BBIN REGIONAL TRANSPORT AND

TRADE FACILITATION PROGRAM – BANGLADESH

PHASE 1

AS PART OF A MULTIPHASE PROGRAMMATIC

APPROACH (MPA)

Environmental and Social Management Framework (ESMF)

January 2022
 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Table of Contents
Abbreviations vii
Executive Summary xii
1. Introduction 1
1.1 Background 1
1.1.1 BBIN MPA Program in Bangladesh (Phase 1) 1
1.1 Purpose of the ESMF 2
1.2 Rationale of the ESMF 3
1.3 Scope of the ESMF 3
1.4 Approach and Methodology 4
2. Project Description 6
2.1 Project Development Objectives (PDO) 6
2.2 Description of BBIN MPA Program Phase 1 in Bangladesh 6
3. Policy, Legal and Regulatory Framework 15
3.1 General 15
3.1 Review of Relevant National Environmental Law, Policy and Regulatory Framework 15
3.1.1 Relevant National Policies 15
3.1.2 Relevant National Environmental and Social Legislations 21
3.2 Applicable International Treaties Signed by the GoB 28
3.3 World Bank’s Environmental and Social Framework (ESF) 29
3.4 Classification of the Project According to the Environment Conservation Rules (ECR) and
Requirement for Environmental Clearance Certificate (ECC) 36
3.5 Gap Analysis of World Bank Requirements and National Laws 36
3.6 Guidance Related to COVID-19 38
4. Environmental and Social Baseline 39
4.1 Baseline Environmental Status Description 39
4.1.1 Physical Environment 39
4.1.1.1 Climate and Meteorology 39
4.1.1.2 Topography 39
4.1.1.3 Hydrology 40
4.1.1.4 Wind Hazard/Cyclone & Seismicity 40
4.1.1.4.1 Solid Waste Management 41
4.1.2 Biological Environment 41
4.1.3 Socio-Economic Environment 42
4.1.3.1 Demography 42
4.1.3.2 Literacy 42

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 4.1.3.3 Employment Status 42
4.1.3.4 Religion 42
4.1.3.5 Vulnerable Groups 42
4.1.3.6 In Migration Issues 43
5. Potential Key Environmental and Social Impacts 44
5.1 Risk Assessment of the Project 44
5.2 Relevant E&S Risks and Impacts 45
5.3 Anticipated Potential Environmental and Social Impacts 45
5.3.1 Pre-Construction Phase/Project Siting 45
5.1.1.1 Site Specific Land Cover and Land Use Changes 45
5.1.1.2 Loss of Trees 46
5.1.1.3 Loss of Habitat 46
5.1.1.4 Drainage congestion and water logging 46
5.1.1.5 Impacts on Vulnerable and disadvantage groups/communities/ individuals 46
5.1.2 Construction Phase 46
5.1.2.1 Air Pollution 46
5.1.2.2 Noise and Vibration Pollution 46
5.1.2.3 Water Pollution 46
5.1.2.3.1 Surface Water 46
5.1.2.3.2 Groundwater 47
5.1.2.4 Impacts of Land Filling (at construction site) 47
5.1.2.5 Soil Contamination 47
5.1.2.6 Drainage congestion and water logging 47
5.1.2.7 Generation of Solid Waste and Hazardous Waste 47
5.1.2.8 Occupational Health and Safety 47
5.1.2.9 Impact on labor, working Conditions and labor risks, including risks of child labor and
forced labor, human trafficking 48
5.1.2.10 Involuntary Resettlement Impacts 48
5.1.2.11 Impact on Cultural Heritage 48
5.1.2.12 Impact of Labor Union 48
5.1.2.13 Security Management Issues 49
5.1.3 Post Construction/Operation Phase 49
5.1.3.1 Loss of Vegetation and Wildlife Biodiversity 49
5.1.3.2 Generation of Solid Waste and Hazardous Waste 49
5.1.3.3 Noise Generation 49
5.1.3.4 Water Pollution and Drainage 49
5.1.3.5 Impacts on local livelihoods 49

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 5.1.3.6 Increased risk of road accidents 50
5.1.3.7 Impact of Labor Union 50
5.1.3.8 Sexual Exploitation and Abuse, and Sexual Harassment (SEA/ SH) 50
5.1.3.9 Security Management Issues 50
5.4 Mitigation Measures to Address Environmental and Social Impacts 58
6. ENVIRONMENTAL AND SOCIAL MANAGEMENT PROCEDURES 72
6.1 General 72
6.2 ES Management Principle 72
6.3 Environmental and Social Assessment and Management Process 73
6.4 Environmental and Social Management Procedure 73
6.4.1 Overall Procedure 73
6.4.2 Project Screening 74
6.4.3 Environmental and Social Impact Assessment 74
6.4.4 Environmental and Social Management Plan (ESMP) 81
6.4.4.1 Scope and Objectives of ESMP 81
6.4.4.2 Inclusion of Relevant Components of ESMP in Contract Documents 81
6.4.4.3 Payment Milestones 81
6.4.4.4 Guideline to Incorporate Environmental and Social Management in Bid Documents 82
6.4.4.5 Environmental and Social Codes of Practice (ESCoPs) 83
6.4.5 Required Site Specific Management Plans (ESS 1-10) 83
6.4.6 Consultation and Participation Plan (ESS10) 85
6.4.7 Labor Management Procedures (ESS2) 85
6.4.8 COVID-19 Health and Safety of the Workforce 85
6.4.9 Implementation of the Solid and Hazardous Waste Management and Disposal 85
6.4.10 Gender, women, children, person with disability/excluded groups’ needs 86
6.4.11 Occupational Health and Safety (OHS) 87
6.4.12 Guideline for preparation of Environmental and Social Monitoring Plan 87
6.4.13 Monitoring Program 91
6.4.13.1 Compliance Monitoring 91
6.4.13.2 Effects Monitoring During Project Implementation 91
6.4.13.3 Third Party Monitoring 94
6.4.13.4 Performance Indicators 94
6.4.13.5 ESMP Implementation Cost 94
7. Stakeholder Engagement, Grievance Mechanism and Disclosure 96
7.1 Stakeholder Engagement, GRM and Information Disclosure 96
7.2 Objectives of the Consultations 96
7.3 Methodology and Tools of the Consultation 97

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 7.4 Outcomes of consultation meetings 98
7.5 Consultations and Communication Framework 102
7.5.1 Community Engagement and Stakeholders Participation (ESS10) 103
7.5.2 Gender Analysis Procedures and Guidelines (ESS 1, 2, 4, 5, 7) 103
7.6 Grievance Redress Mechanism 103
7.6.1 Overview and Scope 103
7.6.2 Objectives of Grievance Redress Mechanism 104
7.6.3 Grievance Redress Mechanism 104
7.6.3.1 GRM for Dealing with Labour Issues 105
7.6.3.2 GRM for Dealing SEA/SH Related Issues 106
7.6.4 World Bank Grievance Redress Service (GRS) 107
7.7 Information Disclosure 107
7.8 Access to Information 109
8. Institutional Arrangement 111
8.1 Bangladesh Land Port Authority (BLPA) 111
8.1.1 Institutional Setting and Implementation Arrangement 112
8.1.2 Consultant Support 113
8.1.3 Contractors 113
8.1.4 Roles and Responsibilities 114
8.2 Ministry of Commerce (MoC) 115
8.3 National Board of Revenue (NBR) 116
8.4 Project Implementing Units 116
8.5 Capacity Assessment of IAs 117
8.5.1 Ministry of Commerce (MoC) 117
8.5.2 National Board of Revenue (NBR) 118
8.5.3 Bangladesh Land Port Authority (BLPA) 118
8.6 Action Plan to Strengthen Staffing, Capacity, Systems and Implementation 119
8.7 Conclusion 122
Annexes 123

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List of Figures
Figure 1.1: Location Map of BBIN Regional Transport and Facilitation MPA Program ............................. 2
Figure 1.2: Approach of ESMF Preparation ............................................................................................... 5
Figure 2.1: Project Location Map .............................................................................................................. 7
Figure 2.2: Benapole Land Port, Jashore ............................................................................................ 8
Figure 2.3: Bhomra Land Port, Satkhira .................................................................................................... 8
Figure 2.4: Burimari Land Port, Lalmonirhat ............................................................................................. 9
Figure 2.5: Proposed Master Plan, Chattogram Customs House ................................................... 10
Figure 2.6: Location of Different Customs House under BBIN RTTF Phase 01....................................... 11
Figure 2.7: Proposed Master Plan, Customs and Value Added Tax (VAT) Training ................................ 11
Figure 2.8: Proposed Master Plan, Customs and Value Added Tax (VAT) Training ................................ 12
Figure 2.9: Proposed Sylhet-Charkhai-Sheila-Sutarkandi Road ..................................................... 14
Figure 4.1: Topographical Status of the Project Area ............................................................................. 40
Figure 4.2: Hydrological Status of the Project Areas ............................................................................... 40
Figure 4.3: Drainage Status of the Project Areas .................................................................................... 40
Figure 4.4: Floral Status of the Project Areas .......................................................................................... 42
Figure 6.1: Overall Procedure of Environmental & Social Management ................................................ 74
Figure 6.3: Quantification of Environmental Impact............................................................................... 79
Figure 6.4: Typical Relative Importance Values of Environmental Parameters Related to Infrastructure
Projects .................................................................................................................................................... 79
Figure 7.1: Grievance Resolution Process ............................................................................................. 105
Figure 8.1: PIU Environmental and Social Cell ...................................................................................... 112
Figure 8.2: Proposed Institutional Framework of MoC-WTO Cell for Implementation of the ESMF.... 115
Figure 8.3: Proposed Institutional Framework of NBR-MoF for implementation of the ESMF ............ 116

List of Tables
Table 3.1: Summary of Relevant Environmental and Social Policies of the GoB .................................... 15
Table 3.2: Summary of Applicable Environmental Laws and Regulations of GoB .................................. 21
Table 3.3: International Conventions, Treaties, and Protocols Signed by Bangladesh ........................... 28
Table 3.4: WB ESS Requirements and Relevance to the Project............................................................. 30
Table 3.5: Gaps Minimization between GoB laws and WB’s ESSs .......................................................... 37
Table 5.1: Summary of Potential Environmental and Social Impacts and their Significance (ESS Risk) . 51
Table 5.2: Categorization of BBIN-MPA Program Activities (Phase 1 Bangladesh) Based on Key
Predicted Impacts and ESS Requirements .............................................................................................. 53
Table 6.1: Format of Monitoring Plan-During Project Implementation Period (Sample) ....................... 88
Table 6.2: Effects Monitoring Plan .......................................................................................................... 91
Table 7.1: Summary of Consultation Meetings and FGDs ....................................................................... 97
Table 7.2: Summary of Stakeholder Consultation Meeting (NBR) .......................................................... 98
Table 7.3: Summary of Stakeholder Consultation Meeting (BLPA)....................................................... 100
Table 7.4: Future Consultation Framework .......................................................................................... 102
Table 7.5: Disclosure Requirements ...................................................................................................... 108
Table 8.1: BLPA Functions for RPF Compliance ..................................................................................... 112
Table 8.2: Roles and Responsibilities for ESMP Implementation.......................................................... 114

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List of Annexes
Annex A: Sample Checklist for Environmental and Social Screening of Sub-Projects........................... 123
Annex B: Details of Public Consultation Meeting and Focus Group Discussions .................................. 129
Annex C: List of Attendees .................................................................................................................. 163
Annex D: Details of the Environmental and Social Code of Practices (ESCoPs) .................................... 172
Annex E: Terms of Reference (ToR) of the ESIA Study .......................................................................... 192
Annex F: Outline of ESIA Reports .......................................................................................................... 197
Annex G: Outline of Labor Management Procedures ........................................................................... 199
Annex H: Outline of Resettlement Policy Framework........................................................................... 201
Annex I: Outline of Resettlement Action Plan....................................................................................... 205
Annex J: Example Outline of Environmental and Social Commitment Plan (ESCP) .............................. 208

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 ABBREVIATIONS
A.M.S.L Above Mean Sea Level
ABMS Automated Border Management System
ADB Asian Development Bank
AIDB Asian Infrastructure Development Bank
ARAP Abbreviated Resettlement Action Plan
ARIPA Acquisition and Requisition of Immovable Property Act
BBIN Bangladesh, Bhutan, India and Nepal
BBIN Program - Bangladesh Phase 1 BBIN Regional Transport and Trade Facilitation Program -
Bangladesh Phase 1
BDT Bangladeshi Taka
BLPA Bangladesh Land Port Authority
BMP’s Best Management Practices
BP Bank Policy
BP Bank Procedures
BRCP Bangladesh Regional Connectivity Project
BTP Bangladesh Trade Portal
BWDB Bangladesh Water Development Board
CBO Community Based Organization
CC Climate Change
COVID-19 Coronavirus Disease of 2019
CPR Common Property Resources
CSO Civil Society Organizations
DAE Department of Agriculture Extension
DoE Department of Environment
DoF Department of Forestry
EA Environmental Assessment
ECA Ecological Critical Area
ECA Environmental Conservation Act
ECC Environmental Clearance Certificate
ECR Environment Conservation Rules
EHS Environmental, Health and Safety
EIA Environmental Impact Assessment
EMF Environmental Management Framework
EMIS Environmental Management Information System
EMP Environmental Management Plan

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EMU Environmental Management Unit
ERP Emergency Response Plan
ES Environmental Screening
ESA Environmental and Social Assessment
ESCoP’s Environmental and Social Code of Practices
ESCP Environmental Social Commitment Plan
ESF Environmental and Social Framework
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESMP Environmental and Social Management Plan
ESMU Environment and Social Management Unit
ESR Environmental Screening Report
ESS Environmental and Social Standards
EU European Union
FAA Flood affected area
FAO Food and Agriculture Organization
FGAP Framework for Gender Action Plan
FGD Focus Group Discussion
FPIC Free, Prior and Informed Consent
GAP Gender Action Plan
GBV Gender Based Violence
GDP Gross Domestic Product
GoB Government of Bangladesh
GPN Good Practice Note
GRC Grievance Redress Committee
GRM Grievance Redress Mechanism
ha Hectare
HH House Hold
HIES Household Income and Expenditure Survey
HORMP Human and Occupational Resource Management Procedure
IA Information Access
ICP Integrated Check Post
ID Identity
IDA International Development Association
IEE Initial Environmental Examination
IFC International Finance Corporation

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ILO International Labor Organization
IoL Inventory of Loss
IP Indigenous People
IPDP Indigenous Peoples Development Plan
IPP Indigenous Peoples’ Plan
IPPF Indigenous Peoples Planning Framework
IWM Integrated Water Management
LAO Land Acquisition Officer
LAP Land Acquisition Plan
LGED Local Government and Engineering Division
LGED Local Government Engineering Department
LGI Local Government Institution
LMP Labour Management Procedures
LMS Land Market Survey
LRSP Livelihood Restoration Support Plan
M Motorized
M&E Monitoring and Evaluation
MCS Monitoring, Control and Surveillance
MEF Ministry of Economy and Finance
MIS Management Information System
MLGRD&C Ministry of Local Government, Rural Development and Co-
operatives
MoC Ministry of Commerce
MoEFCC Ministry of Environment, Forest and Climate Change
MoF Ministry of Finance
MoFA Ministry of Foreign Affairs
MoLE Ministry of Labor and Employment
MoLGRDC Ministry of Local Government, Rural Development and Co-
operatives
MoRTB Ministry of Road Transport and Bridges
MoU Memorandum of Understanding
MPA Multi-Phased Approach
MT Metric Tonne
NGOs Non-Government Organizations
NOC No Objection Certificate
NRS National Resettlement Specialist
NTFC National Trade Facilitation Committee

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O&M Operation and maintenance
OHS Occupational Health and Safety
OHSM Occupational health and safety management
OP Operational Policy
PA Protected Area
PAD Project Appraisal Document
PAH Project Affected Households
PAP’s Project Affected Persons
PCU Program Coordination Unit
PIB Public Information Brochure
PIU Project Implementation Unit
PMO Project Management Office
PMU Project Management Unit
PPE Personnel Protective Equipment
PPR Project Progress Report
PRA Participatory Rural Appraisal
PSC Project Steering committee
PVAC Property Valuation Advisory Committee
R&D Research and Development
RAC Resettlement Advisory Committee
RAP Resettlement Action Plan
RCS Replacement Cost Study
RHD Roads and Highways Department
ROW Right of Way
RPF Resettlement Policy Framework
RTIP Rural Transport Improvement Project
RTTF Regional Trade and Transport Facilitation
SA Social Assessment
SAE Sub Assistant Engineer
SASEC South Asia Subregional Economic Cooperation
SDE Sub Divisional Engineer
SEA Strategic Environmental Assessment
SEC Small Ethnic Community
SECC Social, Environmental and Communication Cell
SECDP Small Ethnic Community Development Plan
SECI Social and Environmental Circle
SEMVPP Small and Ethnic Minorities, Vulnerable Peoples Plan

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SEP Stakeholders Engagement Plan
SIA Social Impact Assessment
SIMP Social Impact Management Plan
SMF Social Management Framework
SMP Social Management Plan
SOP Standard Operating Procedure
TBD To Be Determined
TDP Tribal People Development Plan
TFA Trade Facilitation Agreement
TIG Technical Implementation Group
ToC Table of Contents
ToR Terms of Reference
TPP Tribal People Planning
UNCED United Nations Conference on Environment and Development
UPCC Upazila Project Coordination Committee
USD United States Dollar
VAT Value-added Tax
WB World Bank
WBG World Bank Group

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 EXECUTIVE SUMMARY
The proposed World Bank-financed BBIN Regional Transport and Trade Facilitation Program will seek to
address the main drivers of high cost of trade and transport in the sub-region, namely low levels of
technology adoption in trade facilitation, inadequate transport and logistics infrastructure, and
regulatory and procedural impediments to the cross-border movement of freight.
The Program Development Objective is to develop efficient and resilient regional trade and transport in
the BBIN countries. The program is anchored around the following three pillars that will be common
across all projects in all countries – Bangladesh, Bhutan, India and Nepal (BBIN) - under the Program.
i. Adoption and implementation of digital and automated systems to facilitate trade;
ii. Upgrading of regional transport infrastructure, last mile and hinterland connectivity, and
modernization of priority trade gateways (land ports and customs houses); and
iii. Technical assistance and capacity building to enable reforms required for the adoption of
contemporary trade facilitation environment in the sub-region.
The Program will utilize the Multiphase Programmatic Approach (MPA), which allows a complex
engagement such as regional connectivity to be structured as a series of linked operations or phases.
The ESMF covers the ‘BBIN Regional Transport and Trade Facilitation Program – Bangladesh Phase 1
(BBIN - Bangladesh Phase 1)’ which will provide an estimated US$750million in IDA funding for
Bangladesh. The proposed Project Development Objective is “to augment trade-enabling infrastructure,
technology, and processes to improve the conditions for regional transport and trade in Bangladesh”.
The BBIN - Bangladesh Phase 1 will have four (04) components to be implemented by the following
ministries and agencies: (1) Bangladesh Land Port Authority (BLPA), (2) National Board of Revenue
(NBR), (3) Ministry of Commerce (MoC) – WTO cell, and (4) Roads and Highways Department (RHD).
Location map of the major interventions are presented in the following figure:

Project Components
Component 1: Land Port Development and Border Management Improvement
Implementing Agency: Bangladesh Land Port Authority (BLPA)

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Sub-component 1a: Resilient and green land port development at Benapole, Bhomra, and Burimari
This sub-component will finance the upgrading of infrastructure, systems, and processes at Benapole,
Bhomra, and Burimari land ports, which are critical for trade with India, as well as with Bhutan and
Nepal. Infrastructure modernization will be premised on digitalization, contact-free and paper-free
processing. The investment in infrastructure will follow a comprehensive re-engineering of processes
and systems and will be designed specifically to support the adoption of modern border management
in order to reconcile the objectives of effective control and trade facilitation. The project will adopt a
Coordinated Border Management (CBM) approach to enhance border agency collaboration and
coordination (including with India), contributing to improved border management. The infrastructure
will be developed as green and sustainable infrastructure with a focus on energy efficiency, waste and
pollution reduction, water preservation, renewable energy, and climate resilience.
Benapole-Petrapole is the largest land border crossing in South Asia in terms of freight traffic and value
of goods. The land port is located at Benapole, Sharsha, Jashore District in the southwest region of
Bangladesh and handles about 80 percent of Bangladesh’s total trade with India through land routes.
The modernization of Benapole land port would reduce congestion and enhance capacity of truck flows
from India’s Petrapole Integrated Check Post (ICP). The feasibility study and detail design report for
Benapole are in an early stage of development, and the exact project interventions at Benapole are not
yet determined. The ESIA of the Benapole port will be prepared and disclosed as soon as the feasibility
study and detail design report advance. The timing of the ESIA will be clearly mentioned in the
Environmental and Social Commitment Plan (ESCP) of the Borrower.
Bhomra-Ghojadanga is the second largest land border crossing between Bangladesh and India. The land
port is situated in the village of Lakhidari of Bhomra union of Satkhira Sadar Upazila in the southwest
region of Bangladesh. The land port has seen increasing demand due to congestion at Benapole-
Petrapole border. Demand is expected to increase with the completion of the Padma Multipurpose
Bridge as Bhomra is on shortest route from Kolkata to Dhaka. The port caters for around 650 trucks per
day on average which equates to a volume of more than 4 million tons of cargo per year. Traffic demand
for trucks is forecasted at 1,650 per day by 2030 with the volume of goods expected to reach around
7.2 million tons per year. Like Benapole land port, the feasibility study and detail design report for
Bhomra are in an early stage of preparation, and the exact project interventions are yet to be
determined. The ESIA of the Bhomra port will be prepared and disclosed as soon as the feasibility study
and detail design report advance. The timing of the ESIA will be clearly mentioned in the Environmental
and Social Commitment Plan (ESCP) of the Borrower.

Burimari-Changrabandha is the third largest land border crossing between Bangladesh and India.
The land port is situated in the Rangpur Division in northern Bangladesh. The land port caters to 140,000
trucks per year and is unable to meet increasing freight flows, leading to congestion and delays in border
crossing time. This border is the designated land port for trade to and from Bhutan. The feasibility study
and detail design report for Burimari land port are more advanced than for Benapole and Bhomra. The
expected infrastructure interventions will include, inter alia, construction of open stack yard,
international passenger terminal building, export terminal, warehouse, parking yard, truck terminals,
administrative, residential and dormitory buildings, re-excavation of a dead canal adjacent to the
proposed land, bank protection of river and lake, construction of two culverts to connect the existing
and proposed land port. A site specific ESIA will be prepared and disclosed prior to project appraisal.

Sub-component 1b: Development of Automated Border Management System

This sub-component will support the development of a new multi-agency Automated Border
Management System platform aimed at increasing visibility of the trade chain, reduce costs and
unnecessary interactions with cargo shipments. This automated system is especially relevant in the
context of COVID-19 where it has become imperative to reduce face to face interactions and reduce
manual processes. It will seek to improve processes by BLPA and other border management partners

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that fall within and, outside of the regulatory requirements (e.g., cargo handling, storage, tariff
calculation, and levy payment procedures).
Sub-component 1c: Technical Assistance to enable contemporary trade facilitation practices
This sub-component will finance long-term master plans, feasibility design studies and environmental
and social safeguard studies for priority land ports that will be considered for financing in subsequent
MPA phases (e.g., Banglabandha, Hili, Sonahat, Bilonia, Tamabil, Bholaganj, Darshana and other land
ports). Support will also be provided to build capacity of BLPA staff in modern border management
practices.
Component 2: Customs Modernization
Implementing Agency: National Board of Revenue (NBR)
Sub-component 2a: Upgrading of Custom Infrastructure
This sub-component will support the
upgrading of physical facilities at the
Chattogram Customs House, which
manages 90 percent of Bangladesh’s
import and export declarations,
servicing more than 7,000 traders
per day. Rapidly growing trade
volumes have over-burdened the
existing facilities that were initially
constructed in 1920. The current
complex also includes a customs
laboratory which tests and analyses
samples of various goods intended
for exports or imports. The Custom Figure: Proposed Master Plan, Chattogram Customs House
House would be modernized along
with the customs laboratory in line
with international good practice
with strictly controlled designated areas for trader/customs official interactions and for the laboratory,
with all the necessary safety protocols. The designs would reflect COVID-19 protocols aimed at reducing
face to face interactions. The feasibility and design reports are under preparation. A preliminary master
plan of Chattogram Customs House is presented in above figure. The construction of the Custom House
Chattogram will be on government-owned land (6.77 acres) where the existing custom house is located.
Sub-component 2b: Development of Customs and Value Added Tax (VAT) Training Academy
This sub-component will support the development of a state-of-the-art Training Academy to help
institutionalize NBR’s capacity building programs and allow development of e-Training modules and
planned courses for continuous Human Resource Development. The construction of the Training
Academy will be on government-owned land (38.68 acres) where the existing Training Academy is
located.
Sub-component 2c. Technical assistance
This sub-component will support NBR to develop and implement phased implementation plan for tariff
rationalization, seeking to reduce overall level of tariffs and dispersion as per the vision set out by the
GoB. The sub-component is also expected to finance capacity building for the Risk Management
Commissionerate, National Risk Targeting Center, Bangladesh Single Window Commissionerate, and
Bonded Warehouse modernization.
Component 3: Trade Facilitation Agreement (TFA) Implementation (MoC)

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Implementing Agency: Ministry of Commerce (MOC) – WTO cell
Sub-component 3a: Strengthening of the National Trade Facilitation Committee (NTFC) and
development/implementation of National Trade and Transport Facilitation Action Plan
This sub-component will support establishing the NTFC Secretariat and the development and
implementation of National Trade and Transport Facilitation Action Plan. The NTFC will serve as the
primary trade and transport coordination mechanism in Bangladesh and will serve the functions as
envisioned in the World Trade Organization (WTO) Trade Facilitation Agreement (TFA).
Sub-component 3b: Development of Decision Support System for policy analysis, trade statistics and
trade negotiations
This sub-component will support a Decision Support System that will provide policy analysis, market
research and trade statistics to support MoC’s mandate in implementing trade policy including various
trade agreements.
Sub-component 3c: Formulation and implementation of National Tariff Policy
This sub-component will support the formulation a National Tariff Policy. A concept note is being
prepared with support from IFC Advisory in this regard. Necessary capacity building of officials will also
be carried out for subsequent policy updating and amendments to the policy.
Sub-component 3d: Upgrading of the Bangladesh Trade Portal (BTP)
This sub-component will support the enhancement of the Bangladesh Trade Portal, which is a key
element for the successful functioning of National Trade Single Window.
Sub-component 3e: Training programs on trade facilitation for women traders and entrepreneurs
This sub-component will seek to empower women traders and entrepreneurs and support their
integration into national, regional and global markets through capacity building in capacity building in
trade related regulatory issues.
Component 4: Regional Connectivity Infrastructure (RHD)
Implementing Agency: Roads and Highways Division
Sub-component 4a: Sylhet-Charkhai-Sheola-Sutarkandi Highway Improvement
This sub-component will upgrade
the existing Sylhet - Charkhai -
Sheola – Sutarkandi road (around
43km) from a two-lane single
carriageway to a climate-resilient
four lane dual carriageway. It will
include separate service lanes for
slow moving vehicles and
vulnerable users on both sides of
the carriageway. This road section
connects Sheola Land Port at
Sutarkandi with the Sylhet-Dhaka
Highway (N2) which is part of Asian
Highway 1 and 2. The project road
is also part of a strategic regional
corridor, the Bangladesh-China-
India-Myanmar (BCIM) corridor
which extends from (Kolkata, India Figure: Proposed Sylhet-Charkhai-Sheila-Sutarkandi Road
to Kunming, China).

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Presently, the road is a two-lane carriageway of a regional category road with a width of 5.5m. The
project will widen the road to a four-lane highway with international specifications and standards and
5.5 m services lane on both sides. The pavement works comprise construction of sub-grade, sub-base,
base course, and surface course (binder course & wearing course). The work also includes construction
of embankment, construction of flyover, underpass, and culverts.
The environmental risks and impacts are assessed to be substantial and largely manageable as the civil
works will be carried out in an existing road without any environmentally sensitive receptors such as
natural and critical habitats, and the construction stage environmental impacts will be temporary and
limited with the proposed mitigation measures. The project area is largely agricultural. There will be
issues with occupational and community health and safety during construction related to the increased
number of workers and possible influx and as well as an increase in demand for construction materials
and water resources and increase in air and water pollution. These issues, however, are typical in
medium to large-sized construction with known engineering and housekeeping measures, which will be
adopted and implemented by the project. An ESIA for Sylhet-Charkhai-Sheola-Sutarkandi Highway has
been prepared and disclosed.
Sub-component 4b: Technical Assistance for regional connectivity and policy development
This sub-component will provide technical assistance to help Bangladesh’s preparedness and
subsequently implementation of the Bangladesh-India-Nepal Motor Vehicle Agreement (MVA).
Financing will also be extended to develop a pipeline of regional connectivity transport projects through
the provision of feasibility studies, detailed design and environment and social safeguard impact
studies.

Scope of the ESMF

A site specific ESIA is already prepared for the Sylhet-Charkhai-Sheola road under Component 4, to be
implemented by RHD. This ESMF, thus, only covers BLPA, NBR and MoC-WTO cell (Components 1, 2 and
3) for the Phase 1 components in Bangladesh as a constituent part for guidance in the implementation
stage along with other required E&S documents for disclosure prior to board approval, consistent with
the ESF and the GoB environmental regulatory framework. This ESMF has been prepared and disclosed
covering only the Phase 1 of the MPA program, and the E&S documentations of any subsequent phases
will be prepared separately. As the design and locations of the Burimari Land Port under Component 1
(BLPA) is at a more advanced level of feasibility and design, a separate ESIA is being undertaken will be
disclosed by the appraisal stage. The ESIA for the Sylhet-Charkhai-Sheola-Sutarkandi Highway
Improvement under the Component 4 (RHD) has been completed and is being disclosed together with
this ESMF. As noted, the timing of the site-specific ESIAs for Bhomra and Benapole land ports and
Chattogram Customs House and Customs and Value Added Tax (VAT) Training Academy will be
mentioned in the Borrower’s ESCP.
The preparation of the ESMF considered the following:
● Screening of all sub-projects, components, and activities to be implemented under the BBIN-MPA
Program Phase 1 based on feasibility study initial reports to make a preliminary assessment of the
potential environmental, social, labor, occupational health and safety, community safety and
security (E&S) issues;
● Consideration of all applicable World Bank Environmental Social Framework (ESF) Environmental
and Social Standards (ESSs) including guidelines and standards recommended in the WBG’s
Environmental, Health and Safety Guidelines (EHSG) and existing GoB’s environmental and social
standards;
● Assessment of policy implications for the proposed project activities considering WB, GoB and
International laws/conventions/practices, and identify policy gaps between WB and the GoB, and
suggest options for gap minimization;

Environmental and Social Management Framework (ESMF) Page | xvi

 ● Development of a framework and guidelines for preparation of subproject specific screening,
Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plans
(ESMPs) (measures to reduce, mitigate and/or offset adverse risks and impacts), Resettlement
Action Plans (RAPs) as relevant, to ensure compliance with local E&S laws, Good International
Industry Practices (GIIP) and the WB ESF ESSs;
● Recommendations on institutional implementation and monitoring arrangement including
project-specific Grievance Redress Mechanisms (GRMs);
● Conduct of stakeholder mapping and subsequent consultations to cover groups/ communities/
stakeholders to elicit their views on the proposed project and suggestions on actions and measures
for inclusion in the SEP to ensure inclusion of the potential project affected persons, vulnerable
and marginalized groups and ethnic communities including women in the project preparation
process;
● Development of E&S capacity building plan that will include a broader E&S capacity assessment of
BLPA, NBR, MoC-WTO cell and RHD which will be incorporated as action points in the Borrower’s
Institutional E&S capacity development plan which will be reflected in the Environmental and
Social Commitment Plan (ESCP) to be an integral schedule of the Legal Agreement between the
WB and GoB.
● A cost table and budget to be adopted in the project budgetary provision to ensure
implementation of the ESMF and develop E&S management capacity of the partners.
Once details of the project sites are available at later stages of the project, the need for and type of E&S
assessments and management plans will be reviewed, according to WB policies and GoB legislation.

Policy, Legal and Regulatory Framework

World Bank’s Environmental and Social Framework (ESF)
All ESSs will be relevant to many of the program sub-components specially those involving new or
significant upgrades of infrastructure. Only ESS which is not considered relevant is ESS 9 as no resources
will be channeled through Financial Intermediaries. WB’s legal policies for Projects on International
Waterways (OP 7.50), and Project Disputed Areas (OP 7.60) are not relevant to the project. None of the
sites are located on disputed territory and as well as no transboundary waterways would be affected
from the project’s activities. The overall environmental and social risk rating for the first phase of the
Program is ‘High’, essentially due to social risks and impacts from land acquisition and involuntary
resettlement at the Bhomra and Benapole land port and Sylhet-Sheola road. The environmental risks
are assessed as ‘substantial’ as the civil works will be carried out on existing sites without any
environmentally sensitive receptors such as natural and critical habitats. Overall, thus the environment
and social impacts from the civil works are expected to be largely manageable as these are confined to
the current sites. The relevant section of the ESMF discusses the relevance of ESF Policy, each of the ten
standards (ESS1 to 10), and associated Directive, and their requirements. It also discusses the relevance
and requirements relating to other guidance notes of the World Bank. If the requirements of Bangladesh
law differ from those of ESF, the more stringent requirements will apply.
Applicable Act, Rules and Policies of the GoB
Applicable national policies, Acts and rules have been discussed in the relevant sections. The key
legislations relevant for environmental assessment for BBIN-MPA program Phase 1 components are the
ECA 1995 and the ECR 1997, subsequent amendments. In order to set an illustrative directive for abiding
by the Act, Bangladesh Government through the ECR 1997 and its subsequent amendments, as specified
in rule 7(2), lists the different types of industrial projects into four categories namely, Green, Orange A,
Orange B, or Red, based on severity of its potential environmental impacts.

Environmental and Social Management Framework (ESMF) Page | xvii

As per ECR 1997 amended 2010, due to the planned project interventions and the nature of activities,
the BBIN-MPA program, Phase 1 in Bangladesh falls under Red category and ESIA will be required for
upgrading existing inland port facilities at Benapole, Bhomra, Burimari (Component 1, BLPA);
construction of several multi-storied buildings (NBR will construct a multi-storied residential building,
Bungalow, office building, Multipurpose Hall, Dormitories) school building, cyclone shelters, markets,
local government office building, etc.) in the residential/commercial complex area under the customs
house and training academy (Component 2, NBR); and Sylhet-Charkhai-Sheola-Sutarkandi 4-Lane
Highway (Component 4, RHD). It is the responsibility of the PIUs i.e. BLPA, NBR, MoC-WTO Cell and RHD
to conduct ESIA in accordance with the ESMF and get Environmental Clearance Certificate (ECC) from
DoE. ESIA study and Environment clearance will be obtained by the respective PIUs from the DG,
Department of Environment (DoE) before any construction starts for the respective sub-projects.The
environmental clearance procedure for Red Category projects can be summarized as follows:
Application to DoE→ Obtaining Site Clearance → Applying for Environmental Clearance → Obtaining
Environmental Clearance → Clearance Subject to Annual Renewal.
Gap Analysis of World Bank Requirements and National Laws
A gap analysis between WB’s ESF and GoB Regulations was conducted as part of the E&S capacity
assessment of the BBIN-MPA program in light of the Overview Assessment of Bangladesh's Country
Framework for Addressing Environmental Risks and Impacts of Development Projects (September
2021). The results of the gap analysis indicated the Bangladesh EIA System has a few material gaps with
respect to the WB ESS1.
Foremost among these are: (i) BD national laws does not cover many of the issues relating to other WB
ESSs; (ii) the stakeholder engagement during the EIA study is almost non-existent or very limited,
needless to say, that there is no requirement to engage stakeholders during construction; (iii) it does
not emphasize the application of mitigation hierarchy in selecting mitigation measures; (iv) it recognizes
only Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) and does not
provide for other assessment instruments, particularly Strategic Environmental Assessment (SEA),
Regional Environmental Assessment (REA), Cumulative Impact Assessment (CIA); and, (v) it does not
require analysis of alternatives and associated facilities.

It has also a few problems of its own when compared to a standard ESIA process applied following GIIP
, including but not limited to: (i) it does not provide any formal definition of the projects to be required
the Environmental Clearance--the law only refers to "industry" and "industrial units"; (ii) the screening
process is inadequate--there is no procedure or criteria for determining which category a project would
fall into; and (iii) it does not have formal procedure for compliance monitoring and reporting.
Although there are suggestions in the EIA Guidelines on these issues, the Guidelines does not have the
same compelling effect as the force of law or regulation. There is no assurance that all relevant ESSs (1-
8 and 10) will be well covered in the ESIAs processes and final Report including ESMPs and monitoring
/ supervision measures. Although GoB the EIA requirements lean heavily towards the environmental
aspects, in recent years more and more social issues are being incorporated in the assessment.
Moreover, the practice under normal circumstances does not include labor and OHS management
issues.
Another critical gap pertains to lack of provisions for requiring the preparation of project specific ESMPs.
On the social side, the eminent domain land acquisition system for example does not require the
preparation of Resettlement Action Plan (RAP). There are some gaps between the existing land
acquisition law of the country and ESS5 on Land Acquisition and Involuntary Resettlement in terms of
identification of affected persons and compensation packages and participation of community groups
of diverse interests and vulnerabilities. There are also no provisions to formulate Labor Management
Procedures/Plans (LMP).

Environmental and Social Management Framework (ESMF) Page | xviii

Suggested gap-filling measures are given in relevant section. These gaps are summarized in Table ES-1
, this ESMF will follow the most stringent standards and requirement.
Table ES-1: Gaps Minimization between GoB laws and WB’s ESSs
WB ESF Standard Gap Minimization

ESS-1: Assessment and Management ESMF has suggested following the ESS-1 requirements, given in the relevant
of Environmental and Social Impacts sections of environmental management procedures. In case, DoE rules/ regulations
and Risks do not cover the ESS requirements, and relevant clauses should be added in the
financial agreements and project appraisal document to follow the more stringent
safeguard requirements according to WB ESF. ESS1 requirements will also inform
the E&S requirements of the sub-project ESIAs/ESMPs and these will be used in sub-
project bidding documents.

ESS-2: Labor and Working Conditions Under this project, a LMP will be prepared to regulate working conditions and
management of worker relations including workers specific GRM, terms and
conditions of employment, non-discrimination and equal opportunity, protection
of the workers’ rights to form unions and engage in collective bargain, protection
of work force, prohibition of child/forced labor and provision of occupational health
and safety (OHS) – including Covid-19 precautions and post measures.

ESS-3: Resource Efficiency and ESMP to be developed for BBIN-MPA program component 1, 2, and 4 will address
Pollution Prevention and this issue and incorporate mitigation measures for pollution prevention and will
Management include guidance for efficient use of natural resources.

ESS-4: Community Health and Safety The gaps will be addressed through appropriate provisions in sub-project
ESIA/ESMPs and covered in the ESMP guidance part of this ESMF. In addition,
contractor, operators will be responsible to prepare and implement the
Construction Environmental and Social Management Plan (C-ESMP) regarding
community and occupational health and safety which includes OHS plan, traffic and
road safety management plan etc. Besides, a SEA/SH has been prepared at the
appraisal stage.

Life and Fire Safety (L&FS) risks assessment and management plan for custom
facilities and building, including training facilities and dormitories, will be
performed as part of the ESIA/ESMP, and appropriate management plans
compliant with Good International Industry Practices (GIIP) will be prepared.

Similarly, as part of the ESIA process, a Security Risk Assessment will be prepared,
and commensurate Security Management Plans will be developed for each site.

ESS-5: Land Acquisition, Land Use The project may require land acquisition from private entities. A RPF has been
Restriction, and Involuntary developed to guide preparation of site-specific RAPs/A-RAPs to address the land
Resettlement acquisition and involuntary resettlement and as well as physical and economic
displacement related issues.

ESS-6: Biodiversity Conservation and A detailed guideline has been given in the ESMP preparation section of the ESMF.
Sustainable Management of Living Besides, site-specific management plans with detailed ecological studies will be
Natural Resources prepared for each sub-project/activity in line with WB ESF, including application of
the mitigation hierarchy when potentially impacting Natural and / or Critical
Habitats, and designing management measure to ensure No Net Loss (NNL) or Net
Gain (NG), respectively.

ESS-7: Indigenous People During preliminary screening of the project, no communities meeting the ESS7
criteria were identified. However, if any IPs are identified during the preparation of
site-specific ESIA/ESMP, a Small Ethnic Community Development Plan (SECDP) will
be prepared following the ESS7 requirements.

ESS-8: Cultural Heritage No significant cultural heritages have been identified during the initial screening.
However, further assessment will be carried out during the preparation of the site-
specific ESIAs/ESMPs and in case any such cultural heritage sites are found,
appropriate mitigation measures will be included in the subprojects’ ESIAs/ESMPs.
This will also include a Chance Finds Procedure which will be appended to bidding
and contract documents to illustrate actions to be taken on finding any cultural
heritages. Efforts will also be made to identify cultural heritage in collaboration with

Environmental and Social Management Framework (ESMF) Page | xix

 WB ESF Standard Gap Minimization

communities during the stakeholder consultation process, and avoid siting facilities
on or near culturally important areas.

ESS-9: Financial Intermediaries Not relevant.

ESS-10: Stakeholder Engagement Under this BBIN-MPA program, a SEP has been developed for all the PIUs that
and Information Disclosure identifies the various stakeholders and ways to engage them and close the feedback
loop. The SEP has detailed a GRM for the PIUs to address issues and concerns for
the stakeholders.

Environmental and Social Baseline

Site specific baseline information of all the sub-projects is yet to be generated by the client, except for
Sylhet-Charkhai-Sheola-Sutarkandi road, as clarified above. However, preliminary investigation has
been conducted during the ESMF preparation, confirming that the areas where all three land ports of
BLPA and custom houses/training academy of the NBR are located can be classified as Modified Habitats
where a large portion of plants and/or animals are of non-native origin and human activities have
modified their natural functions and species composition.
There are no archaeological sites, sensitive cultural or biodiversity receptors of international, national,
state, or district importance including protected areas, key biodiversity areas, forest areas, sacred
groves, or historical/cultural monuments around the identified proposed sites or along the alignments.
Homestead trees might need to be cleared in some of the proposed sites, but this impact will be minor,
not related to any protected species and will be mitigated by replanting new trees at a ratio of [1:5] as
noted in the ESMP section below. As the design and locations of the proposed sites proceed in more
advance level, as part of the conducting ESIA for those sub-project, more in-depth E&S baseline will be
developed by the clients.
Burimari Land Port: The River Dharla is located at the east side and adjacent to the proposed land for
expansion of land port. A large waterbody (popularly called dighi in Bangla) is located at the south side
of the proposed land and it serves as water basin throughout the year as it receives the rain runoffs
from the surrounding areas. This dighi is considered artificial aquatic habitat and no birds or fish have
been identified which are endangered. However, the project is not expected to have any significant
impacts on the waterbody’s hydrology, water quality and habitats characteristics.
Key potential impacts will be associated with minor disturbances from construction and increase traffic
/ dust noise, but these will be for the mostly temporary and mitigated with the application of standard
practice such as traffic management plan, noise and dust abatement, awareness training to
construction workers, etc. (see ESMP section below).
A dead canal from Dharla River is connected to this lake at the north and west side of the proposed
land. This canal is currently fully silted and therefore no connecting flow between the river and the lake
is observed throughout the year. In dry season water flow in river Dharla is minimum. In monsoon the
discharge in the river is full, but no flash flood is observed due to rain. Moderate vegetation is observed
at the proposed site and around the proposed land site.
Around the proposed land most trees are Bamboo bush and different type of local fruits, Mango garden,
Mehuguni, Akasmuni (Acasia), Jack fruits etc. are found within 1.00 km area. There are some other
minor canals and lowlands but they are fully silted up and are of no ecological or social value. There is
no designated forest area owned by Forest Department of Bangladesh. There is some agricultural land
within the 1.00 km around the proposed site but no cultivated land.
There is a Private College, High School, Primary School, Kinder Garden School and Madrasha are within
2.00 km around the proposed land. No aesthetic structure or site of cultural importance are within or
around the project site or area of influence. Settler from different region of the country made their

Environmental and Social Management Framework (ESMF) Page | xx

resident around the project site and engaged in different ways of living, such as no ethnic
group/indigenous people found in and around the project site.

Environmental and Social Risk Classification (ESRC)

The ESRC is rated high overall for reasons of substantial land acquisition and involuntary resettlement
at Bhomra and Benapole land port under Component 1 and most significantly for the Sylhet road under
Component 4. The environmental risk of the project (Phase 1) is rated ‘substantial’ as there are no
significant impacts on biodiversity values or ecosystem services of importance and no impact on critical
habitats or protected areas.
The third land port, Burimari, under Component 1, involves land acquisition of about 5 acres with only
minor involuntary resettlement impacts. The remaining 20 acres land are government owned. The E&S
risks for the Component 2 (NBR) are rated ‘moderate’ as no land acquisition is anticipated for both sites
and also the civil works will be confined to the existing locations in an urban setting. The sub-component
2C is essentially composed of TA and rated low on E&S risks. The Component 3 under MOC (WTO Cell)
involves TAs for studies, training and procurement some IT items and is also rated low as regard E&S
risks.
Land Acquisition and Involuntary Resettlement
The anticipated land acquisition for BLPA under Component 1 is about 120 acres and involves
involuntary resettlement related impacts on both legal landowners, informal occupants, businesses,
tenants, homesteads, residential and commercial buildings, particularly in Bhomra and Benapole.
Burimari land port requires 25 acres out of which only about 5 acres (with 16 HHs) will need to be
acquired from private owners.
No land acquisition is anticipated for NBR under Component 2 and there are also no informal occupants.
Under NBR, the proposed rehabilitation and improvement of existing infrastructure will take place
within the building footprint inside the project area with no requirements of land acquisition, physical
and economic displacement of the local community.
Around 313.92-acre land will be needed for the construction of the proposed road project by the RHD.
Of which 176.03-acre is crop lands, 28.48-acre is commercial lands, and 31.32 acre is homestead lands.
Both physically and economically total affected HHs are 4,362 with total PAPs of 17,884 individuals. This
impact is not covered in this ESMF, as it is detailed in the subproject ESIA, which is being simultaneously
disclosed together with the present document.
Potential Key Environmental, Social, Labor, Occupational Health and Safety, Community Health and
Safety and Security (E&S) Impacts and Risks
The BBIN Program - Bangladesh Phase 1 activities and subprojects covered by this ESMF and under
Components 1-3, are expected have limited E&S environmental risk and impacts given that most of the
civil works are rehabilitation and improvement of existing infrastructures by BLPA and NBR or are
related to capacity building, system improvements and soft interventions. Therefore, the anticipated
E&S impacts and risks during construction are those typically associated to civil works such as air, noise,
water and soil pollution, wastewater, solid and hazmat waste generation, as well as labor, occupational
health and safety risks of workers and nearby communities.
During operations, expected E&S impacts and risks will be minor wastewater and solid / hazmat waste
management issues related to operation of offices, laboratory of NBR’s training academy and land port
activities, including but not limited to general domestic wastewaters and solid wastes, e-wastes,
laboratory hazardous wastes and spoiled perishable goods discarded by importers/exporters.
No significant impacts are anticipated on air quality nor major concerns are expected in terms of
environmental or social impacts other than moderate impacts from existing activities. The labor,

Environmental and Social Management Framework (ESMF) Page | xxi

occupational health and safety and security issues will also be typical of operation of these type of
facilities and are expected to improve once the sub-projects are finalized and ESMP measure are
implemented.
Potential environmental and social impacts of the BBIN Program – Bangladesh Phase 1 are:
 Pre-Construction Phase/Project Siting
o Site Specific Land Cover and Land Use Changes
o Loss of Trees
o Loss of Habitat
o Drainage congestion and water logging
o Impacts on Vulnerable and disadvantage groups/communities/ individuals
 Construction Phase
o Air Pollution
o Noise and Vibration Pollution
o Water Pollution (surface and ground water)
o Impacts of Land Filling (at construction site)
o Soil Contamination
o Drainage congestion and water logging
o Generation of Solid Waste and Hazardous Waste
o Occupational Health and Safety
o Community health and safety including SEA/SH risks
o Impact on labor, working conditions and labor risks, including risks of child labor and
forced labor, human trafficking
o Involuntary Resettlement and Livelihood Impacts
o Impact on Cultural Heritage
 Post Construction/Operation Phase
o Loss of Vegetation
o Generation of Solid Waste and Hazardous Waste
o Noise Generation
o Water Pollution and Drainage
o Impacts on local livelihoods
o Increased risk of road accidents
E&S risks and impacts associated to operations are reflected in Table ES-2. E&S impacts and risks that
are particularly relevant and important are highlighted with corresponding measures to be detailed in
the sub-projects ESIAs/ESMPs. These are related to:
 Management of refrigeration units, hazamat cargo (e.g. fuel, chemical) and potential accidental
spills.
 Dealing with labor unions in the Port Facilities;
 Community Risks related to increase containers and heavy commercial import-export traffic;
 Security Risks associated with border activities (e.g. human and illegal drugs trafficking,
contraband, etc);
 Occupational and community health risks including SEA/SH; and
 Life and Fire Safety associated with offices, container storage, training facilities, and
dormitories;
Under this program, there is scope of enhancement of measures in subprojects such as use of renewable
energy in the new buildings, reuse of wastewater and composting of biodegradable wastes.

Sexual Exploitation and Abuse, and Sexual Harassment (SEA/ SH)

A preliminary assessment of SEA/SH risks using the Bank’s SEA/SH risk assessment tool for projects with
major civil works suggests a ‘Moderate’ SEA/SH rating for BLPA, NBR and RHD sub-project components.

Environmental and Social Management Framework (ESMF) Page | xxii

This is due to the project sites being in peri-urban and urban areas which are not hard to supervise.
Most of the unskilled and semi-skilled labor are expected to be locally sourced with only high skilled
and some semi-skilled labor sourced from outside sub-projects’ areas of influence.
However, the construction works of the proposed land ports will inevitably lead to greater mobility of
peoples, which could contribute to raising a number of social problems; namely, greater exposure to
communicable and sexually transmitted diseases including HIV/AIDS due to influx of outsiders such as
traders, businesspersons, skilled and unskilled migrant laborers, transport workers, etc. all of which may
also potentially lead to social tensions among the local communities.
Human and sex trafficking targeting girls and women is common in South Asia where immigration points
at the land ports could potentially serve as conduits for cross-border trafficking. A Gender and SEA/SH
Action Plan is prepared for the project that details the relevant mitigation measures both preventive
and curative, and as well includes specific actions to promote gender and women empowerment.

Mitigation Measures to Address Environmental, Social, Labor, Occupational Health and Safety,
Community Health and Safety and Security (E&S) Impacts and Risks
The ESMF identifies overall E&S risk and impacts for the project and provides relevant mitigation
measures. More specific E&S impacts and risks associated with subprojects will be identified during the
preparation of subproject-specific ESIA/ESMP. The identified E&S risks and impacts are categorized as
pre-construction, construction, commissioning and operational phases along with suggested mitigation
measures which will be further assessed and detailed in the site-specific ESIA/ESMP.
Good International Industry Practice (GIIP) will be applied to mitigate all identified E&S impacts and
risks associated with each sub-project activity and phase and will be described in their construction (C-
ESMP) and operations (O-ESMPs) Environmental, Social, Labor, Occupational Health and Safety,
Community Health and Safety and Security Management Plans. A set of standard mitigation measures
against the typical E&S impacts and risks expected on this program’s subprojects at their different
phases are proposed in the Table 5.3 of Chapter 5 and summarized in Table ES-2 below:
Table ES-2: Potential E&S Impacts and Risks and Mitigating Measures at Different Phases of the BBIN-
MPA Program (Phase 1)

Potential E&S Responsibility

Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

Preconstruction Phase

Land ● Encroachment of - Avoid agricultural land, social/religious PIU E&S PIU/BBIN-

Acquisition/ agricultural land, establishments, fish habitat during consultant, MPA
Requisition (if cultural sites, fish finalization of the alignment of the RAP
required) habitat etc. approach road and location of the bridge; Implementatio
● Loss of - Prior to start construction adequate n NGO
agricultural compensation should be given to the
production, fish PAPs in-time according to RAP.
resources; - Adequate compensation should be given
● Loss of income for standing crops;
and livelihoods; - Avoid agricultural land, if possible;
● Social conflict. - Create job opportunities for the PAPs.
Road, Office, ● Loss of housing - Avoid the housing and commercial Contractors PIU/BBIN-
Training Center, and commercial structure during the finalization of the MPA
Housing structures; alignment and location of the
● Dust pollution; road/bridge;
● Loss of income - Proper compensation shall be provided
and livelihoods. to the affected peoples prior to the
construction activities.
- Create job opportunities for the PAPs.

Environmental and Social Management Framework (ESMF) Page | xxiii

 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

- Water spraying on the bear surface or

dust pollution source;
Loss of ● Accident risk - Prior to start construction, all vegetation Contractors PIU/BBIN-
vegetation/ tree during removal of should be removed from the proposed MPA
trees/vegetation’s construction sites with the consultation
in the project of the local relevant authorities and
sites; other stakeholders;
● Birds and others - Avoid disturbance and be careful during
species can construction about vehicle and
migrate from the equipment movement;
trees/vegetation’s - Proper H&S measures (use of
; appropriate PPE such as hand gloves,
● Impacts on the safety shoes and helmet) for the workers
local climatic should be taken during removal of trees,
condition. bushes & crops;
- To mitigate the ecological impact, tree
plantation plan can be considered in the
design & accordingly tree plantation will
be done in an appropriate location to be
determined by the PIU/BBIN-RTTF1 after
consultation with the concerned
authority and other stakeholders;
- The engineer shall approve such felling;
only when the proponent secures receive
a “clearance” for such felling from the
PIU/BBIN-RTTF 1 as applicable;
- Tree felling, if unavoidable, shall be done
only after compensatory plantation of at
least five saplings for every tree cut is
done;
- During the tree removal from the bridges
and approaches construction sites
diameter at best height of the trees is 6
inches, only such trees should be
considered by the contractor for
compensation and plantation;
- Tree plantation at the suitable locations
after completion of the construction
activities at the 1:5 ratio.
Removal of ● Risks for workers - Prior to start construction, the utility Contractors PIU/BBIN-
Utilities health and safety; services (electrical cables, telephone line, MPA
● During movement water supply pipeline, gas supply
of heavy pipeline and internet line) should be
Construction shifted with the consultation of the
machineries relevant organizations;
equipment’s can - Inform the local community before
damage the utility starting removal or demolishing work;
services if not - Carefully remove the utilities that are
previously connected to any structures;
removed; - Proper Health and safety measures for
● Due to the workers should be taken during
carelessness or shifting of these lines to avoid any
incautiousness incidents.
death from
sudden electric
shocks may occur.

Environmental and Social Management Framework (ESMF) Page | xxiv

 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

Archaeological/ ● Encroachment of - Avoid Contractors PIU/BBIN-

Historical/ Social/ Archaeological/ Archaeological/Historical/Social/Cultural MPA
Cultural/ Religious Historical/ Social/ / Religious sites during the site selection
Sites Cultural/ Religious and improvement works;
sites - Spraying water on the dry surface to
● Air and dust reduce dust pollution;
pollution; - Follow strictly the chance finds
● Noise level may procedures
create uncomfort - Vehicles transporting construction
for the local material to be covered;
community; - Create noise barrier around the
● Vibration can construction sites;
effect on social/ - Limit the speed of vehicles;
cultural/ religious - Stop the demolition work for short time
site. like prayer time.
- Realignment of bridge approach road (in
case of bridge) if required.
Setting up labor ● Land - Include E&S/ESMP provisions on labor, Contractors PIU/BBIN-
camps encroachment; GRM, SEA/SH etc. in the bidding MPA
● Solid and liquid documents and C-ESMP/O-ESMP with
waste from the payment milestones
labor camp - Labor camp will follow GIIP as those
● Potential described in Worker Accommodations:
community health Process and Standards (IFC/EBRD 2006);
including SEA/SH Please see:
risks https://www.ifc.org/wps/wcm/connect/
topics_ext_content/ifc_external_corpor
ate_site/sustainability-at-
ifc/publications/publications_gpn_work
ersaccommodation
- Avoid productive land and away from the
settlement during the selection of land
for the setup of labor camp;
- No solid and liquid waste discharge into
the water bodies;
- Instruct workers to maintain clean
environment in the camps.
- Enforce a Code of Conduct for all workers
- Raise awareness among the communities
on STDs, SEA/SH and the project GRM
Construction Phase

Air Pollution ● Construction - Fit vehicles with appropriate exhaust Contractors PIU/BBIN-
vehicular traffic: Air systems and emission control devices; MPA
quality can be - Maintain vehicles and construction
affected by vehicle equipment in good working condition
exhaust emissions including regular servicing;
and combustion of - Operate the vehicles in a fuel-efficient
fuels manner;
● Construction - Impose speed limits at 30 km/hour on
equipment: Air vehicle movement at the worksite to
quality can be reduce dust emissions;
adversely affected - Control the movement of construction
by emissions from traffic in the access road;
construction - Focus special attention on containing the
machineries and emissions from generators;
combustion of - Construction equipment causing excess
fuels; pollution (e.g. visible smoke) will be
banned from construction sites
● Construction immediately prior to usage;
activities: Dust

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

generation from - Water spray to the dry earth/material

earth excavation, stockpiles, access roads and bare soils as
earth & sand and when required to minimize the
stockpiles during potential for environmental nuisance due
dry period. to dust;
- Increase the watering frequency during
periods of high risk (e.g. high winds);
- Stored materials such as: excavated
earth, dredged soil, gravel and sand shall
be covered and confined to avoid their
wind drifted;
- Restore disturbed areas as soon as
possible by vegetation;
- Establish adequate locations for storage,
mixing and loading of construction
materials, in a way that dust dispersion is
prevented because of such operations;

- The Air quality monitoring should be

carried out by the contractor following
the National Air Quality Standard
(Schedule-2: Standards for Air Quality,
ECR, 1997 and Amendment in 2005).
Noise Pollution ● Construction - Strict measures for noise pollution control Contractors PIU/BBIN-
vehicular traffic: need to be undertaken during MPA
Vibration and Noise construction activities;
quality will be - Create noise barrier and consider the
deteriorated due to minimum noise levels at sensitive
vehicular traffic. receptor sites (e.g. dense residential area,
● Construction schools, mosques, health centers etc.);
equipment: Noise - Stone breaking machine should be
and vibration will confined within a temporary shed so that
have an impact on noise pollution could be kept minimum;
adjacent - Protection devices (ear plugs or ear
surrounding muffs) shall be provided to the workers
residents. operating in the vicinity of high noise
generating machines during construction;
● Construction - Construction equipment and vehicles
activity: Noise will shall be fitted with silencers and
have an impact on maintained properly;
adjacent - Instruction to the drivers to avoid
residents. unnecessary horn;
- The Noise level monitoring should be
carried out by the contractor following
the National Noise Quality Standard
(Schedule-4: Standards for Sound, ECR,
1997 and Noise Pollution (control) rules
2006).

- Vibration monitoring should be carried

out by the contractor.
- Contractors PIU/BBIN-
- The contractor will make arrangement for MPA
Ground Water ● Contamination of water required for construction in such a
Pollution groundwater due to way that the water availability and supply
Pollution lack of to nearby communities remain
septic tanks or unaffected;
mobile toilets; - Handling and storage of the potential
contaminants has to be organized under
● Accidental spillage strict condition to avoid water pollution
of hazardous during construction;
liquid from the

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

construction - Handling of hazardous liquid should be

camps. done carefully by the designated
experienced person;
- Handling and storage of the potential
contaminants should be done by the
experienced workers. Proper monitoring
should be done by the experienced
person;

- The Ground water quality monitoring

should be carried out by the contractor
following the National Water Quality
Standard (Schedule-3: Standards for
Water, ECR, 1997).
Surface Water ● Construction & - Contractor should prepare waste and Contractors PIU/BBIN-
Pollution general wastes Wastewater Management Plan and MPA
from the follow it properly during the construction
construction sites; period;
- Any wastes should not be throwing into
● Oil spill from the the river/khal/canal other than disposing
construction to the designated waste dumping area;
vehicles and - Store the oil and petroleum product in a
construction camp separate location cover by a concrete
can effect on structure;
fishes and aquatic - Handling of hazardous liquid should be
wildlife (such as done carefully by the designated
snakes, frogs etc.) experienced person;

- Monitor the surface water by testing in

designated laboratory should be done by
the Contractor following the National
Water Quality Standard (Schedule-3:
Standards for Water, ECR, 1997).
Land/ Soil ● Decrease the - Avoid the productive land, agricultural Contractors PIU/BBIN-
Pollution production capacity land, archaeological sites, protected area, MPA
of agricultural land; forest area, natural habitat etc.;
● Land or soil erosion - Land/soil quality should be ensured by
from water or wind; the contractor to fill the abutment area
● Sediment pollution and approach road;
and increase the - Soil from fallow land should be used in
turbidity; earthwork in approach road;
- Re-vegetation the exposed area as early
● Reduction the as possible to reduce the soil erosion;
microorganism. - Create barrier for reducing the
sedimentation into the water bodies;

- The Land or soil quality test should be

carried out by the contractor.
Waste (Solid, ● Improper storage - The contractor will minimize the Contractors PIU/BBIN-
Liquid and and handling of generation of sediment, oil and grease, MPA
Hazardous) construction & excess nutrients, organic matter, litter,
Pollution general liquid waste debris and any form of waste (particularly
such as fuels, petroleum and chemical wastes);
lubricants, - Any wastes should not be throwing into
chemicals and the river/khal/canal other than dump into
Organic waste:
hazardous liquid the designated waste dumping area;
remaining foods,
onsite, and - Handling of hazardous liquid should be
leafs, papers,
potential spills from done carefully by the designated
straw, fruit cover
these liquid experienced person;
etc.
materials may harm - Organic waste should be managed by
the environment composting method. A concrete chamber
and health of with 3 rooms is needed to be provided. In

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

Inorganic waste: construction one room organic waste should be

Polythene, workers. dumped and another room inorganic
Glasses, Synthetic ● Improper storage waste will be dumped. When the room
paper, plastic etc. and handling of will be filled then covered by earth. Then
construction & dump to the third room. After 6 month
general solid organic waste will be converted into
wastes. fertilizer and will be used by the farmers;
Hazardous waste:
- Inorganic waste should be given to the
Paint, fuel, ● Improper storage authorized vendor for free of cost for
chemicals, oil,
and handling of recycling;
petroleum
- Accidental spillage of hazardous waste
products,
should be managed by spreading wood
bitumen etc.
powder on the surface of the oil and this
powder mixed with oil must store in a
designated concrete room;
- Make sure all containers, drums and tanks
that are used for storage are in good
condition;
- Take all precautionary measures when
handling and storing fuels and lubricants,
avoiding environmental pollution;

- Wastewater monitoring should be

carried out by the contractor, following
the national standard (Schedule-10:
Standard for waste from Industrial units
or Projects waste).
Hydrological ● Drainage - A detailed hydrological and Contractors PIU/BBIN-
Regime congestion and morphological study of the site (in case of MPA
flood at the site; bridge or other water related structures)
should be conducted;
● Erosion and - Proper design and construction
siltation at the accordingly to accommodate design
site. flows;
- Provision of sufficient sizes of drains to
take design flows;

- Wastes should not be disposed near any

water body. All waste depending on its
characteristics, should be disposed of in
a controlled manner.
Sand ● Impact on river - Material sourcing will be thoroughly Contractors PIU/BBIN-
Extraction/River ecology assessed in the project ESIA. MPA
dredging/Canal - Contractors will be prohibited from
Re-excavation ● Changes in the opening new areas in local Rivers for
river morphology extracting and/or sourcing sands,
including erosion specially areas in local rivers that remain
of banks and loss in relatively good natural conditions and
of agricultural areas that support fish of conservation
land, etc. importance.

- Community adjoining local rivers will be

mobilized in the monitoring of
contractors.
Drainage ● Construction of - Pier of the existing bridge structures and Contractors PIU/BBIN-
Congestion diversion road on other construction waste should be MPA
the river/ clearly removed from the construction
Khal/canal create site during dismantling of existing
drainage structure;
congestion; - Construct diversion road on the
river/khal/canal by keeping provision of

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

● Stockpiling of open space so that water flow cannot

construction hamper by the construction activities;
materials in the - Immediately remove all the construction
river/khal/canal debris from the construction site as well
also create as from the water bodies in a planned
drainage way;
congestion. - Duration of stockpiling should be
minimized as much as possible;
- Avoid the encroachment of the water
bodies;
- Protect water bodies from sediment loads
by silt screen or bubble curtains or other
barrier;
- Construction activity should be
recommended during the dry season;

- Construction workers shall be

instructed to protect water resources;
Road Traffic and ● Increased traffic - Proper Traffic Management Plan (TMP) Contractors PIU/BBIN-
Accidents use of narrow should be prepared by the contractor MPA
access road by during starting of construction & follow it
construction strictly;
vehicle will affect - In this TMP, the road safety measures
the movement of such as speed breakers, warning
normal road signs/lights, road safety signs, flagman
traffics and the etc. should be included to ensure
safety of the road uninterrupted traffic;
users specially the - Movement specially at nearby the
students educational (Schools, colleges, Madrasha
etc.), community infrastructure
(mosques, graveyards, Prayer Ground
etc.) and health complex;
- In addition, BRTA traffic rules and
regulations should be strictly followed;
- Divert traffic to follow alternative routes
to avoid traffic jams;

- All construction drivers will undergo

Defensive Driving training and talking
with mobile phones during driving will be
forbidden.
Landscape and ● Excavation of - Parking of construction vehicles and Contractors PIU/BBIN-
Aesthetics borrow pits, stock stockpiling of construction MPA
piling of materials/excavated earth should be
construction done in systematic way to avoid the
materials, placing of damaging of aesthetics of the site;
construction - Duration of stockpiling should be
equipment and minimized as much as possible;
parking of - Vegetation plantation after completion of
construction the construction work;
vehicles; - Completely remove the construction
● Presence of camp facilities, equipment’s and their
construction camps, activities;
equipment and - Limit the speed of the vehicles and cover
their activities; the vehicles during the movement or
● Movement of transportation of materials on the
construction existing road network and temporary haul
vehicles on the road;
existing road
- Plantation of trees at the construction
network and
site after completion of the construction
activities immediately.

