Final Report

Environmental Impact Assessment Study

for Netrokona Economic Zones
 Acknowledgements

The Center for Environmental and Geographic Information Services (CEGIS) would like to
express its heartfelt thanks and gratitude to Mr. Paban Chowdhury, Executive Chairman
(Secretary), Bangladesh Economic Zones Authority (BEZA) for awarding the assignment of
Consultancy Services titled “Environmental Impact Assessment (EIA) Study of Netrokona
Economic Zone” Project.
CEGIS is also grateful to Mr. Ashoke Kumar Biswas (Additional Secretary), Executive
Member (Planning & Development), Mr. Md. Moniruzzaman, Joint Secretary (General
Manager, Investment Promotion) and Doyananda Debnath, Deputy Chief Manager (MIS &
Research) and Project Director, for extending their cordial cooperation and continuous
guidance to the Study Team from the very beginning in conducting the study. CEGIS is very
thankful to Dr. Tanveer Ahmed (Environment Specialist), Mr. Md. Abdul Quader Khan
(Social Consultant) and Md. Ashraful Islam (Legal Consultant) for their valuable support.
The EIA Team of CEGIS express its gratitude to the District Commissioner (DC), Netrokona
District, and Upazila Nirbahi Officer, Netrokona Sadar for their all-out cooperation during the
field visit and consultation process. The Team is also grateful to all respondents
/stakeholders for providing valuable data/information and participation in the group
discussions and consultation meetings.

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 Table of Contents

Acknowledgements ............................................................................................. i
List of Tables ................................................................................................... viii
List of Figures .................................................................................................... x
Abbreviations and Acronyms ........................................................................... xiii
Executive Summary ......................................................................................... xix
1. Introduction ................................................................................................. 1
1.1 Background ............................................................................................... 1
1.2 Project Brief .............................................................................................. 2
1.3 Rationale of the Project .............................................................................. 7
1.4 Scope of the Study ................................................................................... 10
1.5 EIA Study Team ....................................................................................... 10
1.6 Report Structure ...................................................................................... 11
2. Policy, Legal and Administrative Framework .............................................. 13
2.1 Introduction ............................................................................................ 13
2.2 Procedure for Environmental Clearance Certificate ....................................... 13
2.3 Organizations Related with Enforcement of Environmental Standards ............. 14
2.4 National Legislations Relevant to Environment ............................................. 15
2.5 National Legislations Relevant to the Project (Other than Environment) .......... 16
3. Approach and Methodology ........................................................................ 23
3.1 EIA Process and Approach ......................................................................... 23
3.1.1 Project Desgn and Description ............................................................ 23
3.1.2 Policies and Legal Issues ................................................................... 24
3.1.3 Environmental and Social Baseline ...................................................... 24
3.1.4 Important Environmental and Social Component (Scoping) .................... 27
3.1.5 Bounding ......................................................................................... 27
3.1.6 Impact Assessment and Mitigation ...................................................... 29
3.1.7 Environmental Management and Monitoring Plan .................................. 31
3.1.8 Public Consultations and Disclosure .................................................... 31
4. Project Description ..................................................................................... 33
4.1 Introduction ............................................................................................ 33
4.2 Project Objective and Expected Benefits ..................................................... 33
4.3 Project Components and Activities ............................................................. 34
4.4 Master Plan of Netrokona EZ ..................................................................... 34
4.4.1 Layout and Zoning ............................................................................ 34

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 4.4.2 Plots and General Land Use and Landscape Regulation .......................... 38
4.4.3 Parking and Traffic Management Regulations ....................................... 38
4.4.4 Entry and Gate System ..................................................................... 39
4.4.5 On-site Infrastructure ....................................................................... 39
4.4.6 Land Development by earthfilling ....................................................... 52
4.4.7 Off-site Infrastructure ....................................................................... 52
4.4.8 Utility Demand and Sources ............................................................... 53
4.4.9 Project Cost ..................................................................................... 55
4.4.10 Investment Plan ............................................................................... 55
5. Alternative Analysis ................................................................................... 57
5.1 Introduction ............................................................................................ 57
5.2 “No Action” Alternative ............................................................................. 57
5.3 Evaluation of Alternative Site..................................................................... 57
6. Environmental and Social Baseline ............................................................. 59
6.1 Introduction ............................................................................................ 59
6.2 Physical Environment ............................................................................... 59
6.2.1 Meteorology and Climate ................................................................... 59
6.2.2 Topography ..................................................................................... 63
6.2.3 Ambient Noise Level ......................................................................... 63
6.2.4 Ambient Air Quality .......................................................................... 67
6.2.5 Surface Water Hydrology ................................................................... 68
6.2.6 Groundwater Hydrology .................................................................... 78
6.2.7 Drought .......................................................................................... 85
6.2.8 Surface Physiography and Geology ..................................................... 85
6.2.9 Seismic Analysis ............................................................................... 86
6.3 Biological Environment ............................................................................. 88
6.3.1 The Bio-ecological Zone .................................................................... 88
6.3.2 Ecosystem ....................................................................................... 90
6.3.3 Fisheries Resources .......................................................................... 95
6.3.4 Agriculture..................................................................................... 100
6.3.5 Livestock and Poultry ...................................................................... 116
6.4 Socio-economic Resources ...................................................................... 118
6.4.1 Demographic Profile........................................................................ 118
6.4.2 Land Price ..................................................................................... 119
6.4.3 Employment and Livelihood ............................................................. 120
6.4.4 Literacy Rate ................................................................................. 121
6.4.5 Household Income and Expenditure .................................................. 122
6.4.6 Poverty ......................................................................................... 122
6.4.7 Standard of Living .......................................................................... 122

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 6.4.8 Communication System ................................................................... 125
6.4.9 Social Conflicts ............................................................................... 126
6.4.10 Archeological Sites and Cultural Heritage ........................................... 126
6.4.11 Ethnic Community, Religion and Culture ............................................ 127
7. Identification and Analysis of Key Environmental Issues ......................... 129
7.1 Introduction .......................................................................................... 129
7.2 Environmental Sensitivity Investigation .................................................... 129
7.3 Environmental Asset ............................................................................... 129
7.4 Environmental Hotspots .......................................................................... 132
7.5 Impact Screening ................................................................................... 132
8. Environmental and Social Impacts ........................................................... 135
8.1 Introduction .......................................................................................... 135
8.2 Impacts during Pre-construction Phase ..................................................... 135
8.2.1 Physical Environment ...................................................................... 135
8.2.2 Biological Environment .................................................................... 135
8.2.3 Socio-economic Environment ........................................................... 136
8.3 Impacts during Construction Phase .......................................................... 136
8.3.1 Physical Environment ...................................................................... 136
8.3.2 Biological Environment .................................................................... 138
8.3.3 Socio-economic environment ........................................................... 140
8.4 Impacts during Operation Phase .............................................................. 141
8.4.1 Physical Environment ...................................................................... 141
8.4.2 Biological Environment .................................................................... 144
8.4.3 Socio-economic Environment ........................................................... 145
8.5 Impact Evaluation .................................................................................. 146
9. Environmental and Socio-economic Impact Mitigation Measure ............... 151
9.1 Environmental Impact and Mitigation Plan during Pre-Construction Phase ..... 151
9.2 Socio-Economic Impact and Mitigation Plan during Pre-Construction Phase ... 152
9.3 Environmental Impact and Mitigation Plan during Construction Phase ........... 153
9.4 Socio-Economic Impact and Mitigation Plan during Construction Phase ......... 160
9.5 Environmental Impact and Mitigation Plan during Operation Phase ............... 164
9.6 Socio-Economic Impact and Mitigation Plan during Operation Phase ............. 172
10. Public Consultation and Disclosure .......................................................... 175
10.1 Introduction .......................................................................................... 175
10.2 Objectives and Purpose of Stakeholder Consultation ................................... 175
10.3 Identification of Stakeholders .................................................................. 175
10.4 Approach and Methodology ..................................................................... 176

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 10.5 Major Problems and Suggested Measures .................................................. 176
11. Environmental and Social Management Plan ............................................ 181
11.1 Introduction .......................................................................................... 181
11.2 Objective of Environmental and Social Management Plan ............................ 181
11.3 Management Responsibility/Inclusion of EMP in Contract Documents ............ 181
11.4 Environmental Code of Practices .............................................................. 182
11.5 ESMP during Pre-construction .................................................................. 182
11.6 ESMP during Construction ....................................................................... 185
11.7 ESMP during Operation Phase .................................................................. 190
11.8 Special Environmental and Social Management Plan ................................... 197
11.9 Environmental and Social Management (ESMP) Cost .................................. 204
12. Disaster Impact, Hazard and Risk Assessment ......................................... 209
12.1 Introduction .......................................................................................... 209
12.2 Hazard Identification and Risk Assessment Process .................................... 209
12.3 Natural Disasters and Risk Management ................................................... 209
12.4 Climate Change Impact and Vulnerabilities ................................................ 212
12.4.1 Historical Climatic Trends ................................................................ 212
12.5 Future Climate Projection and Impacts of Climate Changes ......................... 214
12.5.1 Future Temperature and Rainfall Projections ...................................... 214
12.5.2 Flash Flood .................................................................................... 215
12.5.3 Monsoon Flood ............................................................................... 216
12.5.4 Hailstorm ...................................................................................... 219
12.5.5 Drought ........................................................................................ 219
12.5.6 Cold Snap ...................................................................................... 219
12.6 Emission of Short Lived Climatic Pollutant ................................................. 220
12.7 Climate Change Adaptation and Mitigation ................................................ 221
12.8 Technological Disasters and Risk Management ........................................... 222
12.9 Occupational Hazard and Safety .............................................................. 222
12.10 Emergency Management Strategy ........................................................... 231
12.10.1 On-site Emergency Response Plan .................................................... 231
12.10.2 Communication Plan ....................................................................... 231
12.10.3 Emergency Evacuation .................................................................... 232
12.10.4 Emergency Response Organization ................................................... 232
13. Environmental and Social Monitoring Plan ............................................... 235
13.1 Monitoring Plan ...................................................................................... 235
13.1.1 Compliance Monitoring .................................................................... 235
13.1.2 Impact Monitoring during Construction .............................................. 235

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 13.1.3 Independent/External Monitoring...................................................... 235
13.2 Implementation of Environmental Monitoring Plan ...................................... 246
13.2.1 Responsible Agency ........................................................................ 246
13.3 Action during Emergent Operation ........................................................... 247
13.4 Performance Indicators ........................................................................... 247
13.5 Reporting and Feedback Mechanism ......................................................... 248
13.6 Budgets for Monitoring ........................................................................... 248
13.7 Organogram and Staffing for Ensuring ESMP and Environmental Monitoring .. 249
14. Conclusions and Recommendations ......................................................... 251
References ..................................................................................................... 253
Appendix I: Matrix of Comments and Reponses on the Draft Report .............. 255
Appendix II: Approved ToR and Exemption of IEE ......................................... 261
Appendix III: Participants List ....................................................................... 265
Appendix IV: Photographs of the Stakeholder Consultation Meetings ............ 269
Appendix V: Environmental Code of Practices ................................................ 271
Appendix VI: Scanned Copy of Surface Water Test Results ............................ 297
Appendix VII: Scanned Copy of Ground Water Test Results ........................... 303

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 List of Tables

Table 3.1: Sampling locations ID and Name with Longitude-Latitude ......................... 25

Table 3.2: Air Quality Sampling Time schedule........................................................ 25
Table 3.3: Definition of the Magnitude Classes and Parameters ................................. 29
Table 3.4: Scoring Criteria for Magnitude Assessment .............................................. 30
Table 3.5: Definitions of the Sensitivity Classes ...................................................... 30
Table 3.6: Cross Tabular Matrix for Assessing Significance ....................................... 31
Table 4.1: Salinet Features of NEZ ........................................................................ 33
Table 4.2: Project activities in different phases ....................................................... 34
Table 4.3: Zoning of NEZ ..................................................................................... 34
Table 4.4: Allocated land area for different zones and facilities ................................. 36
Table 4.5: Utility Demand .................................................................................... 53
Table 4.6: Details of Cost Estimation of the Netrokona EZ ........................................ 55
Table 5.1: Analysis of Alternative Sites .................................................................. 58
Table 6.1: Baseline noise level monitoring data ....................................................... 65
Table 6.2: Air Quality Monitoring Locations and Sampling Durations .......................... 68
Table 6.3: Baseline Air Quality Monitoring Data of NEZ ............................................ 68
Table 6.4: Inundated Area under Different Water Level of Kangsha River ................... 76
Table 6.5: Baseline surface water quality monitoring sites ........................................ 76
Table 6.6: Baseline surface water quality monitoring data ........................................ 78
Table 6.7: The Lithology of the Area at Different Depths .......................................... 79
Table 6.8: Baseline groundwater quality monitoring sites ......................................... 82
Table 6.9: Groundwater quality monitoring data ..................................................... 84
Table 6.10: Aquatic Vegetation of the Project Area .................................................. 91
Table 6.11: Fish Habitat Assessment of the Study Area ............................................ 97
Table 6.12: Fish Species with IUCN Status ............................................................. 98
Table 6.13: Fish Production Assessment of the Study Area ....................................... 99
Table 6.14: AEZ in the Project Area and Study Area .............................................. 100
Table 6.15: Land Use Pattern in both the Project and Study Area ............................ 103
Table 6.16: Area under Land Types in the Project Area and Study Area ................... 106
Table 6.17: Soil Texture in the Project Area and Study Area ................................... 108
Table 6.18: Drainage Characteristics in the Project and Study Area ......................... 110
Table 6.19: Cropping Patterns in the Project Area and Study Area ........................... 113
Table 6.20: Cropped Area, Yield and Production of the Project Area and Study Area .. 115
Table 6.21: Agricultural Inputs Used in the Project and Study Area ......................... 116
Table 6.22: Status of Livestock/Poultry in the Project and Study Impact Area ........... 116

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Table 6.23: Major Diseases of Livestock and Poultry in Study Area .......................... 118
Table 6.24: Demographic Profile ......................................................................... 118
Table 6.25: Dependency Ratio in the Study Area ................................................... 119
Table 6.26: Land Price for Some Specific Location ................................................. 120
Table 6.27: Connectivity and Surroundings of Proposed Project Site ........................ 126
Table 7.1: Activity-wise Impacts Screening .......................................................... 133
Table 8.1: Impact Evaluation .............................................................................. 148
Table 10.1: Stakeholders Involved into the Project ................................................ 176
Table 10.2: Location of Consultation and Discussion during the Field Visit ................ 176
Table 10.3: Major Problems and Suggested Solution by the Stakeholders ................. 178
Table 11.1: Proposed livelihood restoration program ............................................. 184
Table 11.2: Cost for Environmental and Social management Plans .......................... 205
Table 12.1: Summary of the Natural Disaster, their Consequences and Management . 210
Table 12.2: Annual Average Temperature Anomalies in the North-East Bangladesh ... 215
Table 12.3: Prediction for Change in Seasonal Maximum and Minimum Temperature . 215
Table 12.4: Annual Average Rainfall Anomalies in the North-East Bangladesh ........... 215
Table 12.5: Prediction for Change in Seasonal Rainfall ........................................... 215
Table 12.6: Summary statistics of the flood extents (% area inundated) in pre-monsoon
period (Year 2005 – 2017) ................................................................................. 216
Table 12.7: Hazards and Risk Assessment ............................................................ 223
Table 12.8: Occupational Hazards and Safety ....................................................... 225
Table 13.1: Environmental Compliance Monitoring Plan .......................................... 236
Table 13.2: Impact Monitoring Plan ..................................................................... 243
Table 13.3: Environmental Compliance Monitoring Cost ......................................... 248
Table 13.4: Investment Cost of Environmental Monitoring ...................................... 249
Table 13.5: Cost of Independent Monitor ............................................................. 249

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 List of Figures

Figure 1.1: Proposed Netrokona Economic Zone ........................................................ 4

Figure 1.2: Base Map of the Proposed Netrokona Economic Zone (1km radius) ............. 5
Figure 1.3: Base Map of the Proposed Netrokona Economic Zone (10km radius) ........... 6
Figure 1.4: Land use Plan Map ................................................................................ 8
Figure 1.5: Communication network/connectivity ...................................................... 9
Figure 3.1: Environmental Impact Assessment Process ............................................ 23
Figure 3.2: View of Air Quality Monitoring at Singher Bangla (AQ1) ........................... 25
Figure 3.3: View of Air Quality Monitoring at Chan Mia Mor (AQ2) & Durgasrom (AQ3) 25
Figure 3.4: Air Quality and Noise Monitoring Locations ............................................. 26
Figure 3.5: EIA Study Area including Project Area ................................................... 28
Figure 4.1: Proposed Zoning of the NEZ Area ......................................................... 35
Figure 4.2: General Layout and Plotting of the NEZ ................................................. 37
Figure 4.3: Cross-section of a four-lane road ......................................................... 39
Figure 4.4: A Typical Utility Duct ........................................................................... 40
Figure 4.5: A Typical Lighting Arrangement ............................................................ 40
Figure 4.6: Schematic Diagram Showing Artificial Recharge of Aquifer ....................... 42
Figure 4.7: Layout of Water Supplly System and Provision of Lake to Preserve Rainwater
......................................................................................................................... 43
Figure 4.8: A General Layout of the Storm Water Drainage System ........................... 44
Figure 4.9: A General layout of Domestic Wastewater Collection System Network ....... 45
Figure 4.10: A General Layout of the Effluent Collection Network .............................. 46
Figure 4.11: A General Layout of the WWTP and CETP Discharge Drain ...................... 47
Figure 4.12: Layout Plan of Integrated Waste Management Facilities ......................... 49
Figure 4.13: Elevation and Floor Plan of the Secondary Transfer Station .................... 50
Figure 4.14: Process Diagram of Medium Loaded Activated Sludge Treatment ............ 51
Figure 4.15: Land development and Slope Protection ............................................... 52
Figure 4.16: Off-site Transportation (Rail, Road and Navigation) Connectivity ............. 54
Figure 5.1: Map showing two alternative sites of proposed NEZ ................................ 57
Figure 6.1: Monthly maximum, minimum and average rainfall at Netrokona BWDB
station and Mymensingh BMD station .................................................................... 60
Figure 6.2: Annual rainfall at Netrokona BWDB station and Mymensingh BMD station .. 60
Figure 6.3: Monthly maximum and minimum temperature at Mymensingh BMD station 61
Figure 6.4: Monthly relative humidity at Mymensingh BMD station ............................ 61
Figure 6.5: Monthly Average Wind Speed at Mymensingh BMD Station ...................... 62
Figure 6.6: Wind Rose Diagram at Mymensingh BMD Station; (i) Winter, (ii) Pre-
monsoon, (iii) Post monsoon), (iv) Monsoon ........................................................... 62

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Figure 6.7: Topography of Bangladesh and Digital elevation map of the project area ... 63
Figure 6.8: Noise Level monitoring Sites ................................................................ 66
Figure 6.9: Sensitive receptors around the project area ........................................... 67
Figure 6.10: River and canal network around the project area .................................. 69
Figure 6.11: Water Discharge Simulated Data of Kangsha and Mogra Rivers ............... 70
Figure 6.12: Water Level Hydrographs for 10 Year Return Period at Jaria-Jhanjail and
Mohanganj Station (Kangsha River) ....................................................................... 71
Figure 6.13: Maximum-minimum Water Level at Jaria-Jhanjail and Mohanganj Station
(Kangsha River) .................................................................................................. 71
Figure 6.14: Water Level Hydrographs for 10 Year Return Period and Maximum-minimum
Water Level at Atpara Station (Mogra River) ........................................................... 71
Figure 6.15: Existing Water Management Infrastructure within the Study Area ........... 73
Figure 6.16: Thakurakona and Krishnapur Sluice Gate ............................................. 74
Figure 6.17: Physical Conditions of the Sluice Gates ................................................ 74
Figure 6.18: Area Elevation Curve of the Project Area .............................................. 75
Figure 6.19: Surface Water Quality Monitoring Sites ................................................ 77
Figure 6.20: Borelog Characteristics and Specific Yield at Depths under Ground Level of
Netrokona Sadar ................................................................................................. 80
Figure 6.21: Depth of Dry-period Groundwater and Difference between Potential and Net
Recharge of Groundwater of Bangladesh ................................................................ 81
Figure 6.22: Groundwater Quality Monitoring Sites .................................................. 83
Figure 6.23: Annual Standardized Precipitaion Index of Netrokona Sadar Upazila ........ 85
Figure 6.24: Geology of Bangladesh ...................................................................... 86
Figure 6.25: Seismic zones of Banlgadesh .............................................................. 87
Figure 6.26: Map of Bio-ecological Zones of Bangladesh........................................... 89
Figure 6.27: Pond Heron in a Feeding Habitat at Soail Beel ....................................... 92
Figure 6.28: Little Egret in Social Interactions at Komol Beel .................................... 92
Figure 6.29: Homestead Vegetation at Borni Village ................................................ 93
Figure 6.30: Roadside Vegetation at Singher Bangla ................................................ 93
Figure 6.31: Present Situation of Project Area ......................................................... 96
Figure 6.32: Various Fish Species of Fish ................................................................ 97
Figure 6.33: Catching Fish in the Study Area ........................................................ 100
Figure 6.34: AEZ Map of the Study Area .............................................................. 102
Figure 6.35: Land Use Map of the Project Area ...................................................... 104
Figure 6.36: Land Use Map of the Study Area ....................................................... 105
Figure 6.37: Land Type Map in the Study Area ...................................................... 107
Figure 6.38: Soil Texture Map of the Study Area ................................................... 109
Figure 6.39: Drainage Characteristics Map in the Study Area .................................. 111
Figure 6.40: Present Farming Practices in the Project Area ..................................... 114

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Figure 6.41: Present Farming Practices in the Study Area ....................................... 114
Figure 6.42: Livestock and Poultry are in Project and Study Area ............................ 117
Figure 6.43: Age structure by population ............................................................. 119
Figure 6.44: Employment Status of the Study Area ............................................... 120
Figure 6.45: Occupation Status of the Studied Population....................................... 121
Figure 6.46: Literacy Rate among the Studied Population ....................................... 121
Figure 6.47: Household Income and Expenditure of the Study Area ......................... 122
Figure 6.48: Housing Condition by Households ...................................................... 123
Figure 6.49: Source of Drinking Water used by the Studied Population .................... 124
Figure 6.50: Hand Tubewell for Drinking Water and other Domestic Use .................. 124
Figure 6.51: Deep Tubewell used for Irrigation and Drinking ................................... 124
Figure 6.52: Sanitation Facility in the Study Area .................................................. 125
Figure 6.53: Pucca Road inside the Project Area .................................................... 126
Figure 6.54: Netrokona to Mohanganj Railway Line ............................................... 126
Figure 6.55: Abandoned Zamindar Residence in Singher Bangla .............................. 127
Figure 6.56: Garo Community in Bhattapara, Rouha upazila, Netrokona ................... 128
Figure 6.57: Khatriya (Hindu cast group) Community in Shogundia, Mougati Union,
Netrokona ........................................................................................................ 128
Figure 11.1: Tentative layout options of dredging pipeline ...................................... 198
Figure 11.2: General waste flow diagram for industrial symbiosis ............................ 199
Figure 11.3: Overall concept of Resource Efficiency and Cleaner Production .............. 201
Figure 12.1: Annual Cumulative rainfall (1981-2017) at Netrakona ......................... 213
Figure 12.2: Annual Average Maximum temperature (1981-2017) at Netrakona ....... 213
Figure 12.3: Annual Average Minimum temperature (1981-2017) at Netrakona ........ 214
Figure 12.4: Peak flood level at Sylhet during April against different return periods
(CEGIS, 2017) .................................................................................................. 216
Figure 12.5: Water level hydrograph at Jariajanjail in Kangsha river Thunderstorm ... 217
Figure 12.6: Rate of Fatalities and Injuries during different seasons ........................ 217
Figure 12.7: Lightning occurrence from 1990-2017 in Netrakona ............................ 218
Figure 12.8: Number of Lightening at Netrakona from 1990-2017 ........................... 218
Figure 12.9: Season wise Intensity of Hailstorm in Sylhet ...................................... 219
Figure 12.10: Cold Wave Days in Sylhet from 1990-2017 ....................................... 220
Figure 12.11: Emergency Evacuation Plan ............................................................ 234
Figure 13.1: Proposal Institutional Setting for Environmental Compliance and EHS Unit
during Construction ........................................................................................... 249
Figure 13.2: Proposed Institutional Setting and Organogram for the Environmental
Compliance and EHS Unit during the Operation of the NEZ ..................................... 250

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 Abbreviations and Acronyms

AEZ : Agro-ecological Zone

AEZ-22 : Northern and Eastern Piedmont Plains
AEZ-9 : Old Brahmaputra Floodplain
BARC : Bangladesh Agricultural Research Council
BBS : Bangladesh Bureau of Statistics
BDT : Bangladeshi Taka
BEPZA : Bangladesh Export Processing Zones Authority
BEZ : Bio-ecological Zones
BEZA : Bangladesh Economic Zone Authority
BGD : Bangladesh
BMD : Bangladesh Meteorological Department
BNBC : Bangladesh National Building Code
BOD : Biological Oxygen Demand
BQ : Black Quarter
BWDB : Bangladesh Water Development Board
CCL : Compensation Under Law
CEGIS : Center for Environmental and Geographic Information Services
CEMP : Construction Environmental Management Plan
CETP : Common Effluent Treatment Plant
CO Carbon monoxide
COD : Chemical Oxygen Demand
CSR : Corporate Social Responsibility
DAE : Department of Agricultural Extension
DC : Deputy Commissioner
DEPC : Department of Environmental Pollution Control
DG : Director General
DIA : Disaster Impact Assessment
DLS : Department of Livestock Services
DMA : District Metered Area
DoE : Department of Environment
DoF : Department of Fisheries

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ECA : Environmental Conservation Act
ECA : Ecologically Critical Area
ECC : Environmental Clearance Certificate
ECR : Environment Conservation Rules
EHS : Environmental Health & Safety
EHSU : Emergency Health and Safety Unit
EIA : Environmental Impact Assessment
EMoP : Environmental Monitoring Plan
EMP : Environmental Management Plan
EMP : Environmental Management Plan
EPC : Engineering, Procurement and Construction
EPZ : Export Processing Zones
ERG : Emergency Response Group
ERP : Emergency Response Plan
ESIA : Environmental and Social Impact Assessment
ESMP : Environmental and Social Management Plan
ESMP : Environmental and Social Management Plan
ETP : Effluent Treatment Plant
EZ : Economic Zone
FAO : Food and Agriculture Organization
FCDI : Flood Control, Drainage and Irrigation
FDI : Foreign Direct Investments
FGD : Focused Group Discussion
FMD : Foot and Mouth Disease
FRSS : Fisheries Resources Survey System
FS : Feasibility Study
FY : Financial Year
GDP : Gross Domestic Product
GIS : Geographic Information System
GoB : Government of Bangladesh
GPS : Global Positioning System
GRC : Grievance Redress Committee
GRM : Grievance Redress Mechanism

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GTCL : Gas Transmission Company Limited
HHs : Households
HS : Hemorrhagic Septicemia
HVAC : Heating, Ventilation, and Air Conditioning
HYV : High-Yielding Varieties
IEE : Initial Environmental Examination
IESC : Important Environmental and Social Components
IESMC : Independent Environmental and Social Monitoring Consultant
IFC : International Finance Corporation
ILO : International Labour Organization
IPM : Integrated Pest Management
IRT : Incident Response Team
IUCN : International Union for Conservation of Nature
IWM : Institute of Water Modelling
Kharif-1 : March-June
Kharif-II : July-October
KII : Key Informant Interview
KV : Kilovolt
LGRC : local Grievance Redress Committee
LLP : Low Lift Pump
MO : Muriate of Potash
MoEF : Ministry of Environment and Forest
MoWR : Ministry of Water Resources
MSDS : Material Safety Data Sheets
MT : Metric Ton
MW : Megawatt
NATECH Natural Hazard Induced Technological Disaster
NCA : Net Cultivable Area
NEZ : Netrokona Economic Zone
NEZA : Netrokona Economic Zone Authority
NOx Oxides of Nitrogen
NT : Near Threatened
NWRC : National Water Resources Council

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NWRD : National Water Reuse Database
O3 : Ozone
OHS : Occupational Health and Safety
OHSE : Occupational Health, Safety and Environment
PCM : Public Consultation Meeting
PDO : Project Director Office
PGRC : Project Grievance Redress Committee
pH : Potential of Hydrogen
PIU : Project Implementation Unit
PMO : Prime Minister’s Office
PPE : Personal Protection Equipment
PPP : Public-Private Partnership
PPR : Diarrhoea and Pest Des Petits Ruminants
PSC : Project Steering Committee
RMG : Ready-Made Garments
RRA : Rapid Rural Appraisal
RS : Remote Sensing
SAAO : Sub-Assistant Agriculture Officer
SCC : Site Clearance Certificate
SDS : Safety Data Sheets
SME : Small and Medium-sized Enterprises
SO2 : Sulfur Di-Oxide
SPI : Standardized Precipitation Index
SPM : Suspended Particulate Matter
SRDI : Soil Resource Development Institute
SSP : Single Super Phosphate
STP : Sewerage Treatment Plant
STW : Shallow Tube Well
TDS : Total Dissolved Solids
ToR : Terms of Reference
TSP : Triple Super Phosphate
TSS : Total Suspended Solids
UAO : Upazila Agriculture Officer

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UFO : Upazila Fisheries Office
ULO : Upazila Livestock Officer
UNDP : United Nations Development Programme
UNO : Upazila Nirbahi Officer
WARPO : Water Resources Planning Organization
WASA : Dhaka Water Supply and Sewerage Authority
WHO : World Health Organization
WWTP : Waste Water Treatment Plant

