

13. Consultation Meetings and Stakeholder Participation: During the project preparatory
stage, consultation was held covering the SDL area. The feedback and observations made at
the stakeholders’ meetings have been used in preparing the entitlement matrix and project
benefits for the affected people. In addition, two local workshops were held in the project area,
in which a strong support and positive public responses were observed towards the SDL and
other protection work from riverbank erosion, because it will ensure the safety and security of
the people and bring significant economic benefits to the local communities.

Table A3.1: Entitlement Matrix

Definition of
Type of Loss Application Affected Entitlements Expected Results
Persons
1. Loss of Land on the Legal owners
Cash compensation under law by DC Replacement of
agricultural or SDL ROW of land
Additional cash grant to match agricultural land or
any other type market/replacement value to be the value to the
of land such determined by BWDB through affected persons
as fishponds. independent valuation committee

Refund of registration cost incurred for
replacement land purchase
2. Loss of Land on the Legal owners
Cash compensation under law by DC Replacement of
homestead SDL ROW of land
Replacement value of land homestead/
land
Refund of registration cost incurred for commercial land
replacement land
3. Loss of Structure on Owner(s) of
Cash compensation under law by DC Reconstruction of
residential the SDL structures
Additional cash grant to match structure at a new
structure by ROW identified by replacement costs site
owners DC and the
Tk2,000 as transfer grant for relocation
SES
Tk7,500 for homestead/ land
development and reconstruction cost
4. Loss of Standing Owners of
Compensation at the rate estimated by Compensation for
trees, crops, crops, trees land the Forest Department and the standing crops and
perennials on SDL Agricultural Extension Department trees
ROW
5. Loss of Agricultural Tenants of
Tk200 per decimal (1/247 hectare) of Compensation for
access by plots on the the land as agricultural land under tenant/ loss of access to
tenants/ SDL ROW identified by sharecropping contract farming farmland
sharecroppers the SES

1
ADB. 1995. Involuntary Resettlement. Manila.
30 Appendix 3

Definition of
Type of Loss Application Affected Entitlements Expected Results
Persons
6. Loss of Households Head of
Tk2000 per household Subsistence and
income and affected by households
Tk3000 for households headed by income in post-
work days SDL RoW identified by women displaced period
due to the SES
Employment in the project construction
displacement work
7. Additional Vulnerable Households
Lump sum poverty reduction assistance Poverty reduction
assistance to households relocated to of Tk5,000 per household with incomes measures and
the poor and on the SDL new site under the poverty line development
vulnerable RoW
BWDB=Bangladesh Water Development Board, DC=deputy commissioner, ROW=right of way,
SDL=secondary defense line, SES= socio-economic study.

14. Disclosure, Consultation, and Grievances: The same arrangement as described in

the RF will be followed.

15. Implementation Responsibilities and Cost Estimates: The same arrangement as

described in the RF will be followed. The estimated land acquisition and resettlement cost for
the SDL is Tk15 million ($260,000). The Government will provide the entire fund for land
acquisition and resettlement. The affected people, including those affected by land acquisition,
will receive compensation prior to the start of construction work.

16. Monitoring and Evaluation: During project implementation, BWDB will establish a
monthly monitoring system involving BWDB and implementing NGO staff, and will prepare
monthly progress reports on all aspects of land acquisition/resettlement operations. External
monitoring will be assigned to a local independent agency/expert. BWDB will report to ADB on
land acquisition and resettlement in its quarterly progress report.
 Appendix 4 31