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

temporary haul
roads;

● Closure of existing
bridges by
construction of
diversion road.
Occupational ● Campsites for - Construction workers camp shall be Contractors PIU/BBIN-
Health and Safety construction located at least 500 m away from the MPA
workers and nearest habitation and follow GIIP such
Safety are the as those described on Worker
important Accommodations: Process and
locations that Standards (IFC/EBRD 2006);: Please find:
have significant https://www.ifc.org/wps/wcm/connect/
impacts such as topics_ext_content/ifc_external_corpor
health and safety ate_site/sustainability-at-
hazards on local ifc/publications/publications_gpn_work
resources and ersaccommodation
infrastructure of
nearby
communities.
● Lack of proper - Adequate housing for all workers should Contractors PIU/BBIN-
infrastructure be provided avoiding over crowing; MPA
facilities, such as - Safe and reliable water supply;
housing, water
supply and - Hygienic sanitary facilities and sewerage
sanitation facilities system.
will increase
pressure on the
local services and
generate
substandard living
standards and
health hazards
● Management of - Ensure proper collection and disposal of Contractors PIU/BBIN-
wastes is crucial to solid wastes within the construction MPA
minimize impacts camps;
on the - Insist waste separation by source; organic
environment. wastes in one container and inorganic
wastes in another container at sources;
- Dispose organic wastes in a designated
safe place on daily basis;
- The organic wastes should be always
covered with a thin layer of sand so that
flies, mosquitoes, dogs, cats, rats, etc. are
not attracted;

- Locate the garbage pit/waste disposal

site minimum 500m away from the
resident area so that people are not
disturbed with the odor likely to be
produced from anaerobic decomposition
of wastes at the waste dumping places.
● Risks of diseases to - Provide adequate health care and Contractors PIU/BBIN-
be transmitted sanitation facilities within the MPA
including malaria, construction sites;
exacerbated by - Train all construction workers in basic
inadequate health sanitation and health care issues and
and safety safety matters and on the specific hazards
of their work;

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

practices. - Provide HIV awareness programming,

including STI (sexually transmitted
infections) and HIV information,
● Risk of work crews education and communication for all
spreading sexually workers on regular basis;
transmitted
infections and - Covid-19 protocols will be adopted by
HIV/ AIDS. contractors and all IAs

- Regular mosquito repellant spraying

during monsoon periods.
● Health and safety - Develop detailed OHS Management Plan Contractors PIU/BBIN-
risks to the for each site which shall include, but not MPA
construction be limited to:
workers and site - Task-specific risks assessments;
visitors leading to - Standard Operating Procedures
severe injuries and (SOPs) associated with each task
deaths. which will include capacity / skill
requirements as well as required
Personal Protection Equipment
associated with the task;
- Daily 10 minute safety talks to
every working crew for awareness
and refreshing of the OHS risks
associated with the tasks to be
performed as well as procedures /
chain of command in case of
incidents or accidents;
- Key Performance Indicators (KPI)
tracking man-hours without
incidents and an objective os zero
tolerance / zero fatalities;
- Periodic Safety Audit / Inspections;
and
- Permanent capacity building for
workers.
- Provide the workers a safe and healthy
work environment;
- Provide appropriate PPE for workers,
such as safety boots, helmets, masks,
gloves, protective clothing, goggles, full-
face eye shields and ear protection;
- Maintain the PPE properly by cleaning
dirty ones and replacing them with the
damaged ones;
- Appoint an environment, health and
safety manager to look after the health
and safety of the workers;

- Inform the local authorities responsible

for health, religious and security before
commencement of civil works and
establishment of construction camps so
as to maintain effective surveillance over
public health, social and security matters.
- Prepare and enforce a Life and Fire Safety
protocols consistent with GIIP as part of
the C-ESMP.
● Lack of first aid - Provide health care facilities and first aid Contractors PIU/BBIN-
facilities and facilities are readily available; MPA
health care
facilities in the

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

immediate vicinity - Document and report occupational

will aggravate the accidents, diseases, and incidents and
health conditions actions taken;
of the victim. - Identify potential hazards to workers,
particularly those that may be life
threatening and provide necessary
preventive and protective measures;
- Provide awareness to the construction
drivers to strictly follow the driving rules;

- Provide adequate lighting in the

construction area and along the roads in
the construction site.
Community ● Accidents on the - Include the related E&S provisions in the Contractors PIU/BBIN-
Health and Safety approach road and C-ESMP/O-ESMP with payment MPA
construction site; milestones.
● Noise and dust - Prior to start the construction activities
pollution; contractor will be informed the local
community;
● Communicable - Instruct the drivers and limit the speed of
diseases can spread the vehicles;
among the local - Regular health checkup of the workers
community. and awareness training about the
communicable diseases;
● Risk of SEA/SH - Proper lighting at the project site during
the night time;
- Avoid unnecessary noise pollution;
- Spraying water in the dry surface to
reduce the dust pollution

- Provide proper access control to the

project site and unauthorized entry to the
project site will be controlled by
deploying security personnel.

- Enforce a Code of Conduct for all the

workers

- Set up and run a SEA/SH compliant GRM

- Raise awareness among the workers,
communities and stakeholders on SEA/SH
and the project GRM

Operation Phase

Air Pollution ● Dust emission from - Establish the speed breaker to limit the BLPA and NBR Relevant
the increasing speed of the vehicle near the site; Ministries
number of vehicles - Strictly follow the BRTA rules and with the
in the site area; regulations; assistance
● Vehicular emission - Increase number of plantation by adding of DoE
from burning new species of trees on the appropriate
fuels. locations after consultation with the
concern authority.
Surface Water ● Remaining - Remaining construction materials will be BLPA and NBR Relevant
Pollution construction completely removed from the proposed Ministries
materials may be project site after completing of the with the
washed by the construction activities; assistance
rainfall into the - Cover the bare surface by plantation of of DoE
water sources and trees/vegetation to reduce the surface
lead to soil erosion;
sedimentation and - Speed control measures close to the site
increase turbidity; to reduce the occurrence of accidents;

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

● Hazardous - Bank protection work can be done at the

materials spilled by site;
accidents; - Avoid rainy season for continuing any
● Soil erosion during development activities.
rainy season can - Permanent maintenance and clean up of
contaminate drainage works, specially prior to
nearby surface monsoon to remove potential road trash
water. and other pollutants that could be
● washed down with heavy rains or cause
clogging.
Ground Water ● Accidental spillage - EPR Plan, including contingency plans in BLPA and NBR Relevant
Pollution of hazardous case of accident spills. Ministries
chemicals and - Well defined area within Ports for with the
materials. isolation of leaky cargo, including a SOP assistance
for containment compliant with GIIP. of DoE
- Speed control measures close to the site
to reduce the occurrence of accidents;
- Inform to the concern authority to take
necessary action to reduce the
contamination of groundwater.
Hydrology and ● Increase flood/ - From planning stage and site selection BLPA and NBR Relevant
Flood pattern water logging/ local hydrology and flooding level will be Ministries
drainage condition; considered which will need sto be with the
● Encourage for followed at the operation stage; assistance
erosion and - Vertical navigation clearance should be of DoE
siltation. kept in design and planning at the
operation stage;
- A separate and details hydro-
morphological study should be
conducted before starting construction
activities;
- Site should be clean properly after
completion of the construction activities
so that the natural drainage system may
not hampered.
Noise Pollution ● Faulty engine and - Ensure a designated area for traffic BLPA and NBR Relevant
hydraulic horn waiting to clear customs, with adequate Ministries
may increase the noise abatement to avoid nuances to with the
noise level. potential nearby receptors. assistance
- Noise will be periodically monitored of DoE
through the facilities’ perimeter and at
sensitive receptors.
- Necessary instruction for the drivers;
- Establishment of signboard near the
sensitive receptors like mosques,
schools, temple, bazar etc.
Flora and Fauna ● Dust will hinder - Re-plantation of various suitable local BLPA and NBR Relevant
vegetation growth; trees can be done on the slopes of the Ministries
● Increase number of roads or the suitable locations around the with the
death of wildlife project site; assistance
and collision with - Establish monitoring system to avoid road of DoE
the vehicles; kills of animals from traffic at the nearby
● Avifauna will be port connecting roads; movement in the
affected by the port areas
movement of - No disturbance for aquatic animal and
vehicles; keeps provision for the fish and other
● Fish and other aquatic animals movement;
aquatic animals - Diversion road should be removed
will be affected. properly as soon as possible;

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 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

- Construction workers shall be instructed

to protect natural resources, flora and
fauna, including wild animals;
- Natural river/khal/canal will be reinstated
after completion of construction works;
- Fingerling (fish) can be released to the
river/khal/canal near the
waterbodies/rivers/canals to the sites to
boost up the fish resources.
Landscape and ● Land use of the - Tree/vegetation plantation at the BLPA and NBR Relevant
Aesthetics proposed project suitable site; Ministries
area will be - Proper removal of construction camp with the
changed; facilities and construction wastes from assistance
● Improper the site after completion of the works; of DoE
removal of - Excavated borrow pit area will be
construction camp properly managed by the contractor, it
facilities and other will be preferred to use dredging
construction materials after quality testing, so that it
waste will affect doesn’t left off blank at the operation
landscape and stage.
aesthetics.
Management of ● Lack of related - Ensure strict protocols with appropriate BLPA and NBR Relevant
refrigeration safety and security equipment Ministries
units, hazardous protocols and - Place the hazardous materials and cargo with the
materials and skilled personnel in a contained place away from the assistance
cargo normal materials/cargos and ensure that of DoE
the place is designed with appropriate
civil and structural engineering
Labor unions and ● Lack of proper - Labor Management Procedures to be BLPA and NBR Relevant
labor rights enforcement of the enforced guaranteeing freedom of Ministries
government’s labor association and collective bargain, no with the
rights/rules discrimination and compliance with the assistance
relevant ILO Conventions including of DoE
honoring the Fundamental Principles and
Rights at Work
Community * Accidents on the - Enforce and traffic management plan and BLPA and NBR Relevant
health and safety approach road and instruct the drivers and limit the speed of Ministries
construction site; the vehicles; with the
*Noise and dust - Regular health checkup of the workers assistance
pollution; and awareness training about the of Police
communicable diseases;
*Communicable - Proper lighting at the project site during
diseases can spread the night time;
among the local - Avoid unnecessary noise pollution;
community. - Spraying water in the dry surface to
reduce the dust pollution
*Risk of SEA/SH
*Risk of human - Provide proper access control to the
trafficking project site and unauthorized entry to the
project site will be controlled by
deploying security personnel.

- Enforce a Code of Conduct for all the

workers including the security personnel
and set up and run a SEA/SH compliant
GRM

- Raise awareness among the workers,

communities and stakeholders on SEA/SH
and the project GRM
- Run an inter-agency coordination and
collaboration platform/framework with

Environmental and Social Management Framework (ESMF) Page | xxxiv

 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

police on potential human and drug

trafficking
Occupational ● . Lack of proper - Adequate housing for all workers should BLPA and NBR Relevant
Health and Safety infrastructure be provided avoiding over crowing; Ministries
facilities, such as - Safe and reliable water supply;
housing, water
supply and - Hygienic sanitary facilities and sewerage
sanitation facilities system.
will increase
pressure on the
local services and
generate
substandard living
standards and
health hazards
● Management of - Ensure proper collection and disposal of BLPA and NBR Relevant
wastes is crucial to solid wastes within premises ministries
minimize impacts - Insist waste separation by source; organic
on the wastes in one container and inorganic
environment. wastes in another container at sources;
- Dispose organic wastes in a designated
safe place on daily basis;
- The organic wastes should be always
covered with a thin layer of sand so that
flies, mosquitoes, dogs, cats, rats, etc. are
not attracted;

- Locate the garbage pit/waste disposal

site minimum 500m away from the
resident area so that people are not
disturbed with the odor likely to be
produced from anaerobic decomposition
of wastes at the waste dumping places.
● Risks of diseases to - Provide adequate health care and BLPA and NBR Relevant
be transmitted sanitation facilities within the Ministries
including malaria, construction sites;
exacerbated by - Train all construction workers in basic
inadequate health sanitation and health care issues and
and safety safety matters and on the specific hazards
practices. of their work;
- Provide HIV awareness programming,
including STI (sexually transmitted
● Risk of work crews infections) and HIV information,
spreading sexually education and communication for all
transmitted workers on regular basis;
infections and
HIV/ AIDS. - Covid-19 protocols will be adopted by
contractors and all IAs

- Regular mosquito repellant spraying

during monsoon periods.

-
● Health and safety - Develop detailed OHS Management Plan BLPA and NBR Relevant
risks to the for each site which shall include, but not ministries
construction be limited to:
workers and site - Task-specific risks assessments;
visitors leading to - Standard Operating Procedures
severe injuries and (SOPs) associated with each task
deaths. which will include capacity / skill
requirements as well as required

Environmental and Social Management Framework (ESMF) Page | xxxv

 Potential E&S Responsibility
Issues/ Activities Proposed Mitigation Measures
Impacts Implementation Supervision

Personal Protection Equipment

associated with the task;
- Daily 10 minute safety talks to
every working crew for awareness
and refreshing of the OHS risks
associated with the tasks to be
performed as well as procedures /
chain of command in case of
incidents or accidents;
- Key Performance Indicators (KPI)
tracking man-hours without
incidents and an objective os zero
tolerance / zero fatalities;
- Periodic Safety Audit / Inspections;
and
- Permanent capacity building for
workers.
- Provide the workers a safe and healthy
work environment;
- Provide appropriate PPE for workers,
such as safety boots, helmets, masks,
gloves, protective clothing, goggles, full-
face eye shields and ear protection;
- Maintain the PPE properly by cleaning
dirty ones and replacing them with the
damaged ones;
- Appoint an environment, health and
safety manager to look after the health
and safety of the workers;

- Prepare and enforce a Life and Fire Safety

protocols consistent with GIIP
● Lack of first aid - Provide health care facilities and first aid BLPA and NBR Relevant
facilities and facilities are readily available; Ministries
health care - Document and report occupational
facilities in the accidents, diseases, and incidents and
immediate vicinity actions taken;
will aggravate the - Identify potential hazards to workers,
health conditions particularly those that may be life
of the victim. threatening and provide necessary
preventive and protective measures;
- Provide awareness to the drivers to
strictly follow the driving rules;

- Provide adequate lighting in the

premises and along the roads in the
construction site

Environmental Codes of Practice (ECoPs)

The environmental codes of practice (ECoPs) are generic, non-site-specific guidelines. The ECoPs consist
of environmental and social management guidelines and practices to be followed by the contractors/
implementation organizations for sustainable management of all environmental and social issues. The
contractor will be required to follow them and also use them to prepare site-specific management
plans. Details of the ECoPs listed in Annex H.
Stakeholders Engagement and Consultations

Environmental and Social Management Framework (ESMF) Page | xxxvi

A detail Stakeholder Engagement Plan is prepared by the appraisal and will be followed throughout the
project life cycle. The SEP identifies the “project affected parties”, “other interested parties” and the
“vulnerable and disadvantaged groups” specific to all 4 IAs (BLPA, NBR, MOC and RHD) of the project
and includes the relevant provisions to engage all the stakeholders from the inception to the project to
all through the project cycle, till completion and post-construction/operational phase.
The SEP will be considered as living document and will be revised as necessary if the changing project
context requires so with clearance from the Bank. Finally, the SEPs elaborate a project-specific GRM for
all the 4 IAs.
Both in person and virtual consultations were carried out to develop this ESMF, the latter considering
the ongoing COVID-19 situation in Bangladesh. As part of the ESMF, three (03) stakeholder consultations
were carried out by BLPA, NBR, MoC [and RHD] in different days; two online, and two in person
meetings at the Custom House, Chittagong and at the Land Port Authority Office, Burimari, Satkhira.
Grievance Redress Mechanism
All four implementing agencies (IAs); NBR, MoC, RHD and BLPA will establish and run a GRM for
redressal of the project-specific grievances that may potentially rise in the project cycle. The GRM will
be 2 tiers; site level, and PIU level with a Grievance Redress Committee (GRC) at each level. Members
of the GRCs will include women and PAPs. Training will be provided to the staffs who will work on
managing the grievances.
The GRMs will also be equipped to deal with labor and SEA/SH related grievances. Any SEA/SH related
complaints will be handled following a survivor-centric approach with confidentiality in line with the
World Bank guidelines provided in the WB good practice note on gender-based violence.
Information on the GRM will be widely disseminated among the PAPs and wider stakeholders including
at site levels. The GRM will be accessible to all and all grievances will be resolved within a settled time
period not exceeding 14 days. All proceeding of grievance resolution will be duly recorded and reported
to the stakeholders and the Bank by each IA.

Information Disclosure
All E&S related documents and information of the program and sub-projects will be disclosed in English
and the local languages by the implementing agencies on their website and hard copies will be made
available at project office throughout the project life cycle. Given the ‘high’ overall E&S rating of the
program, the ESIA of the Sylhet-Charkhai-Sheola highway along with the ESMF focusing on the 3 other
IAs/Components are disclosed by the IAs and on the external website of the World Bank. In addition,
the following are some of the other E&S instruments that are being developed and will be disclosed
before appraisal together with the Appraisal Environmental and Social Review Summary (A-ESRS):
 Environmental and Social Commitment Plan (ESCP).
 Stakeholder Engagement Plan (SEP) with a Grievance Redress Mechanism (GRM);
 Labor Management Procedures (LMP) with labor specific GRM;
 Resettlement Policy Framework (RPF); and
 ESIA of the Burimari Land Port;
The mechanism of information disclosure dissemination will be simple and be accessible to all. Two of
the important means that have been followed until now include briefing material and organization of
community consultation sessions. The briefing material (all to be prepared in local language i.e. Bangla)
can be in the form of (a) brochures (including project information, details of entitlements including
compensation and assistance to be given to the PAPs; grievance mechanism) that can be kept in the
offices of local government (union parishad office) and project office; (b) posters to be displayed at
prominent locations and (c) leaflets that can be distributed in the project areas. Consultation meetings

Environmental and Social Management Framework (ESMF) Page | xxxvii

should also be organized at regular intervals by the project to acquaint the communities, target group
beneficiaries and affected persons of the following:

 Timeline and progress of the program and sub-project by components;

 Information on beneficiary participation;
 Information of involuntary displacement, compensation and entitlements;
 Sub-project E&S risks and impacts
Information disclosure procedures are mandated to provide citizen centric information as well as all
documentation necessary for addressing any queries. Disclosure of information will enhance
governance and accountability specifically with respect to strengthening of monitoring indicators to
help the World Bank monitor compliance with the agreements and assess impact on outcomes.
Borrower’s Institutional Capacity Assessment
The Bangladesh Land Port Authority (BLPA), National Board of Revenue (NBR) and the Ministry of
Commerce (MOC WTO Cell) will implement component 1; component 2 and component 3 respectively.
All three implementing agencies (IAs) are currently implementing the Bank-funded Bangladesh Regional
Connectivity Project (BRCP), using the Bank’s safeguards policies as guiding frameworks. All IAs have
experience in implementing Bank-funded projects and are familiar with the Bank’s financial
management, procurement and environment and social safeguards policies and have adequate
institutional knowledge of institutional E&S risk management.
However, the proposed project will be the first under ESF for these three IAs1, , suggesting the need for
upfront technical support to the project teams towards adequate assessment and management of
environmental and social impacts of the program. All four IAs have Project Implementation Units (PIUs)
with dedicated E&S specialist by BLPA. However, in general, all the IAs will require further institutional
E&S risk management capacity building given the expanded scope of E&S management under ESF.
Further, given the duration of the Program, potentially spanning over 10-12 years, scope of setting up
an institutional E&S Risk Management Unit will be explored at BLPA in Bangladesh. For subprojects that
involve resettlement of people or displacement of their livelihoods, an employee with expertise and
adequate rank will be assigned responsibility for coordination of the RAP and ESF implementation, and
best efforts will be used to seek support from qualified NGOs on the implementation of the
resettlement plan and income restoration activities.
In order to strengthen the existing institutional capacity of BLPA, NBR and MoC for E&S impact and risk
management, the program will develop and implement relevant E&S systems and measures. Each of
the Project Implementing Units (PIU) will include a Social, Environmental and Communication Cell
headed by a Deputy Director which will be staffed by qualified specialists (consultants). The PIUs/IAs
will also engage project supervision consultants (PSC) to supervise the contractors including their
execution of construction-related ESMPs and ECoPs. The E&S Specialist within the E&S Cell will assist
the PIUs/IAs on issues related to E&S management, including overseeing the PSC and contractors with
respect to environmental and social risks, orientating contractors and field staff to C-ESMP and O-ESMP
requirements, reviewing PSC monthly monitoring reports, and compiling required monitoring reports
on ESMP compliance for the Project Director and the World Bank throughout the implementation
period.
Capacity Building Plan of the IAs
Capacity building for effective implementation of the ESSs requirements is a key element of the
ESIA/ESMP and will need to be carried out at all tiers of the project, including IAs (NBR, BLPA, MOC),
Project Management Consultant (PMC), and contractors. PMC will take the lead in implementing the

1
Only RHD – not covered under this ESMF – is currently implementing the Bank-funded WECARE MPA program
under ESF.

Environmental and Social Management Framework (ESMF) Page | xxxviii

capacity building plan at the construction site, though the contractors will also be responsible for
conducting training for their own staff and workers.
The various aspects that are covered under the capacity building will include general E&S awareness,
key environmental and social sensitivities of the area, key E&S impacts and risks of the program and
sub-projects, and ESMPs requirements. All staff in the PIUs will receive training and capacity support
from the PMC specialists to ensure learning and development and smooth and effective
implementation of the C-ESMP, O-ESMP and any RAP.
Training shall be imparted periodically to IAs (NBR, BLPA, MOC) officials and Staff on Environmental
and Social Issues. This includes an introduction to the Bank’s ESF along with related environmental,
social, labor, occupational health and safety, community health and safety and security management
aspects (e.g. OHS, Road Safety Management, GRM, Hazardous Waste Management, Stakeholder
Engagement, Gender and SEA/SH, Security Management, L&FS, Traffic Management, Land Acquisition
and Involuntary Resettlement, among others). The IAs/PIUs will also engage third-party resources for
capacity building as relevant/required.
ESMP Implementation Cost
Cost estimates will need to be prepared for all the mitigation and monitoring measures to be proposed
in subproject specific ESIAs in accordance with the ESMF. The cost estimates for some of the mitigation
measures identified in the C-ESMPs will be part of the civil works contract. Some of the suggested
activities from ESIA will be implemented by hiring NGO/consulting firm for some specific IAs. Land
Acquisition and Resettlement / Livelihood Restoration costs are excluded and the budget will come from
client’s own resources.
The following budget is the sum of the cost that would be incurred for E&S personnel of the PIUs, E&S
training and capacity building, ESMP implementation, E&S monitoring, Communications (materials and
campaign), OHS Materials (e.g. PEP, Mask/ Disinfectant Spray/ Handwash etc.), etc.
The Development Project Proposal (DPP)/Technical Assistance Project Proposal (TAPP) of BLPA/NBR/
MoC for the proposed program should reflect the ESMP activities with budget for successful
environmental and social management of the program. Total US$ 1.13 million is estimated for
implementation of ESMF which should be embedded in the proposed total project budget from IDA.
MOC

Remuneration
SI Expert’s Position
Monthly Annually
Gender Specialist (01) 450,000 5,400,000
Environmental and Social
450,000 5,400,000
Development/Stakeholder Engagement Specialist
Total (BDT) 10,800,000
Total (USD) 127,059

NBR
Remuneration
SI Expert’s Position
Monthly Annually
Environmental Expert (01) 450,000 5,400,000
Social Development and SE Expert (01) 450,000 5,400,000
OHS and Labor Management Expert (01) 450,000 5,400,000
Gender and SEA/SH Expert (01) 450,000 5,400,000
Lab Analyst 200,000 2,400,000
Lab Technician 150,000 1,800,000

Environmental and Social Management Framework (ESMF) Page | xxxix

 Total (BDT) 25,800,000
Total (USD) 303,529

BLPA
Remuneration
SI Expert’s Position
Monthly Annually
OHS and Labor Management Expert (01) 450,000 5,400,000
Land Acquisition and Resettlement Expert 450000 5,400,000
(01)
Environmental Expert 450000 5,400,000
Gender and SEA/SH Expert 450000 5,40,0000
Social Development and Stakeholder 450000 5,400,000
Engagement Expert
Total (BDT) 27,000,000
Total (USD) 317,647

(1 USD= 85 BDT)
[Salaries including Tax and VAT] TOTAL: BDT 63,600,000 [USD 748235]

Environmental and Social Management Framework (ESMF) Page | xl

Training/ Seminar
Budget Time Frame
BLPA NBR MOC
Seminar Topic/ [3 Ports]
Training Module
Introduction to World 1,500,000 500,000 500,000 Year 1
Bank ESF
Labor and working 1,500,000 500,000 500,000 Year 1
conditions and OHS
Community health and 1,500,000 500,000 0 Year 1
safety
Grievance Redress 1,500,000 500,000 0 Year 1
Mechanism
Stakeholder 1,500,000 500,000 500000 Year 1
Engagement
Gender and 1,500,000 500,000 500000 Year 1
SEA/SH/GBV
Review of RPF and RAP 900,000 0 0 Year 2
ESMP compliance 600,000 100,000 0 Annually
monitoring
RAP compliance 600,000 0 0 Annually
monitoring
OCHS and Labor 600,000 100,000 0 Annually
Management audit
Contract and 600,000 100,000 100,000 Year 1
Consultant
Management Module
Safe Chemical and 1,000,000 500,000 0 Year 1
Laboratory
Management
Advanced Laboratory 2,000,000 500,000 0 Year 1
Techniques and
Instruments Handling
TOTAL (BDT) 15,300,000 4,300,000 2,100,000 21,700,000
TOTAL (USD) 180,000 50,588 24,706 255,266
Budget Time Frame
BLPA NBR MOC
Other Items
Travel 600,000 100,000 0 Periodically
E&S Monitoring and 600,000 100,000 0 Periodically
Reporting
Studies (lumpsum) 500,000 200,000 100,000 Annually
Communications 1,500,000 500,000 500,000 Bi-annually
(materials and
campaign)
OHS Materials (e.g. 1,500,000 500,000 500,000 Annually
Mask/ Disinfectant
Spray/ Handwash etc.)
TOTAL (BDT) 4,700,000 1,400,000 1,100,000 720,0000

Environmental and Social Management Framework (ESMF) Page | xli

 Budget Time Frame
BLPA NBR MOC
Seminar Topic/ [3 Ports]
Training Module
TOTAL (USD) 55,294 16,471 12,941 84706
(1 USD= 85 BDT)

Conclusion
All the sites under the project are extension or upgrading of the existing infrastructures. The activities
will be carried out on the current E&S footprints and hence, essentially are located on highly modified
habitat which are already subjected to the foreseen E&S impacts and risks. Most concerning impacts
and risks relate to social aspects such as resettlement and economic displacement, potential labor
conflicts due to operating with a heavily unionized workforce, and security issues related to port
operations in international borders. All other potential environmental, social, labor, occupational health
and safety, impacts and risks are limited and incremental to existing ones and can be managed by
applying standard GIIP and the relevant provisions in the ESMPs in compliance with the Bank’s ESF and
Bangladeshi laws.

Environmental and Social Management Framework (ESMF) Page | xlii

 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

1. INTRODUCTION
1.1 Background
The World Bank is preparing a regional connectivity program for the BBIN sub-region. The proposed
program, which utilizes the Multiphase Programmatic Approach (MPA), will seek to address the main
drivers of high cost of trade and transport, namely low levels of technology adoption in trade facilitation,
inadequate transport and logistics infrastructure, and policy, regulatory, and procedural impediments
that constrain the cross-border movement of freight.

1.1.1 BBIN MPA Program in Bangladesh (Phase 1)

The MPA will help Bangladesh in modernizing regional transportation and trade infrastructure,
systems, and procedures. The Project would fund infrastructure at the Benapole, Bhomra, Burimari
Land Ports, custom house and training academy at Chattogram i and the widening of the current
Sheola – Sylhet road into 4-lane highway for better connectivity. Custom houses at Benapole and Dhaka
Airport may also be considered for inclusion in the Project. The infrastructure will be built on
digitization, contactless, and paperless processing principles. In addition, the project will assist in
creating an automated border management system, procedural, regulatory, and legislative reforms,
and accompanying capacity-building support in enabling modern trade facilitation practices. The Project
will improve efficiency, climate resilience and safety of movement of goods and people along the
corridor.
In Bangladesh, the Phase 1 of the Program (Project) will have 4 components with as many implementing
agencies, as following-
● Component 1: Land Port Development and Border Management Improvement (BLPA)
● Component 2: Customs Modernization (NBR)
● Component 3: Trade Facilitation Agreement (TFA) Implementation (MoC)
● Component 4: Regional Connectivity Infrastructure (RHD)
Description of the project components and their typology are furnished in the Chapter 2.
Implementing Agencies
The Project will be implemented by the Bangladesh Land Port Authority (BLPA), National Board of
Revenue (NBR), Ministry of Commerce (MoC) – WTO cell, and Roads and Highways Department (RHD).
Component 1 will be implemented by the BLPA, an autonomous body under the Ministry is Shipping
that manages all land ports of Bangladesh.
Component 2 will be implemented by NBR (Customs Wing) which is under the Internal Resource Division
of the Ministry of Finance. Its main functions are collecting duties and taxes, protecting domestic
industry, trade liberalization, and trade facilitation.
Component 3 will be implemented by MoC – WTO cell which is mandated to implement WTO rules and
regulations, build trade capacity and formulate and implement trade policies.
Component 4 will be implemented by RHD, an agency of the Road Transport and Highways Division of
the Ministry of Roads, Highways and Bridges. This department is responsible for constructing and
maintaining major roads network, including national highways, regional highways, and district roads.

Environmental and Social Management Framework (ESMF) Page | 1

 Figure 1.1: Location Map of BBIN Regional Transport and Facilitation MPA Program

1.1 Purpose of the ESMF

This ESMF has been prepared to ensure environmental and social integration in the planning,
performance, and monitoring of project-supported activities during the preparation and execution of
the BBIN-MPA Phase 1 activities in Bangladesh. The ESMF will guide pre-investment works/studies (such
as environmental and social screening, environmental and social assessment, environmental and social
management plans, etc.) as well as a set of steps, processes, procedures, and mechanisms for ensuring
an adequate level of environmental and social consideration and integration in each investment in the
project-cycle. While the purpose of this ESMF document is to identify the potential adverse effects of
the BBIN MPA Program, the particular objectives are to -
• Ensure that all project interventions are environmentally sustainable and socially feasible,
incorporate environmental and social issues into their identification, design, and execution;
• Ensure that all relevant environmental and social issues are incorporated into the design and
implementation of the projects/sub-projects and the BBIN MPA Program's succeeding
phases.;
• Consider the program's possible environmental and social risks, benefits, and consequences
in a holistic approach, and devise strategies to prevent, mitigate, and manage risks and
impacts while maximizing benefits.;
• Ensure that national rules and regulations, as well as World Bank obligations, are followed.
The ESMF details the BBIN MPA Program's possible impacts, mitigation, enhancement,
contingency, compensation measures, environmental and social management and
monitoring plan, and an institutional framework for implementing the ESMP, including inter-
agency cooperation. The ESMF will make it easier for Bangladeshis to comply with the
government's policies, actions, and rules, as well as the World Bank's environmental and
social standards (ESSs) under the recently established Environmental and Social Framework
(ESF), and
• As suitable to the project phases, guide the preparation and conduct of the thorough
IEE/ESIAs/ESMPs of the subsequent stages of the BBIN MPA Program.

Environmental and Social Management Framework (ESMF) Page | 2

1.2 Rationale of the ESMF
BBIN-MPA Program and its sub-projects’ location and design for Phase 1 in Bangladesh are not known
as yet (though broader area of interventions have been selected) therefore, depth and breadth of risks
and impacts are not known. The component interventions' number, kind, and locations of the sub-
projects will be determined during the project execution stage. Beneficiary groups and places for
infrastructures will be known during implementation. Hence site-specific environmental social issues
and impacts for all the potential sites could not be identified and specified for mitigation during the
planning stage. Each IAs will screen for project interventions at the implementation level and identify
the target group beneficiaries to prepare and implement social action plans. As a result, systematic
guidance for social preparation and management is required. Hence it is essential to develop and follow
a framework approach of the project’s ES assessment and management procedure. The borrowers have
prepared the ESMF based on the overall assessment of the project components and the areas that might
be covered. BLPA with the help of consultant coordinated to prepare the ESMF on behalf of other
implementing agencies NBR/MoC-WTO Cell/RHD as well so that Implementing Agencies (IAs) could
ensure best ES issue management following the WB Environmental and Social Framework (ESF) during
its implementation. However, following screening, site-specific assessment and management plan will
be prepared during implementation in accordance with ESMF as soon as the exact location, layout,
detail activities of subprojects, and design are known.

1.3 Scope of the ESMF

A site specific ESIA is already prepared for the Sylhet-Charkhai-Sheola road under Component 4, to be
implemented by RHD. This ESMF, thus, only covers BLPA, NBR and MoC-WTO cell (Components 1, 2 and
3) for the Phase 1 components in Bangladesh as a constituent part for guidance in the implementation
stage along with other required E&S documents for disclosure prior to board approval, consistent with
the ESF and the GoB environmental regulatory framework. Although, the BBIN is an MPA, this ESMF of
the BBIN Program-Bangladesh Phase 1 has been prepared and disclosed covering only the Phase 1, and
the E&S documentations of the subsequent phases will be prepared separately. However, as the design
and locations of the Burimari Land Ports under Component 1 (BLPA) and Sylhet-Charkhai-Sheola-
Sutarkandi Highway Improvement under the Component 4 (RHD) are more in advance level, two
separate ESIA have been prepared for these sub-projects by the clients and will be disclosed by the
appraisal stage.
The preparation of the ESMF considered the following:
● Screening of all sub-projects, components, and activities to be implemented under the BBIN-MPA
Program based on feasibility study initial reports to make a preliminary assessment of the potential
ES issues;
● Consideration of all applicable ESSs including guidelines and standards prescribed in the WBG’s
Environmental, Health and Safety Guidelines (EHSG) and existing GoB’s environmental standards;
● Assessment of policy implications for the proposed project activities considering WB, GoB and
International laws/conventions/practices, and identify policy gaps between WB and the GoB, and
suggest options for gap minimization;
● Development of a framework and guidelines for preparation of subproject specific screening,
Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plans
(ESMPs) (measures to reduce, mitigate and/or offset adverse risks and impacts), Resettlement
Action Plans (RAPs) that comply with local ES laws and the WB ESF and Environmental and Social
Standards (ESSs);
● Recommendations on institutional implementation and monitoring arrangement including
project-specific GRMs;
● Conduct of stakeholder mapping and subsequent consultations to cover groups/ communities/
stakeholders to elicit their views and suggestions on actions and measures for inclusion in the SEP

Environmental and Social Management Framework (ESMF) Page | 3

 to ensure inclusion of the potential project affected persons, vulnerable and marginalized groups
and ethnic communities including women in the project preparation process;
● Development of ES capacity building plan that will include a broader ES capacity assessment of
BLPA, NBR, MoC-WTO cell and RHD which will be incorporated as action points in the Borrower’s
Institutional ES capacity development plan which has been reflected in the ESCP.
● A cost table and budget to be adopted in the project budgetary provision to ensure
implementation of the ESMF and develop ES management capacity of the partners.
Once details of the project sites are available at later stages of the project, the need for and type of E&S
assessments and management plans will be reviewed, according to WB policies and GoB legislation and
will update accordingly.

1.4 Approach and Methodology

The ESMF has been prepared following the standard methodology consisting of the steps listed below-
1. Review of the program details and meeting/discussions with the respective teams of BLPA,
NBR, MoC-WTO cell, RHD and WB;
2. Review of the policy and regulatory requirements;
3. Field visit by E&S experts with the respective team and initial scoping and identifying to
determine the critical environmental and social parameters and aspects that are likely to be
impacted by the program activities;
4. Collect and analyze the baseline environmental and social data with the help of primary and
secondary field data collection and literature review;
5. Consult with the stakeholders, including beneficiary/neighboring and affected communities,
and develop the consultation process;
6. Assess the potential and likely impacts of the program activities at different construction
phases;
7. Prepare an outline of environmental and social management issues according to the
requirements of the applicable ESSs of the ESF;
8. Prepare an outline of ESMP; and
9. Compile the individual thematic reports into ESMF.
The methodology for the preparation of the ESMF is presented in Figure 1.2.

Environmental and Social Management Framework (ESMF) Page | 4

 Review of information on the BBIN MPA
Reviewing policies, regulations and
Program and consultation done by IAs
administrative frameworks
with stakeholders

Collecting information on environmental and social Review of the key environmental and social resources of
baseline conditions of the program area the area

Assessing the potential impacts of the program activities

on environmental and social resources

Proposing appropriate mitigation and enhancement

measures; Preparing outline of reports as per 10 newly
adopted ESSs of ESF

Compiling ESMF

Figure 1.2: Approach of ESMF Preparation

Environmental and Social Management Framework (ESMF) Page | 5

2. PROJECT DESCRIPTION
As seen by an increasing number of sub-regional and bilateral connectivity agreements, the relationship
between Bangladesh, Bhutan, India, and Nepal (BBIN nations) is developing, indicating momentum to
advance the regional transport and trade facilitation agenda. The project will increase the efficiency,
climate resilience, and safety of products and people moving along regional corridors.
Phase 1 (FY22) will provide an estimated US$ 750million in IDA funding for Bangladesh. BLPA, RHD,
NBR and MoC are the four (04) implementing agencies responsible to carry out the phase-1 activities.
BLPA will be responsible for the expansion work of 03 land ports (Burimari, Bhomra and Benapole)
including construction of administrative buildings along with boundary walls, warehouses, parking
facilities, water supply facilities and other resource accommodation. Under RHD’s supervision, the
Sylhet – Charkhai-Sheola-Sutarkandi road will be widened into 4 lane road. MoC will be implementing
the capacity building facilities to boost the import- export sector. NBR will be expanding the custom
house and training academy at Chattogram . Custom houses at Benapole
and Dhaka Airport may also be considered for inclusion in the Project.

2.1 Project Development Objectives (PDO)

The proposed Project Development Objective is to augment trade-enabling infrastructure, technology,
and processes to improve the conditions for regional transport and trade in Bangladesh.
Outcome indicators would measure progress towards the achievement of the PDO , including
among others:
(i) Reduced transit times at priority border points [Percentage change]
(ii) Increased efficiency of transport mobility for passengers and goods on sections of the BBIN
regional road network [Percentage change]
(iii) Reduced variability in transport costs due to extreme climate events [Percentage change]

2.2 Description of BBIN MPA Program Phase 1 in Bangladesh

As described in the Chapter 1, BBIN-MPA Phase 1 in Bangladesh has four Components to be
implemented by four different agencies i.e., BLPA, NBR, MoC-WTO Cell and RHD. Each of these
components have following sub-components.
Component 1: Land Port Development and Border Management Improvement (BLPA)
Sub-component 1.1: Upgrading of Benapole, Burimari, and Bhomra land ports
Sub-component 1.2: Development of Automated Border Management System
Sub-component 1.3: Technical Assistance to enable contemporary trade facilitation practices
Component 2: Customs Modernization (NBR)
Sub-component 2.1: Upgrading of Custom Infrastructure
Sub-component 2.2: Development of Customs and Value Added Tax (VAT) Training Academy
Sub-component 2.3: Technical assistance for tariff modernization
Sub-component 2.4: Technical assistance for Risk Management Commissionerate, Feasibility
and detailed design for proposed National Risk Targeting Center and TA for proposed
Bangladesh Single Window Commissionerate
Sub-component 2.5: Technical assistance for Bonded Warehouse modernization
Component 3: Trade Facilitation Agreement (TFA) Implementation (MoC)
Sub-component 3.1: Strengthening of the National Trade Facilitation Committee (NTFC) and
development/ implementation of National Trade and Transport Facilitation Action Plan

Environmental and Social Management Framework (ESMF) Page | 6

 Sub-component 3.2: Development of Decision Support System for policy analysis, trade
statistics and trade negotiations
Sub-component 3.3: Formulation and implementation of National Tariff Policy
Sub-component 3.4: Upgrading of the Bangladesh Trade Portal (BTP)
Sub-component 3.5: Training programs on trade facilitation for women traders and
entrepreneurs
Component 4: Regional Connectivity Infrastructure (RHD)
4.1: Sylhet-Charkhai-Sheola-Sutarkandi Highway Improvement
4.2: Technical Assistance for regional connectivity and policy development
Location map of the major interventions are presented in the Figure 2.1.

Figure 2.1: Project Location Map

Description of the components/sub-components and typology of the sub-projects are described below:

Environmental and Social Management Framework (ESMF) Page | 7

Component 1: Land Port Development and Border Management Improvement (BLPA)
Sub-component 1.1: Upgrading of Benapole, Burimari, and Bhomra land ports
This sub-component will support the upgrading of infrastructure facilities of Benapole, Bhomra, and
Burimari land ports, which are critical for trade with India and with Bhutan and Nepal. Infrastructure
modernization will be premised on digitalization, contact-free and paper-free processing. The project
will seek to ensure a holistic development of the land ports, underpinned by enhanced border agency
collaboration and coordination (including with India) and improved border management.
● Benapole-Petrapole
is the largest land
border crossing in
South Asia in terms
of freight traffic and
value of goods. It
handles about 80
percent of the total
trade with India
through land routes.
The modernization
of the land port
would reduce
congestion and
enhance capacity of
truck flows from Figure 2.2: Benapole Land Port, Jashore
India at Petrapole Integrated Check Post (ICP). Currently, the Petrapole ICP has the capacity to
handle 700-750 export trucks but clears only 370 trucks as the present infrastructure, systems,
and processes at Benapole does not match the facilities of its Indian counterpart. Area to be
developed amount to 50 acres. The Benapole Land Port area is at Benapole, Sharsha, Jashore
District. It is in the southwest region of Bangladesh within Bara Achra, Benapole, Choto Achra
and Bhabarber mouzas of Benapole Union under the Sharsha Upazilla of Jashore District. Under
the subproject, boundary wall will be constructed.

● Bhomra-Ghojadanga is the second largest land port between in Bangladesh and India. The Land
Port has seen
increasing
demand due
to congestion
at Benapole-
Petrapole.
Demand is
expected to
increase with
completion of
the Padma
Multipurpose
Bridge as
Bhomra is on
shortest route
from Kolkata
to Dhaka. Figure 2.3: Bhomra Land Port, Satkhira
Traffic
forecast indicates future annual growth of 8 percent. Traffic demand for trucks is forecasted at
1,650 per day by 2030, more than double to current from current traffic. Bhomra land port is

Environmental and Social Management Framework (ESMF) Page | 8

 located at Sadar Upazila, Satkhira. The land port officially started its operation from 19 May
2013. Current storage capacity is 1600 MT. The subproject involves development of 25.87 acres’
area (i.e., existing port area of 15.67 acres and additional areas of 9.21 and 0.99 acres).
● Burimari Land Port
is unable to meet
increasing freight
flows, leading to
congestion and
delays in border
crossing time.
Burimari-
Changrabandha is
the designated land
port for trade to and
from Bhutan.
Burimari land port is
situated at Figure 2.4: Burimari Land Port, Lalmonirhat
Sreerampur Union in
Patgram sub-district. It is the 3rd largest land port of Bangladesh. In 1988 Burimari land port
has been established at Burimari zero point for import and export goods with India, Bhutan and
Nepal by road way. Furthermore, more design details are known from Burimari land port (when
compared to other ports) and then mention that therefore a specific ESIA has already been
prepared during appraisal stage. The other sub-project specific ESIAs will be prepared during
implementation when design works progressed.
The following activities will be carried out for this land port-
Specification for Building
Item No. Type Area
Office 1 Floor: 4-storied Sqm: 2000 per floor
Residential 2 Floor: 4-storied Sqm: 300 per floor
Land Filling
Item Amount/Remarks
Earthwork’s volume 3 lac cum if filling ht is 3meter
Boundary wall: -
Item Amount/Remarks
Length of the boundary wall 1200 meter
Height of the boundary wall Minimum 15 ft from FGL
Width if the boundary wall Thickness 15 and 10 inch
Water Supply System: -
Item No./ Amount/Remarks
Number of Pump House 1 no
Yield of the Wells 300 meter
Estimated daily production 1000 liters daily
Capacity of the water reservoir 100000 liters
Length of the pipeline route 2000 meter
Item No./ Amount/ Remarks
Number of watch tower 6 nos
Height of the watch tower 12 meters
Electrical design Street light, tower, electric tower, over the boundary wall in operational area,
underground cable laying
Requirement of electricity 100 KVA
Capacity of warehouses 15000 sqm
Open Stock yard capacity 81000 sqm
Area of Transshipment Sheds 5000 sqm
RCC Works 3,15,000 cum

Environmental and Social Management Framework (ESMF) Page | 9

 Thickness of the pavement 300 mm
Amounts of steel required 36000 mton
Length of internal road network 1500 meter
Width of Internal Road Network 21 meter
Length of the drainage network 2500 meter
Type of internal drains RCC

1.2: Development of Automated Border Management System

This sub-component will support the development of a new multi-agency Automated Border
Management System platform to increase visibility of the trade chain and reduce costs and unnecessary
interactions with cargo shipments. This automated system is especially relevant in the context of
COVID-19 where it has become imperative to reduce face to face interactions and reduce manual
processes. It will seek to improve processes by BLPA and other border management partners that fall
within and, outside of the regulatory requirements. For example, effective administrative and
operational processes by BLPA, such as cargo handling, storage, tariff calculation, and levy payment
procedures, while not related to regulatory obligations, also contribute to the overall efficiency of cross
border trade flows. Thus, modernizing regulatory and non-regulatory processes, automating them, and
subsequently looking for opportunities to share valuable data amongst border management partners
(including India) will contribute to trade flow efficiencies and trade chain health and security.
1.3: Technical Assistance to enable contemporary trade facilitation practices

This sub-component will finance long-term master plans, feasibility design studies and environmental
and social
safeguard
studies for
priority land
ports that will
be considered
for financing in
subsequent
MPA phases
(e.g.
Banglabandha,
Hili, Sonahat,
Bilonia,
Tamabil,
Bholaganj,
Darshana and
other land
ports). Support Figure 2.5: Proposed Master Plan, Chattogram Customs House
will also be
provided to build capacity of BLPA staff in modern border management practices.

Environmental and Social Management Framework (ESMF) Page | 10

COMPONENT 2: Customs Modernization (NBR)

2.1: Upgrading of Custom Infrastructure

This sub-component will support the upgrading

of physical facilities at the Chattogram Customs
House, which manages 90 percent of
Bangladesh’s import and export declarations
(13,000 per day), servicing more than 7,000
traders per day. Rapidly growing trade volumes
have over-burdened the existing facilities that
were initially constructed in 1920. The Custom
House would be modernized in line with
international good practice with strictly
controlled designated areas for trader/customs
official interactions. The designs would reflect
COVID-19 protocols aimed at reducing face to
face interactions. In addition, Dhaka and
Benapole customs houses may be considered
for inclusion under this sub-component. The
proposed site of Chattogram Customs House is
located at 22°18'42.97"N (Latitude) and
91°47'55.50"E (Longitude) under Chattogram City
Corporation, Thana: Bandar, ward: 36 an area of
8 acres of land. Dhaka Customs House is located
at 23°51'7.88"N (Latitude) and 9o°24'17.01"E
(Longitude) and Benapole Customs House are
located at 23°02'7.12"N (Latitude) and
88°53'56.83"E (Longitude). Locations of these Figure 2.6: Location of Different Customs House
customs houses under BBIN-RTTF Phase 01 in the under BBIN RTTF Phase 01
map in Figure 2.6 followed by the site specific
satellite images. Although the design and implementation plan of NBR for the improvement of
Chattogram Customs House has not been finalized yet, but the NBR presented the proposed master
plan of Chattogram Customs House is furnished in Figure 2.5.
2.2: Development of Customs and Value Added Tax (VAT) Training Academy
This sub-component will
support the
development of a state-
of-the-art Training
Academy to help
institutionalize NBR’s
capacity building
programs and allow
development of e-
Training modules and
planned courses for
continuous Human
Resource Development.
Although the design and
implementation plan of
the NBR for the
Figure 2.7: Proposed Master Plan, Customs and Value Added Tax (VAT) Training
development of the
Customs and Value

Environmental and Social Management Framework (ESMF) Page | 11

Added Tax (VAT) Training Academy has not yet been finalized, the following work will be done per their
discussion and presentation. The proposed master plan is depicted in Fig 2.7 and 2.8.

Figure 2.8: Proposed Master Plan, Customs and Value Added Tax (VAT) Training
2.3. Technical assistance for tariff modernization
This sub-component will support NBR in developing and implementing a phased implementation plan
for tariff rationalization, seeking to reduce the overall level of tariffs and dispersion as per the vision set
out by the GoB in its 8th FYP and proposed Bangladesh National Tariff Policy (to be prepared by Ministry
of Commerce). This will lead to preparation and implementation of a prioritization plan for tariff
rationalization and implementation by NBR. The phased implementation plan will take into
consideration export diversification, sector competitiveness, job creation, investment, Least
Development Country (LDC) graduation and economic recovery from COVID 19. Crafting such a tariff
rationalization plan requires significant capacity improvement in simulation, revenue modeling, and
other statistical analysis supported through this sub-component.
2.4 Technical assistance for Risk Management Commissionerate, Feasibility and detailed design for
proposed National Risk Targeting Center and TA for proposed Bangladesh Single Window
Commissionerate
This sub-component will build on the reform momentum in Risk Management, Jobs DPC Series of the
Bank and IFC advisory project TraCED (602137). The activities will cover the following: (a) Capacity
Building: A competency based human resource strategy and succession plan will be required to ensure
that the CRMC is appropriately staffed to carry out a full range of duties. This will include development
of e-learning modules as well as Training of Trainers (ToT) for continuous capacity development
program. There will be provisions for learning from benchmark countries as well; (b) detailed Standard
Operating Procedures (SOP) for the CRMC including the work functions and coordination with local risk
management units to support operationalization; (c) feasibility and detailed design of proposed
National Risk Targeting Center with SOP for coordinated border management; and (d) for NSW
Commissionerate, TA will be provided for stakeholder consultation, visioning, development of
organogram, job description, roles and functions of officials as well as SOP for such collaborative border
management platform to sustain Bangladesh Single Window.

Environmental and Social Management Framework (ESMF) Page | 12

2.5 Technical assistance for Bonded Warehouse modernization
The key focus of this sub-component will be to support NBR in streamlining Bonded Warehouse Policy
and regulations for bond license, renewal, management, audit and reconciliation removing the
disparities between Ready Made Garments and non-RMG sectors It may also support change
management for Customs Bond Management System (CBMS), proposed automation of Duty Drawback
and Exemption Office and addressing reconciliation challenges.
Component 3: Trade Facilitation Agreement (TFA) Implementation (MoC)

3.1: Strengthening of the National Trade Facilitation Committee (NTFC) and development/
implementation of National Trade and Transport Facilitation Action Plan
This sub-component will support establishing the NTFC Secretariat and developing and implementing
the National Trade and Transport Facilitation Action Plan. The NTFC will serve as the primary trade and
transport coordination mechanism in Bangladesh and serve the functions envisioned in the World Trade
Organization (WTO) Trade Facilitation Agreement (TFA). The formation of the NTFC Secretariat will be
critical for supervising and monitoring the TFA implementation of the trade related agencies.
To deliver its mandate as the focal agency for TFA implementation, the MoC will develop and
periodically update the Road Map of TFA implementation of trade related bodies and develop an Action
Plan Matrix. This activity will require the close involvement of NBR as Bangladesh Customs is directly
involved in implementing 36 out of 37 measures under the TFA. The sub-component will also support
studies and review of trade policy, acts, rules, bilateral agreements, and capacity development
programs of related border clearance agencies on TFA measures, e.g. Risk Management, Appeal
Procedure, Sanitary and Phytosanitary (SPS) measures and Technical Barriers to Trade (TBT), Intellectual
Property Rights (IPR), etc. The capacity development program will be informed by a skills assessment to
be carried out under BBIN program.
3.2 Development of Decision Support System for policy analysis, trade statistics and trade negotiations
This sub-component will support a Decision Support System that will provide policy analysis, market
research and trade statistics to support the MoC’s mandate in implementing trade policy including
negotiating various trade agreements. This incorporates the establishment of an institutional
architecture, ICT connectivity and associated skills and capacity building needs.
3.3: Formulation and implementation of National Tariff Policy
This sub-component will support the formulation a National Tariff Policy. A concept note is being
prepared with support from IFC Advisory in this regard. Necessary capacity building of officials will also
be carried out for subsequent policy updating and amendments to the policy.
3.4. Upgrading of the Bangladesh Trade Portal (BTP)
This sub-component will support the enhancement of the Bangladesh Trade Portal, which is a key
element for the successful functioning of National Trade Single Window.
3.5. Training programs on trade facilitation for women traders and entrepreneurs
This sub-component will seek to empower women traders and entrepreneurs and support their
integration into national, regional and global markets through capacity building in capacity building in
trade related regulatory issues. This activity will reflect emerging from pilot programs undertaken under
BBIN.
Component 4: Regional Connectivity Infrastructure (RHD)
4.1: Sylhet-Charkhai-Sheola-Sutarkandi Highway Improvement
This sub-component will upgrade the existing Sylhet - Charkhai - Sheola – Sutarkandi road. This road
section connects Sheola Land Port (financed by BBIN) at Sutarkandi with the Sylhet-Dhaka Highway (N2)

Environmental and Social Management Framework (ESMF) Page | 13

which is part of Asian
Highway 1 and 2. The
project road section is
part a strategic
regional corridor, the
Bangladesh-China-
India-Myanmar
(BCIM) corridor which
extends from (Kolkata,
India to Kunming,
China). Financing this
road section would
complement the WB’s
investments of
Benapole, Bhomra and
Sheola land ports
(transit gateways of
the BCIM), ADB’s
investments in the Figure 2.9: Proposed Sylhet-Charkhai-Sheila-Sutarkandi Road
Dhaka-Sylhet road, and AIIB’s investment in the Sylhet-Tamabil road.
Presently, Gopalganj-Charkhai-Sheola-Sutarkandi is a two-lane carriageway of a regional category road
with a width of 5.5m. The road starts from the Keen bridge point, passes through Gopalganj, Charkhai,
and Sheola and ends at Sutarkandi a border Land Port with India. Overall condition of the road is poor.
From Charkhai the condition is worsen towards border point. In the project, it has been proposed to a
4-Lane Highway and 5.5 m services lane on both sides. 43.10 kilometer flexible & rigid pavement of four
lane highway with international specifications and standard. The work also includes construction of
embankment, land acquisition and resettlement, construction of flyover, underpass, and culverts.
4.2: Technical Assistance (TA) for regional connectivity and policy development
This sub-component will provide technical assistance to help Bangladesh’s preparedness and
subsequently implementation of the Bangladesh-India-Nepal Motor Vehicle Agreement (MVA). This will
entail, inter alia, developing standard operating procedures, ensuring regulatory alignment, provision
of training and awareness programs (government and private sector), and assessment of infrastructure
requirements along the MVA corridors. The component will also assess IT System requirements for the
electronic issue of permits to authorized operators, tracking system, temporary admission compliance
monitoring system, and associated middleware/API integration to connect and share data with other
MVA signatories, etc. The project may also provide support to establish of regional connectivity
secretariat and continuously provide support for organizing meetings, maps and information sharing
within member countries.
Financing will also be extended to develop a pipeline of regional connectivity transport projects through
the provision of feasibility studies, detailed design and environment and social studies. The focus will
be on priority transport corridors not captured under the SASEC umbrella. A comprehensive trade
gateway connectivity assessment will be conducted to improve congested and less developed road
sections towards ports, rail, inland water terminals, international borders, etc. It will be explored if
potential corridors can be developed as greenfield expressways to facilitate trade. Besides, all TA TORs
and deliverables will be in line with WB ESF.

Environmental and Social Management Framework (ESMF) Page | 14

3. POLICY, LEGAL AND REGULATORY FRAMEWORK
3.1 General
This chapter presents a review of the national policy, legal, and regulatory framework relevant to the
environmental and social aspects of the BBIN MPA Program. In addition to the national environmental
and social laws, regulations, and policy.

3.1 Review of Relevant National Environmental Law, Policy and

Regulatory Framework
3.1.1 Relevant National Policies
Governance and management of the environmental and social sectors are molded largely by key specific
policies. The below discussed significant policies directly bear the state of Bangladesh's environment
and social aspects. The discussion also mentioned the applicability of the policies to the proposed
program.
Table 3.1: Summary of Relevant Environmental and Social Policies of the GoB

Policy Key Features Applicability

Bangladesh Climate Change Strategy The GoB prepared the Bangladesh Relevant as the country is vulnerable
and Action Plan (BCCSAP) 2009 Climate Change Strategy and Action to climate change effect.
Plan (BCCSAP) in 2008 and revised it in
2009. This is a comprehensive strategy
to address climate change challenges
in Bangladesh. Bangladesh Climate
Change Strategy and Action Plan built
on and expanded the NAPA. It is built
around the following six themes-
▪ Food security, social protection,
and health to ensure that the
poorest and most vulnerable in
society, including women and
children, are protected from
climate change and that all
programs focus on the needs of this
group for food security, safe
housing, employment, and access
to essential services, including
health.
▪ Comprehensive disaster
management further strengthens
the country’s already proven
disaster management systems to
deal with increasingly frequent and
severe natural calamities.
▪ Infrastructure ensures that existing
assets (e.g., coastal and river
embankments) are well maintained
and fit for purpose. That urgently
needed infrastructure (cyclone
shelters and urban drainage) is put
in place to deal with the likely
impacts of climate change.
▪ Research and Knowledge
management predict that climate
changes likely to scale and timing

Environmental and Social Management Framework (ESMF) Page | 15

 Policy Key Features Applicability

impacts different sectors of the

economy and socioeconomic
groups; to underpin future
investment strategies and ensure
that Bangladesh is networked into
the latest global thinking on climate
change.
▪ Mitigation and low carbon
development to evolve low carbon
development options and
implement these as the country’s
economy grows over the coming
decades.
▪ Capacity building and Institutional
strengthening enhance
government ministries, civil
society, and the private sector to
meet the challenge of climate
change.
National Environment Policy 2018 Bangladesh adopted the National During the different phases of sub-
Environmental Policy (NEP) in 1992 to project development, sector specific
chart a path towards the country's action plan will be adopted based on
development. The NEP 2018 is a the policy for air pollution control,
revision of the NEP 1992 in the new water resource management, public
reality of climate change. The NEP health, ecosystem management, etc.
2018 also outlines a more up-to-date The policy mentions that
understanding of the extent and Environmental Impact Assessments
magnitude of environmental (EIA) should be conducted before
degradation that has become a fact of projects are undertaken.
life in the world in general and in
Bangladesh in particular. The NEP 2018
outlines the problems of population
growth, poverty, illiteracy, lack of
awareness and healthcare services,
limitation of arable land, unplanned
development and urbanization, and
industrialization as the major
impediments to conserving the
environment. The NEP sets out the
basic framework for environmental
action and broad sectoral guidelines
for action. Major elements of the
policy are-
(i) maintaining the ecological
balance for ensuring sustainable
development;
(ii) protection against natural
disasters;
(iii) identifying and controlling
activities that are polluting and
destroying the environment;
(iv) ensuring environment-friendly
development in all sectors;
(v) promoting sustainable and sound
management of natural
resources; and
(vi) active collaboration with
international initiatives related to
the environment.

Environmental and Social Management Framework (ESMF) Page | 16

 Policy Key Features Applicability

The NEP, amongst other aims, seeks to

ensure that transport systems,
including roads and inland water
transport, do not pollute the
environment or degrade resources.
The policy states that environmental
impact assessment should be
conducted before undertaking
projects. The NEP 2018 includes
additional elements addressing
climate change mitigation and
adaptation as key environmental
issues facing the country and
integrating a comprehensive 3R
approach to the massive and growing
industrial and household waste
problem that has swelled along with
the country's urbanization.
National Water Policy, 1999 The policy aims to guide the major Applicable for the preservation of
water sector players to ensure optimal water quality.
development and management of
water. The policy emphasizes efficient
and equitable management of water
resources, proper harnessing and
development of surface and
groundwater, availability of water to
all concerned, and institutional
capacity building for water resource
management. It also addresses issues
like river basin management, water
rights and allocation, public and
private investment, water supply and
sanitation, and water need for
agriculture, industry, fisheries, wildlife,
navigation, recreation, environment,
preservation of wetlands, etc. The
policy has several clauses related to
the project for ensuring environmental
protection.
National Forest Policy, 1994 The National Forest Policy of 1994 is Applicable when considering global
the amended and revised version of warming and the protection of forests.
the National Forest Policy of 1977. The
policy is designed to conserve the
existing forest areas, bring about 20 %
of the country's land area under the
Forestation Programme, and increase
reserve forests by 10 percent per year
to 2015 through coordinated GoB-
NGOs and active participation of the
people.
National Land Use Policy, 2001 The Bangladesh government adopted Applicable as land-use changes from
the National Land Use Policy in 2001, agricultural to road/highway or its
setting out guidelines for improved relevant facility
land-use and zoning regulations. The
main objectives of this policy are to
ensure criteria-based uses of land and
provide guidelines for usage of land for
agriculture, housing, afforestation,
commercial and industrial
establishments, rail and highway, and
tea and rubber gardens. Overall, this

Environmental and Social Management Framework (ESMF) Page | 17

 Policy Key Features Applicability

policy promotes a sustainable and

planned utilization of land.

The main contents of this policy are:

▪ Stopping the high conversion rate of
agricultural land to nonagricultural
purposes;

▪ Utilizing agro-ecological zones to

determine maximum land-use
efficiency;

▪ Adopting measures to discourage

the conversion of agricultural land
for urban or development purposes;

Improving the environmental

sustainability of land-use practices.
National Land Transport Policy, 2004 The Land Transport Policy has been According to the policy, all new roads
formulated in light of the and major improvements, tolled or
Government’s pledge to establish a otherwise, are subject to an
transport system that is safe, cheap, Environmental Impact Assessment
modern, technologically dependable, (EIA).
and environmentally friendly. The
objectives of this policy are:
▪ To introduce long-term network
planning.
▪ To maintain the road network at a
level, this protects the value of the
investment.
▪ To secure a sustainable means of
funding road maintenance.
▪ To improve the management of
traffic.
▪ Management of roadside activities.
▪ To develop an integrated planning
approach in road construction.
▪ To involve the private sector more in
infrastructure, services, and
maintenance.
▪ To sufficiently protect the
environment from the road
construction program
▪ All new roads and significant
improvements will be subjected to
an EIA
▪ Funding will be provided for
mitigation measures

The Government will publish

environmental standards for new
roads and new design standards
addressing environmental issues
8th Five-Year Plan of GoB (July 2020 - This 8th Five Year Plan represents the The broad scale objective and purpose
June 2025) first phase of the country's Perspective of the proposed BBIN-RTTF phase 01
Plan 2041 (PP2041), which aims to project under MPA program of the
bring Bangladesh closer to the goals of
Word Bank is in line with the 8th five-
attaining Upper Middle-Income
Country (UMIC) status, attaining major year plan of GoB among BBIN countries
Sustainable Development Goal (SDG) - requiring concerted efforts to

Environmental and Social Management Framework (ESMF) Page | 18

 Policy Key Features Applicability

targets, and eliminating extreme develop a contemporary trade

poverty by FY2031. In the backdrop of facilitation system, underpinned by a
these factors, the 8th Plan centers on conducive policy environment for
six core themes: 1. Rapid recovery for
international and regional trade.
COVID-19 to restore human health,
confidence, employment, income and
economic activities; 2. GDP growth
acceleration, employment generation,
productivity acceleration and rapid
poverty reduction; 3. A broad-based
strategy of inclusiveness with a view to
empowering every citizen to
participate fully and benefit from the
development process and helping the
poor and vulnerable with social
protection- based income transfers; 4.
A sustainable development pathway
that is resilient to disaster and climate
change; entails sustainable use of
natural resources; and successfully
manages the inevitable urbanization
transition; 5. Development and
improvement of critical institutions
necessary to lead the economy to
UMIC status; 6. Attaining SDG targets
and coping up the impact of Least
Developed Country (LDC) graduation.
National Women Development Policy This policy was developed with the Yes, under component 3 technical
2011 objective to establish equal rights of assistance provided to MoC-WTO cell
men and women in areas to promote women empowerment
of state and public life, to ensure and entrepreneurship is in line with
security and safety of women, to the policy.
ensure the socio-economic, political,
administrative and legal
empowerment and to establish human
rights of women.
National Information and The objective of the National ICT policy Applicable for the all Component,
Communication Technology (ICT) defines in the section D9 that steps will where IAs need to comply with the
Policy 2015 be taken for the reduction of risk on requirement as stated in the policy for
climate change. By the innovation of managing e-waste in the land ports
environmentally friendly green and in the custom houses.
technology initiatives will also be taken
for safe e-waste management, climate,
and disaster management. In addition
to that the policy in section E defines
strategic themes. The section
describes the five strategies for
environment, climate, and disaster
management. Of this provision under
sub-section E9 clearly mentions about
safe management of electronic waste.
National Industry Policy 2016 Chapter 14 of National Industry Policy Applicable for the all Component,
2016 highlighted environment friendly where IAs need to comply with the
Industry management. The policy requirement as stated in the policy for
stated that Government will provide all managing different types of waste in
sorts of co-operation and incentives to the land ports and in the custom
the local and foreign entrepreneur for houses.
managing and processing industry
waste. Besides, industry entrepreneur
must be influenced to follow 3R
(Reduce, Reuse and Recycle) strategy
for waste management.

Environmental and Social Management Framework (ESMF) Page | 19

 Policy Key Features Applicability

National Health Policy, 2019 We are ensuring quality healthcare Applicable, PIUs (BLPA, NBR and MoC-
facilities to everyone (including WTO Cell) will ensure compliance.
emergency health care), exclusively to People will be engaged directly with
the rural communities, without any this project as both Project Affected
discrimination on the basis of gender Persons (PAPs) and workers. Their
and economic status. health issues are one of many key
issues in consideration during the
project implementation.
Child Labor Elimination Policy, 2010 The main objectives of the policy are as Yes, PIUs (BLPA, NBR and MoC-WTO
follows: Cell) should ensure that no child labor
They are withdrawing working children will be engaged at site for construction
from different forms of occupations, or operation works either directly or by
e.g., hazardous work and the worst the sub-contractors. PIUs should
forms of child labor; Providing special include a clause in the subcontractor
emphasis for indigenous and physically agreements prohibiting employment
challenged children to bring them back of child labor.
to the congenial environment;
Planning and implementing different
short-, medium-, and long-term
strategies and programs to eliminate
various forms of child labor.
Rights & Protection of Persons with Deals with disability issues from a Applicable, PIUs (BLPA, NBR and MoC-
Disabilities Act, 2013 human rights perspective and covers WTO Cell) will ensure compliance with
people with disabilities based on their the law.
impairments. Protection of people
with disabilities from violence, abuse,
and discrimination, as well as
establishing their rights and freedoms.
Hazardous Waste (E-Waste) DoE has published the Hazardous Applicable for all the Components
Management Rules, 2021 Waste (E-waste) Management Rules, during construction and operation
2021 under the Bangladesh phase. During the construction,
Environmental Protection Act, 1995. It wastes, spent oils, lubes, will be used
covers the products listed in the for the civil work involved. The
Schedule (home appliances, operation phase of the ports, roads
monitoring and control equipment, and buildings will result hazardous
medical equipment, automatic chemicals and metals.
machines, IT and communication
equipment), and establishes
obligations for producer, dealers,
assemblers, collectors, sellers, and
consumers of the products. The main
provisions of this regulation.
● Defines the roles of
individual stakeholders
involved in the E-waste
management procedure

● Regulates the import export

and handling of E-wastes

Provides an appropriate
documentation process in order to
facilitate the overall waste
Management implementation.
National 3R Strategy for Waste Deals with Sustainable Resource- Yes, under the all four Components
Management, 2020 Efficient Economy with zero waste wastes will be generated.
policy with 3Rs practices (Reduce,
Reuse and Recycling).