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xviii
 Executive Summary

With the pace of current economic growth, the government of Bangladesh has planned to
establish 100 Economic Zones (EZ) countrywide by 2030, intending to earn around $40
billion through export. Accordingly, Bangladesh Economic Zones Authority (BEZA) was
formed following the Bangladesh Economic Zones Act, 2010 to establish, license, operate,
manage and control economic zones in Bangladesh. In line, BEZA has planned to establish
an Economic Zone over 500-acre of land located at Sadar Upazila of Netrokona District. The
construction of Netrokona Economic Zone (NEZ) includes three major components: i)
development of 500 acre land for the NEZ, ii) construction of on-site infrastructures for
utilities including roads, power lines, water supply, effluent treatment plant, sludge treatment
plant, waste management system, administrative buildings, etc. and iii) off-site connectivity
and infrastructures. The BEZA evaluated two candidate sites at Netrokona for the proposed
economic zone viz. i) Singher Bangla Site and ii) Beel Guzabugi site. According to study
findings, the Singher Bangla site would have low impacts on socio-economy due to no
acquisition of homesteads and other factors; therefore, Singher Bangla site has been
selected for the development of NEZ.
Such as project and activities, according to the Environment Conservation Rules (ECR)
1997, amended in December, 2017, requires approval from the Department of Environment.
The ECR categorizes different industries/projects/units into three broad types: Green,
Orange, and Red, of which the proposed NEZ falls into Red category. In principle, the Red
category project requires ‘Site Clearance Certificate’ (SCC) through an approval of Initial
Environmental Examination (IEE), followed by Environmental Impact Assessment (EIA)
according to approved ToR for getting Environmental Clearance Certificate (ECC). However,
BEZA received an exemption from IEE, hence SCC, upon submission of an application to
the DG, DoE considering importance of the project to boost up economy of the country to
fulfill its targeted objectives to become a middle-income country by 2021 and a developed
country by 2041. Thus, EIA and ECC is required only for carrying out the project, for which
DoE already approved a ToR, following which this EIA has been prepared.
This EIA study follows the participatory approach and a standardized methodology from
beginning to the end of the study trajectory. Both primary and secondary stakeholders were
consulted at different layers through different consultation meetngs. The study steps
included: baseline assessment, scoping, bounding, major field investigation, impact
prediction, mitigation measures, environmental management and monitoring plan.
In describing the existing condition, three environmental components: physical, biological
and socio-economic environment were assessed. The physical environment includes:
meteorology, topography, ambient noise, ambient air quality, surface and ground water. The
biological environment includes: ecology, fishery, agriculture and land resources. The socio-
economic environment includes conditions of social/economic and cultural parameters in the
study area.
With respect to physical environment, it was found that the highest rainfall occurred during
April to October while November to March was the drier part of the year with very less
rainfall. On the other hand, the highest maximum temperature was recorded as 38.1o C in
April of 1992 and the lowest minimum temperature was recorded as 4.7o C in January of
2013. The highest values of humidity for all the months were recorded as 100% whereas the

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minimum values ranged between 20% and 51%. The most humid months were from June to
October.
The general topography of the project area is more or less flat with an elevation of 6.6 to 8.1
mPWD. Out of this area, 37% is highland and 34%, 21% and 7% are medium highland,
medium lowland and lowland respectively. The area of the Komol Beel is approximately 43
acres although retention of water varies at different times of the year. At the time of survey,
the noise level inside the project area was found very calm and low whereas, at several
points surrounding the project area, medium to heavy noise was observed. The places were
recognized mostly as lightly dense residential areas. The existing air quality of the proposed
NEZ area as well as the surroundings were observed to be good. Within the project area the
predominant anthropogenic interventions were observed as farming of crops throughout the
year and for fishing for a certain period of the year.
There are three significant rivers in the study area namely; Kangsha River which is 3~4 km
north to the project area, Mogra River which is 4~5 km south to the project area and Dhalai
river. There are a number of perennial and seasonal beels within the study area: Kuria beel,
Kalabagua beel, Nalghuria beel, Megha beel, Joga Beel, Hailda beel, Komol Beel, Soai beel
etc. Among these, Komol Beel and Soai beel are located within the project area although at
present the Soai beel area is almost dry and used for agricultural purpose. The Komol Beel
is connected to the Kangsha River in the north through internal drainage (Fazar ali canal)
channel. Groundwater is the main source of drinking water for the people living around the
project area as well as in the adjacent area. Analysis of the existing bore logs of Netrokona
Sadar upazila shows that layers of fine to medium sand exist below the surface at different
depths. In one borehole of 59.45 m depth at Netrokona Sadar mouza, fine to medium sand
was found at a depth of 12 m to 29 m and medium sand was observed from 55 m to 59 m
depth.
The study area is in Brahmaputra-Jamuna Floodplain Bio-ecological Zone. Generally, the
vegetation of the area includes: i) submerged plants, ii) free floating plants, iii) rooted floating
plants, iv) sedges and meadows, v) floodplain grassland, vi) crop field vegetation, vii)
roadside vegetation, and viii) homestead vegetation. The project area is also under the Old
Brahmaputra Floodplain (AEZ-9) and Northern and Eastern Piedmont Plains (AEZ-22) agro-
ecological regions. The Net Cultivable Area (NCA) in the project area and Study area are
455 acres and 54,859 acres respectively. There are four land types within the study area
Among the land types, Medium Highland (F1) is dominant (47%) followed by Highland (F0)
which is 26% of the NCA.
The Population in the study area is 531,806 of which 265,632 are males and 266,175 are
female. The average size of the household is 4.7. Agriculture is the dominant source of
livelihood for local people. About 87% households are involved in this sector either directly or
indirectly. Only 3% people are involved in industrial sectors usually working in brickfields,
roads and construction works and many other non-farming sectors. Traditionally,
employment opportunities for women outside the homestead is very limited. Majority of the
women are involved in household activities (e.g. in rice milling, weaving etc.).
Apprehending the project driven impacts on environmental and social parameters, a number
of key issues were identified to assess the potential impacts and their magnitudes. The key
issues are: i) air quality, ii) noise quality, iii) groundwater, iv) surface water, v) drainage and
water logging, vi) flooding, vii) land type, viii) landscape, ix) land use, x) crop production, xi)
fish habitat, xii) fish production, xiii) fish species diversity, xiv) stock susceptibility, xv) wildlife

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 Executive Summary

habitat, xvi) species composition, xvii) dispossession, xviii) livelihoods loss, xix) social
conflict, and xx) employment generation, xxi) off-site development, and xxii) urbanization and
economic development.
Impacts on these key issues were assessed by categorizing them into socio-economic and
environmental. According to plan, 500 acres of land will be acquired for the project, for which
rights of landholders and their livelihoods will be impacted. About 2,161 tons rice production
of project area would be permanently lost per year due to the acquisition of land. During land
acquisition total 392 acres fish habitat will be lost. About 243 MT of fish production would
loss annually due to conversion of fish habitat to NEZ. About 15 households are seasonally
dependent on the land for fishing. Besides, about 150 households are directly dependent on
the acquired land for agricultural activities. After the land acquisition, the farmers and
fishermen will lose their livelihoods. Moreover, 13 Garo households (ethnic group) are
dependent on kuchia catching on the proposed acquired wetland, who will be impacted due
to loss of livelihood. All landholders of the proposed 500 acres of land do not have legal
entitlements, and some have incomplete or no legal documents although they purchased or
occupied land. Thus, people “without documents” are not eligible to get compensation
(according to Law) but will be affected, which might lead to local agitation/conflict.
With respect to environmental impacts, ambient air quality will be deteriorated due to dust
generated from vehicular movements and gaseous emissions of the construction vehicles
and equipment, and alongside, noise will be generated. Due to the land development and
the construction of on-site structures, the natural drainage pattern may get temporarily
blocked at certain places by the land soil and construction debris which can occur water
logging problems in case of heavy rainfall. In addition, during the wet periods floodwater may
not pass through the natural ways and hence can cause water logging at the northeast
corner of the project area as floodwater flows over the project area through this corner.
Groundwater is another important issues for the project. The study area already witnessed
groundwater stress in the past years. Therefore, the withdrawal of groundwater, might cause
depletion of groundwater table, resulting water crisis for the local community and for the
project itself. The project area is the combination of terrestrial and aquatic ecosystem, which
includes large trees and roadside vegetation as well as lowland with five beels that has been
recognized as feeding habitats to many resident and migratory waterfowls. Wetland
associated with different aquatic vegetation is providing support to this wildlife for breeding
and escape from predators. Due to land development work, all habitats with associated
vegetation will permanently be damaged. In addition, wildlife habitat in the project-influenced
area will also be deteriorated due to sand mining.
The EIA study proposed a number of environmental and social management measures to be
strictly considered during pre-construction, construction and operation phases of the project.
These plans include: i) Compensation plan, ii) Labor recruitment plan,iii) Livelihood
restoration plan, iv) Stakeholder engagement plan, v) Grievance Redress Mechanism, vi)
Land development management plan, vii) Occupational Health and Safety (OHS) Plan, viii)
Drainage and flood management plan, ix) Water pollution management plan, x) Air pollution
management plan, xi) Noise pollution management plan, xii) Waste management plan, xiii)
Transportation management plan, xiv) Fisheries resources Management Plan, xv)
Prevention of soil spillage to adjacent agricultural land management plan, xvi) Protection of
standing crop management plan, xvii) Water resources management plan, xviii) Green park
management plan, xix) Sustainable land use management plan, xx) Reduce crop damage by
Integrated Pest Management (IPM). In addition, the study also provided some special

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 Executive Summary

Environmental and Social Management Plan, which are essential to consider for this project.
These include: i) Dredging and Land Development Management Plans, ii) Industrial
Symbiosis Plans, iii) Resource Efficiency and Cleaner Production (RECP) Plans, iv) Water
Conservation and Saving Plan, v) Komol Beel management plan, and 2) East-site Gate
Management Plan. Alongside, the cost of implementing ESMP is tentatively estimated BDT
234.7 million. Alongside, ESMP, three types of environmental and social monitoring plan
have been provided in the report: 1) compliance monitoring, 2) impacts monitoring during
construction, and 3) independent/external monitoring. The monitoring cost for the first one is
BDT 51.5 million, for the next one is BDT 73.5 million, and for the last one is BDT 50 million.
By assessing potential disaster, hazard and risk, and climate change issue, the study
suggested some mechanism to be followed for the project. The hazard assessment has
been carried out to identify the potential hazard associated with or inherent in the design
process and to identify possible measures to avoid the hazard along with the safety plan for
minimizing the risk. Incorporation of these measures and safety plans in design, planning
and operational procedure of the proposed NEZ would eliminate the potential hazards.
The proposed project appears as one of the key cornerstones of the country’s development
activites. Similar to other development project, this project will bring negative consequences
for the local envrironment, landowners and dependent communities; but would be mitigated
with propoer measures, management plan and monitoring. Thus, ground water, surface
water networks, waterbody, aqauatic and wildlife, landlosers and dependent population
should be given special focus following the measures suggested in this report. Alongside,
the project will also bring immense positive impacts for local-regional and national economy,
and socio-economic benefits for the communities. Hence, measures suggested in this report
for enhancing of these positive impacts should be given special focus.

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 1. Introduction

1.1 Background
Bangladesh economy has steadily increased its average decadal growth rate over the last
few decades since its independence in 1971. The average growth rate of Gross Domestic
Product (GDP) increased from less than 4% per year during 1970-90 to 4.8% in 1990-2000.
During the last two decades, it rose to 5.8% in 2001-2010, and above 6% during the current
decade (2011-2020). Government of Bangladesh (GoB) has been successfully providing
land, infrastructure, and a favorable business environment through establishing Export
Processing Zones (EPZs) Program in 1980 under the Bangladesh Export Processing Zone
Authority (BEPZA). Since then, the EPZs have been used as a strategic instrument for
attracting Foreign Direct Investments (FDIs) in Bangladesh and in dealing with the
shortcomings in the overall investment climate in Bangladesh. The EPZ program was the
first systematic initiative to provide fully serviced land and a better business environment for
investors, targeting large scale export-oriented manufacturing. Since 1993, EPZs have
triggered impressive growth in exports, mainly in the Ready-Made Garments (RMG) sector,
at an average annual rate of 23 percent, reaching nearly US$5 billion by FY2018 and have
created half a million jobs within the EPZs.
Having a very positive experiences of EPZs the GoB has planned to generate about 10
million employment opportunities and boost up export earnings around $40 billion through
establishment of 100 Economic Zones (EZ) countrywide by 2030. Bangladesh Economic
Zones Authority (BEZA) has been emerged by the Bangladesh Economic Zones Act, 2010
to establish, license, operate, manage and control economic zones in Bangladesh and
accordingly placed under the Prime Minister’s Office (PMO) and governed by a Board
chaired by the Hon’ble Prime Minister. The law provides legal coverage for attracting and
leveraging private investment in the development of economic zones as zone developers or
operators, and in the provision of tailored infrastructure services, such as, private provision
of power, effluent treatment, wastewater treatment etc. The law also allows for development
of EZs and support infrastructure through a Public-Private Partnership (PPP) mechanism.
Keeping the target to be a middle-income country by 2021 and developed country by 2041,
BEZA is working with the aim to establish economic zones in all potential areas in the
country including backward and underdeveloped regions with a view to encouraging rapid
economic development through increasing and diversifying industry, employment, production
and export. For achieving the national agenda, BEZA has got approval to establish 88
Economic Zones (EZ) countrywide comprising 59 under government and the remaining 29
under private initiatives.
In line with the above initiatives, BEZA is planning to establish an EZ at Sadar Upazila of
Netrokona District, for which a Feasibility Study has been carried out by the Institute of
Water Modelling (IWM), a Public Trust under the Ministry of Water Resources (MoWR),
GoB. Since the government intends to establish EZ countrywide, Netrokona has been
selected as a potential area.
In accordance with the Environmental Conservation Act (ECA), 1995 and Environmental
Conservation Rules (ECR), 1997 including related amendments, the proposed Netrokona EZ
(NEZ) falls under “Red” category and requires simultaneously both Site Clearance Certificate
(SCC) and Environmental Clearance Certificate (ECC) upon approval of the Initial

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Environmental Examination (IEE) and Environmental Impact Assessment (EIA) study reports
by the Department of Environment (DoE). Considering the importance of establishing EZ
aiming to fulfil the long vision of GoB, BEZA requested DoE to get necessary exemption
from carrying out IEE for obtaining the SCC. In a request letter, BEZA desired to conduct an
Environmental Impact Assessment (EIA) study based on a Terms of Reference (ToR)
(through attaching with that letter) to obtain ECC from the DoE. Taking the noted issues in
consideration, DoE provided exemption order (vide the Memo no.
22.02.0000.018.72.131.19.569; dated 22 December, 2019) from conducting IEE and
approved the ToR for conducting a comprehensive EIA of NEZ. The copy of DoE’s approved
ToR is attached in at Appendix-II. In order to conduct the EIA, BEZA assigned CEGIS, a
Public Trust under the Ministry of Water Resources (MoWR), GoB Government of
Bangladesh (GoB) for conducting the study.

1.2 Project Brief

The proposed NEZ is located in Netrokona Sadar Upazila of Netrokona District. The District
Headquarter of Netrokona is located about 04 km in the west of proposed NEZ.
Transportation network such as railway, road and navigation route are available in
Netrokona District. However, these transportation networks need improvement. The main
railway station is located in District Headquarters. A highway passes through close proximity
of the NEZ, connects Netrokona Pourashava with Mohanganj Upazila in the east. Sheikh
Hasina University, Netrokona and Netrokona Medical College are located within 03 km of the
NEZ. The river port of Thakurakona is located within 05 km to the east. Major rivers include
Kangsha River located 03 km to the north and Mogra River 04 km to the south. There are a
number of beels namely Kuria Beel, Megha Beel, Joga Beel, Nanghuria Beel, Dharam Beel
etc. within 10 km area of NEZ. The proposed NEZ will be implemented on approximately
500 acres of land. The location of the proposed NEZ is shown in Figure 1.1.
An outline of a Master Plan for the proposed NEZ has been suggested in the Feasibility
Study (FS) Report (September 2019) prepared by IWM. According to the FS Report, the
Master Plan (outline) covers four (4) land zones which are as follows:
Zone A: Large industrial zone for manufacturing units related to Garments and
Integrated Textiles, Food Processing, Ceramics and Pharmaceuticals;
Zone B: Light engineering and small/medium manufacturing units;
Zone C: Residential areas for staffs and their families; and
Zone D: Administrative area.
In addition to above four zones, some space will be allocated for:
i) Green areas, parks, rest house;
ii) Health care facilities, day care center;
iii) Playground, food plaza, shopping malls;
iv) Utility services like water supply, water treatment plant, wastewater treatment
plant, common effluent treatment plant, power sub-station, solid waste
collection stations, fire stations, utility ducts and drainage passages, sludge
management etc.;
v) Parking and logistics;
vi) Security and surveillance;
vii) Education;

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 Introduction

viii) Truck stand and workshop;

ix) Circular 4-lane one-way road;
x) Internal 4-lane road;
xi) Walkways, etc.

In order to make NEZ more attractive to the investors and to make the zones more
technically and economically feasible the proposed Master Plan has outlined a number of
on-site and off-site infrastructures. The on-site infrastructures are:
i. Road Network (Circular Road, Internal roads, Walkway, Bicycle tract);
ii. Utility ducts and drainage passages (water line, cables, electric power lines, gas
pipelines);
iii. Electric Lighting;
iv. Power Supply System;
v. Water Supply;
vi. Sewage Treatment Plant (STP);
vii. Common Effluent Treatment Plant (CETP);
viii. Sludge Management;
ix. Fire Protection;
x. Data Connectivity;
xi. Solid Waste Management; and
xii. Administration/One-stop Service Building and Other Supporting Buildings.
The proposed off-site infrastructures are:
i. Improvement and rehabilitation of adjacent railway line and establishing a railway
station;
ii. Two lane road adjacent to the NEZ to be extended to four lane regional highway
connecting Dhaka and Sylhet (via Tahirpur – Sunamganj);
iii. Upgrade function of nearby river port at Gaglajur Bazar exclusively for the NEZ to
connect with Ashuganj;
iv. Connectivity with Sylhet Osmani International Airport (146 km) through Netrokona-
Tahirpur-Sunamganj-Sylhet highway; and
v. Connectivity with Dhaka Shahjalal International Airport (150km) through
Netrokona-Dhaka highway.

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 Introduction

Figure 1.1: Proposed Netrokona Economic Zone

4
 Introduction

Figure 1.2: Base Map of the Proposed Netrokona Economic Zone (1km radius)

5
 Introduction

Figure 1.3: Base Map of the Proposed Netrokona Economic Zone (10km radius)

6
 Introduction

1.3 Rationale of the Project

Manufacturing sector of industry in Bangladesh shows predominance in export led garments
and textile industries, which makes the country as world’s second largest garment
manufacturer. However, relatively low emphasis was given to other items and export
competiveness of those items were not explored fully. Therefore, the country during the
period of 1980s required to boost up exports of other indigenous products, which was
improperly enhanced due to absence of industrial infrastructure, capacity building, and policy
initiatives. Owing to that, GoB has provided tailored infrastructure services and business
environment conditions through establishing EPZs in the 1980s. The EPZs were used as the
‘strategic instrument’ for attracting FDI and dealing with the shortcomings of the overall
investment climate, business registration, licensing, etc. which, in fact, were restricting
smooth investments in the country. Further, to overcome the limitations of EPZ model, new
EZ regime has been adopted by the GoB, so as, more spill-over can be harnessed by local
firms from FDI, additional investments can be encouraged within the value chains and more
local produce can be procured.
The EZ development, a zoned industrialization, is required in Bangladesh to maximize the
growth benefits of accumulation and ease the increasing urban congestion. More
importantly, the EZ will enable new sources of growth, where investor will show their interest.
In this context, establishment of economic zones is proposed in Netrokona.
According to the Feasibility Study Report of IWM, major economic activities in Netrokona is
wholesale and retail trades (49%) followed by transportation and storage (15%) and
manufacturing (12%). Here, low-intensive manufacturing sector has immense potential.
Bangladesh Bureau of Statistics (BBS) data (2011) shows that about 40% of people are
employed and about 23% have no job, while about 35% are engaged in household activities.
Therefore, these large number of unemployed labors would get employment opportunity in
the NEZ, where the wage rate of un-skilled, semi-skilled and skilled labors is low.
There are some additional advantages of the proposed NEZ, such as, (i) adjacent railway
line; (ii) existing two lane road, which would be extended to four lane regional highway
connecting Dhaka and Sylhet via Tahirpur and Sunamganj, which, in turn, will create
accessibility to Dhaka Shahjalal International Airport (150km) and the Sylhet Osmani
International Airport (146km); (iii) well connectivity with Dhaka (150 km), the center of all
economic, administrative and commercial activities of the country; (iv) availability of
adequate land for establishing EZ; and (v) no major resettlement issue would arise as the
site is totally agricultural land.
Therefore, establishment of the proposed Netrokona Economic Zones would be a potential
Project to boost up local as well as national economy which will enhance the living standard
and quality of life of the local people in particular and of the country as a whole.

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 Introduction

Source: Feasibility Study, IWM, September 2019

Figure 1.4: Land use Plan Map

8
 Introduction

Source: Feasibility Study, IWM, September 2019

Figure 1.5: Communication network/connectivity

9
 Introduction

1.4 Scope of the Study

The scope of work for the EIA Study are to:
a. Review project interventions designed in the Feasibility Study Report and relevant
literatures about the study context;
b. Review legal and policy documents for defining legislative and regulatory
considerations;
c. Prepare detail environmental and socioeconomic baseline of the study area;
d. Identify important environmental and social components;
e. Conduct environmental and social impact assessment against the project
interventions;
f. Prepare Environmental Management Plan (EMP) and estimate EMP cost;
g. Prepare Environmental Monitoring Plan (EMoP) and estimate EMoP cost; and
h. Prepare EIA Report and assist BEZA to obtain ECC from DoE.

1.5 EIA Study Team

Following Key Professionals were engaged in carrying out the EIA Study:
 Dr. Kazi Md. Noor Newaz - Environmental Expert/Team Leader
 Md. Amanat Ullah – Ecologist
 A T M Shamsul Alam - Socio-economist
 Mohammad Abdur Rashid - Agriculture Specialist
 Md. Firoz Alam - GIS and RS Specialist
The Non-Key Professionals engaged in the EIA Study were:
 Pronab Kumar Halder - Field Researcher, Environment
 Dr. Md. Shawkat Islam Sohel - Field Researcher, Water Resources
 Sharmin Akhter - Field Researcher, Fishery Biology
 Md. Alamgir Hossain - Field Researcher, Livelihood
 Farhan Nafis Hridoy - Field Researcher, Civil Engineering
 Vazana Bala Devi - Communications Specialist
The following additional professionals, not specified in the ToR, were deployed by CEGIS for
the interest of carrying out a good quality study:
 Md. Ebrahim Akanda, Agronomist
 Mohammed Mukteruzzaman, Fisheries Biologist
 Dr. Md. Shibly Sadik, Disaster Management Specialist
 Muhammad Shifuddin Mahmud, Social Scientist
 Mohammad Kamruzzaman, Ecologist
 Most. Tania Karim, Junior Agriculturalist

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 Introduction

1.6 Report Structure

The report contains fourteen chapters as follows:
Chapter 1: Introduction contains background, project brief, rationale of the project,
scope of work, EIA study team and structure of the report.
Chapter 2: Policy, Legal and Administrative Framework describes the relevant
policy and legal frameworks for the EIA process.
Chapter 3: Approach and Methodology covers detailed approaches and methods for
conducting EIA study for the proposed Economic Zones (EZ).
Chapter 4: Project Description contains description of technical details of the
proposed EZ and associated on-site and off-site interventions along with
project plan, activities and schedule.
Chapter 5: Alternative Analysis describes all alternative options considered before
finalizing the proposed site.
Chapter 6: Environmental and Social Baseline describes the environmental and
socio-economic baseline condition with detail on physical, biological and
socio-cultural environment of the project and influenced area.
Chapter 7: Identification and Analysis of Key Environmental Issues presents
identified key environmental and social issues are likely to be affected by
the proposed project.
Chapter 8: Environmental and Social Impacts presents the impacts assessed in this
study with respect to identified key environmental and social issues.
Chapter 9: Environmental and Socio-economic Impact Mitigation Measure
describes mitigation measures for each impact
Chapter 10: Public Consultations includes summary of the consultation with interested
parties and the general people including stakeholders with the note to
consider their views in the planning and execution of the project.
Chapter 11: Environmental and Social Management Plan describes the
environmental and social management plan (ESMP) for minimizing the
effect of the negative impacts and enhancement measures for increasing
the benefits of the positive impacts at pre, during and post construction
phases.
Chapter 12: Disaster Impact, Hazard and Risk Assessment describes assumed
impacts, hazards and risks associated with the project activities and
proposes a plan to overcome/mitigate.
Chapter 13: Environmental and Social Monitoring Plan presents monitoring of
environmental and socio-economic parameters at pre, during and post
construction phases.
Chapter 14: Conclusions and Recommendations is the concluding chapter of the EIA
Report with conclusion and recommendations of the EIA study.

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Introduction

12
 2. Policy, Legal and Administrative Framework

2.1 Introduction
In this chapter, all relevant policies and legislations pertaining to the GoB, particularly, the
Environment Conservation Act (ECA) 1995 (with subsequent amendments) and the
Environment Conservation Rules (ECR) 1997, amended in December, 2017 were assessed.
The Project Proponent, Bangladesh Economic Zone Authority (BEZA), will ensure
adherence to all applicable regulations and standards for environmentally acceptable
operation of this Project.
The Netrokona Economic Zone project includes land development activities for industrial
purposes in Netrokona. The Environment Conservation Rules (ECR) 1997, amended in
December, 2017 is the main legal instrument, which obliges industries/projects/units to get
either site and/or environmental clearances from the competent authority. The
Environmental Conservation Act (ECA) 1995 (subsequent amendment 2002), clearly states
in serial no. 12 that an Environmental Clearance Certificate (ECC), that follows the ECR
1997 (with subsequent amendments), must be approved by the Director General (DG) of the
Department of Environment (DoE) prior to establishing/ undertaking any industrial unit/
project. The ECR categorizes different industries/projects/units into three broad types:
Green, Orange, and Red. According to the industrial unit classification, mentioned in the
ECR 1997 (amended), this proposed project is under the ‘Red’ category: serial 39-industrial
estate. The Red category project, primarily requires ‘Site Clearance Certificate’ (SCC)
through approval of Initial Environmental Examination (IEE), followed by Environmental
Impact Assessment (EIA) according to approved ToR for getting Environmental Clearance
Certificate (ECC). However, BEZA received an exemption from IEE, hence SCC, upon
submission of an application to the DG, DoE. Thus, EIA and ECC is required only for
carrying out the project, for which DoE had already approved a ToR, following which this EIA
has been prepared. In the following Sections, summary of relevant legislations and policies
are presented:

2.2 Procedure for Environmental Clearance Certificate

An Environmental Impact Assessment (EIA) report along with necessary documents is
required to be submitted to the DoE for getting Environmental Clearance Certificate (ECC).
DoE will approve the ECC upon its satisfaction. For this project, the steps of getting ECC are
given below:
 Apply to DoE for waiving of Site Clearance Certificate (SCC) through Initial
Environmental Examination (IEE);
 Exemption of IEE and approval of Terms of References (ToR) for Environmental
Impact Assessment (EIA);
 Apply to DoE with the EIA report appending necessary documents for getting
ECC upon the payment of charge;
 Presentation of EIA report to DoE, and upon satisfaction receive ECC.

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 Policy, Legal and Administrative Framework

2.3 Organizations Related with Enforcement of Environmental Standards

Roles and responsibilities of various Ministries and Departments involved in the enforcement
of environmental requirements are described below:

Ministry of Environment and Forest

The Ministry of Environment and Forest (MoEF) is the key Government institution in
Bangladesh for all matters relating to national environmental policy and regulatory issues.
Realizing the ever-increasing importance of environmental issues, the MoEF replaced the
Ministry of Agriculture and Forest in 1989 and is at present a permanent member of the
Executive Committee of the National Economic Council. This is the major decision-making
body for economic policy issues and is also responsible for approving all public investment
projects. The MoEF oversees the activities of the following technical and implementing
agencies.

Department of Environment
In order to expand the scope of environmental management and to strengthen the power for
achieving it, the Government adopted the Environmental Pollution Control Ordinance in
1977. The ordinance provided the opportunity for the establishment of an Environmental
Pollution Control Board, which was assigned with the responsibility of formulating policies
and proposing measures for their implementation. In 1982, the Board was renamed as the
Department of Environmental Pollution Control (DEPC). Six divisional offices were
established in Dhaka, Chattogram, Khulna, Barishal, Sylhet and Rajshahi.
A special presidential order again renamed the DEPC as the Department of Environment
(DoE) and placed it under the newly formed MoEF in 1989.
The DoE is a Department of the MoEF and is headed by a Director General (DG). The
power of the DG, as given under the Act, may be outlined as follows:
 The DG has the power to close down activities considered harmful to human life
or the environment. The operator has the right to appeal and procedures are in
place for this. However, if the incident is considered an emergency, there is no
opportunity for any appeal.
 The DG has the power to declare an area affected by pollution as an ecologically
critical area. The DoE governs the type of work or process, which can take place
in such an area.
 Before undertaking any new development project, the project proponent must
take Environmental Clearance Certificate (ECC) from the DoE. The procedures to
take such clearance are in place.
 Failure to comply with any part of the Environment Conservation Act (ECA), 1995
with subsequent amendments may result in punishment by imprisonment or a
fine of or both.

Forest Department
This department under the MoEF is responsible for the protection and management of all
reserve forests in the country. Department personnel extend down to the union level in areas
where there are reserve forests. The department has recently started some agroforestry
programs and its officers are also responsible for the protection of wildlife in the forests.

14
 Policy, Legal and Administrative Framework

2.4 National Legislations Relevant to Environment

National Policies, Acts and Rules related with the environment include the following:
Applicable permits and
Summary of applicable policies/Act/Regulations
requirements
National Environment Policy, 1992 and Action Plan
This policy provides a framework for establishment of
legislation for protecting environment. The key provisions of
the policy are:
 Initial Environmental Examination (IEE) and
Environmental Impact Assessment (EIA) of all new Netrokona Economic Zone (NEZ) must
public and private sector industrial project is follow the policy and comply with
mandatory. provisions while implementing the
 Adoption of corrective measures by polluting project.
industries in phases.
 Prevention of land erosion, and environmentally
sound management of newly accreted land.
 Conservation of wildlife, bio-diversity, forest,
fisheries and livestock.
The Environment Conservation Act, 1995 (as amended
till October 5, 2010 (hereinafter referred as ECA)
The main objectives of this Act are: (i) conservation and
improvement of the environment; and (ii) control and
mitigation of pollution of the environment.
The salient features of this Act are given below:
 A Department of Environment (DoE) to be
established subsidiary to the MoEF to exercise the The Project shall uphold the ECA to
provision of the Act. ensure the environment is not
 The Government of Bangladesh (GoB) will declare damaged or compromised at any cost.
Ecologically Critical Areas (ECA) and specify the The Project Authority, i.e. BEZA, shall
activities or processes that cannot be initiated or follow the guideline given in
continued in an ECA. Environmental Management Plan
 An industrial unit/project cannot be established (EMP), and ensure that the post
without obtaining an Environmental Clearance construction phase will gradually allow
Certificate (ECC) from the Director General of DoE. the surrounding environment return to
 Publication of environmental guidelines related to its pre-project condition.
environmental pollution control and mitigation,
conservation and improvement of the environment.
 Prescription of rules for implementing the provisions
of the Act.
 Failure to comply with any part of the Environment
Conservation Act, 1995 may result in punishment to
a maximum of 10 years imprisonment or a
maximum fine of BDT 1,000,000 or both.
The Environment Conservation Rules, 1997 as amended The proposed NEZ falls in Red
in 2002, 2003, and in 2017 (hereinafter referred as ECR) category, for which both SCC and ECC
The Provisions under the ECR are summarized as follows: are required. However, with the
The industries for the purpose of obtaining ECC have been provision in Standard Operating
classified into the following four categories based on their Principle and application to DoE, only
site and impact on the environment: ECC is required for NEZ.
i. Green NEZ will carry out an EIA report to be

15
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
ii. Orange-A submitted to the DoE.
iii. Orange-B NEZ will apply to the DG, DoE for
iv. Red getting ECC with required documents.
The list of industries falling under each category has been NEZ shall follow the guidelines
annexed in the Schedule-1 to the ECR. presented in the ECR to prepare the
 For proposed industries failing under the Orange documentations required to apply for
A&B and Red categories, a Site Clearance and obtain the clearance required to
Certificate (SCC) needs to be obtained from DoE initiate any intervening activities from
prior to the issuance of ECC. the DoE.
 The project entrepreneur shall apply for ECC in NEZ will follow EMP mentioned in EIA
form 3 along with prescribed documents and report and follow the environmental
application fees. quality and other applicable standards
 ECC (for Red category) will be valid for 1 year from mentioned in ECR.
the issuance date and shall be renewed at least 30
days prior to expiry.
 Various environmental quality standards pertaining
to air, water, sound, odor etc. have been laid down
in the schedules attached to the Act.
 Emissions and waste discharge standards have
been laid down in Schedules 9-11.
The person in charge of facility/unit shall notify the Director
General (DG), DoE in case of pollutant emission/ discharge
in excess of prescribed standards or where there is a
possibility of the same.

