NORTH SOUTH
UNIVERSITY
DEPARTMENT OF CIVIL
AND ENVIRONMENTAL
ENGINEERING
CEE 373:
ENVIRONMENTAL
IMPACT ASSESSMENT
HAOR FLOOD MANAGEMENT AND GROUP C
LIVELIHOOD IMPROVEMENT PROJECT: EIA
REPORT REVIEW
1 Page
DISTRIBUTION OF PROJECT WORKS
Team mates ID Contribution to the review report
Rakibul Hossain Khan 161 1338 025 Gaps in Mitigation Measures
Mahbub Karim 161 0943 025 Project Description
Fatima Farhana 132 1662 025 1. List of Stakeholders
2. Role of Stakeholders
S. S. Al Mamun 161 0833 025 Gaps in EMP
Mahmood Rafi 161 1015 025 Improvements in EMP
Md. Mahidy Hossain 161 590 025 Improvements in Mitigation measures
Romana Yasmeen 161 0843 025 1. Gaps in impact identification and
significance level determination and
recommending improvements
2. Report editing, compiling, formatting
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TABLE OF CONTENTS
1. INTRODUCTION ....................................................................................................................... 4
2. METHODOLOGY ....................................................................................................................... 6
3. STAKEHOLDERS ........................................................................................................................ 7
3.1 STAKEHOLDERS LIST .............................................................................................................. 7
3.2 ROLE OF STAKEHOLDERS IN THE PROJECT............................................................................ 7
4. GAPS IN THE EIA REPORT......................................................................................................... 8
4.1 Demand for utilities: ............................................................................................................. 8
4.2 Impact identification method: .............................................................................................. 8
4.3 Determining impact significance level: ................................................................................. 9
4.4 Public involvement: .............................................................................................................. 9
4.5 Residual and Cumulative impact: ......................................................................................... 9
4.6 Decommissioning: ................................................................................................................. 9
4.7 Alternatives: .......................................................................................................................... 9
4.8 Impact monitoring plan ...................................................................................................... 10
4.9 Likelihood analysis .............................................................................................................. 10
5. POSSIBLE IMPROVEMENTS .................................................................................................... 10
5.1 Improvements in Impact identification .............................................................................. 10
5.2 improvements in Public Involvement ................................................................................. 10
5.3 Improvements in EIA Team Composition ........................................................................... 10
5.4 Improvements in Mitigation Measures and Monitoring .................................................... 11
5.5 Improvements in Environmental Management Plan (EMP) ............................................... 11
6. CONCLUSION ......................................................................................................................... 11
7. RECOMMENDATIONS ............................................................................................................ 12
8. REFERENCES .............................................................................................................................. 12
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1. INTRODUCTION
The “Haor Flood Management & Livelihood Improvement Project” aims at improving the living
conditions of the people living adjacent to 29 Haors by reducing or eliminating damages caused
by early or pre-monsoon flash flood and by implementing other synergic interventions in
agriculture and related sectors.
The ‘Haor Flood Management and Livelihood Improvement project’ consists of 15 Haor
rehabilitation subprojects and 14 new Haor subprojects in 5 districts located in the North-eastern
region of Bangladesh namely, Kishorgonj, Netrokona, Sunamgonj, Hobigonj and Brahmanbaria
with small part of Mymensingh.
There are about 373 Haor/ Wetlands covering an area of about 8,58,460 ha which is around 43%
of the total area of the Haor region. It is a mosaic of Wetland habitats' including rivers, Stream,
canals, large area of seasonally flooded cultivated plants, and beels. The project comprises a total
gross area of 1,99,487 ha and net cultivable area of 1,62,630 ha.