Environmental and Social Management Framework (ESMF) Page | 20

3.1.2 Relevant National Environmental and Social Legislations
The main Acts and Regulations guiding environmental and social protection and conservation in
Bangladesh are outlined in Table 3.2 below. The given lists only some most important applicable key
GoB acts, rules, and regulations and their relevance to this project.
Table 3.2: Summary of Applicable Environmental Laws and Regulations of GoB

Act/Rules Key Provisions and Purpose Applicability

Constitution of the People's Bangladesh’s Constitution defines the rights of every This is applicable to ensure the
Republic of Bangladesh citizen irrespective of their ethnicity and religion health and safety of the laborers
where the State is responsible for the provision and project-related persons.
of Basic Necessities for the citizens
Environment Conservation The Environment Conservation Act authorizes the Yes, NBR sub-components and
Act, 1995 DOE to undertake any activity to conserve and BLPA sub-components shall take
enhance the environment's quality and control, environmental clearance from
prevent, and mitigate the pollution. The DOE is DoE.
designated as the regulatory body and enforcement
agency for all environment-related activities. The Act
enables the following critical components of DOE's
remit:

i. declaration of Ecologically Critical Areas;

ii. administration of the procedure for obtaining

Environmental Clearance Certificates for new
industrial projects;

iii. regulation concerning vehicles emitting smoke

harmful to the environment;

iv. environmental regulations for development

activities;

v. standards for quality of air, water, noise, and soils

(including river bed materials) for different areas
and different purposes;

vi. acceptable limits for discharging and emitting

waste; and

vii. formulation of environmental guidelines to

control and mitigate environmental pollution,
conservation, and improvement of the
environment.

Amendments to the ECA in 2000, 2002, and 2010

added significant substantive and procedural scope,
defining the following new areas of authority:

i. ascertaining responsibility for compensation in

cases of damage to ecosystems;

ii. increased provision of preventive measures,

including fines and imprisonment, and the
authority to take cognizance of offenses;

iii. restrictions on polluting automobiles;

iv. restrictions on the production and sale of

environmentally harmful items like polythene
bags;

Environmental and Social Management Framework (ESMF) Page | 21

 Act/Rules Key Provisions and Purpose Applicability

v. obtaining assistance from law enforcement

agencies for environmental actions;

vi. definition and enforcement of punitive measures;

vii. authority to try environmental cases;

viii. prohibition on hill cutting except where

established to be in the national interest;

ix. authority to regulate the management of

hazardous waste produced by shipbreaking yards;

x. prohibition of filling or altering waterways except

when judged to be in the national interest; and

xi. additional powers to compel compliance with

emissions standards.

Environment Conservation These are rules promulgated under the ECA, 1995, Yes, depending on the scope,
Rules, 1997 and amendments and its amendments. The Environment Conservation design and location of the sub-
Rules categorize industries and projects and identify project and for the construction
types of environmental assessment required against of new buildings and other
respective categories of industries or projects. The facilities some of the old
Rules set: buildings/establishments have
to be demolished which poses
▪ The National Environmental Quality Standards substantial risk to the project
(NEQS) for ambient air, various types of water, site. As such NBR and BLPA
industrial effluent, emission, noise, vehicular project may fall under Red
exhaust, etc.; category which require to
conduct both IEE, ESIA, and
▪ The requirement for and procedures to obtain ESMP approved by the DoE and
environmental clearance; and have to deposit prescribe fees
according to the schedule 13 to
▪ The requirement for IEE and EIA according to obtain Environmental Clearance
industrial and other development interventions Certificate (ECC).
categories.

The Environment Conservation Rules, 1997, were

issued by the GOB to exercise power conferred under
the Environment Conservation Act (Section 20), 1995.
Under these Rules, the following aspects, among
others, are covered:

▪ Declaration of ecologically critical areas;

▪ Classification of industries and projects into four

categories;

▪ Procedures for issuing the Environmental

Clearance Certificate (ECC); and

▪ Determination of environmental standards.

Rule 3 defines the factors to be considered in

declaring an 'ecologically critical area’ as per Section 5
of the ECA (1995). It empowers the Government to
declare the area as an Ecologically Critical Areas (ECA)
if it is satisfied that the site’s ecosystem has reached
or is threatened to reach a critical state or condition
due to environmental degradation. The Government
is also empowered to specify which operations or

Environmental and Social Management Framework (ESMF) Page | 22

 Act/Rules Key Provisions and Purpose Applicability

processes may be carried out or may not be initiated

in the ecologically critical area. Under this mandate,
the Ministry of Environment and Forest (MOEF) has
declared Sundarbans, Cox's Bazar-Teknaf Sea Shore,
Saint Martin Island, Sonadia Island, Hakaluki Haor,
Tanguar Haor, Marzat Baor, Gulshan-Baridhara Lake,
Buriganga River, Shitalakhya River, Balu River, Turag
River, Jafflong-Dawki River as ecologically critical
areas and prohibited certain activities in those areas.

Rule 7 of the 1997 ECR categorizes industrial units and

projects into four categories, depending on
environmental impact and location. These categories
are:
▪ Green;

▪ Orange A;

▪ Orange B; and

▪ Red.

The categorization of a project determines the

procedure for issuing an Environmental Clearance
Certificate (ECC). All proposed industrial units and
projects considered low polluting are categorized
under "Green" and shall be granted Environmental
Clearance. These are Orange B for work that requires
Initial Environmental Examination (IEE) and Red for
work that requires full environmental assessment.

A detailed description of those four categories of

industries has been given in Schedule-1 of ECR'97.
Apart from general requirements, for every Red
category proposed industrial unit or project, the
application must be accompanied with a feasibility
report on Initial Environmental Examination,
Environmental Impact Assessment based on
approved TOR by DOE, Environmental Management
Plan (EMP), etc.

Depending upon location, size, and severity of

pollution loads, projects/activities have been
classified in ECR, 1997 into four categories: Green,
Orange A, Orange B, and Red respectively, to nil,
minor, medium, and severe impacts on important
environmental components (IECs). Corresponding
categories of road projects are based on:

Red Category
▪ Considering the project construction activities,
this project falls under the Red category.

Environment Court Act, 2010 The Environment Court Act, 2010, has been enacted According to this Act,
to establish environmental courts in each government can take legal
administrative district of Bangladesh. This Act sets out actions if any environmental
policy for effective pursuance and completion of legal problem or irregularities occurs
proceedings related to environmental crimes. Under due to any sub-project
this Act, the Director General of the DOE has the interventions of NBR, BLPA, and
power to impose heavy penalties on industrial MoC.
polluters who are dumping untreated wastewater
into the environment or not operating their legally
mandated ETPs.

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 Act/Rules Key Provisions and Purpose Applicability

Forest Act 1927 (Amended The Act empowers the government to regulate the Yes, sub-projects may include
2000) felling, extraction, and transport of forest produce in feeling of trees and social
the country. forestry.
Forest Product Transit Rule If it is necessary to remove or transport forest Yes, respective proponents may
2011 products from such government owned land which is have to apply to the local forest
not under the control of the forest department, department if any trees need to
approval has to be obtained by applying to the forest be cut on the premises of the
department in a prescribed form. sub-projects.
The EIA Guidelines for The EIA Guidelines is a handbook defining procedures The Guidelines provide a step-
Industry (1997) for preparing EIAs and reviewing them, ready for the by-step methodology for the
benefit of the development partners, EIA consultants, completion of EIAs.
reviewers, and academicians.
Road Transport Act, 2018 The new Road Transport Act 2018 has finally come Yes, sub-projects of NBR and
into effect at the start of November. After the long- BLPA will use heavy vehicles,
standing Motor Vehicle Ordinance of 1983, the new deploy drivers and operators of
Act introduced a myriad of updated laws added new machineries.
definitions for what constitutes an offense. Most of
the fines and punishments received significant
bumps.
Bangladesh Labor Law, 2006 It is a comprehensive law covering labour issues such Compliance to provisions on
(amendment 2018) as: conditions of service and employment, youth employment standards,
employment, benefits including maternal benefits, occupational health and safety,
compensation for injuries, trade unions and industrial welfare and social protection,
relations, disputes, participation of workers in labor relations and social
company’s profits, regulation of safety of dock dialogue, and enforcement.
workers, penalty procedures, administration and
inspection. Prohibition of employment of
children and adolescents.
This Act pertains to the occupational rights and safety
of factory workers and the provision of a comfortable
environment for working. It also includes rules on
registration of labourers, misconduct rules, income
and benefits, health and fire safety, factory plan. The
amendment of 2018 further ensured the occupational
health and safety rights of the worker by replacing
some of the clauses of 2006 law, such as: paid leave
and associated facilities, parental leave etc.
Bangladesh Labor Rules, 2015 Includes rules on registration of laborers, misconduct Contractors to implement
rules, income and benefits, health and fire safety, occupational health and safety
factory plan measures
Bangladesh National Building The Bangladesh National Building Code (BNBC) sets Yes, it is applicable for NBR sub-
Code (BNBC), 2020 out the constructional responsibilities according to project components which
which the relevant authority of a particular includes construction of new
construction site shall adopt some precautionary office buildings, residential
measures to ensure the safety of the workmen. The buildings, substation generator,
BNBC also stipulates the general duties of the laboratory, warehouse, data
employer to the public as well as workers. center, multistoried buildings,
public plaza , landing centers,
improvement of road etc.
Medical Waste (Management The Government of Bangladesh promulgated the According to these rules, the
and Treatment) Rules 2008 Medical Waste (management and processing) Rule, government can take legal
2008 for processing and management of MW in actions if any environmental
Bangladesh. It was prepared through the active problem occurs due to project
participation of MOHFW to manage medical waste interventions.
and protect the environment properly.
The Medical Waste (Management and Treatment)
Rules 2008 forms the management base of all medical
waste. The rules are applicable only to waste
management facilities/operators, i.e., those involved
in the transportation, treatment, and medical waste
disposal. The law provides for guidance on the
collections, storage treatment, and disposal of

Environmental and Social Management Framework (ESMF) Page | 24

 Act/Rules Key Provisions and Purpose Applicability

medical waste for management facilities/operators.

The institutions or agencies involved in collecting,
transporting, and storage have to obtain
authorization from the Department of Environment.

The existing Environment Conservation Act, 1995 and

the Environment Conservation Rules, 1997 had no
specific laws directly related to management of MW
management. According to Bangladesh Environment
Conservation Act wastes are classified under section
2(1) as “any liquid, solid and radioactive substance
that is discharged, disposed or dumped which may
cause adverse/ negative change to the environment.”
All these procedures were very general for all kinds of
establishments and not specific for the Management
of MW. The shortcoming has been addressed by the
new medical waste rules, 2008.

Broadly the rule has classified the medical waste

(schedule-1) with examples and environment-friendly
management technologies. It also contains
suggestions for using different color bins (schedule-3)
for segregation of medical –waste at source and
symbols to be used on the packaging of medical waste
(schedule-4) for transporting. In schedule -6, the rule
specifies the standard Incineration/ Autoclaving,
standard of liquid waste with permissible limits,
standard of microwaving, standard for deep burial,
and standard for radioactive waste treatment and
disposal, along with other issues related to MWM. The
new medical waste rule has urged for ‘formation of
authority within three months of proclamation. The
authority will be in charge of all activities related to
MWM of their area.

The regulation specified for different (6 nos.) color

bins to be used for segregation of varying MW along
with the specification of the container, standard for
operation of equipment, effluent and emission
standards.
The Water Supply and Regulates the management and control of water Yes, sub-projects of NBR and
Sanitation Act (1996) supply and sanitation in urban areas. BLPA will include construction of
water supply and sanitation
facilities
The Ground Water Describes the management of ground water Yes, construction sites of the
Management Ordinance resources and licensing of tube wells sub-projects may require deep
(1985) tube wells for meeting up water
use.
Bangladesh Wildlife The Act (Schedule 1 and 2) protects 1,307 species of Yes, some of the listed
(Protection and Preservation) plants and animals, including 32 species of amphibian, endangered species may be
Act 2012 154 species of reptile, 113 species of mammal, 52 present in the sub-component
species of fish, 32 species of coral, 137 species of areas.
mollusk, 22 species of crustacean, 24 species of insect,
six species of rodent, 41 species of plant and 13
species of orchid. Of these, eight amphibian, 58
reptile, 41 bird, and 40 mammal species are listed as
endangered in the IUCN Red Data Book (2000,
updated in 2015).
Biodiversity Act, 2017 It provides for creating the National Committee and Yes, all sub-project components
the Biodiversity Management and Surveillance need to include local city
Committees at local levels (i.e., Districts, Upazilas, corporation committees, so that
Municipalities, and Unions). In general, all these

Environmental and Social Management Framework (ESMF) Page | 25

 Act/Rules Key Provisions and Purpose Applicability

committees are mandated to assist the Government they can monitor project impact
in implementing the National Biodiversity Strategy on the local biodiversity.
and Action Plan (NBSAP) and visiting the biodiversity
enriched areas in their respective territories; and
monitoring the progress of implementation NBSAP.
Public Procurement Rules Applies to the procurement of goods, works, or The PPR (2008) will be followed
(2008) services by any government, semi-government, or any during the procurement process
statutory body established under any law; includes of the subprojects
measures regarding the safety, security, and
protection of the environment in construction works;
requires contractors to take all reasonable steps to
safeguard the health and safety of all workers on site,
protect the environment on and off the site, and avoid
damage or nuisance to persons or property of the
public or others
Rules for Removal of Wrecks Rules for removal of wrecks and obstructions Yes, if obstruct natural
and Obstructions in inland canals/rivers or any other
Navigable Water Ways (1973) natural water ways (includes
seasonal water bodies).
Acquisition and Requisition The principal legal instrument governing land Relevant to the sub-project
of Immovable Property Act of acquisition in Bangladesh is the Acquisition and components of BLPA. In case of
2017 Requisition of Immovable Property Act (ARIPA) of NBR sub-components no land
2017. The ARIPA 2017 requires that compensation be acquisition is required but, if
paid for (i) land and assets permanently acquired Land Acquisition (LA) and
(including standing crops, trees, houses); and (ii) any rehabilitation is required then
other damages caused by such acquisition. The Act NBR will duly prepare a LAP and
also provides for the acquisition of properties Resettlement Action Plan (RAP)
belonging to religious organizations like mosques, following the ARIPA 2017
temples, pagodas and graveyards if they are acquired requirement and ESS-5 of the
for public interest. World Bank.
Right to Information Act, The Act makes provisions for ensuring free flow of Yes, provision for public
2009 information and people’s right to information. The information disclosure will be
freedom of thought, conscience and speech is ensured in all phases of the
recognized in Bangladesh Constitution as a project development life cycle.
fundamental right and the right to information is an
alienable part of it. The right to information Act
ensures that transparency and accountability in all
public, autonomous and statutory organizations and
in private organizations run on government or foreign
funding shall increase, corruption shall decrease and
good governance shall be established.
Bangladesh Water Act 2013 As per this Act, all forms of water (e.g., surface water, Applicable if the infrastructure
ground water, sea water, rain water and atmospheric reconstruction/rehabilitation
water) within the territory of Bangladesh belong to activities impede the natural
the government on behalf of the people. Without flow of rivers, canals or any
prior permission issued by the Executive Committee seasonal water bodies. In such
(EC), no individuals or organizations will be allowed to cases prior permission from the
extract, distribute, use, develop, protect, and EC will be required.
conserve water resources, nor they will be allowed to
build any structure that impede the natural flow of
rivers and creeks.
The Noise Pollution Control The Noise Pollution Control Rules have been Applicable since minor to
Rules, 2006 established to manage noise-generating activities moderate noise emission is
which have the potential to impact the health and expected from project activity
wellbeing of workers and the surrounding during construction phase
communities. under the different
components.
The Antiquities Act (1968) Describes the preservation of cultural heritage, It may be applicable to the sub-
historic monuments and protected sites. It projects areas in case it
identifies elements of cultural,
historic and protected values.

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 Act/Rules Key Provisions and Purpose Applicability

The Acquisition and It is the principal legislation governing eminent The nature of the civil works
Requisition of Immovable domain land acquisition in Bangladesh. The Act related to the project will entail
Property Act 2017 (ARIPA) requires that compensation be paid for: (i) land and the land acquisition and
assets permanently acquired (including standing subsequent economic and
crops, trees, houses); and (ii) any other damages physical displacement. ARIPA
caused by such acquisition. The Act also provides the 2017 defines the land
acquisition of properties belonging to religious acquisition process and contains
organizations like mosques, temples, pagodas, and pertinent information related to
graveyards if acquired for the public interest. The a compensation payment to
Ministry of Land (MoL) is the authorized government titleholders.
agency to undertake the process of land acquisition.
The MoL partly delegates its authority in relation to
land acquisition to the Commissioner at Divisional
level and to the Deputy Commissioner at the District
level. The Deputy Commissioners (DC) is empowered
by the MoL to process land acquisition under the Act
and pay compensation to the legal owners of the
acquired property. Khas (government-owned land)
should be acquired first when a project requires both
Khas and private land. If a project requires only khas
land, the land will be transferred through an inter-
ministerial meeting following the acquisition proposal
submitted to DC or MoL. The Government of
Bangladesh does not have a national policy on
involuntary resettlement. The new Act of 2017 has
incorporated specific provisions to address social and
economic impacts that were not previously included
in the 1982 land acquisition ordinance. Therefore,
these provisions under the new law would reduce the
gaps between the national legislative framework of
the government and WB policies.
Bangladesh Labor Act, 2006 The Act provides the guidance on employer’s extent Yes, The policy with the relevant
(amended in 2013, 2015 and of responsibility and workers’ extent of rights to acts and rules are applicable to
2018) compensation in case of injury by accident while the sub-project activities of NBR
working. It also gives a general framework for which involves demolition,
Occupation Health and Safety (OHS), welfare, and construction /re-construction/
working conditions of workers. renovation/ widening of
A number of sections provide the duties of employers, customs house, training
including conditions of service and employment academy, buildings, roads and
(sections 3-33), working hours and leave (sections other utility infrastructures
100-119), payment of wages (sections 120-137), requiring labor from local and
determination of minimum wage (sections 138-149), external areas. In BLPA
and compensation for injuries to workers (sections components also have some
150-174). The Act also specifies provisions on activities will require labour
maternity benefits (sections 45-50), health (sections from local and external areas.
51-60), safety (sections 61-88), and labor welfare
(sections 89-99).
This is a comprehensive legislation and addresses
three area-
(i) Conditions of service and employment including
wages and payment, the establishment of
Wages Boards, employment of young people,
maternity benefits, working hours and leave;

(ii) Health, safety, hygiene, and welfare, and

compensation for injury;

(iii) Trade unions and industrial relations.

The law applies to all “establishments” which are

defined broadly to include, shops, hotels, restaurants,
factories (though these must employ more than five

Environmental and Social Management Framework (ESMF) Page | 27

 Act/Rules Key Provisions and Purpose Applicability

laborer’s), plantations, docks, transport services,

construction sites, and “any premises in which
laborers are employed for the purposes of carrying on
any industry”. It covers contractors (and its operations
at construction sites) however it is not clear if the law
applies to development project organizations which
are "ad hoc" and with co-terminus staff with the
project.
Constitutional Rights of the The Constitution of Bangladesh ensures affirmative Applicable, under the
Tribal People action for small ethnic communities and prohibits component 1, for the
discrimination inter alia on the grounds of race, implementation of the
religion, or place of birth, Article 23A of which construction work in different
provides, “the State shall take steps to protect and land port locations.
develop the unique local culture and tradition of the
tribes, minor races, ethnic sects, and communities.” It
also spells out in Article 28 (4), “nothing in this Article
shall prevent the State from making special provision
in favor of women or children or for the advancement
of any backward section of citizens.”

3.2 Applicable International Treaties Signed by the GoB

Bangladesh has signed most international treaties, conventions, and protocols on the environment,
pollution control, biodiversity conservation, and climate change, including the RAMSAR Convention, the
Bonn Convention on Migratory Birds, the Rio de Janeiro Convention on Biodiversity Conservation, and
the Kyoto Protocol on Climate Change. An overview of the relevant international treaties signed by GoB
is shown in Table 3.3.
Table 3.3: International Conventions, Treaties, and Protocols Signed by Bangladesh

Treaty Year Brief Description/Relevance to NBR/BLPA

Paris Agreement (under UNFCC) 2015 Global temperature rise this century well below 2 degrees
(Paris) Celsius above pre-industrial levels.
Convention on Biological Diversity, 1992 Promote the sustainable use of its components; and
commonly known as CBD encourage fair and equitable sharing of benefits arising from
genetic resources.
Cartagena Protocol on Biosafety to 2000 To help protect the environment and ensure the safe handling,
the Convention on Biological Diversity transport and use of living modified organisms (LMOs)
Nagoya Protocol on Access to Genetic 2010 Nagoya Protocol is a supplementary agreement to the CBD. It
Resources and the Fair and Equitable provides a transparent legal framework for the
Sharing of Benefits Arising from their implementation of one of the three objectives of the CBD
Utilization to the Convention on
Biological Diversity
Protection of birds (Paris) 1950 Protection of birds in wild state Broadly applicable for birds in
and around the project influence area; mitigation measures
included in ESMP address potential impacts on birds as well.
Ramsar Convention 1971 Protection of wetlands. Broadly applicable for wetlands in and
around the project influence area; mitigation measures
included in ESMP address potential impacts on wetlands and
associated resources as well.
Protocol on Waterfowl 1982 Amendment of Ramsar Convention to protect specific habitats
Habitat for waterfowl. Broadly applicable for wetlands in and around
the project influence area; mitigation measures included in
ESMP address potential impacts on wetlands and associated
ecological resources as well.
World Cultural and Natural Heritage 1972 Protection of major cultural and natural heritages. Not
(Paris) applicable since no major cultural or natural monuments are
known to exist in the project influence area.

Environmental and Social Management Framework (ESMF) Page | 28

 Treaty Year Brief Description/Relevance to NBR/BLPA
CITES convention 1973 Ban and restrictions on international trade in endangered
species of wild fauna and flora. Not directly relevant to the NBR
since the project does not involve in any international trade of
endangered species of wild fauna and flora. General
restrictions have however been included in the Environmental
Code of Practice.
Bonn Convention 1979 Conservation of migratory species of wild animals. Broadly
applicable to the migratory birds in and around the project
influence area. Project activities are not likely to have any
significant impacts on these species; precautionary measures
have nonetheless been included in ESMP.
Prevention and Control of 1974 Protect workers against occupational exposure to carcinogenic
Occupational hazards substances and agents. Broadly applicable to the construction
and O&M activities under the project. Appropriate mitigation
and protective measures will be included in the ESMP.
Occupational hazards due to air 1977 Protect workers against occupational hazards in the working
pollution, noise & vibration (Geneva) environment.
Broadly applicable to the construction and O&M activities
under the project.
Appropriate mitigation and protective measures will be
included in the ESMP.
Occupational safety and health in 1981 Prevent accidents and injury to health by minimizing hazards
working in the working environment. Broadly applicable to the
environment (Geneva) construction and O&M activities under the project.
Appropriate mitigation and protective measures will be
included in the ESMP.
Occupational Health Services 1985 To promote a safe and healthy working environment, broadly
applicable to the construction and O&M activities under the
project appropriate mitigation and protective measures will be
included in the ESMP.
Convention on oil pollution damage 1969 Civil liability on oil pollution damage from ships.
(Brussels) Not applicable since no oil carrying cargos are involved in the
proposed project.
Safety in use of chemicals during work 1990 Occupational safety of use of chemicals in the work place.
Broadly applicable to the construction and O&M activities
under the project.
Appropriate mitigation and protective measures will be
included in the ESMP.
Convention on oil pollution 1990 Legal framework and preparedness for control of oil pollution.
Broadly applicable to the construction and O&M activities
under the project.
Appropriate mitigation and protective measures will be
included in the ESMP.
UN framework convention on climate 1992 Regulation of greenhouse gases (GHGs) emissions. Broadly
change (Rio de Janeiro) applicable to the construction and O&M activities under the
project. Appropriate mitigation and protective measures will
be included in the ESMP to minimize emissions of GHGs.
International Convention on Climate 1997 International treaty on climate change and emission of
Changes (Kyoto Protocol) greenhouse gases.
Broadly applicable to the construction and O&M activities
under the project.
Appropriate mitigation and protective measures will be
included in the ESMP to minimize emissions of GHGs.

3.3 World Bank’s Environmental and Social Framework (ESF)

Since October 01, 2018, all WB-funded Investment Project Financing (IPF) are required to follow the ESF
consisting of ten (10) Environmental and Social Standards (ESS). These ESSs set out their requirement
for the borrowers to identify and assess environmental and social risks and impacts associated with any
project. The ESSs support the borrowers in achieving good international practice relating to
environmental and social sustainability, assisting them in fulfilling their national and international

Environmental and Social Management Framework (ESMF) Page | 29

environmental and social obligations, enhancing transparency and accountability, and ensuring
sustainable development outcomes through ongoing stakeholder engagement.
The proposed program's key environmental and social risks and impacts are anticipated to occur mainly
during construction and within existing footprints. Key results include: (i) health & safety of workers and
communities within the corridor and along the transport routes of construction supplies, materials, and
equipment; (iii) exposure of the population in urban and semi-urban centers along the project area and
transport routes to noise, vibrations, air pollution and safety risks; (iv) siltation and sedimentation of
waterways close to the physical works; (v) land acquisition along the expanded ROW; (vi) physical
displacement of structures; (vii) temporary economic displacement of some vendors and businesses
along the ROW; and, (viii) increased risk of SEA/SH and road accidents.
All ESSs will be applicable in the project, except the ESS 9: Financial Intermediaries, WB’s legal policies
for Projects on International Waterways (OP 7.50) as there is no International Waterways within project
areas, and Project Disputed Areas (OP 7.60) as there is no dispute on project area land. The overall
environmental and social risk rating for the first phase of the Program is ‘High’ due to the scale of civil
works and physical footprints. If ESRC is changed, this will require WB’s approval and updating of this
ESMF. The section below discusses the relevance of ESF Policy, each of the ten standards (ESS1 to 10),
and associated Directive; their requirements are tabulated in Table 3.4. It also discusses the relevance
and requirements relating to other guidance notes of the World Bank. If the requirements of Bangladesh
law differ from those of ESF, the more stringent requirements will apply.
Table 3.4: WB ESS Requirements and Relevance to the Project

World Bank ESS

Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

ESS-1 Identify, assess, evaluate, E&S risk and impacts should Relevant. ESMF has been prepared;
Assessment and and manage the be considered in the which provides guidelines for
Management of environmental and social environmental and social screening of targeted sub-project
Environmental and risks and impacts in a assessment. The use and components for environmental and
Social Risks and manner consistent with the strengthening of the social risks and based on the E&S
Impacts ESF. Adopt differentiated Borrower’s ESF of the screening results, further sub-
measures so that adverse evaluation, development, project specific ESIAs and ESMPs
consequences do not fall and implementation of will be prepared during the
disproportionately on the World Bank financed implementation of the project. The
disadvantaged or projects where appropriate. ESMF also provides
vulnerable, and they are recommendations on the capacity
not disadvantaged in Relevant GoB Laws/ building of the implementing
sharing development Regulation agencies’.
benefits and opportunities (a) ECA 1995
(b) ECR 1997 and EIA
guidelines for
Industries
ESS-2 Promote safety and health Requirements for the Relevant. During the construction
Labor-and-Working- at work. Promote fair Borrower to prepare and and operation of different
Conditions treatment, non- adopt labor management infrastructures and roads, the
discrimination, and equal procedures. Provisions on project will involve the employment
opportunity for project the treatment of direct, of direct workers and contracted
workers. Protect project contracted, community, and workers.
workers, with particular primary supply workers and The project has developed a
emphasis on vulnerable government civil servants. separate Labor Management
workers. Prevent the use of Requirements on terms and Framework, which covers the issues
all forms of forced labor conditions of work, non- and concerns of laborers and
and child labor. Support discrimination, equal workers employed/likely to be
the principles of freedom opportunity, and workers’ employed by the PIUs.
of association and organizations. Provisions on The salient points will be addressed
collective bargaining of child labor and forced labor. in the ESMF and appropriate
project workers in a Requirements on requirements will be incorporated in
manner consistent with occupational health and Management of Contractors

Environmental and Social Management Framework (ESMF) Page | 30

 World Bank ESS
Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

national law. Provide safety, in keeping with the documents. A separate workers
project workers with World Bank Group’s GRM will be developed as per the
accessible means to raise Environmental, Health, and requirement of ESS2. The project
workplace concerns. Safety Guidelines (EHSG). will also provide training on waste
management practices and OHS
Relevant GoB related practices to the PIU’s
Laws/Regulation officials, personnel and labors.
a) Labor Law 2006
(Amendment 2013)
b) Occupational Health
and Safety Policy 2013
c) Public Procurement
Rule 2008
ESS-3 Promote the sustainable Requires an estimate of Relevant. The ESMF will assess the
Resource-Efficiency- use of resources, including gross greenhouse gas potential pollution impact and
and-Pollution- energy, water, and raw emissions resulting from provide recommendations for
Prevention-and- materials. Avoid or project (unless minor), systemic improvement of solid
Management minimize adverse impacts where technically and waste management including e-
on human health and the financially feasible. waste and general construction
environment caused by Requirements for managing waste. The implementing agency
pollution from project wastes, chemical and NBR, MoC and BLPA will ensure the
activities. Avoid or mitigate hazardous materials, and execution of the waste
project-related emissions provisions address historical management plans throughout the
of short and long-lived pollution. ESS-3 refers to project implementation period.
climate pollutants. Avoid or national law and Good These implementing agencies will
minimize the generation of International Industry also ensure green and resilient
hazardous and non- Practice, in the first instance design for
hazardous waste. Minimize the World Bank Groups’ reconstruction/renovation of sub-
and manage the risks and EHSGs. Furthermore, the project infrastructure along with an
impacts associated with sub-projects are expected to action plan to achieve expected
pesticide use. Requires be in line with standards outcomes in having safe running
technically and financially which is more stringent (GoB water; functioning and clean
feasible measures to legislation vs WBG EHSGs) toilettes with adequate sewage
improve efficient energy management systems, liquid waste
consumption, water, and processed before discharge.
raw materials and With respect to Pollution
introduces specific Management, based on past
requirements for water project experiences by BLPA, MoC
efficiency where a project and NBR, the project will develop,
has high water demand. as part of the ESA process,
prevention and management
measures to offset risks and
impacts of pollution from potential
sources such as dust and emission
from operation of hot-mix and
batching plants, crushers,
construction and haulage vehicles,
material and spoil stockpile;
effluents and wastewater from
labor camps, construction camp;
spillage or leakage during handling
of chemical admixtures, hazardous
materials like bitumen, high
strength diesel, used oil, battery
wastes etc.; and disposal of non-
hazardous wastes (municipal
wastes) generated during project
implementation period.

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 World Bank ESS
Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

ESS-4 Anticipate or avoid adverse Requirements on The ESS is relevant.

Community-Health- impacts on the health and infrastructure, considering In the NBR/BLPA sub-project
and-Safety safety of project-affected safety and climate change components there is likely to be i)
communities during and applying the concept of road excavation, use of vibratory
project life-cycle from universal access, where equipment, construction debris
routine and non-routine technically and financially handling and disposal etc. during
circumstances. Promote feasible. Requirements on construction; ii) high likelihood of
quality, safety, and climate traffic and road safety, direct exposure to increased
change considerations in including road safety construction related traffic and
infrastructure design and assessments and equipment especially at road
construction, including monitoring. sections traversing settlement area
dams. Avoid or minimize Addresses risks arising from with limited carriageway/roadway
community exposure to impacts on provisioning and width, and sensitive receptors such
project-related traffic and regulating ecosystem as schools, religious place, health
road safety risks, diseases, service. Measures to avoid center/hospitals; iii) high dust
and hazardous materials. or minimize the risk of levels from earthworks/slope
Have in place adequate water-related, cutting, high noise and emission
measures to address communicable, and non- level from traffic congestion and
emergency events. Ensure communicable diseases. idling of vehicles;
that safeguarding Requirements to assess risks and iv) influx of migrant workers
personnel and property are associated with security could potentially cause local
carried out to avoid or personnel and review and discomfort or potential conflicts
minimize risks to the report unlawful and abusive with local people.
project-affected acts to relevant authorities. Sub-project specific ESIAs and
communities. ESMPs for BLPA, MoC and NBR with
GoB Laws and Regulation relevant mitigation measures and
a) National Road monitoring plan will be prepared
Transport Act for the construction/operation
b) ECR 1997 phase of the project;
c) BLA 2006 Considering the potential SEA/SH
d) Public Procurement risks of the project interventions
Rule,2008 Life and Fire Safety (LF&S)
e) Water Act 2013 measures, Emergency Response
and Evacuation Plan, Capacity
Building and Training measures for
in-house staff in accordance with
IFC LF&S good practices and
relevant GRM will be included in
the ESMF and executed by the PIU.
Also, this ESS will include the risks
of COVID-19 and their respective
initiatives to limit its spread.
ESS-5 Avoid or minimize Applies to permanent or A separate RPF and RAP has been
Land-Acquisition- involuntary resettlement temporary physical and prepared to address ESS5. The land
Restrictions-on-Land- by exploring project design economic displacement will be required for widening, up-
Use-and-Involuntary- alternatives. Avoid forced resulting from different gradation works in identified sub-
Resettlement eviction. Mitigate types of land acquisition and projects and possibly rehabilitation
unavoidable adverse restrictions on access. It works, curve/geometric
impacts from land does not apply to voluntary improvements, blind spots,
acquisition or restrictions market transactions, except construction of markets and other
on land use by providing where these affect third infrastructures, etc. Hence impacts
compensation at parties. Provides criteria for on land, private, and community-
replacement cost and “voluntary” land donations, owned assets, including structures,
assisting displaced persons sale of community land, and trees, and crops within existing and
in their efforts to improve, parties obtaining income proposed ROW, are likely. Physical
or at least restore, from illegal rentals. Prohibits and economic displacement, too, is
livelihoods and living forced eviction (removal very likely. The guideline provided
standards to pre- against the will of affected in the RPF associated with this
displacement levels or to people, without legal and ESMF will be followed for this
levels prevailing before the other protection including all project to provide appropriate

Environmental and Social Management Framework (ESMF) Page | 32

 World Bank ESS
Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

beginning of project applicable procedures and compensation to title and non-title

implementation, principles in ESS5). Requires holders.
whichever is higher. that acquisition of land and
Improve living conditions assets is initiated only after The project is not expected to
of poor or vulnerable payment of compensation require any land acquisition nor
persons who are physically and resettlement has restriction use of land as
displaced by providing occurred. Requires Government owned land will be
adequate housing, access community engagement and used for NBR sub-project
to services and facilities, consultation, disclosure of components. In case the sub-
and security of tenure. information, and a grievance project components cause any
Conceive and execute mechanism. adverse impacts/displacement to
resettlement activities as squatters/informal settlers,
sustainable development GoB Laws and regulation restoration plan shall be prepared
programs. Acquisition and Requisition and adopted as per the RPF
of Immovable Property Act, prepared for the sub-project.
2017
ESS-6 Protect and conserve Requirements for projects Site clearance activities for road
Biodiversity- biodiversity and habitats. affecting areas that are and building constructions will
Conservation and Apply the mitigation legally protected designated involve removing vegetation and
Sustainable hierarchy and the for protection or felling of trees. In such cases, site-
Management of precautionary approach in regionally/internationally specific plantation plan will be
Living Natural the design and recognized to be of high prepared in addition to the ESMP to
Resources implementation of projects biodiversity value. The compensate loss of trees. However,
that could impact requirements for sustainable proposed construction works likely
biodiversity. To promote management of living to have no such significant impacts
the sustainable natural resources, including on the natural habitats nor cause
management of living primary production and harm to the biodiversity. No
natural resources. harvesting, distinguish Protected Area have been
between small-scale and identified during the project
commercial activities. preparation. However, sub-
Provisions relating to projects ES screening will further
primary suppliers, where a investigate presence of threatened
project purchases natural animals and significant natural
resource commodities, habitats. Presence of such PA,
including food, timber, and threatened species or natural
fiber. habitats will be managed through
appropriate mitigation measures
following the ESS6.
ESS-7 Ensure that the Applies when the Indigenous Not relevant to this project. Hence
Indigenous- development process Peoples are present or have no differential provisions will be
Peoples/Sub-Saharan fosters full respect for a collective attachment to required to address the impacts on
African Historically affected parties’ human the land, whether they are these households. However, if any
Underserved rights, dignity, aspirations, affected positively or SEC is identified during project
Traditional Local identity, culture, and negatively regardless of implementation, a separate
Communities natural resource-based economic, political, or social SEVCDF followed by a SEVCDP will
livelihoods. Promote vulnerability. The option to be prepared.
sustainable development use different terminologies
benefits and opportunities for groups that meet the
accessible, culturally criteria set out in the
appropriate, and inclusive. Standard. The use of
Improve project design and national screening
promote local support by processes, providing these
establishing and meet World Bank criteria
maintaining an ongoing and requirements. Coverage
relationship based on of forest dwellers, hunter-
meaningful consultation gatherers, pastoralists, and
with affected parties. other nomadic groups.
Obtain the Free, Prior, and Requirements for
Informed Consent (FPIC) of meaningful consultation
affected parties in three tailored to affected parties

Environmental and Social Management Framework (ESMF) Page | 33

 World Bank ESS
Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

circumstances. Recognize, and a grievance mechanism.

respect, and preserve the Requirements for a free,
culture, knowledge, and prior and informed consent
practices of Indigenous process in three
Peoples and provide them circumstances.
with an opportunity to
adapt to changing
conditions in a manner and
in a timeframe acceptable
to them.
ESS-8 Protect cultural heritage Requires a chance finds It is not sure to have any ancient
Cultural-Heritage from the adverse impacts procedure to be established. monuments and/or archaeological
of project activities and Recognition of the need to site(s), protected, and religious
support its preservation— ensure peoples’ continued structures/shrines of local
Address cultural heritage access to culturally importance. This ESMF has
as an integral aspect of important sites and the need suggested a guideline to address
sustainable development. for confidentiality when the ESS8. In case of any chance
Promote meaningful revealing information about findings, chance find procedures
consultation with cultural heritage assets that will be incorporated in the ESMP
stakeholders regarding would compromise or and chance find clauses will be
cultural heritage. Promote jeopardize their safety or incorporated in work contracts
the equitable sharing of integrity. Requirement for with contractors.
benefits from the use of fair and equitable sharing of
cultural heritage. benefits from the
commercial use of cultural
resources. Provisions of
archaeological sites and
materials, built heritage,
natural features with
cultural significance, and
moveable cultural heritage.

Relevant GoB Laws/

Regulation
(a) National Culture Policies
(b) Antiques law 1968
ESS-9 Sets out how Financial Financial Intermediaries (FIs) Not relevant as there is no financial
Financial- Intermediaries (FI) will to have an Environmental intermediary involved.
Intermediaries assess and manage and Social Management
environmental and social System (ESMS) - a system for
risks and impacts identifying, assessing,
associated with the managing and monitoring
subprojects it finances. the environmental and social
Promote sound risks and impacts of FI
environmental and social subprojects on an ongoing
management practices in basis. FI to develop a
the subprojects the FI categorization system for all
finance. Promote good subprojects, with special
environmental and sound provisions for subprojects
human resources categorized as high or
management within the FI. substantial risk. FI borrowers
to conduct stakeholder
engagement in a manner
proportionate to the risks
and impacts of the FI
subprojects.
ESS-10 Establish a systematic Requires stakeholder A separate SEP has been prepared
approach to stakeholder engagement throughout the to address ESS10.
Stakeholder- engagement that helps project life cycle, and Relevant as the project will involve
Engagement-and- Borrowers identify preparation and a wide variety of stakeholders

Environmental and Social Management Framework (ESMF) Page | 34

 World Bank ESS
Relevance to the sub-project/
Policies, Standards, Objectives Requirements
project
Directives

Information- stakeholders and maintain implementation of a during its project cycle that are
Disclosure a constructive relationship Stakeholder Engagement associated with activities under
with them. Assess Plan (SEP). Requires early other components of the project
stakeholder interest and identification of such as Road Safety.
support for the project and stakeholders, both project-
enable stakeholders’ views affected parties and other The project will ensure:
to be considered in project interested parties, and I) Relevant stakeholders for the
design. Promote and clarification on how effective project are correctly identified.
provide means for effective engagement takes place. II) Stakeholders have been
and inclusive engagement Stakeholder engagement to consulted during the preparation of
with project-affected be conducted in a manner the SEP for the duration of the
parties throughout the proportionate to the nature, project.
project life-cycle. Ensure scale, risks and impacts of (III) Stakeholders’ engagement plan
that appropriate project the project and appropriate has been prepared to follow during
information is disclosed to to stakeholders’ interests. the implementation of the project.
stakeholders in a timely, Specifies what is required for
understandable, information disclosure and
accessible, and appropriate to achieve meaningful
manner. consultation.

GoB Laws/Regulation
No Specific Policy or
Legislation identified
World Bank’s The document provides guidelines to address issues and Applicable to all activities of
Guidance note on risks arising from influx of migrant labor leading to gender- project, as civil works are envisaged
managing the risks of based violence, forced labor etc. especially focusing on in the subprojects by BLPA/NBR.
adverse impacts Sexual Exploitation and Abuse (SEA) and Sexual Harassment However, risks of GBV/SEA/SH will
on communities from (SH) in civil works sites. be moderate due to the use of local
temporary project workers.
induced labor influx,
2016
ESF/Safeguards This note was issued on April 7, 2020 and includes links to Applicable to all activities of project
Interim Note: Covid- the latest guidance as of this date (e.g., from WHO). Given during COVID-19 pandemic if it
19 considerations in the COVID-19 situation is rapidly evolving, when using this intensifies during the design,
construction/civil note it is important to check whether any updates to these construction and operation of the
works projects. external resources have been issued. This interim note is project.
intended to provide guidance to teams on how to support
Borrowers in addressing key issues associated with COVID-
19 and consolidates the advice that has already been
provided over the past month. As such, it should be used in
place of other guidance that has been provided to date.
General EHS The General EHS Guidelines contain information on cross- Yes
Guidelines, April cutting environmental, health, and safety issues
2007, IFC potentially applicable to all industry sectors.
EHS Guidelines for The EHS Guidelines contain the performance levels and Yes
Construction measures that are considered to construction materials
Materials Extraction, extraction activities such as aggregates, limestone, slates,
April sand, gravel, clay, gypsum, feldspar, silica sands, and
2007, IFC quartzite.

Environmental and Social Management Framework (ESMF) Page | 35

3.4 Classification of the Project According to the Environment
Conservation Rules (ECR) and Requirement for Environmental
Clearance Certificate (ECC)
The legislations relevant for environmental assessment for BBIN-MPA program components are the ECA
1995 and the ECR 1997, and subsequent amendments . In order to set an illustrative directive for abiding
by the Act, Bangladesh Government through the ECR 1997 and its subsequent amendments, as specified
in rule 7(2), lists the different types of industrial projects into four categories namely, Green, Orange A,
Orange B, or Red, based on severity of its potential environmental impacts. Environmental clearance
can be granted at various tiers depending on the category of project to which an industrial activity
belongs. The procedure and required documents for obtaining environmental clearance in favor of each
category have also been presented by the DoE. As part of a government entity, BLPA, NBR, and MoC-
WTO Cell of the BBIN-MPA program are obliged to abide by all these Acts and rules, in addition of other
GoB Acts, rules or guidelines.
As per ECR 1997 amended 2010and subsequent amendments, due to the planned project interventions
and the nature of activities, the BBIN-MPA program, Phase 1 in Bangladesh falls under Red category and
ESIA will be required for upgrading existing inland port facilities at Benapole, Bhomra, Burimari
(Component 1, BLPA); construction of several multi-storied buildings (NBR will construct a multi-storied
residential building, Bungalow, office building, Multipurpose Hall, Dormitories) school building, cyclone
shelters, markets, local government office building, etc.) in the residential/commercial complex area
under the customs house and training academy (Component 2, NBR. It is the responsibility of the PIUs
i.e., BLPA, NBR and, MoC-WTO Cell and RHD to conduct ESIA in accordance with the ESMF and get ECC
from DoE. ESIA study and Environment clearance will be obtained by the respective PIUs from the DG,
DoE.
The environmental clearance procedure for Red Category projects can be summarized as follows:
Application to DoE→ Obtaining Site Clearance → Applying for Environmental Clearance → Obtaining
Environmental Clearance → Clearance Subject to Annual Renewal.

3.5 Gap Analysis of World Bank Requirements and National Laws

A gap analysis between WB’s ESF and GoB Regulations was conducted as part of the E&S capacity
assessment of the BBIN-MPA program in light of the Overview Assessment of Bangladesh's Country
Framework for Addressing Environmental Risks and Impacts of Development Projects (September 2021).
The results of the gap analysis indicated the Bangladesh EIA System has a few material gaps with respect
to the WB ESS1.
Foremost among these are: (i) BD national laws does not cover many of the issues relating to other WB
ESSs; (ii) the stakeholder engagement during the EIA study is almost non-existent or very limited,
needless to say, that there is no requirement to engage stakeholders during construction; (iii) it does not
emphasize the application of mitigation hierarchy in selecting mitigation measures; (iv) it recognizes only
Initial Environmental Examination (IEE) and Environmental Impact Assessment (EIA) and does not
provide for other assessment instruments, particularly Strategic Environmental Assessment (SEA),
Regional Environmental Assessment (REA), Cumulative Impact Assessment (CIA); and, (v) it does not
require analysis of alternatives and associated facilities. It has also a few problems of its own when
compared to a standard EIA system, including: (i) it does not provide any formal definition of the projects
to be required the Environmental Clearance--the law only refers to "industry" and "industrial units"; (ii)
the screening process is inadequate--there is no procedure or criteria for determining which category a
project would fall into; and (iii) it does not have formal procedure for compliance monitoring and
reporting. Although there are suggestions in the EIA Guidelines on these issues, the Guidelines does not
have the same compelling effect as the force of law or regulation. There is no assurance that each ES
Standard (1-8 and 10) are considered in the EIA study and the formulation of the ESMP. Although the EIA
is heavy towards the environmental aspects, more and more social issues are incorporated in the

Environmental and Social Management Framework (ESMF) Page | 36

assessment. Moreover, the practice under normal circumstances does not include labor management
issues.
It has also a few problems of its own when compared to a standard ESIA process applied following GIIP ,
including but not limited to: (i) it does not provide any formal definition of the projects to be required
the Environmental Clearance--the law only refers to "industry" and "industrial units"; (ii) the screening
process is inadequate--there is no procedure or criteria for determining which category a project would
fall into; and (iii) it does not have formal procedure for compliance monitoring and reporting.
Although there are suggestions in the EIA Guidelines on these issues, the Guidelines does not have the
same compelling effect as the force of law or regulation. There is no assurance that all relevant ESSs (1-
8 and 10) will be well covered in the ESIAs processes and final Report including ESMPs and monitoring /
supervision measures. Although GoB the EIA requirements lean heavily towards the environmental
aspects, in recent years more and more social issues are being incorporated in the assessment.
Moreover, the practice under normal circumstances does not include labor and OHS management issues.
Another critical gap pertains to lack of provisions for requiring the preparation of project specific ESMPs.
On the social side, the eminent domain land acquisition system for example does not require the
preparation of Resettlement Action Plan (RAP). There are some gaps between the existing land
acquisition law of the country and ESS 5 on Involuntary Resettlement in terms of identification of affected
persons and compensation packages and participation of community groups of diverse interests and
vulnerabilities. There are also no provisions to formulate Labor Management Procedures/Plans (LMP).
Suggested gap-filling measures are given in 3.5. Given the gaps, this ESMF will follow the most stringent
standards and requirement.
Table 3.5: Gaps Minimization between GoB laws and WB’s ESSs

WB ESF Standard Gap Minimization

ESS-1: Assessment and Management ESMF has suggested following the ESS-1 requirements, given in the relevant
of Environmental and Social Impacts sections of environmental management procedures. In case, DoE rules/ regulations
and Risks do not cover the ESS requirements, and relevant clauses should be added in the
financial agreements and project appraisal document to follow the more stringent
safeguard requirements according to WB ESF. ESS1 requirements will also inform
the E&S requirements of the sub-project ESIAs/ESMPs and these will be used in sub-
project bidding documents.

ESS-2: Labor and Working Conditions Under this project, a LMP has been prepared to regulate working conditions and
management of worker relations including workers specific GRM, terms and
conditions of employment, non-discrimination and equal opportunity, protection
of the workers’ rights to form unions and engage in collective bargain, protection
of work force, prohibition of child/forced labor and provision of occupational health
and safety (OHS).

ESS-3: Resource Efficiency and ESMP to be developed for BBIN-MPA program component 1, 2, and 4 will address
Pollution Prevention and this issue and incorporate mitigation measures for pollution prevention and will
Management include guidance for efficient use of natural resources.

ESS-4: Community Health and Safety The gaps will be addressed through appropriate provisions in sub-project
ESIA/ESMPs and covered in the ESMP guidance part of this ESMF. In addition,
contractor, operators will be responsible to prepare and implement the Contractor
Environmental and Social Management Plan (C-ESMP) regarding community and
occupational health and safety which includes OHS plan, traffic and road safety
management plan etc. Besides, a SEA/SH has been prepared at the appraisal stage.

Risks assessment and management plan for custom facilities and building will be
performed as part of the ESIA/ESMP, and appropriate management plans
compliant with Good International Industry Practices (GIIP) will be prepared.

Similarly, as part of the ESIA process, a Security Risk Assessment will be prepared,
and commensurate Security Management Plans will be developed for each site.

Environmental and Social Management Framework (ESMF) Page | 37

 WB ESF Standard Gap Minimization
ESS-5: Land Acquisition, Land Use The project may require land acquisition from private entities. A RPF has been
Restriction, and Involuntary developed to guide preparation of site-specific RAPs/A-RAPs to address the land
Resettlement acquisition and involuntary resettlement and as well as physical and economic
displacement related issues.

ESS-6: Biodiversity Conservation and A detailed guideline has been given in the ESMP preparation section of the ESMF.
Sustainable Management of Living Besides, site-specific management plans with detailed ecological studies will be
Natural Resources prepared for each sub-project/activity in line with WB ESF, including application of
the mitigation hierarchy when potentially impacting Natural and / or Critical
Habitats, and designing management measure to ensure NNL or NG, respectively.

ESS-7: Indigenous People During preliminary screening of the project, no communities meeting the ESS7
criteria was identified. However, if any IPs are identified during the preparation of
site-specific ESIA/ESMP, a Small Ethnic Community Development Plan (SECDP) will
be prepared following the ESS7 requirements.

ESS-8: Cultural Heritage No significant cultural heritages have been identified during the initial screening.
However, further assessment will be carried out during the preparation of the site-
specific ESIAs/ESMPs and in case any such cultural heritage are found, appropriate
mitigation measures will be included in the ESIAs/ESMPs. This will also include a
Chance Finds Procedure which will be appended to bidding and contract documents
to illustrate actions to be taken on finding any cultural heritages. Efforts will also be
made to identify cultural heritage in collaboration with communities during the
stakeholder consultation process, and avoid siting facilities on or near culturally
important areas.

ESS-9: Financial Intermediaries Not relevant.

ESS-10: Stakeholder Engagement Under this BBIN-MPA program, a SEP has been developed for all the PIUs that
and Information Disclosure identifies the various stakeholders and ways to engage them and close the
feedback loop. The SEP has detailed a GRM for the PIUs to address issues and
concerns for the stakeholders.

3.6 Guidance Related to COVID-19

Due to ongoing COVID-19 pandemic, World Health Organization (WHO) and Directorate General of
Health Services (DGHS), under the Ministry of Health and Family Welfare, provided guidelines for
infection prevention and control. The government has incorporated the life-threatening novel corona
virus in 'The Communicable Diseases (Prevention, Control and Eradication) Act, 2018’. With the
notification of the gazette the government has a legal basis to take action against the people not
following the government’s direction that relates to COVID-19.
ESF/Safeguards Interim Note: Covid-19 considerations in construction/civil works projects by WB is
applicable to all activities of project during COVID-19 pandemic. This note was issued on April 7, 2020,
and includes links to the latest guidance as of this date (e.g., from WHO). Given the COVID-19 situation
is rapidly evolving, when using this note it is important to check whether any updates to these external
resources have been issued. This interim note is intended to provide guidance to teams on how to
support Borrowers in addressing key issues associated with COVID-19 and consolidates the advice that
has already been provided over the past month. As such, it should be used in place of other guidance
that has been provided to date.

Environmental and Social Management Framework (ESMF) Page | 38

4. ENVIRONMENTAL AND SOCIAL BASELINE
Except for the Sylhet-Charkhai and Sheola roads, which have already been explained, the client has yet
to generate site-specific baseline information for rest of the sub-projects. However, during the ESMF
preparation, preliminary assessment revealed that the project area in all three BLPA land ports and the
NBR custom houses/training academy had no important natural habitats or threatened animals inside
the project effect regions. Around the identified proposed sites or along the alignments, there are no
archaeological sites, sensitive cultural or biodiversity receptors of international, national, state, or
district importance, such as protected areas, key biodiversity areas, forest areas, sacred groves, or
historical/cultural monuments. However, in the suggested places, some minor homestead trees may
need to be removed. The estimated land acquisition for BLPA under Component 1 is 120 acres (25 acres
for Burimari, but 20 acres are government land, so only 5 acres will need to be acquired) and will have
significant involuntary resettlement impacts on both legal and informal land owners, businesses,
tenants, homesteads, residential and commercial buildings, particularly in Bhomra. Under Component
2, no land acquisition is expected for NBR, and there are no unauthorized inhabitants. The ESMF for the
three components includes a general summary of the project's environmental and social baseline.
However, before executing the sub-projects, the ESMF recommends a more thorough assessment.
Because the design and location of the sites are more advanced, the clients will prepare a more detailed
E&S baseline as part of the ESIA for those sub-projects.

4.1 Baseline Environmental Status Description

4.1.1 Physical Environment
4.1.1.1 Climate and Meteorology
The temperature in the project area ranges from mid-30 to 25°C and incase of rainfall, wind speed the
change is almost similar as May, June, July, August and September generally show the highest
concentration.
4.1.1.2 Topography
For component 1, The general topography of the project area is flat. The topography of the specific
project location is 30-75m a.m.s.l and 3-10m a.m.s.l. For component 2, the project area is mainly plain
land with a general elevation of 3.6 m.

Environmental and Social Management Framework (ESMF) Page | 39

 Figure 4.1: Topographical Status of the Project Area

4.1.1.3 Hydrology
For component 1, the Burimari land is located beside the Dharla river, whereas the Bhomra land port is
located beside the Ichamati river and for the Benapole land port, there is no waterbody adjacent to the
land port area. Tap water and water collected from tube wells are the main sources of drinking water.
For component 2, there are two ponds, within the boundary of the Chattogram Customs Office and the
tap water provided by the Chattogram WASA is the main source of potable water in the project area.
But as the project intervention work will be carried out within the boundary wall, so no issue regarding
water pollution or groundwater overextraction. Natural fish is available in the nearby River and Dighi.

Figure 4.2: Hydrological Status of the Project Areas

4.1.1.4 Wind Hazard/Cyclone & Seismicity

The project areas are not subject to wind hazard or cyclones and no recent record have been found
which may indicate the project areas are subject to wind hazard.
For component 1, the project areas fall in zone I and II indicating low to moderate level intensity level
towards seismic activities. Whereas, for component 2 and 3 the project areas fall in zone II indicating
moderate level intensity.
At present, there is issue regarding drainage congestion especially in the land ports. The development
work may improve these conditions.

Figure 4.3: Drainage Status of the Project Areas

Environmental and Social Management Framework (ESMF) Page | 40

4.1.1.4.1 Solid Waste Management
For component 1, there is no waste management plan is developed at present. For component 2, At
present there is some wastes bins are placed to collect the wastes but no centralized waste
management plan is developed yet. During Stakeholder consultation meeting on December 20, 2021 at
Chattogram Customs House conference room, the participants raised the issue of future waste
management system. They expressed their views on taking such measures so that the generated waste
can be disposed of properly. Therefore, these important issues should be actively considered during the
formulation of ESIA and ESMP so that measures can be taken to reduce wastes. The construction
activities will generate solid wastes, construction debris and construction waste that will degrade the
quality of the surrounding environment if not properly disposed-off in the designated dumping site.
Customs House, Chattogram Laboratory is one of the important laboratories in the country, where 90%
of the chemical tests are done which are imported to Bangladesh. But the condition of the laboratory is
not good and the staff position is very inadequate. As a result, the laboratory management system is
very weak. Since there are many hazardous substances in the laboratory, the matter should be taken
seriously. In this case, special attention should be paid to the safe management of hazardous wastes
during ESIA and ESMP preparation. The waste management issues have been addressed in the ESMP
with their possible mitigation measures especially during the construction phase.

4.1.2 Biological Environment

The project areas are mostly abundant with homestead plantations and the construction work may
need to cut some of these trees and most of the trees there are fruitless, so the chances of birds living
or sitting on the trees are very low. However, there may have some small mammals like squirrels, small
birds like butterflies, grasshoppers etc. and some insects in those places. These issues are addressed in
the ESMP with their possible mitigation measures.

Environmental and Social Management Framework (ESMF) Page | 41

 Figure 4.4: Floral Status of the Project Areas

4.1.3 Socio-Economic Environment

4.1.3.1 Demography
The survey team interviewed 50 households (HHs) across Burimari land port project area. Gender Ratio
of male/female was close to 1.214. The 50 sample households have 237, consisting 130 male and 107
female. Household members with average household size of 3 meaning that the sample households in
Burimari, had larger household size than national average 4.4 and that of 145 PAP households 4.29. Of
the population of 50 sample households 21.5% are male above age 45, 21.4% are female above age
45%. The average age of each HH is approximately 28.86 years, with maximum age being 80 years for
male and 70 for female. In case of Bhomra land port area, the 190 sample households have 893
household members with average household size of 4.70 meaning that it has larger household size than
national average 4.4 and that of 145 PAP households 4.29. Out of 190 respondents 140 are men and 50
are women, 35.3% are adult male, 34.6% are adult female, 15.7% are boys and 14.4% are girls. Sex Ratio
of male/female is very close to 1.0 for Benapole. Component 2 sub-project area is occupying 6.77 acres
of land with a commercial/residential land use in 30% built-up coverage of the total available land.
4.1.3.2 Literacy
Literacy rate of sample respondents was 44.6 in Burimari union. Literacy rate of 190 sample respondents
was 63.7% and this should be due to positive change after 2011. There is Private College, High School,
Primary School, Kinder Garden School and Madrasha are within 2.00 km around the proposed land. No
aesthetic structure is available in and around the project site. Settler from different region of the
country made their resident around the project site and engaged in different ways of living.

4.1.3.3 Employment Status

Day-laboring is the single largest occupation of non-PAP sample households. One of the major
professions is shop/hotel owners having highest percentage of 20%. Followed by agriculturists (18.95%)
and labors (16.84%). The lowest percentage (1.05%) is of farmers, teachers and home businesses.
Almost 35% people are involved in port related activities e.g.; export-import.

4.1.3.4 Religion
The study area district, Upazila, UP and village comprise mainly of two religious’ groups- the Muslims
and Hindus. While the district has overall 82:18 Muslim-Hindu population, the proportion of Muslim
increases to 92:8 in the village level which is close to religious composition at the national level.
4.1.3.5 Vulnerable Groups
The vulnerable groups will be identified and addressed in the SEP. Issues regarding their relocation, job
facilities will also be discussed in that plan. Special attention shall be paid to them to ensure their
maximum self-development.

Environmental and Social Management Framework (ESMF) Page | 42

4.1.3.6 In Migration Issues
Several peoples are coming from both India to Bangladesh and Bangladesh to India. The locals are
actively earning their livelihoods by working in jobs closed to the borders. For this, a number of Indian
peoples are coming to Bangladesh and vice versa. These issues also create risk of transmitting sexual
diseases and especially in the time of COVID-19 pandemic, the port areas especially are in vulnerable
conditions. As the three selected land ports have their own medical team to monitor but it is not enough
to render appropriate services.

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5. POTENTIAL KEY ENVIRONMENTAL AND SOCIAL IMPACTS
5.1 Risk Assessment of the Project
The Project will finance infrastructure facilities at Benapole, Bhomra, and Burimari Land Ports and
Chattogram, Beanpole Port and Dhaka Airport Customs Houses. It will also finance improvement of
Sylhet-Charkhai-Sheola-Sutarkandi Highway. The infrastructure will be premised on digitalization,
contact-free and paper-free processing. The Project will also support the development of an automated
border management system coupled with support for procedural, regulatory and legislative reforms,
and associated capacity building support to enable contemporary trade facilitation practices. The
proposed buildings include customs houses, warehouses, transshipment sheds, truck sheds, export
sheds, office and residential buildings, etc. Therefore, the anticipated environmental and pollution risks
are typical for construction works: air, water and land impacts, and health and safety issues of workers
and communities. In the operations phase, there will be normal waste management issues related to
operation of offices and land port activities: general wastes, e-wastes and spoiled perishable goods
discarded by importers/exporters, and typical occupational health and safety issues. Under this project,
there is scope of enhancement measures such as using renewable energy in the new buildings, reusing
wastewater, and composting biodegradable wastes.
Overall, the proposed activities are assessed to have Substantial environment risk given that most of
the works are rehabilitation and improvement of existing infrastructure. Furthermore, there appears to
be no environmentally sensitive areas that will be affected by the sub-project activities under NBR.
During construction, roadside settlements will be exposed to noise, dust, air pollution, landslide risk and
traffic-related safety risks. Considering the ecological sensitivity, environmental footprints, drainage
congestion, traffic and biodiversity loss along the ROW, the proposed expansion of the existing Sylhet-
Charkhai-Sheola-Sutarkandi Highway is assessed to have High environment risk provided that a detailed
site-specific ESA/ESMP will be carried out by the PIU of RHD who is already familiar with WB’s ESF from
the past projects. BLPA has demonstrated under the project that it has the ability to manage
environmental risks and impacts satisfactorily. With trainings and capacity building and specialist
support, it is expected that the anticipated environmental risks can be managed.
Under NBR, the proposed rehabilitation and improvement of existing infrastructure will occur within
the building footprint inside the project area with no land acquisition requirements and physical and
economic displacement of the local community. Therefore, the social risks for NBR are assessed to be
Substantial. Under BLPA, works will require an estimated 120 acres for three land ports in peri-urban
and urban settings and could displace commercial and residential properties. BLPA, the key
implementing agency, has had considerable experience of land acquisition. However, considering the
scale of land acquisition and displacement of commercial and residential properties, social risk rating
for the BLPA activities is assessed to be high.
A preliminary assessment of SEA/SH risks using the Bank’s SEA/SH risk assessment tool for projects
with major civil works suggests a ‘Moderate’ SEA/SH rating for NBR sub-project components. This is due
to the project sites being in peri-urban and urban areas which are not hard to supervise. However, risks
from labor influx in multiple project areas along the regional corridors exists. The major construction
works of the proposed land ports will inevitably lead to greater mobility of peoples, which could
contribute to raising a number of social problems; namely, greater exposure to communicable and
sexually transmitted diseases including HIV/AIDS due to influx of outsiders such as traders,
businesspersons, skilled and unskilled migrant laborers, transport workers, etc. all of which may also
potentially lead to social tensions among the local communities. Human and sex trafficking targeting
girls and women is common in South Asia and the potential labor influx may also create SEA/SH risks
at the project sites. However, most of the ES risk assessment at present focuses on civil works activities
of the project components. As more information becomes available during the project on the skills
development components under MoC of the project, risks will be re-assessed based on appropriate
metrics.

Environmental and Social Management Framework (ESMF) Page | 44

As stated earlier, this chapter will not assess the impacts of the project intervention activities of RHD
sub project.
Environmental and Social Risk Classification (ESRC) of the BBIN-MPA Program has been rated as ‘High’
Environmental and Social Assessment (ESA) study i.e., ESIA should further assess the exact depth of risks
and impacts, based on the evidence, professional judgment and public consultations. A preliminary
categorization of the project components/sub-components based on their ESA requirement is given in
5.2 following the WB ESF/10 ESSs.
The projected impacts of the BBIN-MPA Program on the key ES parameters that have been identified as
part of the ESMF are listed in 5.1, which has also been analyzed in according to the ESS1 risk categories
based on the significance of each impact. In the subsequent sections, these impacts are discussed and
guidelines for mitigation included for the ESMF of the BBIN-MPA Program. The potential ES impacts and
mitigating measures is given in 5.3.

5.2 Relevant E&S Risks and Impacts

Relevant E&S risks and impacts associated to operations are reflected in Table 2. E&S impacts and risks
that are particularly relevant and important are highlighted with corresponding measures to be detailed
in the sub-projects ESIAs/ESMPs. These are related to:
 Management of refrigeration units, hazamat cargo (e.g., fuel, chemical) and potential accidental
spills.
 Dealing with labor unions in the Port Facilities;
 Community Risks related to increase containers and heavy commercial import-export traffic;
and
 Security Risks associated with border activities (e.g., human and illegal drugs trafficking,
contraband, etc.)
 Occupational and community health risks including SEA/SH
 Life and Fire Safety associated with offices, container storage, training facilities, and
dormitories;
Under this program, there is scope of enhancement of measures in subprojects such as use of renewable
energy in the new buildings, reuse of wastewater and composting of biodegradable wastes.

5.3 Anticipated Potential Environmental and Social Impacts

It is important to identify the potential impacts related with project location, design, construction, and
operation phases of the project on the physical, biological and socioeconomic domains. An impact is
defined as any change to an existing condition of the environment. Identification of potential impacts
is based on data analyses and stakeholder discussions. Environmental and social impacts can be broadly
classified as those taking place during pre-construction, construction and operational phases of the
project. Activities involved affecting environmental components at different phases of the project
implementation as well as potential environmental impacts are discussed in the following sections and
also in below table 5.2 mention the ESSs which may relevant in the subprojects (BLPA, NBR, RHD &
MoC).