2.5 National Legislations Relevant to the Project (Other than Environment)

National Policies, Acts and Rules related to the project other than environment are
discussed in the following:
Applicable permits and
Summary of applicable policies/Act/Regulations
requirements
Bangladesh Economic Zone Act 2010 (Act No. 42 of
2010)
This Act is to make provisions for the establishment of
economic zones in all potential areas including backward
and underdeveloped regions for encouraging economic
development through increase and diversification of
industry, employment, production and export. The
NEZ must follow this Act while
applicable clauses are given below:
implementing the project.
 Acquisition of land for economic zone
 Division of economic zone into several areas (EPZ,
Domestic Processing Zone, Commercial area, Non-
Processing area)
 Compliance to laws connected with environment
 Applicability of laws on workers’ welfare association
and industrial relations
Bangladesh National Building Code, 2006 The implication of this legal binding in
The Bangladesh National Building Code (BNBC) was first this proposed project arises from the
published in 1993 and revised in 2006 which is the code of safety of public and workers in relation

16
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
practice for construction sector in Bangladesh. The to development work of economic zone
provisions of this Code is applicable to the design, development. Thus, NEZ is obliged to
construction, use or occupancy, alteration, moving, follow the applicable code.
demolition and repair of any building or structure and to any
appurtenances installed therein or connected or attached
with the building/structure. The Code also sets out the
constructional responsibilities according to which the
relevant authority of a particular construction site shall
adopt some precautionary measures to ensure the safety of
the workmen during construction. With relation to this, the
Code set out the details about the different safety tools of
specified standard. The general duties of the employer to
the public as well as workers are also stipulated in the
BNBC.
Bangladesh Economic Zones (Construction of
Building) Rules, 2017
This rule is to provide a guideline for design required while
constructing building in the economic zone. The following
key issues are given:
 Open space (5% of the total area)
 Other amenities (5% of the total area)
 Green space (5% of the total area)
In addition, the rules provide guideline for the following
issues:
i) Drainage, waste management, etc.
The following provisions shall be followed in drainage,
waste management and other systems of the economic
zones:
 preparing a master plan of the drainage and
sanitary system for the total economic zone
showing slopes, retention areas and ultimate
NEZ must comply the requirements
discharge point;
and follow the standard mentioned in
 preparing a master plan of the waste management
this Rules.
having CETP with metering system so that
individual may be charged as per their effluent
discharge;
 heterogeneous effluents shall be pre-treated before
discharging to CETP as per requirement of CETP;
 economic zone shall have STP for individual plot;
 economic zones having more than 80 acres in size
shall have central power, water supply system with
metering system so that individual may be charged
as per their use.

ii) Fire appliance access requirements

The fire appliance access requirements in industrial area
layouts shall be as follows:
 every economic zone shall have fire zone as per
BNBC;
 adequate fire brigade stations shall be provided

17
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
according to the size of the economic zone;
 each industrial plot shall be provided with vehicular
access roads;
 If a central median is provided in industrial plot, the
minimum width of the dual carriageway shall be
7.3m wide for one-way traffic: Provided that if
constraints do not allow the provision of a central
median, the minimum width of a carriageway
without a central divider shall be 13.5m for two-lane
two-way traffic.
iii) Rain water harvesting
The plot shall incorporate a rainwater harvesting system
designed to capture roof run minimum of 200m off from a
(or 50% of the available roof catchment area for roof areas
less than 400m) during regular rainfall events. The collected
rainwater shall be plumbed to supply a seasonally
independent water use e.g. toilet flushing. The water
harvesting system shall be same standard system for each
plot.
Acquisition and Requisition of Immovable Property Act,
2017
Land acquisition in Bangladesh is governed by a) the
Acquisition and Requisition of Immovable Property Act,
2017 (henceforth, the 2017 Act) which repealed the
Acquisition and Requisition of Immovable Property
Ordinance 1982 (with subsequent amendments of the latter This Project will require acquisition of
up to 1994) and b) the East Bengal State Acquisition and approximately 500 acres of land for
Tenancy Act (1950) revised in 1994. The 2017 Act provides construction of the proposed Economic
certain safeguards for the owners and has provision for Zone. NEZ will carry out land
payment of “fair value” for the property acquired. acquisition following this and shall
 The Deputy Commissioner (DC) in all cases, determine abide by the 2017 Act for any future
“market value” of acquired assets on the date of notice land acquisition if required under this
of acquisition (notice under Section 9 of the 2017 Act). Project.
The assessment of this market value is done
considering the average price of immovable properties
of the same class, with similar facilities and within the
vicinity of the “to be” permanently acquired land and
assets. The DC then adds 200% and 300% premium of
the assessed value for cash compensation under law
(CCL) of the land and assets including house for
government and non-governmental acquisitions

18
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
respectively.
 For any other losses as specified above, i.e. from (b) to
(e)1, the DC adds 100% premium of the assessed value
to pay as compensation.
 If land acquired has standing crops cultivated by tenant
(bargadar) under a legally constituted written
agreement, the law requires that part of the
compensation money be paid in cash to the tenants as
per the agreement. If there is a dispute regarding the
amount of compensation, there is an option for
arbitration and the procedures for such is in place.
National Water Management Plan, 2001 (Approved in
2004)
The objectives of the plan are listed below:
 To operationalize directives given in National Water The proposed NEZ is within the area of
Policy and to do in accordance with the Thakur Kona FCDI scheme by
Government approved Development Strategy. Bangladesh Water Development Board
 To address issues related to harnessing and (BWDB). NEZ must ensure that the
development of all forms of surface and ground objectives related to this FCDI scheme
water and management of these resources in an will not be hampered by the proposed
efficient and equitable manner project.
 Consultation on and Participation with the direct
beneficiaries in the hand over and development of
water schemes.
Bangladesh Water Act, 2013
The key features of the Act are:
 A National Water Resources Council (NWRC) to be
established for implementing the provisions of the
Act
 A National Water Policy shall be adopted by the
Council addressing the following issues:
o Purpose and sectors of water use NEZ shall ensure compliance with legal
o Affordability of water users requirements under this Act, if
o Actual cost of water abstraction and distribution applicable.
o Financial ability and backwardness of water
users of any group there of
o Water demand and supply
o Any other issues considered relevant by the
government
 An Executive Committee of the Council shall be
established or ensuring efficient performance of
the Council.

1 (b) loss of crops or trees; (c) loss of affected immovable property separated from existing immovable property;
(d) loss of other immovable property or movable property or income; (e) transfer cost of affected residential and
commercial properties.

19
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
 The GoB can declare certain areas as Water
Stress Areas for the protection of water sources
or aquifers.
 Water zone demarcation (industrial, agricultural,
brackish water aquaculture and hatchery water
zones) through gazette notification and issuance
of protection order for efficient water management
in such zones.
 Declaration of flood control zone and its
management.
 Restriction on abstraction of total water from any
water source.
Ground Water Management Ordinance, 1985
 As per the provisions as per schedule 5 of this The project area falls under ground
act, no tube well shall be installed in any place water stress area; therefore,
without a license granted by the Union Parishad. groundwater withdrawal requires
 Also, no application shall be entertained by the necessary investigation and
Union Parishad unless it is accompanied by such compliance with the Ordinance.
fee as may be prescribed under the requirements
of this ordinance.
The National Fisheries policy, 1999
The policy broadly aims at fisheries development, regulation
NEZ shall ensure that during project
of aquaculture, biodiversity conservation and formulation of
operation, no untreated effluent is
laws to ban the disposal of any untreated industrial effluents
disposed into the river. The treated
into the water bodies.
effluent shall also meet the standards
The objectives of the fisheries policy are:
stipulated under the ECR.
 Enhancement of the fisheries production;
 Poverty alleviation through creation of self- The project area usually becomes an
employment and improvement of socio-economic open waterbody during wet season,
conditions of the fishermen; which provides habitats for different
 Fulfilling the demand for animal protein; varieties of fish. It also, provides
 Achieve economic growth through earning foreign livelihoods for local people. NEZ shall
currency by exporting fish and Fisheries products; ensure the fish habitat, susceptibility
and and options for livelihoods for
 Maintain ecological balance, conserve biodiversity, dependent people.
ensure public health and provide recreational
facilities.
Bangladesh Labour Act, 2006 (as amended through July
22, 2013)
The previous prescribed under chapters pertaining to
occupational health and safety, and compensation due to NEZ shall ensure compliance with the
accidents are entailed below. provisions mentioned in this Act with
Chapter V: Health and Hygiene respect to labor recruitment and
The chapter deals with provisions regarding cleanliness of working condition.
any facility, drinking water supply, ventilation, lighting, dust
bean and spittoons, etc.
Chapter VI: Safety
The chapter address the issues regarding safety of building

20
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
and machinery, precautions in case of fire, fencing of
machinery, work on or near machinery in motion, hoist and
lifts protection of eyes, explosive and inflammable dust/gas
etc.
Chapter VII: Special provisions related to health,
Hygiene and safety
The chapter deals with previous to be taken in case of
hazardous operations,
Chapter VIII: Welfare
This Chapter prescribes the provisions to be facilitated in
the facility regarding first-aid appliances, safety record
books, washing facilities, canteens, shelters, room for
children, etc.
This Act consolidates and amends the laws relating to
employment of labor, relation between workers and
employers, determination of minimum wages, payment of
wages and compensation for injuries to workers, formation
of trade unions, raising and settlement of industrial
disputes, health, safety welfare and working conditions of
workers, apprenticeship and matters connected therewith.
The previous prescribed under chapters pertaining to labor
benefits and entitlements are as follows:
 Condition of Service and employment
 Employment of Adolescent
 Maternity Benefits
 Working Hours and Leave
 Wages and Payment
 Workmen’s Compensation for injury by Accidents
 Trade Unions and Industrial Relations Regulation of
Employment and Safety of Dock Workers
Bangladesh EZ Labour Law Ordinance No 01, 2019
(adopted from Bangladesh Export Processing Zone (EPZ) This Law give strong emphasis on
Law) labour rights, irrespective to gender
and their orientation. It includes a
This law although follows Bangladesh Labour Act, 2006, it separate chapter on occupational
exclusively focuses on industrial sectors and economic health and safety.
zone related employments. It provides instructions for the
directives on labour appointment, wages, working hours, BEZA is obliged to follow all of these
termination, occupational health and safety issues etc. The rules during land development and
salient features are as follows: period and to monitor so that
established industries follow this law
 Providing appoint letter and id card is mandatory during the operation period.
 Maximum working hours is restricted to 48 hours,
The law, however, does not contain
additional payment is required in the case of extra
any close concerning to the community
hour work
health and safety. During construction
 Any labour will get one day weekly leave with pay
and operation community health and
 Female labour will get eight week of maternity leave
safety issue will be more crucial.
 Prior notice is required for termination,
Therefore, such an addition will be
retrenchment and discharge
required.
 Inappropriate/indecent behaviour and harassment

21
 Policy, Legal and Administrative Framework

Applicable permits and

Summary of applicable policies/Act/Regulations
requirements
to female worker will be strongly handles
 It is prohibited to appoint under-aged and forceful
labours
 The employers are entitled to ensure the safety of
workers and also maintain a safe and healthy
working environment within the workplace
 It is mandatory to facilitate every zone with health
cares
 In case of industries containing more than twenty-
five (25) permanent workers, it is obligatory for
employers to maintain group insurance for the
workers
Bangladesh Factories Act, 1995
As per section 6 of the Act, the occupier shall furnish some
information to Chief Inspector at least fifteen days before he
begins to occupy or use any premise as a factory. NEZ shall ensure that approval for plan
As per section B, the plans and specifications must be and specifications has been procured
approved by Chief Inspector. from Chief Inspector of concerned
Provisions for cleanliness, disposal of effluents, ventilation, area.
lightening, latrines, and urinals have been described in
Chapter II of the Act.
Chapter IV and V provisions for safety and welfare of the
workers.
National Industrial policy, 2010
The policy aims to ensure the industrialization process is
compliant with internationally agreed environment, health,
and safety and labor standards. NEZ shall ensure that the proposed
project authority follows the policy.
The government will ensure assistance for creating
alternative employment, keeping the socio-economic
backdrop in mind, for any privatization proposal.
Investment Board Act (1989)
Board of Investment, established under this act, is the
principle private investment promotion and facilitation
agency of Bangladesh, which is responsible for
implementation of provisions of above said policy.
Under the provision of this Act as per schedule 11, all NEZ shall ensure that the proposed
industries established in non-governmental sectors licensed project is registered as prescribed by
by the board shall be registered in the prescribed manner the Act.
As per Schedule 15 of this Act, any industrial undertaking
licensed transgresses any provision of this Act or of any
rule made there under or breaks any condition relating to
the license, the board may, in such manner as may be
prescribed, cancel the license of the industrial undertaking.

22
 3. Approach and Methodology

3.1 EIA Process and Approach

The EIA study was conducted in accordance with the Environment Conservation Act, 1995,
the Environmental Conservation Rules 1997 (amended in 2017), the EA guideline of Water
Resources Project, WARPO, 2005, and the EIA guideline for industries, Department of
Environment (DoE). The overall EIA process required for the proposed project is shown
schematically in Figure 3.1.

Figure 3.1: Environmental Impact Assessment Process

Activities to be carried out at each stage of the EIA process are described in the following
sections.

3.1.1 Project Desgn and Description

The Project Description was prepared by collecting Project related information from the
Feasibility Study (FS) report. Among the information, type of industry and their emissions as
well as effluents, effluent treatment facilities, surface and groundwater consumption, land
development activities, and other project related information are very crucial for assessing
impacts of the project in surrounding environment. Proposed project layout was collected
from feasibility report.

23
 Approach and Methodology

3.1.2 Policies and Legal Issues

The relevant legal and policy issues were reviewed in light of field findings to concentrate on
the significant impacts related to the IESCs. Project compliance with the relevant
environmental protection policies were also reviewed.

3.1.3 Environmental and Social Baseline

a) Physical Environment

Physiography, Geology and Seismicity

The general physiographical, geological features and the seismicity of the project and its
surrounding areas were collected from available secondary data sources. More importantly,
earthquake zone and presence of any active faults in and around the project area were
analysed.

Climate and Meteorology

Meteorological data such as rainfall, evapo-transpiration, temperature, sunshine hours,
humidity and wind pattern of selected stations were collected from the Bangladesh
Meteorological Department (BMD) and analysed for assessing local climate that are directly
related to the project.

Water Resources
Water resources data of river/wetland in terms of hydrology, drainage pattern, flooding
history, groundwater reserve, water use were collected from available secondary sources
and analysed. Flood inundation extent and flood depth map were also produced using GIS
technology considering present and future climate change scenario. Besides, relevant water
quality parameters were tested following both ex-situ and in-site methods to ascertain the
baseline situation.

Soil and Land Resources

The Agro-ecological Region of the project influence area were identified using secondary
sources (BARC, FAO/UNDP GIS Project/BGD/1995/2006). Soil data was also collected from
Upazila Land and Soil Resources Utilization Guide (Upazila Nirdeshika/Guide) of Soil
Resources Development Institute (SRDI). Data from available satellite images were
collected and Transect Survey in the field were carried out.

Air quality
Air quality data in terms of Fine Particulate Matter (PM2.5), Respirable Dust Content (PM10),
Suspended Particulate Matter (SPM), Sulfur Di-Oxide (SO2), Oxides of Nitrogen (NOx),
Carbon Mono-Oxide (CO), Ozone (O3) were collected from Singher Bangla, Chan Mia Mor
and Durgasrom sites to get an idea of the baseline situation.

24
 Approach and Methodology

Table 3.1: Sampling locations ID and Name with Longitude-Latitude

Sampling location Assigned ID Longitude & Latitude
N- 24º 54´ 33.48´´
Singher Bangla AQ1
E- 90º 46´ 42.87´´
N- 24º 55´ 31.08´´
Chan Mia Mor AQ2
E- 90º 46´ 59.12”
N- 24º 54´ 49.33´´
Durgasrom AQ3
E- 90º 47´ 32.54´´

Table 3.2: Air Quality Sampling Time schedule

Location ID Date Time started Time ended Duration

3.15 pm 3.00 pm
AQ1 11th to 12th February, 2020 23 hrs 45 mins
(11/02/2020) (12/02/2020)
4.00 pm 3.40 pm
AQ2 12th to 13th February, 2020 23 hrs 40 mins
(12/02/2020) (13/02/2020)
13th February to 14th 5.25 pm 5.30 pm
AQ3 24 hrs 05 mins
February (13/02/2020) (14/02/2020)

Figure 3.2: View of Air Quality Monitoring Figure 3.3: View of Air Quality Monitoring
at Singher Bangla (AQ1) at Chan Mia Mor (AQ2) & Durgasrom
(AQ3)

Noise
Noise levels were measured for twice in a day (Day and night time) within the project
influenced area. Each time, noise level was recorded for a five minutes time span with a 30
second intervals by using portable noise level meter. Depending on the site condition and
acoustic environment, the noise meter was set up and calibrated each time.

25
 Approach and Methodology

Figure 3.4: Air Quality and Noise Monitoring Locations

b) Biological Environment

Fisheries Resources
Fisheries resources (both natural and capture fishery) data and information were collected
based on different parameters such as available fish species, production of fish, and loss of
fish habitat. Primary data was collected through questionnaire survey and Focus Group
Discussion (FGD). Secondary data was collected from concerned Upazila Fisheries Office
(UFO) and from review of Fisheries Resources Survey System (FRSS) of Department of
Fisheries (DoF). Fisheries habitat (water bodies) was identified using satellite images.

Agricultural Resources
Agricultural resources data interims of farming practices, crop production constraints,
existing cropping patterns, crop variety, crop yield, crop damage and agricultural inputs were
collected from both primary and secondary sources. Primary agriculture data was collected
through questionnaires, key informant interview and focused group discussions. Secondary
data was collected from Upazila Agricultural Office of Department of Agricultural Extension
(DAE). High resolution recent images were used to compute net cropped area. Crop
production was determined using the formula: Total crop production = damage free area ×
normal yield + damaged area × damaged yield. The crop damage (production loss) was
calculated using the formula: Crop production loss = Total cropped area ×normal yield-
(damaged area ×damaged yield+ damage free area × normal yield). The crop damage data
was collected from the field for last three years.

26
 Approach and Methodology

Livestock resources
Secondary livestock data like population feed and fodder shortage diseases was collected
from Department of Livestock Services (DLS). Primary data was collected through
questionnaires, key informant interview and focused group discussions.

Floral and wild faunal Resources

Information on bio-ecological zones and their characteristics was collected from the
publications of the International Union for Conservation of Nature (IUCN) and Bangladesh
Forest Department. The aim of the ecological study was to investigate the likely impact of
project on different ecosystem component such as flora, birds, reptiles, amphibians,
mammals, and migratory birds. The field activities included collection of ecosystem
information, sensitive habitat identification, identifying ecological changes and potential
ecological impact. Field investigation methods included physical observation, transect walk,
and consultation with local people. The land use information on different ecosystem
(terrestrial and aquatic ecosystem) was generated through analysis of archived satellite
images/google images. An inventory of common flora and fauna was made based on field
survey and the IUCN database as well as from secondary sources.

c) Socio-economic Environment
Socio-economic baseline information including demography, occupation, literacy rate, public
utilities (drinking water, electricity facilities), etc. were collected from secondary sources, i.e.
Bangladesh Bureau of Statistics and other relevant literatures. Data on income, expenditure,
social overhead capitals and quality of life, livelihood pattern, communication system,
proposed project impact on socio-economic status and cultural and heritage features of the
project area was collected mainly from primary sources through questionnaire survey, Focus
Group Discussion (FGD), discussion with BEZA officials and local stakeholders.

3.1.4 Important Environmental and Social Component (Scoping)

The main objectives were to identify the Important Environmental and Social Components
(IESCs) or other important environmental component through a scoping process. IESCs
were selected in consultation with the local people to investigate likely impact of the
proposed interventions. Scoping process helped to eliminate the environmental issues and
components which would not be impacted or which will suffer from negligible impacts as a
result of the project.

3.1.5 Bounding
Area likely to be impacted by the proposed project was delineated in consultation with the
project proponent in addition to feedback received from the local people during baseline
consultation. The entire project area was defined as “Project Area.” On the other hand, the
area within surrounding 10 km radius of the project area was defined as “Study Area” or
“Project Influence Area”. Both Project area and Project Influence Area were taken into
account in the EIA study

27
 Approach and Methodology

Figure 3.5: EIA Study Area including Project Area

28
 Approach and Methodology

3.1.6 Impact Assessment and Mitigation

Once an impact was identified, it was further evaluated on the basis of its degree of
significance. The degree of significance of an impact defined by a five-point Likert scale was
assessed by its magnitude and sensitivity. Thus, an approach of qualitative quantification
was followed to evaluate the impact. The details of the methodology for assessing
magnitude, sensitivity and finally the significance are provided below.

Assessing magnitude of an impact

The magnitude of each identified impact was assessed on the basis of five parameters such
as: i) duration of the impact, ii) spatial extent of the potential impact, iii) reversibility of the
impact, iv) likelihood of occurring and v) compliance to national and international standards.
A scoring technique of qualitative quantification was adopted to assess the magnitude of an
impact assessing these five parameters. A Likert scale was developed (Table 1.1) to assess
degree of each parameter. The scale had a maximum score “4” which was labelled as
“major” and minimum score “1” which was labelled as “minimal)” (Table 3.3). A word
scenario was also developed to guide quantification of each parameter. Once the
assessment of each parameter is complete for an impact, a composite score for each impact
was calculated summing scores of all five parameters. Depending on the composite score,
the magnitude of the impact was assessed following the scale provided in Table 3.4.

Table 3.3: Definition of the Magnitude Classes and Parameters

Qualitative Scale to Quantify the Parameter (corresponding score is in
Parameter parenthesis)
Major (4) Moderate (3) Minor (2) Minimal (1)
Long term Limited to Temporary with
Duration of Medium Term
(more than 15 construction no detectable
potential impact (5 to 15 years)
years) period potential impact
Specific location
within project
Beyond immediate
Spatial extent of Widespread far component or
project components, Within project
the potential beyond project site boundaries
site boundaries or boundary
impact boundaries with no
local area
detectable
potential impact
Potential impact is
Potential impact Baseline returns
effectively
requires a year or naturally or with
permanent,
Reversibility of so for recovering limited Baseline remains
requiring
potential impacts with some intervention almost constant
considerable
interventions to within a few
intervention to
return to baseline months
return to baseline
Complies with limits
Breaches national given in national Meets minimum
Compliance to
standards and or standards but national standard
Legal Standards
international breaches limits or Not applicable
before Mitigation
guidelines/ international lender international
Measures
obligations guidelines in one or guidelines
more parameters

29
 Approach and Methodology

Qualitative Scale to Quantify the Parameter (corresponding score is in

Parameter parenthesis)
Major (4) Moderate (3) Minor (2) Minimal (1)
Occurs under worst Occurs under
Occurs under
case (negative abnormal,
Likelihood of typical operating or
impact) or best case exceptional or
potential impacts construction Unlikely to occur
(positive impact) emergency
occurring conditions
operating conditions conditions
(Certain)
(Likely) (occasional)

Table 3.4: Scoring Criteria for Magnitude Assessment

Magnitude of Impact Composite score to define magnitude of an impact

Major 16 – 20
Moderate 11 – 15
Minor 6 – 10
Minimal 0–5

Assessing Sensitivity of a Receptor

The sensitivity of a receptor for each impact was assessed on the basis of the capacity or
features (including proximity/numbers/vulnerability etc.) of the receptors to handle or tackle
an impact. A four-level qualitative scale defining the sensitivity as “low”, “medium”, “high” and
“very high” was developed to assess the sensitivity. The definitions of the sensitivity classes
are outlined in Table 3.5.

Table 3.5: Definitions of the Sensitivity Classes

Sensitivity Class Definition
Vulnerable receptor with no capacity to absorb proposed changes or minimal
Very High
opportunities for mitigation.
Vulnerable receptor with little capacity to absorb proposed changes or limited
High
opportunities for mitigation.
Vulnerable receptor with some capacity to absorb proposed changes or
Medium
moderate opportunities for mitigation
Vulnerable receptor with good capacity to absorb proposed changes and/or
Low
good opportunities for mitigation

Assessing Significance of an Impact

The significance of an impact was assessed by its magnitude and sensitivity. A cross-tabular
matrix was developed to assess the magnitude qualitatively.
The significance of an impact was evaluated following a five-level scale (Critical, Major,
Moderate, Minor and Minimal) which was determined by a cross tabular matrix between
magnitude and sensitivity Table 3.6.

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 Approach and Methodology

Table 3.6: Cross Tabular Matrix for Assessing Significance

Sensitivity of Receptors
Magnitude of Impact
Very High High Medium Low
Major Critical Major Moderate Minimal
Moderate Major Major Moderate Minimal
Minor Moderate Moderate Minor Minimal
Minimal Minimal Minimal Minimal Minimal

3.1.7 Environmental Management and Monitoring Plan

The Environmental Management Plan was prepared suggesting mitigation measures for
minimizing the effect of the negative impacts, enhancement measures for increasing the
benefit of the positive impacts, measures for compensating the negative impacts that cannot
be mitigated and an environmental monitoring plan for monitoring changes taking place
through implementation of the project. Cost estimate for implementing the EMP was also
suggested for inclusion in the project cost estimate.

3.1.8 Public Consultations and Disclosure

Public Consultation Meetings (PCM) were conducted to ensure people’s participation in the
proposed Project. Formal and informal consultations were conducted in each step of the
study. This helped to understand people’s attitudes towards the project, potential impacts
(both positive and negative) and mitigation measures.

31
Approach and Methodology

32
 4. Project Description

4.1 Introduction
The proposed Netrokona Economic Zone (NEZ) is a part of the government’s plan of
establishing new 100 EZs across the country especially in areas which are underdeveloped
and backward. The aim is to promote domestic investment and as well as foreign investment
for local and regional economic development. The BEZA was the proponent of the NEZ and
engaged Institute of Water Modelling for carrying out the feasibility study. This chapter
outlines the overall master plan of the NEZ developed by IWM. The master plan includes
layout description, zoning, NEZ facilities, on-site and off-site infrastructures, etc. The salient
features of NEZ are provided in Table 4.1.

Table 4.1: Salinet Features of NEZ



Division Mymensingh
District Netrokona
Upazila Netrokona Sadar
Mouza Barni, Kashipur, Singher Bangla, Bhadrapara
24°55'34.15"N to 24°54'31.99"N
Coordinates
90°46'24.00"E to 90°47'30.92"E
Area 500 acres
Current land-use Agriculture
Average land elevation 7.25 mPWD
The distance along road from Dhaka 150 km
Distance along road from Chittagong 401 km
Distance from nearest airport 150 km (Hazrat Shah Jalal International Airport, Dhaka)
Distance from nearest river Kangsha 3 km
Distance from nearest railway line Adjacent
Distance from nearest highway Adjacent
Distance from nearest 33 KVA electric line Adjacent
Distance from nearest gas supply line 4 km
Groundwater, Kangsha River, rainwater harvesting inside
Probable water sources
waterbody
Source: Feasibility Study Report prepared by IWM (BEZA, 2019)

4.2 Project Objective and Expected Benefits

With the aim of encouraging rapid economic development by increasing and diversifying
industry, employment, production and exports, BEZA plans to establish 100 economic zones
and NEZ is one of them. Netrokona is one of the least developed Districts with low
industrialization. One of the main objectives of this EZ establishment is to upgrade the
economic condition of the district by enabling the environment of industrialization and
economic diversification. It will encourage local entrepreneurs as well as attract investors
from outside including foreign investment. It will enable opportunities for creating new
employment. The project would also encourage other induced development especially
infrastructural development, economic development, etc.

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 Project Description

4.3 Project Components and Activities

The construction of NEZ would include three major components – i) development of land for
the NEZ which is 500 acres, ii) construction of on-site infrastructures for utilities including
roads, power lines, water supply, effluent treatment plant, sludge treatment plant, waste
management system, administrative buildings, etc. and iii) off-site connectivity and
infrastructures. This EIA has been conducted for land development and construction of on-
site infrastructures as per the master plan provided in the Feasibility Study Report conducted
by IWM. The following sections thereby represent the overall master plan of the NEZ
incorporated in the Feasibility Study Report. Project activities in different phases are given
below:

Table 4.2: Project activities in different phases

Pre-Construction Operation
Construction Phase
Phase Phase
 Development of land
 Site preparation, labor shed construction,
 Utility infrastructures (green area, school, hospital, religious
Land Acquisition facilities etc.) Establishment
 Mobilization of construction equipment and materials of industries
 Development of on-site road network
 Establishment of administrative units
 Boundary development

4.4 Master Plan of Netrokona EZ

This outline of the master plan has been proposed in the feasibility study and accepted by
BEZA. The EIA study has therefore, been carried out on the basis of the master plan.

4.4.1 Layout and Zoning

Plots of the NEZ will be spatially divided into four zones – A, B, C and D. These four zones
are exclusive for industrial area, residential area, recreational area, and administrative and
service area.. Table 4.3 and Figure 4.1 describe the details

Table 4.3: Zoning of NEZ

Zone Zone Name Description
In this zone, manufacturing units related to Garments, Integrated
Zone A Industrial Zone Textiles, Food Processing, Ceramics, Small Industries, Light
Engineering and Pharmaceuticals will be established.
Zone B Residential Area This zone is planned for residential area for staffs and their families
Recreational Recreational zone is planned to be facilitated with green areas, parks,
Zone C
Zone playground, food plaza, etc.
Administrative and service zone includes health care facilities, day care
centre, commercial spaces, utility services (water treatment plant,
Administrative
wastewater treatment plan, common effluent treatment plant, power
Zone D and Service
sub-station, solid waste collection stations, fire stations etc.), parking
Zones
and logistics, security and surveillance, educational spaces, truck stand
and workshop.
Source: Feasibility Study Report of Netrokona Economic Zone.

The feasibility study approximately allocated area for different zones and facilities which is
presented in Table 4.4.