IMPACT EVALUATION MATRIX SHOWING THE PROJECT IMPACT ON IMPORTANT

ENVIRONMENTAL COMPONENTS

Important Project Phase

Environmental Implementation O&M
Components Sand Mining and Preparation Construction Flood Protection of
Transportation of Geo-bags and of Revetment Protection Infrastructure
Sand Manufacture and Low Solid and Natural
of Concrete Spurs Resources
Blocks
River Erosion 0 -1 -1 +8 +9
Land Use and 0 -1 -3 +6 +6
Settlement
Agricultural Land 0 -1 -2 +6 +6
Agricultural 0 -1 -2 +7 +7
Productivity
Terrestrial Habitat 0 -1 -2 +3 +4
Aquatic Habitat -1 -1 -2 +1 +1
Culture Fisheries 0 0 0 +7 +7
Captive Fisheries -1 -1 -2 -3 -5
Drainage 0 -2 -1 +5 +5
River Morphology 0 0 -1 +4 +4
Hydrology and 0 0 -1 0 -1
Hydraulics
Navigation -1 0 -2 0 -2
Irrigation 0 0 0 +5 +6
Sedimentation -1 -1 -2 +2 +2
Open Water 0 -1 -2 0 0
Areas(River, etc.)
Water Pollution -1 -1 -2 +3 +3
Groundwater 0 0 0 0 +2
Recharge
Drinking Water 0 0 -1 +1 +3
Supply
Education and 0 -1 -1 +2 +3
Health
Employment and +3 +3 +3 +3 +3
Economic
Activities
Poverty +1 +2 +3 +3 +7
Migration from 0 0 0 +4 +7
the area
Status of Women +1 +1 +1 +2 +2
Equity +2 +2 +2 +2 +2
O&M=operation and maintenance.

Note : The Impact has been scored on a 1 to 10 scale. No impact is “0,” negative impacts from –1 to –
10, and positive impacts from +1 to +10.
32 Appendix 5

PROJECT INVESTMENT IN ENVIRONMENTAL AND SOCIAL MEASURES

(2001 prices)

Quantifiable Items Cost

($)
A. Resettlement and Social Development

1. Resettlement and Compensation 2,000.0

2. Social Development 1,150.0

B. Environmental Costs – Civil Works Contract

1. Construction of Camp Requirements (e.g., clean

drinking water, proper waste handling and disposal,
50.0
drainage, training staff)

2. Compensation for Income Loss (crop loss, loss of 100.0

fishermen from captive fishery, etc.)

3. Provision of Health Care, First Aid Facilities, Staff etc. 30.0

4. Rehabilitation and Slope Protection (grass and tree 170.0

plantation)

5. Construction of Ghats and Access Roads 180.0

C. Disaster Preparedness

Awareness Campaigns and Training 104.5

D. Monitoring and Information Management

River Surveys, Remote Sensing Analysis, Modeling, 906.0

Equipment.

E. Project Management Support

Monitoring and Evaluation, Environmental Monitoring 120.0

F. Capacity Development

Training, Environmental Monitoring 50.0

G. Contingencies

Physical Contingencies. 360.0

Total 5,220.5
 Appendix 6 33

ENVIRONMENTAL MANAGEMENT PLAN

1. The Institutional Requirements for mitigation of the adverse effects of the Jamuna-
Meghna River Erosion Mitigation Project (JMREMP) and the associated Environmental
Monitoring Program have been incorporated into an environmental management plan (EMP).
This entails the procedural framework to ensure that all mitigation measures and monitoring
requirements specified in the assessment of environmental impacts will be carried out in the
subsequent project stages.

2. The EMP outlines the environmental management system that will be implemented
during the detailed design and protection works of the Project to minimize deleterious effects
and implement enhancement measures. The EMP also embraces environmental management
issues following the implementation of the riverbank protection measures, to maximize the
beneficial effects of the Project, and detect and ameliorate adverse long-term effects. The EMP
is based on the anticipated environmental impacts and mitigation measures identified in the
environmental impact assessment, and will be further developed and updated when the
contractor’s design are completed, together with the contractors’ subsequent environmental
action plan.

A. Objective of the Environmental Management Plan

3. The objective of the EMP is to provide a framework for the monitoring and management
of the environmental aspects and issues of the Project during detailed design, construction, and
operation and maintenance of the riverbank protection works, during its expected lifetime of 30
years. The basic objectives are to

(i) define a recommended plan of action and a means of testing this plan to meet
existing and projected environmental needs and problems;

(ii) provide an organizational framework that assigns roles and responsibilities to all
parties involved for environmental monitoring and management;

(iii) identify potential environmental impacts;

(v) recommend mitigation measures for the negative impacts;

(vi) identify opportunities for enhancement measures; and

(vii) establish a supervision, monitoring, auditing, and reporting framework.