5.3.1 Pre-Construction Phase/Project Siting

5.1.1.1 Site Specific Land Cover and Land Use Changes
Reconstruction of the NBR building (will include, inter alia, office, residential, dormitory, Training center
and laboratories buildings) projects may change existing land use and land cover at the local level,
although potential negative impacts would be limited within the construction site and reversible.
Expansion of the 3 land ports may change the existing land use pattern but would be limited within the
construction yard.

Environmental and Social Management Framework (ESMF) Page | 45

5.1.1.2 Loss of Trees
Siting of proposed infrastructure for the reconstruction of ports and buildings of the project may require
cutting of trees and removal of natural vegetation, if realignment are necessary. Tree felling will affect
timber and bio-mass production potential directly at local level. Ecological impacts can be reversed
planting site specific tree species as per the directives of Social Forestry Act (2004).
5.1.1.3 Loss of Habitat
Any loss of trees will impact on other flora and may affect wildlife, particularly birds and mammals that
rely on trees their food source. In addition, the loss of tree may increase soil erosion from rain cut. Apart
from trees and undergrowth other vegetation affected will be agricultural crops, bamboo bush and
other native vegetation. Excavation of borrow pits will add to the destruction of flora.
5.1.1.4 Drainage congestion and water logging
Proposed infrastructure for the subproject’s activities under all IAs may cause drainage congestion and
water logging at the local area, if not properly considered the local drainage of runoff.
5.1.1.5 Impacts on Vulnerable and disadvantage groups/communities/
individuals
The sub-projects intend to ensure effective and efficient transit of goods, creating jobs and improving
the safety of communities enabling access to livelihoods and economic activities using improved
communication and connectivity towards national highway and land port, etc. Project’s inclusive
approach will result in benefits to households and individuals, especially the most disadvantaged like
female-headed households, widows, the poorest, and the elderly peoples in the rural communities.

5.1.2 Construction Phase

5.1.2.1 Air Pollution
For component 1, Air quality may be affected for short duration in and around the construction site due
to various construction activities and construction vehicular movement. The pollutants of primary
concern include SOx and Suspended Particular Matter (SPM). The construction equipment/vehicles,
using fuel and diesel and movement of vehicles will also contribute to air pollution releasing hazardous
air emissions such as NOX, SO2, etc. This will impact the air quality affecting the immediate vicinity
(especially governmental institutions) of the working area. For component 2, the construction vehicles
may contribute to air pollution
5.1.2.2 Noise and Vibration Pollution
For all the components, a significant increase in noise is expected during construction. Noise levels in
and around the construction sites could further increase as a result of operating construction
vehicles/equipment and during unloading and loading of construction materials. A number of vehicles
and equipment will be required for the construction of the proposed infrastructures and will depend
upon the construction methodology for various types of works. However, the equipment will broadly
consist of mixture machine, concrete vibrator, brick/boulder breaking machine, crane etc. and
construction vehicles will consist of dump trucks, transport vehicles, etc. which will cause noise
pollution. Especially as the land ports are already being noisy, the construction activities may add to it
and this may result in health hazard of the labourers specifically if proper measures would not be taken.
5.1.2.3 Water Pollution
5.1.2.3.1 Surface Water
During the construction activities, ponds/canals/water streams-rivers can potentially cause some
localized increase in water turbidity due to poor waste management. However, this increase in turbidity
is not likely to have any significant impact on overall water quality and the aquatic fauna primarily

Environmental and Social Management Framework (ESMF) Page | 46

because of its temporary and localized nature. The accidental leakage or spillage of fuels, oils, and other
chemicals may also generate considerable quantities of waste effluents. These effluents can potentially
contaminate the water sources of the area and can also be harmful for the natural vegetation,
cultivation fields, water bodies, and aquatic flora and fauna.
5.1.2.3.2 Groundwater
Increased demand of groundwater is anticipated during the construction phase for construction
activities and domestic purposes. Since groundwater is likely to be contaminated with arsenic at large
places, consumption of arsenic contaminated groundwater may have adverse health effect on workers.
Uncontrolled extraction of water may also affect availability of waters to locals. In addition to that,
construction waste, if left unattended will result in forming leachate which will percolate through the
soil strata and will reach underground water table and hence, will end up contaminating it. Construction
of building and bridges may cause impact to groundwater level and quality. The piles driven into the
ground with multi layers to the depth of about 40 ~ 50 m (bottom of the quaternary deposits), would
penetrate the aquiclude/aquitard and then cause the risk to pollute the water quality of the aquifer.
5.1.2.4 Impacts of Land Filling (at construction site)
Potential impacts that can arise from the proposed construction of NBR/BLPA facilities, if not very
carefully planned and monitored the collection of land filling materials. Land filling activity must avoid
collection of topsoil from crop fields, hills cuttings and illegal sand mining from river beds.
5.1.2.5 Soil Contamination
Much like water pollution discussed above, soils in the construction or expansion area and nearby lands
may be prone to pollution from the construction activities, construction yards, workers camps and other
construction areas. Fuel and hazardous material storage sites and their handling are also the potential
sources for soil and water pollution. Improper siting, storage and handling of fuels, lubricants, chemicals
and hazardous materials, and potential spills from these will severely impact the soil and water quality
and also cause safety and health hazards.
5.1.2.6 Drainage congestion and water logging
Run off from storage of construction material near water bodies, or uncontrolled disposal may cause
temporary drainage congestion, especially near the locations of small bridges, culverts, service areas,
and construction sites. Hence, no significant impact is anticipated on these water bodies during this
phase. The project area is not prone to flood. As per assessment and considering the existing road levels
some parts of the road stretch is likely to be affected by flood respectively.
5.1.2.7 Generation of Solid Waste and Hazardous Waste
Solid waste generated during the construction phase will include excess construction materials such as
sand and soil, faulty/damaged parts, metal scraps, cardboard boxes, containers, and cotton swaths from
workshops, and domestic solid waste from construction offices and camps. In addition to the above,
small quantities of hazardous waste will also be generated mainly from the vehicle maintenance
activities (liquid fuels; lubricants, hydraulic oils; chemicals, such as anti-freeze; contaminated soil;
spillage control materials used to absorb oil and chemical spillages; machine/engine filter cartridges;
oily rags, spent filters, contaminated soil, and others). The above-mentioned waste need to be properly
managed to adverse environmental, human health and aesthetic impacts. Inappropriate disposal of
these wastes can lead to soil and water contamination as well as health hazards for the local
communities, livestock, and aquatic as well as terrestrial fauna.
5.1.2.8 Occupational Health and Safety
Generally, the construction activities will involve small to medium scale excavation, operations of
construction machinery and vehicular traffic. These activities may pose health and safety hazards to the
workers at site during use of hazardous substances, lifting and handling of heavy equipment, operating

Environmental and Social Management Framework (ESMF) Page | 47

machinery and electrical equipment, working near water or at height and more. The program will need
fuels, oils, and asphalt during the construction phase. Inappropriate handling or accidental
spillage/leakage of these substances can potentially lead to safety and health hazards for the
construction workers as well as the local community. Similarly, various construction/renovation of
facilities and setting up equipment activities in laboratory/workshops/training lab may cause safety
issues including physical injuries and accidental death. This may be increased in absence of proper
training of unskilled workers to be engaged. Local community will also be vulnerable to accidental cases
starting from minor injuries for careless disposal of hazardous materials to death i.e., movement of the
heavy machineries and equipment.
5.1.2.9 Impact on labor, working Conditions and labor risks, including risks of
child labor and forced labor, human trafficking
The proposed sub-projects will entail employment of a significant number of labors especially during
construction. The majority of labor will be locally hired, with the exception of skilled workers who may
not be found in the program areas. However, potential risks engaged both for the hired skilled and non-
skilled workers especially during construction period includes health hazards, poor living condition,
accidental hazards risks, etc. Similarly, hiring labor from external area may cause social risk on the local
communities includes gender-based violence, price hiking of daily used products/foods, etc. A separate
LMP will be prepared for each component which will guide to manage the risk associated with labor
related issues.
5.1.2.10 Involuntary Resettlement Impacts
The proposed activities are expected to require land acquisition with physical and economic
displacement which may impact rural, low-income, and indigenous communities. The project will try to
avoid take any private land through involuntary acquisition and avoid any physical displacement of
residents for activities under the project. Most of the works will be carried out within the existing
available lands. However, acquisition of private lands would be required in some areas, likelihood that
infrastructures construction may involve displacement of formal and informal private users. For all
these reasons, and largely as a precautionary measure, the project triggers ESS5 on involuntary
resettlement. For the IAs, separate RPF will be prepared. Site-specific RAPs will be developed - if and as
necessary - during the project implementation. The RPF and any RAP will ensure the proper calculation
and recording of the involuntary displacement impacts as well as identification of the affected people
and mitigation of their loss and impacts. The purpose of the RPF and implementation of the RAPs is to
ensure that there is no adverse effect on the living conditions and livelihoods of the affected people
because of the project.
5.1.2.11 Impact on Cultural Heritage
There are some mosques, temples and graves along the proposed sub-projects areas, which may be
affected by project works. If they are found by the ESIA to be affected, they will have to be relocated
and will be included in the RAP prepared for the program. Chance Find Procedures will be included in
the ESMP and chance find clause will be included in works contracts requiring contractors to stop
construction, if cultural heritage is encountered during construction. NBR/BLPA/MoC will also have to
notify and closely coordinate with the relevant mandated country authority for the salvaging and
restoration of such cultural heritage.
5.1.2.12 Impact of Labor Union
Especially for component 1, as the construction works progress, the labor union leaders may create
problems which will affect the progress and slow down the construction activities eventually will be
resulted in economic loss. Prior to the start of the work thus an agreement needs to be maintained
between the respective IAs and leaders of labor union.

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5.1.2.13 Security Management Issues
As the sub project areas are very sensitive especially the land ports, it is very important to maintain the
security properly. Otherwise, accident may occur which may affect the peoples as well as the resources
may also be affected. Continuous security setups are required at the construction sites to avoid any
unwanted incidents.

5.1.3 Post Construction/Operation Phase

5.1.3.1 Loss of Vegetation and Wildlife Biodiversity
Construction of buildings or other infrastructures/facilities would increase human access in the existing
facilities, which may lead to loss of more vegetation (herbs, shrubs and trees) at the surroundings due
to human footprint and have potential negative impact on homestead wildlife biodiversity. In such cases
of potential impact on homestead plants and wildlife, demands detail baseline survey and implement
appropriate homestead habitat management activities by the authority.
5.1.3.2 Generation of Solid Waste and Hazardous Waste
Solid waste will be generated from landing sites, during regular operation and maintenance activities of
the constructed road. Hazardous waste will also be generated from access road maintenance. This
waste if not appropriately disposed has a potential to contaminate soil and water resources, thus
negatively affecting communities as well as natural habitat. Improper management of solid wastes may
lead to soil and ground water contamination through the generation of leachate. Bad odor due to non-
removal of waste regularly will also cause unhealthy conditions in the surrounding area including
attracting nuisance animals such as flies and mosquitoes. Wastes will also cause human health diseases.
Overall, negative impacts are predicted due to wastes during the operation stage if handling and
disposal of solid wastes will not be carried out in accordance with a proper waste management plan
(WMP).
5.1.3.3 Noise Generation
During operation, noise levels will be increased due to the higher traffic volume and mass people
gathering especially for port areas. Traffic noise will be a significant nuisance to the sensitive receptors
such as schools and religious places located very close to the roads, housing facilities and also to the
children and aged persons.
5.1.3.4 Water Pollution and Drainage
During the operation phase, some localized increase in turbidity may take place during any maintenance
works of the constructed/renovated sites. Similarly, the maintenance works can also generate a limited
quantity of waste effluents.
5.1.3.5 Impacts on local livelihoods
While effort will be exerted for livelihood improvement of the farmers and local dependent
communities, yet some of the project activities may have reversible and mitigable impacts on them.
The probable impacts on income and livelihoods are minor since project will try to avoid acquisition of
land and involuntary displacement of people. However, temporary economic displacement of some
vendors and businesses along the roads and in market areas where the proposed road and port facilities
will be constructed, expanded and/or rehabilitated. If so, impacted persons will be compensated
following the criteria as outlined in the RPF/RAP. The major aim is to improve livelihoods of the poor
rural community as well to expand the export-import facilities with the capacity to better manage local
resources and expand their participation in more exclusive and sustainable development. The
beneficiaries and their location will be selected by the IAs and the program will be designed and
implemented by PIU.

Environmental and Social Management Framework (ESMF) Page | 49

5.1.3.6 Increased risk of road accidents
One of the key potential risks associated with the sub-projects is increased risk of road accidents due to
higher traffic. However, substantial road safety measures and facilities will be installed under the BLPA/
NBR/MoC sub-project components to minimize the accidents.
5.1.3.7 Impact of Labor Union
The union may arise issues which will affect the operation of the ports especially. To minimize these
issues, regular monitoring along with monthly meeting session may help to ease the condition.

5.1.3.8 Sexual Exploitation and Abuse, and Sexual Harassment (SEA/ SH)
A preliminary assessment of SEA/SH risks using the Bank’s SEA/SH risk assessment tool for projects with
major civil works suggests a ‘Moderate’ SEA/SH rating for BLPA, NBR sub-project components. This is
due to the project sites being in peri-urban and urban areas which are not hard to supervise. Most of
the unskilled and semi-skilled labor are expected to be locally sourced with only high skilled and some
semi-skilled labor sourced from outside sub-projects’ areas of influence.
However, the construction works of the proposed land ports will inevitably lead to greater mobility of
peoples, which could contribute to raising a number of social problems; namely, greater exposure to
communicable and sexually transmitted diseases including HIV/AIDS due to influx of outsiders such as
traders, businesspersons, skilled and unskilled migrant laborers, transport workers, etc. all of which may
also potentially lead to social tensions among the local communities.
Human and sex trafficking targeting girls and women is common in South Asia where immigration points
at the land ports could potentially serve as conduits for cross-border trafficking. A Gender and SEA/SH
Action Plan is prepared for the project that details the relevant mitigation measures both preventive
and curative, and as well includes specific actions to promote gender and women empowerment.
5.1.3.9 Security Management Issues
Specially, the land ports are very crucial points as everyday a number of people cross these points and
without proper security managements there might be incidents affecting the national security issues
apart from local accidents.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Table 5.1: Summary of Potential Environmental and Social Impacts and their Significance (ESS Risk)
Duration of Reversible or Significance Prior to Significance after
Potential Impacts Spatial Extent Likelihood Magnitude Sensitivity
Impact not Mitigation Mitigation
Impacts related to Project Siting
Land cover and land use Long term Local No Certain Moderate Moderate Moderate Low
changes
Loss of trees Long term Local Yes Certain Moderate Moderate Moderate Low
Loss of habitat Long term Local No Likely Moderate Substantial Moderate Low
Drainage congestion and Long term Local but beyond Yes Likely High Moderate Moderate Low
water logging project footprint
Impacts during Project Implementation Phase
Air pollution Short term Local Yes Certain Moderate Moderate Moderate Low
Noise Short term Local Yes Likely Moderate Moderate Moderate Low
Water pollution Long term Local but beyond No Certain Moderate Moderate Moderate Low to moderate
project footprint
Land Filling Long term Local but beyond No Certain Moderate Moderate Moderate Low to moderate
project footprint
Soil contamination Short term Local Yes Certain Moderate Moderate Moderate Moderate
Solid wastes and hazardous Short term Local Yes Certain Moderate Moderate Low
wastes
Impacts on homestead Long term Local but beyond No Certain Moderate Moderate Moderate Low
biodiversity project footprint
Site clearance and Short term Local Yes Certain Moderate Moderate Low
restoration
Occupational health and Short term Local Yes Certain Moderate Moderate Moderate Low to moderate
safety
Labor Impacts and risks of
child labor, forced labor, Short term Local Yes Certain Moderate Moderate Moderate Low to moderate
human trafficking
SEA/SH Long Term Local Yes Certain Moderate Moderate Moderate Moderate
Involuntary Resettlement Short term Local Yes Certain Moderate Moderate Moderate Moderate
Impact on Cultural
Short term Local Yes Certain Moderate Moderate Moderate Low to moderate
Heritage
Impact of Labor Union Long term Local Yes Likely Moderate Moderate Moderate Low to moderate
Security Issues Long term Local Yes Likely Moderate Moderate Moderate Moderate
Impacts during Post Project Operational Period
Loss of Homestead Long term Local No Certain Moderate Moderate Moderate Low
Vegetation and Wildlife
Biodiversity

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Duration of Reversible or Significance Prior to Significance after

Potential Impacts Spatial Extent Likelihood Magnitude Sensitivity
Impact not Mitigation Mitigation
Generation of Solid Waste Long term Local Yes Certain Moderate Moderate Moderate Low
and Hazardous Waste
Noise generation Long term Local Yes Likely Negligible Mild Moderate Low
Water pollution and Long term Local No Certain Moderate Moderate Moderate Low to moderate
drainage
Changes in land use
Long term Local No Certain Moderate Moderate Moderate Low
pattern
Impacts on local livelihoods Long term Local No Certain Moderate Moderate Moderate Low
Increased risk of road
Long term Local No Likely Negligible Moderate Low Low
accidents
Impact of Labor Union Long term Local Yes Likely Moderate Moderate Moderate Moderate
Security Issues Long term Local Yes Likely Moderate Moderate Moderate Moderate

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Table 5.2: Categorization of BBIN-MPA Program Activities (Phase 1 Bangladesh) Based on Key Predicted Impacts and ESS Requirements

Component Sub- Component Activities/ Investments Potential Impacts Risk Category ESSs Requirement
1.1 Upgrading of Office buildings, residential Component 1.1 will have potential ES impacts because of Substantial E&S Screening, ESIA, ESMP,
Benapole, buildings, land filling, boundary wall, construction activities, impacts include, among others, LMP, SEP, OHP, EHS (GIIP);
Burimari, and water supply system, watch towers, noise, vibration and air pollution; GRM, SEA/SH, RPF/RAP, C-
Bhomra land Electric system, warehouses, stock water pollution & drainage congestion; ESMP, COVID-19 safety
ports yard, transshipment sheds, Land filling and soil contamination; protocol and Integration of
pavement, internal road network, Solid waste generation; E&S requirements in the ToRs,
RCC draining network, solid waste traffic / mobility / access;
management and automation impacts to physical cultural resources; Impact on
premised on digitalization, contact- disposing accidental chemical waste from
free and paper-free processing sheds/warehouses;
Labor related risk (Occupational and Community health
and safety;
issues related to the COVID-19 pandemic); The civil
works may need private land acquisition and may cause
resettlement, relocation and other issues associated
Component 1: with land acquisition.
Land Port 1.2 Development This sub-component will support the No physical activities under component 1.2. This Low E&S Screening, Integration of
Development and of Automated development of a new multi-agency component will cover modernizing both regulatory and E&S requirements in the ToRs,
Border Border Automated Border Management non-regulatory processes, automating them and SEP, GRM, COVID-19 safety
Management Management System platform aimed at increasing subsequently share valuable data amongst border protocol
Improvement System visibility of the trade chain, reduce management partners.
(BLPA) costs and unnecessary interactions
with cargo shipments.
1.3 Technical This sub-component will finance Component 1.3 will have no physical activities, thus have Low E&S Screening, Integration of
Assistance to long-term master plans, feasibility no potential ES impacts, rather will contribute to the E&S requirements in the ToRs,
enable design studies and environmental capacity building of the IAs staff in managing ES SEP, GRM, COVID-19 safety
contemporary and social safeguard studies for compliances during project implementation and protocol
trade priority land ports that will be operation.
facilitation considered for financing in
practices subsequent MPA phases (e.g.,
Banglabandha, Hili, Sonahat, Bilonia,
Tamabil, Bholaganj, Darshana and
other land ports).
Support will also be provided to
build capacity of BLPA staff in
modern border management
practices.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Component Sub- Component Activities/ Investments Potential Impacts Risk Category ESSs Requirement
2.1. Upgrading of Upgrading of physical facilities at the Component 2.1 will have potential ES impacts because of Substantial E&S Screening, ESIA, ESMP,
Custom Chattogram Customs House construction activities, impacts include, among others, LMP, SEP, OHP, EHS (GIIP);
Infrastructure In addition, Dhaka and Benapole Noise, vibration and Air pollution; water pollution, GRM, SEA/SH, RPF/RAP, C-
customs houses will also be Land filling and soil contamination; ESMP, COVID-19 safety
modernized. These physical setups Solid waste generation; protocol and Integration of
will include different types of Labor associated risk (Community health and safety; E&S requirements in the ToRs.
residential and office buildings, community health and safety
laboratory, warehouse, data centre, and issues related to the COVID-19 pandemic);
etc. Operation of laboratory may generate laboratory
wastes; The civil works may need private land acquisition
and may cause resettlement, relocation and other issues
associated with land acquisition. Labor related risk
Occupational and Community health and safety;
and issues related to the COVID-19 pandemic;
2.2. Development development of a state-of-the-art Component 2.2 will have potential ES impacts because of Substantial E&S Screening, ESIA, ESMP,
of Customs and Training Academy to help construction activities, impacts include, among others, LMP, SEP, OHP, EHS (GIIP);
Value Added institutionalize NBR’s capacity GRM, SEA/SH, RPF/RAP, C-
Tax (VAT) building programs and allow Noise, vibration and Air pollution; water pollution, ESMP, COVID-19 safety
Component 2:
Training development of e-Training modules Land filling and soil contamination; protocol and Integration of
Customs
Academy and planned courses for continuous Solid waste generation; E&S requirements in the ToRs.
Modernization
Human Resource Development. This Labor associated risk (Community health and safety;
(NBR)
TA will include admin building, community health and safety
conference room, labs, gallery, and issues related to the COVID-19 pandemic); The civil
library, multipurpose hall, cafeteria, works may need private land acquisition and may cause
prayer house, rest ouse, dormitory, resettlement, relocation and other issues associated
residential buildings, relocation of with land acquisition. Labor related risk Occupational
school, pump house, water tank, and Community health and safety;
mosque, pond, playground, water and issues related to the COVID-19 pandemic;
treatment plant, Rainwater
harvesting system, Sewerage
treatment plant, solar power,
draining network, internal roads, etc.
2.3. Technical Develop and implement phased No environmental or social impacts are envisaged. Low E&S Screening
assistance for implementation plan for tariff Rather this sub-component will have positive impact on SEP, GRM, COVID-19 safety
tariff rationalization, seeking to reduce NBR’s capacity building and job creation. protocol.
modernization overall level of tariffs and dispersion
as per the vision set out by the GoB
in its 8th FYP and proposed
Bangladesh National Tariff Policy (to

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Component Sub- Component Activities/ Investments Potential Impacts Risk Category ESSs Requirement
be prepared by Ministry of
Commerce).
The phased implementation plan will
take into consideration export
diversification, sector
competitiveness, job creation,
investment, Least Development
Country (LDC) graduation and
economic recovery from COVID 19.
Crafting such tariff rationalization
plan requires significant capacity
improvement in simulation, revenue
modeling and other statistical
analysis which will be supported
through this sub-component.
2.4. Technical This sub-component will build on the No environmental or social impacts are envisaged. Low E&S Screening
assistance for reform momentum in Risk Rather this sub-component will have positive impact on SEP, GRM, COVID-19 safety
Risk Management supported through NBR’s capacity building and job creation. protocol.
Management BBIN, Jobs DPC Series of the Bank
Commissioner and IFC advisory project TraCED
ate, Feasibility (602137). The activities will cover the
and detailed following: (a) Capacity Building: A
design for competency based human resource
proposed strategy and succession plan will be
National Risk required to ensure that the CRMC is
Targeting appropriately staffed to carry out a
Center and TA full range of duties. This will include
for proposed development of e-learning modules
Bangladesh as well as Training of Trainers (ToT)
Single Window for continuous capacity
Commissioner development program. There will be
ate provisions for learning from
benchmark countries as well; (b)
detailed Standard Operating
Procedures (SOP) for the CRMC
including the work functions and
coordination with local risk
management units to support
operationalization; (c) feasibility and

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Component Sub- Component Activities/ Investments Potential Impacts Risk Category ESSs Requirement
detailed design of proposed National
Risk Targeting Center with SOP for
coordinated border management;
and (d) for NSW Commissionerate,
TA will be provided for stakeholder
consultation, visioning, development
of organogram, job description, roles
and functions of officials as well as
SOP for such collaborative border
management platform to sustain
Bangladesh Single Window.
2.5. Technical This sub-component will be to No environmental or social impacts are envisaged. Low E&S Screening
assistance for support NBR in streamlining Bonded Rather this sub-component will have positive impact on SEP, GRM, COVID-19 safety
Bonded Warehouse Policy and regulations NBR’s capacity building and job creation. protocol.
Warehouse for bond license, renewal,
modernization management, audit and
reconciliation removing the
disparities between Ready Made
Garments and non-RMG sectors It
may also support change
management for Customs Bond
Management System (CBMS),
proposed automation of Duty
Drawback and Exemption Office and
addressing reconciliation challenges.
3.1. Strengthening This sub-component will support No environmental or social impacts are envisaged. Low E&S Screening
of the National establishing the NTFC Secretariat Rather this sub-component will have positive impact on SEP, GRM, COVID-19 safety
Trade and the development and MoC-WTO cell’s capacity building in implementation of protocol.
Facilitation implementation of National Trade the TFA.
Committee and Transport Facilitation Action
Component 3:
(NTFC) and Plan. The NTFC will serve as the
Trade Facilitation
development/ primary trade and transport
Agreement (TFA)
implementatio coordination mechanism in
Implementation
n of National Bangladesh and will serve the
(MoC)
Trade and functions as envisioned in the World
Transport Trade Organization (WTO) Trade
Facilitation Facilitation Agreement (TFA). The
Action Plan formation of the NTFC Secretariat
will be critical for supervising and

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Component Sub- Component Activities/ Investments Potential Impacts Risk Category ESSs Requirement
monitoring the TFA implementation
of the trade related agencies.
3.2. Development This sub-component will support a No physical activities under component 3.2. This Low E&S Screening, SEP, GRM,
of Decision Decision Support System that will component will positively contribute to capacity building COVID-19 safety protocol
Support provide policy analysis, market and systemic management of of MoC-WTO cell.
System for research and trade statistics to
policy analysis, support the MoC’s mandate in
trade statistics implementing trade policy including
and trade negotiating various trade
negotiations agreements. This incorporates the
establishment of an institutional
architecture, ICT connectivity and
associated skills and capacity
building needs.
3.3. Formulation This sub-component will support the No environmental or social impacts are envisaged. This Low E&S Screening, SEP, GRM,
and formulation a National Tariff Policy. component will positively contribute to capacity building COVID-19 safety protocol
implementatio Necessary capacity building of and systemic management of of MoC-WTO cell.
n of National officials will also be carried out for
Tariff Policy subsequent policy updating and
amendments to the policy.
3.4. Upgrading of This sub-component will support the No environmental or social impacts are envisaged. Low E&S Screening, SEP, GRM,
the Bangladesh enhancement of the Bangladesh COVID-19 safety protocol
Trade Portal Trade Portal, which is a key element
(BTP) for the successful functioning of
National Trade Single Window.
3.5. Training This sub-component will seek to No environmental or social impacts are envisaged, rather Low E&S Screening, IEE, SEP, GRM,
programs on empower women traders and this will contribute positively in empowering women SEA/SH, COVID-19 safety
trade entrepreneurs and support their traders and entrepreneurs and their capacity building in protocol
facilitation for integration into national, regional trade related issue.
women traders and global markets through capacity
and building in capacity building in trade
entrepreneurs related regulatory issues. This
activity will reflect emerging from
pilot programs undertaken under
BBIN.

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5.4 Mitigation Measures to Address Environmental and Social Impacts

The ESMF identifies the generic E&S risk and impacts for the project and provides the relevant
mitigation measures. More specific E&S impacts and risks associated with subprojects will be identified
during the preparation of ESIA/ESMP. The identified E&S risks and impacts are categorized as pre-
construction, construction, commissioning and operational phases along with suggested mitigation
measures which will be further assessed and detailed in the site-specific ESIA/ESMP.
Good International Industry Practice (GIIP) will be applied to mitigate all identified E&S impacts and
risks associated with each sub-project activity and phase, and will be described in their C-ESMP and O-
ESMPs. A set of standard mitigation measures against the typical E&S impacts and risks expected on
this program’s subprojects at their different phases are proposed in the Table 5.3 below.

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Table 5.3: Potential Environmental and Social Impacts and Mitigating Measures at Different Phases of the BBIN-MPA Program
Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
Preconstruction Phase
Land Acquisition/ ● Encroachment of agricultural - Avoid agricultural land, social/religious establishments, fish habitat PIU E&S consultant, RAP PIU/BBIN-MPA
Requisition (if required) land, cultural sites, fish habitat during finalization of the alignment of the approach road and Implementation NGO
etc. location of the bridge;
● Loss of agricultural production, - Prior to start construction adequate compensation should be given
fish resources; to the PAPs in-time according to RAP.
● Loss of income and livelihoods; - Adequate compensation should be given for standing crops;
● Social conflict. - Avoid agricultural land, if possible;
- Create job opportunities for the PAPs.
Road, Office, Training ● Loss of housing and - Avoid the housing and commercial structure during the finalization Contractors PIU/BBIN-MPA
Center, Housing commercial structures; of the alignment and location of the road/bridge;
● Dust pollution; - Proper compensation shall be provided to the affected peoples prior
● Loss of income and livelihoods. to the construction activities.
- Create job opportunities for the PAPs.
- Water spraying on the bear surface or dust pollution source;
Loss of vegetation/ tree ● Accident risk during removal of - Prior to start construction, all vegetation should be removed from Contractors PIU/BBIN-MPA
trees/vegetation’s in the project the proposed construction sites with the consultation of the local
sites; relevant authorities;
● Birds and others species can - Avoid disturbance and be careful during construction about vehicle
migrate from the and equipment movement;
trees/vegetation’s; - Proper H&S measures (use of appropriate PPE such as hand gloves,
● Impacts on the local climatic safety shoes and helmet) for the workers should be taken during
condition. removal of trees, bushes & crops;
- To mitigate the ecological impact, tree plantation plan can be
considered in the design & accordingly tree plantation will be done
in an appropriate location to be determined by the PIU/BBIN-RTTF1
after consultation with the concerned authority;
- The engineer shall approve such felling; only when the proponent
secures receive a “clearance” for such felling from the PIU/BBIN-
RTTF 1 as applicable;
- Tree felling, if unavoidable, shall be done only after compensatory
plantation of at least two saplings for every tree cut is done;
- During the tree removal from the bridges and approaches
construction sites diameter at best height (DBH) of the trees is 6
inches, only such trees should be considered by the contractor for
compensation and plantation;

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
- Tree plantation at the suitable locations after completion of the
construction activities at the 1:5 ratio.
Removal of Utilities ● Risks for workers health and - Prior to start construction, the utility services (electrical cables, Contractors PIU/BBIN-MPA
safety; telephone line, water supply pipeline, gas supply pipeline and
● During movement of heavy internet line) should be shifted with the consultation of the relevant
Construction machineries organizations;
equipment’s can damage the - Inform the local community before starting removal or demolishing
utility services if not previously work;
removed; - Carefully remove the utilities that are connected to any structures;
● Due to carelessness or - Proper Health and safety measures for the workers should be taken
incautiousness death from during shifting of these lines to avoid any incidents.
sudden electric shocks may
occur.
Archaeological/ Historical/ ● Encroachment of - Avoid Archaeological/Historical/Social/Cultural/ Religious sites Contractors PIU/BBIN-MPA
Social/ Cultural/ Religious Archaeological/ Historical/ during the site selection and improvement works;
Sites Social/ Cultural/ Religious sites - Spraying water on the dry surface to reduce dust pollution;
● Air and dust pollution; - Follow strictly the chance finds procedures
● Noise level may create - Vehicles transporting construction material to be covered;
uncomfort for the local - Create noise barrier around the construction sites;
community; - Limit the speed of vehicles;
● Vibration can effect on social/ - Stop the demolition work for short time like prayer time.
cultural/ religious site. - Realignment of bridge approach road (in case of bridge) if required.
Setting up labor camps ● Land encroachment; - Include E&S/ESMP provisions on labor, GRM, SEA/SH etc. in the Contractors PIU/BBIN-MPA
● Solid and liquid waste from the bidding documents and C-ESMP/O-ESMP with payment milestones
labor camp - Labor camp should be constructed at a distance from the water
● Potential community health bodies;
including SEA/SH risks - Avoid productive land and away from the settlement during the
selection of land for the setup of labor camp;
- No solid and liquid waste discharge into the water bodies;
- Instruct workers to maintain clean environment in the camps.
- Enforce a Code of Conduct for all workers
- Raise awareness among the communities on STDs, SEA/SH and the
project GRM
Construction Phase
Air Pollution ● Construction vehicular traffic: Air - Fit vehicles with appropriate exhaust systems and emission control Contractors PIU/BBIN-MPA
quality can be affected by vehicle devices;
exhaust emissions and - Maintain vehicles and construction equipment in good working
combustion of fuels condition including regular servicing;

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
● Construction equipment: Air - Operate the vehicles in a fuel-efficient manner;
quality can be adversely affected - Impose speed limits at 30 km/hour on vehicle movement at the
by emissions from construction worksite to reduce dust emissions;
machineries and combustion of - Control the movement of construction traffic in the access road;
fuels; - Focus special attention on containing the emissions from generators;
● Construction activities: Dust - Construction equipment causing excess pollution (e.g. visible smoke)
generation from earth will be banned from construction sites immediately prior to usage;
excavation, earth & sand - Water spray to the dry earth/material stockpiles, access roads and
stockpiles during dry period. bare soils as and when required to minimize the potential for
environmental nuisance due to dust;
- Increase the watering frequency during periods of high risk (e.g. high
winds);
- Stored materials such as: excavated earth, dredged soil, gravel and
sand shall be covered and confined to avoid their wind drifted;
- Restore disturbed areas as soon as possible by vegetation;
- Establish adequate locations for storage, mixing and loading of
construction materials, in a way that dust dispersion is prevented
because of such operations;
- The Air quality monitoring should be carried out by the contractor
following the National Air Quality Standard (Schedule-2: Standards
for Air Quality, ECR, 1997 and Amendment in 2005).
Noise Pollution ● Construction vehicular traffic: - Strict measures for noise pollution control need to be undertaken Contractors PIU/BBIN-MPA
Vibration and Noise quality will be during construction activities;
deteriorated due to vehicular - Create noise barrier and consider the minimum noise levels at
traffic. sensitive receptor sites (e.g. dense residential area, schools,
● Construction equipment: Noise mosques, health centers etc.);
and vibration will have an impact - Stone breaking machine should be confined within a temporary shed
on adjacent surrounding so that noise pollution could be kept minimum;
residents. - Protection devices (ear plugs or ear muffs) shall be provided to the
● Construction activity: Noise will workers operating in the vicinity of high noise generating machines
have an impact on adjacent during construction;
residents. - Construction equipment and vehicles shall be fitted with silencers
and maintained properly;
- Instruction to the drivers to avoid unnecessary horn;
- The Noise level monitoring should be carried out by the contractor
following the National Noise Quality Standard (Schedule-4:
Standards for Sound, ECR, 1997 and Noise Pollution (control) rules
2006).
- Vibration monitoring should be carried out by the contractor.

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
- Contractors PIU/BBIN-MPA
Ground Water Pollution ● Contamination of groundwater - The contractor will make arrangement for water required for
due to Pollution lack of septic construction in such a way that the water availability and supply to
tanks or mobile toilets; nearby communities remain unaffected;
● Accidental spillage of hazardous - Handling and storage of the potential contaminants has to be
liquid from the construction organized under strict condition to avoid water pollution during
camps. construction;
- Handling of hazardous liquid should be done carefully by the
designated experienced person;
- Handling and storage of the potential contaminants should be done
by the experienced workers. Proper monitoring should be done by
the experienced person;
- The Ground water quality monitoring should be carried out by the
contractor following the National Water Quality Standard
(Schedule-3: Standards for Water, ECR, 1997).
Surface Water Pollution ● Construction & general wastes - Contractor should prepare waste and Wastewater Management Contractors PIU/BBIN-MPA
from the construction sites; Plan and follow it properly during the construction period;
● Oil spill from the construction - Any wastes should not be throwing into the river/khal/canal other
vehicles and construction camp than disposing to the designated waste dumping area;
can effect on fishes and aquatic - Store the oil and petroleum product in a separate location cover by
wildlife (such as snakes, frogs a concrete structure;
etc.) - Handling of hazardous liquid should be done carefully by the
designated experienced person;
- Monitor the surface water by testing in designated laboratory
should be done by the Contractor following the National Water
Quality Standard (Schedule-3: Standards for Water, ECR, 1997).
Land/ Soil Pollution ● Decrease the production capacity - Avoid the productive land, agricultural land, archaeological sites, Contractors PIU/BBIN-MPA
of agricultural land; protected area, forest area, natural habitat etc.;
● Land or soil erosion from water or - Land/soil quality should be ensured by the contractor to fill the
wind; abutment area and approach road;
● Sediment pollution and increase - Soil from fallow land should be used in earthwork in approach road;
the turbidity; - Re-vegetation the exposed area as early as possible to reduce the
● Reduction the microorganism. soil erosion;
- Create barrier for reducing the sedimentation into the water bodies;
- The Land or soil quality test should be carried out by the contractor.
Waste (Solid, Liquid and ● Improper storage and handling of - The contractor will minimize the generation of sediment, oil and Contractors PIU/BBIN-MPA
Hazardous) Pollution construction & general liquid grease, excess nutrients, organic matter, litter, debris and any form
waste such as fuels, lubricants, of waste (particularly petroleum and chemical wastes);
chemicals and hazardous liquid

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
Organic waste: remaining onsite, and potential spills from - Any wastes should not be throwing into the river/khal/canal other
foods, leafs, papers, straw, these liquid materials may harm than dump into the designated waste dumping area;
fruit cover etc. the environment and health of - Handling of hazardous liquid should be done carefully by the
construction workers. designated experienced person;
Inorganic waste: Polythene, ● Improper storage and handling of - Organic waste should be managed by composting method. A
Glasses, Synthetic paper, construction & general solid concrete chamber with 3 rooms is needed to be provided. In one
plastic etc. wastes. room organic waste should be dumped and another room inorganic
● waste will be dumped. When the room will be filled then covered by
Hazardous waste: Paint, fuel, earth. Then dump to the third room. After 6 month organic waste
chemicals, oil, petroleum will be converted into fertilizer and will be used by the farmers;
products, bitumen etc. - Inorganic waste should be given to the authorized vendor for free of
cost for recycling;
- Accidental spillage of hazardous waste should be managed by
spreading wood powder on the surface of the oil and this powder
mixed with oil must store in a designated concrete room;
- Provide appropriate PPE to the construction personnel for handle
construction materials;
- Make sure all containers, drums and tanks that are used for storage
are in good condition;
- Take all precautionary measures when handling and storing fuels and
lubricants, avoiding environmental pollution;
- Wastewater monitoring should be carried out by the contractor,
following the national standard (Schedule-10: Standard for waste
from Industrial units or Projects waste).
Hydrological Regime ● Drainage congestion and flood at - A detailed hydrological and morphological study of the site (in case Contractors PIU/BBIN-MPA
the site; of bridge or other water related structures) should be conducted;
● Erosion and siltation at the site. - Proper design and construction accordingly to accommodate design
flows;
- Provision of sufficient sizes of drains to take design flows;
- Wastes should not be disposed near any water body. All waste
depending on its characteristics, should be disposed of in a
controlled manner.
Sand Extraction/River ● Impact on river ecology - Material sourcing will be thoroughly assessed in the project ESIA. Contractors PIU/BBIN-MPA
dredging/Canal Re-excavation ● Changes in the river morphology - Contractors will be prohibited from opening new areas in local Rivers
including erosion of banks and for extracting and/or sourcing sands, including areas in local rivers
loss of agricultural land, etc. that remain in relatively good natural conditions and areas that
support fish of conservation importance.
- Community adjoining local rivers will be mobilized in the monitoring
of contractors.

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
Drainage Congestion ● Construction of diversion road on - Pier of the existing bridge structures and other construction waste Contractors PIU/BBIN-MPA
the river/ Khal/canal create should be clearly removed from the construction site during
drainage congestion; dismantling of existing structure;
- Construct diversion road on the river/khal/canal by keeping
● Stockpiling of construction provision of open space so that water flow cannot hamper by the
materials in the river/khal/canal construction activities;
also create drainage congestion. - Immediately remove all the construction debris from the
construction site as well as from the water bodies in a planned way;
- Duration of stockpiling should be minimized as much as possible;
- Avoid the encroachment of the water bodies;
- Protect water bodies from sediment loads by silt screen or bubble
curtains or other barrier;
- Construction activity should be recommended during the dry season;
- Construction workers shall be instructed to protect water
resources;
Road Traffic and Accidents ● Increased traffic use of narrow - Proper Traffic Management Plan (TMP) should be prepared by the Contractors PIU/BBIN-MPA
access road by construction contractor during starting of construction & follow it strictly;
vehicle will affect the movement - In this TMP, the road safety measures such as speed breakers,
of normal road traffics and the warning signs/lights, road safety signs, flagman etc. should be
safety of the road users specially included to ensure uninterrupted traffic;
the students - Movement specially at nearby the educational (Schools, colleges,
Madrasha etc.), community infrastructure (mosques, graveyards,
Prayer Ground etc.) and health complex;
- In addition, BRTA traffic rules and regulations should be strictly
followed;
- Divert traffic to follow alternative routes to avoid traffic jams;
- Avoid talking with mobile during driving.
Landscape and Aesthetics ● Excavation of borrow pits, stock - Parking of construction vehicles and stockpiling of construction Contractors PIU/BBIN-MPA
piling of construction materials, materials/excavated earth should be done in systematic way to avoid
placing of construction equipment the damaging of aesthetics of the site;
and parking of construction - Duration of stockpiling should be minimized as much as possible;
vehicles; - Vegetation plantation after completion of the construction work;
● Presence of construction camps, - Completely remove the construction camp facilities, equipment’s
equipment and their activities; and their activities;
● Movement of construction - Limit the speed of the vehicles and cover the vehicles during the
vehicles on the existing road movement or transportation of materials on the existing road
network and temporary haul network and temporary haul road;
roads; - Plantation of trees at the construction site after completion of the
construction activities immediately.

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
● Closure of existing bridges by
construction of diversion road.
Occupational Health and ● Campsites for construction - Construction workers camp shall be located at least 500 m away Contractors PIU/BBIN-MPA
Safety workers and Safety are the from the nearest habitation;
important locations that have - Consider the location of construction camps away from communities
significant impacts such as health in order to avoid social conflicts;
and safety hazards on local - Create awareness among the camp users on health and safety
resources and infrastructure of requirements to be maintained and code of conduct.
nearby communities.
● Lack of proper infrastructure - Adequate housing for all workers should be provided avoiding over Contractors PIU/BBIN-MPA
facilities, such as housing, water crowing;
supply and sanitation facilities - Safe and reliable water supply;
will increase pressure on the - Hygienic sanitary facilities and sewerage system.
local services and generate
substandard living standards and
health hazards
● Management of wastes is crucial - Ensure proper collection and disposal of solid wastes within the Contractors PIU/BBIN-MPA
to minimize impacts on the construction camps;
environment. - Insist waste separation by source; organic wastes in one container
and inorganic wastes in another container at sources;
- Dispose organic wastes in a designated safe place on daily basis;
- The organic wastes should be always covered with a thin layer of
sand so that flies, mosquitoes, dogs, cats, rats, etc. are not attracted;
- Locate the garbage pit/waste disposal site minimum 500m away
from the resident area so that people are not disturbed with the
odor likely to be produced from anaerobic decomposition of wastes
at the waste dumping places.
● Risks of diseases to be - Provide adequate health care and sanitation facilities within the Contractors PIU/BBIN-MPA
transmitted including malaria, construction sites;
exacerbated by inadequate health - Train all construction workers in basic sanitation and health care
and safety practices. issues and safety matters and on the specific hazards of their work;
- Provide HIV awareness programming, including STI (sexually
● Risk of work crews spreading transmitted infections) and HIV information, education and
sexually transmitted infections communication for all workers on regular basis;
and HIV/ AIDS. - Regular mosquito repellant spraying during monsoon periods.
● Health and safety risks to the - Provide the workers a safe and healthy work environment; Contractors PIU/BBIN-MPA
construction workers and site

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
visitors leading to severe injuries - Provide appropriate PPE for workers, such as safety boots, helmets,
and deaths. masks, gloves, protective clothing, goggles, full-face eye shields and
ear protection;
- Maintain the PPE properly by cleaning dirty ones and replacing them
with the damaged ones;
- Appoint an environment, health and safety manager to look after the
health and safety of the workers;
- Inform the local authorities responsible for health, religious and
security before commencement of civil works and establishment of
construction camps so as to maintain effective surveillance over
public health, social and security matters.
● Lack of first aid facilities and - Provide health care facilities and first aid facilities are readily Contractors PIU/BBIN-MPA
health care facilities in the available;
immediate vicinity will aggravate - Document and report occupational accidents, diseases, and
the health conditions of the incidents and actions taken;
victim. - Identify potential hazards to workers, particularly those that may be
life threatening and provide necessary preventive and protective
measures;
- Provide awareness to the construction drivers to strictly follow the
driving rules;
- Provide adequate lighting in the construction area and along the
roads in the construction site.
Community Health and Safety ● Accidents on the approach road - Include the related E&S provisions in the C-ESMP/O-ESMP with Contractors PIU/BBIN-MPA
and construction site; payment milestones.
● Noise and dust pollution; - Prior to start the construction activities contractor will be informed
● Communicable diseases can the local community;
spread among the local - Instruct the drivers and limit the speed of the vehicles;
community. - Regular health checkup of the workers and awareness training about
● Risk of SEA/SH the communicable diseases;
- Ban all swimming and fishing activities in the construction site, in
case of a bridge site;
- Proper lighting at the project site during the night time;
- Avoid unnecessary noise pollution;
- Spraying water in the dry surface to reduce the dust pollution
- Provide proper access control to the project site and unauthorized
entry to the project site will be controlled by deploying security
personnel.
- Enforce a Code of Conduct for all the workers
- Set up and run a SEA/SH compliant GRM

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
- Raise awareness among the workers, communities and stakeholders
on SEA/SH and the project GRM
Labor Union ● Slow down the progress and - Strict implementation of labor laws Contractors PIU/BBIN-MPA
haphazard conditions in the - Face to face meetings and signed some agreements
construction sites may arise - Regular monitoring of the labor sites to note down any negative
aspects.
Security ● May affect the project - Code of conduct, behavior commitments, clear and accessible Contractors PIU/BBIN-MPA
economically and also result in disciplinary process, and grievance process;
loss of resources - Engagement with communities about the project's impacts on
community safety and security, awareness raising concerning the
Code of Conduct commitment and project grievance mechanism, as
outlined in the Stakeholder Engagement Plan (SEP)
- Policy on "use of force" and clarity on proportionality to risk. The use
of force by direct or contracted workers in providing security should
not be sanctioned except when used for preventive and defensive
purposes in proportion to the nature and extent of the threat.
- Incident reporting: means of receiving and reporting incidents and
allegations, and guidelines for receiving and following up on them,
including procedures for reporting to the Borrower and the Bank, as
required.
- Site access control: guidelines for security personnel on how to
interact with community members seeking access to a project site or
raising a concern (for example, training on the grievance mechanism
and Code of Conduct).
- Any allegations of criminal behavior should be reported to relevant
authorities, whether from private or public security, employees or
contractors.
- If gender-based violence or sexual exploitation and abuse issues
arise or are alleged during project implementation or supervision,
Bank Management must be alerted immediately. Security-related
allegations or incidents can include issues such as theft, abuse of
power and retaliation, sexual harassment and exploitation, gender-
based violence, and bribery and corruption.
SEA/SH Issues Greater exposure to communicable - A Gender and SEA/SH Action Plan is prepared for the project that Contractors PIU/BBIN-MPA
and sexually transmitted diseases details the relevant mitigation measures both preventive and
including HIV/AIDS due to influx of curative, and as well includes specific actions to promote gender and
outsiders such as traders, women empowerment.
businesspersons, skilled and
unskilled migrant laborers, transport

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
workers, etc. all of which may also
potentially lead to social tensions
among the local communities
Operation Phase
Air Pollution ● Dust emission from the increasing - Establish the speed breaker to limit the speed of the vehicle near the MoC, BLPA, NBR and Relevant
number of vehicles in the site site; RHD Ministries with
area; - Strictly follow the BRTA rules and regulations; the assistance of
● Vehicular emission from burning - Increase number of plantation by adding new species of trees on the DoE
fuels. appropriate locations after consultation with the concern authority.
Surface Water Pollution ● Remaining construction materials - Remaining construction materials will be completely removed from MoC, BLPA, NBR and Relevant
may be washed by the rainfall the proposed project site after completing of the construction RHD Ministries with
into the water sources and lead activities; the assistance of
to sedimentation and increase - Cover the bare surface by plantation of trees/vegetation to reduce DoE
turbidity; the surface soil erosion;
● Hazardous materials spilled by - Speed control measures close to the site to reduce the occurrence
accidents; of accidents;
● Soil erosion during rainy season - Bank protection work can be done at the site;
can contaminate nearby surface - Avoid rainy season for continuing any development activities.
water.
●
Ground Water Pollution ● Accidental spillage of hazardous - Speed control measures close to the site to reduce the occurrence MoC, BLPA, NBR and Relevant
chemicals and materials. of accidents; RHD Ministries with
- Inform to the concern authority to take necessary action to reduce the assistance of
the contamination of groundwater. DoE
Hydrology and Flood pattern ● Increase flood/ water logging/ - During the planning stage and site selection local hydrology and MoC, BLPA, NBR and Relevant
drainage condition; flooding level will be considered; RHD Ministries with
● Encourage for erosion and - Vertical navigation clearance should be kept in design and planning; the assistance of
siltation. - A separate and details hydro-morphological study should be DoE
conducted before starting construction activities;
- Site should be clean properly after completion of the construction
activities so that the natural drainage system may not hampered.
Noise Pollution ● Faulty engine and hydraulic horn - Necessary instruction for the drivers; MoC, BLPA, NBR and Relevant
may increase the noise level. - Establishment of signboard near the sensitive receptors like RHD Ministries with
mosques, schools, temple, bazar etc. the assistance of
DoE
Flora and Fauna ● Dust will hinder vegetation - Re-plantation of various suitable local trees can be done on the MoC, BLPA, NBR and Relevant
growth; slopes of the roads or the suitable locations around the project site; RHD Ministries with

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
● Increase number of death of - Establishment of speed breaker or signboard indicating the the assistance of
wildlife and collision with the movement route of the wildlife; DoE
vehicles; - No disturbance for aquatic animal and keeps provision for the fish
● Avifauna will be affected by the and other aquatic animals movement;
movement of vehicles; - Diversion road should be removed properly as soon as possible;
● Fish and other aquatic animals - Construction workers shall be instructed to protect natural
will be affected. resources, flora and fauna, including wild animals;
- Natural river/khal/canal will be reinstated after completion of
construction works;
- Fingerling (fish) can be released to the river/khal/canal near the
bridge site to boost up the fish resources.
Landscape and Aesthetics ● Land use of the proposed - Tree/vegetation plantation at the suitable site; MoC, BLPA, NBR and Relevant
project area will be changed; - Proper removal of construction camp facilities and construction RHD Ministries with
● Improper removal of wastes from the site after completion of the works; the assistance of
construction camp facilities and - Excavated borrow pit area will be properly managed by the DoE
other construction waste will contractor, it will be preferred to use dredging materials after
affect landscape and quality testing.
aesthetics.
Labor Union ● Slow down the progress and - Strict implementation of labor laws MoC, BLPA, NBR Relevant
haphazard conditions in the sites - Face to face meetings and signed some agreements Ministries with
may arise - Regular monitoring of the labor sites to note down any negative the assistance of
aspects. DoE
- Revisit the agreements and do necessary changes.
Security ● May affect economically and also - Policy on "use of force" and clarity on proportionality to risk. The use MoC, BLPA, NBR Relevant
result in loss of resources of force by direct or contracted workers in providing security should Ministries with
● May result in national security not be sanctioned except when used for preventive and defensive the assistance of
issues purposes in proportion to the nature and extent of the threat. DoE
- Incident reporting: means of receiving and reporting incidents and
allegations, and guidelines for receiving and following up on them,
including procedures for reporting to the Borrower and the Bank, as
required.
- Site access control: guidelines for security personnel on how to
interact with community members seeking access to a project site or
raising a concern (for example, training on the grievance mechanism
and Code of Conduct).
- Any allegations of criminal behavior should be reported to relevant
authorities, whether from private or public security, employees or
contractors.

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Responsibility
Issues/ Activities Potential E&S Impacts Proposed Mitigation Measures
Implementation Supervision
- If gender-based violence or sexual exploitation and abuse issues
arise or are alleged during project implementation or supervision,
Bank Management must be alerted immediately. Security-related
allegations or incidents can include issues such as theft, abuse of
power and retaliation, sexual harassment and exploitation, gender-
based violence, and bribery and corruption.

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Environmental Codes of Practice (ECoPs)

The environmental codes of practice (ECoPs) are generic, non-site-specific guidelines. The ECoPs consist
of environmental and social management guidelines and practices to be followed by the contractors/
implementation organizations for sustainable management of all environmental and social issues. The
contractor will be required to follow them and also use them to prepare site-specific management
plans. Details of the ECoPs listed in Annex D.

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6. ENVIRONMENTAL AND SOCIAL MANAGEMENT PROCEDURES

6.1 General
This chapter outlines the framework for assessing and managing environmental and social issues in
different sub-projects. It also provides necessary procedures and tools for screening and assessing
environmental and social impacts. Each phase-wise development's environmental and social
assessment need to be carried out based on the provisions of the Environment Conservation Acts and
Rules of GoB, ES Management Principles and the relevant World Bank’s Environmental and Social
Standards (ESSs).

6.2 ES Management Principle

Due to the nature of some of the proposed project activities of BBIN- RTTF 1 and their potential
environmental and social risks and impacts, the project falls under ‘RED’ category according to ECR,
1997 and also rated as ‘HIGH’ as per the World Bank ESS1 risk category. This requires detailed ESIAs and
execution of environmental and social management plans for relevant sub-projects. Therefore, the
ESMF is prepared based on the following principles that can lead the planning and implementation of
the project activities.
1. The PCC/BBIN-MPA Program at the national level and Project Directors (PD) of PIUs of the IAs at the
project level are responsible for the compliance with national policies, regulations, and WB ESSs
and Guidelines, as mentioned in this ESMF report. The ESMF will serve as the basis for ensuring ES
compliance.
2. PDs of the respective PIUs/BBIN- MPA program, is responsible for obtaining environmental
clearance from DoE, local government agencies and World Bank, as required. IEE, ESIA and ESMP
need to be prepared for activities as determined by DoE. In case, requirements of DoE’s ESIA
guideline differ from those of WB ESF, the more stringent standards and requirements will apply.
Planning and design of the any additional activities should ensure ES screening, based on which
further ES assessment will be carried out to develop proper ESMP.
3. Environmentally Sensitive areas, cultural sites, restricted or disputed lands (of identified during
project implementation) should be taken care of with appropriate mitigation or compensation
measures during implementation.
4. Participation of stakeholders (especially local communities) should be ensured by PIUs/BBIN- MPA
program in planning, implementation and monitoring of each sub-components and associated
activities.
5. PIUs will inform project stakeholders about project interventions and its potential impacts on the
surrounding ES elements. PIUs/BBIN- MPA program will ensure appropriate institutional set up for
implementing environmental and social management plan and inter-agency coordination. PIUs
should also ensure that bidding documents for construction contractors have specific clauses to
ensure implementation of ESMPs, as required.
6. Contractors to be engaged for construction/renovation/expansion/repair and maintenance and
equipment installation under the project will ensure provision of First Aid Kit at camp/work site with
proper drinking water and sanitation facilities. Worker‘s/crew’s health and safety measures shall be
ensured and use of personal protective equipment shall be at place.
7. PIU/BBIN- MPA program, will ensure safety provision has been provided for the resettlement sites.
8. PIU/BBIN- MPA program will undertake public disclosure about the project interventions and
potential impacts.
9. In case co-financing PIU/BBIN- MPA program by other development partners, apply ESF to all
activities throughout the project cycle. All E&S assessments, instruments and documents will be
prepared in accordance with the ESF and the Bank will conduct its due diligence of these
instruments and documents. During implementation, the GoB will supervise and monitor E&S risks

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

and impacts of the entire project activities, in accordance with the E&S instruments and documents
and will ensure all supervision records and project sites are accessible to both WB and DPs. WB and
DPs may also conduct joint supervision missions. However, there will be a single Grievance Redress
Mechanism (GRM) covering the PIU/BBIN- MPA program.

6.3 Environmental and Social Assessment and Management Process

● PIUs in coordination of the ES experts of the 4 PIUs will provide technical backstopping and
coordination support to the PCC to perform the ES screening of the respective components of the
BBIN-MPA Program. The relevant ES experts of PIUs will start the task during the initial stage of
the project implementation.
● If ES Screening would identify any activities that requires further ES Assessment, respective PD of
that PIU in coordination of other relevant staff will engage an independent ESIA consulting firm to
generate a detail ES baseline of the project, conduct initial scoping (or IEE) and prepare a ToR for
ESIA study.
● PIUs will share the scoping/IEE report along with the draft ESIA ToR to respective clearance office
of DoE.
● PCC with support of the respective PIU will review, and clear screening and environmental
assessment reports made by Environmental consultant before submitting for DoE clearance and
provide necessary technical inputs.
● PCC through 4 PIUs will conduct verification of some screening and assessment through field visit.
● PIUs through relevant ES staff will ensure that environmental considerations are given enough
attention, weight, and influence over selection of construction sites and improvement of
infrastructures.
● Bid documents will be prepared by the respective PIU. ES consultants of PIUs will make sure
necessary ES clauses are included in the bidding documents and ESMP implementation should be
done by Contractors. PIUs consultants and other technical and M&E experts will supervise ESMP
implementation and ES compliance. Furthermore, preparation of ESIA and ESMPs should be added
as a separate item before bidding document references.
● All the activities of BBIN-MPA Program will follow existing Environmental and Social Code of
Practices (ESCoPs) prepared under ESMF.
● The project will ensure that ESIA addresses all potential ES direct and indirect impacts of the
project throughout its life: pre-project, during project and operation stages; and suggest
appropriate mitigation measures. If any additional impacts are identified, ESIA and ESMP should
be reviewed and updated.

6.4 Environmental and Social Management Procedure

6.4.1 Overall Procedure
The overall environmental and social management procedure is shown in the figure below. After the
sub-project has been developed with outline design and location/alignment options, screening of
environmental and social risks can be done. It is expected that most of the sub-projects will require
some form of feasibility study. This will help in the preparation of E&S documents such as IEE/ESA, ESIA,
RAP and ESMP. The recommendations from these E&S documents need to be incorporated by the
detailed design team and also incorporated into the tender (bidding) documents. PMU would then need
to implement the proposed mitigation measures, monitor and report compliance.

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6.4.2 Project Screening

The formal environmental and social
assessment starts with proposed
interventions' environmental and social
screening (Annex A). The purpose of the
environmental screening is to get
relevant concerns addressed in the
project's design phase. Environmental
and Social Screening will determine
whether sub-project interventions will
require an IEE/ESA or a full scale ESIA.
Using the screening forms, the
proposed sub-projects interventions
will be screened by PIU/PMC to identify
any potential adverse impacts/effects
from the sub project activities and stage
of further assessment with preparation
of separate environmental
management plan to be required for the
PIU under BBIN MPA program.
The environmental and social screening
would involve: (i) reconnaissance of
sub-project area and its surroundings;
(ii) identification of major sub-project Figure 6.1: Overall Procedure of Environmental & Social Management
activities; and (iii) preliminary
assessment of the impacts of these activities on the ecological, physico-chemical and socio-economic
environment of the sub-project surrounding areas and considerations that need to be further
investigated through IEE/ESA or ESIA.

6.4.3 Environmental and Social Impact Assessment

The purpose of ESIA is to give the environment and people its due importance in the decision-making
process by clearly evaluating the environmental and social consequences of the proposed study before
action is taken. Early identification and characterization of critical environmental and social impacts
allows the public and the government to form a view about the environmental viability and social
acceptability of a proposed development project and what conditions should apply to mitigate or
minimize those risks and impacts.
The ESIAs will utilize a well-planned and all-inclusive communication and consultation strategy and
include a baseline survey covering the prevailing status of income, employment, education, age, skills
and other socio-economic aspects along with cultural and community aspects in the areas. The
assessment will feed into the individual Resettlement Plans prepared for each site and will be
incorporated, along with consultation feedback from those identified in the PAP census and all other
relevant stakeholders, in the development of mitigation measures, especially livelihood strategies.
IAs will undertake a survey for identification of the persons and their families likely to be affected by
the project. Every survey shall contain the following information of, the project affected families-

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▪ Members of families who are residing, practicing any trade, occupation or vocation in the
project affected area;
▪ Project Affected Families who are likely to lose their immovable assets, commercial
establishment, agricultural land, employment or are alienated wholly or substantially from the
main source of their trade occupation or vocation;
▪ Families belonging to indigenous categories;
▪ Vulnerable persons;
▪ Families that are landless (not having homestead land, agriculture land or ether homestead or
agriculture land) and are below poverty line, but residing in the affected area;
▪ Losing access to private property or common property resources.
IAs on completion of the assessment will disseminate the results among the affected community. Based
on the assessment, the project will prepare an action plan to mitigate or minimize the adverse impacts
identified during the survey. The draft mitigation plan in form of a RAP will be again disseminated among
the affected individuals/ community. The feedback received from the affected groups will be
incorporated to the extent possible before finalization of the RAPs. Procedure of RAP has been
separately discussed in detail in the Phase 1 Resettlement Policy Framework (RPF).
The initial screening carried out as part of preparation of this ESMF has not found any indigenous
communities as potential project affected persons (PAPs). However, additional in-depth screening and
assessment will be carried out during site-specific ESIA/ESMP preparation and if at that time, such
indigenous communities are found, relevant mitigation measures will be put forward with relevant
small ethnic community development plan, with “free, prior and informed consent” as relevant.
According to the project implementation planning, the activities that need ESIA will be implemented at
different periods and hence, site-specific ESIAs will be required prior to the actual intervention start. In
the preparation phase, the ESIA shall achieve the following objectives-
▪ To establish the environmental and social baseline in the study area (a guideline to establish
the baseline is given in Section 4.4), and to identify any significant environmental issue;
▪ To assess these impacts and provide for measures to address the adverse impacts by the
provision of the requisite avoidance, mitigation and compensation measures;
▪ To integrate the environmental issues in the project planning and design;
▪ To develop appropriate management plans for implementing, monitoring, and reporting the
environmental mitigation and enhancement measures suggested.
The impact assessment will be conducted using major stages as shown in the Figure 6.3.
Stage 1: Planning
Soon after the commencement of project, based on desk study, reconnaissance survey and experience
of earlier similar projects, detailed methodology and schedule should be prepared for the effective and
timely execution of the Environmental and Social Impact Assessment.

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● Desk Study: To collect the secondary information and checking out the methodology for
carrying out the ESIA study and fixing of responsibilities of the EA team members for preparing
a complete, addressing all issues, Environmental and Social Management Plan.
● Reconnaissance survey: To collect the first-hand information about the project area and
develop a perspective of the entire team and revise the methodology and work program.
● Experience from Earlier Project:
o Focus on the main issues: The ESIA must not try to cover too many topics in too much
detail. Effective scoping can save both time and money by focusing the ESIA studies on the
key issues.
o ESIA requires the formation of a multidisciplinary team and the leadership of a strong
Coordinator. The range of effects considered in the ESIA requires the skills of technical
experts to be employed on an assessment team, led by a Team Leader. It is important to
involve the right people (e.g., scientists, engineers, policymakers, government
representatives, representatives of public interest groups and the local community) and
agencies (e.g., the developer, the aid agency, regulatory authorities and politicians) in the
ESA process. Selection will be made through consultation at different stages.
o Make maximum use of existing information before engaging expensive field studies.
o Determination of Project influence Area. The project influence area will be finalized based
on the reconnaissance survey and desk study and technical assessment.
o Present clear and appropriate options for mitigation of impacts and for sound
environmental and social risk management. Mitigation is an integral part of impacts
assessment. Application of appropriate mitigation can eliminate or reduce negative
impacts, and improve the net overall environmental performance of a project. Hence,
public consent and practical viability will be considered in proposing mitigation measures.
o Post-ESIA audits
and monitoring
programs are
essential to
ensuring that ESIA
commitments are
carried out and
that future ESIA
improve. An
effective
monitoring plan
will be proposed
in consultation
with the client and
the World Bank.
Proper budgeting
will be ensured for
smooth
functioning of
monitoring plan
proposed.

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Stage 2: Scoping
Scoping will identify which of the activities has a potential to interact with the environment. Scoping
will be conducted early in the ESA process so that a focus on the priority issues (i.e., those that have the
greatest potential to affect the natural and/or environment) can be established for the rest of the ESA
process. After scoping, necessary consultation with stakeholders will be made to incorporate any
unattended issues. Key elements/inputs to the scoping exercise will be as follows:
● Gathering and reviewing existing environmental data like atmosphere, climate, topography,
congestion area, alternative requirement, land use pattern, hydrology and drainage
pattern, major River and waterways, religious, cultural and archaeological sites and
sensitive areas.
● Identifying project stakeholders; including PAPs, marginalized and vulnerable groups,
women, poorest of the poor, Government and nongovernment agencies (utilities),
Bangladesh Water Development Board, LGED, Agricultural Department, Department of
Environment (DoE), local government institutions, other relevant government department
and ministries, etc.
● Assemble and review relevant legislative requirements, environmental and social standards
and guidelines (national and international) associated with the proposed development, and
the World Bank’s operational policies and standards.
● Gathering existing information sources and local knowledge;
● Informing stakeholders of the project and its objectives and get input on the ESA;
● Identifying the key environmental concerns (community and scientific) related to a project
and the relative importance of issues;
● Defining/preparing the ESA work program, including a plan for public and stakeholder
involvement;
● Carrying out monitoring of natural environment including air, water, soil, noise etc.
● Defining the range of project alternatives to be considered.
● Obtaining agreement/consensus on the methods and techniques to be used in ESA studies
and document preparation;
● Determining/freezing the spatial and temporal boundaries for the ESA studies.
1. The following issues will be addressed through scoping, but will not be limited to.
● To improve the quality of ESA information by focusing scientific efforts and ESA analysis on
truly significant issues;
● To ensure environmental concerns identified and incorporated early in the project planning
process, at the same time as cost and design factors are considered;
● Reducing the likelihood of overlooking important environmental issues;
● Thinning the chance of prolonged delays and conflicts later in the ESA process by engaging
stakeholders in a constructive participatory process early in the ESA process.
Stage 3: Environmental and Social Impact Assessment
After conducting ESA/IEE, if necessary, the ESIA should be conducted, as per ToR for ESIA suggested in
ESA/IEE and cleared by DoE. The process of ESIA study is briefly described below:
● Analysis of the Project Components: All the RHD, MoC, BLPA, NRB components and design
specifications will be analyzed to get insight into the project activities. This will guide detail
environmental baseline survey and particular investigations.
● Data collection on Environmental and Social Baseline: The proposed subprojects'
environmental and social baseline conditions will be collected through field visits, surveys,
and intensive consultation with local people. Intensive consultation with the stakeholders
should be carried out to update the baseline condition to obtain their perceptions of the
proposed activities and the possible impacts. A guideline to establish the baseline is given
in Section 4.4.