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 Project Description

Figure 4.1: Proposed Zoning of the NEZ Area

35
 Project Description

Table 4.4: Allocated land area for different zones and facilities
Area Percentage of
Type of Zone Type of Land Use
(Acres) Total Area
Ceramic Ind. (16 plots) 15.79 3.11%
Food Processing (28 plots) 27.71 5.45%
Garments (47 plots) 47.16 9.27%
Zone A: Industrial Area
Integrated Textiles (26 plots) 25.7 5.05%
(39.99% of total NEZ area)
Light Engineering (16plots) 16 3.15%
Pharmaceuticals (22 plots) 22.02 4.33%
Small and Cottage Industries(49 plots) 49.01 9.64%
Zone B: Residential Area
Residential Area 29.53 5.81%
(5.81% of total NEZ area)
Club, Playground & Food Plaza 4.5 0.88%
Eco Park 7.59 1.49%
Green 16.4 3.22%
Zone C: Recreational Area Landscaping & Slope Protection 28.3 5.56%
(24.76% of total NEZ area) Park 1.18 0.23%
Playground 1.53 0.30%
Water body (Lake & Canal) 66.45 13.07%
Administration 5.65 1.11%
Central Truck Stand & Workshop 7.12 1.40%
CETP 5.83 1.15%
Commercial Area 7.5 1.47%
Day Care Center 1 0.20%
DTW 1.09 0.21%
Education 3.43 0.68%
Entrance, Parking & Security 6.1 1.20%
Fire Station 2 0.39%
Zone D: Administrative & Health Care 2 0.39%
Service Area (29.44% of total Lifting Station 0.6 0.12%
NEZ area) Logistics & Helipad 2 0.39%
Power Sub-station 1.88 0.37%
Religious Facilities 2 0.39%
Rest house 4 0.79%
Road Network 69.46 13.66%
School & Playground 6.12 1.20%
Solid Waste Management Site 1.83 0.36%
STP 6 1.18%
Utility Services Management 3.93 0.77%
WTP 10.16 2.00%
Total 100%

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 Project Description

Figure 4.2: General Layout and Plotting of the NEZ

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 Project Description

4.4.2 Plots and General Land Use and Landscape Regulation

Each of the plot sizes shall be roughly 1 acre in size in uniform rectangular length and width.
There will be some large plots for special industrial purposes. The master plan proposed a
set of regulation, which should be followed while establishing industrial units are mentioned
below:
 Nothing can be constructed on the set back area on the side of the building for
the fire fighting.
 It should be properly landscaped with small-sized trees.
 30% of the setback area on the backyard can be used for services (generator
room, prayer room, etc.)
 65% of the frontage can be used for parking, loading-unloading, security booth,
walkway, driveway etc.
 35% of the setback at the frontage should be landscaped with trees and properly
grassed.
 Each tenant will build the fence surrounding own leased land. The maximum
height of fences shall be 2.2m from the ground level. For the front side, the upper
half portion should be open type and the lower half portion should be closed type.
The standard sample is shown below:
o The fences facing the front road shall be open-type fences made of iron bars
or galvanized chain- link fencing material framed with galvanized pipes and
other similar types of fences.
o Details of color and material should be discussed with the zone administration.
o No concealing fences shall be erected facing the roads. On the other hand,
the structure of the side and back fence should be closed type for security
purposes.
o The fence between two adjoining plots could be built rightly on the plot
division line with the agreement of both tenants of plot and the cost of the
fencing could be shared by the two tenants.
o The setback of 3.281 feet (1m) is required between the u-channel and the
fence. This is for necessary maintenance of the fence foundation in the future.
The setback should be grassed for landscape purposes.

4.4.3 Parking and Traffic Management Regulations

Each unit of industries would have its own facilities. Each unit shall comply with the following
rules as per master plan:
 Parking for industries and other facilities is to be developed within the plot. Noon-
street parking will be allowed within the Zone (EZ).
 30% of the setback area on the front can be used as open parking.
 30% of the setback area on the front can be used for loading and unloading.
 All plots will have a minimum parking space allocation of one standard sized
automobile (2.5mx4.6m) per 200 sqm of floor space.

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 Project Description

 An extra 5% of ground coverage is permissible for construction of automated

multilevel/ multi-level parking with ramp parking structures for additional needs.
 In case of basement parking, it cannot exceed the setback line and maximum
20% of the ground coverage. It should be kept as service area (prayer room,
generator room etc.).
 For bicycle parking, one space per 500 sqm floor space is to be provided.
The master plan also specifies the dimension of parking area and turning radius that must be
followed while constructing each industrial unit.

4.4.4 Entry and Gate System

The master plan carefully considered the gate system of proposed Netrokona Economic
Zone (NEZ): It proposes two gates:
 Gate 1 (main gate) located at the entry point
 Gate 2 (main gate) located between processing zone and non-processing zone

4.4.5 On-site Infrastructure

a) Road Network
The detail of the road network is illustrated in the general layout shown in Figure 4.2 above.
Four (04) lane roads: The length of the four-lane road is approximately 3.66 km. The right of
way (RoW) of this road is 30m. Typical cross- section of road is Shown in Figure 3. Two
(02) lane roads: The length of the two-lane road is approximately 8.79 km. The right of way
(RoW) of this road is 20m. Typical cross- section of road is Shown in Figure 3.
Walkway: Walkways are proposed along the periphery of the Kamal lake and the Channel.
The walkway should be at least 3m wide.

Figure 4.3: Cross-section of a four-lane road

39
 Project Description

b) Utility ducts and drainage passages

All roads should be integrated with utility ducts. All water lines, cables, electric power lines,
gas pipelines should be installed within the utility ducts. The utility ducts shall be integrated
with the drainage passages. A typical section of the integrated drain and utility duct is shown
in Figure 4.4.

Figure 4.4: A Typical Utility Duct

Figure 4.5: A Typical Lighting

Arrangement

c) Roadside Electric Lighting

All roads shall have LED street lighting arrangement with central auto controls. Typical
lighting arrangement to be installed is shown in Figure 4.5.

d) Power Demand and Supply System

The feasibility study estimated that the power demand of NEZ would be 43 MW. The NEZ
plans to get power from the national power grid. A 33 KV power distribution line passes
along the highway adjacent to the site. The feasibility study proposed an option of
33KV/11KV sub-station with 11KV distribution line and another option of 11KV/0.4KV sub-
station with 0.4 KV /0.25KV distribution lines, which will be finalized later according to the
load calculation.
PDB is engaged for the installation of a sub-station for Sheikh Hasina University on the
same road to EZ. It is told that PDB at Netrokona is capable of power arrangement
for the Netrokona EZ and they require approximately one acre of land setting up an
electrical sub-station. The nearest sub-station is approximately 4.5 km away from NEZ site.

e) Conservation of lake
The Komol beel area will be preserved as a lake, which is expected to provide an essential
part in the internal drainage system of NEZ by retaining the rainwater. Figure 4.7 shows the
layout of the provision of lake. The lake will be connected with the adjacent canal at the
northern side of the project area through an open drainage channel. A water regulator will be
established at this connection point to control overflow inside the NEZ area. A walkway and
bicycle path will be established around the lake, which will also have provision to cross the

40
 Project Description

lake. A small island and bird watching tower will be built at the center of the lake for
recreational purposes.

f) Water Demand and Supply

The NEZ will require 40 million litres per day (MLD) water supply. According to the
assessment of water resources, the most reliable water source will be groundwater. The
groundwater quality is good. Groundwater (40 MLD) from 11 nos. of DTW (each of 1.5 cusec
capacity) will be used for proposed NEZ. No groundwater treatment plant (WTP) is needed
at present. Provision (space) for groundwater treatment plant (WTP) have been kept if it is
required in future. The feasibility study also considered surface water as a provision and kept
a large lake to reserve rainwater.

g) Provision of Rainwater Harvesting System

The Feasibility Study proposes use of rain water for several purpuses including drinking and
cooking, bathing and laundry, flushing toilets, watering lawns, gardens and houseplants,
composting, storing water in ponds, washing vehicles and equipment, fire protection, etc.
However, rainwater harvesting has not been considered for industrial process. The industrial
demand will be met from surface water and groundwater sources. However, for the industrial
units having the roof top area >300m2, it has been encouraged to implement rainwater
harvesting components in their premises. The storm water drainage system has been
planned to be discharged at the Kamal Beel. Kamal Beel will improve the overall recharge of
rainwater to the shallow aquifer.
The feasibility study has recommended measures for rainwater harvesting for artificial
recharge of groundwater aquifer. Several methods of groundwater recharge like spreading,
pit, induced recharge and injection well method are practiced. The area requirement of
spreading method sometimes limits its use. Among them the recharge / injection wells can
directly feed depleted aquifers with fresh water by gravity from ground surface. The recharge
through this technique is fast and has no transit losses or evaporation losses. It may ensure
timely disposal of the excess runoff as well as replenishment of aquifer. Except recharge pit,
other structure of recharge well remains underground; there is hardly any loss of land. Figure
4.6 shows the schematic diagram of artificial recharge of ground water aquifer.

41
 Project Description

Source: Feasibility Study Report of the NEZ

Figure 4.6: Schematic Diagram Showing Artificial Recharge of Aquifer

42
 Project Description

Figure 4.7: Layout of Water Supplly System and Provision of Lake to Preserve Rainwater

43
 Project Description

Figure 4.8: A General Layout of the Storm Water Drainage System

44
 Project Description

Figure 4.9: A General layout of Domestic Wastewater Collection System Network

45
 Project Description

Figure 4.10: A General Layout of the Effluent Collection Network

46
 Project Description

Figure 4.11: A General Layout of the WWTP and CETP Discharge Drain

47
 Project Description

h) Storm Water Drainage

Storm water drain has been planned to build on the both sides of the roads as indicated in
Figure 4.8. Total length of the storm water drain is about 17 km. This drainage network will
drain the storm water into Kamal beel through seven (07) outfalls.

i) Domestic Wastewater (Sewage) Treatment Plant

The master plan of the feasibility study proposed a central sewerage treatment plant (STP)
to treat domestic wastewater and sewage. The total capacity of the STP would be 6 million
liters per day. The layout of domestic wastewater collection system network is shown in
Figure 4.9. The Sewerage Network will be equipped with 12.07 km of sewerage pipe and
drain, three Sewage Lifting Station (SLS). The treated discharge from the STP shall be
carried out combinedly with treated industrial effluent from CETP by a 5.91 km RCC drain
(1000mm dia pipe) along the Netrokona-Mohonganj rail line and ultimately discharge to
Dhonkhali river near Thakurakona rail bridge (Figure 4.11)

j) Common Effluent Treatment Plant

A central ETP has been planned as shown in Figure 4.2, 4.10 and 4.11. All industries shall
have their own ETP for preliminary treatment according to ECR 2007. A Central ETP will be
constructed when all development will be completed. Until development of CETP, each
industry must have its own ETP. The treated water from the ETPs will be conveyed to a
CETP for further treatment before discharge. A total of 8.08 km effluent pipes and drains
have been proposed for the effluent collection network of the CETP. The effluent network will
also have three lifting stations (Figure 4.10). Preliminary capacity of CETP has been
estimated as 28 MLD but this capacity of CETP will be determined later based on the nature
of the future industries that will be built in this EZ. Layout of industrial waste water
collection network system is shown in Figure 4.10 and 4.11. The treated water from CETP
will be discharged to Dhonkhali River through a 5.91km channel to be constructed along the
Netrokona-Mohonganj rail line and ultimately discharge near Thakurakona rail bridge which
is illustrated in Figure 4.11.

k) Integrated Waste Management Facilities (IWMF) including Waste Sorting and Material
Recovery facility
Generated solid waste will be transported to Secondary Transfer Stations (STS) from
individual plots. Location of STSs has been proposed in the plot of Integrated Waste
Management Facility. The area of this site is about 1.83 acres. There will be four (04)
Secondary Transfer Station (STS) in this integrated waste management facility (IWMF);
among which one (01) will be used for residential zone and three (03) will be used for
industrial zone. Sufficient nos. of dustbin should be placed along the road network and in
public places (i.e. parks, playgrounds, etc.). A waste sorting facility will be constructed to
process waste and recover material from industrial and municipal waste, including metals,
glass, paper, textiles, and plastics, as well as domestic food waste, roads and building
construction waste and electronic waste. Mechanical sorting technologies will be used to
ensure effective and safe material recovery from industrial and municipal waste. The facility
will screen, sort, shred, separate and store industrial and municipal solid waste to be
recycled.

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 Project Description

Figure 4.12: Layout Plan of Integrated Waste Management Facilities

49
 Project Description

Figure 4.13: Elevation and Floor Plan of the Secondary Transfer Station

50
 Project Description

l) Sludge Management
When a liquid sludge is produced, further treatment may be required to make it suitable for
final disposal. Typically, sludge is thickened (dewatered) to reduce the volumes for disposal.
Near the settling tank, there is a sludge drying bed. By dewatering the sludge and proper
treatment, sludge cake will be produced. The Feasibility study proposes a few possibilities of
using slugde:
 Use of sludge as land-filling material;
 Use of sludge as filling material for public works (road, pipe laying) provided
that sludge contents in organic matter are acceptable;
 Use of sludge as material for brick manufacturing by incorporating sludge in clay;
 Use of sludge as material for agricultural soil improvement, providing that lime is
added and aluminum concentration is acceptable (aluminum is toxic for humans
and plants);
 Evacuation of sludge to dumping site.

Figure 4.14: Process Diagram of Medium Loaded Activated Sludge Treatment

m) Fire Protection
For the fire protection system, a fire station and two fire trucks have been considered in case
of fire incidence.

n) Data Connectivity
A robust infrastructure for high-speed internet connectivity is essential for ensuring the
sustainable operation of the zone. On top of that, it is imperative to have connectivity from
multiple operators to maintain high uptime and seamless service levels to the tenants. An
operator with sufficient capability may provide network connectivity inside the zone and
maintain clientele among tenants independently.

o) Administrative and Other Supportive Buildings

The master plan of NEZ specifies the plan of administrative/One-Stop Service Buildings,
which shall include the followings:

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 Project Description

 One-Stop Service Division (about 10 staffs)

 Economic Zone Administration Division (about 30 staffs)
 Security Office (10 staffs: 24 hours)
 Presentation/Seminar Room (50 people can be accommodated)
 Meeting Rooms (3 Rooms)
 Custom House
In addition, a number of support services shall be provided from the establishment:
 Banks
 Insurance companies
 Shopping mall/market
 Restaurants
 Residential hotel/Rest House

4.4.6 Land Development by earthfilling

Existing average land level of Netrokona EZ area excluding Kamal beel is 7.36 mPWD. The
land level should be raised to 10.9 mPWD for flood protection. The required sand for earth
filling may be provided from the dredged sand of the Kangsha, Mogra and Dhonaikhali
rivers.

Figure 4.15: Land development and Slope Protection

4.4.7 Off-site Infrastructure

To make the Netrokona Economic Zone more attractive to the investors and to make it more
economically feasible, the following off-site infrastructure has been proposed.
 Improvement and rehabilitation of adjacent railway line and establishing a railway
station.

52
 Project Description

 The two-lane road adjacent to the site is planned to be extended to four-lane

regional highway connecting Dhaka and also Sylhet via Tahirpur and Sunamganj.
 Nearby river port at Gaglajur Bazar to be upgraded to function exclusively for the
NEZ. Large vessels could then travel to the proposed river port from Ashuganj or
further from the sea along Surma-Dhanu-Meghna River. The Netrokona–
Mohanganj road and railway are extended by 18km.
 If the Netrokona-Tahirpur-Sunamganj-Sylhet highway is implemented, then the
site will have
 Access to two major international airports Dhaka Shahjalal International Airport
(150km) and the Sylhet Osmani International Airport (146km).

4.4.8 Utility Demand and Sources

The proposed NEZ will have an integrated comprehensive infrastructure for utility services
especially for power, gas, water, etc. The master plan specifies relevant plans for power and
water. The financial analysis considers that utility services will be constructed and run by
third party, which includes power, water, wastewater treatment and sewerage treatment. The
gas supply is assumed to be provided directly to the investor and NEZ will not take any
responsibility. The Table 4.5 describes utility demand and sources.

Table 4.5: Utility Demand

Utility Demand Source Remarks
Sub-stations and transmission line will be
BPDB through
Power 43 MW constructed at site. Section 4.5.3 may be seen for
national power grid
details.
The master plan mentions that there would be
Ground water,
40 Million liter provision of using surface water and rain water.
Water Surfacewater and
per day The existing Komol Beel will be rehabilitated to a
Rainwater
permanent lake, which would reserve rain water.
Not specified in Not specified in the The nearest gas supply/transmission station of
Gas
the Master Plan Master Plan GTCL is inly at 4 km away.
Source: Feasibility Study Report of NEZ (BEZA, 2019)

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 Project Description

Figure 4.16: Off-site Transportation (Rail, Road and Navigation) Connectivity

54
 Project Description

4.4.9 Project Cost

The Feasibility Study estimated the cost of establishing NEZ as Tk. 14,959 million.

4.4.10 Investment Plan

The Feasibility Study assumed that the NEZ will be in its full capacity by 2029. Allocation of
the land to the investor is planned to begin prior to 2023. The investment plan is given in
table below:
Year % of Land functional with a secured investor
2023 25%
2024 38%
2025 56%
2026 84%
2027 100%
Source: Feasibility Study Report, IWM

Table 4.6: Details of Cost Estimation of the Netrokona EZ

Amount
Sl.
Item Unit Quantity Rate (BDT) (Million
No.
BDT)
1 Land Development and Boundary Wall 302 2,723
1.1 Land Filling Cum 7,142,833 10,023 2,157
1.2 Boundary Wall M 6,600 66
1.3 Landscaping and slope protection LS 7,103.025 500
2 Land Cost Acres 500 3,552
3 Off-site Infrastructure 840
Establishment of Railway Station in front of LS
3.1 800
NEZ Gate
3.2 Data Connectivity (i.e. Optical Fiber Cable) LS 40
4 On-site Infrastructure 112,274,948 3,701
4.1 Four (04) Lane Roads Km 3.66 36,993,869 411
4.2 Two (02) Lane Roads Km 8.79 325
Other Common Zone Facilities i.e. LS
4.3 administration, rest house, fire station, club, 700
logistics, helipad and religious facilities
Social Facilities i.e. playground, education, LS
4.4 25,000 500
park, green and daycare etc.
4.5 Training Center (3 floors Sqm 1815 45
4.6 Commercial Facilities LS 900
Lake and Canal Improvement including LS
4.7 820
regulator and walkway
5 Business Component (utilities/others) 3,348
5.1 Water Supply & Sewerage System 710
5.1.1 Water Supply Network incl. DTW Km 20.02 349
5.1.2 Sewer Network incl. SLS & STP Km 28.29 361
5.2 Drainage System Km 17.42 937

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 Project Description

Amount
Sl.
Item Unit Quantity Rate (BDT) (Million
No.
BDT)
5.3 Power Supply System incl. sub station LS 288
5.4 Gas Supply System LS 165
CETP incl. effluent & discharge pipeline, lift Km
5.5 13.99 873
station
IWMF (Integrated Waste Management
5.6 375
Facilities)
6 Project Preparatory Costs of the Sponsors 152
Consultancy Fees for Design, Construction and LS
6.1 48
Supervision
6.2 Off-site Infrastructure Consultancy Fees LS 50
6.3 Legal Support LS 24
6.4 Administrative & Marketing Promotions LS 10
6.5 Vehicle LS 20
Sub-total (1 to 6) 14,315
7 Contingency (2% of sub-total) 286
8 Cost Escalation LS 358
Total Cost (BDT in Million) 14,959
Source: Feasibility Study Report Prepared by IWM

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 5. Alternative Analysis

5.1 Introduction
The BEZA evaluated two candidate sites at Netrokona for the proposed economic zone – i)
Singher Bangla Site, ii) Beel Guzabugi site before finally selecting the Singher Bangla site.
According to BEZA, the Singher Bangla site would have low impacts on socio-economic
condition since there will be no acquisition of settlements.

Figure 5.1: Map showing two alternative sites of proposed NEZ

5.2 “No Action” Alternative

“No Action” alternative means no construction of the proposed NEZ. In such a case the
present trend of unsustainable growth of industrial development, unplanned conversion of
wetlands, agricultural lands, and settlements to industries would continue. Apart from the
economic objective boosting economic growth to contribute to make Bangladesh as middle-
income country by 2021 and developed country by 2041 by proposed NEZ, another
objective is to stop unplanned industrial growth and concentrate all industries in a planned
area.

5.3 Evaluation of Alternative Site

The ESIA study team consulted the BEZA officials and Land Acquisition Officer of
Netrokona, Additional Deputy Commissioner (Land) of Netrokona, District Commissioner of
Netrokona to document their evaluation of alternative sites to document it for the purpose of
EIA. Additionally, the Environmental Expert of the ESIA team compared the two sites from
the perspective of the environmental, ecological and socioeconomic impacts. The
comparison between the two sites is presented in the table below.

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 Alternative Analysis

Table 5.1: Analysis of Alternative Sites

Evaluation Criteria Beel Guzabugi Singher Bangla
Land Availability 266.755 acre 500 acre
Accessible by Netrokona – Sunamganj
Accessible by Regional Road Regional highway. Besides, Netrokona-
Accessibility
(Netrokona to Bharirab) Mohonganj railway line runs adjacent to
the proposed area
Acquisition and
relocation of 4.03 acre No need to acquire any settlements
settlements
Groundwater throughout the
Groundwater throughout the season but
Water Availability season but surface water during
surface water during monsoon only
monsoon only
More or less similar to Beel Guzabugi
site. However, the Shingerbangla site is
Since the proposed area is located
only 3 km away from the Kangsha river
in an area surrounded by dense
Impact on Local which is possible source of dredged
settlements, the potential of
Community material, Therefore, impacts due to
affecting the local community is
transportation of dredged material would
higher
be less than that of the Beel Guzabugi
site.
Impact on 455 acres of agricultural land out of 500
Cultivable area is less, so the
agricultural acres will be converted to industrial area
impact is less
production with an annual loss of 2161 tons of rice
Impacts on water quality, air quality,
hydrology due to land development,
construction activities and industrial
Potential of having impacts on pollution. are more or less same as that
water quality, air quality, hydrology of the Beel Guzabugi site. However, the
Environmental
due to land development, Shingerbangla site is only 3 km away
Impact
construction activities and from the Kangsha river which is possible
industrial pollution. source of dredged material, Therefore,
impacts due to transportation of dredged
material would be less than that of the
Beel Guzabugi site
The proposed area includes beel Singher Bangla site might have same
and haor. Therefore, landfilling of impact. However, the master plan
Ecological Impact
beels and Haor might impact haor proposes to conserve the Komol Beel as
ecosystem. a lake/wetland within the NEZ.
Since the area is surrounded by There is no dense settlement surrounded
Community Safety dense settlements, there would be by the proposed site. Therefore, impacts
and Security issue of community safety and on community safety and security would
security be less than that of Beel Guzabugi site
Many households will be There is no settlement in the project area.
displaced, leading to the adverse On the other hand, some people have no
socio-economic impacts on legal entitlements, which may lead to
Social agitation
community, which, as a result, social agitation, but proper compensation
have a higher chance of social and livelihood restoration will mitigate this
agitation against the project. tension.

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 6. Environmental and Social Baseline

6.1 Introduction
This section provides the baseline condition of physical, biological and socio-economic
resources in both study and project area. As mentioned before, project area refers to the
location where the economic zone will be established; whereas the study area refers to the
area within 10 km radius of the proposed project site.

6.2 Physical Environment

6.2.1 Meteorology and Climate

Bangladesh is a low-lying tropical country in the Asiatic monsoon region. Despite of having a
moderate spatial variability, significant temporal changes are also observed in climatic
condition. From the climate perspective, three main seasons can be recognized in
Bangladesh: a hot and dry pre monsoon season from March to May/June, wet monsoon
season from June/July to October during which more than 85% of the annual rainfall occurs,
and a dry winter from November to February (FAO, 2011). Bangladesh is created by the
alluvial deposit of the great Ganges-Brahmaputra-Meghna Rivers. These great rivers flow
through Bangladesh and flow through a single outlet to the bay of Bengal to the tune of over
138,700 m3/day which is the largest for and single outlet in the world, 1.5 times greater than
the Amazon River (FAO, 2011).
The proposed economic zone in Netrokona is located in the north-central hydrologic region
of Bangladesh which lies within the Brahmaputra catchment. Meteorological data of the
project area in terms of rainfall, temperature, relative humidity and wind speed were
collected from secondary data sources especially from the NWRD-CEGIS archive. Brief
analytical overview of some important parameters is presented in the following subsections.

Rainfall
Rainfall data was collected from Netrokona Sadar BWDB station and Mymensingh BWDB
station. From the available data, the analysis at Netrokona station was done for the period
from 1978 to 2008 and at Mymensingh station for the period from 1983 to 2013. Both the
areas receive high rainfall during April to October while November to March is the drier part
of the year with very less rainfall. The analysis shows that the monthly average rainfall varies
from 6.4 mm to 673.4 mm at Netrokona and from 6.68 mm to 447.19 mm at Mymensingh. At
Netrokona the maximum rainfall for an amount of 1218.6 mm occurred in July, 1982 while at
Mymensingh the maximum rainfall of 865 mm occurred in July, 1983. The monthly
maximum, minimum and average rainfall is shown in Figure 6.1 and, the annual rainfall at
Netrokona (1978 – 2008) and Mymensingh (1978 – 2017) are presented in Figure 6.2. The
maximum annual rainfall of 4327.4 mm was recorded at Netrokona in 1988 and 3312 mm at
Mymensingh in 1991. The linear trend line of the annual rainfall shows a slight increasing
trend at Netrokona and slight decreasing trend at Mymensingh.

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 Environmental and Social Baseline

Source: National Water Resources Database

Figure 6.1: Monthly maximum, minimum and average rainfall at Netrokona BWDB
station and Mymensingh BMD station

Source: National Water Resources Database

Figure 6.2: Annual rainfall at Netrokona BWDB station and Mymensingh BMD station

Temperature
The temperature data was collected from the nearest meteorological station at Mymensingh
and analyzed. The highest and the lowest temperature values for each month for the period
from 1988 to 2017 is presented in the Figure 6.3. The highest maximum temperature was
recorded as 38.1o C in April, 1992 and the lowest minimum temperature was recorded as
4.7o C in January, 2013. It revealed from the values that the warmer months are June, July,
August and September and the cooler months are November to March.

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 Environmental and Social Baseline

Source: National Water resources Database

Figure 6.3: Monthly maximum and minimum temperature at Mymensingh BMD station

Relative Humidity
Relative Humidity data was also collected from the BMD station at Mymensingh and
analyzed. The analysis of monthly relative humidity data for the period from 1988 to 2018 is
shown in Figure 6.4. The analysis shows that the highest Relative Humidity in all the months
were recorded as 100% whereas the minimum values vary between 20% and 51%. The
most humid months are from June to October.

Source: National Water resources Database

Figure 6.4: Monthly relative humidity at Mymensingh BMD station

Wind speed and direction

The wind speed data of Mymensingh BMD station for the period from 1988 to 2017 was
collected, analysed and shown in Figure 6.5. It shows that the monthly average wind speed
varies from 29.4 km/day to 143.9 km/day. Wind speed is higher during April - July and during
October- January. Generally, the north-easterly winds blows from land to the sea in south
during winter season in Bangladesh. Low temperature and light winds are common
phenomena of this period. Whereas, in summer the air pressure falls and wind direction

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 Environmental and Social Baseline

changes from sea to land (Khatun, Rashid, & Hygen, 2016). The monsoon period plays a
vital role in the wind distribution. Wind rose diagrams at Mymensingh station for the period of
1971 to 2010 are obtained from Khatun et al. and are shown in Figure 6.6. Wind distribution
diagrams show that wind speeds at winter (November, December, and January) and post
monsoon (September and October) were comparatively lower than in monsoon (May, June,
July and August) and pre-monsoon period (February, March and April). The direction of wind
was predominantly eastward but in winter both multidirectional.

Source: National Water resources Database

Figure 6.5: Monthly Average Wind Speed at Mymensingh BMD Station

Source: Khatun et al., 2016.

Figure 6.6: Wind Rose Diagram at Mymensingh BMD Station; (i) Winter, (ii) Pre-
monsoon, (iii) Post monsoon), (iv) Monsoon

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 Environmental and Social Baseline

6.2.2 Topography
Netrokona District falls within the old Brahmaputra alluvial floodplain which has an elevation
of 10 m above sea level (Rashid, 2019). Floodplains are not always totally flat, but comprise
with slightly higher parts (ridges) separated by depressions (basin) and spatial patterns
change over time (Uddin, Hooda, Mohiuddin, Smith, & Waller, 2019). Figure 6.7 shows a
topography map of Bangladesh (Awal, 2014) and the location of the project area. According
to the classification of land types of Bangladesh, land which is above normal flood level is
called highland, lands which are flooded up to 90 cm and between 90 cm and 180 cm deep
during flood are called medium highland and medium lowland respectively (Uddin et al.,
2019). The general topography of the project area is more or less flat with an elevation of 6.6
to 8.1 mPWD. Out of this area, 37% is highland and 34%, 21% and 7% are medium
highland, medium lowland and lowland respectively(IWM, 2019). Figure 6.7 shows digital
elevation model of the project area. The area of the Komol Beel is approximately 43 acres
and its water retention changes at different times of the year.

Source: Awal, 2014 and Feasibility study report of NEZ (IWM, 2019)

Figure 6.7: Topography of Bangladesh and Digital elevation map of the project area

6.2.3 Ambient Noise Level

Noise level around the project area was monitored at six selected points (Figure 6.8). Noise
level was measured for 10 minutes at each point for two times a day, between 9 am and 1
pm during day time and between 6:30 pm and 7:40 pm for the night time. From the obtained
data the LAeq value which is defined by a weighted equivalent of continuous sound level
was computed. Also, the Lmax and Lmin values were monitored.
At the time of survey, the noise level inside the project area was found very calm and low
whereas, at several points surrounding the project area, medium to heavy noise was
recorded. Mostly the places could be recognized as lightly dense residential areas. Along
with the residential settlements there were few small commercial units at the north-middle

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corner of the project area which could be defined by mixed areas. The monitoring site at the
south-west corner was designated as silent area because of the presence of a high school
although, a local market place and few residential houses were also located there. As there
was no industry close by, the major sources of noise at the locations were the movements of
vehicles and hydraulic horns. Table 6.1 shows the monitoring data at the locations with
standard values of residential and mixed area as per Noise Pollution Control Rule, 2006.
The survey data shows that most of the noise levels slightly exceeded the standard values.