The major project infrastructure components for the HFMLIP include the followings:
I. Re-excavation of canal/ Khal;
II. Construction and rehabilitation of regulator
III. Re-sectioning and rehabilitation of full embankment
IV. Construction and re-sectioning/rehabilitation of submergible embankment
V. Provision for pipe inlet and causeway
VI. Protection works by CC blocks for sluice;
VII. Protection works by grass turfing on the embankment slopes
Total budget for overall project implementation is said to be BDT 99337.72 million and the budget
for civil construction as per physical intervention is BDT 4830.926 million. Total Estimated EMP
budget for the project implementation is BDT 59615600 as per the report. A map indicating the
location of 29 Haors is given below:
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Figure 1: Location map
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2. METHODOLOGY
The review task was initiated by finding out the description of the project, including the study
area, for which this EIA report was prepared. Along with this we looked for the project
components and the map. Afterwards, we prepared the lists of stakeholders, level and form
of consultations described in the report. We also checked the project ToR and matched with
our lecture notes. We looked for main gaps of the report and then went through the
identified impacts and their significance level, along with the Environment Management plan
that was proposed. Considering the tasks listed above, all the limitations of the report that
we found out was compiled together and hence we listed some improvements. All the steps
are shown in the flow chart below:
STEP 1: IDENTIFYING
Identifying project
Identifying project area Selecting the map
components
STEP 2: CHECKING AND IDENTIFYING
Making the list of
Checking the project ToR Identifying the gaps
stakeholders
STEP 3: CHECKING AND EVALUATING
Evaluating identified
Evaluating the mitigation
impacts and their Evaluating proposed EMP
measures
significance
STEP 4: SUMMING
overall evaluation of the
Compiling the limitations Improvements
report
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Figure 2: Methodology flow chart
3. STAKEHOLDERS
3.1 STAKEHOLDERS LIST
Stakeholders and their stakes were identified during field survey. All the stakeholders had
different types of stakes according to their professions and livelihood characteristics. The list of
stakeholder is given below:
1. Villagers/ local residents
2. Government officials
3. Fishermen
4. Farmers
5. Businessmen
6. Shop keepers
7. Public representatives and
8. NGOs
3.2 ROLE OF STAKEHOLDERS IN THE PROJECT
The purpose of the stakeholder consultation is to identify the views of major institutional and
project affected persons and stakeholders in the project area, and to identify issues that are
relevant to EIA, as well as any impacts which the project may have on project planned by the
stakeholders, and to assess any mitigation measures which may be undertaken to minimize any
adverse impacts of the proposed project. Stakeholders are one of the important part of EIA to
address the environmental aspects as well as socio-economic issues from stakeholders’ point of
view.
In the report, the government officials and the NGOs were informed with the project’s objectives,
types and components of the project in a simplified manner. They were asked about the concerns
about significant negative impacts on different components of the environment, flood
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experiences, presence of wildlife, environmentally sensitive issues, and finally their overall
expectation regarding HFMLIP. The Information disclosure meetings in different zones were
called and the representatives of all the stakeholders, along with some general people were
informed and their opinion was recorded. The stakeholders arose some issues regarding drainage
congestion, siltation, and drying-up of Khals during summer etc. and most importantly, they
informed about biodiversity and their availability, average depth of water, source of water during
droughts etc. in short, the stakeholders play the role of local informer, caretaker, the receiver of
both detriments and benefits of the project simultaneously.
4. GAPS IN THE EIA REPORT
A detail evaluation of the EIA report has been conducted to find out the main gaps of the report.
According to our evaluation, the report followed the ToR (Terms of Reference) approved by
Department of Environment (DoE) and also the methods and principles that should be followed
in an EIA, except for the cases described below:
4.1 Demand for utilities:
In the resources and utilities requirement part, the report had mentioned only about the
resources that would be used in the civil works. There were no description of the requirement
for the utilities such as water supply, electricity, sewerage and waste disposal.
4.2 Impact identification method:
In identifying the potential impacts, only professional judgment and relevant case studies was
done. So, the impact analyses was fully qualitative whereas, quantitative approach were
preferable. Also, the outcome of the analyses was not presented with the scenarios, maps or
graphics which was mentioned in the DoE approved ToR.
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4.3 Determining impact significance level:
The impact significant level was shown only by mentioning the qualitative magnitude, such as,
‘Severe, Moderate, Low’. No quantitative approach was taken classify the impacts in a precise
manner. For example, if 10 impacts are severe, then how they are comparable to each other.
Also, there was almost no explanation how the severity level was measured.
4.4 Public involvement:
As mentioned before the project area includes 5 districts where the stakeholder consultation
meetings should have been done for public involvement. But no such meeting was called in
Brahmanbaria. Furthermore, the percentage of participation of females in the ‘information
disclosure meetings’ was very less compared male participants in the focus group discussions.
Overall, it can be said that, there are lacking in public involvement part.
4.5 Residual and Cumulative impact:
The report did not mention whether there are any residual impacts or not. Moreover, in the
report, it was mentioned that due to some subprojects activities, the ecosystems might have
cumulative impacts. But, there were no further discussion regarding the cumulative impacts
identification or any mitigation measure for this.
4.6 Decommissioning:
An EIA report should mention the decommissioning part clearly. Nevertheless, no
decommissioning plan was specified in this report.