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● Major Field investigations: At this stage, detailed field survey (social and environmental)
will be carried out to obtain information on the possible impact of the interventions on the
environmental parameter.
● Assessment of Impacts: The impacts of the proposed subprojects on the environmental
and social components will be identified through consultation with experts and local
community. The impacts will be analyzed and graded qualitatively (e.g., high, medium, low)
in order to identify the major impacts. The future-without-project (FWOP) condition will be
generated through trend analysis using information collected. The future-with-project
(FWIP) condition will be predicted using professional judgment of the multi-disciplinary
team members based on information collected. Difference between the two (FWIP-FWOP)
conditions will be taken as impact of the proposed interventions. The impact will also be
monitored. Moreover, cumulative impacts of the project inside or outside the project area
will be analyzed. Possible mitigation measures for alternatives of the project will be
identified in this stage. For true impacts prediction following questionnaire will be
attempted to answer:
o How will a particular project activity give rise to an impact?
o How likely is it that an impact will occur?
o What will be the consequence of each impact?
o What will be the spatial and temporal extent of each impact?
● Evaluation of impacts: Impact assessed on different parameters will be evaluated for both
positive (+) and negative (-) impacts considering magnitude, immediacy, reversibility and
sustainability. Phase I ESIA studies will be used to understand the impact assessment for
subsequent phases. Impacts can also be quantified for the infrastructure projects; a typical
subproject can evaluate the impact using the formula described below:

⮚ Impact Assessment of Infrastructure Project

− The Method of Assessment. A simple methodology has been developed for Environmental
Evaluation System (EES) developed by Battelle Columbus Laboratories in the United States. In
Bangladesh, in absence of a database it is only possible to estimate the potential environmental
changes from the existing situation. In this method, the existing environmental conditions will
be the reference level and the positive and negative changes in environmental conditions
resulting from the proposed project will be evaluated. The environmental impact will be
assessed by Environmental Impact Values (EIVs), which may be defined mathematically as
follows:
EIV =∑ (𝑉𝑖) (𝑊𝑖)
where Vi is the relative change in the value of environmental quality of parameter i with respect
to existing situation, Wi is the relative importance or weight of parameter i, and n is the total
number of environmental parameters related to the project.
The computation of Environmental Impact Value (EIV) of a project needs determination of Vi,
the value representing the magnitude of alteration of the environmental parameters, and Wi
the value representing relative weight or importance of the respective parameters.
− Magnitude of Environmental Alterations. Change of environmental parameters should not be
measured with respect to existing condition. The standard practice is to compare the future-
with-project condition against the future-without-project condition, difference between these
two are taken as the change in environmental parameters. The future-without-project
condition should be generated through trend analysis using historical data collected during the
establishment of baseline condition.
The beneficial and adverse changes in environmental parameters resulting from a project,
usually expressed in qualitative terms have been plotted in a scale to quantify the

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environmental
alterations. Figure 6.2
shows the correlation
between qualitative
statement and proposed
quantitative values of
environmental changes
resulting from a project.
Since the changes of

Figure 6.2: Quantification of Environmental Impact

environmental parameters are
measured with respect to
existing condition, no change
has 0 values. Benefits or
positive impacts are graded
from +1 to +5, and negative
impacts are scored from -1 to -
5. Impacts are assessed
quantitatively wherever
possible. For example, if a
project will positively impact
agricultural productivity and the
production will be increased by
50%, then a scoring of +3 is
applied to agricultural
productivity. Similarly, if
assessed that the fish
production will be decreased by
30%, a negative scoring of –2 is
applied for the respective
Figure 6.3: Typical Relative Importance Values of Environmental
fishery component. A value
Parameters Related to Infrastructure Projects
from the scale representing
effect of the project on each parameter will be taken to compute the EIV of the project.
Where it is not possible to directly quantify the impact in terms of increase or decrease in
production, or deterioration of water quality or degradation of environment, the impact has to
be estimated. For the purpose of estimation, positive and negative impacts are divided into
three different groups, as Low, Medium and High. A low numerical value ranges from 1 to 2,
Medium 3 and High with a numerical value ranging from 4 to 5.
− Relative Importance of Environmental Parameters. All environmental parameters influenced
by the project are not of equal importance or weight. The importance of a parameter varies
from country to country depending on the country's environmental concerns. Generally, in
Bangladesh flood, employment, agriculture, fisheries etc. carry more importance than many

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others. The importance may also vary in different regions within the country. So, the same
parameter may have different values for subprojects located in different regions.
The parameters related to infrastructure projects have been given different values based on
prevailing environmental concerns in Bangladesh and presented in Figure 6.5. These values
have been arrived at after consideration of all probable impacts due to the project during its
pre-construction, construction and post-construction stages. These are average values only
based on normal conditions, which should be modified if the projects are located in special
locations with significant environmental concerns. The values representing importance or
weight of the parameters can be used to compute the relative impacts of the parameters which
are then summed up to obtain the total EIV of the project. In Table 6.5 a sample calculation for
determination of EIV has been shown. Relative Importance Values of Environmental Parameters
shown in Figure 6.5 has been assigned considering the infrastructure development projects.
● Preparation of Environmental and Social Management Plan: The ESMP will be prepared
suggesting mitigation measures for minimizing the effect of the negative impacts,
compensation measures for the negative impacts which cannot be mitigated, enhancement
measures for increasing the benefits of the positive impacts, emergency plan for taking care of
natural hazards and accidental events. An environmental and social monitoring plan will also be
suggested in the ESMP. Each component of the ESMP will be divided into pre-project, during
project, post project and operation and maintenance phases. Responsibilities of the institutions
in the implementation of the ESMP will be suggested to ensure efficient utilization of all the
parties involved. The ESMP should also include institutional capacity assessment and capacity
building plan.
● ESIA Report Preparation: All the findings would be presented in the ESIA reports as per ToR. A
preliminary ToR for ESIA is given in Annex E. Annex F is an indicative guideline on preparing ESIA
report.
● Environmental Assessment and Management for Resettlement Sites: Environmental
assessment and management principles and requirements described above will be equally
applicable for the construction of the resettlement sites (if any). If necessary, a generic guideline
to conduct ESIA of resettlement site/s will be prepared during the detail ESIA.
● Contingency Plan for COVID-19: BBIN- MPA Program will develop a contingency plan following
the WHO guidelines and the World Bank requirements for each district to put in place
procedures in the event of COVID-19 reaching the area or already there. The contingency plan
will be developed in consultation with national and local healthcare facilities, to ensure that
arrangements are in place for the effective containment, care and treatment of workers who
have contracted COVID-19. The contingency plan will also consider the response at the events
of infections among the workforce, community transmission is taking place and when it is likely
that access to and from a target area will be restricted to avoid spread of COVID-19. The
contingency plan will be articulate to GBV risks screening and putting in the corresponding
measures to prevent and mitigate the SEA/SH risks. The contingent incidents will be duly
registered with the GM with observations of anonymity protocol. The Contingency Plan will be
developed in consideration of the potential challenges with the project staff and workers in
COVID-19 situations including health and safety of the workforce as well as the beneficiary
communities.
Stage 4: Stakeholder Consultation and Public Disclosure
“Public consultation” refers to the process by which the concerns of affected persons and other
stakeholders who have plausible stake in the environmental and social impacts of the project or activity
are ascertained with a view to taking into account all the material concerns in the project or activity
design as appropriate. As part of the stakeholder consultation process, all the relevant stakeholders will
be identified with particular focus on directly affected persons and the disadvantaged and marginalized
groups and peoples.

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The consultations will ensure participation of all the relevant stakeholders and where necessary
separate consultations will be organized for the women and disadvanted and marginalized groups. After
completion of the public consultation, the feedback on environmental and social risks and impacts will
be addressed and appropriate mitigation measures will be included in the ESIA and ESMP. The final ESIA
report, so prepared, shall be submitted by the client to the concerned authority for appraisal.

6.4.4 Environmental and Social Management Plan (ESMP)

This section presents the project's outline environmental and social management plan (ESMP). A more
detailed version of ESMP must be included in the ESIA of the BBIN MPA Program subprojects.

6.4.4.1 Scope and Objectives of ESMP

The basic objective of the ESMP is to manage adverse impacts of program interventions in a way that
minimizes the possible adverse impact on the environment and people of the program influence area.
The specific objectives of the ESMP are to-
▪ Identify the mitigation measures during ESMF and ESIA; and facilitate implementation of those
during implementation of the project
▪ Maximize and sustain potential program benefits and control negative impacts;
▪ Draw responsibilities for program proponent, contractors, consultants, and other members of
the program team for the environmental and social management of the program;
▪ Define a monitoring mechanism and identify monitoring parameters in order to:
o Ensure the complete implementation of all mitigation measures,
o Ensure the effectiveness of the mitigation measures,
o Maintain essential ecological process, preserving biodiversity and where possible restoring
degraded natural resources and habitats; and
o Assess environmental training requirements for different stakeholders at various levels.
2. The ESMP will be managed through a number of tasks and activities and site-specific management
plans. One purpose of the ESMP is to record the procedure and methodology for managing
mitigation identified for each negative impact of the program. The management will clearly
delineate the responsibility of various participants and stakeholders involved in the program's
planning, implementation, and operation.
6.4.4.2 Inclusion of Relevant Components of ESMP in Contract Documents
The specific ESIA should include a section on special environmental clauses (SECs) to be incorporated in
the Tender Document under General/Particular Specification. These clauses aim to ensure that the
Contractor carries out his responsibility of implementing the environmental and social management
plan (ESMP), monitoring plan, and other environmental and safety measures. Such clauses may specify,
for example, penalties for non-compliance as well as incentives to promote strong compliance. The
various contractors must be made accountable to implement the plans and mitigation measures which
pertain to them through contract documents and/or other agreements of the obligations and
importance of the environmental and social components of the program. In addition, the specific ESIA
will ask to submit an Environment Management Action Plan (EMAP) to encompass all of the detailed
plans, measures and management systems they are required to develop and implement, to be based
on the ESMF recommendation and ESIA findings, their work methodology, work force involvement,
equipment’s standard, and work scheduling.

6.4.4.3 Payment Milestones

Payments to contractors would be linked to environmental performance, measured by completion of
the prescribed environmental and social mitigation measures. Contractors would be required to join
forces with the executing agency, project management unit, supervising consultants and local

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population for the mitigation of adverse impacts of the program. Effective implementation of the
proposed mitigation and monitoring measures would attract trained and experienced environmental
management staff.

6.4.4.4 Guideline to Incorporate Environmental and Social Management in Bid

Documents
The PIU consultants will be responsible for incorporating environmental management requirements in
the bidding documents, with the assistance of the environmental and social consultants. The generic
guidelines to incorporate environmental and social aspects in the bidding documents are listed below.
These are examples only and shall be further elaborated and expanded upon based on the findings and
recommendations of the specific ESIAs.
▪ Prepare cost estimates, to be incorporated in Bid Documents.
▪ Contractor version of the Environmental Management Plan along with the ESCoPs to be
incorporated in the bid document’s work requirements.
▪ Penalty clauses for not complying with ESMP requirements to be incorporated.
▪ Indicative penalty clauses are presented below (Addendum to Clause 17.2 Contractor’s Care of
the Works of FIDIC).
o The contractor has to follow all traffic safety measures as defined in the technical
specification. A specific amount shall be determined to handle the damage issue for non–
conformity of traffic safety measures as per the decision of the PIU officials.
o The contractor has to follow all environmental mitigation and management measures as
defined in the technical specification read along with the Environmental and Social
Management Plan for the specific project activities. . A specific amount shall be determined
to handle the damage issue for non–conformity of traffic safety measures as per the
decision of the PIU officials..
o The contractor has to ensure that prior to every monsoon season, during the construction
period; all the temporary and permanent cross drainage structures are free from debris as
defined in the Technical Specifications read along with the ESMP. . A specific amount shall
be determined to handle the damage issue for non–conformity of traffic safety measures
as per the decision of the PIU officials.
o The contractor has to ensure that a comprehensive Health and Safety program is in place
for the duration of construction. Implementation of the program will include, among other
aspects, ensuring that sufficient numbers and good quality Personnel Protective Equipment
(PPE), should be provide to staff and labor all time as defined in the labor codes read along
with the ESMP. . A specific amount shall be determined to handle the damage issue for
non–conformity of traffic safety measures as per the decision of the PIU officials.
o In addition, for any non-compliance causing damages or material harm to the natural
environment, public or private property or resources, the contractor will be required to
either remediate / rectify any such damages in a timeframe specified by and agreed with
the engineer, or pay PIU for the cost (as assessed by NPIU) of contracting a third party to
carry out the remediation work.
o Since many contractors do not have clear understanding the need of environmental
management, some quote very low price for implementation of ESMP and eventually
cannot implement ESMP as per specific requirement of ESMP and project design. To avoid
this problem, fixed budget may be assigned for ESMP implementation. The contractors may
need orientation on the requirement of the ESMP in the pre-bidding meeting.

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6.4.4.5 Environmental and Social Codes of Practice (ESCoPs)

The environmental and social codes of practice (ESCoPs) are generic, non-site-specific guidelines. The
ESCoPs consist of environmental and social management guidelines and practices to be followed by the
contractors/ implementation organizations for sustainable management of all environmental and social
issues. The contractor will be required to follow them and also use them to prepare site-specific
management plans. Details of the ESCoPs listed below are in Annex D.
▪ ESCoP 1: Waste Management
▪ ESCoP 2: Fuels and Hazardous Substances Management
▪ ESCoP 3: Water Resources Management
▪ ESCoP 4: Drainage Management
▪ ESCoP 5: Soil Quality Management
▪ ESCoP 6: Top Soil Management
▪ ESCoP 7: Topography and Landscaping
▪ ESCoP 8: Air Quality Management
▪ ESCoP 9: Noise and Vibration Management
▪ ESCoP 10: Protection of Flora
▪ ESCoP 11: Protection of Fauna
▪ ESCoP 12: Protection of Fisheries
▪ ESCoP 13: Road Transport and Road Traffic Management
▪ ESCoP 14: Construction Camp Management
▪ ESCoP 15: Cultural and Religious Issues
▪ ESCoP 16: Workers Health and Safety
▪ ESCoP 17: Security Management

6.4.5 Required Site Specific Management Plans (ESS 1-10)

The contractors of the sub-projects will prepare site Specific Management Plans. Selection of the
management plans required by the sub-projects will be determined by the ESS requirements, applicable
ESCoPs and recommendation of ESMP. WB will review and clear plans for substantial risk sub-projects.
Those lower than substantial risk will be reviewed and cleared by PIU/PMC.
i. Contractor’s Environmental and Social Management Plan (CESMP): will be prepared and
implemented by the contractor. This document will be reviewed by the IAs as well as by the
WB. The plan shall be submitted prior to the start of the construction activities. The contractor
will be responsible to implement this plan appropriately.
ii. Sand or soil borrowing plan (if required from river bed, agriculture land and wetlands): will be
prepared and implemented by the contractors on the basis of the ESCoPs. The Plan will describe
among others the methodology to be adopted, restrictions to be followed, prior survey to be
conducted, and documentation to be maintained for the sand extraction. The Plan will be
submitted for review and approval before the sand extraction activity is initiated.
iii. Pollution Prevention Plan: will be prepared and implemented by the contractors on the basis
of the ESCoPs and WBG EHS Guidelines (1997) that will be part of the bidding documents. The
Plan will be submitted for review and approval before contractor mobilization.
iv. Waste Disposal and Effluent Management Plan: will be prepared and implemented by the
Contractor on the basis of the ESMP, ESCoP, and WBG EHS Guidelines (1997), which will be part
of the bidding documents. The Plan will be submitted for review and approval before contractor
mobilization.
v. Drinking Water Supply and Sanitation Plan: Separate water supply and sanitation provisions
will be needed for the temporary facilities including offices, labor camps and workshops in order
not to cause shortages and/or contamination of existing drinking water sources. A Plan will be
prepared by the contractors on basis of the ESMP and ESCoPs, which are part of the bidding
documents. The Plan will be submitted for review and approval before contractor mobilization.

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vi. Occupational Health and Safety (OHS) Plan: will be prepared and implemented by each
contractor on the basis of the WBG EHS Guidelines (1997), ESCoPs, mitigation plan, and other
relevant standards. The Plan will be submitted for review and approval before contractor
mobilization. For labor-intensive maintenance works to be carried out by poor people in rural
areas, OHS measures outlined in the Labor Management Procedures will be implemented by
NPIU.
vii. Traffic Management Plan: will be prepared by each contractor after discussion with NPIU and
authorities responsible for roads and traffic. The Plan will be submitted for review and approval
before contractor mobilization. The Plan will identify the routes to be used by the contractors,
procedures for the local community's safety, particularly pedestrians, and a monitoring
mechanism to avoid traffic congestion.
viii. Construction Camp Management Plan: will be prepared by each contractor. The Plan will
include the camp layout, details of various facilities including supplies, storage, and disposal.
The Plan will be submitted for review and approval before camp establishment.
ix. Fuel and Hazardous Substances Management Plan: will be prepared by each contractor in
accordance with the standard operating procedures, relevant guidelines, and where applicable,
material safety data sheets (MSDS). The Plan will include the procedures for handling the oils
and chemical spills. The Plan will be submitted for review and approval before contractor
mobilization.
x. Emergency Preparedness Plan: will be prepared by each contractor after assessing potential
risks and hazards that could be encountered during construction. The Plan will be submitted for
review and approval before contractor mobilization.
xi. Plantation Plan: A plantation plan will be prepared for the trees to be planted on the project
construction site. The Plan will include the species to be planted, the plantation methodology,
and plantation layout.
xii. Environmental Management of Resettlement Sites: will be prepared by the Contractor in
compliance with the stand-alone ESMP prepared for Resettlement Sites and presented in the
main ESIA.
xiii. Health, Safety and Environment Plan: will be prepared by NPIU to address solid waste and
emergencies associated with workers and community health and safety and to properly manage
waste effluents generated from the maintenance works. The Plan will be submitted to the
World Bank for review and approval prior to completion of construction.
xiv. Resettlement Action Plan (RAP): A separate RPF will be prepared to guide the preparation
of RAPs for all the sub-projects.
xv. Communication Strategy: A formal communication strategy will be prepared for the project
laying out various communication needs and outreach tools and explaining the responsibility of
PIU to convey the project impacts and its implications for various stakeholders. A key aspect of
this strategy shall be communicating any project-related impacts.
xvi. Biodiversity conservation and monitoring: During ESIA study in the project impact area,
Detailed ecological studies will be carried out to broaden the existing baseline data. The ESIA of
each component should identify potential sites of sensitive ecological area, mangrove area, fish
conservation area, locations of dolphin conservation, habitat for coastal birds, sea turtle, etc. in
the project area. The proposed study will confirm these locations, identify additional locations
and islands/chars of conservation significance and prepare detailed conservation plans and
implement these plans. A consulting firm will be hired to carry out the studies and to conduct
biodiversity monitoring during the construction and post-construction periods.
xvii. Pest Management Plan: it will be prepared during ESIA, this will be used to provide training of
farmers and project staff based in research vessels on integrated pest control. A community
NGO is suggested to engage to implement the IPM plan.

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6.4.6 Consultation and Participation Plan (ESS10)

A separate SEP for all IAs has been prepared which discussed this ESS10 requirements elaborately. The
overall framework for consultation is provided in the Chapter 7.

6.4.7 Labor Management Procedures (ESS2)

A standalone LMP for all IAs has been prepared to fulfill the requirement of ESS2 and will be disclosed
by PIU/IAs.
Besides the LMP, separate OHS management plan will be developed and implemented at the project
activities. To inspect the OHS plan at construction sites and its evaluation will be carried out with
different checklist as given in Annex G.

6.4.8 COVID-19 Health and Safety of the Workforce

The project will require construction workers that may raise issues with manual labor employment,
particularly regarding potential transmission risks for COVID-19 both within the worksite and for nearby
communities. These risks are not only from workers that are mobilized locally but also workers moving
from other regions/countries. The national COVID-19 response protocol along with the World Bank
relevant guidelines will be adopted by the contractors and any consulting firms of such workers.

6.4.9 Implementation of the Solid and Hazardous Waste Management and

Disposal
Solid and hazardous wastes (including water, reagents, infected materials, etc.) from facilities that are
supported through the project can have a substantial impact on the environment and human health.
Wastes that may be generated from lab facilities could include liquid contaminated waste, chemicals,
and other hazardous materials, and other waste from labs and quarantine and isolation centers
including sharp objects, used in diagnosis and treatment. Each recipient sub-project facility will follow
the requirements of this ESMF, national legislation, WHO COVID-19 guidance documents, WBG EHS
guideline for general facility design and waste management and any other relevant best international
practices. The PMU will ensure the following-
a. Hazardous waste is handled according to the regulatory requirements (i.e the Hazardous Waste
Management Rules, 2011 etc.) and it covers all aspects of hazardous waste collection, storage,
transportation and disposal;
b. Each facility is operated in accordance with the ICWMP prepared based on the template
attached in the ESMF and WHO COVID-19 Guidelines;
c. Waste segregation, packaging, collection, storage disposal, and transport is conducted in
compliance with the ICWMP and WHO COVID-19 Guidelines;
d. Onsite waste management and disposal will be reviewed regularly and training on protocols
contained in the ICWMP conducted on a quarterly basis;
e. The PMU will audit any off-site waste disposal (including transportation of hazardous wastes)
required on a quarterly basis and institute any remedial measures required to ensure
compliance; and
f. Waste generation, minimization, reuse and recycling are practiced where practical in the
COVID-19 context;
g. All relevant staff regularly undergoes refresher training on solid and hazardous waste
management. Additionally, information posters will be provided for all location where such
waste might be generated (laboratories, stores, warehouse, dormitories, commercial/
residential unit etc.).
Measures shall be put into place to ensure the separate collection of the different categories of waste.
In particular, staff will be trained and informed on the mechanisms for safe collection of hazardous
wastes. All wastes shall be managed by authorized waste operators/handlers and recovered or disposed

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of in an environmentally friendly manner. All wastes shall be disposed at appropriate landfill sites,
burrow pits or incinerators (if available). Pending collection of hazardous wastes, they shall be
temporarily stored in appropriate, safe and secure areas marked with appropriate warning labels. Staff
shall be trained for the safe use of such equipment.

6.4.10 Gender, women, children, person with disability/excluded

groups’ needs
Advancement of gender equality, transforming traditional gender roles and progressive changes in
power relationships between women and men are essential to the success of any development
initiative. Therefore, BBIN-RTTF phase 1 will ensure that gender inclusiveness as well as chance to
benefit as equally as possible from the project interventions. Women’s and excluded group’s
involvement in decision-making should be a genuine and meaningful participation. Because, their
development has always been lagging behind due to socio-political discrimination, geographically in
disadvantaged position and paternalistic attitude of the state and powerful social actors. Therefore, the
sub-projects will give a special attention to creating an enabling environment for women, adolescent
girls, children, elderly physically challenged people and excluded groups for their empowerment.
The project will develop separate Gender Action Plan (GAP) with inclusiveness and sensitivity as core
guiding principle for all of the sub-components of the project activities. It will recognize existing gender
norms, roles and power relations, therefore address gender inequities.
The project seeks to develop the following approaches towards mainstreaming gender and equality
with the sub-projects at BLPA/MoS, MoF, MoC and MoRTB and community level for more strategic
inclusiveness;
a. Approaches at BLPA/MoS, MoF/MoC/MoRTB level:
⮚ Gender Policy.
⮚ Staffing ratio following existing government policy.
⮚ Equal logistical and capacity building support.
⮚ Internalization of learnings and experiences into policies and practices
b. Approaches at Project level:
⮚ Fixed the gender indicator.
⮚ Gender audit provision.
⮚ Gender training.
⮚ Disaggregated data management system.
⮚ Integrated monitoring system.
⮚ Transparent decision making provision in GRM.
c. Approaches at community level:
⮚ Equal decision making power.
⮚ Equal access to, control over resources & benefits of trade and transport services
⮚ Priority to most vulnerable on resource allocation of services
⮚ Provision of transparency and accountability.
⮚ Mainstreaming women to access and control of trade and transport service benefits.
The project with its inclusive approach will target to reduce gender gaps. More productive and better
performing institutions will ensure participation of women over time, which will eventually lead more
women to actively take part in trading that are highly male dominated at this point. Reservations for
women in every possible area of infrastructure will ensure their safety, hence enabling a women friendly
environment.

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6.4.11 Occupational Health and Safety (OHS)

OHS plan will be prepared and implemented by each contractor on the basis of the WBG EHS Guidelines,
ESCoPs, mitigation plan, and other relevant standards. The Plan will be submitted for review and
approval before contractor mobilization. For labor-intensive maintenance works to be carried out by
poor people in rural areas, OHS measures outlined in the Labor Management Procedures will be
implemented by PIU.

6.4.12 Guideline for preparation of Environmental and Social

Monitoring Plan
The monitoring plan is the key element of ESMP to be prepared on the basis of impact assessment
described in earlier section. The Plan describes each program activity's potentially negative impacts,
lists mitigation and control measures to address the negative impacts, and assigns responsibilities for
implementation and monitoring of these measures. The Plans for the all the subproject will be prepared
and included in the ESIA. Table 6.6 presents the sample format of these plans. An overview of
monitoring requirement of the key environmental and social impacts described in Chapter 5 is given in
Table 6.6.

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Table 6.1: Format of Monitoring Plan-During Project Implementation Period (Sample)

Environmental Responsibility Key Performance
Actions Timing Cost Allocation
Impact/Issue Execution Monitoring Indicator
1. Activity: Design / pre-construction considerations of infrastructures
1.1 Changes in −The RAP will be implemented for Contractor PIU, PMC ● Documentary evidence of Before Included in
land use, loss of permanent land acquisition and RAP implementation construction Overall program
properties, loss of assets/ livelihood and ● Establishment of resettlement Cost
cultivated land other similar impacts sites
and grazing land, ● Payment of compensation
relocation of amounts
settlements and ● People resettling in new
amenities villages
● Income levels of displaced
households
● Number of public grievances
re resettlement and
compensation
-Contractors will lease the land Contractor PIU, PMC ● Documentary evidence of Before Included in
for construction facilities on land leasing for temporary contractor contractors’ costs
temporary basis. Proper facilities mobilization
documentation will be carried ● PMC approval for the selected
out for this leasing. Site selection site(s)
will be carried out in consultation ● Absence of grievances
with the community and local regarding temporary facilities
officials; approval from DSM will
also be required for the selected
sites.
1.2 Borrowing - A material (particularly river Contractor PIU, PMC ● Approved plan Before Included in
construction sand and soil from agricultural ● Plan itself will outline construction Contractors’
material land/wetlands, if required) appropriate KPIs for its costs
borrowing plan will be prepared implementation.

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Table 6.2: Overview of Impacts, Mitigation and Monitoring Plan

Time Cost Responsibility Key Monitoring Monitoring
Impacts/Issues Mitigation Measures
Frame (USD x 106) Implementation Supervision Indicators Frequency
ENVIRONMENTAL IMPACTS DUE TO PROJECT SITING
Land cover and land use Relevant ESCoPs of site 2022-2026 In budget of Contractor PIU, PMC -to be developed Six-monthly
changes selection. ESMP under IPM
Integrated Pest Management
Plan; Linkages with ongoing
pest management programs
Loss of natural Compensatory tree plantation 2022-2026 In budget of Contractor PIU, PMC -trees cut and trees Monthly
vegetation and trees along reconstructed ESMP planted
embankment
Loss of aquatic habitat Organic shrimp 2022-2026 In budget of Contractor PIU, PMC -abundance of fishes Quarterly
firming/aquaculture ESMP and species diversity in
expansion MPA/sanctuaries
Fish sanctuaries/MPA in BoB
Drainage congestion Installation of regulators and 2022-2026 Project Contractor PIU, PMC -User committees are Quarterly
and water logging culverts design formed and trained; (Monthly
area water logged during flood
season)
ENVIRONMENT IMPACTS DURING IMPLEMENTATON PERIOD
Impacts of burrowing of Compliance with relevant 2022-2026 In budget of Contractor PIU, PMC Sites approved, At the
material from river beds, ESCoPs of sand extraction, Contractor ongoing visual beginning of
agriculture land and agricultural top soil inspection of sand works and
wetlands (if required) management and wetland extraction through sand
digging extraction
Air pollution Pollution prevention and 2022-2026 In budget of Contractor PIU, PMC Plan approved and Quarterly
implementation of ESCoPs Contractor implemented;
community
complaints
Noise Noise control measures and 2022-2026 In budget of Contractor PIU, PMC Plan approved and Quarterly
relevant ESCoPs Contractor implemented;
community
complaints
Water pollution Pollution prevention and 2022-2026 In budget of Contractor PIU, PMC Plan approved and Quarterly
control plan Contractor implemented
Soil contamination Pollution prevention and 2022-2026 In Contractor PIU, PMC Plan approved and Quarterly
control plan Contractors implemented
budget

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Time Cost Responsibility Key Monitoring Monitoring

Impacts/Issues Mitigation Measures
Frame (USD x 106) Implementation Supervision Indicators Frequency
Solid wastes and Waste management and 2022-2026 In budget of Contractor PIU, PMC Plan approved and Quarterly
hazardous wastes pollution control plan Contractor implemented
Impacts on aquatic Treatment of waste effluents 2022-2026 In budget of Contractor PIU, PMC Sites approved and Before and
habitat Contractor ongoing monitoring of during
plan implementation construction
Impacts on wildlife No construction related 2022-2026 In budget of Contractor PIU, PMC Biodiversity monitoring Semi
habitats activities on sensitive wildlife ESMP studies annually
habitat, use of low wattage
lights at construction sites
Site clearance and Site restoration and 2022-2026 In budget of Contractor PIU, PMC Sites established and After
restoration landscaping Contractor cleared construction
Occupational health Implement health and safety, 2022-2026 In budget of Contractor PIU, PMC Plan prepared and Quarterly
and safety and emergency response Contractor implemented
plan
ENVIRONMENTAL IMPACTS DURING POST PROJECT PERIOD
Generation of solid waste Implementation of Health 2022-2026 IA’s annual IA IA Plan prepared and Semi
Safety Environment Plan budget implemented annually
Air and noise pollution Air and noise quality and 2022-2026 IA’s annual IA IA to be developed Quarterly
appropriate measures budget
Water pollution Organic aquaculture, water 2022-2026 IA’s annual IA IA to be developed Quarterly
treatment, etc. budget

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6.4.13 Monitoring Program

As one of the key elements of the ESMP, a three-tier monitoring program is proposed comprising
compliance monitoring, effects monitoring, and external monitoring. The main purpose of this
monitoring program is to ensure that the various tasks detailed in the ESMP particularly the mitigation
measures, are implemented effectively and evaluate program impacts on the key environment
parameters. Various types of ESMP monitoring are discussed below.

6.4.13.1 Compliance Monitoring

The purpose of the compliance monitoring is to ensure that the contractor implements the mitigation
measures given in the ESMP are effectively and timely implemented. This monitoring will generally be
carried out by the PMC with the help of checklists to be prepared on the basis of the Mitigation Plan.

6.4.13.2 Effects Monitoring During Project Implementation

Effects monitoring is a very important aspect of environmental and social risk management. The
monitoring plan proposed for the project is presented in Table 6.2. After the preparation of the site-
specific ESIA, this program will be revisited and revised. The monitoring will comprise surveillance to
check whether the contractor is meeting the provisions of the contract during construction and
operation of the program including the responsible agencies for implementation and supervision.
Table 6.2: Effects Monitoring Plan
Responsible Agency
Means of
Parameter / Activity Location Frequency Implemented
Monitoring Supervised By
By
During Project Implementation
Ecological
inspection of
the site prior to
At all sand
Sand extraction/soil development;
extraction Weekly Contractor PIU
collection and extraction
points
carried out not
in long
stretches
Visual
Construction inspection that Beginning
site, camp & filling is through of earth Contractor PIU
RS several filling works
compartments
Ensure no
Soil Pollution contaminated
Construction, effluent is
RS and leaving from
Weekly Contractor PIU
material the filling area
storage sites to the nearby
agricultural
lands
Visual
Inspection of
Construction
Hydrocarbon and chemical storage
camps and Monthly Contractor PIU
storage facilities
yards

Visual
inspection to
see whether
Construction proper traffic
Traffic Safety Monthly Contractor PIU
Access Roads signs are
placed and
flag-men for
traffic

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Responsible Agency
Means of
Parameter / Activity Location Frequency Implemented
Monitoring Supervised By
By
management
are engaged
Visual
inspection to
ensure good
standard
equipment is in
Construction
use and dust Daily Contractor PIU
sites
suppression
measures (e.g.,
spraying of
Air Quality (dust, smoke) waters) are in
place.
Visual
inspection to
ensure dust
Material
suppression Monthly Contractor PIU
storage sites
work plan is
being
implemented
24 hours
continuous
monitoring with
the help of
Sensitive
appropriate
receptors
instruments and
Air quality along Quarterly Contractor PIU
analyzers
construction
(particulate
corridor
matter, carbon
dioxide, sulphur
and nitrogen
oxides)
Noise
measurement
using noise
meter; Ensure
Construction
Noise work restriction Weekly Contractor PIU
sites
between 21:00-
06:00 close to
the sensitive
locations
Sampling and
analysis of
surface water
quality (TDS, Contractor
At the
Turbidity, pH, through a
baseline
Surface Water Quality dissolved Quarterly nationally PIU
monitoring
oxygen, recognized
sites
biological and laboratory
chemical
oxygen
demand)
Depth of tube
well should be
more than 30m.
Locations of Test water for
tube-well arsenic iron Contractor
installation and During trough a
Groundwater quality (for workers manganese drilling of nationally PIU
camps and before wells recognized
RS), Other installing of laboratory
buildings casing. If the
quality is found
not suitable
further

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Responsible Agency
Means of
Parameter / Activity Location Frequency Implemented
Monitoring Supervised By
By
deepening will
be done.
Laboratory
analysis of all Contractor
Water wells to
drinking water After trough a
be used by
parameters developme nationally PIU
contractors
specified in nt of wells recognized
for drinking
national laboratory
standards
Building Visual
construction inspection to
Plantation sites, affected ensure Monthly Contractor PIU
vegetation plantations are
sites taken care of.
Construction
camps and
Visual
construction
inspection that
sites, other
Waste Management solid waste is Monthly Contractor PIU
infrastructure
disposed at
sites,
designated site
laboratory,
etc.
Ensure the
construction
Construction
workers are
camps and
provided with
construction
safe water and
Drinking water and sites, other
sanitation Weekly Contractor PIU
sanitation infrastructure
facilities in the
sites,
site by
laboratory,
checking
etc.
drinking water
quality
Survey and
comparison
with baseline
environment
Sensitive
Ensure use of Six-monthly Biodiversity
habitats in
lighting at Conservation
Flora and Fauna Project PIU
construction and Monitoring
influence
sites conforms Consultant
area
with
requirements to
limit impacts to
wildlife

Restoration of Work Sites All Work Sites After Contractor

Visual
completion PIU
Inspection
of all works
Usage of
Personal
Protective
Safety of workers Monitoring
At work sites equipment and Monthly Contractor PIU
and reporting accidents
implementatio
n of contractor
OHS plan
Number of
Grievances (environmental In the project grievances
Monthly PIU PIU
issues) area registered and
addressed
During Operation and Maintenance Period
Visual
Resettlement inspection of
Stability of protection works Monthly PIU/BBIN- RTTF1 PIU
Sites (if any) erosion
prevention

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Responsible Agency
Means of
Parameter / Activity Location Frequency Implemented
Monitoring Supervised By
By
measures and
occurrence of
erosion
Visual
inspection to
Construction
Plantation ensure Monthly Contractor PIU
sites, etc.
plantations are
taken care of.
Construction Visual
camps and inspection that
construction solid and liquid
sites, other waste effluents EMU of
Waste effluents Six-monthly PIU
infrastructure are properly PIU/BBIN- RTTF1
sites, managed
laboratory, during post
etc. project period

6.4.13.3 Third Party Monitoring

PIU will engage an independent consulting firm to conduct external and independent monitoring of the
ESIA and ESMP implementation will be conducted on quarterly basis. The main purpose of the external
monitoring will be to ensure that all the key entities including MOC, BLPA, RHD, NBR, PMC and
contractors are effectively and adequately fulfilling their designated role for ESMP implementation, and
that all the ESMP requirements are being implemented in a timely and effective manner. The ToR of the
external monitoring will be presented in the respective ESIA reports. Third party monitoring will be hired
for RHD and port authority works and other monitoring activities for other IAs, the monitoring will be
performed by inhouse consultants of those IA agencies (MoC and NBR).
6.4.13.4 Performance Indicators
For evaluating the performance of the environmental management and monitoring plan, performance
indicators are identified to for efficient and timely implementation of measures/actions proposed in
ESMP. The indicators are defined both for implementation phase and for post project period. Project
Supervision Consultant (PSC) will be responsible for compiling the information on these indicators and
report to PIU.
Separate performance indicators for each environmental issue will be specified in the mitigation plans
for the project and included in the associated ESIA. To measure the overall environmental performance
of the program, an additional list of performance indicators is given below.
▪ Number of inspections carried out by PSC per month.
▪ Number of non-compliances observed by PSC.
▪ Availability of environmental specialists in PIU.
▪ Availability of environmental specialists in PIU.
▪ Availability of environmental specialists with contractors.
▪ Timely reporting of documents (as defined in ESMP and monitoring plan).
▪ Number of trainings imparted to stakeholders/other capacity building initiatives.
▪ Timely disbursement of compensation/ timely resettlement of program affected.
▪ Timely implementation of resettlement schedule.
▪ Number of grievances received.
▪ Number of grievances resolved.
▪ Number of constructions related accidents.
6.4.13.5 ESMP Implementation Cost
Cost estimates will need to be prepared for all the mitigation and monitoring measures to be proposed
in the specific ESIA in accordance with the ESMF. The cost estimates for some of the mitigation

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

measures identified in the ESMP will be part of the civil works contract. Some of the suggested
activities from ESIA will be implemented by hiring NGO/consulting firm for some specific IAs. Land
Acquisition cost is excluded and the budget will come from client’s own resources. The following
budget is the sum of the cost that would be incurred for ES personnel of the PIUs, ES training and
capacity building, ESMP implementation, ES monitoring, Communications (materials and campaign),
OHS Materials (e.g., Mask/ Disinfectant Spray/ Handwash etc.), etc. Human resource cost for
recruitment of ES personnel to provide implementation support, monitoring and supervision and cost
for all the mitigation and monitoring measures including reimbursables (such as travels,
communication, ESIA studies, OHS materials, monitoring and reporting) will be finalized after the
completion of the sub-project ESIAs. The necessary budgetary provision for implementation of
ESMF/ESMP should be made in the DPP by the PIUs.
The Development Project Proposal (DPP)/Technical Assistance Project Proposal (TAPP) of BLPA/NBR/
MoC/RHD for the proposed program should reflect the ESMP activities with budget for successful
environmental and social management of the program. Total US$ 1.13 million is estimated for
implementation of ESMF which should be embedded in the proposed total project budget from IDA.

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7. STAKEHOLDER ENGAGEMENT, GRIEVANCE MECHANISM

AND DISCLOSURE
7.1 Stakeholder Engagement, GRM and Information Disclosure
Stakeholder consultation is a crucial element, particularly to solicit, collect and document the opinions
of project affected people and interested parties to ensure that project design reflects the stakeholders’
collective views. A detail Stakeholder Engagement Plan will be prepared by the appraisal and followed
out throughout the project life cycle and will be the main guiding document for the project. The SEP
identifies the “project affected parties”, “other interested parties” and the “vulnerable and
disadvantaged groups” specific to all 4 IAs (BLPA, NBR, MOC and RHD) of the project and includes the
relevant provisions to engage all the stakeholders from the inception to the project to all through the
project cycle, till completion and post-construction/operational phase. The SEP will be considered as
living document and will be revised as necessary if the project context requires so with clearance from
the Bank. The SEP will elaborate a project-specific GRM for all the 4 IAs. The following sections are
summarizing the ESMF requirements for stakeholder’s consultations and disclosures.

7.2 Objectives of the Consultations

The World Banks’s Environmental and Social Framework (ESF) underscores the importance of open
and transparent engagement between the borrower and project stakeholders as an important pillar
of good practice. Effective stakeholder engagement through a robust consultation and disclosure
mechanism promotes environmental and social sustainability of the project, enhances its acceptance,
makes important contributions to design, and aids in smooth implementation of the project.
Stakeholder engagement is an inclusive process and is carried out throughout the project's life cycle.
ESS10 refers to Stakeholder Engagement and Information disclosure requirements of the ESF. The
following are the objectives of ESS10:
● Establish a systematic approach to stakeholder engagement that will enable borrowers to
identify and form constructive relationships with the relevant stakeholders, including Project
Affected People (PAP).
● To assess the level of interest and support stakeholders have for the project and ensure that
through this mechanism, the views of the stakeholders are incorporated into the project
design.
● Encourage and facilitate methods of effective, meaningful consultation and engagement with
PAPs throughout the project cycle on issues that could potentially have an impact on them
● Ensure that project information related to environmental and social risks and impacts is
disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and
format.
ESS10 promotes meaningful consultation and communication with all stakeholders, and the process
of stakeholder engagement involves the design and implementation of a Stakeholder Engagement
Plan (SEP). The SEP covers the following aspects:
(i) Stakeholder identification and analysis;
(ii) planning how stakeholder engagement will take place;
(iii) disclosure of information;
(iv) consultation with stakeholders;
(v) consultation with stakeholders;
(vi) addressing and responding to grievances;
(vii) reporting to stakeholders.
The SEP for BBIN MPA program has been prepared. The coordination and monitoring mechanisms
established in the SEP are overseen by committees comprising of staff from BLPA, MoC, NBR, RHD. As
part of the process, five FGDs and three stakeholder consultation meetings were conducted on
different days and locations, and the participants included officials from port authority of Burimari,

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Patgram, Chattogram Custom House, local importers, community representatives, female laborers and
entrepreneurs, local traders and truck labor association representative. During the consultation the
people were informed about:
 A background of the program and sub-projects
 Likely E&S impacts and risks and proposed mitigation measures
 The ESF of World Bank
 Other possible impacts, risks, benefits and opportunity associated with the program.
The Consultations elicited from the participants the following:
 Grievance Redress Mechanism (GRM)
 Their views on the project especially the likely adverse E&S impacts and risks;
 Possible mitigation measures in case of adverse impacts and risks;
 Means to better delivery of compensation and assistance, and benefit from potential
opportunities (e.g., temporary / permanent employment, traffic safety measures);
 The assurance from the project authority not to marginalize people by depriving them from
their livelihood.
 Provision of infrastructure related to safety.
Through public participation, stakeholder’s viewpoints and suggestions were captured as an input to
the technical design, which were duly considered, and all the suggestions were incorporated in the
project design to the extent feasible and /or warranted.

7.3 Methodology and Tools of the Consultation

The consultation and participation process in preparing and disclosing the ESMF was limited to three
public consultation meeting and five FGDs. Stakeholders’ consultation and engagement at the individual
household level was not carried out during the preparation of the ESMF. However, this will be done at
the sub-projects level once they are identified and will be more inclusive irrespective of gender,
profession, religion and age groups. The various tools identified in the SEP will be used for consultations
including household level interviews, participatory rural appraisal, FGDs, stakeholders’ consultation
meetings, issue specific consultation meetings, open meetings, and workshops at both local and
national levels. During preparation of RPF, consultation meetings and workshops with different
stakeholders at the initial stage and a disclosure workshop to share findings of the draft ESMF at the
later stage of project preparation will be conducted. The discussion, concerns and responses are
extensively documented in SEP. A summary of consultation meetings is given below:
Table 7.1: Summary of Consultation Meetings and FGDs
Name of Participants Participants
Date Meeting & Place Total
the IA (Male) (Female)
10 December 2021 BLPA FGD at Burimari Land Port with local 13 - 13
community (Zero Point) (males only)
11 December 2021 BLPA FGD at Conference Hall, Burimari Land 10 - 10
Port with Importers and C&F Agents
11 December 2021 BLPA FGD at Tatipara, Burimari Land Port 10 - 10
with Community Elite Persons
11 December 2021 BLPA FGD at Burimari Bazar with Truck Labor 07 - 07
Association
11 December 2021 BLPA FGD at Burimari Land Port with local - 13 13
community (Zero Point) (females only)
13 December 2021 BLPA Consultation Meeting with stakeholders 39 01 40
at Burimari Land Port
9 December, 2021 NBR Online (Zoom); Consultations with the 24 04 28
participants from IAs (focal person),

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Name of Participants Participants

Date Meeting & Place Total
the IA (Male) (Female)
government officials based in Dhaka
Headquarters of relevant departments.
20 December, 2021 NBR Conference Room, Custom House, 18 04 22
Chattogram; Local level consultation
with the participants of district level
government officials of NBR,
representatives of C&F Association, and
representatives of Chattogram Women
Chamber and Commerce.

A detail discussions with photographs and participants list are presented in Annex B and C respectively.

7.4 Outcomes of consultation meetings

During preparation of the ESMF, BLPA and NBR have engaged with the stakeholders and collected their
opinion and those are incorporated with the entitlement matrix preparation. A summary of consultation
outcomes and disclosure workshop is given below. The following table summarizes the stakeholder
consultation outcomes of Chattogram Customs House:
Table 7.2: Summary of Stakeholder Consultation Meeting (NBR)

Issues Discussion
Environmental Risks and Due to the nature and size of the project, the participants were more interested to discuss on
Management the infrastructural design and environmental aspects of the project. Followings are some key
environmental factors that were identified and asked to take into consideration during
implementation of the project:

 Air and Noise pollution would be one of the vital issues, particularly during the period
when the existing building would be demolished to build new ones. There should be a
proper plan in place to minimize air and noise pollution during the implementation
period.
 One of the major environmental risks is air pollution from the vehicles. It is seen that
vehicles have to wait in a long que at the existing VICs and gas emission from the vehicles
is a concern of air pollution. Noise level is also higher around the VICs which creates
nuisance to the local environment (From SCM with RHD).
 Another concern was on the species of trees planted in road sides. Though it is known
that some exotic species like eucalyptus, acacia are not good for our environment but
the arboriculture department of RHD is planting those species along the highways; for an
example the Rajshahi-Naogaon highway (From SCM with RHD).
 Custom House, Chattogram discard huge amount of paper every day. They usually store
those papers in a warehouse and then sell those off later. During the site visit, the World
Bank team observed a huge amount of waste paper stored in the corners of the balconies
those are waiting to get disposed in the proper way. However, a paper recycling center
or/and waste treatment plant can be considered to build so that they can dispose them
immediately to maintain a clean working environment.
 Sound pollution management system in the new buildings; this needs to take into
consideration by installing sound proof windows and other ventilation systems.
 The Custom House, Chattogram has a decent number of trees inside their compound.
During the implementation of the project, need to minimize the number of trees will be
cut down.
 Custom House, Chattogram chemical laboratory is one of the crucial laboratories in the
country, where 90% of the chemicals are tested that are imported in Bangladesh. The lab
is severely understaffed (it has only 4 people and among them 3 are assistants) and the
lab technically operates only in two rooms. The ESMF should propose a “Hazardous
Material Management Plan” before implementation of the project. The HCMP should
clearly mention probations on how to transfer the chemicals from one place to another.
 Water logging during the rainy season: Custom Excise and VAT Training Academy goes
under water during the rainy season. This temporary yet hazardous problem makes lives
miserable for the people who live and work in that area.

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Issues Discussion
 Custom Excise and VAT Training Academy (CEVTA) produces significant amount of waste
every day and the representative of the CEVTA suggested a waste treatment plant in their
compound to keep the environment clean and safe on a regular basis.
 Drainage system: Proper drainage system is important to keep the area clean and safe
for all. While designing and panning for this system, need to consider sustainability
issues, like capacity and proper management in mind.
 Rooftop Management: Green rooftop management can be considered to increase the
aesthetic aspect of the building. Also, plantation, proper sitting area for small meetings,
well managed open area for different activities can be considered within the design which
can potentially benefit everyone.
 Sometimes there are accidents and even fatalities during construction. Proper measures
have to be taken to avoid these kinds of incidents.
 Temporary resettlement of the NBR employees/workers living in the compound of both
sites; proper compensation and related issues has to be considered with utmost care.
There are no squatters/informal occupants at both sites.
 People visiting Custom House, Chattogram mostly have their lunch in the compound in
an existing canteen. During the reconstruction of the compound, the canteen will not be
there and that may create some inconveniences for the people visiting Custom House.
Social Risks and An alternative of this system needs to be considered during the implementation.
Management  Mosquitoes and pesticides control measures; mostly forgotten but one of the crucial
issues since serious health issues like dengue, chikungunya, etc. are associated with this.
 Traffic congestion: During the construction period, the amount of usable land will be
reduced, hence creating traffic congestion inside the compound. An alternative plan
needs to put in place to minimize the congestion.

Infrastructural Design Everyday around 2000 people come visit Custom House, Chattogram and the number of
Related Feedback for incoming people will go up in next decades, given the growth trajectory of Bangladesh. Hence,
Custom House, the design of the building has to be foresightful and it is important that the building is designed
Chattogram in a way that would be sustainable with green engineering design, remain relevant to time,
and most importantly, can accommodate any changes in demand of time.

 The new buildings need to be built in a way that they have enough probation to use
daylight during the day time as a source of light. Enough open space and green building
need to take into consideration to minimize the use of Air Conditioner.
 The buildings need to have wide stair case to manage fire hazard; and the lift and stair
can’t be side by side.
 The building must have an emergency exit and the staircase of the exit has to be wide
enough to accommodate enough people at a time during fire or any other disaster.
 The building must have a separate prayer room and washroom for ladies. Also, a separate
rest room for child care or can be used as a rest room.
 The building must have two to three seminar halls of different capacity and an
auditorium. Also, the present stakeholders suggested considering a gym/yoga center, a
library and dining halls as of needs.
 The building must have three to four lifts and each lift should have a capacity to lift 20
people or more.
 Proper parking space is of high importance and it has to be properly managed to
accommodate all incoming vehicles.
 The compound must have proper toilet facilities outside for the visitors.
Planning and Operational  During the project implementation, there will be temporary arrangement for issues, like
Management resettlements, labor sheds, server reinstallation, and many more. It needs to make sure
that the temporary operational issues are smooth and not interrupting the daily
activities.
 Custom House, Chattogram server reinstallation is supremely important; sincere
attention is needed here during implementation
 The existing Custom House building will not be broken initially; the rest of the complex
will be rebuilt first and then the official activities will be moved to those new buildings
temporarily.
 There is a grave, that has to be preserved.
 NBR needs to apply to the forest department for clearance for cutting down the trees of
the compound.

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Issues Discussion
Suggestions (Not related  Alternative connecting road from Bangladesh to Agartala: People living in Agartala need
to ES) 36 hours to reach Kolkata, whereas they can reach to the nearest Bangladesh districts
within 3-4 hours. There is a huge untapped trade potential for both counties in that area.
An alternative smooth road connectivity can ease the process and can facilitate trading
in that area.
 Custom House and port connectivity: To mitigate traffic congestion, an underpass
connecting the Custom House and Port would be helpful.

The following table summarizes the stakeholder consultation outcomes of BLPA; the meeting was
conducted at Burimari Land Port.
Table 7.3: Summary of Stakeholder Consultation Meeting (BLPA)
Key Issues Participant/S
Sl Response
Raised Type
1 Brief on the AD, Burimari The AD of Burimari Land Port welcomed and thanked all the participants for their
project Land Port presence in the public consultation meeting. Then he gave a brief on the project.
Environmental The consultants discussed to the participants what environmental and social
and Social standards will be maintained throughout the project like, preparing separate
consultants documents on Environmental and Social Management Framework (ESMF),
Environmental and Social Impact Assessment (ESIA), Stakeholder Engagement
Plan (SEP), Labor Management Procedure (LMP), Resettlement Policy
Framework (RPF), Resettlement Action Plan (RAP), Sexual Exploitation & Abuse
and Sexual Harassment (SEA/SH), Gender Action Plan (GAP), Environmental and
Social Commitment Plan (ESCP)
Company The BGB company commander then said that his organization would try to
Commander, provide all possible assistance in implementing the project.
Border Guard
Bangladesh
(BGB)
2 How the price is AD, Burimari Social consultants firstly said that, for the development or expansion of the
determined in Land Port existing land port, according to the World Bank’s Environmental and Social
case of land Framework (ESF) the project Implementing Agency’s primary target is to avoid
acquisition? any kind of private property/ land acquisition. If it is not avoidable then the
project will go following the Resettlement Policy Framework and Resettlement
Action Plan for land acquisition where policy from both the Government of
Bangladesh and The World Bank will be followed. It was also discussed that, to
determine the price of land or any kind of loss (e.g., structures, crops, tress,
business etc.) there will be Property Valuation/Market Survey.
Mr. Sayed, He said that, if possible, there would be about 25 acres of vacant land on the
President, C&F east side of the present port. That space can be acquired and used for project
Agents Union work.
3 If someone Md. Anowar Answering the question raised by the Immigration Police consultants discussed
runs a floating Hossain (In- in the meeting that any business, whether small, medium or large, permanent
business on Charge, or temporary, would be compensated if affected by the project.
other’s land or Immigration The participant also wanted to know, if land acquisition takes place,
Government- Police, compensation will be determined for the lands on the front side of the road and
owned land Burimari land that are away from the main road. Consultants informed that by evaluating the
(Khas) and if port) market survey and government rate land price, all affected person/s should get
that business is a fair price for their land parcel.
affected, how
will that person
be paid
compensation?
4 If land From Consultants assured them again that if land acquisition is unavoidable, then the
acquisition representatives project will follow the RAP and accordingly affected persons will be
takes place that are living compensated and provided support for their resettlement.
what will the in the
community proposed land
living very close area adjacent
to the land port to the existing
do land port (near
zero point)

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Key Issues Participant/S

Sl Response
Raised Type
5 Education Mst. Rahena Stone is the most important of the various products imported through this land
system and Sultana, Head port. The stone crushing business around this port area is currently making a
children’s Teacher of huge contribution to the economy of Burimari. But due to the business of stone
security primary school, crushing, stone powder, etc., the environment has become much polluted in the
and area around 5/8 km near Burimari port. All the citizens living here are moving in
Community a dusty and sandy environment. As a result, people are suffering from shortness
representatives of breath, asthma, cold and cough. The headmistress drew the attention of the
authorities to keep in mind reducing the environmental pollution by expanding
and modernizing the port area.
The participants agreed with what she said and they suggested Participants
suggested that a particular area with boundary be set up in an uninhabited area
for the stone related businesses and that the companies regularly set up
sprinklers on their behalf and abide by those rules.
Nearly one third of the participant said that the education system in this area is
poor. In addition, it is plagued with various problems due to which number of
school dropout is also high.
More than 15 primary school is located in this area contrarily only 1 high school
and 1 college which is 6 kilometers away from this area.
The Head Teacher again said, ‘A country is bigger than the individual’.
Therefore, in the interest of development of the country, we have to take any
kind of action positively. But the project will be implemented by giving priority
to the 6 basic needs of the people - that is what they hope. Burimari is not as
green as before. All the trees in the area are now covered in dust. If the Ministry
of Environment initiates a tree planting program here, it is very good for the
area.
Excessive load-sheading has resulted in students not being able to study
properly.
6 Labor related Mst. Rahena All workers who come to the area to work on the project must ensure that they
issues Sultana, Head are provided with the Covid-19 vaccine.
Teacher of The use of gloves, helmets, boots, etc. should be ensured to avoid the risk of
primary school accidents and safety of those who will work as laborers.
President, About 3000 workers are involved in various activities of the port. They do not
Landport labor have restrooms, toilets, overnight accommodation etc. in the port area.
union
Mr. Sayed, There is no accommodation for the drivers of freight vehicles arriving in the port
President, C&F area. Most of the incoming drivers spend the night in freight cars or trucks.
Agents Union Which is very risky for them to do their job properly. So accommodation needs
to be arranged for them.
7 Communication All Participants Getting students to school is challenging as they have to sit in traffic jams for a
facilities long time almost every day.
In addition, Heavy mud in rainy days and extensive dust in normal times creates
a tremendous suffering to the school-college going children.
Furthermore, road accident happens very often there, driving of over loaded
tracks in less width road is responsible for accidents.
Accidents often happen because of narrow roads, broken roads. In addition,
dust, severe traffic congestion has made communication in this area difficult.
Communication will be much easier if a bypass road can be made from Burimari
Land port zero point aligning with the rail way line. Undoubtedly it will be a
tremendous support for local residence.
Mr. Sayed, The highway that started from Burimari Zero Point area and passed through
President, C&F Burimari Bazar towards Patgram is quite narrow considering the number of
Agents Union vehicles currently plying in the area. This road needs to be at least 6 lanes. This
will almost completely alleviate the severe traffic congestion in the area.
Company He said if the port is developed, the country will develop. First, the allocation of
Commander, BGB's security needs to be expanded. The existing highways need to be
Border Guard widened. A separate walkway has to be built for people to walk. In this project,
Bangladesh all the infrastructural development has to be done considering Burimari port,
(BGB) but infrastructural development has to be done keeping in view the common
man.
8 Health system All Participants Nearly all the participants said that the health system of this area is terrible.
of this area Community clinic, upazila health complex, even in Sadar hostipal don’t have

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Key Issues Participant/S

Sl Response
Raised Type
sufficient medical facility, and nowadays they don’t even expect to get adequate
service.
Consequently, critical patients are taken to rangpur medical where they get
proper treatment.
At least 70 people in this area have died of silicosis due to excessive air pollution,
and 100 more people are still infected.
A large number of residences of this area suffer from Asthma, silicosis, shortness
of breath and other critical diseases due to open stone crushing miles.
9 Environmental All Participants Majority of the participants blame ‘Stone traders’ for environmental pollution
awareness of as crushing rocks in the open air, the dust of the rock spreads in the air and
stone crushing pollutes the air.
company After being washed by rain water, this dust goes into rivers or reservoirs and
causes water pollution.
As there is a possibility of air pollution by the project, the authority should take
necessary steps to reduce the environmental pollution.
Wastes of this project should be kept or managed away from localities.
If the stone crushing traders water regularly, the dust will be reduced in this
area.
Regular monitoring by law enforcement agencies will reduce such irregularities.
Mr. Sayed, At present, the volume of Burimari land port-centric business has increased
President, C&F many times over. The area of Burimari land port is presently approximately 11
Agents Union acres. Even if the size of the port is increased 10 times more than it is now, it will
not be enough to run port-based businesses.
Neither the traders nor the appropriate authorities are responsible for reducing
the environmental pollution by the stone business. The stone workers are risking
their lives to earn a living. The stone business is one of the major contributors to
the region's economy. According to the government policy, all the stone
crushing businesses are supposed to operate within 3 km of the port area, but
at present the stone business establishments are spread over an area of about
8 km. Therefore, administrative monitoring is very important for sustaining the
business and keeping the environment safe.
10 Development Md. Anowar The current situation of rest, toilets, food intake for our immigrant passengers
of Land Port Hossain (In- is very inadequate compared to other countries in the international arena. Since
Immigration Charge, they have to face immigration first by crossing the border from a neighboring
related issues Immigration country, their first impression of our country will be positive once immigration
and other Police, Burimari meets international standards. So, we want a tidy, tidy, clean immigration.
facilities land port)
11 What should be All Participants There are no residence facilities for drivers and staff from India or other
kept in mind for countries, and even there are no toilet or bathing facilities. These issues must be
this project? kept in mind planning this project.
A mosque should be built within port boundary so that workers can pray in time
properly.
To reduce road accident a foot over bridge needs to be installed in the land port
area.
The labors are often victims of accidents. Contrarily, there is no insurance
facilities for them. There should be an insurance facility so that they can get
support from.

7.5 Consultations and Communication Framework

Consultations with the key stakeholders will need to be carried out throughout the program life. These
will include consultations and liaison with communities and other stakeholders during the project
implementation and also extensive consultations with the local people as well as institutional
stakeholders during the ESA studies. The framework for the future consultations is presented in Table
7.4.
Table 7.4: Future Consultation Framework

Description Objective/Purpose Responsibility Timing Frequency

Consultations with Sharing ESIA ToR PIUs and ESA team During scoping Consultation
communities and stage of ESA Meeting at all

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Description Objective/Purpose Responsibility Timing Frequency

other stakeholders Districts and
during ESA study Urban areas
Dissemination of PIUs and ESA team During ESA study Consultation
information on program (once draft analysis Meeting at all
and its key impacts and is available for Districts and
proposed mitigation discussion and Urban areas;
measures; soliciting feedback) before National
views, comments, submission to DoE for Stakeholders
concerns, and clearance Consultation.
recommendations of
stakeholders
Consultations with Information PIUs; Contractors; During Project Project Specific
communities and dissemination; public PMC Implementation Location of
other stakeholders relation; confidence interventions and
during project building; awareness impacted areas.
implementation about risks and
impacts; minimizing
conflicts and frictions.
Consultations with Liaison with IAs Post Project Period As and when
communities during communities and necessary
project operation program beneficiaries

7.5.1 Community Engagement and Stakeholders Participation (ESS10)

A detailed standalone Stakeholders Engagement Plan (SEP) will be prepared and disclose following the
ESS 10 requirements.

7.5.2 Gender Analysis Procedures and Guidelines (ESS 1, 2, 4, 5, 7)

The project would address gender issues through approaches that are participatory and responsive to
the needs of the poor, particularly when it involves management of public works sites. However, a
separate standalone Gender Action Plan (GAP) will be prepared and disclosed to address the ESS
requirements.

7.6 Grievance Redress Mechanism

The project will establish a grievance redress mechanism (GRM) for addressing grievances and
complaints received from the project affected persons due to environmental issues. The GRM will be
two tiers; site level and PMU level. The GRMs will also be equipped to receive labor and SEA/SH related
GRM. The GRM is a valuable tool which will allows affected people to voice concerns regarding
environmental and social impacts for the project activities. The proposed project will ensure that
grievance redress procedures are in place and that all project actors and beneficiaries are informed of
the processes involved in filing a complaint. The project would monitor those procedures to ensure that
grievances are handled properly. The project office will establish a procedure to answer sub-component
related queries and address complaints, disputes, and grievances about any aspect of the sub-
component, including disagreements regarding the assessment and mitigation of environmental and
social impacts. Details of the institutional arrangements and procedures are discussed in following
sections.

7.6.1 Overview and Scope

The project will establish and will follow a GRM for answering queries, receiving suggestions and
addressing complaints and grievances likely to raise in the project cycle including identification,
planning, design and implementation. The GRM spans the entire implementation period and will cater
to both the beneficiary communities and the directly and indirectly affected population including the
staff, beneficiaries and other stakeholders. Though the GRM proposed here a mechanism of redress has
been designed to address environmental and social problems identified during implementation, it will

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also cater to manage any disconnects that emerge from the site level and that has significant
implications for effective implementation of the project interventions.

7.6.2 Objectives of Grievance Redress Mechanism

The fundamental objective of GRM will be to resolve any project related grievances locally in
consultation with the aggrieved party to facilitate smooth implementation of the social and
environmental action plans. Another important objective is to democratize the development process at
the local level and to establish accountability to the affected people. The procedures will however not
a person’s right to go to the courts of law pre-empt.
The GRM will be consistent with the requirements of the World Bank policies to ensure mitigation of
community concerns, risk management, and maximization of environmental and social benefits. The
overall objective of the GRM is therefore to provide a robust system of procedures and processes that
provides for transparent and rapid resolution of concerns and complaints identified at the local level.
The GRM will be accessible to diverse members of the community, including women, senior citizens and
other vulnerable groups. Culturally-appropriate communication mechanisms will be used at all project
sites both to spread awareness regarding the GRM process as well as complaints management. Where
project intervention areas cover beneficiaries from the small ethnic communities, project GRM will
integrate traditional grievance management system available with the small ethnic communities and
the Grievance Redress Committee (GRC) will include a representative from these communities.
In any working environment, both employers and employees need to be fully conversant with all aspects
of disciplinary processes, the grievance handling procedures and the legal requirements and rights
involved. In implementing an effective dispute management system consideration must be given to the
disputes resulting from the following:
1. Disciplinary action
2. Individual grievances
3. Collective grievances and negotiation of collective grievances
4. Gender-based violence, sexual exploitation and workplace sexual harassment

7.6.3 Grievance Redress Mechanism

Information about the GRM will be publicized as part of the initial disclosure consultations in the
participating subproject areas. Brochures will be distributed during consultations and public meetings,
and posters will be displayed in public places such as in government offices, project offices, village notice
boards, community centres, etc. Information about the GRM will also be posted online on the respective
IA’s website (MOC: https://mincom.gov.bd/; RHD: https://rhd.portal.gov.bd/; BLPA:
http://www.bsbk.gov.bd/; NBR: https://nbr.gov.bd/).
The overall process for the GRM will include six steps as described below. This GRM process structure
is the combined output of all the IAs.
▪ Step 1: Uptake. Project stakeholders will be able to provide feedback and report complaints
through several channels: in person at offices (village/mahalla, Union, project, and Upazila
offices) and at project sites, and by mail, telephone, and email.
▪ Step 2: Sorting and processing. Complaints and feedback will be compiled by the Assistant
Manager/Social Development Officer and recorded in a register. Submissions related to the
resettlement and compensation program will be referred to the planning department for
processing and resolution.
▪ Step 3: Acknowledgement and follow-up. Within seven (7) days of the date a complaint is
submitted, the responsible person will communicate with the complainant and provide
information on the likely course of action and the anticipated timeframe for resolution of the
complaint.

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▪ Step 4: Verification, investigation and action. This step involves gathering information about
the grievance to determine the facts surrounding the issue and verifying the complaint’s
validity, and resolve the complaints following the Figure 7.1. It is expected that many or most
grievances would be resolved at this stage. All activities taken during this and the other steps
will be fully documented, and any resolution logged in the register.
▪ Step 5: Monitoring and evaluation. Monitoring refers to the process of tracking grievances and
assessing the progress that has been toward resolution. This will be accomplished by
maintaining the grievance register and records of all steps taken to resolve grievances or
otherwise respond to feedback and questions. Typical grievance resolution process is shown on
Figure7.1.
▪ Step 6: Providing Feedback. This step involves informing those to submit complaints, feedback,
and questions about how issues were resolved, or providing answers to questions. On a monthly
basis, the Planning Department will report to the Executive Chairman on grievances resolved
since the previous report and on grievances that remain unresolved, with an explanation as to
steps to be taken to resolve grievances that have not been resolved within 30 days.
Any GBV related complaints will be handled in a survivor-centric manner in line with the World Bank
guidelines provided in the WB good practice note on GBV. GBV-related complaints will be dealt with
strict confidentiality, based on the wishes of the GBV-survivor. Any GBV-survivor will be referred to an
NGO assigned for the project by the Borrower to manage and respond to GBV cases. This NGO will
support GBV survivors in accessing service providers and guiding them through options of lodging a
complaint. Process of grievance resolution is presented in Figure 7.1.