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Table 6.1: Baseline noise level monitoring data

Location characterization Noise Standards2
Sites GPS Location Location Measurement time LAeq Lmax Lmin
and remarks Silent Residential4 Mixed5
3

Residential area 55
Day time (12:23 pm to 12.33 pm) 65 77 45
South-East (surrounded by few houses,
24°54'56.9"N
1 corner of agricultural land and a small
90°47'30.0"E
project area connecting road to the Night time (7:28 pm to 7:38 pm) 49.5 68 42 45
highway)
South-Middle Residential area 55
24°54'34.8"N Day time (12:09 pm to 12.19 pm) 71.5 90 43
2 part of (Surrounded by households
90°46'58.4"E
project area and highway) Night time (7:14 pm to 7:24 pm) 56 86 42 45
South-West Silent area (Surrounded by
24°54'34.8"N Day time (12:52 pm to 1.02 pm) 60.5 75 48 50
3 corner of several households, small
90°46'35.5"E
project area market and a high school) Night time (6:55 pm to 7:05 pm) 52.5 65 42 40
Residential area 55
North-West Day time (10:30 am to 10.40 am) 56.6 63 41
24°55'14.1"N (Surrounded by several
4 corner of
90°46'26.1"E households and agricultural
project area Night time (6:37 pm to 6:47 pm) 47 60 40 45
land)
North-Middle Mixed area (Surrounded by Day time (9:17 am to 9:27 am) 69 83 57 60
24°55'29.7"N
5 part of few households, few small
90°46'59.5"E Night time (6:52 pm to 7:02 pm) 55 70 41 50
project area shops, school)
Residential area Day time (9:54 am pm to 10:04
North-East 56 75 45 55
24°55'31.5"N; (surrounded by few small am)
6 corner of
90°47'33.6"E houses, agricultural land and
project area Night time (7:16 pm to 7:26 pm) 45 59 41 45
a small village road)
Source: Field data, 2019

2 Noise Standards are adopted from Bangladesh Noise Pollution (Control) Rules, 2006.
3 According to the Noise Pollution control Rules, ‘Silent Area’ is defined by the places where hospital, educational institute, office is located.
4 According to the Noise Pollution control Rules, ‘Residential Area’ is defined by the places where people live with their families.
5 According to the Noise Pollution control Rules, ‘Mixed Area’ is defined by the areas which are combinedly used as residential, commercial and/or industrial areas.

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Figure 6.8: Noise Level monitoring Sites

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 Environmental and Social Baseline

Figure 6.9 shows a google earth image with the sensitive receptors of noise at a 4 km radius
of the project area. The receptors are not assembled in a single area but scattered. The
major receptors are several mosques and a few educational institutes. The rural settlements
around the project area are mostly households which might be affected due to the
establishment of heavy industries. It should be noted that, it will not be appropriate to select
the total area of the Economic Zone as Industrial area as there are plans to establish parks,
educational institutes and office areas which do not fall under industrial area.

Figure 6.9: Sensitive receptors around the project area

6.2.4 Ambient Air Quality

The existing air quality of the proposed NEZ area as well as the surroundings were observed
to be good. Agriculture is the major activities in the project area for which farmers use pumpi
machines. Burning of fuel for operation of the pumps has potential effects on the air quality.
Within a radius of several kilometers, only a few small industries were observed. Among
those, several brick fields were observed that emit gas which can potentially affect the air
quality. Besides, the vehicles plying on the highway as well as the local roads can contribute
to bad air quality. The local roads were mostly observed to be made of soil. These roads
could produce dust during the movements of the vehicles. At three locations around the
project area the air quality was monitored. The positions of the sampling locations are
presented in Table 6.2.

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Table 6.2: Air Quality Monitoring Locations and Sampling Durations

Sampling location Sampling ID GPS coordinate Sampling duration
N 240 54´ 33.48´´
Singher Bangla AQ1 23 hours and 45 minutes
E 90º 46´ 42.87´´
N 240 55´ 31.08´´
Chan Mia Mor AQ2 23 hours and 40 minutes
E 90º 46´ 59.12´´
N 240 54´ 49.33´´
Durgasrom AQ3 24 hours and 05 minutes
E 90º 47´ 32.54´´
Seven parameters were monitored. Sampling was done for around 24 hours at each
location. The monitored values and the allowable standards are presented in Table 6.3. The
air quality standards were set by the Department of Environment of Bangladesh as ambient
air quality standards, 2005. All the parameters were found to be within the acceptable range.

Table 6.3: Baseline Air Quality Monitoring Data of NEZ

Sampling Bangladesh
Parameters Unit AQ1 AQ2 AQ3
method Standard
Fine Particulate Matter (PM2.5) µg/m3 Gravimetric 29.37 31.74 19.71 656
Respirable Dust Content (PM10) µg/m3 Gravimetric 70.23 81.62 63.28 1506
Suspended Particulate Matter
µg/m3 Gravimetric 105.14 117.52 91.11 2007
(SPM)
Sulfur Di-Oxide (SO2) µg/m3 West-Geake 10.25 7.16 11.26 3656
Jacob and
Oxides of Nitrogen (NOx) µg/m3 12.38 16.62 14.73 1008
Hoccheiser
Carbon Mono-Oxide (CO) µg/m3 Multi Gas meter 4 4 0 100007
Ozone (O3) µg/m3 Multi Gas meter 2 0 0 1577

6.2.5 Surface Water Hydrology

River and canal network

There are three rivers in the in the study area namely; Kangsha River which is 3~4 km north
to the project area, Mogra River which is 4~5 km south to the project area and Dhalai River.
Kangsha River is a transboundary river, which has entered Bangladesh as Bhogai through
the Ramchondrokura-Mandaliay Union of the Nolitabarhi Upozilla under the Sherpur District.
Total length of this river is 228 km and average width is 95m (CEGIS, 2013). The Mogrha
river originates from the Kakni union of the Phulpur Upazilla, Mymensingh District. And flows
through the Atpara and the Modon Upazillas and drains into the Dhonu River at the Badla
union of the Itna Upazilla under Kishoreganj. The Dholai-Bisnai joins with the Moghra in
Sonai Union of the Atparha Upazilla. Water remains stagnant almost throughout the year in

6
Standard set for an averaging time period of 24 hours
7 Standard set for an averaging time period of 8 hours
8 Standard set for an averaging time period of 1 year

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 Environmental and Social Baseline

this river. But, when the flow boosts during the monsoon, it overflows its banks. Total length
of this river is approximately 163 km (CEGIS, 2013).
There are a number of perennial and seasonal beel areas within the study area- Kuria Beel,
Kalabagua Beel, Nalghuria Beel, Megha Beel, Joga Beel, Hailda Beel, Komol Beel, Soai
Beel etc. Among these, Komol Beel and Soai Beel are located within the project area
although at present, the Soai Beel is almost dry and used for agricultural purpose. One
distributary channel named Thakurakona Canal that originates from Kangsha River near
Thakurakona bus station and reaches the project area with a name of Fazar Ali canal
through the south-east corner. At the western side of Komol Beel another channel offtakes
namely Krishna Khali canal and after flowing for 3 km joins with Kuria Beel which eventually
flows further south to meet with the Mogra River. Figure 6.10 shows the water resources
network within 5~6 km radius of the project area.

Figure 6.10: River and canal network around the project area

Discharge and Water level of nearby rivers

The long term (1982 to 2012) simulated flows of Kangsha River and Mogra River based on
the feasibility study done by IWM were assessed and shown in Figure 6.11. It is observed
that high discharge occurs between June and October and the lowest flows occurs during
the winter periods. The maximum average flows of Kangsha River and Mogra River occur in
July which are 644.9 m3/s and 242.4 m3/s respectively. The lowest average flows ocuur in
February that are 23.7 m3/s and 1.2 m3/s for Kangsha River and Mogra River respectively
(IWM, 2019). According to the local people, there is severe water scarcity in Mogra River
during the dry periods.

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Source: Feasibility study report of NEZ (IWM, 2019)

Figure 6.11: Water Discharge Simulated Data of Kangsha and Mogra Rivers

There are two water level gauge stations at the Kangsha River- one is at Jaria-Jhanjail,
around 17 km upstream from the project area and the other one is at Mohanganj, around 20
km downstream from the project area. Analysis of 10-year averaged water level hydrographs
shows that at Jaria-Jhanjail station the hydrographs are almost similar throughout the past
50 years while at Mohanganj station dry season water levels showed a rising trend during
the last three decades. The maximum water level varies from 9.5 mPWD to 12.5 mPWD at
Jaria-Jhanjail station and from 7 mPWD to 9 mPWD at Mohanganj station. Minimum water
levels ranges between 2 mPWD and 5.5 mPWD at both stations.
There is another waterlevel gauge station on the Mogra River at Atpara, which is around 15
km downstream from the project site. The 10-year averaged water level analysis showed a
decreasing trend in the recent past. The water level data of 1980-1989 to 2000-2009 shows
that the water level has lowered down by at least 1.5 mPWD in the dry periods and 2 mPWD
in the monsoon periods. The maximum and minimum water level at Atpara station ranged
from 6.7 mPWD to 11.2 mPWD and from 1.1 mPWD to 3.4 mPWD respectively.

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Source: Feasibility study report of river management at the haor areas (CEGIS, 2013)

Figure 6.12: Water Level Hydrographs for 10 Year Return Period at Jaria-Jhanjail and
Mohanganj Station (Kangsha River)

Source: Feasibility study report of river management at the haor areas (CEGIS, 2013)

Figure 6.13: Maximum-minimum Water Level at Jaria-Jhanjail and Mohanganj Station

(Kangsha River)

Source: Feasibility study report of river management at the haor areas (CEGIS, 2013)

Figure 6.14: Water Level Hydrographs for 10 Year Return Period and Maximum-
minimum Water Level at Atpara Station (Mogra River)

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Water management infrastructure

There is a project of BWDB at Natrokona Sadar Upazila, within which the area of Netrokona
Economic Zone lies. The objective of the project was to control flood, improve drainage and
irrigation facilities by constructing water management structures. According to the plan of the
project, 13.15 km of embankment, 3 number of sluice gates, 33 irrigation inlets and 13
drainage outlets and 23.02 km drainage canals were established although at existing
condition these infrastructures are not totally functional. Among the three sluice gates,
Thakurakona and Krishnapur regulators are partly damaged and almost out of order (Figure
6.15). According to the local people, the regulators are not able to serve the purpose at all
and need to be repaired. Drainage outlets were not found in design condition and need to be
re-excavated. Irrigation canals are also filled by siltation and need to be re-excavated
(CEGIS, 2012). During the survey, local people demanded for new excavation for improved
drainage facility.

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Figure 6.15: Existing Water Management Infrastructure within the Study Area

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Source: Fieldwork, 2019

Figure 6.16: Thakurakona and Krishnapur Sluice Gate

Source: Fieldwork, 2019

Figure 6.17: Physical Conditions of the Sluice Gates

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Water Management Related Problems and Issues

Drainage and water logging

During the wet periods water flows from north-west to the south-east through Thakurakona
canal, Fazar Ali canal and Krishna Khali canal and crosses the project area in the way. On
the other hand, during dry periods the canals get dry at several locations and drainage
becomes disrupted. The major reason is heavy siltation and absence of maintenance of the
drainage canals (CEGIS, 2012). The drainage canals have heavily been silted up and the
conveyance capacity has been reduced. Besides, water cannot flow out to the river due to
non-functioning of the regulators, which cause local and temporal water logging near the
sluice gates. Leakage and non-functioning of the inlet structures cause water logging at the
agricultural lands near the regulators. Encroachment of the canals by settlement and
presence of high land are also causes of temporal water logging.

Flooding
Flooding occurs due to the flow and rise of the water level of Kangsha River and intensive
rainfall. Approximately 10.1% of the total Upazila area is homestead and 1% is water bodies
(very low land) (IWM, 2019). The area elevation curve of the project area as shown in
Figure 6.18 and the flooding statistics as shown in Table 6.4, depicts that the project area
would be inundated during the peak flooding. 100% area of the proposed economic zone is
below the annual maximum peak water level (8.8 mPWD) of Kangsha River. The peak
normally comes in the month of April and receding starts in the month of October. Historical
maximum peak flood level (11.50 mPWD) was recorded in the month of June, 1988 while
the minimum flood level (4.16 mPWD) occurred in the month of April, 1994 (CEGIS, 2012).
During the last 15 years, heavy floods had occurred in 2007 and 2017. Excessive rainfall in
the upstream catchment areas was the main reason for those flash floods. According to the
local people, every year during the seasons of flooding the flood level around the project
area rises close to the existing embankments and at several points the embankments are
overtopped.

Source: Feasibility study report of NEZ (IWM, 2019)

Figure 6.18: Area Elevation Curve of the Project Area

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Table 6.4: Inundated Area under Different Water Level of Kangsha River

Water level scenarios Water level Area under flood

Annual max (5-year) 9.2 mPWD 100%
Mean annual peak water level 8.8 mPWD 100%
Mean annual min water level 3.4 mPWD 0%
Recorded highest flood level 11.7 mPWD 100%
Source: Feasibility study report of NEZ (IWM, 2019)

Quality of surface water

Surface water quality was assessed by sampling at three locations. The locations fell within
the surface water network adjacent to the project area, two sites were at the eastern part
and the other one was at the western part of the project area. The position of the water
quality monitoring sites are shown in Table 6.5 and Figure 6.19.

Table 6.5: Baseline surface water quality monitoring sites

Collection date
Sample ID Location GPS Coordinate
& time
Kongsha river, near Thakurakona bridge N 240 54´ 38.2´´ 06/01/2020; 5:05
SW-1
(Thakurakona, Netrokona) E 90º 49´ 36.8´´ pm
East side of Komol/Rupsha Beel N 240 55´ 08.0´´ 06/01/2020; 5:40
SW-2
(Thakurakona, Netrokona) E 90º 48´ 17.6´´ pm
West side of Komol/Rupsha Beel (Shingher N 240 55´ 03.3´´ 07/01/2020; 1:05
SW-3
Bangla, Netrokona) E 90º 45´ 44.4´´ pm

Several parameters were assessed through lab analysis. Acidified and non-acidified bottles
were used for sampling to test metallic and non-metallic concentrations respectively. The
results along with the methods of tests are presented in Table 6.6. In the Environmental
Conservation Rules of Bangladesh, 1997, standards for inland surface water were found for
only a few parameters which are also provided in the same table. The samples were found
to be within the acceptable range for the parameters available with standard values. From
the results, it can be observed that, the sample SW-1, which was sampled at the Kangsha
River was better in quality than the other two samples. All the samples showed some
similarities for a few parameters such as temperature, pH and color. However, the sample
SW-2, which was collected from a canal connected to the Komol beel (Fazar Ali canal)
showed way higher value than the other two samples for several parameters such as
turbidity, TDS, TSS, COD, electric conductivity, sulphate, ammonia-nitrogen. The reason for
such contamination could be the agricultural emission (fertilizers, pesticides) from the
adjacent lands. Also, the sample was taken from a location where the depth of water was
very shallow and organic matter as well as solids from the bed level could be mixed with the
sample. The sample SW-3 which was also taken from the canal connected to the beel
(Krishna Khali canal) showed better quality than SW-2 but worse than SW-1.

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Figure 6.19: Surface Water Quality Monitoring Sites

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Table 6.6: Baseline surface water quality monitoring data

Analysis Concentration Present Bangladesh

Parameters Unit
Method SW-1 SW-2 SW-3 Standard

0C Temperature 21 20.80 20.50 -

Temperature
sensor
pH - Electrometric 7.98 7.64 7.73 6.5 – 8.59
Turbidity NTU Nephelometric 115.00 >LOQ 15.00 -
Color Hazen UVS 1.00 2.10 2.00 -
Total Dissolved Solid 50.30 198.00 92.80 -
mg/l Conductivity
(TDS)
Total Suspended Solid 13.00 76.00 8.00 -
mg/l Gravimetric
(TSS)
Electric Conductivity 100.50 385.00 182.80
µS/cm Conductivity ≤2259
(EC)
Dissolved Oxygen (DO) mg/l Electro-chemical 7.70 6.75 5.85 ≥5.09
Chemical Oxygen 4.00 184.00 40.00 -
mg/l CRM
Demand (COD)
Arsenic (As) mg/l AAS 0.001 0.10 0.003 -
Chromium (Cr) mg/l AAS <LOQ <LOQ <LOQ -
Lead (Pb) mg/l AAS <LOQ <LOQ <LOQ -
Ammonia-N (NH3-N) mg/l UVS 0.3 3.50 1.40 ≤1.210
Sulphate (SO43-) mg/l UVS 17.00 47.00 4.00 -

6.2.6 Groundwater Hydrology

Aquifer characteristics
Groundwater is the main source of drinking water for the people living around the project
area as well as within the impact area. In this regard, lithological investigation was
conducted to ascertain the characteristic of aquifer of the area. Analysis of the existing bore
logs of Netrokona Sadar Upazila shows that layers of fine to medium sand exist below the
surface at different depths (Figure 6.20). The lithology of the area at different depths are
given in the following table.

9 Standard of inland surface water usable for recreational use, irrigation, fisheries.
10 Standard of inland surface water usable for pisiculture.

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Table 6.7: The Lithology of the Area at Different Depths

Depth of
Location of Borelog Type of soil with depth of strata
Borelog (m)
Fine to medium within 12-29 m and
Netrokona Sadar mouza 59.45
Medium sand from 55 to 59 m
Phaiska area of Fine to medium within 20-32 m and
98.17
Netrokona Sadar Medium sand from 66 to 98 m
Medium sand from 75 m to 93 m, fine to medium sand
309 from 135 m to 153 m and again medium sand from 216 m
to 228 m and 273 m to 297 m
Fine to medium sand from 14 m to 20 m and medium
Pourashava
sand from 46 m to 55 m
Source: Feasibility study report of NEZ (IWM, 2019)

The specific yields of sand layers in this area ranges between 0.12 and 0.15 which indicates
that aquifer quality is favourable for groundwater abstraction but not at all depts.

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Source: Feasibility study report of NEZ (IWM, 2019)

Figure 6.20: Borelog Characteristics and Specific Yield at Depths under Ground Level
of Netrokona Sadar

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Availability of groundwater
Intensive groundwater abstraction and depletion of groundwater level are common issues in
Bangladesh. Mean annual groundwater recharge is found to be higher (300-600 mm) in the
north-western and the south-western areas than the south-eastern and north-eastern areas
(<100 mm) where rainfall and potential recharge are greater (Shamsudduha, Taylor, Ahmed,
& Zahid, 2011). Figure 6.21 shows a map of Bangladesh indicating the nation-wide
distribution of groundwater depth and the difference between potential and net recharge of
groundwater over a period of 1975 to 2007. The dry-period depth of groundwater beneath
the project area including the impact area was found within 5-7 m below ground level, which
is not alarming but the location of Netrokona is very close to the areas where groundwater
level is the lowest. From the following figure, it can also be seen that Netrokona has a higher
difference between potential and net recharge of groundwater, which means the rate of
recharge at the project area is very slow.

Source: Shamsudduha et al., 2011

Figure 6.21: Depth of Dry-period Groundwater and Difference between Potential and
Net Recharge of Groundwater of Bangladesh

It was observed during the field visit that majority of the local people use electric motors to
abstract groundwater from a depth more than 120 m below the ground level. Several deep
tube-wells were also found to draw groundwater from the depth of 120~150 m. Local people
also stated that wells are dug to such long depth not because of availability issue but
because of quality issues such as iron and odor.

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Quality of groundwater
According to the Department of Public Health of Bangladesh, groundwater up to the depth of
30~40 m in and around the project area contain iron and groundwater from 73 m to 105 m is
suitable for drinking (IWM, 2019).
Groundwater quality was assessed in the field from three sample locations surrounding the
proposed NEZ project area. Water samples were collected from deep tube wells. The
locations of the sampling sites are presented in Table 6.8 and Figure 6.22.

Table 6.8: Baseline groundwater quality monitoring sites

Depth from
Sample GPS Collection
Location surface
ID Coordinate date & time
(m)
North-West Corner of the project area 85 m N 240 55´ 14.3´´ 06/01/2020;
GW-1
(Shingher Bangla, Netrokona) E 90º 46´ 26.5´´ 10:50 am
North-middle side of the project area 68 m N 240 55´ 31.3´´ 06/01/2020;
GW-2
(Thakurakona, Netrokona) E 90º 46´ 57.6´´ 9:37 am
South-West corner of Komol/Rupsha 95 m N 240 55´ 33.8´´ 06/01/2020;
GW-3
Beel (Shingher Bangla, Netrokona) E 90º 46´ 27.9´´ 12:50 pm

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Figure 6.22: Groundwater Quality Monitoring Sites

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A number of parameters were tested in the laboratory. Acidified and non-acidified bottles
were used for samples to measure metallic and non-metallic concentrations respectively.
Test results, analysis method as well as Bangladesh standards for drinking water (according
to Bangladesh Environmental Conservation Rules, 1997) are presented in Table 6.9. From
the monitoring data, it can be observed that most of the parameters of the samples, GW-1
and GW-3 were within the standard limits except for COD, chloride at both locations and
fluoride, manganese for GW-1. The sample, GW-2 showed higher concentrations than the
maximum acceptable values for turbidity, COD, manganese, iron and lower concentrations
than the minimum acceptable value of DO and chloride. The reason of such bad quality
could be that the water was being abstracted from a higher elevation underground than the
other two samples. However, parameters such as pH, temperature, color, TDS, TSS,
Sulphate, phosphate for the sample GW-2 were within the standard values. Chloride was
found to be very low while COD was observed to be very high at all the locations.

Table 6.9: Groundwater quality monitoring data

Analysis Concentration Present Bangladesh

Parameters Unit
Method GW-1 GW-2 GW-3 Standard
Temperature
Temperature 0C 21 20.80 20.50 20 – 30
sensor
pH - Electrometric 7.66 7.37 7.70 6.5 – 8.5
Turbidity NTU Nephelometric 0.53 155.00 2.20 ≤10.0
Color Hazen UVS 0.85 1.20 0.90 ≤15
Total Dissolved Solid
mg/l Conductivity 216.00 208.00 218.00 ≤1000
(TDS)
Total Suspended Solid
mg/l Gravimetric 1.00 4.00 2.00 ≤10
(TSS)
Electric Conductivity
µS/cm Conductivity 428.00 411.00 431.00 -
(EC)
Electro-
Dissolved Oxygen (DO) mg/l 6.60 4.63 6.79 ≥6.0
chemical
Chemical Oxygen
mg/l CRM 20.00 44.00 40.00 ≤4.0
Demand (COD)
Chloride (Cl-) mg/l Titrimetric 45.00 15.00 14.00 150 - 600
Fluoride (Fl-) mg/l UVS 1.20 0.90 1.00 ≤1.0
Nitrite-N (NO2-N) mg/l AAS <LOQ <LOQ <LOQ ≤1.0
Nitrate (NO3-) ppm UVS 0.21 7.27 4.27 ≤10.0
Manganese (Mn) mg/l AAS 0.45 0.15 0.03 ≤0.1
Iron (Fe) ppm UVS 0.00 4.65 0.02 0.3 – 1.0
Phosphate (PO43-) ppm UVS 0.046 0.097 0.15 ≤6.0
Sulphate (SO4 2-) mg/l UVS 1.00 1.00 3.00 ≤400

Note: NTU- Nephelometric Turbidity Unit; UVS- UV- Visible Spectrophotometer; CRM- Closed Reflex Methods;
AAS- Atomic Absorption Spectrophotometer; LOQ- Limit of Quantification; LOQ for Nitrite-N is 0.02 mg/l

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6.2.7 Drought
Drought conditions for the Netrokona Sadar Upazila was assessed based on Standardized
Precipitation Index (SPI) of annual rainfall. The analysis was based on gridded rainfall data
for the period from 1965 to 2012 (Figure 6.23). During this period, it was found that in this
Upazila, 15% of the years were dry: one extremely dry year, one severely dry year and 5
moderately dry years (IWM, 2019).

Source: Feasibility study report of NEZ (IWM, 2019)

Figure 6.23: Annual Standardized Precipitaion Index of Netrokona Sadar Upazila

6.2.8 Surface Physiography and Geology

The surface geology is important to understand the lithological exposure of the surface, soil
characteristics, capacity to hold irrigation water and groundwater conditions. From a
stratigraphic point of view, the tectonic platforms of Bangladesh which started in the
Precambrian age, can be divided into two divisions: stable platform in the northwest part
(found at a very shallower depth and mostly made up by coal, sandstone and shale) and
deep basin in the southeast part (found at a higher elevation and mostly made up by
sandstone and shale) (Alam & Islam, 2018). The study area falls within the deep basin
platform. From a geological standpoint, the depositional history and development of Bengal
fan began in the Early Eocene age (Curray J., 1971). The Bengal basin has more than 20
km of Tertiary-Holecene sedimentary fill derived mostly from the eastern Himalayas (Alam &
Islam, 2018). Considering the upper surface, there are 27 geological formations of Holocene
sediments that covers the whole country (Whitney, 2001). The project area of NEZ falls
under ‘Alluvial Silt and Clay’ zone which were created from alluvial deposition This means
the upper surface of the project area were formed through the deposition of alluvial
materials, mostly silt and clay, deposited from the bed of a flowing river. Besides, the
geology of the major parts of the surrounding area are associated with ‘Marsh Clay and
Peat’ zone from Paludal deposition meaning the accumulation of clay materials were
influenced by marshy environment.

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Source: Whitney, 2001

Figure 6.24: Geology of Bangladesh

6.2.9 Seismic Analysis

Seismicity is a measure which encompasses earthquake occurrences, mechanisms, and
magnitude at a given geographical location. As such, it summarizes a region's seismic
activity. On the basis of distribution of earthquake epicenters and behavior of different
tectonic blocks, Bangladesh has been divided into four seismic zones: Zone- I, II, III and IV
with seismic coefficient of 0.12, 0.20, 0.28 and 0.36 respectively. Zone having higher
coefficient value is more earthquake-prone or the earthquake load is heavier. The study area
falls under zone IV with the maximum earthquake load to be considered while constructing
heavy and taller buildings.

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Figure 6.25: Seismic zones of Banlgadesh

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6.3 Biological Environment

6.3.1 The Bio-ecological Zone

IUCN, the World conservation Union, Bangladesh has divided the whole country into 25 Bio-
ecological Zones (Nishat et al., 2002) in the context of physiography and Biological diversity.
Each Bio-ecological zone represents overall ecologic description of an area in the country.
The project and study area both are in the Brahmaputra-Jamuna Floodplain Bio-ecological
Zone. Brief description on this BEZ is presented below:
The Brahmaputra floodplain consists of several interconnecting channels, which erode and
form new lands on a large scale during each flooding season (Brammer, 1996). It possesses
a unique variety of plants, medicinal herbs, fruit bearing trees, hundreds of jungle shrubs,
creepers and climbers, flowering trees, etc., many of which yield valuable products. Some of
the floral species, which yield valued as timber producers are the Banyan (Ficus
bengalensis), Tamarind (Tamarindus indica), Sada Koroi (Albizia procera), Simul (Bombax
ceiba) and Ashwath (Ficus religiosa). The prominent fruit-bearing trees of this zone are, the
Mango (Mangifera indica), Jackfruit (Artocarpus heterophyllus), and Litchi (Litchi chinensis).
Bushes of reeds and canes are also found here. This zone is similarly enriched with orchids.
The Rasna (Vanda roxburghii) is commonly found in this zone (Khan, 1991).
According to Hunters (1875), leopards were frequently sighted in this zone. A few species of
Deer, such as the Samber (Cervus unicolor), Hog Deer (Axis porcinus), Swamp Deer
(Cervus duvauceli), and Barking Deer (Muntiacus muntjak) were also once found in
abundance everywhere in the forests of this zone. Among the bird species, small game birds
such as the Common Peafowl (Pavo cristatus), Red Junglefowl (Gallus gallus), Partridges,
and several varieties of pheasants were commonly found. The Bengal florican (Houbaropsis
bengalensis) and snipes are plentiful in the sandbanks and chars of this zone. On the other
hand, the most common poisonous snake is the Banded Krait (Bungarus fasciatus) in this
zone, which could easily be identified by its broad black and yellow bands. The map of this
zone is given in Figure 6.24.

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Figure 6.26: Map of Bio-ecological Zones of Bangladesh

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6.3.2 Ecosystem
The study area lies in the North-eastern haor region. The haor ecosystem possess unique
characteristics with many beels, canals and river system especially in the northeast region of
Bangladesh. Climate, and its influence on soil water availability, is the most important driver
of the density and diversity of plants found in the ecosystems. Interactions between plants
and water play a central role in the energy, water, and carbon cycles, which we rely on to
grow food and maintain a habitable climate. To forecast critical earth system functions such
as water availability and agricultural productivity, study is conducted to investigate how
rainfall variability at daily, seasonal, and inter-annual scales impacts ecosystem structure
and functions.
The prominent river systems and their tributaries and distributaries crisscross the study area.
The existing scenario of the haor ecosystem with low lying area for crop cultivation,
homesteads with planted fruiting trees and built-up area as embankments and floodplains
mostly inundated in the monsoon and post-monsoon seasons.
The vegetation, one of the major components of the ecosystem especially in the haor area
can be considered as a number of classes. Each type is assemblage of particular plant
species on the basis of a characteristic of particular environmental conditions such as hydro-
period, flow regime, water and soil quality. Therefore, wetland condition ranges from
perennial aquatic lowlands to seasonally dry uplands.
The vegetation of the project influence area including project area can be categorized into
eight groups, namely - 1) Submerged plants, 2) Free floating plants, 3) Rooted floating
plants, 4) Sedges and meadows, 5) Floodplain grassland, 6) Crop field vegetation, 7)
Roadside vegetation, and 8) Homestead vegetation. Detail description of these vegetation
types is given in appropriate subsections under the ecosystem resources.

The flora of the project area

The project area is generally low-lying area occupied with beels namely the Komol Beel
locally known as Ruksa Beel, Soail Beel, Kaittarashi Beel and Kajapuria Beel. All are
seasonal wetlands connected to Kangsa River to the west and Mogra River to the east side
of the project area through canal systems. In addition, some ponds were found in the project
area. The remaining parts of the project area is crop-field and fallow land. The project area
possesses single and double-cropped paddy field having two types of vegetation crop-field
along with floodplain grassland, and roadside vegetation.
Of the crop-field vegetation in the terrestrial environment major weed species grow between
crops and periphery of the cropland as well as floodplain are grasses like Prickly Amaranth
(Amaranthus spinosus), Bermuda Grass (Cynodon dactylon), Knotweed (Polygonum Sp.),
Yellow Sorrel (Oxalis corniculata). Besides, some aquatic species were also observed during
the field investigations. Based on the field investigation, the project area has been
categorized as seasonal wetland and further categorized as submerged vegetation, free-
floating vegetation, rooted vegetation, sedges and meadows on the basis of plants life-
forms.
The major plants in the road slopes are Rain Tree, Mahogony, and Chambul. Some part of
roadside is covered with Toddy Palm and Date Palm.

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Aquatic vegetation has been classified into submerged vegetation, free-floating vegetation,
rooted vegetation, sedges and meadows. The population and diversity of these aquatic
vegetation types in this project area (500 acre) is comparatively low due to human induced
pressures and regular cultivation practice as well as fishing and practice of bio-fertilizer and
bio-gas production. People involved in cultivation and capture fishery were also consulted to
gather information on aquatic ecosystem. A few aquatic vegetation found during the major
field investigation are presented in Table 6.10.