The EMP will thus ensure implementation of recommended corrective actions aimed for
environment protection, mitigation, and its enhancement.

B. Parties Responsible for EMP Implementation

4. Parties to be involved in environmental management of the Project are

(i) Ministry of Water Resources,

(ii) Ministry of Environment and Forestry,

34 Appendix 6

(iii) Bangladesh Water Development Board (BWDB),

(iv) project management office

(v) joint management committee,

(vi) line agencies (Department of Environment, Department of Agricultural Extension,

Department of Fisheries, Bangladesh Inland Water Transport Authority),

(vii) subproject management offices,

(viii) Construction Division,

(ix) Construction Subdivision,

(x) Monitoring and Evaluation Subdivision,

(xi) external design and project management consultants,

(xii) construction contractors,

(xiii) local governments, and

(xiv) water management associations and other stakeholder organizations.

5. The primary responsibility for environmental management lies with BWDB. However,
the parties involved have important roles and responsibilities for the efficient implementation of
the EMP in order to avoid, minimize, and mitigate adverse impacts and effectuate planned
enhancements. The main roles of the different parties are summarized in Table 2 of the main
text and the overall institutional framework is presented in Appendix 7.

C. Environmental Management and Monitoring during Different Phases of project

Implementation

6. The environmental mitigation measures will be implemented progressively in the various

stages of project implementation (design, construction, and operation and maintenance). The
environmental impacts and mitigation measures are summarized in Appendix 8. The mitigation
measures during design take into considerations environmental requirements to minimize land
acquisition and disturbance to people, infrastructure, facilities, and services. In addition,
provision is planned for means for rehabilitation, compensation, and enhancement into the
design and incorporation of all relevant environmental protection requirements in the tender
documents, risk and hazard assessment, and permit and approval. The contractor will describe
the implementation of the required environmental mitigation measures in an environmental
action plan to be approved by the project management office (PMO)/Department of
Environment (DOE).

7. The construction phase mitigation measures include renting of land for temporary labor
camps and working sites; compensation, resettlement, and rehabilitation to affected people prior
to permanent acquisition of land for construction; site preparation; work area; and labor camp
establishment; drainage; topsoil saving for reuse; waste and spoil management; job
opportunities for local people; occupational health and safety, provision of safe drinking water,
 Appendix 6 35

health care, and emergency facilities and first aid services; monitoring and control of air, water,
and land pollution; survey of sand mining activities and loss and degradation of terrestrial and
aquatic environment; subsequent demolition of facilities not required for further construction;
and restoration of rented land, replacing of top soil, turfing, and planting.

8. The operation and maintenance phase will include monitoring of the general
environment and especially developments in river morphology; implementation of supporting
structures and repairs in the event of an erosion threat to protection work; and liaison with line
agencies to avoid activities endangering riverbank protection structures, such as dredging in the
vicinity of the sites by the Bangladesh Inland Water Transport Authority.

D. Records, Audits, and Corrective Actions

9. The construction contractor and the permanent M&E subdivision of SMO with the
assistance of the supervision consultant will keep all records pertaining to project environmental
management, mitigation measures, corrective actions, and monitoring during the construction
phase. In the operation and maintenance phase, keeping and maintaining the records of the
environmental monitoring and possible measures will be the responsibility of the M&E
subdivision.

10. The monitoring and evaluation (M&E) subdivision of SMO with the assistance of the
supervision consultant will carry out compliance auditing regarding the environmental
performance during the periods of construction. Besides, the PMO and funding agencies will
audit works carried out by the M&E subdivision and the supervision consultant. Quarterly and
annual audit reports will be prepared by the M&E subdivision to be forwarded to the PMO for its
consideration. DOE and the joint management committee will annually review the audit reports,
and if required carry out site visits and provide recommendations for remediation activities. The
PMO will prepare an integrated audit report on completion of each year’s construction work
during project implementation.