Figure 7.1: Grievance Resolution Process

7.6.3.1 GRM for Dealing with Labour Issues
The GRM with its present scope addresses the grievances/ complaints lodged by the project affected
persons and other local stakeholders. But according to the lessons learned in various project contexts,
there is also an urgent need to establish a GRM to deal exclusively with those that involve workers
employed by the Contractors for site development, construction and other activities. Such grievances

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may involve wage rates and unpaid overtime works; irregular and partial payments; lack/ inadequacy
of living accommodations; lack of clean drinking water and sanitation facilities; lack of medical care in
emergencies.
The GRCs dealing with labour grievances/complaints will have members who are directly and indirectly
associated with the construction and other works under the individual Contract packages of the project.
Each GRC will have 5 members-
▪ Project Implementing Agency (here MOC, BLPA, RHD, NBR) official who is in charge of all
construction and other activities at individual work sites, will act as convener;
▪ Resident engineer of the Construction Supervision Consultant;
▪ A male worker representing the workers;
▪ A female worker representing the workers;
▪ A PIU official, designated by the Project Director, who is not associated with the construction
activities in the field, but a member of the PIU.
7.6.3.2 GRM for Dealing SEA/SH Related Issues
SEA/SH allegations can be reported to the respective personnel using the available project-level GRM
channels. The PIU safeguards specialist logs the SEA/SH allegations, acknowledges their receipt, and
takes the following mandatory actions-
1. ACTION 1: Complaint Intake and Refer
If the survivor agrees, the Gender Specialist completes the complaints form, leaving out any information
that could be used to identify the survivor-
● The substance of the allegation (what the complainant says without being questioned directly)
● If the alleged offender was/is affiliated with the project to the best of the survivor's knowledge
(yes/no)
● If the survivor was referred to services, the survivor's age and/or sex (if provided).
If the survivor does not want to provide her consent in writing, she can give her consent verbally. The
Gender Specialist connects the survivor to an appropriate Gender Based Violence (GBV) specialist if
requested or preferred by the survivor. Even if the survivor's consent is given verbally, it must be
documented. If a survivor requests more services, the GBV specialist will be able to refer them to other
care providers. The Gender Specialist will keep the survivor updated on the perpetrator's behavior. The
Gender Specialist can close the case if the survivor has been referred to the appropriate GBV specialist,
has received adequate assistance, and no longer requires support; and if appropriate actions have been
taken against the perpetrator or if the survivor does not wish to file an official grievance with the
employer.
2. ACTION 2: Incident Reporting
The Gender Specialist must immediately report the anonymous SEA/SH incident to the Project Manager,
who will then alert the Team Leader (TL). The Gender Specialist should save all complaint forms and
other specific information in a secure area. Neither the PIU safeguards specialist nor the Project
Manager should ask the survivor for additional information.
Although survivors' consent is not required for GBV incident reporting, the Gender Specialist must
provide ongoing feedback to the survivor at many points in time: (1) when the grievance is received; (2)
when the matter is referred to the PIU, IA, and WB; (3) when the verification process begins or when it
is determined that there is insufficient evidence to proceed; and (4) when the case is closed. The Gender
Specialist must immediately report the anonymous SEA/SH incident to the Project Manager, who will
then alert the Team Leader (TL). The Gender Specialist should save all complaint forms and other
specific information in a secure area. While the SEA/SH is still open, the Gender Specialist and/or Project
Manager should keep the TL up to date on the steps made to resolve the situation.
3. ACTION 3: Grievance Verification and Investigation

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To identify if a SEA/SH incident was related to the project, it should be verified. A SEA/SH verification
committee should be formed by the Gender Specialist, one member of each IA, one member of a local
authority, and a contractor representative (if relevant). The Gender Specialist shall report the incident
to the SEA/SH Committee within 24 hours of its occurrence. The SEA/SH verification committee will look
into the SEA/SH allegation to see if the grievance is likely to be related to the project.
If the SEA/SH claim is proven after the committee review and it is established that it is linked to the
project, the verification committee analyzes possible steps to be proposed to the appropriate party—
the perpetrator's employer, which might be the PIU or a contractor. Contractors will be asked to take
appropriate action by the PIU. The committee informs the perpetrator's employers of the occurrence
so that the appropriate remedy/disciplinary action can be taken in accordance with local labor laws and
employment contracts.
When a survivor of a SEA/SH incident refuses to cooperate with an investigation, the appropriate steps
should be taken to ensure that the survivor is referred to/aware of available services, and that the
project mitigation measures are reviewed to see if they are still adequate and appropriate, or if they
need to be strengthened.
The PIU Safeguards Specialist should give links to the necessary organizations if the survivor is interested
in seeking redress and desires to file an official complaint with the employer. The police and the courts,
not the SEA/SH verification committee, are responsible for ensuring proper legal procedure like other
types of issues, the Gender Specialist does not conduct investigations, make any announcements, or
judge the veracity of an allegation.

7.6.4 World Bank Grievance Redress Service (GRS)

Communities and individuals who believe that they are adversely affected by Sub-project interventions
may submit complaints to existing project-level GRM or the WB Grievance Redress Service (GRS).
Project affected communities and individuals may also submit their complaint to the World Bank’s
independent Inspection Panel, which determines whether harm occurred, or could occur, because of
non-compliance with WB safeguards policies and procedures. Details of the procedures to submit
complaints to the WB’s corporate GRS, is available in the GRS website:
http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service .
For information on how to submit complaints to the WB Inspection Panel, please visit
www.inspectionpanel.org. Any disclosure instrument on GRM will provide addresses of the GRS and the
Inspection Panel.

7.7 Information Disclosure

The mechanism of information dissemination should be simple and be accessible to all. Two of the
important means that have been followed until now include briefing material and organization of
community consultation sessions. The briefing material (all to be prepared in local language) can be in
the form of (a) brochures (including project information, details of entitlements including compensation
and assistance to be given to the PAPs; grievance mechanism) that can be kept in the offices of local
government (union parishad office) and project office; (b) posters to be displayed at prominent
locations and (c) leaflets that can be distributed in the project areas. Consultation meetings should also
be organized at regular intervals by the project to acquaint the communities, target group beneficiaries
and affected persons of the following:
▪ Timeline and progress of the project by components;
▪ Information on beneficiary participation;
▪ Information of involuntary displacement, compensation and entitlements;
▪ Information of participation of small ethnic communities;
▪ Time line for acquisition of land using voluntary donation, direct purchase and any
other voluntary approach.

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Also, opinion and consensus of the community needs to be sought for livelihood transformation,
relocation of any community assets and involuntary resettlement management. Information disclosure
procedures are mandated to provide citizen centric information as well as all documentation necessary
for addressing any queries. Disclosure of information will enhance governance and accountability
specifically with respect to strengthening of monitoring indicators to help the World Bank monitor
compliance with the agreements and assess impact on outcomes.
Table 7.5: Disclosure Requirements

Documents to be
Topic Frequency Where
Disclosed
Environmental Environmental and Social Once in the entire project World Bank’s website;
and Social Impact Management cycle. But to remain on the On the website of IA’s (NBR, BLPA, RHD
Assessment; Framework (ESMF), website and other disclosure and MOC);
Resettlement, Environmental and Social locations throughout the
ESMF will be prepared by borrower and
Rehabilitation Impact Assessment project period.
and Land (ESIA); Environmental disclosed in the website of the IAs and
requirement and Social Management WB in both English and Bangla language.
Plan; Resettlement The site-specific ESIA/ESMP will be
Action Plan (RAP). prepared prior to the project
intervention and disclosed in both
Bangla and English languages in the
websites of IA’s as well as WB.
The client would make the ESA Report,
ESMP, RAP available at a place
accessible to displaced persons and local
NGOs, in a form, manner, and language
that are understandable to the
stakeholders and PAPs in the following
offices:
UP Office
Municipality Office
City Corporation/Councilor Office
Public Library if any
Project Office
Resettlement Policy Once in the entire project Distributed among Project Affected
Framework translated in cycle. Persons (PAP)
local language
Information regarding Once at the start of the Through one-to-one contact with PAPs.
impacts and their project and as and when Community consultation
entitlements in local demanded by the PAP. List of PAPs with impacts and
language entitlements to be pasted in the project
office and website of IA’s (NBR, BLPA,
RHD and MOC),
R&R monthly progress 10th day of every month Website of IA’s (NBR, BLPA, RHD and
report. MOC).
Hard copy in the project office
RAP Impact Assessment At midterm and end of the IA’s (NBR, BLPA, RHD and MOC) website
Report RAP implementation in local language.
Small ethnic Small Ethnic Community Identification, design and IA’s (NBR, BLPA, RHD and MOC)
communities (if Development implementation, monitoring websites
any) Framework and Plans and evaluation Hard copies in local language in the
following offices:
UP Office
Municipality Office
City Corporation/Councilor Office
Public Library if any
Project Office

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Documents to be
Topic Frequency Where
Disclosed
SECs to be informed on one-to-one
contact
Public Minutes of Formal Public Within two weeks of meeting On the web sites of IA’s (NBR, BLPA, RHD
Consultation Consultation Meetings and MOC)
Hard copies in local language in the
following offices:
UP Office
Municipality Office
City Corporation/Councilor Office
Project Office
Grievance Proceedings of grievance Continuous process On the web sites of IA’s (NBR, BLPA, RHD
redressed process process/ monitoring throughout the project cycle. and MOC)
reports Hard copies in local language in the
following offices:
UP Office
Municipality Office
City Corporation/Councilor Office
Project Office
Beneficiaries and affected persons to be
informed on one-to-one contact
Beneficiary Approach and Continuous process On the web sites of IA’s (NBR, BLPA, RHD
identification and proceedings/long and throughout the project cycle. and MOC)
engagement short list of beneficiaries Hard copies in local language in the
following offices:
UP Office
Municipality Office
City Corporation/Councilor Office
Project Office
Potential target group beneficiaries to
be informed on one-to-one contact

7.8 Access to Information

The draft ESMF of the project will be disclosed to the local and national level stakeholders through
different methods as described below.
Workshop: A national workshop will be held at Dhaka to present the detailed project including
safeguard aspects of the project to the key stakeholders. In addition, stakeholders’ meetings will be
held at all selected administrative areas to disclose the ToR and results of the ESIA. Representative of
implementing authority, the study team, government officials from different departments, NGOs, local
communities of different occupation, journalists, and local elite/civil society may attend the workshops.
The participants will share their observations, views, and remarks with the study team in the workshops.
Appropriate suggestions and recommendations on different issues from the stakeholders of the
meeting would be incorporated in the program specific ESIA. The workshops will also help to resolve
conflicting issues among stakeholders. Besides, FGDs and personal interviews will be carried out at the
all selected administrative areas of the project area to generate communities’ views and concerns. IAs
could develop respective Communication Plans based on the nature of the sub-projects. For example:
BLPA and RHD would require comprehensive Communication Plans. They both need to reach a larger
community
Publication in electronic and print media: The information on program interventions and the findings
of environmental assessment would also be disclosed through newspapers and electronic media (e.g.,
internet, TV, radio, etc.). The report would be disclosed in Bengali language.
Availability of the Document: Summary of the ESIA and ESMF report along with ESMP will be translated
into Bengali language and disseminated locally. The full report (in English) and the summary (in Bengali)

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will also be uploaded in the website of IA’s (MOC, BLPA, RHD, NBR) and World Bank. Hard copy of the
ESIA and ESMF will also be available at District, Upazila offices of the program area.

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8. INSTITUTIONAL ARRANGEMENT
BBIN-MPA Phase 1 project will be implemented by the BLPA, NBR, MoC (WTO cell) and RHD in
Bangladesh. The BLPA is an autonomous body under the Ministry of Shipping that manages all land
ports of Bangladesh. The NBR (Customs Wing) is under the Internal Resource Division of the Ministry of
Finance. Its main functions are collecting duties and taxes, protecting domestic industry, trade
liberalization, and trade facilitation. The MoC – WTO cell is mandated to implement WTO rules and
regulations, build trade capacity and formulate and implement trade policies. All IAs have experience
in implementing WB projects, notably the ongoing Bangladesh Regional Connectivity Project (BRCP),
and are familiar with the Bank’s financial management, procurement and environment and social
safeguards policies. Except RHD, none of the agencies are familiar with the Bank’s ESF.
Four Project Implementation Units (PIUs) will oversee the day-to-day administration of project
activities, including, inter alia, (i) the management of designated accounts, (ii) financial management
and reporting, (iii) execution of the audit of the project, (iv) preparation of quarterly financial and bi-
annual progress reports, (v) management of the environmental and social safeguards aspects, and (vi)
undertaking all procurement and contract management activities. The PIUs will be headed by full-time
Project directors; be staffed with full-time technical experts and specialists in, inter alia, project
management, procurement, financial management, environmental, health and social aspects, etc. The
provision of a Project Implementation Services Consultants will also be considered.
A Project Coordination Committee (PCC) will be established to provide strategic and policy direction,
review implementation progress, and facilitate the coordination of project activities. The PCC will report
on progress to the National Trade Facilitation Committee (NTFC), as well as the Heads of the respective
implementing agencies. Institutions and Roles in Project Implementation
The implementation agencies for the projects are BLPA, NBR, MoC and RHD.

8.1 Bangladesh Land Port Authority (BLPA)

The Chairman is the executive head of BLPA. He is assisted by Member, Traffic; Member, Development
and Member, Finance and Administration and others are part time Members. Chairman is the head of
the organization. BLPA has a total of strength 310 employees of which 46 are Class I officers, 18 are
Class II officers, 203 are Class III staff and 43 are Class IV staff.
The project will have two Monitoring Committees. The upper-level committee will provide overall
guidelines and cooperation for project implementation especially for the disbursement of fund provided
in the RAP and liaise with various stakeholders including Development Partner, different governmental
organizations and other relevant agencies. The upper-level committee will comprise-
● Representative from Ministry of Shipping (MoS);
● Representative from Local Administration (DC/Upazila Nirbahi Officer (UNO) or
authorized representative);
● Representative from Local Government (Chairman/Ward member);
● Representative from BLPA;
● Representative from Project Affected Persons.
The PIU will also engage an independent organization to carry out external monitoring and evaluation
on implementation of RAP; however, this component will not involve monitoring and evaluation of EMP
due to limited nature of impacts.
The field level committee will be established one for each port is the same as local level and align with
the GRM and will comprise-
● Concerned Port Officer as representative of BLPA- Chairman;
● Local UP Chairman-member;
● Concerned UP woman member- member;
● Representative of business community working in the port area (importer, exporter,

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Clearing and Forwarding (C&F) agent etc.) – member;

● Representative of PAPs- member;
● Sub-Assistant Engineer (SAE) of the port- Member Secretary.
The field level committee will be responsible for direct implementation of RAP especially making
disbursement of payment of compensation to individual PAPs together and in coordination with the DC.
They will facilitate the disbursement process though dissemination of Land Acquisition (LA)/RAP related
information to PAPs and other stakeholders; assist the PAPs getting mutation and other documents
needed for submission to DC to get payment of compensation; assist DC/UNO offices to identify suitable
guardian to receive cheque on behalf of underage children; assist weaker segments among the PAPs
(women, uneducated, lacking competence to deal land related issues) to get proper compensation in
time; and cooperate and coordinate with DC/UNO offices to arrange disbursement of cheques to
individual PAPs at local level.

8.1.1 Institutional Setting and Implementation Arrangement

BLPA will arrange for RPF/RAP implementation and monitoring mechanism. The PIU will have an
Environmental and Social Cell in the PIU. At overall project level all RPF/RAP oversight will be ensured
by BLPA. Executive Engineer of BLPA will head the Environmental and Social Cell of BLPA. One Assistant
Project Director & one Project Manager each in charge for Environment and Social aspects of the
project. The Deputy Director including Assistant Project Director & Project Manager of the Social cell
will be assisted by a Senior Social Specialist-BBIN who is in-charge for Community Engagement and
Gender. The Supervision Consultants and Contractors will have Environmental and Social Specialists to
supervise and implement the RAP provisions. M&E Consultants (here Supervision Consultant) will do
regular monitoring with periodic reporting as necessary. At the end of the project, an end-line
evaluation will be carried out. The all of the monitoring and evaluation reports will be shared with Bank
for their feedback. The BLPA considers that they can carry out midterm review and end line evaluation
internally and does not intend to engage any third party. The third party may be engaged for impact
evaluation at a later stage after two- or three-years project execution. There is no need to include any
budget here for the midterm review or end line evaluation as third-party involvement is not required.
At the time of impact evaluation, the project execution period is already over, and the budget cannot
be included under the project.
Figure 8.1: PIU Environmental and Social Cell

Project Director (PIU)

Design Consultant for

Environment & Social (E&S) Cell Preparation of Designs and EIA
Manager (from permanent BLPA staff) reports for subprojects
Construction Supervision
Consultant– Environmental and
Environmental Resettlement and Social Social Specialists
Specialist Specialist
(Consultant) Contractors Environmental
(Consultant)
and Social Specialists

Monitoring & Evaluation (M&E)

Environmental Consultants (Supervision
Social, Gender, Community Consultant)
consultants as
consultants as required
required
EHS Officer at Each Land Port
during O&M Stage

PIU Environmental and Social cell

Table 8.1: BLPA Functions for RPF Compliance

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Name Organization Functions

Project BLPA ● Orientation and training to Field Units on RPF/RAP and providing
Environment and oversight on the SIA process and its outputs
social cell ● Assisting in fulfilling requirements for all Category sub- projects
● Review of monitoring reports submitted by the M&E Consultants on RAP
implementation
● Regularly visiting sub-project sites to review RPF compliance during sub-
project planning and implementation
● Providing guidance and inputs to the Field Units on social management
aspects
● Managing Monitoring Evaluation of RPF/RAP implementation
● Preparing half yearly and yearly Compliance Reports and sharing them
with The World Bank
● All the actions related to ensure compliance with RPF.
Field BLPA at port- level ● Managing RAP implementation and monitoring
● Collecting data for monitoring
● Providing assistance to local communities
● Coordination with the other agencies for RAP

8.1.2 Consultant Support

The CSC functioning under the BLPA will be directly responsible for contract administration and day-to-
day project supervision including environmental and social management. The CSC will consist of an
environmental and social unit with 1 environmental expert and 1 social expert. The CSC will advise the
BLPA and the PIUs on ESMP implementation and monitor the work of the contractors in the field. The
consultants will also help the PIU prepare quarterly progress reports to be submitted to the BLPA, who
in turn will submit semi-annual reports to co-financier for review. The CSC will, inter alia, be responsible
for the following-
● Engage international/national environment specialists to ensure proper implementation of
ESMP provisions;
● Undertake regular monitoring of the contractor’s environmental performance, as scheduled in
the ESMP;
● Conduct periodical environmental audits;
● Prior to construction, review and approve CESMPs/method statements prepared by the
contractors;
● Supervise site environmental management system of the contractors, and provide corrective
instructions;
● Monitor the implementation of the CESMP and review the environmental management and
monitoring reports prepared by the contractor;
● Review and report on CESMP implementation by the contractor.
Overall, CSC is responsible for ensuring the proper and timely implementation of all their tasks specified
in the ESMP.

8.1.3 Contractors
An ESMP has been prepared to mitigate Project’s environmental and social risks and impacts. It includes
mitigation measures, monitoring plan, capacity building, responsibilities and reporting system and
budget. In addition, the ESMP provide measures to address GBV issue at project level. The ESMP
obligates the contractor, upon mobilization, to prepare the C-ESMP, which shall be approved prior to
the commencement of construction activities. The Contractor’s CESMP shall include OHS plan, Water
and Waste Management Plan, Influx management Plan, Workers camp management plan, CHS Plan,
Traffic management and road safety management Plan, Quarry/borrow area management plan,
Procedure to compensate for damages caused to structures while using heavy machineries, and Site
restoration Plan among others in accordance with the GoB and IFC & WB workers accommodation

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guidelines. All such plans will be reviewed and approved by the PMU of RHD prior to commencement
of construction works. The approved C-ESMP shall be reviewed periodically (but not less than every six
(6) months), and updated in a timely manner.
The contractor will be primarily responsible for preparing implementing the CESMP. Each contractor
will be recommended to have one Environmental Specialist and one Occupational, Health and Safety
(OHS) Specialist and one Social Specialist who will be working in close coordination with the
environmental staff of CSC and PIU. The main functions of the contractor with regard to environmental
and social management and monitoring are to-
● Prior to the start of construction, prepare the CESMP and other method statements and
management plans according to requirements of ESMP and get them approved by CSC.
● Recruit qualified environmental and social safety officers (ESO) to ensure compliance with
environmental and social contractual obligations and proper implementation of CESMP;
● Provide sufficient funding and human resources for proper implementation of CESMP;
● Prepare monthly reports related to environmental and social management and monitoring for
review and verification by the CSC;
● Prepare and implement an Environmental Management system according to the requirement
specified in ESIA/ ISO 14001.

8.1.4 Roles and Responsibilities

The BLPA will be responsible for implementation of the project. The BLPA will establish a Project
Implementation Unit, headed by the Project Director at the Project office which will be responsible for
the overall execution of the project. The PIU consists of Engineering service unit, environmental
management consultant and social specialist for total implementation of the project. The Chairman,
BLPA, will oversee the project PIU activity.
Table 8.2: Roles and Responsibilities for ESMP Implementation

Organizations Responsibilities
PIU/BLPA ● Ensure that all project activities are well-managed and coordinated.
● Procurement of works and goods.
● Payment of compensation to the project affected people
● Recruitment and supervision of Construction Supervision Consultants (CSC)
● Recruitment and supervision of external monitor and independent Panel of
Experts
● Carry out environmental assessment of sub projects in Component 1A
implementation.
● Quarterly reporting on RAP implementation to BLPA.
● All the actions related to ensure compliance with RPF as directed by BLPA and
preparatory studies in Component 1C in compliance with the World Bank and
Government of Bangladesh requirements
E&S Cell within PIU/BLPA ● Responsible for assisting PD with developing TORs and hiring of consultants to carry
out any required environmental assessment work for subprojects and also for
preparatory studies in Component 1C, reviewing consultant deliverables related to
environmental assessment, reviewing bid documents for inclusion of ESMP
measures, supervising construction activities, producing periodic monitoring
reports,
● Ensuring inclusion of ESMP in bidding documents
● Providing training on ESMP principles and requirements to CSC, contractors, BLPA
field staff, and others as needed to ensure effective implementation of ESMP
● Supervising CSC for the implementation of ESMP
● Closely coordinate with other concerned agencies, local governments and
communities to support implementation of ESMP
● Preparation of progress reports on implementation of ESMP.
● Ensure effective implementation of ESMP components not directly tasked to the
contractor including components dealing with indirect, induced and cumulative
effects, as well as operations and maintenance stage plans and measures.
● Commissioning and oversight/review of consultant reports for ESIAs/ESMPs to be
developed for the subcomponents of the Project

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Organizations Responsibilities
● Ensure compliance of the studies on Component 1C (Component 1C: Preparation
Studies and Activities to Enhance Connectivity of Land Ports and Project
Implementation Support) comply with World Bank and Government of Bangladesh
requirements.
● Responsible for developing standard environmental code of practices during
operation stage of land ports
EHS Officer at each Land port ● Responsible for implementing standard environmental code of practices during
operation stage of land ports
● Implementation of mitigation and monitoring measures during operation stage of
the land ports (monitoring of dust, traffic, solid waste collection and disposal, OHS
issues, etc.)
ESIA Consultant ● Carrying out ESIA studies in compliance with the GoB and World Bank guidelines
following the ESMF.
● Preparing ESMP for inclusion in the bid documents.
Contractor ● Responsible for implementation of mitigation and monitoring measures proposed
in the ESMP
● Each contractor will recruit an Environmental, Health, and Safety (EHS) Manager,
who will be responsible for implementing the contractors’ environmental, health
and safety responsibilities, and liaising with government agencies. S/he will have
adequate number of staff to support him/her for these tasks.
M&E Consultant ● External Monitoring and evaluation of RAP

8.2 Ministry of Commerce (MoC)

Institutional Arrangement for MoC-WTO Cell
Under Component 03, BBIN-RTTF phase 01
project MoC will get technical assistance to
implement the trade facilitation agreement by
Setting up of National Trade Facilitation
Committee (NTFC) Secretariat and support the
development and implementation of National
Trade and Transport Facilitation Action Plan,
review of trade related policies, regulations and
agreements with skills development and
capacity building support. As per the existing
institutional arrangement for BBIN, MoC has a
coordinating role to synchronize trade related
activities of the other two components through
a national level trade and transport facilitation
committee. This technical assistance project
being implemented in the Ministry of
Commerce through a Project Implementation
Unit (PIU) in the WTO Cell with the
administrative structure comprising a project
director , project manager (01), national trade
Figure 8.2: Proposed Institutional Framework of MoC-WTO
expert (01), procurement specialist (01), Cell for Implementation of the ESMF
financial management expert (01), data
management consultant (01), focal person coordinator , legal expert (01), senior trade specialist (local
consultant) (01), junior trade specialist (01), jr. monitoring & supervising consultant (02), gender
specialist (01) (for training program, 120 working day). The existing project implementation unit will be
strengthened by appointing by appointing a social development and stakeholder engagement expert
and a gender/SEA-SH specialist to support ES monitoring unit for ensuring proper implementation of ES
requirements. The institutional arrangements for MoC-WTO and MoF- NBR have been illustrated in
Figure 8.2.

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8.3 National Board of Revenue (NBR)

Institutional Arrangement for NBR under MoF:
Bangladesh Customs is working under the umbrella of National Board of Revenue (NBR), the apex body
for direct and indirect tax revenue in Bangladesh. NBR is the major organ of Internal Resources Division
(IRD) under the ministry of Finance, Government of Bangladesh. The MoF will be leading
implementation of component 2 of the project and a project implementation unit (PIU) will be setup in
the Department of Customs under NBR. A Project Coordination Committee (PCC) normally include the
agency’s Head (Chairman, Director General, or Secretary), relevant members, the Project Director and
sub-project/field managers, representatives of the Economic Relations Division (ERD) under the
Ministry of Finance, Planning Commission, Implementation Monitoring and Evaluation Division (IMED)
of the Planning Ministry, and the parent technical ministry (Ministry of Finance for NBR, Ministry of
Shipping for BLPA). The PCC will be responsible for strategic discussions and decisions, inter-agency
coordination, and overall project
monitoring and oversight. The PCC
would be expected to meet on a six-
monthly basis or on an as-needed
basis. The PIU incudes– Project
Director, Deputy Project Director, a
procurement consultant, a project
management/monitoring and
evaluation (M&E) consultant,
environmental specialist, social
development and stakeholder
engagement specialist (full time to
support ES monitoring unit) for the
following core functions: grant
administration including
disbursement, ES management, waste
management, compliance monitoring,
monitoring and evaluation, financial,
procurement management, and
reporting. Besides, one professional Figure 8.3: Proposed Institutional Framework of NBR-MoF for
laboratory analyst with two laboratory implementation of the ESMF
technicians will be hired for capacity
building and modernization of the chemical laboratory facility inside Chattogram Customs house under
the project. In addition, the PIU will ensure coordination of project implementation, including
supervision of and support for the implementation of the sub-project (Figure 8.3).

8.4 Project Implementing Units

The Project Implementation Unit will be established under the RHD and will include an Environmental
and Social unit (ESU). The ESU will consist of one Executive engineer, one sub-divisional engineer and
two assistant engineers to monitor environmental compliance. Similarly, the social unit will comprise of
one Executive engineer, one sub-divisional engineer and two assistant engineers who will be tasked
with ensuring and monitoring compliance related to the social dimensions of the project. The ESU will
be responsible for overseeing the monitoring activities conducted by the CSC on behalf of RHD. It will
also be monitoring the activities of the contractor through the activities of PIU. The main activities of
the ESU with regard to environmental and social safeguards are:
● Planning and implementation of ESMP
● Ensuring that the social and environmental protection and mitigation measures in the ESMP are
incorporated in the Construction Environmental and Social Management Plan (CESMP);

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● Ensuring that the CSC commits and retains dedicated staff as social and environmental
managers to oversee CEMP implementation
● Supervision and monitoring of the progress of activities of the consultants and contractors for
the implementation of different components of ESMP
● Provide guidance to PIU, CSC and contractors in conducting subsequent monitoring and
reporting and in undertaking corrective options
● Responsible for modifications to the ESMP when unforeseen changes are observed during
implementation.
● Ensure submission of periodical environmental and social management and monitoring reports
to the steering committee and co-financers through RHD;
● Submit semi-annual monitoring reports on ESMP implementation for co-financiers review
through RHD;
● Ensure the establishment and implementation of an environmental and social management
system;
● Implementation of environmental monitoring measures (such as environmental quality
monitoring, tree plantation, landscaping, wildlife monitoring) during the O/M stage of the
Project.
● Promote improved social and environmental performance through the effective use of
management systems;
● External communications with other government, semi-government and non-government
organizations, universities, research institutes in the country on the matters of mutual interest
related to environmental management and filming of activities to be carried out under the
project development.

8.5 Capacity Assessment of IAs

The Bangladesh Land Port Authority (BLPA), National Board of Revenue (NBR) and the Ministry of
Commerce (MOC WTO Cell) will implement component 1; component 2 and component 3 respectively.
All three implementing agencies (IAs) are currently implementing the Bank-funded Bangladesh Regional
Connectivity Project (BRCP), using the Bank’s safeguards policies as guiding frameworks. All IAs have
experience in implementing Bank-funded projects and are familiar with the Bank’s financial
management, procurement and environment and social safeguards policies and have adequate
institutional knowledge of institutional E&S risk management. However, the proposed project will be
the first under ESF, except RHD who are currently implementing the Bank-funded WECARE MPA
program, suggesting the need for upfront technical support to the project teams towards adequate
assessment and management of environmental and social impacts of the program. All four IAs have
Project Implementation Units (PIUs) with dedicated E&S specialist by BLPA. However, in general, all the
IAs will require further institutional E&S risk management capacity building given the expanded scope
of E&S management under ESF.

8.5.1 Ministry of Commerce (MoC)

Ministry of Commerce (MoC) has not been involved in WB funded projects. The World Bank has not
performed any capacity assessment of the MoC on the implementation of environmental and social
safeguards in donor-assisted projects.
The Consultants will work under direct control of the Project Director under the supervision of relevant
Deputy Project Director. Consultants will report directly to the Project Director/relevant Deputy Project
Director with close collaboration with other officials of the Project. They shall be accountable to the
Project Director/ relevant Deputy Project Director for his/her day-to-day activities. NBR will provide the
expert working space and office consumables at PIU premises in Dhaka. All international travel, city
transportation arrangements, and accommodation will solely be the Consultant’s own responsibility. If
necessary, MoC will assist in finding accommodation during his stay in Bangladesh. MoC may provide
further reasonable assistance for Visa and other activities in connection with carrying out his
responsibilities under the project scope, upon the request. The ITS will be paid a negotiable consolidated

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

remuneration inclusive of all applicable Tax and VAT as per law of Bangladesh. The language of the
project and all reports shall be English and translation or interpretation to/from Bangla will be provided,
if necessary, by the PIU. The ITS will submit a brief monthly Progress Report (applicable only if his/her
input is provided to the project in that month) to the PIU and the designated team detailing the progress
of all activities and any impediments encountered that may jeopardize the good progress of the project.
PIU will provide the ITS with access to documents relevant to the assignment, including previous studies,
legal texts and regulations, etc., and will facilitate meetings with key counterparts.

8.5.2 National Board of Revenue (NBR)

The national board of revenue (NBR) are taking steps towards strengthening the existing efforts of the
government of the people’s republic of Bangladesh (GoB) in the area of public financial management
reforms. The World Bank performed a capacity assessment of the NBR on the implementation of
environmental and social safeguards in donor-assisted projects. Some of the initiatives supported by
the World Bank are, VAT Online Project (VOP), Strategic Action Plan for Customs Modernization,
Conduct TRS of Chittagong, Benapole, Dhaka Custom House and Dhaka ICD, VAT improvement program,
Revenue Mobilization program. Most of the NBR's current projects are related to infrastructure
development, including construction of revenue building in the city's Agargaon area.
The Consultants will work under direct control of the Project Director under the supervision of relevant
Deputy Project Director. Consultants will report directly to the Project Director/relevant Deputy Project
Director with close collaboration with other officials of the Project. They shall be accountable to the
Project Director/ relevant Deputy Project Director for his/her day-to-day activities. NBR will provide the
expert working space and office consumables at PIU premises in Dhaka. All international travel, city
transportation arrangements, and accommodation will solely be the Consultant’s own responsibility. If
necessary, NBR will assist in finding accommodation during his stay in Bangladesh. NBR may provide
further reasonable assistance for Visa and other activities in connection with carrying out his
responsibilities under the project scope, upon the request. The ITS will be paid a negotiable consolidated
remuneration inclusive of all applicable Tax and VAT as per law of Bangladesh. The language of the
project and all reports shall be English and translation or interpretation to/from Bangla will be provided,
if necessary, by the PIU. The ITS will submit a brief monthly Progress Report (applicable only if his/her
input is provided to the project in that month) to the PIU and the designated team detailing the progress
of all activities and any impediments encountered that may jeopardize the good progress of the project.
PIU will provide the ITS with access to documents relevant to the assignment, including previous studies,
legal texts and regulations, etc., and will facilitate meetings with key counterparts.

8.5.3 Bangladesh Land Port Authority (BLPA)

The BLPA has implemented a variety of initiatives supported by the World Bank, the Asian Development
Bank, Japan International Cooperation Agency, and other donors. Within the BLPA, there is an in-house
social and environmental circle (SEC). Delegated officers are also responsible for bringing environmental
and social issues to the attention of high management. Currently, SEC engineering officers are tasked
with reviewing environmental and social assessments submitted by consultants, but they are not tasked
with reviewing the ESMP's adequacy. The DOE of the Ministry of Environment, Forests, and Climate
Change (MoEFCC) reviews and approves the IEEs/EIAs and EMPs. The BLPA SEC is not directly involved
in project delivery, but instead has administrative responsibilities for ensuring environmental
compliance and a broader role in raising environmental awareness for BLPA. BLPA authority will train
up their existing staffs for monitoring during operation and maintenance period and they will
periodically perform these monitoring and evaluations during operation phases.

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8.6 Action Plan to Strengthen Staffing, Capacity, Systems and

Implementation
Project Co-ordination Institutional Arrangements and capacity Building for environmental and social
management:
A number of institutions will be involved during the construction and operation phase of the sub-project
to achieve the environmental compliance goal set by ESMP. In order to strengthen the existing
institutional capacity of NBR, MoC and RHD for environmental and social management the Project will
develop and implement systems and measures. Each of these Project Implementing Units (PIU) will
include a Social, Environmental and Communication Cell headed by a Deputy Director which will be
staffed by qualified specialists (consultants) as mentioned earlier under the Project. The PIU will also
engage project management consultants (PMC) to supervise the contractors including their execution
of construction-related ESMPs and ECoPs. The Environmental and Social Specialist within the E&S Cell
will assist the PIU on issues related to environmental and social management, including overseeing the
PMC and contractors with respect to environmental issues, orientating contractors and field staff to
ESMP requirements, reviewing PMC monthly monitoring reports, and compiling quarterly monitoring
reports on ESMP compliance for the Project Director and the World Bank throughout the construction
period. Prior to completion of construction, each PIU will appoint permanent Environment Specialist,
Social Specialist, Gender Specialist, Occupational, Health and Safety specialists as required for
overseeing the sub-project activities, who will be responsible for overseeing the environmental and
social mitigation measures during operation and maintenance period.
With particular reference to the proposed master plan of Chattogram Customs House, a full-fledged
chemical laboratory will be setup in a three storied building occupying 5,500 sft area for which a
professional lab analyst trained on modern lab facilities, equipment handling, bio-safety and waste
management protocols with two lab technicians will be hired to support the ES monitoring unit under
NBR. These specialists will be trained enough throughout the project to effectively transfer the
adequate skills and knowledge to the workforce and carry out their roles even after the Project closes.
An environmental and a social specialist under the PIU who will be responsible for:
● Preparation and consultation for required ES instruments
● Addressing ES risks and impacts including monitoring of the implementation of all ES
instruments, community health and safety measures, the functioning of the grievance redress
mechanism (GRM), etc.
● Screening of subprojects (Annex A) for ES issues, disclosure, review and clearance of subprojects
to monitoring the implementation of the ESMP
● Prepare relevant ESMP and ensure implementation and monitoring
Environmental and Social specialists will be full time consultants for each of the PIUs to monitor ESMF,
ESCP, SEP and LMP implementation and ensure compliance with both World Bank and Government E&S
requirements.
Capacity building training is needed for BLPA, RHD, NBR, MoC officials. The project will finance sub-
project level officers and staff training related to RAP implementation, gender and vulnerability for
BLPA and RHD, etc. The PIUs will have their own capacity building plan and the tentative budget
provided here is supplementary to it.
Capacity building for effective implementation of the ESSs requirements is a key element of the ESMP.
Capacity building for environmental and social safeguard management will need to be carried out at all
tiers of the BBIN-RTTF phase 01 project, including PIUs and contractors. At the construction site, PIUs
will take the lead in implementing the capacity building plan, though the contractors will also be
responsible to arrange trainings for their own staff and workers. The various aspects that are covered
under the capacity building will include general environmental and social awareness, key environmental
and social sensitivities of the area, key environmental and social impacts of the project, ESMP
requirements, OHS aspects, and waste disposal. Hence, a separate Capacity Building Plan for the BBIN-

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RTTF phase 01 has been prepared which will guide to build capacity of the PIUs for implementing this
ESMF. Following paragraphs provide summary of the capacity building requirements as assessed in this
report.
Training on Environmental & Social Management
Capacity building for effective implementation of the ESSs requirements is a key element of the ESMP.
Capacity building for environmental and social standards management will need to be carried out at all
tiers of the program, including IAs (NBR, BLPA, RHD, MOC), Project Management Consultant (PMC), and
contractors. PMC will take the lead in implementing the capacity building plan at the construction site,
though the contractors will also be responsible for conducting training for their own staff and workers.
The various aspects that are covered under the capacity building will include general environmental and
social awareness, key environmental and social sensitivities of the area, key environmental and social
impacts of the program, ESMP requirements, OHS aspects, and waste disposal.
all PIU staff and Land Port level staff will receive training and capacity support from the PMC safeguard
specialists to ensure learning and development and smooth and effective implementation of the ESMP
and resettlement plan.
Training shall be imparted, on a regular interval, to the IAs (NBR, BLPA, RHD, MOC) officials and Staff on
Environmental and Social Issues. The ESMF document will be used as training material for IAs officials/
staff capacity building, and the Environmental & Social Specialist will act as facilitators for the capacity
building sessions. If the Consultants, ES & SS, do not feel confident on their subjects, the ESIA
consultants will initiate training for the IAs (NBR, BLPA, RHD, MOC) officials as a TOT course on ESS
issues. Later on, the IAs officials and Consultants will train the Contractors’ people on safeguard
compliance.
BLPA authority will train up their existing staffs for monitoring during operation and maintenance
period and they will periodically perform these monitoring and evaluations during operation phases
apart from their general tasks.
The below tables are prepared to estimate the cost for hiring specialist to implement this project for all
the IAs.
MOC
Remuneration
SI Expert’s Position
Monthly Annually
1. Gender Specialist (01) 450,000 5,400,000
2. Environmental and Social Development/Stakeholder
450,000 5,400,000
Engagement Specialist
Total (BDT) 10,800,000
Total (USD) 127,059
NBR
Remuneration
SI Expert’s Position
Monthly Annually
1. Environmental Expert (01) 450,000 5,400,000
2. Social Development and SE Expert (01) 450,000 5,400,000
3. OHS and Labor Management Expert (01) 450,000 5,400,000
4. Gender and SEA/SH Expert (01) 450,000 5,400,000
5. Lab Analyst 200,000 2,400,000
6. Lab Technician 150,000 1,800,000
Total (BDT) 25,800,000
Total (USD) 303,529

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

BLPA
Remuneration
SI Expert’s Position
Monthly Annually
1. OHS and Labor Management Expert (01) 450,000 5,400,000
2. Land Acquisition and Resettlement Expert (01) 450000 5,400,000
3. Environmental Expert 450000 5,400,000
4. Gender and SEA/SH Expert 450000 5,40,0000
5. Social Development and Stakeholder Engagement Expert 450000 5,400,000
Total (BDT) 27,000,000
Total (USD) 317,647

(1 USD= 85 BDT)
[Salaries including Tax and VAT] TOTAL: BDT 63,600,000 [USD 748235]

Training/ Seminar
Budget
Seminar Topic/
BLPA Time Frame
Training Module NBR MOC
[3 Ports]
Introduction to World Bank ESF 1,500,000 500,000 500,000 Year 1
Labor and working conditions and 1,500,000 500,000 500,000 Year 1
OHS
Community health and safety 1,500,000 500,000 0 Year 1
Grievance Redress Mechanism 1,500,000 500,000 0 Year 1
Stakeholder Engagement 1,500,000 500,000 500000 Year 1
Gender and SEA/SH/GBV 1,500,000 500,000 500000 Year 1
Review of RPF and RAP 900,000 0 0 Year 2
ESMP compliance monitoring 600,000 100,000 0 Annually
RAP compliance monitoring 600,000 0 0 Annually
OCHS and Labor Management 600,000 100,000 0 Annually
audit
Contract and Consultant 600,000 100,000 100,000 Year 1
Management Module
Safe Chemical and Laboratory 1,000,000 500,000 0 Year 1
Management
Advanced Laboratory Techniques 2,000,000 500,000 0 Year 1
and Instruments Handling
TOTAL (BDT) 15,300,000 4,300,000 2,100,000 21,700,000
TOTAL (USD) 180,000 50,588 24,706 255,266
Budget Time Frame
BLPA NBR MOC
Other Items
Travel 600,000 100,000 0 Periodically
E&S Monitoring and Reporting 600,000 100,000 0 Periodically
Studies (lumpsum) 500,000 200,000 100,000 Annually
Communications (materials and 1,500,000 500,000 500,000 Bi-annually
campaign)
OHS Materials (e.g., Mask/ 1,500,000 500,000 500,000 Annually
Disinfectant Spray/ Handwash
etc.)
TOTAL (BDT) 4,700,000 1,400,000 1,100,000 720,0000
TOTAL (USD) 55,294 16,471 12,941 84706
(1 USD= 85 BDT)

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8.7 Conclusion
All the sites under the project are extension or upgrading of the existing infrastructures. The activities
will be carried out on the current E&S footprints and hence, essentially consist of modified habitat. The
potential impacts are limited and can be easily managed by applying standard GIIP and the relevant
provisions in the ESMPs in compliance with the Bank’s ESF and Bangladeshi laws.

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ANNEXES
Annex A: Sample Checklist for Environmental and Social Screening of Sub-Projects

Subproject Name

Implementing Agency

Subproject Location

Estimated Investment

Start and Completion Date

Sub-project Description and Key Activities: Please fill the table below

Name of the sub- Type of Brief description of the

Key stakeholders
project Intervention/s design

Response
to the ES Impact
Question
Negative Impact
Sl
Positive Impact

Screening criteria Remarks

No Impact

No

Substantial
Moderate
Yes No

High
Low

ESS-1: Assessment and Management of Environmental & Social Risk and Impacts
1 Does the subproject carry risk
that disadvantaged and
vulnerable groups may have
unequitable access to project
benefits?
2 Will the project contribute to any
long- term significant adverse
(negative), large scale,
irreversible, sensitive impact at a
regional scale or area broader
than the project sites?
3 Whether accessibility of
differently able people have
been made in the project design?
ESS-2: Labor and Working Conditions
4 Does the subproject involve 2
recruiting workers, including
direct, contracted, primary
supply, and/or community
workers?

2
If yes, please provide the tentative numbers here. Such as: 1. number of Local laborers, migrated labors,
community labors, supply workers and number of contractors

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Response
to the ES Impact
Question
Negative Impact
Sl

Positive Impact
Screening criteria Remarks

No Impact
No

Substantial
Moderate
Yes No

High
Low
5 Will there be migrated labor in 3
the project?
6 Will there be any labor camp for 4
the accommodation of the
labors?
7 Will there be separate facilities
for women workers?
8 How severely the project 5
activities can impact the OHS of
the workers?
9 Is there a possibility of employing 6
vulnerable workers, including
women and child labor?
10 Does the project area present 7
considerable Gender-Based
Violence (GBV) and Sexual
Exploitation and Abuse (SEA) as
well as Sexual Harrassment (SH)
risk?
11 Is there possibility that activities
and deployment of labor would
cause potential GBV cases?
12 Will the activities cause
interaction between laborers
and communities in view of
COVID-19 situation?
13 Is there any potential for conflict
between construction workers
and local peoples (and vice
versa)?
14 Does the subproject have a GRM
in place, to which all workers
have access, designed to respond
quickly and effectively?
ESS-3: Resource Efficiency and Pollution Prevention and Management
14 Will the activities use or generate
substances that will cause
pollution of water bodies
(groundwater/surface water)
during the construction or use of
the facilities?

3
Answer should be linked above
4
Labor camp, rented house etc.? If a labor camp is required, should a location be mentioned?
5
Accidents, safety, Covid-19
6
Engaging vulnerable women is preferred but adequate safety measures must be taken
7
Answer should be linked with question 8. Also, community based GBV/SEA/SH should be considered including
previous history.

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Response
to the ES Impact
Question
Negative Impact
Sl

Positive Impact
Screening criteria Remarks

No Impact
No

Substantial
Moderate
Yes No

High
Low
15 If the sup-project is located by the
side of a river, is there any
drinking water source upstream
and downstream of the project
location that can be affected?
16 Are there any low-lying areas
prone to water logging/flooding
due to project activities?
17 Is there necessity of substantial
removal of Top Soil?
18 Will the project / any of its
component might contaminate
or pollute the Land?
19 Will the project result in
stagnation of water flow or
pondage or weed growth
20 Will the project use or store
dangerous substances (e.g.,
massive quantities of hazardous
chemicals/ materials like
Chlorine, Diesel, Petroleum
products; any other?
21 Will the project produce solid or
liquid wastes; including
construction/demolition wastes
(including de-weeding wastes,
muck/silt, dust); polluted liquids?
22 Will the project cause or increase
air pollution or odor nuisance?
23 Will the project cause or increase
noise pollution or vibration
level?
24 Is there any potential for
release of toxic gases or accident
risks (e.g., potential fire
outbreaks)
ESS-4: Community Health and Safety
25 Will the project result in Health &
Safety Risks in the
neighborhood?
26 Is there possibility of potential 8
disruption to common property,
accessibility, traffic system etc.
due to project activity?
27 Will the activities affect other
communities who rely (or might

8
If common properties are affected or disrupted, please link with ESS5 as well.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Response
to the ES Impact
Question
Negative Impact
Sl

Positive Impact
Screening criteria Remarks

No Impact
No

Substantial
Moderate
Yes No

High
Low
become dependent) on the same
resources that the proposed
activity will be using?
28 Will the activities create a
situation that may threaten the
livelihood of people who have
been providing similar types of
services in the community?
29 Are there any sensitive ES
receptors such as residences,
schools, hospitals etc. which the
project might impact?
30 What types of precautions have been taken to limit the spread of COVID-19 pandemic?
(i) Wearing Mask
(ii) Maintaining PPE
(iii) Using sanitizer
(iv) Regular temperature checkup
(v) Disinfection facilities
ESS-5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement
30 Will the proposed activities
potentially involve resettlement
and displacement, land
acquisition, restrictions and
economic displacement of
persons and communities?
31 If the answer to Ques. 28 is yes, Please write detailed here
answer below and write detailed
here.
31a Will there be any land acquisition Please write the purpose of acquisition or requisition here
or requisition?
31b Is the ownership status of the 9
land known? If yes, please
provide details here.
31c Is there a possibility of voluntary 10
land donation? If yes, please
provide details here.
31d Will there be any loss of 11
residential, commercial or
community structures?
31e Is there any presence of
squatters who may be affected
due to interventions?

9
Government/private or owned? by other entities
10
If yes, who will donate?
11
Please provide numbers here, if the answer is yes

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Response
to the ES Impact
Question
Negative Impact
Sl

Positive Impact
Screening criteria Remarks

No Impact
No

Substantial
Moderate
Yes No

High
Low
12
31f Will there be any loss of trees,
crops, or any fixed assets?
31g Would the resettlement site
culturally sensitive?
ESS-6: Biodiversity Conservation and Sustainable Management of Living Natural Recourses
32 Will the activities be located
within or close to protected
areas and areas of ecological
significance including critical
habitats, key biodiversity areas
and internationally recognized
conservation sites?
33 Is there any possibility of
degradation of land / eco-
systems due to the project
activities?
34 Is there any possibility of tree
cutting that may have impact on
local ecology?
35 Will the activities cause any
degradation to the nearby
aquatic environment?
ESS-7: Indigenous/Tribal Peoples
13
36 Will the activities affect tribal
peoples affected by the project
interventions?
ESS-8: Cultural Heritage
37 Loss or impacts on
Cultural/heritage properties
ESS-10: Stakeholders Engagement and Information Disclosure
38 Has the screening team
conducted any consultations
with the different stakeholders
during screening?
39 Do the local people aware of the
proposed project?
40 Were there any information
shared in print with the
stakeholders during
consultations?

12
Numbers and types
13
If yes, please provide details here. Also communicate with Bank’s E&S team.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Conclusions
Sub-Project Category □ Low □ Moderate □ Substantial □ High
Key Reasons

E&S Instruments Required □ Detailed ESIA and ESMP

□ Resettlement Plan
□ Site-specific ESMP

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Annex B: Details of Public Consultation Meeting and Focus Group Discussions

Burimari Land Port

Summary of Consultation Meeting with Officials (I)

Sl Key Issues Raised Participant/S Type Response

1 Brief on the project AD, Burimari Land Port The AD of Burimari Land Port welcomed and
thanked all the participants for their presence in
the public consultation meeting. Then he gave a
brief on the project.
Environmental and Social The consultants discussed to the participants
consultants what environmental and social standards will be
maintained throughout the project like, preparing
separate documents on Environmental and Social
Management Framework (ESMF), Environmental
and Social Impact Assessment (ESIA), Stakeholder
Engagement Plan (SEP), Labor Management
Procedure (LMP), Resettlement Policy
Framework (RPF), Resettlement Action Plan
(RAP), Sexual Exploitation & Abuse and Sexual
Harassment (SEA/SH), Gender Action Plan (GAP),
Environmental and Social Commitment Plan
(ESCP)
Company Commander, The BGB company commander then said that his
Border Guard Bangladesh organization would try to provide all possible
(BGB) assistance in implementing the project.
2 How the price is AD, Burimari Land Port Social consultants firstly said that, for the
determined in case of development or expansion of the existing land
land acquisition? port, according to the World Bank’s
Environmental and Social Framework (ESF) the
project Implementing Agency’s primary target is
to avoid any kind of private property/ land
acquisition. If it is not avoidable then the project
will go following the Resettlement Policy
Framework and Resettlement Action Plan for land
acquisition where policy from both the
Government of Bangladesh and The World Bank
will be followed. It was also discussed that, to
determine the price of land or any kind of loss
(e.g. structures, crops, tress, business etc.) there
will be Property Valuation/Market Survey.
Mr. Sayed, President, C&F He said that, if possible, there would be about 25
Agents Union acres of vacant land on the east side of the
present port. That space can be acquired and
used for project work.
3 If someone runs a Md. Anowar Hossain (In- Answering the question raised by the
floating business on Charge, Immigration Immigration Police consultants discussed in the
other’s land or Police, Burimari land meeting that any business, whether small,
Government-owned port) medium or large, permanent or temporary,
land (Khas) and if that would be compensated if affected by the project.
business is affected, The participant also wanted to know, if land
how will that person be acquisition takes place, compensation will be
paid compensation? determined for the lands on the front side of the
road and that are away from the main road.
Consultants informed that by evaluating the
market survey and government rate land price, all

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Sl Key Issues Raised Participant/S Type Response

affected person/s should get a fair price for their
land parcel.
4 If land acquisition takes From representatives that Consultants assured them again that if land
place what will the are living in the proposed acquisition is unavoidable, then the project will
community living very land area adjacent to the follow the RAP and accordingly affected persons
close to the land port do existing land port (near will be compensated and provided support for
zero point) their resettlement.
5 Education system and Mst. Rahena Sultana, Stone is the most important of the various
children’s security Head Teacher of primary products imported through this land port. The
school, and Community stone crushing business around this port area is
representatives currently making a huge contribution to the
economy of Burimari. But due to the business of
stone crushing, stone powder, etc., the
environment has become much polluted in the
area around 5/8 km near Burimari port. All the
citizens living here are moving in a dusty and
sandy environment. As a result, people are
suffering from shortness of breath, asthma, cold
and cough. The headmistress drew the attention
of the authorities to keep in mind reducing the
environmental pollution by expanding and
modernizing the port area.
The participants agreed with what she said and
they suggested Participants suggested that a
particular area with boundary be set up in an
uninhabited area for the stone related businesses
and that the companies regularly set up sprinklers
on their behalf and abide by those rules.
Nearly one third of the participant said that the
education system in this area is poor. In addition,
it is plagued with various problems due to which
number of school dropout is also high.
More than 15 primary school is located in this
area contrarily only 1 high school and 1 college
which is 6 kilometers away from this area.
The Head Teacher again said, ‘A country is bigger
than the individual’. Therefore, in the interest of
development of the country, we have to take any
kind of action positively. But the project will be
implemented by giving priority to the 6 basic
needs of the people - that is what they hope.
Burimari is not as green as before. All the trees in
the area are now covered in dust. If the Ministry
of Environment initiates a tree planting program
here, it is very good for the area.
Excessive load-sheading has resulted in students
not being able to study properly.
6 Labor related issues Mst. Rahena Sultana, All workers who come to the area to work on the
Head Teacher of primary project must ensure that they are provided with
school the Covid-19 vaccine.
The use of gloves, helmets, boots, etc. should be
ensured to avoid the risk of accidents and safety
of those who will work as laborers.
President, Landport labor About 3000 workers are involved in various
union activities of the port. They do not have restrooms,

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Sl Key Issues Raised Participant/S Type Response

toilets, overnight accommodation etc. in the port
area.
Mr. Sayed, President, C&F There is no accommodation for the drivers of
Agents Union freight vehicles arriving in the port area. Most of
the incoming drivers spend the night in freight
cars or trucks. Which is very risky for them to do
their job properly. So accommodation needs to
be arranged for them.
7 Communication All Participants Getting students to school is challenging as they
facilities have to sit in traffic jams for a long time almost
every day.
In addition, Heavy mud in rainy days and
extensive dust in normal times creates a
tremendous suffering to the school-college going
children.
Furthermore, road accident happens very often
there, driving of over loaded tracks in less width
road is responsible for accidents.
Accidents often happen because of narrow roads,
broken roads. In addition, dust, severe traffic
congestion has made communication in this area
difficult.
Communication will be much easier if a bypass
road can be made from Burimari Land port zero
point aligning with the rail way line. Undoubtedly
it will be a tremendous support for local
residence.
Mr. Sayed, President, C&F The highway that started from Burimari Zero
Agents Union Point area and passed through Burimari Bazar
towards Patgram is quite narrow considering the
number of vehicles currently plying in the area.
This road needs to be at least 6 lane. This will
almost completely alleviate the severe traffic
congestion in the area.
Company Commander, He said if the port is developed, the country will
Border Guard Bangladesh develop. First, the allocation of BGB's security
(BGB) needs to be expanded. The existing highways
need to be widened. A separate walkway has to
be built for people to walk. In this project, all the
infrastructural development has to be done
considering Burimari port, but infrastructural
development has to be done keeping in view the
common man.
8 Health system of this All Participants Nearly all the participants said that the health
area system of this area is terrible. Community clinic,
upazila health complex, even in Sadar hostipal
don’t have sufficient medical facility, and
nowadays they don’t even expect to get adequate
service.
Consequently, critical patients are taken to
rangpur medical where they get proper
treatment.
At least 70 people in this area have died of
silicosis due to excessive air pollution, and 100
more people are still infected.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Sl Key Issues Raised Participant/S Type Response

A large number of residences of this area suffer
from Asthma, silicosis, shortness of breath and
other critical diseases due to open stone crushing
miles.
9 Environmental All Participants Majority of the participants blame ‘Stone traders’
awareness of stone for environmental pollution as crushing rocks in
crushing company the open air, the dust of the rock spreads in the
air and pollutes the air.
After being washed by rain water, this dust goes
into rivers or reservoirs and causes water
pollution.
As there is a possibility of air pollution by the
project, the authority should take necessary steps
to reduce the environmental pollution.
Wastes of this project should be kept or managed
away from localities.
If the stone crushing traders water regularly, the
dust will be reduced in this area.
Regular monitoring by law enforcement agencies
will reduce such irregularities.
Mr. Sayed, President, C&F At present, the volume of Burimari land port-
Agents Union centric business has increased many times over.
The area of Burimari land port is presently
approximately 11 acres. Even if the size of the
port is increased 10 times more than it is now, it
will not be enough to run port based businesses.
Neither the traders nor the appropriate
authorities are responsible for reducing the
environmental pollution by the stone business.
The stone workers are risking their lives to earn a
living. The stone business is one of the major
contributors to the region's economy. According
to the government policy, all the stone crushing
businesses are supposed to operate within 3 km
of the port area, but at present the stone business
establishments are spread over an area of about
8 km. Therefore, administrative monitoring is
very important for sustaining the business and
keeping the environment safe.
10 Development of Land Md. Anowar Hossain (In- The current situation of rest, toilets, food intake
Port Immigration Charge, Immigration for our immigrant passengers is very inadequate
related issues and other Police, Burimari land port) compared to other countries in the international
facilities arena. Since they have to face immigration first by
crossing the border from a neighboring country,
their first impression of our country will be
positive once immigration meets international
standards. So, we want a tidy, tidy, clean
immigration.
11 What should be kept in All Participants There are no residence facilities for drivers and
mind for this project? staff from India or other countries, and even
there are no toilet or bathing facilities. These
issues must be kept in mind planning this project.
A mosque should be built within port boundary so
that workers can pray in time properly.
To reduce road accident a foot over bridge needs
to be installed in the land port area.

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Sl Key Issues Raised Participant/S Type Response

The labors are often victims of accidents.
Contrarily, there is no insurance facilities for
them. There should be an insurance facility so
that they can get support from.

Figure: Consultation Meeting, Burimari Land Port, Burimari, Patgram, Lalmonirhat

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of FGD with Burimari Local Importers/ C&F Agents (II)

The FGD with Local Importers/ C&F Agents was conducted on 13th December 2021.

Date Location Participants

13/12/21 Conference hall, Burimari Land Port Office, Burimari, Patgram, Lalmonirhat 10 (men)

Summary of Queries, Concerns and Suggestions

Raised by Local Importers/ C&F Agents during FGD Responses
Sessions (II)
1) Development activities of Burimari Land Port are Respondents said they did not know anything about
going to start in your area under Bangladesh land port development activities. At present, the
Land Port Authority. What do you know about perimeter of the land port is not sufficient for trade,
this project? If you know, tell us the details of they said. If the modernization of the port is done and
what you know about the project. (Tell us in perimeter of the land port is increased, it will bring
detail about the project's start time, about the positive change for the people of the port area. The size
land acquisition, how you know about the of the port yard needs to be increased. According to
project.) them, they conduct business properly by paying
revenue / port charges etc. to the port authorities, but
they are not getting the kind of trade-friendly benefits
they are supposed to get from the port. Therefore, they
think that the port development activities will bring
opportunities for improvement in their area.
2) What are the advantages and disadvantages of They believe that the development of land ports will
the project in the area? Who do you think could increase the dynamism of trade. They said that the yard
be directly affected by the project and who could (car park field in the local language) should be
be indirectly affected? Whose interest do you increased in the port during the discussion. At present
think is involved in land port development? the number of cargo vehicles entering the port is
What are your comments / suggestions for approximately 400/500 daily. Increasing the size of the
problem solving? yard will almost double the number of cargo vehicles
entering. They expressed the view that a better
banking system needs to be formulated in the port
area. As no banking system is available inside the port,
they need to move away from the port to complete
their banking activities. As a result, their time is wasted.
Moreover, in order to develop the port, the roads
adjacent to the port will also have to be developed, as
a result of which the port-centric traffic congestion will
be eliminated, more cargo vehicles can enter, which
will also increase the revenue of the government.
The current weight scale of the port is flawed. If the
port is developed, a weight scale that provides accurate
measurements will be established, which will reduce
the amount of losses to traders.
When the respondents were asked about the
inconvenience caused by the project, they said that if
the port is to be expanded as part of its development
activities, land will be required. In that case if the land
is acquired in a place where there is privately owned
land then the land owners will face loss. But if the
government compensates them for the land at a
reasonable price, they think the acquisition will not
cause much trouble.
Besides, the environment of the huge area adjacent to
the port is unsuitable for human health. Many people
suffer from respiratory problems due to dust and sand.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of Queries, Concerns and Suggestions

Raised by Local Importers/ C&F Agents during FGD Responses
Sessions (II)
Once the project starts, the level of environmental
pollution will increase.
3) Please discuss in detail what issues should be They mentioned that some issues should be given
given priority in land port development project priority in the formulation of the development plan.
planning and why. (E.g., port infrastructure, Such as:
what can be linked to modernization, what 1) Port area size should be increased 3 times more than
needs to be considered for residents and at present
business groups living in the port and related 2) The highway adjacent to the port has to be upgraded
areas, etc.) to 4 or 6 lane roads, starting from Zero Point to at least
10 km.
3) In order to reduce the amount of dust, regular water
sprinkling should be done by water truck
4) Parking area should be increased
5) A bypass road should be constructed along the
railway line
6) Planned sewerage system should be maintained
7) Stone-breaking businesses scattered over a wide
area should be given the opportunity to conduct
business by enclosing the boundaries in a certain place.
8) The bank is located about 3 km. away from the port.
Therefore, it is important to set up bank branches
inside the port to prevent wastage of time for traders.
9) It is necessary to set up a mosque inside the port.
10) Modern fire service system is required.
11) It is necessary to increase the skilled manpower in
different institutions or departments of the port.
4) What will be the impact on the women in your They believe that the project will not have a specific
area due to the difficulties that may/will occur as impact on women and children, but on all the people
a result of the project? Please provide us with a living in and around the project area. They said the
detailed idea of how safe the environment in Burimari area is safe enough for everyone, men and
your area is for the movement of women and women alike.
children.
5) If there have been any incidents of violence / There have never been any incidents of violence or
torture against women in the area before, please torture against women in the area. Women workers
tell us about it. Please tell us in detail if there are working in the agricultural sector and in stone
have been any conflicts / conflicts with women breaking businesses without any hindrance.
workers / women workers groups who have
come to work under any project or participated
in any work before.
6) In the interest of the project there is a large They said workers coming to work on the project will
section of workers who will come to your area not have any problem working or staying in the area.
from different districts and stay here for the sake But local people should also be employed as laborers
of work. What could be the problem due to according to their qualifications in the project. Local
workers coming from elsewhere in the project? people will be interested in working if there is an
What are your comments / suggestions for opportunity to be involved in any kind of project work.
solving this problem? What percentage of local Women will also be able to work as workers in different
people in your area do you think could stages of the project. Women workers are working in
participate in the project as workers? Provide an stone breaking business establishments.
idea of the state of child labor in the area. Do you There is no fear among the workers. However, in case
think that women as workers can / will of any unwanted incident, a committee consisting of
participate in various activities of the project? local administration, elected representatives, local
What is your advice in this regard? Please let us businessmen may be formed to resolve the grievances.
know if there are any subsequent workers' They said there are separate organizations for C&F
grievances, abuse or any kind of untoward employees in their area. This organization is trying to
incident. (Gender based violence, sexual solve any problem of the employees at any time. Apart

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of Queries, Concerns and Suggestions

Raised by Local Importers/ C&F Agents during FGD Responses
Sessions (II)
violence, child labor, forced labor, inequality in from this, such committees can be formed with
wages or other employment opportunities for importers, C&F Staff Association etc.
female workers, etc.)

7) What kind of problems do you think might arise They said that if land was acquired in the interest of the
if land is acquired in the interest of the project? project in the port area, there would be no special
Explain the details of the compensation process problem if the land owners were given proper
when an acquisition is made. If you have any compensation. Privately owned land was acquired
previous acquisition experience in your area, before the port was established on the present
discuss it with us. If the acquisition is done, Burimari land port site. Many of those who lost land in
discuss what you think would be better to the acquired area later bought land near the Zero Point
compensate for the loss. area on the north side adjacent to the port and settled
there. All those whose land has been acquired were
compensated for the land as far as they know.
However, it is best to use demesne land without
acquiring privately owned land.
8) To whom/ where will you go to resolve any kind A committee consisting of concerned authorities and
of complaint/problem arising out of the project? local people's representatives may be formed to report
Do you know if there is any effective any grievances or problems related to the project.
committee/arrangement in resolving the
complaint? If so, tell us about the working style
of that committee. (Whether there should be a
committee, with whom this committee should
be consisted of, what kind of work should be
done, etc.)

9) Do you think any special aspect should be taken Respondents have previously suggested that the
into consideration while using different project could increase environmental pollution. They
resources (such as fuel, gas, water, sand, stone, suggest that the materials or construction materials
road construction raw material etc.) used in the used in the project should be kept in a designated place
project? Can the use of the mentioned resources and covered with tarpaulin material when the work is
cause environmental pollution? If so, what are stopped to prevent the spread of such materials on the
the measures that can be taken to prevent roads.
pollution?