Table 6.10: Aquatic Vegetation of the Project Area

Bangla Name Common Name Scientific Name Type Status
Kalmi Shak Chinese Spinach Ipomoea aquatica Submerged M
Kachuripana Water Hyacinth Eichhornia crassipes Free-floating H
Khudipana Duckweed Lemna Sp. Free-floating L
Topapana Water Lettuce Pistia stratiotes Free-floating L
Kutipana Water Fern Azolla pinnata Free-floating L
Panchuli Water Snowflake Nymphoides indicum Rooted floating M
Chandmala Crested Floating Heart Nyphoides cristata Rooted floating M
Dhol Kolmi Pink Morning Glory Ipomoea purpurea Sedges and meadows H
Mati Konduri Dwarf Copperleaf Alternanthera sessilis Sedges and meadows L
Source: Fieldwork, 2020; Note: H-High, M- Moderate, L-Low

There is no swamp and reed forests in this project area.

The fauna of the project area

The fauna is a composition of minor phyla to large vertebrates those belong to different
classes and families on the basis of morphology or phylogenetic characteristics. In this
study, only vertebrate especially the wildlife species has been considered. The wildlife
species, have been described below according to hierarchy along with their habitats and
status defined by IUCN-Bangladesh (2015) viz. amphibian, reptile, bird and mammal groups.
The amphibians are not diverse in the project area. Abundant Indian Bullfrog
(Hoplobatrachus tigerinus) were seen during the major field work. It was found in waterside
bushes, banks of ditches, ponds, canals and rivers. Ornate Frog (Microhyla ornata) also
occurs in in this area and considered as moderate in terms of population, occupies a number
of different habitats types including lowland grassland, agricultural land, and pastureland.
Of the reptiles, Common Garden Lizard (Calotes versicolor), Bengal Lizard (Varanus
bengalensis), Checkered Keelback (Xenochrophis piscator), and Rat Snake (Ptyas
mucosus), Monocellate Cobra (Naja naja) were observed in leaf litters, low shrubs, and
grasslands. According to IUCN-Bangladesh Redlist (2015), Bengal Lizard and Monocellate
Cobra have been categorized as Near Threatened (NT) species in Bangladesh.
The birds are magnificent and most attractive among the wildlife species in the haor
ecosystem but lack of dense vegetation on crop fields as well as absence of forest patches
caused low diversity of terrestrial fauna inside the project area. Local birds like House Crow
(Corvus splendens), House Sparrow (Passer domesticus), Common Myna (Acridotheres
tristis), Red-vented Bulbul (Pycnonotus cafer), and Green Bee-eater (Merops orientalis) are

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frequently seen in the project area. Habitats are the edges of crop field, canal and river
banks associated with bushes and standing crops.
The large mammals have been affected by hunting and almost on the verge of extinction.
Currently, small to medium-sized mammal species were reported available in this project
area namely; Rats, Common Mongoose, Indian Civet, Jungle Cat, Bengal Fox (Vulpes
bengalensis), and Jackals (Canis aurues). Except Rats and Jungle Cats, all are threatened.
In the aquatic habitat, the Skipper Frog (Euphlyctis cyanophlyctis) is frequently observed
species. Of the reptiles, common aquatic snakes include the Checkered Keelback
(Xenochrophis piscator) and Water Snake (Atretium schistosum) are also observed.
Besides, a good number of waterfowl including migratory birds were found during the field
visit namely; Little Egret (Egretta garzetta), Little Cormorant (Phalacrocorax niger), Indian
Pond Heron (Ardeola grayii), Great Egret (Ardea alba), Common Snipe (Gallinago
gallinago), Spot-billed Duck (Anas poecilorhyncha), and Asian Openbill (Anastomus
oscitans) which were observed roaming in beels, ditches, and, floodplains. The above
aquatic species have been categorized as threatened by the IUCN-Bangladesh (2015).
Photographs of aquatic fauna are given in Figure 6.25 & 6.26.

Figure 6.27: Pond Heron in a Feeding Figure 6.28: Little Egret in Social
Habitat at Soail Beel Interactions at Komol Beel

The flora of the study area

The study area as well as the surroundings of the proposed site possesses different
landforms which support different ecosystems like homestead, crop fields, rivers, beels and
khals. Each of the ecosystems has its special features and special biodiversity. Overall
ecosystems with both flora and fauna of the study area are described below.
The Homestead vegetation at the study area comprises various plant communities in terms
of population and diversity. Homestead flora consists of both native and exotic species. No
endangered species was found within 10 km radius of the Project site during the field visit as
well as in consultation with local people and experts or even from published literatures. The
dominant plant of the study area is Raintree (Samanea saman), Betel-nut (Areca catechu)
and Mango (Mangifera indica).
The main fruit trees are Mango (Mangifera indica), Jackfruits (Artocarpus heterophyllus),
Litchi (Litchi chinensis), Tamarind (Tarnarindus indica), Guava (Psidium guajava), Lemon
(Citrus carantifolia), Custard Apple (Anona squamosa), Wood Apple (Aegle marmelos),

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Coconut (Cocos nucifera), Papaya (Carica papaya) and various kinds of plums. The most
important species are Banana, Jackfruit, and Date Palm (Phoenix sylvestris).
The important timber trees are Gazari (Shorea robusta), Tamarind (Tamarindus indica),
Karoi (Albizzia procera), Simul (Bombax ceiba) and Aswatha (Ficus religlosa). In addition to
Gazari and Mango, other timber trees are Jarul (Legerstroemia speciosa), Karoi (Albizzia
procera), Jackfruit (Artocarpus heterophyllus), Cotton (Bombax ceiba), and Palmyra Palm
(Borassus flabelliformis). The latter is useful for its juice and fruit. The bamboo and cane are
common floral species and have multiple uses. Besides, palms are also available and work
against lightening.
The Banyan (Ficus benghalensis) is considered as keystone species globally and was found
common in the study area. Among the shrub Hill Glory Bower (Clerodendrum infortunatum),
Turkey Berry (Solanum torvum) and Hairy Fig (Ficus hispida) were seen to occupy most
habitats. The common herb species are Arum (Alocasia esculenta), Indian Nettle (Urtica
Sp.), Prickly Chaff Flower (Achyranthes aspera), Tulsi (Ocimum americanum), and Bermuda
Grass (Cynodon dactylon).
The crop-field vegetation has low diversity of all types, but it is more important for food and
shelter to wildlife. The major species (weed) that grows with the crop in this area are
Bermuda Grass (Cynodon dactylon), Beefsteak Plant (Perilla frutescens), Spiny Amaranth
(Amaranthus spinosus), Indian Heliotrope (Heliotropium indicum), and Creeping Wood
Sorrel (Oxalis corniculata).
The major roadside vegetation which are mostly planted are; Rain Tree, Mahogony and
Chambul. Some part of roadside is covered with Toddy Palm and Date Palm. Common
shrub species along the roadside are Tulsi (Ocimum americanum), Crown Flower
(Calotropis gigantea), Hill Glory Bower (Clerodendrum infortunatum), Banana (Musa Sp.),
etc. Terrestrial vegetation of the study area is presented in Figure 6.27 & 6.28.

Figure 6.29: Homestead Vegetation at Figure 6.30: Roadside Vegetation at

Borni Village Singher Bangla

The aquatic ecosystem especially the floodplains possess high density and diversity of
aquatic plants. Water Hyacinth (Eicchornia crassipes) is the most common free-floating
hydrophytes that covers maximum portion of water area of river. Topapana (Pistia
strateotes), Khudipana (Lemna minor) were also found in beel and river water mixed with
hyacinth. Chandmala (Nyphoides cristata) are dominating the floodplain vegetation
community. It was reported that Sedges are quite common during monsoon along the river
bank lines. Helencha (Enhydra fluctuans), Jungle rice (Echinochola Sp.), Asian Water Grass

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(Hygrorhyza aristata) are the main floral composition of marginal sedges vegetation.
Occurrences of submerged hydrophytes are low inside the beels and river water due to
excessive aggregation of water hyacinth. The floodplains have low density of free-floating
hydrophytes and submerged plants like Hydrilla, Vallisneria, Potramogeton and Otellia.

The fauna of the study area

The data and information on fauna of the both terrestrial and aquatic habitats gathered
physically and collected from the local people during the field visit and are described
sequentially with following hierarchy:
The Common Toad (Duttaphrynus melanostictus), Indian Bull frog (Hoplobactrachus
crassus), and Cricket Frog (Fejervarya limnocharis) are commonly found species. Population
of these amphibians are rich due to having huge moist habitats.
Of the reptiles, Common Garden Llizard (Calotes versicolor), Bengal Monitor (Varanus
bengalensis), Golden Monitor (Varanus flavescens) and Rat Snake (Ptyas mucosus) are
found in the study area. It was reported during the field visit that different varieties of
poisonous snakes such as Indian Krait (Bungarus fasciatus) and Cobra (Naja naja) are
rarely found.
It was gathered during the field visit that Birds are rich population among all the group of
wildlife. The common birds occurring in this area are Common Myna (Acridotheres tristis),
Black Drongo (Dicrurus macrocercus), Asian Pied Starling (Sturnus contra), Spotted Dove
(Streptopelia chinensis), Red-vented Bulbul (Pycnonotus cafer), House Sparrow (Passer
domesticus), Black Kite (Milvus migrans), Oriental Magpie Robin (Copsychus saularis), and
Green Bee-eater (Merops orientalis). Besides, Black-hooded Oriole, White eyed Tit, Yellow-
breasted Wren Babbler, Common Tailorbird (Orthotomus sutorius), House Crow (Corvus
splendens), Oriental Magpie Robin (Copsychus saularis), Chestnut-tailed Starling (Sturnus
malabarica), Brown Shrike (Lanius cristatus), Plaintive Koel (Eudynamis scolopacea),
Cuckoo (Culculus microplerus), Canary Flycatcher (Anthus rufulus), Common Barbet,
Common Kingfisher (Alcedo atthis), Brown Fish Owl (Bubo zeylenensis), Brahminy Kite
(Haliastur indus), Crested Serpent Eagle (Spilornis cheela), Pigeon (Treron phoenioplera)
and Red Turtle Dove (Streptopelia tranquebarica).
A small number of mammals occur in homestead and associated habitat all of which are
small tomedium-sized. Grater Bandicoot Rat (Bandicota indica), Common Mongoose
(Herpestes edwardsi), Tomb Bat (Taphozous saccolaimus), Bengal Fox (Vulpes
bengalensis) are found in village grooves and other bushy areas.
Occurrence of aquatic fauna varies according to wetlands characteristics and availability of
water in the wetlands. The skipper Frog (Euphlyctis cyanophlyctis) is common amphibian
found throughout the year and the most successful adapted species. Abundance of Bullfrogs
(Hoplobactruchus tigerinus) increase in rainy season at crop-fields, ditches and other
marshy places. Common aquatic snakes include the Checkered Keelback (Xenochrophis
piscator) and Water Snake (Atretium schistosum). Water dependent avifauna are found
year-round for having wetland habitats and available fishes. Common Kingfisher (Alcedo
atthis), Little Egret (Egretta garzetta), Kura (Haliaeetus leucoryphus), Little Cormorant
(Phalacrocorax niger), Indian Pond Heron (Ardeola grayii), and Great Egret (Ardea alba)
were found roaming along beels, river, ditches, floodplains and ponds inside the study area.

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The Bar-headed Goose (Anser indicus) arrives about the first week of November and
departs at the end of February.

Ecosystem Services
Contribution of ecosystem services from the beels and allied ecosystems are widely
recognized. The beels are the main source of water in the project surrounding areas for
sustaining all types of vegetation as well as faunal resources. The seasonal Komol Beel,
Soail Beel, Kaittarashi Beel and Kajapuria Beel water is main source of irrigation. Seasonal
inundation enhances fertility of the floodplains. The aquatic plants of the beels provide good
habitat to local fishes. River and floodplains water is the main habitat as well as breeding
ground for fisheries that meet up partial protein demand of the local people. Cereal crops are
produced from crop field vegetation provide feeds for local people.
Water hyacinth is used as cattle feed during monsoon and afterwards. Water hyacinth is also
used as compost and natural fertilizer to crop fields. Levees vegetation protects settlements
from wave action and erosion. Demand of domestic fuel for cooking and timber for making
furniture are met from homestead vegetation. River levees vegetation also supply fuel and
thatching materials, help carbon sequestration, maintain ecosystem stability and the integrity
of other ecosystems, fish breeding grounds, maintain biological and genetic diversity,
support food chains and habitat for wildlife and protect wildlife It also help pollination,
habitats to a variety of resident waterfowl and a significant number of endangered species of
international interest. Besides it provides shelter to migratory waterfowl, principally ducks
and shorebirds during winter.
In addition, terrestrial ecosystem also provides services via plants used mainly for medicinal
purposes for common diseases from the bark and roots of the Mango, Tulsi, Simul and other
generally useful trees. The wood apple (Aegle marmelos), Gab (Diospyros precatorius) and
Babla (Acacia arabica) provide gum, the seeds of the tamarind produce oil which is used in
painting idols, and the bark of the guava is used for tanning.

Threats to ecosystem
The anthropogenic pressure is the main threat to ecosystem like hunting of waterfowl, and
overexploitation of natural resources like overfishing that has triggered scarcity of
nourishment for waterfowl in their feeding habitat.

6.3.3 Fisheries Resources

Bangladesh possesses enormous area of wetlands including rivers and streams, freshwater
lakes and marshes, haors, baors, beels, water storage reservoirs, fish ponds, flooded
cultivated fields and estuarine systems. Haors are located in the north-eastern region of
Bangladesh that also include Netrokona. According to Haor Master Plan (2012), the haor
area in Netrokona constitutes about 1.49 lakh ha, which provides. around 8,559.8 Metric Ton
(MT) fish (Upazila Website11).

11http://www.netrokona.gov.bd/site/page/0416ce70-1e86-11e7-8f57-
286ed488c766/%E0%A6%8F%E0%A6%95%20%E0%A6%A8%E0%A6%9C%E0%A6%B0%E0%A7%87%20%

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Fish Habitat Characteristics and Description

Fish habitats of the project area is classified into two broad categories based on land use,
such as capture fishery which includes river, khal, wetland, floodplain and culture fishery is
practiced in fish pond. The proposed Netrokona Economic zone, located in the haor region is
prone to flood especially flash flood. Haors are the wetland areas covered by water almost
six or seven months in a year starting from the pre-monsoon. There is a large low beel area
called Komol Beel within the NEZ. The area of the beel is approximately 43 acres. The beel
is connected to the Kangsha River in the north through internal drainage (Fazar ali canal)
channel. There are a number of beel areas namely Komol beel, Soai beel, Kaitta-rasi beel,
Kazapuria Beel in the project area. These beels dry up in the winter but during the rains,
expand into broad and shallow sheets of water. From April to October all the lands are
submerged under water by about 5-6 ft. At that time, no land could come in sight. During
winter, these beels contain little water (around 1 ft.) and are restricted to a small area, and a
large area is covered with paddy and other crops. There are some big ponds and ditch in
project area where fish are cultured commercially.

Figure 6.31: Present Situation of Project Area

Fish Habitat Assessment

Estimated fish total habitat in the fishing environments of the study area is 44,314 acres of
which 392 acre lies in the project area. The dominant fish habitat of the project area is
seasonal floodplain having an area of around 347 acre (89%) of which contribution of Komol
Beel is around 43 Acres. Detailed capture and culture fish habitat in the project and Study
area are presented in (Table 6.11).

E0%A6%A8%E0%A7%87%E0%A6%A4%E0%A7%8D%E0%A6%B0%E0%A6%95%E0%A7%8B%E0%A6%A3
%E0%A6%BE

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Table 6.11: Fish Habitat Assessment of the Study Area

Study Area
Habitat Project Area Study Area Total Habitat
Habitat type
Category (Acre) (Acre) Area (Acre)
River and Khal 0 1908 1908
Capture Fishery Beel 43 1042 1085
Floodplain 347 40473 40820
Sub-Total= 390 43,422 43,813
Baor 0 210 210
Extensive Fish pond 2 18 20
Culture Fishery
Semi-intensive Fish pond 0 193 193
Intensive Fish pond 0 78 78
Sub-Total= 2 499 501
Grand Total= 392 43,921 44,314
Source: Land use 2015 and DoF, 2017-18

Fish Species Diversity

Haor area is naturally enriched with various types of fish species. During consultation at
Chaindar Mor, Borni local fishermen and elderly people reported that various types of
indigenous fish species are found in these floodplain areas. Kuchia Fish are found
abundantly specially in Komol Beel and Kajapuria Beel. On the other hand, local people
culture various types of fish for commercial purpose like Rui (Labeo rohita), katla (Catla
catla), Sarpunti (puntius sarana), Madhu Pabda (Ompok pabda), Shing (Heteropneustes
fossilis), Magur (Clarias batrachus) etc. Some fish species are decreasing gradually
specially which inhabit in the marshes and tanks due to over catching and other reasons
such as use of insecticides and pesticides for crop production.

Figure 6.32: Various Fish Species of Fish

A list of mostly abundant fish species in the project area is given in Table 6.12 with IUCN
status.

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Table 6.12: Fish Species with IUCN Status

Scientific Name English Name Local Name IUCN Status, BD 2015
Chitala chitala Humped Feather back Chital EN
Cirrhinus cirrhosus White carp Mrigel VU
Labeo calbasu Orange fin labeo Kalibaus LC
Corica soborna Ganges river sprat Kachki LC
Mystus tengara Tengara catfish Tengra LC
Puntius chola Swamp barb Puti LC
Wallago attu Wallago Boal VU
Sperata seenghala Giant river-catfish Ayre VU
Macrognathus pancalus Barred spiny eel Baim LC
Channa punctatus Spotted snakehead Taki LC
Colisa fasciatus Stripled Gourami Kholisha DD
Notopterus notopterus Gray featherback Foli VU
Channa striatus Striped snakehead Shol LC
Channa marulius Great snakehead Gozar LC
Bagarius yarrelli Dwarf goonch Baghair DD
Ailia coila Gangetic ailia Kajli LC
Ompok pabda Indian catfish Pabda NT
Monopterus cuchia Freshwater mud eel Kuchia LC
Anabas testudineus climbing perch Koi DD
Wallago attu Boal Boal VU
Salmophasia bacaila Large Razor belly Minnow Chela LC
Botia lohachata Y-loach Rani EN
Macrognathus aculeatus One-stripe Spiny eel Tara Baim NT
Pseudeutropius
Indian Potasi Batashi LC
atherinoides
Xenentodon cancila Freshwater garfish Kakila LC
Note: LC- least Concern; NT- Not Threatened; VU- Vulnerable; EN- Endangered; DD: Data Deficiency; NE: Not
Evaluated

a) Indicator Species
Various types of fish species are found in this area, mainly during winter season from
October-December. According to local fishers punti, Kholisha, koi, kakila, baim, batashi,
kachki, kajuli, taki, shol, magur, ayre, pabda, kuchia etc. fish are found abundantly during
post monsoon season, but in monsoon season Goinna, Rani, Puiya, chela, ghora, bacha,
kalibaus, boal, chiatal etc. are also found.

b) Life cycle of Kuchia

The fresh water mud eel Monopterus cuchia is a tasteful, nutritionally rich and medicinally
valuable fish with high export demands which can play a unique role for socio-economic
welfare of the area. In Bangladesh it is found in shallow, well vegetated waters and mud

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(IUCN Bangladesh, 2000). Kuchia inhabits in mud holes in shallow beels and boro paddy
field throughout Bangladesh especially in Sylhet, Mymensingh and Tangail Districts
(Rahman, 1989 and 2005). It often spends its daytime hiding under stones and mud.

Fish Migration
During the monsoon period, some riverine fishes migrate to the floodplain area for breeding,
grazing and nursing purpose. But in winter season, the floodplain area dries up (observed
during field visit) and farmers cultivate crops in that low land area. Fazar Ali canal between
floodplain habitats and river channels act as a lateral fish migratory route or connectivity.

Fish Production Assessment

Fish production of the project area totally depend on in-migration from adjoining aquatic
habitats like rivers, beels, khals, etc. during monsoon season. The total fish production of the
project area is about 333 MT/Acre (Table 6.13). The capture fishery production is 32,453
metric ton (82%) and culture fish production is 7,086 metric ton (18%).

Table 6.13: Fish Production Assessment of the Study Area

Fish production
Habitat In project Total Fish
Habitat Type In Study Area
Category Area Production
(MT/Acre)
(MT/Acre) (MT/Acre)
River and Khal 0 1774 1774
Capture
Beel 83 2021 2105
Fishery
Floodplain 243 28331 28574
Sub-Total= 326 32,127 32,453
Baor 0 4193 4193
Culture Extensive Fish pond 6.8 61.2 68
Fishery Semi-intensive Fish pond 0 1679.1 1679.1
Intensive Fish pond 0 1146.6 1146.6
Sub-Total= 6.8 7,080 7,086
Grand Total= 333 39,206 35,347
Source: Land use 2015 and DoF, 2017-18.

c) Fishing Efforts
During monsoon, all the private lands goes under water and become a single water body;
and as such people avails free access opportunity for fishing. People of this project area are
depended on a single crop (Boro) and fishing (only from natural sources) to earn their
livelihoods. According to local people, around 10% are fishermen who live in Singher
Bangla. They are directly engaged in fishing. But, no permanent fishermen were found in
project area. During monsoon season maximum local people fishes in this area to fulfil their
protein intake. During winter season some ethnic group (Khotrio and Garo) from Rouha
Union comes to catch fish specially Kuchia in Komol and Kazapuria Beel.

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Figure 6.33: Catching Fish in the Study Area

d) Fisheries Management
Fisheries sector is contributing significantly to the haor economy. During field visit, it was
gathered from the local fishers and elderly people that there is no fishing comity in the
project area. However, Upazila Fisheries officer (UFOs) in Netrokona District informed that,
there is fishing community in the study area who culture fish commercially.

6.3.4 Agriculture

Land Resources
Agro-ecological Zones
The study area and the proposed project area has fallen under the Old Brahmaputra
Floodplain (AEZ-9) and Northern and Eastern Piedmont Plains (AEZ-22) agro-ecological
regions. Details are shown in the Table 6.14 and Figure 6.32.

Table 6.14: AEZ in the Project Area and Study Area

Project Study Area excluding Total Study % of total

AEZ
area (acre) project area (acre) Area (acre)* Study Area
Old Brahmaputra
500 64,691 65,191 84.07
Floodplain
Northern and
0 11,176 11,176 14.41
Eastern Piedmont
Unknown 0 1,177 1,177 1.52
Total 500 77,044 77,544 100.00
Source: BARC/UNDP/FAO GIS Project/BGD/1995/2006
* total study area refers to project and study area combined

Characteristics of the two AEZ are described in the following sections.

a. Old Brahmaputra Floodplain (AEZ-9)

This region occupies a large area of Brahmaputra sediments before the river shifted to its
present Jamuna channel about 200 years ago. The region has broad ridges and basins.
Soils of the area are predominantly silt loams to silty clay loams on the ridges and clay in the
basins. General soil types predominantly include Dark Grey Floodplain soil. Organic matter

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content is low on the ridges and moderate in the basins; topsoils are moderately acidic but
sub-soil is neutral in reaction. General fertility level is low.

b. Northern and Eastern Piedmont Plains (AEZ-22)

This is a discontinuous region occurring as a narrow strip of land at the foot of the northern
and eastern hills. The area comprises merging alluvial fans, which slope gently outward from
the foot of the hills into smooth low-lying basin. Grey Piedmont soils and Non-calcareous
Grey Floodplain soils are the major general soil types of the area. Soils of the area are
loams to clays in texture, having slightly acidic to strongly acidic reaction. General fertility
level is low to medium.

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Figure 6.34: AEZ Map of the Study Area

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Land use
Gross study area of the proposed project is 77,544 acres of which 500 acres has been
selected for project area. Net Cultivable Area (NCA) in the project area and Study area are
455 acres and 54,859 acres respectively. Detailed land use of the project area and Study
area are presented in Table 6.15 and Figure 6.33 & 6.34.

Table 6.15: Land Use Pattern in both the Project and Study Area

Project area Study Area excluding Total Study % of total

Land Use
(acre) project area (acre) Area (acre)* Study Area
Net cultivated area 455 54,859 55,314 71.33
Baor 0 210 210 0.27
Brickfield 0 109 109 0.14
Built-Up Non-Linear 0 350 350 0.45
Fresh Water Aquaculture 2 291 293 0.38
Orchards and Other
0 56 56 0.07
Plantations (Trees)
Perennial Beels/Haors 43 1,042 1,085 1.39
Rivers and Khals 0 1,908 1,908 2.46
Rural Settlements 0 18,219 18,219 23.5
Total 500 77,044 77,544 100.00
Sources: Spot image, 2015 and CEGIS estimation from January 2020.
* total study area refers to project and study area combined

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Figure 6.35: Land Use Map of the Project Area

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Figure 6.36: Land Use Map of the Study Area

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Land Types
There are four land types in the study area. Among the land types, Medium Highland (F1) is
dominant (47%) followed by Highland (F0) which is 26% of the NCA. Distribution of area
under different land type is presented in the following Table 6.16 & Figure 6.35.

Table 6.16: Area under Land Types in the Project Area and Study Area

Project Area Study Area excluding Total Area Percent (%) of

Land Type
(acres) project area (acres) (acres) the NCA
Highland (F0) 90 14,388 14,478 26
Medium Highland (F1) 58 25,860 25,918 47
Medium Lowland (F2) 166 9,817 9,983 18
Lowland (F3) 141 4,795 4,936 9
Total 455 54,860 55,315 100
Source: SRDI 1995 and CEGIS estimation from January 2020.

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Figure 6.37: Land Type Map in the Study Area

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Soil Texture
Soil texture is the relative proportions of sand, silt and clay. It influences many other
properties of great significance to land use and management. There are four types of soil
texture in the study area which are clay, clay loam, clay loam/loam and loam. Detailed
distribution of soil texture in the project area and Study area is presented in Table 6.17 &
Figure 6.36.

Table 6.17: Soil Texture in the Project Area and Study Area

Study Area excluding Total study % of the

Soil Texture Project Area (acre)
project area (acre) Area (acre) NCA
Clay 332 21,047 21,379 39
Clay Loam - 23,725 23,725 43
Loam 123 9,086 9,209 17
Silty Loam - 1,002 1,002 2
Total 455 54,860 55,315 100
Source: SRDI 1995 and CEGIS estimation from January 2020.

Soil Quality
Soil quality data is derived from Upazila Nirdeshika of SRDI. According to that database,
organic matter concentration of that area is medium (1.71-3.4%). Nitrogen concentration is
also follows the similar trend. Soils of the study area suffers with Phosphorus deficiency.
This element’s concentration varies from low (6.1-12 ppm) to very low (<6.1 ppm). The area
is also rich is Zinc concentration in soil. In case of Boro and Sulphur concentration, the study
area shows a mixed situation with both high and low concentration. But in combination of
these elemental composition, this area is suitable for agricultural practice. According to
BARC, soil fertility status of this area is high.

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Figure 6.38: Soil Texture Map of the Study Area

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Drainage Characteristics
Drainage plays a vital role in the management of soil. Drainage classes of the project area
and Study area is Imperfectly Drained (51% of NCA) followed by Poorly Drained (49% of the
NCA) as shown in Table 6.18 & Figure 6.37.

Table 6.18: Drainage Characteristics in the Project and Study Area

Drainage Project Area Study Area excluding Total Study % of the

Characteristics (acres) project area (acre) Area (acres) NCA
Imperfectly Drained 173 28,059 28,232 51
Poorly Drained 282 26,743 27,025 49
Very Poorly Drained 0 58 58 0
Total 455 54,860 55,315 100
Source: SRDI 1995 and CEGIS estimation from January 2020.

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Figure 6.39: Drainage Characteristics Map in the Study Area

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Agricultural Resources
Existing cropping pattern by land type, cropping intensity, cropped area, crop yield and
production, inputs and irrigation are discussed below.

Farming Practice
Agricultural crops are grown by cropping seasons. There are two distinct cropping seasons
in a year viz. Kharif and Rabi seasons. The Kharif season starts from March and ends in
October while the Rabi season starts from November and ends in February. Based on crop
adaptability and crop culture, the Kharif season has been further sub-divided into Kharif-1
(March-June) and Kharif-II (July-October) season.
The Kharif-I season is characterized by the uncertainty of weather of alternating dry and wet
spells. Some agricultural potential land remains fallow in this season in the project area. In
the Study area, mainly Aus (both Local and HYV) and summer vegetables are grown in this
season.
The Kharif-II season experiences wet and cloudy environment and heavy rainfall but uneven
distribution, low solar radiation, high temperature and humidity. According to local farmers,
HYV T. Aman crop is grown in the project area and in the study area Local Aman, HYV T.
Aman, maize, and summer vegetables are grown in this season under rain-fed condition.
Rabi season crops are favoured with high solar radiation, low humidity and temperature, but
lack of adequate soil moisture depresses the crop yield. HYV Boro crop is grown in the
project area and in the Study area HYV Boro, maize, wheat, mustard and winter vegetables
are grown in the in this season.

Cropping Pattern
The most prominent cropping patterns in the project area is Fallow – Fallow – HYV Boro in
F2 land and Study area dominant cropping patterns is Fallow – HYV Aman – HYV Boro in F1
land. Detailed cropping patterns by land type in different blocks are presented in Table 6.19.
In the project area 148 acres of land is medium low land (F2), land which normally is flooded
between 90 -180 cm deep of inundation continuously for few months in flood season and
141 acres of land is Low land (F3), Land which normally is flooded between 180 and 360 cm
deep of inundation continuously for few months in flood season. In the project area F2 land
is much closed to the F3 because it’s very risky to grow more than one crop.

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Table 6.19: Cropping Patterns in the Project Area and Study Area
Project Area Study Area excluding project area
Land Total Study % of
Type Area % of Area % of Area (acre) NCA
Cropping Pattern Cropping Pattern
(acres) NCA (acres) NCA
90 20 Fallow – HYV Aman – HYV Boro 7,890 14 7,980 14
Fallow – HYV Aman – HYV HYV Aus – HYV Aman – HYV Boro 4,918 9 4,918 9
F0
Boro HYV Aus – Summer vegetables -
1,580 3 1,580 3
Maize
28 6 Fallow – HYV Aman – HYV Boro 8,990 16 9,018 16
Fallow – HYV Aman – HYV
HYV Aus – HYV Aman – HYV Boro 5,480 10 5,480 10
Boro
F1 HYV Aus – Maize – W. vegetables 4,370 8 4,370 8
Fallow – Local Aman – HYV 48 11 Fallow – Local Aman – HYV Boro 3,750 7 3,798 7
Boro Fallow – HYV Aman - Maize 3,270 6 3,270 6
Fallow – HYV Aman - Mustard 1,990 4 1,990 4
Fallow – HYV Aman - Wheat 1,267 2 1,267 2
F2 Fallow – Fallow – HYV Boro
148 33 Fallow - Fallow - HYV Boro 3,280 6 3,428 6
Fallow – HYV Aman - HYV Boro 3,280 6 3,280 6
141 31 Fallow – Fallow – HYV Boro 3,515 6 3,656 7
F3 Fallow – Fallow – HYV Boro
Fallow – Local Aman – HYV Boro 1,280 2 1,280 2
Total 455 100 54,860 100 55,315 100
Source: CEGIS, 2020 (estimated by CEGIS based on field data collected from UAO, SAAO of DAE and local farmers)

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Aman Rice straw in the project area Boro seed bed in the project area

Farmers are preparing field for Boro Rice Transplanted Boro Rice Cultivation

Figure 6.40: Present Farming Practices in the Project Area

Mustard field at Chainder more Potato field at study area

Figure 6.41: Present Farming Practices in the Study Area

Crop production
In the project area, the annual clean rice production stands at 2,161 metric tons while in the
Study area, clean rice production is 298,624 metric tons and non-rice crop production is
105,900 metric tons. Detailed data on crop area, yield rate and crop production in project
area and Study impact area are presented in Table 6.20.