11. BWDB will prepare an environmental audit report every year during the 6 years of
project implementation. These project performance audit reports will include an assessment of
the performance of the Project with respect to expected environmental impacts, including effects
on the river morphology. In addition, the report will describe to what degree the Project satisfies
the environmental requirements, the efficiency of mitigation and enhancement measures, and if
any unforeseen effects have occurred, and how these were addressed and mitigated.

E. Complaints and Grievances

12. Complaints and grievances from the public will be directed to the parties responsible for
environmental management through the water management associations and stakeholder
organizations to the construction subdivision or operation and maintenance subdivisions at each
site. All complaints will be properly recorded and reported to the SMO for immediate
consideration. Complaints on minor issues that need immediate attention will be handled by the
SMO. Complaints on major issues will be reported to the PMO for its immediate consideration
and direction. All complaints will be reported in the quarterly and annual audit reports forwarded
to the PMO.
 OVERALL INSTITUTIONAL FRAMEWORK FOR IMPLEMENTATION OF THE PROJECT AND
ENVIRONMENT MANAGEMENT PLAN

Organization Chart of the Project

Ministry of Water Resources Governing Council of BWDB

DG, BWDB

Additional DG, O&M, BWDB

Zonal Consultants Project Management Office Joint Management Committee

CE NGOs Project Director: Director/ Additional CE Representatives of line agencies, local governments,
Chief Resettlement and Environmental Officer WMAs, etc.

Subproject Management Office

Subproject Director: SE of concerned circle

WMAs and Other

Construction Division O&M Division Stakeholder
Institutions

Construction subdivision M&E subdivision O&M Sub-divisions

Resettlement and Environmental management
social development officer officer

CE=chief engineer, M&E=monitoring and evaluation, NGO=nongovernment organization, WMA=water management association
 Appendix 8 37

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

Possible Impact Mitigation during Design Mitigation during Mitigation during

Construction Maintenance
Air pollution - - Spray water regularly on -
dry surfaces creating dust
problems
- Regulate vehicle emission
Noise pollution - - Regulate use of horns -
- Avoid unnecessary noise,
especially at night
Destruction of land - Minimize need for land for - Remove and store topsoil -
and vegetation construction for replacing after
construction
- Afforestation and grass
planting of work place
after works
Morphological - Careful alignment of river - Monitoring of function of - Monitoring of
changes bank protection works constructed riverbank morphological changes
protection works and - Construction of
impact on river hydraulics supporting structures
- Compensation if
significant changes occur
Dredging spoils - - If clay and silt in outflow -
water exceeds water
quality standards, change
site for dredging for sand
Deterioration of - - Prevent discharge of -
water quality wastewater from labor
camps
- Prevent spills of oil and
lubricants from vehicles,
engines, etc.
Disturbance to - - Establish adequate -
water supply alternative water supply
Disturbance of - - Avoid sand mining close -
wildlife to sand bars
- Minimize noise
Disruption of - Minimize need for use of - Reinstate land after -
agricultural agricultural land during construction
activities construction - Provide adequate land
- Minimize need to disrupt rent and compensation
irrigation - Restore irrigation facilities
immediately if affected
- Provide compensation
Disruption of - - Avoid disruption of -
irrigation irrigation channels
- Provide compensation
Disruption of - Provide adequate river - Maintain close liaison with - Maintain close liaison with
navigation ports and ghats BIWTA BIWTA concerning their
- Provide buoys and dredging operations
navigational lights
- Avoid sand dredging in
navigational routes
Disruption of road - Minimize need for - Maintain access to ghats -
traffic affecting existing roads - Practice caution in use of
vehicles
Disruption to char - - Avoid sand mining close -
dwellers to inhabited chars
Transmission of - - Provide health inspection -
diseases among and vaccination
 38 Appendix 8

Possible Impact Mitigation during Design Mitigation during Mitigation during

Construction Maintenance
workers - Organize proper
collection of wastes
- Provide adequate sanitary
facilities to personnel and
workers
Safety of workers - - Adopt appropriate safety -
measures
- Provide first aid services
- Make workers aware of
risks and how to avoid
these
BIWTA=Bangladesh Inland Water Transport Authority