10) Will the project have any impact on roads, Due to the project, the highway used at present may be
environment and canals / rivers? If so, what kind further damaged or the movement of people may be
of impact? What are your comments / disrupted. However, they think that it is a temporary
suggestions for problem solving? effect. They do not think that any kind of canal or river
is likely to be damaged
11) Give an idea about the existing educational Excessive dust, noise, busy roads, etc. make children
institutions in your area. (Number of primary, reluctant to go to school. Stone-crushing machines are
secondary, higher secondary educational supposed to be installed at least 300 yards away from
institutions / your satisfaction with the quality of the school, but the stone-crushing businesses are
education provided in the educational scattering them in an unplanned manner. Even if no
institutions / infrastructural condition of the educational institution is likely to be directly affected
educational institutions etc.). Do you think any due to the project, it may worsen the existing situation.
school / college / madrasa / cultural heritage /
historical place in your area will be affected by
the impact of this project? If this happens, what
is your advice to avoid or compensate for the
loss?
12) Do you think that the local area's religious They said no religious institutions, historical structures
institutions, historical and traditional are likely to be damaged due to the project.
establishments will be damaged due to the

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of Queries, Concerns and Suggestions

Raised by Local Importers/ C&F Agents during FGD Responses
Sessions (II)
project? What are your comments / suggestions
for problem solving?
13) Describe in detail the state of healthcare in your In this regard, they said, Patgram Upazila Health
area. (What are the names of the health care Complex is located about 15 km away from Burimari.
providers in the area, whether they have Besides, there is no other medical service provider
adequate manpower, adequate medicine or nearby in their area. People usually go to the local
medical equipment, what level of organization pharmacy or village doctors for any ailment early.
do you usually visit to receive healthcare etc.) There is no first aid facility inside the port.
14) State which media might be most effective in Miking, giving notices to local newspapers to get
conveying any information about the project. information about the project can be fruitful.
(Miking, leaflets, magazines, etc.)
15) What percentage of houses in this area have an All the houses in this area have electricity connection.
electricity connection? Describe the current state However, due to the high level of load shedding, people
of load shedding. are not able to enjoy that benefit despite having an
electricity connection.
16) Name some of the NGOs operating in your area. NGOs like BRAC, Grameen Bank, TMSS, RDRS etc. are
Tell us what programs these NGOs run. Please conducting their loan, education related activities in
discuss about the local people’s level of the area.
involvement and the reason for such
involvement with the NGOs. What kind of
organization is working / has done in the past to
raise awareness about environmental pollution?

Figure: FGD with Importer and C&F agent representatives

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of FGD with Burimari Community Male (III)

Date Location Participants

10/12/21 North side of the Land Port boundary wall, Burimari, Patgram, Lalmonirhat 13 (men)

Summary of FGD Sessions with community males (III) Responses

1. Development activities of Burimari Land Port Participants present in the meeting said, they did
are going to start in your area under Bangladesh Land not know of any projects related to the
Port Authority. What do you know about this project? development activities of Burimari land port. One
If you know, tell us the details of what you know about said he had heard from a person working at the port
the project. (For example, details about when the that the port would be expanded, separate parking
project will start, about land acquisition, how you would be provided, there would be a fire service,
know about all these things etc.) and a weight bridge (weight scale) would be built,
but he did not know when that work would begin.
He doesn't know anything. He added that he had
heard that no land would be acquired on the port's
north side.
2. What are the advantages and disadvantages One of the respondents thinks that the project's
of the project in the area? Who do you think could be impact will be economic development of the area,
directly affected by the project and who could be which means that the socio-economic condition of
the people of the area will also be better. He said,
indirectly affected? Whose interest do you think is
“Coming of people from other areas to work in the
involved in land port development? If any problem project will actually increase the sales of food
arises, what are your comments / suggestions for hotels, grocery stores, etc. in our area which will be
solving the problem? good for us." However, he said that expanding the
port could be started on the land lying fallow next
to the existing port. By using the amount of space
available there, the port can be increased 3/4 times
more than the current one.
Talking about the inconvenience, the respondent
said that due to lack of proper management/
monitoring, the authorities are not able to manage
the activities of the port properly. If the port is
enlarged, it will be more difficult to manage its
activities properly. The environment of their area is
already much polluted due to the stone crushing
businesses that import the stone through the port.
He added that 90% of the people in the area have
dry cough.
3. What will be the impact on the women in your Respondents said the project would not significantly
area due to the difficulties that may / may not occur impact women and children in the area. The
as a result of the project? Please provide us with a Burimari area is completely safe for women and
children to move around. However, they believe
detailed idea of how safe the environment in your
that once construction begins, environmental
area is for women and children.
pollution in the area may increase, which could
increase health risks for people of all walks of life,
not just women and children.
4. If there have been any incidents of violence / All the respondents present said that no incident of
abuse against women in the area before, please tell us violence against women has taken place in the area
about it. Please tell us in detail if there have been any before. No untoward incident has ever taken place
with a female worker.
conflicts / conflicts with women workers / women
workers groups who have come to work under any
project or participated in any work before.

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of FGD Sessions with community males (III) Responses

5. In the interest of the project a large number of They said a large portion of the workers intended to
workers that will come to your area from different work on the project would come from other areas,
districts and stay here in the interest of work. What but there would be no particular difficulty for their
area. However, if the supply of all the workers is
could be the problem due to workers coming from
brought from elsewhere, many people in the area
elsewhere for the purpose of working in the project? will be deprived of working as laborers. This may
What are your comments / suggestions for solving if cause dissatisfaction among the locals. All those
there is any problem regarding that? What percentage present at the discussion said that there are skilled
of local people in your area do you think could workers in their area who are skilled in many kinds
participate in the project as workers? Provide an idea of work like cutting soil, working on stone breaking
of the state of child labor in the area. Do you think that machine, working on stone to powder making
machine, etc.
women as workers can / will participate in various
Earlier, two workers had fallen to their deaths while
activities of the project? What is your advice in this working at the port, they said, adding that there
regard? Please let us know if there has been any were no major workers' accidents or grievances in
previous worker dissatisfaction, abuse or any kind of the port area.
untoward incident. (e.g., Gender-Based Violence,
Sexual Violence, Child Labor, Forced Labor,
Inconsistencies in Wages or other work opportunities
for women workers, etc.)

6. Do women in your area face any obstacles in Attendees said that 70% of the girls in the Burimari
getting education, engaging in income generating area are involved in education, but in the case of
activities, etc.? What is women's participation rate / boys, the rate is lower, at 30%. The reason for this,
they said, is that most of the families, driven by
opportunity in local government and other
scarcity, take their children away from education
government organizations? What kind of income-
and engage them in various income-generating
generating work do widows / divorced women usually activities. However, they said that they are very
engage in to support their families? Do they have the careful about their children's education because the
opportunity to earn enough? girls will not be able to work outside the home and
earn a living, so the girls are more involved in
education.
They know that there are 2 government primary
schools in almost every ward in the area and 1 high
school in the union. There is a college in Patgram.
Besides, there are 7/8 more private educational
institutions at pre-primary and primary level.
Widows or divorced women in the area usually work
as laborers and make a living by sewing.
7. Do men and women enjoy the wealth they In most families, women do not get the resources
deserve in the distribution of wealth and land in your they deserve. In some families, it may be seen that
area? What is the ratio of female land owner to male a woman is being paid by her brother the same
amount of property as she deserves.
land owner in this area?
8. Is there a practice of child marriage in the Respondents said that 10% of child marriages are
area? If so, what is the percentage of child marriage? prevalent in their area at present. And this practice
What are the causes of child marriage? Is there a is more common in extremely poor families.
However, the practice of exchanging dowry in
dowry system in marriage? Please give us a detailed
marriage is seen in 100% of the families in the area.
idea about all these. Dowry is a social custom in the area, they said.
9. What kind of problems do you think might In this regard, the participants said that today's land
arise if the land is acquired in the interest of the port has been built in the place where almost every
project? Explain the details of the compensation one of the communities on the north side of the port
used to live. The government has already acquired
process when an acquisition is made. Does the
their land and built the port. They have moved from

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acquisition create any inconvenient situation that place to current place. If this place is acquired
especially for women? If you have any previous again, it will be a big concern for them. This is
acquisition experience in your area, discuss it with us. because the place where they have now bought
land and settled anew was formerly a pond. They
If the acquisition is done, discuss what you think
bought land in that pond and later filled the pond to
would be better to compensate for the loss. settle. They have had to spend a lot of money for
land filling purpose.
Moreover, at present it is very difficult to get land
for purchase in the vicinity of the port area.
Because, the land owners here are able to earn five
lakh (500,000) taka a year by renting land to the
stone crushing traders. So no one wants to sell land
in this area. They said that they have been living in
the present place for a long time and all their
income-based work has been developed based on
this place. Once they have moved. Now if they have
to relocate again, their standard of living will be
severely affected. They will lose the opportunity to
earn a living.
Earlier they were verbally informed about the
acquisition of land. Then suddenly the people
appointed by the authorities came and took pictures
and videos of their place, settlement etc. The
process of compensating them for the acquisition
was not easy. The distance from their settlement to
Lalmonirhat Sadar is about 100 km. Every affected
person had to travel to Lalmonirhat Sadar about 4/5
times.
Participants also said that many well-to-do families
have become extremely poor over the years due to
the acquisition of arable land. Because those
families could not use the compensation to build a
new source of income, they were not skilled in any
kind of work other than farming. Arable land was
their economic strength.
10. Are there any indigenous / ethnic groups living It is learned from the discussion that there are no
in the project area? If so, what kind of problems might indigenous / ethnic groups living in the project area,
they have due to the project? Tell us your opinions / they are not likely to be harmed in any way.
suggestions to solve that problem.
11. To whom / where will you go to resolve any They are of the view that the port authorities
grievances / problems arising out of the project? Do themselves can solve any problem related to the
you know if there is any effective committee / project.
arrangement in resolving the complaint? If so, tell us
about the working style of that committee. (E.g.,
whether there should be a committee, who should
have this committee, what kind of work should be
done, etc.?)

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12. Do you think any special aspect should be Respondents said that while using the construction
taken into consideration while using different materials used in the project, care should be taken
resources/ materials used in the project (such as fuel, not to pollute the environment. Because the
environment of this area is already in a very bad
gas, water, sand, stone, road construction raw
condition. They further suggested that when the
material etc.)? Do you think that using the above- construction work for the development of port
mentioned resources/ materials can cause infrastructure starts, if the concerned people make
environmental pollution? If so, what are the steps that arrangements for regular sprinkling of water on the
can be taken to prevent environmental pollution? roads, then the rate of dust and sand spreading in
the air can be controlled to a great extent.
13. Will the project have any impact on roads, Participants all felt that the project would impact
environment and canals / rivers? What kind of impact roads and the environment. They said that the
current size of the highway adjacent to the port is
can it have? What are your comments / suggestions
not enough for the movement of vehicles and
for problem solving? people in the port. It is necessary to increase the size
of this highway in view of the number of vehicles
currently used in the import-export activities of the
port. Due to the severe traffic congestion for the
cargo trucks, the cargo vehicles arriving at the port
have to spend an unusual amount of time unloading
the goods and returning. Ordinary passenger autos,
vans, motorcycles, etc., often do not have space for
movement. They feared that the traffic congestion
could increase further when work on the project
begins.
They said the severe traffic congestion caused by
the lack of adequate space could make the
environment in the area even direr.
Some people think that the Dharala River beside the
port may be further damaged due to the project.
According to them, the sewerage system of the port
is inadequate, due to lack of proper sewerage
system inside the port, muddy water enters the
main road adjacent to the port and the roads are
almost always dirty. They think that this situation
may become more evident when the project starts.
14. Do you think any school / college / madrasa / They believe that the project will not harm any
cultural heritage / historical place in your area will be educational institution or any cultural or traditional
affected by the impact of this project? What is your place in the area.
advice on how to avoid or compensate if something
like this happens?
15. Do you think that the project will damage the They think no religious institution or any traditional
religious institutions and historical sites in the area installation in the area will affect the project.
adjacent to the project? What are your comments /
suggestions for solving such problems?
16. Explain in detail the state of healthcare system Discussions on healthcare in the area revealed that
in your area. (e.g., the type of health care providers in the number of quality healthcare providers is almost
the area, whether they have adequate manpower, non-existent. People of the area have to rely on
Lalmonirhat Sadar or Rangpur Sadar to get good
adequate medicine or medical equipment, what type
medical care. They said that Lalmonirhat district
of organization you usually visit, etc.?) proper is about 100 km from Burimari. It is difficult
and time consuming for people to go to Lalmonirhat
for medical treatment due to its remoteness and
unavailability of transportation. Most people
depend on trains to travel from Burimari to

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Lalmonirhat. However, the departure schedule of
the train is indefinite and the time required for the
journey is not less. If you want to go to Lalmonirhat
by road, first you have to go to Patgram, then you
have to go to Lalmonirhat by bus from there, it takes
more cost and time. Respondents said they receive
medical services mainly from local pharmacies.
However, if the illness is more, they travel to
Lalmonirhat or Rangpur as needed.
17. Give an idea about the existing educational Respondents said that although the number of
institutions in your area. (E.g., number of primary, primary schools in their area is adequate, the
secondary, higher secondary education institutions, number of secondary and higher secondary level
educational institutions is insufficient. While the
your satisfaction with the quality of education offered
standard of education at the primary level is quite
in educational institutions / infrastructural condition satisfactory, the standard of education at the
of educational institutions, scholarship system, etc.). secondary level is not so satisfactory.
18. Which media can be most effective in getting The participants said that it would be more effective
any information about the project to the masses? to conduct area-wide miking, notice and door-to-
(e.g., miking, leaflets, magazines, etc.) door meetings to reach the public with any
information about the project. They also said that it
is also help to inform the people in their respective
areas about the project through local public
representatives/ local government leaders.
19. How is the communication system in your Participants said that the condition of roads in the
area? Is there a road that breaks or disrupts travel? Is area is not good. The road from Burimari port to
there enough road? If not, where is the new road Patgram through Burimari market is almost broken.
Attempts to repair the road have not been made as
needed? What type of vehicle is used as means of
long as heavy freight vehicles are exceeded. The
communication in your area? stone breaking business is spread in a scattered or
unplanned way upto about 5/6 km from the port
area. Until then. In the month of November 2021,
three heavy trucks carrying stones overturned. Such
accidents often happen. Respondents said that a
bypass road is needed along the highway from
Burimari port, taking people directly to Patgram
road. They think that if this bypass road is built along
the railway line, it will be good for the people.
Engine driven vans, rickshaws, autorickshaws,
motorcycles, bicycles, Mahindra (large size autos),
buses and trains are used as vehicles in the area.
There is no direct train from Burimari to Dhaka.
From Burimari you have to reach Lalmonirhat first
and then catch another train for Dhaka. They said
that the importance and busyness of Burimari land
port is increasing day by day, so launching a direct
train from Burimari to Dhaka to improve the
communication system of Burimari would be very
beneficial for further improving the socio-economic
condition of the area.
20. Since there is a lot of freight trucks / vehicles The participants unanimously stated that there is no
plying in the port area, do you have any problem with security risk in the area. They said that anyone can
this? How is the safety of travel? For example, move around safely with a few lakhs of cash in hand.
There is no risk of theft or robbery.
whether there is any theft at night? If yes, in which
point or area such incidents happens mostly? What is
your advice to solve such problems?

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21. What is the type of land in the project area Double crop lands are commonly seen in the project
(mouza area of the project) (one crop / two crop)? area. The main crops grown here are Amon, Maize
What crops are usually produced on the land? What and Tobacco. At present large portion of land in
Burimari area is leased to stone traders where they
kind of crop is produced in which season / month? If a
are conducting stone crushing business.
land does not produce any crop all year round, what is
the use? When is the land vacant? Are fallow / vacant
lands used for work?
22. What kind of trees do you usually have in your Mango, Jackfruit, Litchi, Coconut, Betel nut,
area? How is the tree's price determined / at what Mahogany, Guava, Kadam, Blackberry etc. trees are
price is it bought and sold? more common in the area. The value of a tree is
usually determined based on its size.
23. What type of ownership of the trees can be Respondents said that the trees along the roadside
seen on the side of the road? How are these trees include government trees as well as privately owned
sold? Who gets the money if sold? trees. The tree owner bears the selling price of
privately owned trees.
24. If there are ponds / lakes in this area, for what They said that ponds / lakes are less visible in
purpose are they used? Is fish farmed in the ponds Burimari area. It goes without saying that there are
throughout the year? What fish is farmed? What is the almost no ponds where fish are farmed.
price of fish?
25. What is the percentage of mobile usage of According to the discussion, 30% women and 80%
women and men in this area? men in the area use mobile phones.
26. What percentage of households in this area Hundred percent of the houses in this area have
have electricity connection? Describe the current load electricity connection. But loadshedding is plentiful.
shedding situation in the area. There is an average of 8 to 14 hours of electricity in
24 hours
27. What percentage of people in this area use About 60% of the people in the area use the
internet? Who uses the Internet more and what is the Internet. Internet usage is more prevalent among
purpose of using internet? relatively young people. They use the internet for
Studying, Facebooking, YouTube, playing games,
communicating with expatriates. There are about 2-
3% expatriates in this area.
28. Name some of the NGOs operating in your NGOs like BRAC, Grameen Bank, Asha, Popi, TMSS,
area. Tell us what programs these NGOs run. Discuss Padakshep, RDRS etc. are conducting their activities
in detail how much the area's people are involved in the area. A large part of the activities of NGOs are
related to microcredit. About 90% of the people in
with the NGO and for what reason. What kind of
the area are involved in loan or savings activities of
organization is working / has worked in the past to NGO organization.
raise awareness about environmental pollution?

Figure: FGD with community male

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Summary of FGD with Burimari Community elite persons (IV)

Date Location Participants

11/12/21 Roqun’s House (Rowshon Villa), Tatipara, Burimari, Patgram, Lalmonirhat 10 (men)

Summary of FGD Sessions with community elite

Responses
persons(iv)
1. A development initiative of Burimari Land Port Almost all the respondents answered that they had
are going to start in your area under been hearing this issue in public for a few days.
Bangladesh Land Port Authority. Do you know However, they said that they had no specific idea
about this project? If you know about the regarding this issue. Some added that, they didn’t hear
project, tell us in details. (Tell us about the anything from adjacent authority. Notwithstanding, all
project's starting time and land acquisition, the respondents wanted a proper development
how did you know?) therein. When they were asked about starting time
and acquisition process, they responded that they had
no idea when the project would start. But majority of
them had expressed perturbation over land
acquisition. According to them, the land owners had to
face a huge financial loss in acquiring the land of the
present port.
2. What are the advantages and disadvantages of After giving a brief idea about the project and then
this project you think? Who do you think could asked them about its advantages and disadvantages,
be directly affected by the project and who nearly all the respondents said that it would be an
could be indirectly affected? Whose interest economic development for the people of that area. In
do you think is involved in land port this regard, Mr. Roknuzzaman Rokon, a stone trader,
development? What are your suggestions for said, “if the port infrastructure develops, our stone
problem solving in this project? imports will definitely increase, which will create more
jobs opportunity in my organization that will be good
for all. Based on his words, Mr. Abdus Salam said, “The
Indian driver-helpers who carry these stones have to
stay and eat here until unload the goods. As a result,
Restaurants, hotels, tea stalls owner will definitely be
benefited." On the question of loss, they have
expressed concern about getting a fair price against
land acquisition. Majority said that if this port is
developed, it will be beneficial for all. Regarding the
possible problems, the Imam of Zero Point Mosque,
Mr. Saeed Ahmed said, “Road accidents are very often
here, each and every day we heard about road
accident. If the authority won’t take proper road
management plans, there is a good chance to increase
road accidents here.” Soon after, Mr. Ramzan Ali, a
primary school teacher, said, "There may be obstacles
in such work, but it will be easy in an orderly fashion if
there is a proper plan."
3. What will be the impact on the women in your Majority said, they did not think the project would
area due to the difficulties that may / may not have a special impact on women and children.
occur as a result of the project? Please provide However, Hafeez Noor Mohammad said that children
us with a detailed idea of how safe the will have a challenge going to school or college.
environment in your area for women and Agreeing with his statement, Mr. Rokon said that in the
children? case of random movement of trucks, cars etc. one has
to sit in traffic jams for a long time and takes breaths
with dust in road which will create various diseases. All
the participants on the question of safety and security
responded that this area was very safe for movement.
Shahjahan Mia said, “There is no such thing like theft

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Responses
persons(iv)
or snatching in this area. He can't even remember that
such a thing happened. Even walking on the street
carrying with 50 lakh, 1 crore taka will not be a
problem here”. Altaf Hossain, ward president of rolling
party and businessman, said that there were no
incidents such theft, looting or harassment of women
in their area. He said that their reputation for security
and safety was appreciated by all who step in to this
port.
4. If there have been any incidents of violence / In reply, they said that they have not heard of any
abuse against women in the area before, incidents of violence against women in that area. In
please tell us about it. Please tell us in detail if this regard, Mr. Altaf Hossain said that people always
there have been any conflicts between women come to him with various issues being a political
workers and women workers groups who have leader. He added that he had to keep his eyes to
come to work under any project or everyone in that area. His ears could not be avoided if
participated in any work before in your area. there was any incident of violence against women
happened. None of them can remember whether
women workers have worked before in Land port
project, and even if someone worked, they didn't think
there's a such problem.
5. In this project, there are many workers who When they were asked about the problems of the
will come to your area from different districts workers from outside, Mr. Shahjahan Mia said that
and stay here. What could be the problem due there was no problem if project authority would fair
to workers coming from elsewhere in the wages. Before finishing his speech, Mr. Saeed Ahmed
project? What are your statements / said that the workers' accommodation should be fair.
suggestions for solving this problem? What He added that lack of adequate toilets and bathrooms
percentage of local people in your area do you was a major problem. He further added that if those
think could participate in the project as were adequate and fair wages were paid, they would
workers? Provide an idea of the state of child have no problem. All the participants agreed to this
labor in the area. Do you think that women statement. Regarding the recruitment of workers in
workers can / will participate in various the project, some of them said in a depressing voice
activities of the project? What is your advice in that no workers were taken from the area for the
this regard? In case of any kind of worker construction of the present land port. So in the new
dissatisfaction, torture or any kind of project, everyone in this area should be given a job.
untoward incident, please let us know. “Especially those who will lose their land or business
(Gender based violence, sexual violence, child so that they can be involved in this project. Child labor
labor, forced labor, inconsistencies in wages or is not very common but it cannot be said that there is
other job opportunities for female workers, no such thing at all. Those whose financial condition is
etc.) miserable, they have to work to feed their family,” said
Mr. Sajjad. Almost all the respondents confessed that
there is inequality exists between men and women but
some of them pointed out the rationale of this
inequality. According to them, men are physically
more capable than women in manual labor that is why
wage inequality exists
6. Do women in your area face any obstacles in Some of them said that women were more educated
getting education, engaging in income than men in that area in response to this question.
generating activities, etc.? What is women's Abdus Salam said that his daughter-in-law was an B.A.
participation rate / opportunity in local On the other hand, his son could not cross the school
government and other government boundary. He added that there were many examples
organizations? What kind of income- in regards. Another said that women had less
generating work do widows / divorced women opportunity to earn because there was more physical
usually engage in to support their families? Do work in that area as a result women's participation was
they have the opportunity to earn enough? less in physical lobor. “Some women have been doing
well by sewing clothes and some others are conducting
hotel business for many years,” Shahjahan Mia Said.

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Responses
persons(iv)

7. Do men and women get the wealth they Most of the respondents on the issue of land
deserve in the distribution of wealth and land distribution said that the distribution of land in their
in your area? What is the ratio of female land area was done in accordance to Islamic and state law.
owners to male land owners in this area? No one could say much about actual ratio of land
ownership between man and women. However, one
of the attendees said that if a man was 80, that a
woman would be 20.
8. Is there any practice of child marriage in the In response to this question, Mr. Enamul said, “though
area? If so, what is the percentage? What are recently child marriage is less, it was more a few years
the causes of child marriage? Is there any ago. However, if you still search, you will find the news
dowry system in marriage? Please give us a of child marriage.” When they were asked about the
detailed idea about all these. reasons for this child marriage, Mr. Ramzan Ali said,
“there may be various reasons, but the family's
financial condition is considered the main reason for
child marriage. Almost everyone agreed with him on
this point. In the question of dowry system, majority of
them said that dowry was very often in that area.
9. What kind of problems do you think might They think that the biggest problem in acquiring land
arise if the project acquired the land? Explain for the project is not getting a fair price. Some said that
in details of the compensation process when due to irregularities in the distribution of land price,
an acquisition is made. Does the acquisition market price and difference in mouza price, land
create any inconvenient situation especially owners are likely to suffer huge financial losses. When
for women? they were asked about past experience regarding land
acquisition for present land port, they said, the owners
of the lands acquired during the construction of the
present port had to pay bribes to various offices to get
compensation. They added that they had to travel
daily to get the money they deserved. Many of them
complained that they were paid far less than the
market value. When they were asked how the
acquisition could be compensated, Abdus Salam said,
those whose land or infrastructure would be damaged
would have to be properly compensated and their
losses could be compensated if the project could
provide them with employment. With his words, Altaf
Hossain said, “homestead land is scarce.”
10. Are there any tribes / ethnic groups in the In response to this question, they said that there was
project area? If so, what kind of problems no ethnic group living in their area.
might those tribes have because of the
project? Tell us your opinions / suggestions to
solve that problem.
11. To whom / where will you go to resolve any when they were asked who they would go to if there
problems arising out of the project? Do you was any problem related to the project, Mr. Sajjad
know if there is any effective committee / replied, "We have to talk openly to the leaders
arrangement in resolving the complaint? If so, concerned about the problem. This will solve most of
tell us about the working style of that the problems. If the situation will be more
committee. (Whether there should be a complicated, the resolving committee will find a
committee. Who should this committee be solution by contacting the port authorities. However,
with, what kind of work should be done, etc.) there is no separate conflict resolving committee.” All
of the participants agreed that if there is such
committee, the workers’ rights will be protected and
the working environment for all concerned will
appeasement. When they were asked who would be
included in the committee, Altaf Hossain said he

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Responses
persons(iv)
believed it would be better to form a committee
comprising labor leaders, public representatives,
government officials, low enforces agencies, BGB,
political leaders and dignitaries from all walks of life.
All the participants agreed to this statement.
12. Do you think any special aspect should be In response to this question, Altaf Hossain said that if
taken into consideration while using different the resources were not used properly in this project,
resources used in the project (such as fuel, gas, environmental pollution and tremendous suffering of
water, sand, stone, road construction raw the people of the area will increase a lot. He added that
material etc.)? Can the use of the mentioned if these materials will leave under open sky or bare
issues cause environmental pollution? If so, land, there is a possibility of obstruction of
what are the actions that can be taken to pedestrians, which will be a suffering in regards to
reduce such pollution? public movement. On whether there will be
environmental pollution, Hafeez Noor Mohammad
said that if cement, sand, rods, etc., cannot be
covered, that will pollute the environment. He added
that the environment that area had been polluted due
to lack of proper management of stone traders at
present. He further said that proper waste
management was required in that project and
authority should build a separate plant for waste
management. Everyone agreed to his statement.
13. Will the project have any impact on roads, In response to this question, Mr. Rokon said that that
environment and canals/rivers? If so, what was normal for a new project to affect the
kind of impact? What are your comments / environment during construction negatively. He
suggestions in this regard? added, however, proper management must be taken
to minimize it. He further added that other
construction materials, including cement and sand,
would be washed away by rainwater in rivers or
reservoirs, harming the environment and animals.
Therefore, to prevent such problems, an adequate
shed should be built to store construction materials so
that they do not harm the environment under any
circumstances.
14. Do you think any school / college / madrasa / They said, “the project will not directly damage any
cultural heritage / historical place in your area school-college-madrasa or traditional cultural-
will be affected by this project? If this happens historical site, but they may cause some indirect
then what is your advice to avoid or damage.
compensate for the loss?
15. Do you think that any religious institutions, They said, there were no mosques, madrasas or other
historical and traditional structures will be important structures in the project area.
damaged due to the project? What are your
statements/suggestions for solving this
problem?
16. Describe the state of healthcare in your area. When they were asked about the state of healthcare,
(What are the names of the health care Ramzan Ali, school teacher, “people in the area are
providers in the area, whether they have deprived of proper healthcare. The nearest ham quack
adequate man power, adequate medicine or is 2 km away. So, when anyone get sick, he must get
medical equipment. How often do you visit into a lot of trouble. Saidur Rahman said, “No
there?) specialized doctor provide service in this area.” “If
there is a minor problem, we take medicine from the
dispensary. If the situation seems a bit complicated,
we plan to move Rangpur Medical College for better
services.” According to all the respondents, the quality
of services in the Upazila Health Complex is very low.
Even the Lalmonirhat Sadar Hospital does not provide

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Responses
persons(iv)
good treatment. “If there is a hospital, that will be a
blessing for us,” they said.
17. Give an idea about the existing educational When they were a asked about the number of
institutions in your area. (Number of primary, educational institutions, Almost all the respondents
secondary, higher secondary education said, they could not say exact numbers. However,
institutions, do you satisfy with the quality of Hafeez Noor Mohammad said, “the primary school in
education offered in educational institutions / Burimari Union is approximately 15 and only 1
infrastructural condition of educational secondary school exist in this area. There is only one
institutions, scholarship system etc.). college which is 6 km away. There is 7/8 Noorani
Madrasha and one government Alim Madrasa in this
union.”
18. Which media can be most effective in They think miking is a good way to share any
conveying any information about the project? information. Altaf Hossain said, “Neither magazines
(Miking, leaflets, magazines, etc.) nor leaflets can be understood and read by ordinary
workers. So, we believe that miking or in person
publicity is an effective medium.”
19. How is the communication system in your When they were asked about the communication
area? Is there any road that breaks or disrupts system, everyone present highlighted that the
travel? Is there enough road? If not, what is condition of the roads in this area is the fragile.
your idea about new road in this area? What “Especially the condition of the road on the south side
type of vehicle is used as a means of of the land port is very bad. Excess mud in rainy season
communication in your area? and excessive dust in winter is significant problem in
this area,” Said Mr. Rokon. Enamul Haque said, “no
repairing action has been done on this road for at least
15 years. Local government representatives of the
area had promised more than once, but it has not been
implemented even today. About one-third of the
respondents thought that the only way to get through
the road is to repair it. Others believe that the
construction of some new roads, such as the
construction of a bypass road from Burimari railway
station to the land port, would greatly benefit the
people of the area. They added this road would be
constructed; local people of this area would be
relieved from the present situation.
20. Since the port area has a lot of cargo trucks / Majority said, “road accidents are very often in this
vehicles, do you have any problem with it? area as many vehicles move around within these
How is the safety of travel? For example, narrow roads. However, theft and snatching do not
whether there is any theft at night? Which happen in this area. This area has a reputation in this
place is considered? What is your advice to regard.” All the participants unanimously agreed on
solve such problems? this point.
21. What is the type of the land in the project area In reply they said, “The lands in the project area are
(mouza area of the project) (one crop / two generally cultivated with aman paddy, tobacco and
crop)? Which crops are usually produced on corn. In addition, many landowners here earn money
this land? What kind of crop is produced in by renting land to stone traders annually.
which season / month? When is the land
vacant? Are fallow / vacant lands used for
work?
22. What kind of trees do you usually have in your Some said, “We have no such specific tress but
area? How is the price of these tree eucalyptus, Mehguni, Mango, Bamboo, Banana trees
determined / at what price is it bought and etc. are plentiful in this area. Mr. Enamul said, “there
sold? are no special rules for pricing trees. prices are
determined by eye sight.” According to Altaf Hossain,
“there are other trees and more or less.” When asked
about the price, Mr. Rokon said that large trees are

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Summary of FGD Sessions with community elite

Responses
persons(iv)
usually sold for TK 20,000-100,000, medium trees are
also sold for TK 5000-20000.
23. What is the type of ownership of this tree that In response to this question, Ramzan Ali said that most
is on the side of this area? How are these trees of the trees along the road are owned by government.
sold? Who gets the money after selling? And if it is sold, the money is deposited in the
government treasury.”
24. If there is a pond / reservoir in this area, what In reply, Mr. Ramzan Ali said, “Fish farming is very rare
is it used for? Is this pond / reservoir in this area.” Some of the respondents said that most
cultivating all the year? what type of fish is of the water bodies remain uncultivated. “However,
farmed? What is the price of fish? Rui, Katla, Tilapia and other carp fishes are the most
cultivated fish in this area,” Mr. Altaf said. Mr Rokon
said that fish prices were much higher compared to
other areas. In the rainy season, it is a little less, but it
is much more at other times. Further, he gave an
example that 1 kg size rui fish is available here for 250
Taka, sold elsewhere for 200 Taka.
25. What is the percentage of mobile usage of When they were asked about the percentage of men
women and men in this area? and women using mobile phones, some of them said,
“approximately 40 percent of women use mobile
phones, while men use about 60 percent of mobile
phones
26. What percentage of households in this area “All the houses in this area have electricity connection
have electricity connection? Is there any load but there is a lot of load shedding,” they said. Mr.
shedding in your area? If occur, tell us in brief. Ramzan Ali said “at present there is at least 7/8 hours
of load shedding in a day, which has put us in a lot of
trouble. Students can’t study well due to this
problem.” Everyone presents agreed with him.
27. What percentage of people in this area use When they were asked about internet usage, one of
internet? Who uses the Internet more and them said, “those who have smart phones in this area
what they use internet for? use internet, whether they are men or women.” Mr.
Abdus Salam Said, “Facebook and YouTube are the
most browsing sites here and recently I see some
young use the internet to play online games. Mr.
Sazzad said, “however, Imo, WhatsApp are widely
used for talking.
28. Name some of the NGOs operating in your In reply to this question, one said, “there are many
area. Tell us what programs these NGOs run? micro-credit NGOs in this area namely Proshika,
Tell us in detail how many people in this area Grameen, Asha, RDRS etc. Apart from this, they do not
are involved with the NGOs. Is there any remember that any NGO has come for social or
organization who is working / has done in the environmental issue.
past to raise awareness about environmental
pollution?

Figure: FGD with Community elite person

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of FGD with Burimari Truck labor association representative (V)

Date Location Participants

11/12/21 Burimari Bazar, Burimari, Patgram, Lalmonirhat 7 (men)

Summary of FGD Sessions with Truck labor

Responses
association representative (v)
1. Development activities of Burimari Land Port When asked about the acquisition and the project, almost
are going to start in your area under Bangladesh everyone present there said that for some time they are
Land Port Authority. Tell us the details of what hearing from the people, the surrounding area which is
you know about this project. (About the starting adjacent to the land port will be acquired. They do not
time of the project, land acquisition, how you know anything else. When asked if they had any objections
know, please tell in detail.) to the project, all respondents present there said that they
all favor development. And they believe that if this project
executes there, it will make the life of the people in this
area more beautiful. They said they have no objection in
the interest of development.
2. Is your income or livelihood involved in any way When asked to know about this, the respondents said that
with Burimari land port? If so, give us a detailed most of the people in this area are involved in land port
idea how it happend related work. Their livelihood is closely linked with the
transportation of imported stones and imported goods
from different countries and post-processing of
transportation. There are at least 1500 stone breaking
machines in operation in Burimari. And the population of
this area is about 25000, of which a large part is involved
with stone related activities. One of the participants said
that he has been involved in stone transportation for the
last four years and his family is doing very well with the
income earned from this stone transport. He added that
most of the people in the area are involved in stone related
business. When it is asked if their livelihoods would be
affected by the project, some participants who present
there said that their income will increase significantly if the
project is implemented.
3. What are the occupations usually the worker In response to this question, a respondent who present
involved with in your area? Are there any there said that about 90% of the people in this area are
specific types of work / occupation for men and directly and indirectly involved with stone related work.
women working as labor? Another participant said that apart from the locals in the
area, government and private officials-employees who
have been posted in the area are not directly involved in
the stone business only. Except this, almost all the local
people are involved with stone business, stone supply,
stone breaking factory, etc. Another respondent said that
" usually women in the area don't do much work outside
of the house, those who are educated, if they work in
office work, in that case they work easily".
4. Are there any organizations or unions in your One of the respondents said that there are several trade
area that work to protect the interests or rights unions in our area, including labor unions and truck unions,
of workers? If so, what is its organizational working in the interest of the workers. If someone is sick
structure? Explain in detail, in what matters or in danger then assistance provided to them. When one
does this organization work? of our workers affected by Silicosis disease a few years ago,
an NGO called RDRS bears all the medicine costs. In
addition, trade unions are constantly look after for
problems for their workers.

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Summary of FGD Sessions with Truck labor

Responses
association representative (v)
5. Do you know what labor law is? If you know, When asked about the labor law, the participants who
please tell present there, could not give a clear idea about it. The
truck owners' association president said he had heard
about the labor law but had no idea why and how it was
enforced. Even till today no person or organization has told
us anything about this. He said that the workers in this area
have to work for their own self.
6. In the interest of the project, a large section of Several people present said that our area is very peaceful
workers will come to your area from different in response to this question. It can be said that there is no
districts and stay here for the sake of work. fighting, stealing, snatching or any kind of adulteration.
What problems could be happened due to They do not know whether there is any problem raised in
workers coming from elsewhere in the project? the time of constructing land port, but no worker was
What are your comments / suggestions for appointed from the area. Later on, the people of the area
expressed their dissatisfaction. Another respondent said
solving this problem? What percentage of local
that they do not think there will be any problem if the
people in your area do you think could
project which is going to be started now, gives the
participate in the project as workers? Provide opportunity with priority to the workers of this area to
an idea about the situation of child labor in the work. This will benefit the people of this area financially.
area. Do you think that women as workers can When asked about child labor, one of the respondents said
/ will participate in various activities of the that the children work in some stone breaking mills due to
project? What is your advice in this regard? the family's financial strain, whether the child or the old
Please let us know if there has been any man, they have to work. There is no problem if women
previous worker dissatisfaction, abuse or any workers are given jobs in low-risk jobs, as women have
kind of unwanted incident. (Gender-based, some problems in physically risky jobs. They believe that
Violence, Sexual Violence, Child Labor, Forced socio-economic development will be possible if proper
Labor, Inequality in Wages or Other Job action plans for women is formulated with the project and
involve the local women.
Opportunities for Women Workers, etc.)
7. Is there a possibility of any kind of conflict Workers from outside do not seem to have any problem in
between local workers and workers from other this area. The people of this area are very peaceful.
areas? If so, what kind of conflicts are there? Another respondent said that people from other areas are
Whether any policy is followed in conflict doing business in this area without any hindrance, they are
resolution? not having any problem. When asked for suggestions on
how to solve any problem arise, they said that if a
committee is formed with the concurrence of the
administration and the Labor Union leaders, it will be
possible to immediately solve any problem in the project.
8. What kind of conditions / contracts do you think In response to this question, almost all the respondents
should be remain in the time of hiring workers? who were present there said that there should be a
If so, what are the terms / contracts? Let us specific policy regarding recruitment of workers. There
know about your views on whether the terms / should be clear guidelines on how much a worker will be
contracts of the workers hired for the project paid, how many hours he will work, what kind of
are being implemented. (Interviewer: compensation will be given in case of any accident. This
will protect the interests of the workers as well as improve
Recruitment duration, working hours, salary,
the quality of life of the workers who are working on this
leave, other benefits etc.)
project. At present the average wage of the workers in this
area is 300 to 350 taka. This is very low in the current
market. These issues must be considered in hiring all the
workers involved in the project. Then the workers will be
mentally strong and the project will move forward to
execution smoothly.
9. What kind of measures do you think are needed In response to this question, all the respondents who were
in the workplace to ensure the safety of the present said that safety must be given priority in the work
workers engaged in the project? (Interviewer: of this project. Workers must be provided with adequate
Helmet use, shoe use, machinery use, etc.) amounts of safety equipment such as helmets, gloves,
goggles and other safety equipment. Another respondent

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Summary of FGD Sessions with Truck labor

Responses
association representative (v)
said that the risk allowance and compensation should be
kept in mind in case of an accident.
10. Please tell us in detail if there had been any Some of the respondents who are present there said they
clashes/ conflicts happened before with women do not think any of the women workers who had come to
workers / women workers groups who have work on the project has faced any trouble. However, no
come to work under any project or participated female labor or female worker will certainly face any kind
in any work. of problem by the people of the area. Because eve-teasing,
violence against women or women harassment are not
common in their area.
11. To whom / where will the workers go to When asked about the grievance redressal committee, all
resolve any grievances / problems arising the respondent who was present there agreed that the
among the workers involved in the project? committee is needed. The proper working environment of
What is your opinion on an effective committee the project will be maintained if this committee works for
/ action in resolving the grievances and how this the safety of the labors and project workers and their
committee will work, please give various problems solutions
recommendation in regard of this. (Whether
there should be a committee, who should this
committee be with, what type of work will be
there, etc.)
12. Do you think there is a need to pay Leaving construction materials scattered during the work
special attention to the use of different of the project causes huge damage to the environment.
resources (such as fuel, gas, water, sand, stone, Environmental pollution will be much less if these
raw materials for road construction, etc.) used construction materials can be kept in a specific place
in the project? Could the use of the mentioned making by a shed. They think that the project should have
things cause environmental pollution? If so, good waste management to avoid environmental
pollution. Waste should be dumped somewhere far
what are the measures that can be taken to
outside the project area so that the environment of the
prevent pollution?
area is not polluted. The respondents said that many
trucks will come from outside during the project, which
will make it difficult to move on the road. To solve this
problem, regular watering should be done at least twice in
the morning and afternoon to reduce dust. This will reduce
environmental pollution.
13. Describe the state of healthcare in your area. When asked about health services, the respondents who
(What are the names of the health care were present there said that the quality of health services
providers in the area, whether they have in this area is very poor. If someone is sick, he first buys
adequate manpower, adequate medicine or medicine from the pharmacy. When the situation is out of
medical equipment, what type of organization control, they are taken to Rangpur Medical College. Asked
do you usually visit to get services, etc.) why they were not taken to the Upazila Health Complex or
Sadar Hospital, some of the respondents who were
present said that the facilities at these hospitals were not
adequate and even patients are referred to Rangpur
Medical College when they saw their condition was a bit
worse. So, if the patient seems a little bad condition, the
patient taken directly to Rangpur Medical College.
14. Since the port area has a lot of cargo trucks / In response to this question, the respondents who were
vehicles, do you have any problem with it? How present said that theft and robbery do not happen in this
is the safety of traveling? For example, whether area but road accidents are always happening. The roads
there is any theft at night? If so, in what place it are very narrow and that’s why freight trucks are getting
occurs the most? What is your advice to solve into this accident. According to this, the number of
such problems? vehicles move there is roads are not adequate, so the
accident happened here. A respondent said that a truck
overturned in front of the school a few days ago. Luckily,
some students were present there but they were not
harmed. The roads in the area is very dusty and become

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Summary of FGD Sessions with Truck labor

Responses
association representative (v)
muddy on rainy days where some people jokingly plant
paddy plants and spread them through social media.
Another person said that the people of the area would be
relieved of their misery if the road could be widened with
the implementation of this project.
15. What is the type of land in the project area It is learned in the discussion that tobacco, maize and
(mouza area of the project) (one crop / two paddy are predominant in land cultivation in the area
crop)? What crops are usually produced on the which is adjacent to the project. Farmers make more profit
land? What kind of crop is produced in which by cultivating tobacco in the land. The lands here are
season / month? What is the use of this land if usually planted twice a year. However, there are some
lands where multiple times crops are cultivated. Many
it is not produced all year round? When is the
landowners are renting land as a stone trading field
land uncultivated? What is the use of
instead of cultivating crops on the land. It makes a lucrative
uncultivated/vacant lands?
income every year by making annual contracts with
traders. The amount of land which is lying fallow in the
area is very low.

Figure: FGD with Truck labor association representative

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 BBIN Regional Transport and Trade Facilitation Program - Bangladesh Phase 1

Summary of FGD with Burimari Community Female (VI)

Date Location Participants

11/12/21 Burimari zero-point, North side of the wall. Burimari, Patgram, Lalmonirhat 13 (Women)

Summary of FGD Sessions with Community Female

Responses
(VI)
1. Development activities of Burimari Land Port are The respondents of the focus group discussion said
going to start in your area under Bangladesh Land that they had not heard anything about the project
Port Authority. What do you know about this from anyone.
project? If you know about the project, please tell us
the in details. (Tell us in detail about the project's
start time, the land acquisition, and how you know.)
2. What do you think that what are/will the Asked about the advantages and disadvantages of the
advantages and disadvantages of the project in the project, the women participants said that if the size of
area? Who do you think could be directly affected by the port is increased as part of the project work, those
the project and who could be indirectly affected? people living on the north side of the port will suffer.
Whose interest do you think is involved in land port They will lose their land. Another respondent said that
development? What are your comments / the business and work of the people living here are all
suggestions for problem solving in this case? centered on this place. If the government acquires this
community's land to increase the size of the port, they
will be in trouble. Moreover, land is not readily
available for purchase in this area, so they will be in
danger if this land is acquired. Besides, no one has said
anything about the advantages of the project.
3. What will be the impact on the women in your The respondents feel that the project will not have any
area due to the difficulties or problems that may or special impact on women or children or cause them
may not occur as a result of this project? Please any inconvenience. However, one respondent said
provide us with a detailed idea of how safe the that there is already heavy traffic in the area, which
environment in your area is for the movement of makes it difficult for common people or school-going
women and children. children to travel to school easily. If the project starts
and the traffic is not resolved in a planned way, the
movement of people will be completely disrupted.
4. Please tell us if there have been any incidents of The respondents said there had never been any
violence or abuse against women in the area before. incident of violence or torture against women in the
Please tell us in detail if there have been any conflicts area. They said they did not know if the women of the
or conflicts with women workers or women workers area had worked as laborers in any project before.
groups who have come to work under any project or However, the men work as laborers in many different
participated in any work before in this area. sectors of the area.

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Summary of FGD Sessions with Community Female

Responses
(VI)
5. There is a large portion of workers who will come According to the respondents, it is better to employ
to your area from different districts and stay here in locals as laborers in the project. They said that people
the interest of work in the project. What could be the from other areas are usually hired as laborers for any
problem due to workers coming from elsewhere in kind of work. But the people of the area are not given
the project? What are your comments or suggestions job opportunities more. Earlier, when land was
for solving this problem? What percentage of local acquired for the port, the families were informed that
people in your area do you think could participate in at least one member of each of the families whose land
the project as workers? Provide an idea of the state was being acquired would be involved in some form of
of child labor in the area. Do you think that women work at the port. But later the families were not given
as workers can or will participate in various activities any scope for works. According to the respondents,
of the project? What is your advice in this regard? persons will be interested to do work as their capability
Please let us know, is there any kind of worker of work.
dissatisfaction, torture or any kind of unwanted
incident are happened. (Gender based violence,
sexual violence, child labor, forced labor, inequality If there is any conflict or dissatisfaction among the
in wages or other employment opportunities for workers involved in the project, only the people
female workers, etc.) associated with the port can resolve it. No major
clashes have ever taken place in the port area.

6. Do women in your area face any obstacles in The respondents said that girls are far ahead of boys in
getting education, engaging in income generating getting education in their area. Educated women are
activities, etc.? What is the participation rate or being engaged with various jobs. And there are no
opportunity of women in local government and other barriers for women in this area to get education or
government organizations? What kind of income- engage in income generating activities. Rather, the
generating work do widows or divorced women family tries to give them enough support in getting
usually engage in to support their families? Do they education. There are women members in this area
have the opportunity to earn enough? who are quite active in politics. Widows and divorced
women in the area work as stonemasons, cooks in
various hotels, and agricultural laborers on other
people's agricultural lands to support their families.
There is no social barrier for women to be involved in
any kind of income generating activities.
7. Do men and women enjoy the resources they Regarding the distribution of wealth or land ownership
deserve in the distribution of wealth and land in your among women, the female respondents said that most
area? What is the ratio of female landowners to male of the women in the area are not given their due or
landowners in this area? right number of assets. In most cases the men of the
family enjoy the wealth or asset, in very few cases the
woman is given a share or equal amount of her due
wealth. They said men in this area own about 90
percent of the land.
8. Is there any practice of child marriage in the area? The respondents said that child marriage is almost
If so, what is the percentage? What are the causes of non-existent in the area at present. But on the
child marriage? Is there a dowry system in marriage? question of dowry, they said, there is no marriage in
Please give us a detailed idea about all these. What is their area without dowry. Dowry is exchanged at the
the ratio of female landowners to male landowners time of marriage in almost all the families and there is
in this area? no such difference in the exchange of dowry between
rich family or relatively poor family. Dowry is
exchanged according to the ability of each family in
this area.
9. What kind of problems do you think might arise if In the context of land acquisition in the interest of the
land is acquired in the interest of the project? Please project, the respondents actually objected to the
explain the details of the compensation process acquisition of privately owned land. They said, "We
when an acquisition is made. Does the acquisition have been evicted from our land once before. Our land
create any inconvenient situation especially for was acquired in the present land port construction and
women? If you have any previous acquisition a port was established there. We left that place

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Summary of FGD Sessions with Community Female

Responses
(VI)
experience in your area, discuss it with us. If the because of the acquisition and moved to where we are
acquisition is done, discuss what you think would be now. So where would we go if we were evicted again?
better to compensate for the loss. This will be a big problem for us”. They suggested that
the port authorities could operate the port on the khas
land on the east side of the port. In that case, they have
no problem and they will cooperate with the port
authorities. They also said that the government or the
port authorities may think that the people will have no
problem acquiring land if they get compensation. But
even if they get compensation in reality, they will
suffer because it is very difficult to find suitable land to
buy after getting the compensation. At present, the
amount of land which is sold in Burimari area is very
low. Because landowners do not want to sell land. If
they are evicted from their present place, they may
have to leave this area and move to some other village
far away or even to some other upazila. They think it
will have a negative effect on their lives. The amount
of compensation previously paid for their land
acquisition was not adequate for them. In addition,
they had to face various types of harassment in order
to receive compensation. So, they are requesting to
the port authorities to modernize the port on
government fallow khas land without acquiring
privately owned land.
10. Are there any tribes or ethnic groups in the project All respondents said that no tribe and small ethnic
area? If so, what kind of problems might those tribes groups live in this area.
have because of the project? Tell us your opinions or
suggestions to solve that problem.
11. To whom or where will you go to resolve any kind The respondents think that they have to face a
of complaint or problem arising out of the project? problem in this situation. If such a situation arises, they
Do you know if there is any effective committee or will try to solve the problem by contacting the people
arrangement in resolving the complaint? If so, tell us in charge. Almost everyone present in this discussion
about the working style of that committee. (Whether thinks that it is necessary to have such a committee
there should be a committee, who should be included where the functioning of the committee will increase
in the committee, what kind of work should be done, if there are representatives at all levels.
etc.)?
12. Do you think any special aspect should be taken In this question, they said that the raw materials, fuel
into consideration while using different resources and other utensils used in the project should be kept
(such as fuel, gas, water, sand, stone, raw materials in a specific place. One of the respondents said that it
of road construction etc.) used in the project? Can the is common to see in these works that rods, sand, etc.
use of the mentioned issues cause environmental construction materials are left on the road during the
pollution? If so, what are the measures that can be work, which creates widespread problems in
taken to prevent pollution? movement. They said that if the daily wastage is
removed every day, there will be no harm to the
environment.
13. Will the project have any impact on roads, The respondents think that a lot of freight cars or
environment and canals or rivers? If so, what kind? trucks will come during the project which will make the
What are your comments or suggestions for problem roads in this area more destroyed. The roads in this
solving? area are very narrow, leading to frequent road
accidents. They think that if the road is not widened
before the project starts, the number of road accidents
and traffic congestion will increase. The idea of the
respondents is that if the project does not have proper
waste management, the environment of the area will
be severely damaged. So, before starting work on the

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Summary of FGD Sessions with Community Female

Responses
(VI)
project, they think that work should be started keeping
in mind the issue of proper waste management.
14. Do you think that any school or college or madrasa The respondents said that there is no school or college
or cultural heritage or historical place in your area or madrasha or cultural organization in this area.
will be affected by the impact of this project? If this
happens, what is your advice to avoid or compensate
for the loss?
15. Do you think that the local area's religious The respondents said no religious institutions or
institutions, historical and traditional structures will historical sites would be damaged in the project area.
be hampered or damaged by the project? What are
your comments or suggestions for problem solving?

16. Please describe in detail about the state of When asked about health services, everyone present
healthcare in your area. (What are the names of the in the discussion gave a picture of the health system in
health care providers in the area, whether they have the area. If a patient's condition is critical or if he is a
adequate manpower, adequate medicine or medical dying patient, the people of the area take him directly
equipment, what level of organization do you usually to Rangpur Medical without taking him to Upazila
visit, etc.) Health Complex or Lalmonirhat Sadar Hospital. Asked
about the reasons for not going to Patgram Upazila
Health Complex or Lalmonirhat Sadar Hospital, they
said that people do not get adequate health care in
these hospitals due to poor quality of health services,
inadequate manpower and lack of medical equipment.
Even the local doctors who serve locally, their skills are
comparatively less, so they take any dying patient
directly to Rangpur or Dhaka without taking him in the
local area hospitals.
17. Give an idea about the existing educational The respondents said there are enough primary
institutions in your area. (Number of primary, education institutions in the area. There are 10/15
secondary, higher secondary education institutions / primary schools in the area, but only one secondary
your satisfaction with the quality of education school. On the other hand, there is only one college
offered in educational institutions or infrastructural which is situated about 7/8 km away from here. They
condition of educational institutions, scholarship said that the number of schools going girls is higher
system etc.) than the number of boys in the area because boys have
to take care of their families at an early age, which is
why the dropout rate is much higher among the boys.
18. Please tell us which way may be most effective for The respondents said that miking can be the most
conveying any information about the project. effective way to convey any information about a
(Miking, leaflets, magazines, etc.) project because most people are day laborers. So, they
think miking can be an important and effective way to
inform about the project.
19. How is the communication system in your area? Is In response to this question, every respondent present
there a road that breaks or disrupts travel? Is there there said that roads in the area are bad. No work has
enough road? If not, where the new road should be been done in the last 10/15 years to repair the road on
constructed for you which will be helpful for you? the south side of the land port. In addition, the road
What type of vehicle is used as a means of from Burimari Bazar to Burimari Zero Point is less wide
communication in your area? than the amount of traffic on the main highway which
leads to incidents like road accidents. Traffic jams are
a daily occurrence in this area. Small or big road
accidents are often heard by them. Being a port area,
a lot of trucks or heavy vehicles enter the Burimari
area, so they have to wait or sit in traffic jams for a long
time. They think that if an alternative road can be built,
it will be a blessing for the movement of the common
people. They use engine driven vans or autorickshaws
to get anywhere in the less distance. They use train or

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Summary of FGD Sessions with Community Female

Responses
(VI)
bus to get to some remote places like Patgram or
Lalmonirhat. However, auto is easily available to go to
the upazila level.
20. Since a lot of cargo trucks are run in the port area, In response to this question, the respondents said that
do you have any problem with it? How is the safety it is very difficult for them to move on the roads due to
of travel? For example, whether there is any theft at the movement of a lot of trucks. They have to wait for
night? If the theft is more in any place? What is your a long on the road. They mentioned about the
advice to solve such kind of problems? problems of road accidents, lots of dust etc. However,
it can be said that the incident of theft and snatching
did not happen at all.

21. What is the type of land in the project area (mouza The female respondents said that cultivation of crops
area of the project) (one crop or two crop)? What is decreasing in this area. Only tobacco and corn are
crops are usually produced on the land? What kind of more cultivated in the lands which are still cultivated.
crop is produced in which season or month? What is
the use of this land if it is not produced all year
round? When the land is vacant? Are fallow or vacant
lands used for work?
22. What kind of trees do you usually have in your The respondents said that the number of mango and
area? How is the price of the tree determined or at betelnut trees are more in this area. Eucalyptus and
what price trees are bought and sold? mahogany trees are the most common among the
woody trees. Apart from this, coconut, jackfruit,
mango, neem etc. trees are also seen more or less in
this area.
23. What is the type of ownership of the roadside The respondents said they had no idea about how the
trees? How these trees are sold? Who gets the money roadside trees are sold.
of selling trees?
24. If there is a pond or lake in this area, what is the The respondents said that fishes are farmed or
usage of that? Is fish farmed in the ponds all year cultivated so much in this area. The number of ponds
round where fish is farmed usually, what kind of is not also high. Telapia, Ruhi, Catal fishes are farmed
fishes are farmed? What is the price of fish? more in the ponds where fishes are farmed.
25. What is the percentage of mobile usage of men None of the respondents could say anything about the
and women in this area? percentage of mobile usage of women and men.
However, they mentioned that males and 40% by
females use approximately 60%.
26. What percentage of houses in this area have The respondents said that all of the houses in this area
electricity connection? Describe the current state of have electricity connection. However, they mentioned
load shedding. that there is a lot of load shedding. There is at least
seven to eight times of load shedding in every day.
They have informed the electricuty office several
times, but the situation has not changed.
27. What percentage of people in this area use Asked about the internet usage, they said that almost
internet? Who uses the Internet more and what kind everyone who has a smartphone uses facebook-
of work do they use the internet? youtube etc. more. They also said that internet is used
for various purposes including admission in various
government schools and colleges.
28. Please tell us the name the NGOs that conduct According to the respondents, all the NGOs in the area
activities in your area. Tell us what programs these are involved in micro-credit at high interest rates.
NGOs run. Discuss in detail how much people in the Grameen Bank, RDRS, Proshika, BRAC, TMSS have
area are involved with the NGO and for what reason. more activities in this sector. However, no one has run
What kind of organization is working or has done in a social or environmental awareness campaign in this
the past to raise awareness about environmental area.
pollution?

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Figure: FGD with community Female

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Summary of FGD Carried Out by NBR

Details of the In-person Stakeholder Consultation Meeting

Issues Description
Stakeholder Consultation Meeting Date 20 December, 2021
Stakeholder Consultation Meeting Time 11.00 am - 1.00 pm
Stakeholder Consultation Meeting Venue Conference Room, Custom House, Chattogram
Issues Discussion
Due to the nature and size of the project, the participants were more interested to
discuss on the infrastructural design and environmental aspects of the project.
Followings are some key environmental factors that were identified and asked to
take into consideration during implementation of the project:
 Air and Noise pollution would be one of the vital issues, particularly during
the period when the existing building would be demolished to build new
ones. There should be a proper plan in place to minimize air and noise
pollution during the implementation period.
 Custom House, Chattogram discard huge amount of paper every day. They
usually store those papers in a warehouse and then sell those off later.
During the site visit, the World Bank team observed a huge amount of waste
paper stored in the corners of the balconies those are waiting to get
Environmental Risks disposed in the proper way. However, a paper recycling center or/and waste
and Management treatment plant can be considered to build so that they can dispose them
immediately to maintain a clean working environment.
 Sound pollution management system in the new buildings; this needs to
take into consideration by installing sound proof windows and other
ventilation systems.
 The Custom House, Chattogram has a decent number of trees inside their
compound. During the implementation of the project, need to minimize the
number of trees will be cut down.
 Custom House, Chattogram chemical laboratory is one of the crucial
laboratories in the country, where 90% of the chemicals are tested that are
imported in Bangladesh. The lab is severely understaffed (it has only 4
people and among them 3 are assistants) and the lab technically operates
only in two rooms. The ESMF should propose a “Hazardous Material
Management Plan” before implementation of the project. The HCMP
should clearly mention probations on how to transfer the chemicals from
one place to another.
 Water logging during the rainy season: Custom Excise and VAT Training
Academy goes under water during the rainy season. This temporary yet
hazardous problem makes lives miserable for the people who live and work
in that area.
 Custom Excise and VAT Training Academy (CEVTA) produces significant
amount of waste every day and the representative of the CEVTA suggested
a waste treatment plant in their compound to keep the environment clean
and safe on a regular basis.
 Drainage system: Proper drainage system is important to keep the area
clean and safe for all. While designing and panning for this system, need to
consider sustainability issues, like capacity and proper management in
mind.
 Rooftop Management: Green rooftop management can be considered to
increase the aesthetic aspect of the building. Also, plantation, proper sitting
area for small meetings, well managed open area for different activities can
be considered within the design which can potentially benefit everyone.
 Sometimes there are accidents and even fatalities during construction.
Proper measures have to be taken to avoid these kinds of incidents.

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Issues Discussion
 Temporary resettlement of the NBR employees/workers living in the
compound of both sites; proper compensation and related issues has to be
considered with utmost care. There are no squatters/informal occupants at
both sites.
 People visiting Custom House, Chattogram mostly have their lunch in the
Social Risks and compound in an existing canteen. During the reconstruction of the
Management compound, the canteen will not be there and that may create some
inconveniences for the people visiting Custom House. An alternative of this
system needs to be considered during the implementation.
 Mosquitoes and pesticides control measures; mostly forgotten but one of
the crucial issues since serious health issues like dengue, chikungunya, etc.
are associated with this.
 Traffic congestion: During the construction period, the amount of usable
land will be reduced, hence creating traffic congestion inside the
compound. An alternative plan needs to put in place to minimize the
congestion.
Infrastructural Design Everyday around 2000 people come visit Custom House, Chattogram and the number
Related Feedback for of incoming people will go up in next decades, given the growth trajectory of
Custom House, Bangladesh. Hence, the design of the building has to be foresightful and it is
Chattogram important that the building is designed in a way that would be sustainable with green
engineering design, remain relevant to time, and most importantly, can
accommodate any changes in demand of time.

 The new buildings need to be built in a way that they have enough probation
to use daylight during the day time as a source of light. Enough open space
and green building need to take into consideration to minimize the use of
Air Conditioner.
 The buildings need to have wide stair case to manage fire hazard; and the
lift and stair can’t be side by side.
 The building must have an emergency exit and the staircase of the exit has
to be wide enough to accommodate enough people at a time during fire or
any other disaster.
 The building must have a separate prayer room and washroom for ladies.
Also, a separate rest room for child care or can be used as a rest room.
 The building must have two to three seminar halls of different capacity and
an auditorium. Also, the present stakeholders suggested considering a
gym/yoga center, a library and dining halls as of needs.
 The building must have three to four lifts and each lift should have a capacity
to lift 20 people or more.
 Proper parking space is of high importance and it has to be properly
managed to accommodate all incoming vehicles.
 The compound must have proper toilet facilities outside for the visitors.
 During the project implementation, there will be temporary arrangement
for many issues, like resettlements, labor sheds, server reinstallation, and
many more. It needs to make sure that the temporary operational issues
are smooth and not interrupting the daily activities of Custom House,
Chattogram.
 Custom House, Chattogram server installation is supremely important;
Planning and sincere attention is needed here.
Operational  The existing Custom House building will not be broken initially; the rest of
Management the complex will be rebuilt first and then the official activities will be moved
to those new buildings temporarily.
 There is a grave, that has to be preserved.
 NBR needs to apply to the forest department for clearance for cutting down
the trees of the compound.

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Issues Discussion
Suggestions (Not  Alternative connecting road from Bangladesh to Agartala: People living in
related to ES) Agartala need 36 hours to reach Kolkata, whereas they can reach to the
nearest Bangladesh districts within 3-4 hours. There is a huge untapped
trade potential for both counties in that area. An alternative smooth road
connectivity can ease the process and can facilitate trading in that area.
 Custom House and port connectivity: To mitigate traffic congestion, an
underpass connecting the Custom House and Port would be helpful.

Stakeholder Consultation Meeting, Custom House, Chattogram

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Annex C: List of Attendees

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List of Participants (NBR Part)

Sl No. Name of the Participants Designation

1. Dr. Abu Nur Rashed Ahmed Additional Commissioner of Custom House,
Chattogram
2. Mohammed Shafi Uddin Additional Commissioner of Custom House,
Chattogram
3. Mohammad Tafsir Uddin Bhuyan Joint Commissioner, Custom House, Chattogram
4. Md. Tofayel Ahmed Joint Commissioner, Custom House, Chattogram
5. Salahuddin Rizvi Deputy Commissioner, Custom House, Chattogram
6. Khadiza Parvin Shumy Deputy Director, CEVTA
7. Salina Akhtar Member, Chattogram Women Chamber of
Commerce
8. Rebeka Nasreen Director, Chattogram Women Chamber of
Commerce
9. Tori Chakma Owner, Mizel Hozal
10. M.M Rafiqul Islam Vice President, C&F Agent Association
11. Ashraful Haque Khan Swapon Joint Customs Secretary, C&F Agent Association
12. Abul Khair Joint Customs Secretary, C&F Agent Association
13. Md. Golam Shamsun Bhuiyan Salim Brothers (Pvt) Ltd, C&F Agent
14. Dedarul Hasan Araf Enterprise, C&F Agent
15. Mominul Hasan Mithun Assistant Revenue Officer, Custom House,
Chattogram
16. Palindra Chakma Assistant Revenue Officer, Custom House,
Chattogram
17. Partha Kumar Biswas Assistant Revenue Officer, Custom House,
Chattogram
18. Sarowar Alam Assistant Revenue Officer, Custom House,
Chattogram
19. Mohammad Ashraf Karim Assistant Terminal Manager, Traffic Department,
Chowdhury Chattogram Port Authority
20. Kirti Nishan Chakma Social Development Specialist, The World Bank
21. Dr. Md. Billal Hossain Environment Consultant, The World Bank
22. Ferdausi Mahojabin Sumana Social Development Consultant, The World Bank

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Annex D: Details of the Environmental and Social Code of Practices (ESCoPs)

ESCoP 1: Waste Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
General Waste Soil and water pollution The Contractor shall
from the improper  Develop a waste management plan for various
management of wastes specific waste streams (e.g., reusable waste,
and excess materials from flammable waste, construction debris, food
the construction sites. waste, etc.) prior to construction and submit to
DSM for approval.
 Organize disposal of all wastes generated during
construction in an environmentally acceptable
manner. This will include consideration of the
nature and location of the disposal site to cause
less environmental impact.
 Minimize waste materials production by 3R
(Reduce, Recycle and Reuse) approach.
 Segregate and reuse or recycle all the wastes,
wherever practical.
 Prohibit burning of solid waste
 Collect and transport non-hazardous wastes to all
the approved disposal sites. Vehicles transporting
solid waste shall be covered with tarps or nets to
prevent spilling waste along the route
 Train and instruct all personnel in waste
management practices and procedures as a
component of the environmental induction
process.
 Provide refuse containers at each worksite.
 Request suppliers to minimize packaging where
practicable.
 Place a high emphasis on good housekeeping
practices.
 Maintain all construction sites in a cleaner, tidy
and safe condition and provide and maintain
appropriate facilities to temporarily store all
wastes before transportation and final disposal.
Hazardous Waste Health hazards and The Contractor shall
environmental impacts  Collect chemical wastes in 200-liter drums (or
due to improper waste similar sealed container), appropriately labeled
management practices for safe transport to an approved chemical waste
depot.
 Store, transport and handle all chemicals avoiding
potential environmental pollution.
 Store all hazardous wastes appropriately in
bunded areas away from water courses.
 Make available Material Safety Data Sheets
(MSDS) for hazardous materials on-site during
construction.
 Collect hydrocarbon wastes, including lube oils,
for safe transport off-site for reuse, recycling,
treatment or disposal at approved locations.
 Construct concrete or other impermeable flooring
to prevent seepage in case of spills.