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Table 6.20: Cropped Area, Yield and Production of the Project Area and Study Area
Study Area excluding
Project Area
project area
Total Total

Production

Production
Cropped Production

Yield (ton /

Yield (ton /
Crop Name
Area (Metric

(acres)

(acres)
(Metric

(Metric
(acre) tons)

tons)

tons)
acre)

acre)
Area

Area
HYV Aus 0 1.9 - 16,348 1.9 31,061 16,348 31,061
Local Aman 48 1.9 91 5,030 1.9 9,557 5,078 9,648
HYV Aman 118 2.5 295 37,085 2.5 92,713 37,203 93,008
HYV Boro 455 3.9 1,775 42,383 3.9 165,294 42,838 167,068
Total: Rice 621 2,161 100,846 298,624 101,467 300,785
S. Vegetables 0 12.5 0 1,580 12.5 19,750 1,580 19,750
W. Vegetables 0 13.5 0 4,370 13.5 58,995 4,370 58,995
Mustard 0 0.99 0 1,990 0.99 1,970 1,990 1,970
Wheat 0 3.8 0 1,267 3.8 4,815 1,267 4,815
Maize 0 4.2 0 4,850 4.2 20,370 4,850 20,370
Total: Non-rice 0 0 14,057 105,900 14,057 105,900
Grand Total 621 114,903 115,524
Source: CEGIS field estimation, January 2020, UAO, SAAO of DAE and local farmers. * Clean rice

Cropping Intensity
In the project area, net cultivated area is 455 acres and total cropped area is 621 acres,
resulting the cropping intensity to be 136%.
On the otherhand, in the Study area, net cultivated area is 54,859 acres and total cropped
area is 114,903 acres giving rise to 209% cropping intensity in the area.

Crop Damage
Crop damage information over the last five years were collected from the Sub-Assistant
Agriculture Officer (SAAO) and local farmers both for project area and Study area. A total of
5.5 Metric tons HYV T Aman crop was damaged in the project area while a total of 22 Metric
tons HYV T Aman crop was damaged in the Study area.

Irrigation
The farmers are using LLP and STW in the project area. On the other hand they are using
LLP, STW and Deep tube well in the study area. Mainly irrigation is provided for growing
HYV Boro, in the project area and HYV Boro, vegetables and other crops in the Study area.

Agricultural Inputs
Seed, labor, fertilizer and pesticide are the major inputs for crop production. The seed rate
used by the farmers in the project and Study area are given in Table 6.21. In case of rice,
the farmers are using more seed than recommended as they normally use more seedlings
per hill. In the project area, almost 70% of the cultural practices for crop production are being
done manually. So, agricultural labor for seed sowing, intercultural operations, harvest and

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post-harvest technologies is considered as one of the essential inputs for crop production.
The labor requirement is not uniform throughout the year. The rate of fertilizer use per acre
varies considerably from farmer to farmer depending on soil fertility, cropping pattern,
financial ability etc. The major fertilizers used in this area are Urea, TSP/SSP, MP and
Gypsum. Farmers reported that they were using TSP but during the field visit, it was found
they applied SSP in vegetables. The use of pesticides depends on the degree of pest
infestation. The major insects as reported by the farmers are stem borer, green leaf hopper,
and Rice bug. Local farmers reported that they were using different types of pesticides such
as Basudin, Furadan, Fighter, Rovral, Ridomil gold etc.

Table 6.21: Agricultural Inputs Used in the Project and Study Area
Pesticide
Seed Labor Fertilizer (Kg/acre) Used by Farmers Used by
Crop Name Farmers
No./ No. of Liq. (ml/
Kg/ acre Compost Urea TSP MP Zn
acre application acre) aprx.
HYV Aus 20 57 0 25 20 15 0 0 150
Local Aman 25 60 0 20 10 0 0 1-2 0
HYV Aman 20 65 0 90 30 25 0 0 125
HYV Boro 18 81 0 55 40 33 0 0 600
S. Vegetables 0.25-1.5 40 405 45 40 33 1kg 2 to 2.5 800
W.
0.25-1.5 40 405 45 40 33 1kg 2 to 2.5 800
Vegetables
Mustard 2.5 49 0 33 15 15 0 0 100
Maize 6-8 30 0 65 50 38 27 2 600
Source: CEGIS field estimation, January 2020, UAO, SAAO of DAE and local farmers

6.3.5 Livestock and Poultry

A large number of populations of the study area earn their livelihood from raising livestock/
poultry. Farmers are using cattle for land preparation but cattle health was found to be very
poor.

Livestock Population
Livestock population in the project area is very small but a large number of populations of
the Study area earn their livelihood from raising livestock / poultry. Farmers are using cattle
for land preparation but cattle health was observed very poor in both the areas. Detailed
status of livestock and poultry in the household level is presented in Table 6.22.

Table 6.22: Status of Livestock/Poultry in the Project and Study Impact Area
Project area Study area excluding project are Total study
Livestock/Poultry
No. Livestock/Poultry No. Livestock/Poultry area
Cattle/cow/bullock 490 26,605 27,095
Buffalo - 3 3
Goat 55 12,390 12,445
Sheep - 102 102
Duck 15,900 122,890 138,790
Chicken 2,650 953,400 956,050
Source: CEGIS field estimation, January 2020, ULO, DLS and local people

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Cattles are grazing in crop land under project Goats are at project area
area

Ducks are at project area Chicken is in Shotrochi village under

Thakurakona Union

Figure 6.42: Livestock and Poultry are in Project and Study Area

Feed and Fodder Shortage

The owners of the project and Study area of the livestock population are facing problems in
respect of availability of fodder and feeds during the monsoon season due to non-availability
of grazing land. During monsoon, aman crops remain in the field, when rice straw is the only
source of fodder. In addition, rice husk and oil cakes, are other common fodders in the
project as well as in the Study area. But, during the dry season, especially from late
December to late April, grazing land is available in both the areas. Poultry and duck
population at family level survives by scavenging and generally no feed supplements are
provided.

Livestock/Poultry Diseases
Productions of livestock and poultry are mainly constrained due to diseases and death of the
population. Livestock population is affected by different diseases like Tarka, Anthrax, Foot
and Mouth Disease (FMD), Black Quarter (BQ) and Hemorrhagic Septicemia (HS),
Diarrhoea and Pest Des Petits Ruminants (PPR). Major poultry diseases are duck plague,
Ranikhet (Newcastle), Fowl Pox and Fowl cholera. Moreover, the unhygienic condition of the
courtyard during this season increases the diseases of poultry birds. July to October (rainy
season) is period of spreading diseases to livestock and poultry population in large scale.

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There are many deaths of animal and birds every year because of outbreaks of diseases
due to poor drainage conditions. Detailed status of livestock and poultry diseases is
presented in Table 6.23.

Table 6.23: Major Diseases of Livestock and Poultry in Study Area

Cattle Goat Chicken Duck
Disease Timing Disease Timing Disease Timing Disease Timing
Foot and Paste des
Newcastle Duck
Mouth June-Sept petits Whole Raining
Disease Whole year plague
Disease Ruminants year season
(Ranikhet)
(FMD) (PPR)
Black
June-Aug. - - Fowl Pox Whole year - -
Quarter
- - - - Fowl cholera Whole year - -

6.4 Socio-economic Resources

6.4.1 Demographic Profile

Population and household

The demographic profile of the study area was captured from the Population and Housing
Census, 2011 and projected population up to 2020. As per the census, 480,655 people live
in 102,656 households where the average size of the household was 4.7. The population
density (per square kilometer) is 1531 with a sex ratio of 99.8 indicating that there are 99.8
males per 100 females in the study area. The projected population up to 2020 based on
1.1312 growth rate (BBS, 2012) is 531,806 where 265,632 are male and 266,175 are female.
Population distribution of the study area is presented in Table 6.24.

Table 6.24: Demographic Profile

Total Total Population

Data source Male Female Sex Ratio
Household Population Density
Census 2011 102,656 480,655 240,082 240,573 1531
99.8
Projected Population (2020) 531,806 265,632 266,175 -
Source: BBS, 2012; (Estimated to 2020)

Age composition and dependency ratio

Age structure breakdown shows (Figure 6.41) that the age group of 30-49 forms the largest
segment (21.7%), which is regarded as one of the economically active population (15-64
years of age) segments. The age group of 60 and above is smaller compared to others. The
detailed age structure which is important to calculate the dependency ratio is given below in
Figure 6:41.

12Annual growth rate of Netrokona District, Community Report Netrokona Zila, Population and Housing Census
2011 (BBS, 2012)

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 Environmental and Social Baseline

Source: BBS, 2012

Figure 6.43: Age structure by population

Dependency ratio is a measure of the portion of a population which is dependent (people

who are too young or too old to work) on other population for their living. The categorization
is made on the basis of ILO reference for opting out the potential labor force and the
dependent population. Population between 15 and 64 years is categorized as the labor force
whereas, population below 15 years and above 64 years are considered as dependents. So,
the portion of dependent and economically active population of the study area is found as
46:54 based on Population and Housing Census 2011.

Table 6.25: Dependency Ratio in the Study Area

Categories Percentage
Age up to 14 40
Working force (Age 15-64) 54
Age 65 and above 6
Source: Population and Housing Census 2011, BBS 2012

6.4.2 Land Price

The land prices of different types of land were collected during the field survey. People of
different areas, occupations, ages gave ideas about the land price. The land prices of 3
mouzas (Barni, Bhadrapara, Singhar Bangla) are given in Table 6.26. The land price is
increasing after start of some development projects (For example: Sheikh Hasina University
and Medical College) in the surrounding area. The land price is comparatively moderate than
that in other area of the country.

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 Environmental and Social Baseline

Table 6.26: Land Price for Some Specific Location

District Upazila Location Types of land Price per acre (BDT)
Homestead 1,000,000
Barni Agricultural 700,000
Commercial 1,000,000
Homestead 1,000,000
Netrokona Netrokona Sadar Bhadrapara Agricultural 700,000
Commercial 1,000,000
Homestead 1,500,000
Singhar Bangla Agricultural 1,000,000
Commercial 1,500,000
Source: CEGIS field visit, 2020

6.4.3 Employment and Livelihood

Employment status
Figure 6.42 shows that about 42.2% of the population is employed in different sectors of
which 39.8% are male and 2.4% are female. Around 40.6% of the women are engaged in
household works.

Source: Population and Housing Census, BBS 2012

Figure 6.44: Employment Status of the Study Area

The occupation of the people in the study area is mainly centred upon the agricultural sector
(87%). About 3% people are enged in industrial sector which is very low. Field findings show
that the tendency of the people growing towards non-farming sectors. They are working in
brick fields, roads and construction and many other non-farming sectors. Traditionally,
employment opportunities for women outside the homestead is very limited. Majority of the
labor activities performed by women is at household level (e.g. in rice milling, weaving etc.)
Here, most important factor is that women are moving forward to income generation
activities. Ethnic women are also working in agricultural sector.

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 Environmental and Social Baseline

Source: Population and Housing Census 2011, BBS, 2012

Figure 6.45: Occupation Status of the Studied Population

Labor availability and wage rate

The daily average wage rate of male farming and non-farming laborer at the Upazila level is
BDT 500-700 and that for female laborers is BDT 300-400. Both Male and female labors in
farming works are mostly engaged in crop cultivation. The non-farming laborers are engaged
in industries, business related works, brickfield works, earthworks, construction works, etc.

6.4.4 Literacy Rate

According to Census 2011, literacy rate, based on a definition “ability to write a letter in any
language” is 37.3%, where male is 38.3% and female is 36.4%. The national literacy rate of
both male and female is 51.8% in which male is 54.1% and female is 49.4%. It reveals that
literacy rate of the study area is very low in comparison with the national literacy rate. Figure
6.44 show the rate of literacy of male and female in study area.

Source: Population and Housing Census 2011, BBS, 2012

Figure 6.46: Literacy Rate among the Studied Population

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 Environmental and Social Baseline

6.4.5 Household Income and Expenditure

Household income and expenditure is an important indicator to assess the socio-economic
condition of people. In the study area, it was found that in most of the cases income and
expenditure vary from BDT 15,000 to 25,000 per month. Figure 6.45 shows that the average
income and expenditure ratio in this range of the study area are 53% and 50% respectively.
The lowest income and expenditure vary from BDT 7,000 to 10,000 per month and the ratio
is about 7% and 8%, respectively.

Source: Field survey for this study, 2020

Figure 6.47: Household Income and Expenditure of the Study Area

6.4.6 Poverty
Poverty was measured through self-assessment of the people in the study area. This
measurement is mainly based on monetary value. Self-assessed poverty is a well-known
method where people/farmer themselves assess their poverty on the basis of their year-
round food security and income. Their responses were assembled into three categories such
as deficit, balance/breakeven and surplus.
No poverty related data is directly provided in the Census 2011. Local people assessed that
on an average about 55% of total population living in the project area are in balanced or
breakeven condition. Their economic activities are subsistence oriented. They also reported
that 15% people belong to deficit category; they borrow money throughout the year for their
consumption. It was gathered during the field visit that about 30% people belong to surplus
category; who are either large land owner or related to business, some of them live in foreign
countries.

6.4.7 Standard of Living

Standard of living indicates the scenario of socio-economic status of the study area which
can be assessed based on housing condition, source of drinking water, sanitation facility,
and power consumption.

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 Environmental and Social Baseline

Housing condition
In the study area, overall housing condition is not good. On an average, only 0.9% house is
pucka whereas 7.3% are semi-pucka, 79% houses are kutcha, remaining houses are jhupri
(Census 2011). These indicate the low economic status of the people of the area. From the
field survey it was observed that most people are living in kutcha and jhupri houses. The
household pattern shows a grim picture of poverty in the proposed EZ area. The housing
condition is presented in Figure 6.46.

Source: Population and Housing Census 2011, BBS, 2012

Figure 6.48: Housing Condition by Households

Drinking water
Fresh water which is drinkable to maintain people’s lives in a good manner is regarded as
another indicator to assess standard of living in the study area. Different sources of water
were analysed using both primary and secondary data. Most of the people collect water from
tube-well (some use submersible pump) and other sources but tap water is very negligible
(0.2%). On an average, 89.8% people collect drinking water from tube well and the
remaining 23% collect drinking water from other sources such as ponds (Census 2011).
According to the local people, during the dry season the ground water level drops down and
the operation of hand tube-wells become difficult. Figure 6.47 shows the sources of drinking
water in the study area.

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 Environmental and Social Baseline

Source: Population and Housing Census 2011, BBS, 2012

Figure 6.49: Source of Drinking Water used by the Studied Population

Figure 6.50: Hand Tubewell for Drinking Figure 6.51: Deep Tubewell used for
Water and other Domestic Use Irrigation and Drinking

Sanitation facility
Figure 6.50 presents the sanitation facilities prevailing in the study area. It illustrates that till
now about 45% of population are using non sanitary toilet which is not satisfactory. It is also
a matter of anxiety that still 15% households have no sanitation facility. Besides, only 40%
households have sanitary toilet facilities of which 11% are water-sealed and another 29%
are non-water-sealed. So, the overall sanitation scenario of the study area is alarming from
the present perspective.

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 Environmental and Social Baseline

Source: Population and Housing Census 2011, BBS, 2012

Figure 6.52: Sanitation Facility in the Study Area

Access to electricity
In the study area, electricity supply is not satisfactory. Only 26% household of the study area
has electricity connection from national grid and remaining 74%, a large portion of the
population are out of electricity facilities. So, access to electricity of the people in the study
area is not satisfactory.

6.4.8 Communication System

There is very good transportation network such as road, rail and navigation route which can
be accessed from the proposed NEZ area. The site is at 4 km west of the Netrokona District
Headquarter and 42 km west of the Mymensingh City Corporation. The Mymensingh-
Netrokona-Sunamganj Highway is adjacent to the proposed NEZ area. Besides, a railway
line goes parallel to this road connecting Netrokona Rail Station with Mohanganj Upazila.
The Osmani International Airport in Sylhet is located east of the site at a distance of 153 km.
The nearest river port is 5 km east of the site which is located on the bank of the Kangsha
River at Thakurakona Bazar. The site is accessible by double lane road. It is planned to
widen double lane road to four lanes road so as to accommodate increased traffic pressure.
Netrokona Barobazar, the nearest market is only 4 km west and Thakurakona Bazar is 5 km
east to the site.

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 Environmental and Social Baseline

Figure 6.53: Pucca Road inside the Figure 6.54: Netrokona to Mohanganj
Project Area Railway Line

Table 6.27: Connectivity and Surroundings of Proposed Project Site

Connectivity Name Distance Direction

Nearest Road/ Mymensingh Netrokona Sunamganj
Adjacent North
Highway highway
Nearest Railway
Netrokona to Mohanganj railway line Adjacent North
Station
Nearest Airport Osmani International Airport at Sylhet 153 km East
Available inland water Thakurakona river port/ Gaglajur river
5 km / 40 km East
transport port
Nearest Village/ Barni, Singhar Bangla, Bhadrapara, East, West,
Surroundings
Residential Area Durgasrom South, North
Nearest Bazar Barobazar 4 km East
Source: Field visit 2020

6.4.9 Social Conflicts

At present, there is no reported social conflicts among local people. However, not all land
controllers of the proposed project site are not legally entitled. Therefore, social
agitation/conflict may arose regarding compensation issue.

6.4.10 Archeological Sites and Cultural Heritage

There is no archeological site within the proposed economic zone. However, there are three
archeological sites outside of the project location which are almost destroyed. Singhar
Bangla Zamindar residence (200-meter distance from the project area) is one of them which
is abandoned and almost destroyed. There are two historical sites in Narayonpur Monastery
and Dwippur Zamindar residence which are around 2/3 km away from the project site under
the Singhar Bangla union. It was found that all of the cultural heritages have historical
importance. The local elderly people and key persons could not give any historical
background of those sites. But it was gathered that the entire area was under the control of
Zamindars.

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 Environmental and Social Baseline

Figure 6.55: Abandoned Zamindar Residence in Singher Bangla

6.4.11 Ethnic Community, Religion and Culture

There is an age-old tradition and culture of the Garo, a large indigenous community of
Mymensingh region (division). This region was once renowned for its ethnic diversity and
harmony among people of different faith and cultures and vibrant display of their respective
heritage. The indigenous groups living in this study area are: Garo and Khatriya. Currently
13 HHS Garos and 70-80 HHs Khatriyas are living in the study area under Rouha and
Mougati Unions in Netrokona Sadar Upazila.
The Garo society is matrilineal and mothers inherit property and they are the head of their
respective families and get ownership of the properties from the family, a tradition completely
opposite of the Bengali people. Most of the Garos are now Christian in religion. The Garo
ethnic people also have their own culture. Their festivals are very colourful and full of music
and dancing. Christmas and Easter are the two major religious festivals. Their dress, food
habit and celebration styles can be easily distinguished from the Bengalis and other
communities. They started to embrace Christianity by the end of the 19th century when the
Christian missionaries came to their settlements.
The livelihoods of Garos in Shahpur village are mainly agriculture dependent. Rice is the
main agricultural product of this area. It was observed that the Garo community is suffering
from poverty. Most of the Garo is hard working people engaged in agriculture as day laborer.
In the Garo culture, both male and female have to work for the family. The younger members
of this indigenous group work in garments factories, beauty parlours and at times as
domestic help. Besides, some households are involved in kuchia (a variety of fish) catching
from the surrounding beels and haors. It was observed from the result of the FGDs that the
Garo community of the Rouha Union catch kuchia from the Komol Beel (project area) and
surrounding area. Most of the family of this area catch kuchia in the post-monsoon season
during recession of water in the beel area.
About 70-80 households of Khatriya community, living in Shogundia village in the Mougati
Union, is mainly involved in agriculture and bamboo crafting. Most of the families are
bamboo craft producer, mainly women group are involved in making different types of
bamboo products such as stools, mats, baskets, kula (winnowing fan), chalani (sieve),
mathal (hat), fish traps as well as decorative items. At present the demand of bamboo craft
products are decreasing due to other alternative products of less cost.
In the ethnic communities of this area, people still depend of subsistence economies. They
lost their ancestral professions, lands and properties due to illiteracy, unfavorable

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 Environmental and Social Baseline

environmental conditions, political ignorance, carelessness and lack of awareness. They are
experiencing countless challenges. As a result, they are moving away from their professions
to seek urban jobs with government and private offices, garment stores, beauty parlars, tea
gardens, factories, police and military services.

Figure 6.56: Garo Community in Figure 6.57: Khatriya (Hindu cast group)
Bhattapara, Rouha upazila, Netrokona Community in Shogundia, Mougati
Union, Netrokona

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 7. Identification and Analysis of Key Environmental Issues

7.1 Introduction
This chapter presents results of environmental screening which were conducted before
carrying out the impact assessment. This screening exercise helped to understand the key
environmental issues, to identify environmental impacts and in general it helped to
understand the scope of environmental and social impact assessment.

7.2 Environmental Sensitivity Investigation

The screening exercise started with sensitivity analysis. Attempts were made to identify
environmental and social components sensitive to the proposed NEZ construction and
operation on the basis of reconnaissance field survey and stakeholder consultation. The
preliminary results were presented in the inception report which was later disclosed to the
high officials of BEZA in the inception workshop. This preliminary assessment and thereafter
consultation and interactions helped to design the detail field investigations, analysis and
overall scope of EIA. The sensitivity investigation helped to identify important environmental
and social components which are presented in the sub-section “Environmental Asset” below.

7.3 Environmental Asset

Environmental asset is defined by important environmental and social components. The
Important Environmental and Social Components (IESC) were identified through a process
of field investigation, stakeholder consultation including consultation with local people, and
expert judgment. Thereafter, the preliminary results were shared with the ESIA team
members and later finalized in an in-house workshop with all ESIA members and few
designated experts of CEGIS. The IESCs and their rationale are presented below.

IESCs Rationale for Selection

During construction phase, interventions such as deposition of soil, civil

constructions of roads and concrete structures, mobilization of construction
vehicles etc. will create fugitive dust and emit gas. At post construction phase,
Air Quality the operations of heavy industries and transportation of logistics will emit
smoke and gases. Also, the solid and liquid waste treatment plants may cause
odor problem within the adjacent areas of the plants. As such air quality has
been considered as an IESC.

Additional noise will be generated during the construction phase by the

movements of construction vehicles, operations of construction equipment,
and construction activities. Furthermore, the installation of heavy industries
and their operation for production will cause increased noise level during the
Noise Quality
operation phase. Eventually, the generated noise, in both phases, will affect
both on campus people (such as construction workers, campus living
officials/staffs, etc.) and adjacent living community people. Therefore, noise
quality has been considered as an IESC.

According to the Feasibility Study, groundwater has been proposed as one of

Groundwater the major sources for the operation of the project. However, several
Availability studies/literatures already identified the study area as ground water-stressed,
and therefore, this withdrawal of water will accelerate the depletion further,

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 Identification and Analysis of Key Environmental Issues

IESCs Rationale for Selection

since industrial sector is one of the biggest water consumers. Therefore,
groundwater availability is considered as an IESC.

During the construction and operation phases there could be a number of

reasons for water quality deterioration. Spillage of oil from the construction
vehicles and equipment, improper disposal of solid waste and wastewater
produced by the construction activities as well as industrial production,
untreated storm water discharge, leakage of the wastewater collection
Water Quality
network etc. can cause contamination of surface water within the project area
as well as at the nearby canals. Faulty operation of the wastewater treatment
plant could deteriorate the water quality of Kangsha River where treated
wastewater will be discharged. As such water quality has been chosen as an
IESC.

As per the master plan of NEZ, the natural drainage pattern will be disrupted
by developing a higher land than the adjacent area as well as isolating the
project area from the connecting canals and thus, free flowing of water
Drainage congestion through the project area would be ceased. This might potentially cause
and Water Logging drainage congestion and water logging problems during a heavy rainfall event
in the construction phase as well as by the improper management of drainage
during the operation phase. Therefore, drainage congestion and water logging
are considered as an IESC.

Due to the establishment of the NEZ, the natural drainage connection will be
disturbed and the natural water storage capacity of the project area will be
Flooding encroached. These might exacerbate both the flash flood and monsoon flood
situation within and around the project area. Hence, flooding has been
considered as an IESC.

Construction activities might change the visual landscape of the project area.
Development of land, site preparation, mobilization of construction equipment
Landscape and
and materials, construction of on-site road network, residential area on green
scenic beauty
field site might affect the scenic beauty. So, landscape and scenic beauty has
been taken as an IESC.

The existing land type in the study area will be changed by the construction of
the proposed project as well as new industries and associated development in
Land use
nearby area. Thus, present agricultural land would be converted into non-
agriculture land. Therefore, land use has been considered as one of the IESC.

The crop production in the project site will be lost permanently due to its
conversion for industrial use. As such, crop production in the surrounding area
Crop production
would be changed because of the changes in land type and land use pattern.
Therefore, crop production is taken as an IESC.

The project area is ‘floodplain’ as it is inundated with tidal and monsoon flood,
which then becomes an ideal fish habitat during wet season. The land
Fish habitat development for the proposed project will convert this floodplain into high land,
and eventually would damage the seasonal fish habitat. Therefore, fish habitat
has been considered as an IESC.

During monsoon, this floodplain area (proposed project area) becomes a

Fish Production source of fish capture, which thus provides considerable fish stock for both
petty-commercial and subsistence fisherman. The proposed project would
affect the fish production permanently. Therefore, fish production has been

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 Identification and Analysis of Key Environmental Issues

IESCs Rationale for Selection

considered as an IESC.

The composition of fish species diversity might be changed due to loss of

Fish Species
floodplain and alternation of the Kangsha River. Therefore, fish species
Diversity
diversity has been considered as an IESC.

Fishing susceptibility might increase due to loss of fish habitat, food

Stock Susceptibility unavailability and changing of fish movement. So, it has been considered as
an IESC.

Wildlife habitat is an important component of any given ecosystem which is

composed of various plant individuals. The land development activities and
Wildlife habitat post-project operation in this intact environment would lead to changes in
wildlife habitats and their mobility. Therefore, wildlife habitat has been
identified as an IESC.

The various intervention including set up of industries would change the

Species composition existing species composition especially in the aquatic habitat. Hence, species
composition has been taken as an IESC.

500 acres of land will be acquired for the proposed project. There are seven
semi-pucca structures (shops) and a kindergarten school located inside this
Land Acquisition and
proposed site. Thus, through acquisition, landholders will be dispossessed
Dispossession
and the structures will be evicted. Therefore, Land Acquisition and
Dispossession have been selected as an IESC.

According to field data, all landholders of the proposed project site do not
have legal entitlement. Eventually, landholders without entitlements do not
receive any compensation according to the country’s land acquisition Act.
Local Conflict of Although people with legal entitlements are positive toward the project, people
Interest without legal documents expressed concerns. Thus, conflict could arise
between ‘with’ and ‘without’ entitlement holders as well as voice against the
project might also be raised. Therefore, local conflict of interest has been
considered as an IESC.

About 150 to 200 nearby households are earning their livelihoods from the
proposed project area by means of crop production (during summer) and
Loss of Livelihoods catching fish (during wet season). Therefore, the proposed project will
interrupt their livelihood source. So, the Loss of Livelihood has been selected
as an IESC.

Employment for local local people is expected to be generated during both

Employment
construction and operation period of the proposed project. Hence,
Opportunity
Employment Opportunity has been selected as an ISC.

The proposed project has been planned to be constructed close to the

Mymensingh-Netrokona-Sunamganj two lanes road. Heavy traffic for carrying
Traffic congestion
construction materials may cause traffic congestion at different junctions,
market places etc. Thus, Traffic congestion has been considered as an IESC.

The road networks are expected to be improved/developed for smooth

movement of vehicles for carrying materials, equipment during and operation
Roadway phase of the project.
communication
This would have a positive impact in the locality of the project. Thus the
roadway communication has been considered as an IESC.

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 Identification and Analysis of Key Environmental Issues

IESCs Rationale for Selection

Community health is anticipated to be negatively affected due to different

Community Health
construction activities, which would generate dust, particles and other
and Safety
emissions. This has thus been selected as an IESC.

Occupational Health and Safety (OHS) for workers is an important issue

during the construction phase, since a number of workers will need to stay at
Occupational Health the project site, get involved in risky and hazardous activities etc. This health
and Safety and safety measures usually include: availability of safe drinking water, proper
sanitation, labor-friendly shed and restroom, first aid tool box etc. for workers.
Therefore, OHS has been selected as an IESC.

The rural area of study area will be transformed into urban area due to the
Urbanization and
Economic Zone-led industrial development, which, on the one hand, will bring
Economic
economic development, and on the other hand, affect local environment
Development
negatively. Therefore, this has been chosen as IESC.

Many off-site development, i.e. infrastructural development, will be held in the

Off-site development area which will improve living standard of the local people, also affect local
environment negatively.

7.4 Environmental Hotspots

The proposed area falls in haor region. There are several beels e.g. Komol Beels, Soai
beels, Kaitta-rasi beel, Kazapuria beel and their connecting canals are locally important
ecological and fisheries hotspot. Among theme, Komol Beel and Soai beel fall within the
proposed NEZ boundary and will be acquired for the proposed land development. However,
the master plan of the NEZ considers excavation of Komol Beel to construct a permanent
lake for landscape purpose.

7.5 Impact Screening

As a part of the Environmental Impact Assessment process, a screening matrix of generic
impacts are given in the following table, which shows the activity wise impacts on different
environments: physical, biological and social. The symbol tick (√) refers to activity carries
impacts on given indicators of environment, whereas dash (-) refers to no impact. A details
discussion of impact evaluation is presented in Chapter-8.