4.7 Alternatives:
An EIA report should consider the alternatives, firstly to consider the ‘no project’ impacts and
afterwards, for all the positive and negative impacts to enhance and mitigate respectively. But,
EIA report did not looked for any alternatives and did not even compared the situation with ‘no
project’ alternative.
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4.8 Impact monitoring plan
The biophysical and socio-economic parameters within the project area, must be measured
during the construction period and operation period of the project to determine the
environmental changes. In the report, there were no such plan for impact monitoring.
4.9 Likelihood analysis
A statistical analysis should be done to know to confidence level prediction for identified impacts,
along with the uncertainty study. The EIA report do not contain such analyses.
5. POSSIBLE IMPROVEMENTS
5.1 Improvements in Impact identification
In identifying the impacts, a quantitative approach can be followed. This will be possible if
computer modelling or experiments or physical model can be developed to foresee the impacts.
For example, a hydrological model could be beneficial to see the changes in the flow regimes of
the water-bodies. These will not only allow to have a quantitative approach of identifying impacts
but also allow to make scenarios, maps and graphics to demonstrate the impacts as mentioned
in the approved ToR. Adding to this, quantitative approach of identifying impacts will help to
create a quantitative scaling of impact significance level.
5.2 improvements in Public Involvement
To improve the public involvement part, an ‘information disclosure meeting’ can be called in
Brahmanbaria as it is not done before. Also, several short focus group discussion can be arranged
where the female participants will be more encouraged to join as they are also involved with crop
production works.
5.3 Improvements in EIA Team Composition
Consultation with a geologist can be done since, there were no geologist in the EIA team experts.
Then, more precise lithological information can be gathered. Also, information about fault zones,
history of earthquakes and the composition of soil and aquifer, chances of contaminant flow in
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aquifer, etc. can be added to the report. And a better mitigation plan can be developed as well.
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5.4 Improvements in Mitigation Measures and Monitoring
The mitigation measures given, in some cases, these are just telling about the awareness or law
enforcement. For example, for workers’ safety, ‘adequate lighting’ was mentioned as the
mitigation action which is more alike to increase awareness. Here, inclusion of ‘workers’ safety’
clause in construction contract may be better mitigation plan for health and safety issues.
Examining the alternatives may also help in mitigating the negative impacts and as well as
enhancing the positive ones. An impact monitoring plan during the construction period and
operation period of the project to determine the environmental changes can be added as well.
5.5 Improvements in Environmental Management Plan (EMP)
As the residual impacts, cumulative impacts and the decommissioning were unobserved in the
report, so this is an obvious indication that the Environmental Management Plan (EMP) is
deficient. Evaluating the residual impacts significance will strengthen the EMP and also
determining the impact significance level in a precise and scientific manner will do the same as
well. Moreover, a likelihood analyses for impact prediction to observe the uncertainty can be
added. This likelihood analyses will give an interpretation of unforeseen impacts. Therefore, a
precise and better EMP can be developed by including a technical and precise determination of
impact significance level, the mitigation measures for residual (if any) impacts, cumulative
impacts, planning for decommissioning and unanticipated impacts.
6. CONCLUSION
The HFMLIP aims at the improvement of the performance of 15 existing haor projects and 14
new haor to enhance and sustain the livelihoods of rural people through water management
infrastructure and support services for agriculture, fishery development and gender & livelihood
enhancement support activities.
The proposed project will have overall positive benefits by preserving and improving the pre-
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monsoon flash flood protection of boro crops, benefits provided by the existing facilities, and
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installment of additional small structures to address internal water management problems that
have not been addressed in case of haors implemented earlier.
The EIA report successfully observed the project area and project components. Also, the report
was structured properly. Moreover, the report identified both positive and negetive impacts
from which some positive impacts were enhanced and appreciable mitigation measures was
specified for the negative impacts. Nevertheless, some gaps of the EIA report has been observed
and mentioned briefly.
7. RECOMMENDATIONS
The area of public involvement requires more stakeholder consultation with the missed
district people and also a short focus group discussion with females.
More improvements needed in the impact identification and significance part. Through
improving the impact analyses part the mitigation measures, along with EMP will be
improved automatically.
Examining the alternatives and planning for decommissioning and a probabilistic analyses
of the impacts will deliver a more robust EMP for the report, hence will enhance the
quality of the EIA.
8. REFERENCES
(2016). Environmental Impact Assessment of 'Haor Flood Management and Improvement
Project'. Bangladesh Water Development Board (BWDB). DevConsultants ltd.
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