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ESCoP 2: Fuels and Hazardous Substances Management

Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Fuels and Materials used in The Contractor shall
hazardous goods construction have a  Prepare spill control procedures and submit the
potential to be a source of plan for DSM approval.
contamination. Improper  Train the relevant construction personnel in
storage and handling of handling of fuels and spill control procedures.
fuels, lubricants,  Store dangerous goods in bunded areas on a top of
chemicals and hazardous a sealed plastic sheet away from watercourses.
goods/materials on-site,  Refueling shall occur only within bunded areas.
and potential spills from  Make available MSDS for chemicals and dangerous
these goods may harm the goods on-site.
environment or health of  Transport waste of dangerous goods, which cannot
construction workers. be recycled, to a designated disposal site approved
by DoE.
 Provide absorbent and containment material (e.g.,
absorbent matting) where hazardous material are
used and stored and personnel trained in the
correct use.
 Provide protective clothing, safety boots, helmets,
masks, gloves, goggles, to the construction
personnel, appropriate to materials in use.
 Ensure all containers, drums, and tanks used for
storage are in good condition and are labeled with
expiry date. Any container, drum, or tank that is
dented, cracked, or rusted might eventually leak.
Check for leakage regularly to identify potential
problems before they occur.
 Store hazardous materials above flood plain level.
 Put containers and drums in temporary storages in
clearly marked areas, where they will not be run
over by vehicles or heavy machinery. The area shall
preferably slope or drain to a safe collection area
in the event of a spill.
 Put containers and drums in permanent storage
areas on an impermeable floor that slopes to a safe
collection area in the event of a spill or leak.
 When handling and storing fuels and lubricants,
take all precautionary measures, avoiding
environmental pollution.
 Avoid the use of material with greater potential for
contamination by substituting them with more
environmentally friendly materials.
 Return the gas cylinders to the supplier. However,
suppose they are not empty prior to their return.
In that case, they must be labeled with the name of
the material they contained or contain,
information on the supplier, cylinder serial
number, pressure, their last hydrostatic test date,
and any additional identification marking that may
be considered necessary.

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ESCoP 3: Water Resources Management

Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Hazardous Water pollution from The Contractor shall
Material and storage, handling and  Follow the management guidelines proposed in
Waste disposal of hazardous EC0Ps 1 and 2.
materials, general  Minimize the generation of sediment, oil and
construction waste, and grease, excess nutrients, organic matter, litter,
accidental spillage. debris and any form of waste (particularly
petroleum and chemical wastes). These
substances must not enter waterways, storm
water systems or underground water tables.
Discharge from During construction, both The Contractor shall
Construction sites surface and groundwater  Install temporary drainage works (channels and
quality may deteriorate bunds) in areas required for sediment and erosion
due to river construction control and around storage areas for construction
activities, sewerages from materials
construction sites, and  Install temporary sediment basins, where
work camps. The appropriate, to capture sediment-laden run-off
construction works will from site
modify groundcover and  Divert runoff from undisturbed areas around the
topography, changing the construction site
area's surface water  Stockpile materials away from drainage lines
drainage patterns,  Prevent all solid and liquid wastes entering
including infiltration and waterways by collecting solid waste, oils,
storage of storm water. chemicals, bitumen spray waste and wastewaters
These changes in from brick, concrete and asphalt cutting where
hydrological regime lead possible and transport to an approved waste
to increased rate of disposal site or recycling depot
runoff, increase in  Wash out ready-mix concrete agitators and
sediment and concrete handling equipment at washing facilities
contaminant loading, off site or into approved bunded areas on site.
increased flooding, Ensure that the tires of construction vehicles are
groundwater cleaned in the washing bay (constructed at the
contamination, and effect construction site entrance) to remove the mud
habitat of fish and other from the wheels. This shall be done in every exit
aquatic biology. of each construction vehicle to ensure the local
roads are kept clean.
Soil Erosion and Soil erosion and dust from The Contractor shall
siltation the material stockpiles  Stabilize the cleared areas not used for
will increase surface construction activities with vegetation or
water bodies' sediment appropriate surface water treatments as soon as
and contaminant loading. practicable following earthwork to minimize
erosion
 Ensure that roads used by construction vehicles
are swept regularly to remove sediment
 Water the material stockpiles, access roads and
bare soils on an as required basis to minimize
dust. Increase the watering frequency during
periods of high risk (e.g. high winds)
Construction Construction works in the The Contractor shall
activities in water bodies will increase  Dewater sites by pumping water to a sediment
water bodies sediment and basin prior to release off site – do not pump
contaminant loading, and directly off site
effect habitat of fish and  Monitor the water quality in the runoff from the
other aquatic biology. site or areas affected by dredge plumes, and
improve work practices as necessary

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Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines

Impact Source
 Protect water bodies from sediment loads by silt
screen or bubble curtains or other barriers
 Minimize the generation of sediment, oil and
grease, excess nutrients, organic matter, litter,
debris and any form of waste (particularly
petroleum and chemical wastes). These
substances must not enter waterways, storm
water systems or underground water tables.
 Use environment friendly and nontoxic slurry
during construction of piles to discharge into the
river.
 Reduce infiltration of contaminated drainage
through storm water management design
 Do not discharge cement and water curing used
for cement concrete directly into water courses
and drainage inlets.
Drinking water Groundwater at shallow The Contractor shall
depths is contaminated  Pumping of groundwater shall be from deep
with arsenic and hence aquifers of more than 300 m to supply arsenic
not suitable for drinking free water. Safe and sustainable discharges are to
purposes. be ascertained prior to selection of pumps.
 Tube wells will be installed with due regard for
the surface environment, protection of
groundwater from surface contaminants, and
protection of aquifer cross contamination
 All tube wells, test holes, monitoring wells that
are no longer in use or needed shall be properly
decommissioned.
Depletion and pollution  Install monitoring wells both upstream and
of groundwater resources downstream areas near construction yards and
construction camps to monitor the water quality
and water levels regularly.
 Protect groundwater supplies of adjacent lands
ESCoP 4: Drainage Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Excavation and Lack of proper drainage The Contractor shall
earth works, and for rainwater/liquid waste  Prepare a program for preventing/avoiding
construction or wastewater due to the standing waters, which DSM will verify in advance
yards construction activities and confirm during implementation
harms the environment in  Provide alternative drainage for rainwater if the
terms of water and soil construction works/earth-fillings cut the
contamination and established drainage line
mosquito growth.  Establish local drainage line with appropriate silt
collector and silt screen for rainwater or
wastewater connecting to the existing
established drainage lines already there
 Rehabilitate road drainage structures
immediately if damaged by contractors’ road
transports.
 Build new drainage lines as appropriate and
required for wastewater from construction yards
connecting to the available nearby recipient
water bodies. Ensure wastewater quality

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Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines

Impact Source
conforms to the relevant standards provided by
DoE, before it being discharged into the recipient
water bodies.
 Ensure the internal roads/hard surfaces in the
construction yards/construction camps that
generate has storm water drainage to
accommodate high runoff during downpour and
that there is no stagnant water in the area at the
end of the downpour.
 Construct wide drains instead of deep drains to
avoid sand deposition in the drains that require
frequent cleaning.
 Provide appropriate silt collector and silt screen
at the inlet and manholes and periodically clean
the drainage system to avoid drainage
congestion.
 Protect natural slopes of drainage channels to
ensure adequate storm water drains.
 Regularly inspect and maintain all drainage
channels to assess and alleviate any drainage
congestion problem.
 Reduce infiltration of contaminated drainage
through storm water management design.
Ponding of Health hazards due to The Contractor shall
water mosquito breeding  Do not allow ponding/storage of water especially
near the waste storage areas and construction
camps
 Discard all the storage containers capable of
storing water, after use or store them in inverted
position.
ESCoP 5: Soil Quality Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Filling of Sites Soil contamination will The Contractor shall
with dredge occur from drainage of  Ensure that dredged sand used for land filling shall
spoils dredged spoils be free of pollutants. Prior to filling, sand quality
shall be tested to confirm whether soil is pollution
free. Sediments shall be properly compacted. Top
layer shall be the 0.5 m thick clay on the surface
and boundary slopes along with grass. Suitable
soils shall construct side Slope of Filled Land of 1:2
with proper compaction as per design. Slope
surface shall be covered by top soils/ cladding
materials (0.5m thick) and grass turfing with
suitable grass.
 Leaching from the sediments shall be contained to
seep into the subsoil or shall be discharged into
settling lagoons before final disposal.
 No sediment laden water in the adjacent lands
near the construction sites, and/or wastewater of
suspended materials excessive of 200mg/l from
dredge spoil storage/use area in the adjacent
agricultural lands.

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Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines

Impact Source
Storage of Spillage of hazardous and The Contractor shall
hazardous and toxic chemicals will  Strictly manage the wastes management plans
toxic chemicals contaminate the soils proposed in ECP1 and storage of materials in ECP2
 Construct appropriate spill contaminant facilities
for all fuel storage areas
 Establish and maintain a hazardous materials
register detailing the location and quantities of
hazardous substances including the storage, use
of disposals
 Train personnel and implement safe work
practices for minimizing the risk of spillage
 Identify the cause of contamination, if it is
reported, and contain the area of contamination.
The impact may be contained by isolating the
source or implementing controls around the
affected site
 Remediate the contaminated land using the most
appropriate available method to achieve required
commercial/industrial guideline validation results.
Construction Erosion from The Contractor shall
material stock construction material  Protect the toe of all stockpiles, where erosion is
piles stockpiles may likely to occur, with silt fences, straw bales or
contaminate the soils bunds.
ESCoP 6: Top Soil Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Land clearing Earthworks will impact The Contractor shall
and earth the fertile top soils that  Strip the top soil to a depth of 15 cm and store in
works are enriched with stock piles of height not exceeding 2m.
nutrients required for  Remove unwanted materials from top soil like
plant growth or grass, roots of trees and similar others.
agricultural development  The stockpiles will be done in slopes of 2:1 to
reduce surface runoff and enhance percolation
through the mass of stored soil.
 Locate topsoil stockpiles in areas outside drainage
lines and protect from erosion.
 Construct diversion channels and silt fences
around the topsoil stockpiles to prevent erosion
and loss of topsoil.
 Spread the topsoil to maintain the physico-
chemical and biological activity of the soil. The
stored top soil will be utilized for covering all
disturbed area and along the proposed plantation
sites
 Prior to the re-spreading of topsoil, the ground
surface will be ripped to assist the bunding of the
soil layers, water penetration and revegetation.
Transport Vehicular movement The Contractor shall
outside ROW or  Limit equipment and vehicular movements to
temporary access roads within the approved construction zone
will affect the soil fertility  Construct temporary access tracks to cross
of the agricultural lands concentrated water flow lines at right angles
 Plan construction access to make use, if possible,
of the final road alignment

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 Use vehicle-cleaning devices, for example, ramps
or wash down areas.
ESCoP 7: Topography and Landscaping
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Land clearing Flood plains of the The Contractor shall
and earth existing Project area will  Ensure the topography of the final surface of all
works be affected by the raised lands (construction yards, approach roads,
construction of various access roads, bridge end facilities, etc.) are
project activities. conducive to enhance natural draining of
Construction activities, rainwater/flood water;
especially earthworks, will  Keep the final or finished surface of all the raised
change topography, lands free from any kind of depression that insists
disturb the natural water logging
rainwater/flood water  Undertake mitigation measures for erosion
drainage, and change the control/prevention by grass-turfing and tree
local landscape. plantation, where there is a possibility of rain-cut
that will change the shape of topography.
 Cover the uncovered open surface immediately
with no use of construction activities with grass-
cover and tree plantation to prevent soil erosion
and bring improved landscaping.
ESCoP 8: Air Quality Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction Air quality can be The Contractor shall
vehicular traffic adversely affected by  Fit vehicles with appropriate exhaust systems and
vehicle exhaust emission control devices. Maintain these devices
emissions and in good working condition.
combustion of fuels.  Operate the vehicles in a fuel-efficient manner
 Cover haul vehicles carrying dusty materials
moving outside the construction site Impose
speed limits on all vehicle movement at the
worksite to reduce dust emissions
 Control the movement of construction traffic
 Water construction materials prior to loading and
transport
 Service all vehicles regularly to minimize emissions
 Limit the idling time of vehicles not more than 2
minutes.
Construction Air quality can be The Contractor shall
machinery adversely affected by  Fit machinery with appropriate exhaust systems
emissions from and emission control devices. Maintain these
machinery and devices in good working condition in accordance
combustion of fuels. with the specifications defined by their
manufacturers to maximize combustion efficiency
and minimize the contaminant emissions. Proof or
maintenance register shall be required by the
equipment suppliers and
contractors/subcontractors
 Focus special attention on containing the
emissions from generators

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 Machinery causing excess pollution (e.g. visible
smoke) will be banned from construction sites
 Service all equipment regularly to minimize
emissions
 Provide filtering systems, duct collectors or
humidification or other techniques (as applicable)
to the concrete batching and mixing plant to
control the particle emissions in all its stages,
including unloading, collection, aggregate
handling, cement dumping, circulation of trucks
and machinery inside the installations
Construction Dust generation from The Contractor shall
activities construction sites,  Water the material stockpiles, access roads and
material stockpiles and bare soils on an as required basis to minimize the
access roads is a nuisance potential for environmental nuisance due to dust.
in the environment and Increase the watering frequency during high risk
can be a health hazard. periods (e.g. high winds). Stored materials such as
gravel and sand shall be covered and confined to
avoid their being wind-drifted
 Minimize the extent and period of exposure of the
bare surfaces
 Reschedule earthwork activities or vegetation
clearing activities, where practical, if necessary to
avoid during periods of high wind and if visible
dust is blowing off-site
 Restore disturbed areas as soon as practicable by
vegetation/grass-turfing
 Store the cement in silos and minimize the
emissions from silos by equipping them with
filters.
 Establish adequate locations for storage, mixing
and loading of construction materials, in a way
that dust dispersion is prevented because of such
operations
 Crushing of rocky and aggregate materials shall be
wet-crushed, or performed with particle emission
control systems.
ESCoP 9: Noise and Vibration Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction Noise quality will be The Contractor shall
vehicular traffic deteriorated due to  Maintain all vehicles in order to keep it in good
vehicular traffic working order in accordance with manufactures
maintenance procedures
 Ensure all drivers comply with the traffic codes
concerning maximum speed limit, driving hours,
etc.
 Organize the loading and unloading of trucks, and
handling operations for the purpose of
minimizing construction noise on the work site
Construction Noise and vibration may The Contractor shall
machinery have an impact on  Appropriately site all noise generating activities
to avoid noise pollution to local residents
 Use the quietest available plant and equipment

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people, property, fauna,  Modify equipment to reduce noise (for example,
livestock and the natural noise control kits, lining of truck trays or
environment. pipelines)
 Maintain all equipment to keep it in good working
order in accordance with manufacturers
maintenance procedures. Equipment suppliers
and contractors shall present proof of
maintenance register of their equipment.
 Install acoustic enclosures around generators to
reduce noise levels.
 Fit high efficiency mufflers to appropriate
construction equipment
 Avoid the unnecessary use of alarms, horns and
sirens.
Construction Noise and vibration may The Contractor shall
activities impact people, property,  Notify adjacent landholders prior any typical
fauna, livestock and the noise events outside of daylight hours
natural environment.  Educate the operators of construction equipment
on potential noise problems and the techniques
to minimize noise emissions
 Employ best available work practices on-site to
minimize occupational noise levels
 Install temporary noise control barriers where
appropriate
 Notify affected people if major noisy activities will
be undertaken, e.g. pile driving
 Plan activities on site and deliveries to and from
site to minimize impact
 Monitor and analyze noise and vibration results
and adjust construction practices as required.
 Avoid undertaking the noisiest activities, where
possible, when working at night near the
residential areas.
ESCoP 10: Protection of Flora
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Vegetation Local flora is important to The Contractor shall
clearance provide shelters for the  Reduce disturbance to surrounding vegetation
birds, offer fruits and/or  Use appropriate type and minimum size of
timber/fire wood, protect machine to avoid disturbance to adjacent
soil erosion, and keep the vegetation.
environment very friendly  Get approval from supervision consultant for
to human living. As such clearance of vegetation.
damage to flora has wide  Make selective and careful pruning of trees where
range of adverse possible to reduce need of tree removal.
environmental impacts.  Control noxious weeds by disposing of at
designated dump site or burn on site.
 Clear only the vegetation that needs to be cleared
in accordance with the plans. These measures are
applicable to both the construction areas as well
as to any associated activities such as sites for
stockpiles, disposal of fill and construction of
diversion roads, etc.

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 Do not burn off cleared vegetation – where
feasible, chip or mulch and reuse it for the
rehabilitation of affected areas, temporary access
tracks or landscaping. Mulch provides a seed
source, limiting embankment erosion, retaining
soil moisture and nutrients, and encourages
regrowth and protection from weeds.
 Return topsoil and mulched vegetation (in areas
of native vegetation) to approximately the same
area of the roadside it came from.
 Avoid work within the drip-line of trees to prevent
damage to the tree roots and compacting the soil.
 Minimize the time the ground is exposed or
excavation left open by clearing and re-vegetating
the area at the earliest possible time.
 Ensure excavation works occur progressively and
revegetation done at the earliest
 Provide adequate knowledge to the workers
regarding nature protection and the need of avoid
felling trees during construction
 Supply appropriate fuel in the work caps to
prevent fuel wood collection
ESCoP 11: Protection of Fauna
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction The location of The Contractor shall
activities construction activities can  Limit the construction works within the
result in the loss of wild designated sites allocated to the contractors
life habitat and habitat  Check the site for animals trapped in, or in danger
quality. from site works and use a qualified person to
relocate the animal.
Impact on migratory birds, The Contractor shall
its habitat and its active  Not be permitted to destruct active nests or eggs
nests of migratory birds
 Minimize the tree removal during the bird
breeding season. If works must be continued
during the bird breeding season, a nest survey
will be conducted by a qualified biologist prior to
commence of works to identify and located
active nests
 Minimize the release of oil, oil wastes, or other
substances harmful to migratory birds to any
waters or areas frequented by migratory birds.
Vegetation Clearance of vegetation The Contractor shall
clearance may impact shelter,  Restrict the tree removal to the minimum
feeding and/or breeding required.
and/or physical  Retain tree hollows on site, or relocate hollows,
destruction and severing where appropriate
of habitat areas  Leave dead trees where possible as habitat for
fauna
 Fell the hollow bearing trees in a manner which
reduces the potential for fauna mortality. Felled
trees will be inspected after felling for fauna and
if identified and readily accessible will be

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removed and relocated or rendered assistance if
injured. After felling, hollow bearing trees will
remain unmoved overnight to allow animals to
move of their own volition.
Construction Illegal poaching The Contractor shall
camps  Provide adequate knowledge to the workers
regarding protection of flora and fauna, and
relevant government regulations and
punishments for illegal poaching.
ESCoP 12: Protection of Fisheries
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction The main potential The Contractor shall
activities in River impacts to fisheries are  Ensure the riverine transports, vessels and ships
and Floodplain hydrocarbon spills and are well maintained and do not have oil leakage to
Water leaks from riverine contaminate river water.
transport and disposal of  Contain oil immediately on river in case of
wastes into the river and accidental spillage from vessels and ships and in
floodplain water this regard, make an emergency oil spill
containment plan to be supported with enough
equipment, materials and human resources
 Do not dump wastes, be it hazardous or non-
hazardous into the nearby water bodies or in the
river.
The main potential The Contractor shall
impacts to aquatic flora  follow mitigation measures proposed in ECoP 3:
and fauna River are Water Resources Management and EC4: Drainage
increased suspended Management
solids from earthworks
erosion, sanitary
discharge from work
camps, and hydrocarbon
spills
Construction Filling of ponds for site The Contractor shall
activities on the preparation will impact  Inspect any area of a water body containing fish
land the fishes that is temporarily isolated for the presence of fish,
and all fish shall be captured and released
unharmed in adjacent fish habitat
 Install and maintain fish screens etc. on any water
intake with drawing water from any water body
that contain fish.
ESCoP 13: Road Transport and Road Traffic Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction Increased traffic use of The Contractor shall
vehicular traffic road by construction  Prepare and submit a traffic management plan to
vehicles will affect the the DSM for his approval at least 30 days before
movement of normal commencing work on any project component
road traffics and the involved in traffic diversion and management.
safety of the road-users.  Include in the traffic management plan to ensure
uninterrupted traffic movement during
construction: detailed drawings of traffic
arrangements showing all detours, temporary

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road, temporary bridges temporary diversions,
necessary barricades, warning signs / lights, and
road signs.
 Provide signs at strategic locations of the roads
complying with the schedules of signs contained in
the Bangladesh Traffic Regulations.
 Install and maintain a display board at each
important road intersection on the roads to be
used during construction, which shall clearly show
the following information in Bangla:
o Location: Village name
o Duration of construction period
o Period of proposed detour / alternative
route
o Suggested detour route map
o Name and contact address/telephone
number of the concerned personnel
o Name and contact address / telephone
number of the Contractor
o Inconvenience is sincerely regretted.
Accidents and spillage of The Contractor shall
fuels and chemicals  Restrict truck deliveries, where practicable, to day
time working hours.
 Restrict the transport of oversize loads.
 Operate road traffics/transport vehicles, if
possible, to nonpeak periods to minimize traffic
disruptions.
 Enforce on-site speed limit
ESCoP 14: Construction Camp Management
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Siting and Location Campsites for The Contractor shall
of construction construction workers are  Locate the construction camps at acceptable areas
camps the important locations from an environmental, cultural or social point of
that have significant view.
impacts such as health  Consider the location of construction camps away
and safety hazards on from communities in order to avoid social conflict
local resources and in using the natural resources such as water or to
infrastructure of nearby avoid the possible adverse impacts of the
communities. construction camps on the surrounding
communities.
 Submit to the DSM for approval a detailed layout
plan for the development of the construction
camp showing the relative locations of all
temporary buildings and facilities that are to be
constructed together with the location of site
roads, fuel storage areas (for use in power supply
generators), solid waste management and
dumping locations, and drainage facilities, prior to
the development of the construction camps.
 Local authorities responsible for health, religious
and security shall be duly informed on the set up
of camp facilities so as to maintain effective

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surveillance over public health, social and security
matters
Construction Lack of proper The Contractor shall provide the following facilities in the
Camp Facilities infrastructure facilities, campsites:
such as housing, water  Adequate housing for all workers
supply and sanitation  Safe and reliable water supply. Water supply from
facilities will increase deep tube wells of 300 m depth that meets the
pressure on the local national standards
services and generate  Hygienic sanitary facilities and sewerage system.
substandard living The toilets and domestic waste water will be
standards and health collected through a common sewerage. Provide
hazards. separate latrines and bathing places for males and
females with total isolation by wall or by location.
The minimum number of toilet facilities required
is one toilet for every ten persons.
 Treatment facilities for sewerage of toilet and
domestic wastes
 Storm water drainage facilities. Both sides of
roads are to be provided with shallow v drains to
drain off storm water to a silt retention pond
which shall be sized to provide a minimum of 20
minutes retention of storm water flow from the
whole site. Channel all discharge from the silt
retention pond to natural drainage via a grassed
swale at least 20 meters in length with suitable
longitudinal gradient.
 Paved internal roads. Ensure with
grass/vegetation coverage to be made of the use
of top soil that there is no dust generation from
the loose/exposed sandy surface. Pave the
internal roads of at least haring-bond bricks to
suppress dusts and to work against possible
muddy surface during monsoon.
 Provide child crèches for women working
construction site. The crèche shall have facilities
for dormitory, kitchen, indoor and outdoor play
area. Schools shall be attached to these crèches so
that children are not deprived of education whose
mothers are construction workers
 Provide in-house community/common
entertainment facilities dependence of local
entertainment outlets by the construction camps
to be discouraged/prohibited to the extent
possible.
Disposal of Management of wastes The Contractor shall
waste is crucial to minimize  Ensure proper collection and disposal of solid
impacts on the wastes within the construction camps
environment  Insist waste separation by source; organic wastes
in one pot and inorganic wastes in another pot at
household level.
 Store inorganic wastes in a safe place within the
household and clear organic wastes on daily basis
to waste collector. Establish waste collection,
transportation and disposal systems with the
manpower and equipment/vehicles needed.

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 Dispose organic wastes in a designated safe place
on daily basis. At the end of the day cover the
organic wastes with a thin layer of sand so that
flies, mosquitoes, dogs, cats, rats, are not
attracted. One may dig a large hole to put organic
wastes in it; take care to protect groundwater
from contamination by leachate formed due to
decomposition of wastes. Cover the bed of the pit
with impervious layer of materials (clayey or thin
concrete) to protect groundwater from
contamination.
 Locate the garbage pit/waste disposal site min 500
m away from the residence so that peoples are not
disturbed with the odor likely to be produced from
anaerobic decomposition of wastes at the waste
dumping places. Encompass the waste dumping
place by fencing and tree plantation to prevent
children from entering and playing.
 Do not establish site specific landfill sites. All solid
waste will be collected and removed from the
work camps and disposed in approval waste
disposal sites.
Fuel supplies for Illegal sourcing of fuel The Contractor shall
cooking wood by construction  Provide fuel to the construction camps for their
purposes workers will impact the domestic purpose to discourage them from using
natural flora and fauna fuelwood or other biomass.
 Made available alternative fuels like natural gas or
kerosene on ration to the workforce to prevent
them using biomass for cooking.
 Conduct awareness campaigns to educate
workers on preserving and protecting the project
area's biodiversity and wildlife, and relevant
government regulations and punishments on
wildlife protection.
Health and There will be a potential The Contractor shall
Hygiene for diseases to be  Provide adequate health care facilities within
transmitted including construction sites.
malaria, exacerbated by  Provide first aid facility round the clock. Maintain
inadequate health and stock of medicines in the facility and appoint
safety practices. There fulltime designated first aider or nurse.
will be an increased risk  Provide ambulance facility for the laborers during
of work crews spreading emergency to be transported to nearest hospitals.
sexually transmitted  Initial health screening of the laborers coming
infections and HIV/AIDS. from outside areas
Special attentions should  Train all construction workers in basic sanitation
be paid to limit the and health care issues and safety matters, and on
spread of COVID-19 the specific hazards of their work
 Provide HIV awareness programming, including
STI (sexually transmitted infections) and HIV
information, education and communication for all
workers on regular basis
 Complement educational interventions with easy
access to condoms at campsites as well as
voluntary counseling and testing

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 Provide adequate drainage facilities throughout
the camps to ensure that disease vectors such as
stagnant water bodies and puddles do not form.
Regular mosquito repellant sprays during
monsoon.
 Carryout short training sessions on best hygiene
practices to be mandatorily participated by all
workers. Place display boards at strategic
locations within the camps containing messages
on best hygienic practices
 Regular temperature checking, strict use of PPE
including masks should be ensured
 Sanitization facility should be established
Safety In adequate safety The Contractor shall
facilities to the  Provide appropriate security personnel (police /
construction camps may home guard or private security guards) and
create security problems enclosures to prevent unauthorized entry in to the
and fire hazards camp area.
 Maintain register to keep a track on a head count
of persons present in the camp at any given time.
 Encourage use of flameproof material for the
construction of labor housing / site office. Also,
ensure that these houses/rooms are of sound
construction and capable of withstanding wind
storms/cyclones.
 Provide appropriate type of firefighting
equipment suitable for the construction camps
 Display emergency contact numbers clearly and
prominently at strategic places in camps.
 Communicate the roles and responsibilities of
laborers in case of emergency in the monthly
meetings with contractors
 Special supervisions, training session to avoid
GBV/SEA/SH within the camps
Site Restoration Restoration of the The Contractor shall
construction camps to  Dismantle and remove from the site all facilities
original condition established within the construction camp
requires demolition of including the perimeter fence and lockable gates
construction camps. at the completion of the construction work.
 Dismantle camps in phases and as the work gets
decreased and not wait for the entire work to be
completed
 Give prior notice to the laborers before
demolishing their camps/units
 Maintain the noise levels within the national
standards during demolition activities
 Different contractors shall be hired to demolish
different structures to promote recycling or reuse
of demolished material.
 Reuse the demolition debris to a maximum extent.
Dispose remaining debris at the designated waste
disposal site.
 Handover the construction camps with all built
facilities as it is if agreement between both parties
(contactor and land-owner) has been made so.

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 Restore the site to its condition prior to
commencement of the works or to an agreed
condition with the landowner.
 Not make false promises to the laborers for future
employment in O&M of the project.
ESCoP 15: Cultural and Religious Issues
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Construction Disturbance from The Contractor shall
activities near construction works to  Communicate to the public through community
religious and the cultural and religious consultation and newspaper announcements
cultural sites sites, and contractors regarding the scope and schedule of construction
lack of knowledge on and certain construction activities causing
cultural issues cause disruptions or access restriction.
social disturbances.  Do not block access to cultural and religious sites,
wherever possible
 Restrict all construction activities within the foot
prints of the construction sites.
 Stop construction works that produce noise
(particularly during prayer time) shall there be any
mosque/religious/educational institutions close to
the construction sites and users make objections.
 Take special care and use appropriate equipment
when working next to a cultural/religious
institution.
 Stop work immediately and notify the site manager
if, during construction, an archaeological or burial
site is discovered. It is an offence to recommence
work in the vicinity of the site until approval to
continue is given by the DSM/PIU. Provide
separate prayer facilities to the construction
workers.
 Show appropriate behavior with all construction
workers especially women and elderly people
 Allow the workers to participate in praying during
construction time
 Resolve cultural issues in consultation with local
leaders and supervision consultants
 Establish a mechanism that allows local people to
raise grievances arising from the construction
process.
 Inform the local authorities responsible for health,
religious and security duly informed before
commencement of civil works so as to maintain
effective surveillance over public health, social and
security matters
ESCoP 16: Worker Health and Safety
Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Best practices Construction works may The Contractor shall
pose health and safety  Implement suitable safety standards for all workers
risks to the construction and site visitors which shall not be less than those laid
workers and site visitors down on the international standards (e.g.

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leading to severe injuries International Labor Office guideline on ‘Safety and
and deaths. The Health in Construction; World Bank Group’s
population in the ‘Environmental Health and Safety Guidelines’) and
proximity of the contractor’s own national standards or statutory
construction site and the regulations, in addition to complying with the
construction workers national standards of the Government of Bangladesh
will be exposed to a (e.g. `The Bangladesh Labor Code, 2006’)
number  Provide the workers with a safe and healthy work
of (i) biophysical health environment, taking into account inherent risks in its
risk factors, (e.g., noise, particular construction activity and specific classes of
dust, chemicals, hazards in the work areas,
construction material,  Provide personal protection equipment (PPE) for
solid waste, waste workers, such as safety boots, helmets, masks, gloves,
water, vector protective clothing, goggles, full-face eye shields, and
transmitted diseases ear protection. Maintain the PPE properly by cleaning
etc.), (ii) risk factors dirty ones and replacing them with the damaged
resulting from human ones.
behavior (e.g., STD, HIV  Safety procedures include provision of information,
etc.) and (iii) road training and protective clothing to workers involved
accidents from in hazardous operations and proper performance of
construction traffic. their job
 Appoint an environment, health and safety manager
to look after the health and safety of the workers
 Inform the local authorities responsible for health,
religious and security duly informed before
commencement of civil works and establishment of
construction camps so as to maintain effective
surveillance over public health, social and security
matters.
 Provision of fine or handover to the law enforcing
agency in case of any forced labor issues.
 Health and safety related to COVID-19 including
appropriate PPE and sanitization facilities
Child and pregnant labor The Contractor shall
 not hire children of less than 18 years of age and
pregnant women or women who delivered a child
within 8 preceding weeks, in accordance with the
Bangladesh Labor Code, 2006
Accidents Lack of first aid facilities  Provide health care facilities and first aid facilities are
and health care facilities readily available. Appropriately equipped first-aid
in the immediate vicinity stations shall be easily accessible throughout the
will aggravate the health place of work
conditions of the victims  Document and report occupational accidents,
diseases, and incidents.
 Prevent accidents, injury, and disease arising from,
associated with, or occurring in the course of work by
minimizing, so far as reasonably practicable, the
causes of hazards. In a manner consistent with good
international industry practice.
 Identify potential hazards to workers, particularly
those that may be life-threatening and provide
necessary preventive and protective measures.
 Provide awareness to the construction drivers to
strictly follow the driving rules

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 Provide adequate lighting in the construction area
and along the roads
Construction Lack of proper  The Contractor shall provide the following facilities in
Camps infrastructure facilities, the campsites to improve health and hygienic
such as housing, water conditions as mentioned in ECoP 17 Construction
supply and sanitation Camp Management
facilities will increase  Adequate ventilation facilities
pressure on the local  Safe and reliable water supply. Water supply from
services and generate deep tube wells that meets the national standards
substandard living  Hygienic sanitary facilities and sewerage system. The
standards and health toilets and domestic waste water will be collected
hazards. through a common sewerage.
 Treatment facilities for sewerage of toilet and
domestic wastes
 Storm water drainage facilities.
 Recreational and social facilities
 Safe storage facilities for petroleum and other
chemicals in accordance with ECoP 2
 Solid waste collection and disposal system in
accordance with ECP1.
 Arrangement for trainings
 Paved internal roads.
 Security fence at least 2 m height.
 Sick bay and first aid facilities
Water and Lack of Water sanitation  The contractor shall provide portable toilets at the
sanitation facilities at construction construction sites, if about 25 people are working the
facilities at the sites cause whole day for a month. Location of portable facilities
construction sites inconvenience to the shall be at least 6 m away from storm drain system
construction workers and surface waters. These portable toilets shall be
and affect their personal cleaned once a day and all the sewerage shall be
hygiene. pumped from the collection tank once a day and shall
be brought to the common septic tank for further
treatment.
 Contractor shall provide bottled drinking water
facilities to the construction workers at all the
construction sites.
Other ECoPs Potential risks on health The Contractor shall follow the following ECPs to reduce health
and hygiene of risks to the construction workers and nearby community
construction workers  ECoP 2: Fuels and Hazardous Goods Management
and general public  ECoP 4: Drainage Management
 ECoP 10: Air Quality Management
 ECoP 11: Noise and Vibration Management
 ECoP 15: Road Transport and Road Traffic
Management
 ECoP 16: River Transport management
Trainings Lack of awareness and The Contractor shall
basic knowledge in  Train all construction workers in basic sanitation and
health care among the health care issues (e.g., how to avoid malaria and
construction workforce, transmission of sexually transmitted infections (STI)
make them susceptible HIV/AIDS and communicable diseases.
to potential diseases.  Train all construction workers in general health and
safety matters, and on the specific hazards of their
work Training shall consist of basic hazard awareness,
site specific hazards, safe work practices, and

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Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines

Impact Source
emergency procedures for fire, evacuation, and
natural disaster, as appropriate.
 Commence the malaria, HIV/AIDS and STI education
campaign before the start of the construction phase
and complement it with a strong condom marketing,
increased access to condoms in the area, and
voluntary counseling and testing.
 Implement malaria, HIV/AIDS and STI education
campaign targeting all workers hired, international
and national, female and male, skilled, semi- and
unskilled occupations, at the time of recruitment and
thereafter pursued throughout the construction
phase on ongoing and regular basis. This shall be
complemented by easy access to condoms at the
workplace as well as to voluntary counseling and
testing.
 Provision of wearing masks, PPE, sanitizer shall be
ensured.
 Preparation of Gender and SEA/SH Action Plan which
details the relevant mitigation measures both
preventive and curative, and as well includes specific
actions to promote gender and women
empowerment.

ESCoP 17: Security Management

Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
Absence of May affect the project The contractor shall ensure
Proper Security economically and also - Code of conduct, behavior commitments, clear and
Management result in loss of resources accessible disciplinary process, and grievance process;
- Engagement with communities about the project's impacts
on community safety and security, awareness raising
concerning the Code of Conduct commitment and project
grievance mechanism, as outlined in the Stakeholder
Engagement Plan (SEP)
- Policy on "use of force" and clarity on proportionality to risk.
The use of force by direct or contracted workers in providing
security should not be sanctioned except when used for
preventive and defensive purposes in proportion to the
nature and extent of the threat.
- Incident reporting: means of receiving and reporting
incidents and allegations, and guidelines for receiving and
following up on them, including procedures for reporting to
the Borrower and the Bank, as required.
- Site access control: guidelines for security personnel on how
to interact with community members seeking access to a
project site or raising a concern (for example, training on the
grievance mechanism and Code of Conduct).
- Any allegations of criminal behavior should be reported to
relevant authorities, whether from private or public
security, employees or contractors.
- If gender-based violence or sexual exploitation and abuse
issues arise or are alleged during project implementation or
supervision, Bank Management must be alerted
immediately. Security-related allegations or incidents can

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Project Activity/ Environmental Impacts Mitigation Measures/ Management Guidelines

Impact Source
include issues such as theft, abuse of power and retaliation,
sexual harassment and exploitation, gender-based violence,
and bribery and corruption.14

14
https://documents1.worldbank.org/curated/en/692931540325377520/Environment-and-Social-Framework-ESF-Good-
Practice-Note-on-Security-Personnel-English

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Annex E: Terms of Reference (ToR) of the ESIA Study

Introduction: World Bank is currently funding a regional infrastructure development program involving
Bangladesh, Nepal, Bhutan, and India. The proposed program, titled “BBIN Regional Transport and
Trade Facilitation Program” adopts a Multiphase Programmatic Approach (MPA) and will be
implemented in several phases over a period of 10-12 years.
Phase 1 of the Program will comprise of US$730m in IDA financing in total: for Bangladesh (US$480m)
and Nepal (US$250m). In Bangladesh, the Program include 3 (three) components: (a) upscaling and
modernization of 3 land ports at Bhomra, Benapole and Burimari with Bangladesh Land Port Authority
(BLPA) as implementing agency (IA) (b) the development of automated border management systems at
selected border points to be implemented by National Board of Revenue (NBR), and c) technical
assistance to support the implementation of the WTO Trade Facilitation Agreement (TFA) with Ministry
of Commerce (MoC). The works are expected to include, among other things, warehouses, stack yards,
truck terminal, chassis terminal, passenger shed, godown (warehouse), a passenger terminal with
parking area, transshipment yard, mosque, workshop, medical center, pedestrian road laboratories and
the required-service facilities and buildings. A consulting firm will prepare the scope of development for
phase 1 under the new BBIN Program.
Given the extend of the project, the potential environmental and social risks and impacts of the program
could be adverse and significant, covering a larger area of influence. Land acquisition and involuntary
resettlement will be very insignificant and few number of mature trees will be felled down along the
considered Right of Way (RoW). Environment, occupational and community health, safety, and labour
issues will also be significant, particularly along the corridor and transport and access routes during
construction. This Environmental and Social Management Framework (ESMF) is required to draft for
the project to identify the required environmental and social management measures that need to be
taken by the project authorities in IAs during the planning, design, construction and operations of the
project, in order to ensure compliance with the Government of Bangladesh own requirements and
those of the World Bank.
The risks and impacts of project interventions cannot be determined until the program or subproject
details have been identified. Therefore, an ESMF was prepared for this project during appraisal mainly
to address the potential environmental and social, labour, Environment, Health and Safety (EHS) and
stakeholder’s engagement issues related to individual IA’s sub-projects to be implemented under the
project. All the potential major environmental and social impacts along with mitigation and
management measures have been compiled in the form of ESMF. More particularly, this ESMF highlights
the requirements related to the 10 Environment and Social Standards (ESSs) of the World Bank
Environmental and Social Framework (ESF).
Objectives of the ESIA: The objective of the assignment is to carry out the tasks related to
environmental aspects in light of the ToR. These include preparation of the Environmental Impact
Assessment (including ESMP) of the BRSP.
Scope of Services: Carry out an overall Environmental and Social Impact Assessment (ESIA) and prepare
Environmental and Social Management Plan (ESMP) for the project area covered under the project. ESIA
and ESMP would be prepared according to the World Bank ESSs and the GoB procedures. The
Consultant shall familiarize themselves with the project details and components. The Consultant should
interact with other preparation consultants of PIU to determine best way of conducting environment
activities. Consultant shall appropriately plan the timing of the deliverables.
The major activities to be carried out will include, but not limited to the following:

A. Review the ESMF Report

a. Review of the ESMF report;
b. Review the preliminary Baseline report prepared on the basis of reconnaissance field
investigations carried out during ESMF preparation;

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c. Determine any gaps particularly in the ESMF;

B. Review the Project details
a. Obtain from the IA and PIU consultants all the details about the project;
b. Hold meetings with the PIU team to understand the scope and nature of work;
C. Scoping
a. Carry out reconnaissance field visit. On the basis of this field visit and review of the
project details, carry out scoping for the ESIA study. Screen out the impacts that are not
likely to take place and prepare a list of potential impacts that are likely to take place.
b. Prepare criteria to be used to determine the program influence area for conducting
ESIA;
c. Specify the boundaries of the study area for the assessment (project influence area):
canal area, river basin/catchments, land use, the drainage area and patterns,
aquaculture and other development interventions – current and proposed, watersheds,
access to sensitive/remote areas such as parks/ reserves/forests/agriculture land,
elements of transport development program in the area.
D. Describe the Proposed Project
a. Provide information on the following: location of all project-related development sites
and general layout and extent of facilities at project-related development sites;
diagrams/drawings of proposed structures; design basis, size, capacity; preconstruction
activities; construction activities (land clearing, land grading, worker camps, if any),
schedule, staffing and support, facilities and services; operation and maintenance
activities, staffing and support, facilities and services; management of risks, including
health and safety; life expectancy for major components. Components may include any
or all of the following: structural measures; dikes and levees; drainage, and
nonstructural measures, service road and route(s), adjustments to alignments of canals,
including earthworks; fish passes and regulator, repair/replacement of infrastructures;
and resettlement sites. Also describe sources of materials used during proposed works;
generation of wastes and their disposal, expected volume of use, construction-related
vehicular traffic; resettlement, land acquisition, safety features; staffing and
accommodation of employees, including site clearance, scheduling of project activities,
approximate quantity and likely source of construction materials.
b. Provide maps and diagrams with appropriate scales to illustrate the general setting of
project-related development sites and key project components. These maps and
diagrams shall include overall project layout, details of individual components, project
time schedule, and any related aspects.
E. Analysis of Alternatives
a. An examination and evaluation of the project and potential alternative of not
proceeding with it will be taken into consideration in the ESIA. The evaluation will
include:
 An analysis of the alternative means of carrying out the Project, including need for
the project, alternative sites, alternate projects and variations to the scope of the
project (major components included and excluded) and if any of the alternatives
could result in a minimization of adverse impacts. A comparison of their
environmental and technical performance potential and other relevant variables
will be included for the project components.
 A discussion on the status of any ongoing analyses, including a discussion of the
options not chosen and the rationale for their exclusion.
 Contingency plans if major project components or methods prove infeasible or do
not perform as expected; and

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 The implications of a delay in proceeding with the Project, or any phase of the
Project.
 Examination of the ‘do nothing’ alternative
F. Description of the Environment
a. Review the Baseline report prepared as part of the ESMF of the project and identify
gaps if any. Obtain additional data as needed.
b. Assemble and evaluate and baseline data on the environmental characteristics of the
study area, including river basin/watershed, construction, resettlement sites,
inundation, floodplain, and biological features (habitats and rare species, vegetation,
fisheries, birds, terrestrial fauna), and floodplain (recession) agriculture. Include
information on any changes anticipated before the project commences.
c. Physical environment: geology, topography, soils, climate, surface and ground water
hydrology, annual peak discharge, ambient air quality; noise; vehicular traffic;
recurrence intervals of various peak discharges and peak stages of various discharges,
erosion and sediment loading, existing/projected pollution discharges and receiving
water quality; instances of flooding, siltation/erosion, depth, bottom topography of the
rivers;
d. Biological environment: ecology: flora and fauna, including rare or endangered species;
sensitive natural habitats, including sanctuaries and reserves; biological connectivity;
potential vectors for disease; exotics and aquatic weeds; application of pesticides and
fertilizers (current and projected as agriculture production is expected to be increased);
e. Socio-cultural environment: land use (including current crops and cropping patterns;
fisheries and farm outputs and inputs; transportation; land tenure and land titling;
present water supply and water uses (including current distribution of water
resources); control over allocation of resource use rights; water and fisheries related
human health problems; cultural sites, present and projected population; present land
use/ownership; planned development activities; community structure; present and
projected employment by industrial category; distribution of income, goods and
services; recreation; public health; cultural properties; indigenous peoples, customs
and aspirations; significant natural, cultural or historic sites, etc. Presence of HIV/AIDS
and other sexually transmitted diseases;
f. Provide location and union/upazila wise information on the project intervention and
identify any critical aspects that need special consideration during design, construction
and operation.
G. Stakeholder consultations
a. Consultations need to be carried out at least twice, in accordance with the WB
requirements: (a) shortly after environmental screening and before the terms of
reference for the ESIA is finalized; and (b) once a draft ESIA report is prepared.
b. Review the consultations carried out during the ESMF.
c. Carry out consultations with institutional stakeholders including but not limited to
officials from DoE, MoC, BLPA, RHD, BGB and also with local, national, and international
NGOs, and other organization as appropriate and relevant.
d. Carry out comprehensive consultations with primary stakeholders, particularly the
communities to be positively and negatively affected by the project.
e. Relevant materials will be provided to affected groups in a timely manner prior to
consultations and in a form and language that is understandable and accessible to the
groups being consulted. The Consultant should maintain a record of the public
consultation (written and video and pictorial proof) and the records should indicate:
means other than consultations (e.g., surveys) used to seek the views of affected
stakeholders; the date and location of the consultation meetings, a list of the attendees
and their affiliation and contact address; and, summary minutes.

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H. Determination of the Potential Impacts of and Impacts on the Proposed Project

a. Review the impact assessment carried out during the ESMP and identify gaps if any.
b. Review the ESMP compliance for the ESMF, particularly review the institutional setup,
implementation of mitigation measures, environmental monitoring and
documentation, environmental monitoring reports, environmental quarterly progress
reports, and other reports. Determine gaps if any; also determine impracticality and or
inappropriateness of any ESMP aspect such as institutional set up, mitigation measures,
monitoring measures, and others.
c. This analysis will require in depth interpretation. This analysis distinguishes between
significant positive and negative impacts, direct and indirect impacts, and immediate
and long-term impacts. Identify impacts that are unavoidable or irreversible. Wherever
possible, describe impacts quantitatively, in terms of environmental costs and benefits.
Assign economic values when feasible. Characterize the extent and quality of available
data, explaining significant information deficiencies and any uncertainties associated
with predictions of impact. Compare the impact with the baseline. Provide ToRs for
studies to obtain the missing information. Special attention should be given to the
environmental impact those identified during the screening process of ESMF.
I. Development of an Environmental and Social Management Plan (ESMP)
a. Review the ESMP included guideline in the ESMF.
b. Identify key mitigation and enhancement approaches and prepare the impact specific
mitigation measures. Estimate the mitigation measures' impacts and costs and the
institutional and training requirements to implement them. If appropriate, assess
compensation to affected parties for impacts that cannot be mitigated. Prepare an
ESMP, including proposed work programs, budget estimates, schedules, staffing and
training requirements, and other necessary support services to implement the
mitigating measures, monitoring, etc. Include measures for emergency response to
accidental events (e.g., entry of raw sewage or toxic wastes into rivers, streams).
c. Prepare a detailed plan to monitor the implementation of mitigating measures and the
impacts of the project during rehabilitation and operation (e.g., emission and ambient
levels of pollutants where these may be detrimental to human health, soil erosion,
changes in the floodplain). Include in the plan an estimate of capital and operating costs
and a description of other inputs (such as training and institutional strengthening)
needed to implement the plan. Include a regular schedule of monitoring the quality of
surface and ground waters to ensure that mitigation measures are effective. Provide
guidance for reporting and enforcement and conducting environmental audits.
d. Estimate the costing of ESMP, environmental and social code of practices (ESCoPs) and
provide necessary clauses for incorporating in the bid document.
e. Review the responsibilities and capability of institutions at local, provincial/regional,
and national levels and recommend steps to strengthen or expand them so that the
ESMP may be effectively implemented. The recommendations may extend to new laws
and regulations, new agencies or agency functions, inter-sectoral arrangements,
management procedures and training, staffing, operation and maintenance training,
budgeting and financial support.
f. An outline of the contents of the ESMP to be included in the project’s Operational
Manual should be provided along with environmental/social protection clauses for
contracts and specifications.
g. Define the roles and responsibilities of officials, staff, consultants, and IA’s contractors
on environmental and social management.
h. Describe in details who will (a) implement the environmental mitigation activities (b)
carrying out environmental monitoring; (c) supervise environmental mitigation and
monitoring; (d) design, implement and apply the environmental management
information system (EMIS); and (e) prepare quarterly progress report on environmental
management;

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ESIA Report Compilation

a. Finalize the draft ESIA incorporating the comment from the consultation (see Annex D
for the ESIA structure);
b. Translate and finalize the executive summary of ESIA in Bengali.
Team composition and qualifications:
The assignment requires interdisciplinary analysis with specialized sector knowledge (i.e., ecology,
fisheries, marine sciences, water resource and hydrology). The general skills required of the
Environmental Safeguard team are: environmental management planning, civil engineer(s), with
particular experience in road projects, river/canal re-excavation, general construction, growth center
establishment, wildlife and aquatic biologist depending upon the predicted impacts, land use planner,
sociologist, archaeologist and communications/stakeholder engagement. The consulting team must be
able to demonstrate appropriate skill mix and depth of experience to cover all areas of the proposed
analysis, including incorporation of other specialized skill sets where required. A Team Leader shall lead
the consulting team with at least 10 years of experience leading ESIA studies, including prior
international experience on similar types of LGED projects, and prior experience as either team leader
or deputy team leader on at least one (1) previous major ESIA for World Bank funded projects.

Reporting
The consultant will report to the Project Director, BBIN MPA.

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Annex F: Outline of ESIA Reports

Executive Summary

This should be standalone and concisely provides a good summary of the project, the policy, and
regulatory frameworks, summary of consultations with critical stakeholders, a summary of key baseline
information relevant to the analysis of key impacts, a summary of key and site-specific impacts, a
summary of key measures to address land port-specific impacts, implementation arrangements for the
ESMP with an estimated budget. The ES should be accompanied by a good and readable map showing
the port's location, connecting transport corridors, and locations of ancillary facilities.

Chapter 1: Project Description

Describes the physical components of the port in full detail, including location, size, design elements,
components, ancillary facilities such as borrow pits, quarry sites, workers camps, disposal areas, hauling
& transport routes, etc. Maps, photos, and design details should be included. Estimates of resources
required during construction and operation phases should be provided, with supporting calculations in
annexes.

Chapter 2: Legal and Institutional Framework

These needs include an evaluation of the local laws and regulations (including relevant laws, regulations,
and institutions on labor & working conditions and health & safety) vis a vis, the new ESF and 10 ES
Standards, GBV Good Practice Note, World Bank Group EHS Guidelines and Industry Sector Guidelines
for Construction Material Extraction and relevant international treaties and protocols.

Chapter 3: Description of Environment (Baseline Data)

A specific description of the environment (Physical, Biological, and Socio-Economic) for each port and
the surrounding area, its component activities, and ancillary facilities are required to ensure that key
baseline information is up-to-date. In addition, baseline data for ESS2 and ESS4 will need to be collected.

Chapter 4: Stakeholder Engagement and Public Consultations

It should summarize the consultation processes, dates of consultations, who were consulted, issues
raised, and how issues will be addressed by the project for each of the ports.

Information on the consultation process, dates of consultations, the person/ institutions consulted,
issues raised, and how the project address issues and should.

Chapter 5: Environmental and Social Risks and Impacts

It is suggested to separate risk and impact assessment from mitigation. Thus, this chapter should focus
on assessing the risks and impacts of the project related to all other relevant standards (ESS2, ESS3,
ESS4, ESS5, ESS6, ESS7, ESS8), including stakeholder engagement, vulnerable groups, and assessment
and management of environmental and social risks and impacts of contractors.

In addition, this chapter also needs to include cumulative impact assessment following IFC Good
Practice Handbook on Cumulative Impact Assessment. This also needs to have indirect and induced
impacts of the port development on valued ecosystem components.

It is suggested that a summary table be provided showing the locations, sensitive receptors, distance of
the receptors from the project, and how the project will impact sensitive receptors.

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Chapter 6: Mitigation Measures

This will be the ESMP, which should demonstrate the application of mitigation hierarchy (i.e., avoidance,
minimization, mitigation, offset/ compensation) and should cover both generic mitigation measures for
noise, dust, pollution, health & safety, etc. and site-specific measures for sensitive receptors, monitoring
& audit, including grievance redress.

Where possible, technical specifications should be provided for generic and site-specific measures that
can be readily adopted in the bidding documents.

This chapter should accompany a table summarizing the project phase, activities, risks & impacts,
management measures that apply the mitigation hierarchy, responsible party, and indicative budget.

It should specify specific plans that will be prepared and implemented by the contractor before site
mobilization, including but not limited to the Construction-ESMP, Traffic Management Plan, Health and
Safety Plan, Labor Influx Management Plan, Workers' Camp Management Plan, Spoils Disposal
Management Plan, Site Rehabilitation and Restoration Plan, Waste Management Plan, Material
Extraction Plan, Gender and Gender-Based Violence Action Plan etc.

The detailed specifications for the bidding documents' environmental, social, health, and safety (ESHS)
requirements will be consistent with standard requirements in the Bank's 2017 SBD documents for ICB.

a. The following needs to be clearly outlined:

b. Unit cost and quantity of the mitigation measures
c. Minimum specification of the measures
d. Timing to implement the mitigation activities
e. Provisions to be made in the contract (as a part of Special Condition of Contract) for Supervision
Consultant and the Contractor
Chapter 7: Analysis of Alternatives

This chapter should assess and present different alternatives, including phased development, degree of
mechanization during construction, the pace of construction, construction techniques, without the
project scenario, etc. The pros and cons should be presented and rationale for their selection over other
options.

Chapter 8: Key measures and actions for the Environmental and Social Commitment Plan (ESCP)

This summarizes key measures and actions and the timeframe required for the project to meet the
requirements of the ESSs. This will build on the ESMP proposed under Chapter 6.

Chapter 9: Institutional Arrangements

This will be the Implementation Arrangements for the ESMP, including safeguard capacity assessment
and staffing among the Employer, Construction Supervision Consultant (CSC), and Contractors.

In addition, this chapter should make clear the minimum EHS staffing at BLPA, Contractor, and the CSC.

The chapter should also outline the institutional arrangements during the operation phase, especially
regarding environmental and social issues management.

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Annex G: Outline of Labor Management Procedures

The Labor Management Procedures (LMP) is prepared to meet the objectives and requirements of the
World Bank Environmental and Social Framework (ESF) Environmental and Social Standards (ESSs) 2 and
4 as well as the national Labor Laws of Bangladesh. This LMP assesses the potential risks and impacts
of assignment of labor for the implementation of the Project activities by the Implementing Agencies
(IAs)— and addresses them through mitigation measures in line with ESSs and Bangladesh Labor policies
and provisions.
Various types of workers (Direct and Contracted), their estimated numbers, characteristics etc, as well
as key potential environmental and social risks—such as unscrupulous labor practices, Occupational
Health and Safety (OHS) issues, community risks, exclusion of the disadvantaged and the vulnerable
from project benefit and engagement, exploitation of child/ forced/trafficked labor/beneficiaries as
well potential health and safety issues while working under COVID-19 pandemic situation, are assessed
and presented in an LMP. Mitigation measures to reduce such risks depend on the project's size, the
potential Environmental and Social (ES) risks and impacts, the capacity of the implementing agencies to
manage and mitigate the ES risks, and the context under which the project is being implemented.
Provisions of ESSs, Labor Act 2006 (including Amendments of 2013 and 2018), National Child Labor
Elimination Policy 2010. Governmental and WHO guidelines for COVID-19 etc, should be studied to
meet requirement and obligations. Major points of consideration that include Conditions of
Employment, OHS, and Child/Forced Labor etc. have also been referred to as guidelines. Finally, a
Grievance Redress Mechanism (GRM) for workers has to be established to raise any potential
dissatisfaction or concern by anyone employed by the IAs and the PMUs.
Table of Contents for LMP
Acronym

1. Introduction

1.1 Project Description

1.2 Project Subcomponents

1.3 Summary of Key Project Subcomponent Activities

1.4 Project Area and Beneficiaries

1.5 Project Management Overview

1.6 Activity Level Environmental and Social Risk Management Responsibilities

2. Labour Use on the Project

2.1 Categorization of the Workforce
2.2 Project Labour Requirements
3. Potential Labour Risks

4. Overview of Labour Legislation

5. Roles and Responsibilities for Project Labour Management

5.1 BLPA

5.2 RHD

5.3 NBR

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5.4 RHD

6. Project Labour Policies and Procedures

6.1 Terms and Conditions of Employment

6.2 Age of Employment

6.3 Occupational Health and Safety

6.3.1 Workers’ Rights to Refuse Unsafe Work Environments

6.3.2 Sexual Exploitation and Abuse and Sexual Harassment

6.3.3 Workers’ Grievance Management

Annex 1: WHO Guidance on OHS and Covid-19 Outbreak

Annex 2: Code of Conduct for direct workers (other) and contracted workers

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Annex H: Outline of Resettlement Policy Framework

An RPF can be prepared as part of the Environmental and Social Management Framework (ESMF) to
provide guidance to client and implementing agencies in situations where sub-component/components
may require the use of land on a temporary or permanent basis and/or through voluntary land
donations. Accordingly, the RPF is prepared to set out the policies and procedures for preventing or
mitigating adverse impacts related to involuntary land acquisition and resettlement because of
proposed project and sub-projects. The RPF set also the process that need to be duly implemented
regarding voluntary donation.
The purpose of the resettlement policy is to ensure that people and households affected by the project
can maintain or improve their pre-project living standards. The objective of the RPF is to minimize
involuntary resettlement and to provide a framework for assessing concerns of PAP and PAH who may
be subject to loss of land, assets, livelihoods and well-being or living standards because of the
construction of proposed project/sub-projects.
The RPF establishes guidelines for determining land loss eligibility and includes a description of what a
voluntary land donation might entail. The RPF does not have comprehensive baseline information to
define detailed compensation packages. These determinations can be completed at the Abbreviated
Resettlement Action Plan (ARAP) or Resettlement Action Plan (RAP) stage of project implementation
when more comprehensive and up-to-date project information is available.
Table of Contents for RPF
Acronyms and Abbreviations

Executive Summary
1. Introduction

1.1 Background
1.2 Purpose of The Studies
1.3 Resettlement Policy Framework for the Project
1.4 RPF Study Methodology

1.4.1 Contents of the RPF Report

2. Policy and Regulatory Framework

2.1 Introduction
2.2 Social Policies, Laws and Regulations of GoB

2.2.1 Constitutional Provisions

2.2.2 The Acquisition and Requisition of Immovable Property Ordinance, 1982
2.2.3 Other Relevant Acts

2.2.3.2 National Land-use Policy, 2001

2.2.3.2 The East Bengal State Acquisition and Tenancy Act 1950 (Act XV of 1951)

2.2.3.3 Bangladesh Labor Act, 2006

2.2.3.4 Regulation Related to Children

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2.2.3.5 Regulation Related to Women

2.3 Operational Policies and Directives of The World Bank

2.3.1 Applicable World Bank Policies to Component 2 investments

2.3.2 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement (ESS-5)
2.3.3 Public Consultation and Disclosure Requirements by The World Bank

2.3.3.1 Consultations
2.3.3.2 Disclosure

3. Project Description

3.1 Project Development Objective

3.2 Project Description

3.2.1 Project Components

3.2.1.1 Component 1: Investments in infrastructure, systems and procedures to modernize

and improve key land ports essential for trade with India and Bhutan (US$75 million) (BLPA-
managed Component)
3.2.1.2 Component 2: Enhance trade sector coordination and productive capacity (managed by
Ministry of Commerce, WTO Cell)
3.2.1.3 Component 3: National Single Window Implementation and Strengthening Customs
Modernization (US$67 million)

3.2.2 Proposed Developments in Land Ports

3.2.3 Proposed Developments

3.3 Implementing Agency and other Agencies Present at the Border

3.4 Implementation Schedule

3.5 General and Common Principles

3.5.1 Operational Options

3.5.2 Procedures
3. Infrastructure Requirements – Land Requirement
4. Socio-Economic Baseline

4.1 Introduction
4.1.1 Economy
4.1.2 Rivers

4.1.3 Climate

4.1.4 Agriculture
4.1.5 Industry
4.2 Information on Sub-Project Locations

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4.2.1.1 Position
4.2.1.2 Traffic
4.2.1.3 Present Features

4.3.1.4 Current Development Plans

4.3 Gender Issues
4.4 Consultations
4.4.1 Objectives of Consultations

4.5 Project Impacts

4.5.1 Proposed Management Measures

5. Resettlement Policy Framework (RPF)

5.1 Introduction

5.2 RPF - Objectives

5.3 Resettlement Policy Framework

5.4 Procuring Lands

5.4.1 Willing Buyer and Willing Seller

5.4.1.1 Registration and Mutation of Records

5.4.2 Voluntary Land Donation

5.4.2.1 Rules for Transparency in Donation

5.4.3 Land Acquisition

5.4.3.1 Compensation Payment Norms

5.4.3.2 Eligibility for Compensation and Assistance

5.4.3.3 Compensation Principles and Standards

5.4.3.4 Displacement from Homesteads

5.4.3.5 Loss of Business, Employment and Rental Income

5.5 Eligibility and Entitlement Matrix
5.5.1 Eligibility Criteria

5.5.2 Compensation and Entitlements

5.6 Community Engagement

5.6.1 Stakeholder Participation

5.7 Special Attention to Women and Other Disadvantaged Groups

5.7.1 Disadvantaged Groups

5.7.2 Actions to be taken

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5.7.2.1 Other Actions

5.8 Small Ethnic and Disadvantaged Communities Development Framework

5.9 Grievance Redress Mechanism (GRM)
5.9.1 Objective of the GRM

5.9.2 Scope of GRM

5.9.4 Phase One - GRM under Safeguard Issues

5.9.4 Phase Two – Establishment of Implementation Arrangements for Setting up Project Level
GRM
5.9.5 Legal Options to Aggrieved Parties
5.9.6 Grievance Redress Service of The World Bank
5.10 Institutional Arrangements and Capacity Enhancement
5.11 Monitoring, Evaluation and Assessment

5.11.1 Social Monitoring Indicators

5.11.2 Capacity Enhancement

5.12 RPF Budget
5.13 non-Negotiables

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Annex I: Outline of Resettlement Action Plan

The Resettlement Action Plan (RAP) outlines the procedures that the project implementing agency will
follow and the actions that it will take to mitigate adverse effects, compensate losses, and provide
development benefits to persons and communities affected by an investment project.
In accordance with ESS 5, the RAP follows these principles-
1) involuntary resettlement should be avoided
2) where involuntary resettlement is unavoidable, affected people should be compensated
fully, and fairly for lost assets
3) involuntary resettlement should be conceived as an opportunity to improve the livelihoods
of the affected people, and, undertaken accordingly; and,
4) people affected by involuntary resettlement, should be consulted, and involved in
resettlement planning, to ensure that mitigation, and benefits are appropriate and sustainable.
Given that involuntary resettlement entails both the physical displacement of peoples, and the
disruption of their livelihoods, a RAP details the outline of the rights, roles, and responsibilities of all
parties involved in involuntary resettlement. The RAP must identify the full range of people affected by
the project and justify their displacement after consideration of alternatives that would minimize or
avoid displacement. The RAP outlines eligibility criteria for affected parties, establishes rates of
compensation for lost assets, and describes levels of assistance for relocation and reconstruction of
affected households.
Table of Contents
Chapter 1: Introduction

1.1 Background
1.2 Purpose of the Studies
1.3 Resettlement Policy Framework for the Project

1.4 Proposed Project Locations

1.4.1 BLPA

1.4.2 RHD
1.5 Infrastructure Requirements – Land Requirement
1.5.1 Overall Estimates of Land Acquisition and R&R

1.6 Preparation of Resettlement Action Plan

1.6.1 RAP Preparation Methodology
1.6.2. Cut-off date for the RAP

1.6.3 Budget required to implement RAP

Chapter 2: Rapid Social Assessment

2.1 Baseline Description of Project Area .

2.2 Local Economy and Culture

2.2.1 Income and poverty level

2.2.2 Occupation pattern

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2.2.3 Land Holding Pattern and Tenure System

2.2.4 Literacy
2.2.5 Health Facilities and Sanitation
2.2.6 Indigenous People

2.2.7 Women Headed household and handicapped

2.3 Land Price

Chapter 3: Measures to Minimize Resettlement

3.1 Introduction

3.2 Potential Project Social Impacts

3.3 Positive Impact of the project
Chapter 4: Census and Socio-Economic Surveys

4.1 The Affected Persons

4.2 Types of Losses
Chapter 5: Consultation and Involvement of PAPs

5.1 Consultations

5.2 FGD Meetings

5.3 National Consultation
Chapter 6: Entitlement Framework

6.1 Land Acquisition and Compensation Policy Matrix

6.2 Compensation Mechanism
Relocation and

6.3 Income Restoration

Chapter 7: Institutional Arrangements

7.1 Institutional Set-up

7.2 Monitoring, Evaluation and Assessment

7.2.1 Social Monitoring Indicators

7.3 Grievance Redress Mechanism (GRM)

7.3.1 Scope of GRM

7.3.2 Phase One - GRM under Safeguard Issues
7.3.3 Phase Two – Establishment of Implementation Arrangements for Setting up

Project Level GRM

7.3.4 Legal Options to Aggrieved Parties

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7.3.5 Grievance Redress Service of The World Bank

7.3.6 The role and responsibility of NGO

Chapter 8: Implementation Schedule

8.1 Implementation Schedule of Resettlement Plan

Chapter 9: Costs and Budgets

9.1 Budget

9.2 Minimum wage Calculation

9.3 Taxes
9.4 Information Disclosure
9.5 Disclosure

Annexure

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Annex J: Example Outline of Environmental and Social Commitment Plan (ESCP)

The GoB will implement material measures and actions so that the Project is implemented in
accordance with the Environmental and Social Standards (ESSs). This Environmental and Social
Commitment Plan (ESCP) sets out material measures and actions.
Where the ESCP refers to specific plans or other documents, whether they have already been prepared
or are to be developed, the ESCP requires compliance with all provisions of such plans or other
documents. In particular, the ESCP requires compliance with the provisions set out in the ESMF/ESMP,
SEP, LMP, RAP and GAP.
The table below summarizes the material measures and actions that are required as well as the timing
of the material measures and actions. GoB is responsible for compliance with all requirements of the
ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency
or unit referenced in 1 above.
Implementation of the material measures and actions set out in this ESCP will be monitored and
reported to the Bank by GoB as required by the ESCP and the conditions of the legal agreement, and
the Bank will monitor and assess progress and completion of the material measures and actions
throughout implementation of the Project.
As agreed by the Bank and GoB, this ESCP may be revised from time to time during Project
implementation, to reflect adaptive management of Project changes and unforeseen circumstances or
in response to assessment of Project performance conducted under the ESCP itself. In such
circumstances, GoB will agree to the Bank's changes and update the ESCP to reflect such changes.
Agreement on changes to the ESCP will be documented through the exchange of letters signed between
the Bank and the GoB. The GoB will promptly disclose the updated ESCP.
Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks
and impacts during Project implementation, the GoB shall provide additional funds, if needed, to
implement actions and measures to address such risks and impacts, which may include relevant
environmental and social risks (including, but not limited to health and safety impacts, labor influx,
Gender Based Violence (GBV) etc.).

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