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 Identification and Analysis of Key Environmental Issues

Table 7.1: Activity-wise Impacts Screening

Physical Biological Social

Drainage congestion and Water Logging

Urbanization & economic development

Land Acquisition and Dispossession

Occupational Health and Safety

Roadway and Communication

Community Health and Safety

Landscape and scenic beauty
Solid Waste and Wastewater

Employment Opportunity
Groundwater Availability

Local Conflict of Interest

Project Phases and Activities

Fish Species Diversity

Species composition

Off-site development
Stock Susceptibility

Loss of Livelihoods

Additional traffic
Crop production

Fish Production

Wildlife habitat
Water Quality
Noise Quality

Fish habitat
Air Quality

Land use
Flooding
Pre-construction Phase
Land acquisition and compensation - - - - - - - - - - - - - - - - √ √ √ √ √ - - - - -
Demarcation of land - - - - - - - √ √ - - - - - - - - √ - - - - - - - -
Engagement of Contractors - - - - - - - - - - - - - - - - - √ - √ - - - - - -
Procurement of labor - - - - - - - - - - - - - - - - - - - √ - - - - - -
Setting Project's bill boards - - - - - - √ √ - - - - - - - - - - - - - - - - - -
Transportation of construction materials √ √ - √ √ √ √ √ √ √ √ √ √ √ √ √ - √ - √ √ √ √ - - -
Construction Phase
Land development √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - - -
Labor shed construction √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - - -
Boundary wall construction √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - √ - √ √ √ √ - - -
Off-site infrastructure development √ √ - √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - - √
On-site infrastructure development √ √ - √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - - √
Lake development √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ √ - - -

133
 construction
Operation Phase
CETP construction
sewerage, power, gas, etc.)

Industrial Production and activities

Project Phases and Activities

Utility system development (Water supply &

IWMF (Integrated Waste Management Facilities)

√
√
√
√ Air Quality

√
√
√
√

Noise Quality

-
-
-

√
Groundwater Availability

√
√
√
√

Water Quality
Physical

√
√
√
√

√ Drainage congestion and Water Logging

√
√
√

Flooding
√
√
√
√

Solid Waste and Wastewater

-
√
√
√

Landscape and scenic beauty

-
√
√
√

Land use
-
√
√
√

Crop production
-
√
√
√

Fish habitat
-
√
√
√

Fish Production
-
Biological

√
√
√

Fish Species Diversity

-
√
√
√

Stock Susceptibility
-
√
√
√

Wildlife habitat
-
√
√
√

Species composition
-
√
√
√

Land Acquisition and Dispossession

√
√
√
√

Local Conflict of Interest

-
√
√
√

Loss of Livelihoods
√
√
√
√

Employment Opportunity
√
√
√
√

Roadway and Communication

Social

√
√
√
√

Community Health and Safety

√
√
√
√

Occupational Health and Safety

-
-
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Identification and Analysis of Key Environmental Issues

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 8. Environmental and Social Impacts

8.1 Introduction
The anticipated impacts driven by the proposed project on key environmental and social
components in different phases of the project are discussed in this chapter. If there are no
impacts, anticipated in any phase, also mentioned here. Project phase refers to timeframe
for the project completion, and thus is divided into three: pre-construction phase,
construction phase and operation phase. Pre-construction phase refers to the timeframe
from project formulation to just before the land development activities is started. The land
development work for NEZ is considered construction phase. Finally, when the NEZ
becomes ready and invites investors and their subsequent operations are started, this
timeframe is defined as operation phase.

8.2 Impacts during Pre-construction Phase

8.2.1 Physical Environment

Water Resources
No impact is anticipated against the selected IECs.

Environmental quality
No impact is anticipated against the selected IECs.

8.2.2 Biological Environment

Ecological resources
No impact is anticipated against the selected IECs.

Fisheries
Land acquisition on the proposed 500-acre area will permanently convert the floodplain, beel
and pond into a planned area for the NEZ. The estimated loss of floodplain is about 347
acres and beel is about 43 acres. The estimated fish production loss would be about 333
MT/year.

Agriculture

Impacts on Land Use

Total 500 acres land would be acquired for proposed Netrokona Economic Zone. The
existing land of this area includes 455 acres agricultural land, 43 acres perennial beels/haors
and 2 acres fresh water aquaculture respectively. The land use would be permanently
changed to industrial area due to land acquisition.

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Impacts on Crop Production

Due to acquisition of 455 acres of agricultural land, about 2,161 metric tons of clean rice
production would be lost annually. This loss includes 91 tons of Local Aman, 295 tons of
HYV Aman and 1,775 tons of HYV Boro.

8.2.3 Socio-economic Environment

Land Acquisition and Dispossession

Both government and private ownership (control) land will be acquired for the proposed
project. However, there is no plan to acquire land outside of this area for off-site
development. But, eight small structures including one kindergarten school and seven shops
within the proposed acquisition will be evicted. Thus, the proposed land acquisition will
dispossess private land holders and evict one kindergarten school and seven shops.

Local Conflict of Interest

Field findings showed that all landholders of the proposed project site do not have legal
entitlements of land. Eventually, landholders without entitlements do not receive any
compensation according to the country’s land acquisition Act. Although people with legal
entitlements are positive toward the project, people without legal documents expressed their
concerns regarding their dispossession and compensation. Thus, there is a possibility of
conflict among ‘with’ and ‘without’ entitlement holders as well as voice could be raised
against the project.

Loss of Livelihoods
There is no resettlement and rehabilitation or land acquisition provision for development of
off-site infrastructures. Seven structures and a kindergarten on the acquired land will be
displaced and would require rehabilitation. Number of affected people will lose their structure
and livelihood. In addition, for the displacement of the kindergarten a large number of
children will be deprived from education opportunity.
About 15 HHs are seasonally dependent on the land by fishing. Besides, about 150 HHs are
directly dependent on the acquired land by agricultural activities. After the land acquisition,
the farmer and fisherman will lose their livelihoods. Moreover, 13 households of Garo
community (minor ethnic group) earn their livelihood partially from the proposed project area
by means of catching kuchia. Their livelihoods will also be affected.

8.3 Impacts during Construction Phase

8.3.1 Physical Environment

At this stage of project implementation, the total land will be developed to a certain level and
then the construction of all the facilities required to establish the economic zone will be done.
The major activities include dredging of soil from a suitable source, preparation of sites and
construction of labor sheds, mobilization of construction equipment and materials, carrying
out of the soil to the project site, dumping of the soil to develop the land to a certain level. It
also involves construction of boundary wall and gates, administrative and residential areas
and other on-site infrastructures and supporting utility services such as road network,
sewerage network, green areas, solid and liquid waste management facilities, parking,

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educational institute, playground, health care facility etc. The impacts of these interventions
on various environmental aspects are described in the following sections.

Air Quality
Air pollution can occur due to the construction activities as heavy machineries and
construction vehicles will be on operation. Burning of fuel to operate the engines is the main
source of the emission of toxic gases (sulfur, nitrogen, carbon). If low emission measures
could not be undertaken, the pollution will be high, dispersed to the surrounding area, and
affect the residential areas nearby. Besides, generation of fugitive dust particles during
construction and movement of vehicles might affect the air quality. Another source of air
quality deterioration might be the incineration of any waste at the project area. The dredging
interventions required for the land development may also cause air pollution due to emission
from dredgers and houseboats.

Noise Quality
Due to the operations of heavy construction equipment, the noise level would exceed the
existing level. The primary effects of noise pollution would be on the workers. If high noise
could not be controlled, the sensitive receptors near the project area would be affected.
There is a high school very close to the project area. Besides, there are several mosques,
temples and local markets which could be impacted due to noise pollution. High noise could
also disturb the birds and other faunas, specially the migratory birds. These could eventually
impact on the overall ecosystem of this area. Besides the dredging activities may also
increase the ambient noise level.

Groundwater Availability
During the construction period groundwater will be abstracted for the civil interventions as
well as the domestic uses by the workers such as drinking, cooking, bathing and washing.
The additional demand of water will pose negative impact on the availability of groundwater,
although the degree of impact cannot be predicted without detailed study (it is beyond the
scope of this study). However, several studies/literatures already identified the study area as
ground water-stressed, and therefore, this withdrawal of water will accelerate the depletion
further. Moreover, it was gathered from the field that groundwater is available at a larger
depth benath the ground. The additional abstraction during the construction and opeeation
period could further lower the groundwater level.

Water Quality
The quality of both surface water and groundwater might get affected in the construction
phase. If the soil, which will be used for land development, contains toxic concentrations, the
toxicity could contaminate the surface water nearby. Toxicity could also leach through the
ground slowly and contaminate groundwater in the long run. During the mobilization of soil
carrying vehicles and operation of construction equipment, various wastes such as oil, mud,
dust, scrap metal, paper etc. could be generated and dispersed around. Solid wastes and
wastewater will be generated from the labor camps as well. Improper management of these
wastes could contaminate the canals nearby and deteriorate the water quality. Especially,
during the times of rainfall all the wastes from the protect area could be washed away to the
nearby waterbodies and even be travelled to Kangsha River. During dredging the river water
quality could get deteriorated from the turbulence of dredger equipment, spillage of oil and

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bilge water, improper management of waste inside the dredger etc. Contaminated water
could potentially cause diseases to the local people in case of domestic uses such as
cooking, drinking, bathing. The bad quality of water could also harm the existing fish
resources as well as the health of the micro ecosystem of invertebrates.

Drainage Congestion and Water Logging

At the present situation, the project area is a seasonal wetland which will be changed to a
comparatively higher and flat land. Significant amount of wetland area (mostly seasonal) will
permanently be lost. As a consequence, water storage capacity of the project area will be
reduced. Besides, natural drainage pathways might temporarily or permanently be blocked
due to the development of land. Due to inadequate drainage capacity water logging might be
caused within the project area. The existing drainage pathway connects the Kangsha River
with Magra River by canals crossing through the project area. As this connection will be lost,
the adjacent areas around the project site might potentially face water logging problems.

Flooding
Almost every year during the monsoon times flooding occurs around the project area. Due to
land development, the natural drainage system will be disrupted which could potentially
increase the flood risk at the surrounding areas. Especially, the areas beside the Kangsha
River might face more flood risks than the existing condition as water flowing capacity will be
partially reduced. Also, during the events of heavy rainfall, flash flood might occur within the
project area due to poor drainage capacity.

Solid Waste and Wastewater

Construction works produce a lot of debris and solid wastes that include construction wastes
such as brick chips, stones, cement ash, torn boxes of paper, ripped polythene and plastic
bags, broken glass and ceramic, scrap steel, aluminum and other metals etc. For several
purposes’ construction activities will generate wastewater. Also, from the labor camps both
greywater (wastewater from kitchen) and black water (wastewater from toilet) will be
discharged. If the wastes are not managed according to the best practices available, they
could be dispersed and deteriorate the quality of the overall environment.
Hazardous and toxic wastes unless properly managed would have harmful effects on human
health and the environment. Toxic chemicals from paint, junk batteries from equipment, oil
from vehicles and machineries, chemicals used for cleaning and polishing etc. are the main
sources of hazardous wastes. If proper precautions and guidelines are not maintained during
handling of these hazardous substances, the health of the workers could be negatively
affected. Also, improper and irresponsible dumping of such kinds of wastes could lead to
deteriorate the air and water quality around the project area.

8.3.2 Biological Environment

Ecosystem

Wildlife habitat
The project area is the combination of terrestrial and aquatic ecosystem that include large
trees and roadside vegetation. Tree community is composed of small to tall trees with
indigenous and exotic species to the peripheries of the project area. Some of them are

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providing shelter to local wildlife as breeding habitats. Besides, croplands within the project
area also provide macro habitats to some tiny wildlife like Bengal Lizard, Checkered
Keelback, Rat Snake, House Sparrow, Common Myna, Red-vented Bulbul, Rats, Common
Mongoose, Indian Civet, and so on. On the other hand, this project area is lowland with five
beels which has been recognized as feeding habitats to many resident and migratory
waterfowls like Little Egret, Little Cormorant, Indian Pond Heron, Great Egret, Common
Snipe, Spot-billed Duck, and Asian Openbill. Wetland associated with different aquatic
vegetation is also providing support to this wildlife for breeding and shelters for escaping
from predators. As per land development requirement, all habitats with associated
vegetation will permanently be damaged. In addition, wildlife habitat in project influence area
will also get deteriorated during sand mining.
During installation of utility facilities like gas, water, electricity services to the project area will
involve some earth works for pipe setting and overhead transmission lines for electricity
those will definitely destroy existing micro habitats of wildlife in the project influence area. Of
the shrub and herbs, Hill Glory Bower, Turkey Berry and Hairy Fig found associated with
micro habitats might get damaged. Therefore, it is anticipated that a good numbers of wildlife
habitats might be destroyed in this phase.

Species composition
There will be no impact on species composition with this intervention in this phase.

Fisheries

Impact on fish habitat

The proposed project will be developed at low lying area that is regularly inundated during
monsoon season. The low-lying area known as floodplain function as fish grazing, breeding
and nursing ground for many small fishes like on spot barb, Pool barb, Tyangra, Baila, Zig-
zag eel, Climbing perch, Banded gourami, Stinging catfish, Walking Catfish, Cichlid, etc.
Land development on the proposed 500-acre area will permanently convert the floodplain,
beel and pond into a plan area for the NEZ. The estimated loss of floodplain is about 347
acres and beel is about 43 acres. The land will be developed by filling sand which might be
collected by dredging from the Kangsha River.
Dredging in Kangsha River might impact fish habitat of the river. Especially Pelagic fishes
would be shifted to nearby water areas while some demersal and sedentary fish species
might die under the dredger. During dredging work, many toxic substances might be mixed
in water column which would deteriorate riverine habitat quality. Turbidity generated from the
dredging work might cause the habitat unsuitable for some fish species.
If run-on and run-off drainage are not adequately constructed in the project site during land
development, during a heavy rainfall spillage of sediment to nearby water bodies might take
place which would ultimately affect fish habitat of the nearby area.

Impact on fish production

Fish habitat loss due to construction activities will cause reduction of fish production
permanently. The estimated fish production loss would be about 333 MT/year. Most of the
fish production loss will come from Floodplain, which comprises 243 MT/year. Fish

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production loss from beel and Ponds would be insignificant. Moreover, degradation of water
quality of Kangsha River would decline fish productivity of the river. During land development
activities, if proper management are not taken like fencing/making wall within the project
area the fish habitat of the nearby area might be affected.

Agriculture

Impacts on Land Type

Land development for construction of the NEZ would change the existing 455 acres
agriculture land type. However, such change would not directly affect land type of the area
adjacent to the proposed project (NEZ) area.

Impacts on Landscape and Scenic Beauty

Construction activities might change the visual landscape of the project area. Stocking of
construction material, mobilization of construction equipment, construction activities on the
green field site might affect the scenic beauty.

Impacts on Land Use

Present land use of the proposed Economic zone comprises 455 acres agricultural land, 43
acres perennial beels/haors and 2 acres fresh water aquaculture respectively. All of these
lands would be changed into permanent structure and service area. The construction would
not directly affect the land use of the adjacent area.

Impacts on Crop Production

Since the proposed area for land development will no longer be available for agricultural
activities, 2,161 metric tons clean rice production will be lost annually. In addition, if the
construction activities extend to nearby areas, it may damage standing crops. Besides, if
adequate run-on and run-off drainage are not properly constructed, sediment spillage to
adjacent area in an event of heavy rainfall may cause damage to crops.

8.3.3 Socio-economic environment

Occupational Health and Safety

The project would involve development of land, demolishing or eviction of existing structures
and a Kindergarten school. Besides, the project activities will involve movement of heavy
construction machinery, vehicular traffic, excavation and filling operations. These activities
might cause health hazards of the construction workers. The workers might also encounter
accident while performing the activities around the construction areas due to the operation
and movement of heavy equipment, vehicles and machinery. As such, Occupational Health
and Safety (OHS) of the working labourers might be at risk. Besides, the ongoing Covid-19
is becoming a threat to human health, which is highly contagious disease. For tackling this
pandemic, special measures/equipment for ensuring Occupational Health and Safety (OHS)
of workers need to be taken into account.

Community Health and Safety

The health and safety of the local people might be impacted due to the hazards likely to be
created during the construction period. The hazards could be in terms of increased noise, air

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pollution due to dust while land filling, demolishing structures, construction of industrial
infrastructures etc. There would also be risk of accidents due to operation and movement of
heavy equipment, vehicles and machineries. The labour influx in the local area may have
chance to spread COVID-19 disease, therefore, special measures are needed.

Employment opportunity
Construction of the proposed EZ requires both skilled and non-skilled labourers, which would
create employment opportunities for poor people near the study area. Employment
opportunities will be ensured through two channels (i) direct employment for unskilled labour,
(ii) indirect employment to the local community and women workers (both skilled and
unskilled). Direct employment includes site clearance, excavation, loading and offloading of
materials and deliveries, mason and construction works. The local community members
could take advantage of these opportunities. Employment generation benefits improve the
quality of life of the labourers and enhance their productivity and living standards.
Employment generation, both direct and indirect, through Netrokona EZ will have a
tremendous impact on human development and poverty reduction in this area.

Road and Communication

The proposed project site is next to the Mymensingh-Netrokona-Sunamganj highway and
Netrokona-Mohanganj railway. There is a road, between Singher Bangla and Barni village
passing through the project site. The development project might disrupt the communication
of the two villages. Besides, for the operation and movement of heavy equipment, vehicle,
machineries, the communication might disrupt the normal communication and could damage
the road. In addition, Movement of heavy construction vehicle might create traffic congestion
at connecting road to Mymensingh-Netrokona-Sunamganj and other places.

Off-site development
During the construction period, many infrastructural development will take place, which on
the one hand, will provide facilities to the local communities; on the other hand, landowners
will lose their land.

8.4 Impacts during Operation Phase

8.4.1 Physical Environment

All the large and medium industries will be under operation while NEZ will function at a full-
scale. During this time, administrative units will be function, residential areas, parks,
playgrounds, food plaza and shopping malls will be occupied by residents living inside and
roads will be busy for movement of vehicles. Such operations will have a number of impacts
on the various environmental aspects as described in the following sections.

Air Quality
During the operation stage, air quality might deteriorate due to different activities. The major
sources of air pollution could be vehicles and the industries. Unless low emission measures
are adopted by the industries, the emissions of toxic gases would deteriorate the air quality.
Deteriorated air quality have potential negative impacts on public health. In addition, the
ecosystem could get affected by the air pollution.

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Noise Quality
The noise level of the project area could be changed due to operation of industrial
machineries. The movement of vehicles within the project would also raise noise level. The
hydraulic horns and the sounds of engines could be other sources of noise pollution if
honking could not be controlled. There would be three distinct zones (residential areas
including offices, commercial and industrial zones) within the project area wherein of noise
level should be maintained according to the standard noise rule of Bangladesh. If the
distinction is not considered carefully in terms of noise generation, sensitive receptors such
as residents living inside NEZ, patients in the hospital, young community at the schools or
playgrounds, workers and officials working inside the production chambers would be badly
impacted.
Noise may potentially spread outside and increase the noise level of the environment.
Exposure to loud noises for any length of time causes fatigue of the ear’s sensory cells
which results a temporary hear loss and if the time period is long term irreversible and
permanent hearing problems can occur. For the young children learning disabilities, anxiety,
attention-seeking behavior, reduced motivation and concentration are some of the most
likely negative impacts of loud noises (Kozak & Grundfast, 2009).

Groundwater Availability
During the operation stage, water availability will be a major issue. As stated in the master
plan, among the large industries, there will be integrated textile units, food processing
factories, ceramic industries and pharmaceutical companies. Other small and medium
industries will be light engineering and small/medium manufacturing units. The large
industries consume a lot of water per day. Depending on the specific stages of a composite
textile unit the water consumption ranges from 0.5 to 300 liter of water per 1 kg of production
(Shaikh, 2009). Food processing unit is also one of the most water intensive industries and
for the production of 1 kg of food (of various kinds such as potato, wheat, corn, rice chicken,
beef etc.) approximately 500 to 70000 liter of water is required (Kirby, Bartram, & Carr,
2003). As the numbers and types of the industries are not finalized yet, the exact demand of
water could not be assessed.
Water is not only used for manufacturing purposes, but also for drinking and domestic
purposes by the workers in the industries and the residents. According to the standard value
used by WASA, averagely a person consumes 100 to 150 liter of water per day. According
to the master plan, 40 million liters of water will be required daily based on a rough
estimation and groundwater was selected as the major reliable source of the water supply.
Surface water from Kangsha River will also be used in the wet season. Hence, in the dry
periods groundwater would be the only source of water.
As a result of various uses, the groundwater level might get depleted which would affect the
surrounding area of NEZ as well. Water scarcity could potentially affect the agriculture if
irrigation water would not be available as per requirement. The lowering of groundwater
could even lead to land subsidence in the long run. It was gathered from the field that water
availability is already an issue at certain places and the full operation of NEZ would increase
the problem. To assess the availability problem in detail a separate study is recommended
with more accurate data of demand and resources as well as scenarios with extreme
demand condition such as the combination of dry period and maximum production of the
industries.

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Water Quality
Water quality of both surface water and groundwater could be impacted if proper
management of solid and liquid wastes would not ensure. As per plan of the project, the pre-
treated effluents as well as the wastewater from the residential and administrative areas
would be collected through a sewerage network and conveyed to a Common Effluent
Treatment Plant (CETP) and Sewerage Treatment Plant (STP) respectively. Due any faulty
operation or any leakage in the collection network the surface water quality of the nearby
water bodies could be deteriorated and would not be fit for domestic use. Besides, it would
also pollute the water of Kangsha River wherein it has been planned to be disposed finally.
If this discharge is carried through open channel and the quality of treated water is not up to
the required level, local agriculture might get affected due to contamination of pollution with
irrigation water.
The solid wastes generated within the project area could be another source of pollution if not
properly managed. There will be separate collection network for the drainage of storm water.
This network will be designed to meet the Komol Beel through four outfall points and Komol
Beel will be connected with the natural drainage at the northern part of the project area. No
treatment of the storm water is proposed by the master plan. Rainwater would likely to wash
out all types of wastes and debris from the land area of the economic zone. The direct
disposal of storm water might deteriorate the water quality of Komol Beel.

Drainage Congestion and Water Logging

At the existing situation, water of Kangsha River from the north-east side of the project
crosses Komol Beel and moves through the east for a few distance and farther south to
meet Mogra River. There are three canals that execute this drainage pattern and it happens
mainly in the wet seasons. On the other hand, in the dry periods, the canals get dry at
certain points and water comes re from the Komol Beel to augment this area. According to
the plan of NEZ, the Fazar Ali canal at the northern part of the beel will be connected with
Komol Beel through a drainage canal but the connection with Krishna Khali canal at the
southeast part of the project will not be restored. There will be a regulator on the drainage
way at the northern part of the project area. Hence, the natural drainage system will be
interruoted. The Krishna Khali canal might be lost its water and at a broad scale, the
hydrology of Mogra River could be influenced negatively because of this. During the wet
seasons water coming from the north could not pass the beel and so, can cause flooding
problems in the northern parts if the regulator is closed and high water is blocked to enter
the project area. On the other hand, in case of technical flaws of the regulator, the project
area could be flooded by overflowing of the beel as the natural drainage will be disrupted.

Flooding
The flood plain area would be reduced due to filling of project area. However, l the Komol
Beel would be excavated to form a reservoir to store flood water. If the capacities of the
drainage network as well as the reservoir (Komol Beel) are not adequately designed for the
extreme conditions, then the storm water collection pipes and the Komol Beel might overflow
at the time of high flood. There were two sluice gates to control the natural drainage between
Kangsha River and Mogra River although the conditions of those gates were poor. During
operation stage of NEZ, this natural connection will be disrupted and as such, the sluice
gates will become useless unless any diversion channel is developed. There is a FCDI

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(Flood Control Drainage and Irrigation) project of BWDB at Netrokona Sadar Upazila. The
infrastructures established under this project were intended to facilitate agriculture in this
area. Due to the possible change of land use of the surrounding area of NEZ from
agricultural to residential or commercial, the irrigation outlets might no longer be required,
rather embankments to control flood would be required. As the natural drainage of the
project area will be disturbed, flooding situation might aggravate, unless need based water
management infrastructures are built.

Solid Waste and Wastewater

A substantial quantum of debris and solid wastes would be generated in the project. The
solid wastes might create environmental hazard if not properly managed. Water logging
could also occur due to faulty the drainage networks as well as drainage congestion. There
should be recycling and reusing arrangement for management of wastes, otherwise it would
be difficult to handle wastes. Besides, any local incineration of solid wastes would also emit
toxic gases that will pollute the atmosphere.
The industries and hospitals would also produce hazardous wastes. The types of the wastes
will vary depending on the characters, shapes and production procedures of different
industries. Food and textile color, toxic and sensitive chemicals used by pharmaceuticals
and hospitals, scrap metals from the engineering production units and hospital wastes are
the major examples of hazardous materials. Unplanned disposal of hazardous waste has
potential negative health impacts. Surface water as well as groundwater could be
contaminated by these wastes if not properly managed. Aquatic ecosystem might get
severely affected in case of toxic contamination in the Komol Beel which will eventually
create negative impact on the overall water quality.

8.4.2 Biological Environment

Ecosystem

Wildlife habitat
The wildlife habitat would be impacted during operation phase of the project if appropriate
measures would not be taken as per DoE standard. It is anticipated that some air borne
particles (PM10, PM2.5) will be produced during industries’ daily activities. Similarly, pollutants
e.g. chemicals, oil, grease, etc. might get released through drains to the main river system
and deteriorate water quality. It will also deteriorate healthy aquatic habitats. Feeding
habitats to waterfowls might also decline due to industrial pollution in the nearby aquatic
habitats.

Species composition
Various types of affluent would be released from different industries during construction and
operation phase of the NEZ. The effluents if not properly treated might impact tiny organisms
of both flora and fauna like minor phyla e.g. planktons, benthos, other sensitive species
which might even disappear from existing ecosystem.

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Fisheries

Impact on Fish Habitat Condition

Fish habitat of the study area would be degraded in the event of discharging untreated
industrial effluent to nearby water bodies. In such events, water quality of nearby water
bodies as well as fish habitats could be deteriorated.

Impact on Fish Species Diversity

Fish species diversity might be declined due to river water pollution if industrial wastewater
would not be properly treated before discharging into the water bodies.

Impact on Stock Susceptibility

In this project area small indigenous fish species (Ticto barb, Zig-zag eel, Climbing perch,
Banded gourami etc.) are found abundantly. Since the area would be developed for the
project, it would be no longer serve as spawning and grazing land for local beel fishes.
Therefore, during monsoon, fishes would migrate to other waterbodies for spawning and
grazing.

Agriculture

Impacts on Land Use

After the completion of this project, land use in surrounding areas might be changed at
present, major land use of study area is for agriculture. Development of EZ would attract
more infrastructural development around the project site to facilitate industrial growth
changing the land use area from agriculture to industrial land use. Some of the other
developments including construction of roads, housing facility, commercial areas including
hotels, hospital, restaurants, schools, ancillary industries, etc. might also take place in
nearby areas. The induced economic development might also result change of typical rural
and agricultural area to urban or semi-urban area which might result in a major change in
land use pattern.

Impacts on Crop Production

The infrastructural and industrial development might change the existing land use for
agricultural purpose to industrial and infrastructural development which would ultimately
cause loss of crop production.
Generally light attracts pest. Therefore, lighting of the NEZ area might cause pest infestation
to the adjacent agricultural areas which might also lead to crop damage.

8.4.3 Socio-economic Environment

Community Health and Safety

The development of the economic zone & setting up of industries would have some impacts
on the Socio-economic conditions of the area. Industrial development would involve
generation of emissions, effluents, waste and increased vehicular movements. These
altogether might have overall negative impact on the health of the people and aesthetics of
neighbouring area.

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Occupational Health and Safety

The use of machineries and other project’s equipment would put the workers and employees
at risks of fire, explosion and accident. As such, the occupational health and safety of the
workers and employees would be a concern during operation phase of the project.

Employment Opportunity
After construction, the proposed economic zone would create huge employment opportunity.
Besides, expansion of industrialization and other associated set up would also generate
additional employment opportunities and associated facilities in future for the local people.
The local market and business will also be expanded. Indirect employment would also be
generated through other opportunity such as agriculture, food production, and retail
business. Besides, the proposed EZ could create some job opportunity for the local
educated young people and outsiders. This employment generation, through Netrokona EZ
will have a tremendous impact on human development and poverty reduction in this area.

Urbanization and economic development

Urbanization is regarded as an engine of growth and development of the country. The area
selected for the proposed NEZ is now rural. The establishment of economic zone in this
area, and coming of various industries will lead to transform this area into an urban center.
Many associated infrastructures will be developed, many facilities will be established.
Eventually, regional economy will be developed leading to the contribution to the overall
national economy. This urbanization and economic development process on the one hand,
will improve the living standard of local people and increase the asset value; on the other
hand, it will create pressure on local environment, transformation of agricultural land into
industrial enterprises, and dispossession of poor/smallholders people.

Impacts of Additional Traffics

During the operation phase of NEZ, movement of an additional amount of traffics are
expected. The newly established industries will have traffics for the transportation of their
raw materials and finished products. Also, as a consequence of the economic activities and
urbanisation, the number of existing traffics will be increased. If the road networks around
the project area is not adopted accordingly, traffic congestion could be occurred. The roads
might get damaged due to the additional load of traffics. Traffic congestions and damaged
roads will cause delay in movement, which eventually will affect the community and hamper
the swiftness of all kinds of businesses. At a broader scale, these impacts may hinder the
success of NEZ. Additional traffics without proper road management and law enforcement
may cause road accidents as well.

8.5 Impact Evaluation

In addition to the impact identification and further analysis, each impact was evaluated by
the significance of each impact. The significance is defined by the magnitude and sensitivity.
The result of the impact evaluation is provided in the following table. Each impact was
evaluated for two scenarios- i) no mitigation measures adopted and ii) strict adoption of the
proposed mitigation measures. Thus, the impact evaluation indicates the residual impacts
after adoption of the mitigation measures which would help the environmental regulating
agencies to decide the fate of the proposed NEZ.

146
 Environmental and Social Impacts

The ESIA study preliminary found most of the impacts (24 out of 35) will be “major” due to
their magnitude and sensitivity if no mitigation measure is adopted. Thereafter, the ESIA
team carefully identified mitigation measures to avoid, minimize or offsetting which were
discussed in the previous chapter. The residual impacts, impact assuming mitigation
measures would at place, were again assessed. The result says among the 35 identified
impacts, 30 impact will be reduced to “minimal” and five will be reduced to “moderate.” Most
of the moderate significant residual impacts are related to occupation health and safety, and
community health, safety and security.
To understand the risk associated with the occupation health safety and security and
community health safety and security, a further analysis was carried out. Thereafter, further
advance mitigation measures and management plan have been proposed.

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 Environmental and Social Impacts

Table 8.1: Impact Evaluation

Temporal Aspects

Residual Impact15
Spatial Aspects

Significance14
Reversibility

Magnitude13
Compliance

Sensitivity
Likelihood
Potential Impacts

Pre-construction Phase
Loss of lands M Mn M Mn M M Md Md Ml
Loss of livelihood of fishermen and farmers M Mn M Mn M M Md Md Ml
Land use of the project area will be permanently changed M Mn M Mn M M Md Md Ml
Loss agriculture production (rice and fish) M Mn M Mn M M Md Md Ml
Construction Phase
Loss of natural water storage due to the encroachment of water bodies M Ml M Mn M Md H M Ml
Temporary water logging due to the disturbance of natural drainage pattern Mn Ml Md Mn Md Md H M Ml
Flooding due to loss of natural drainage connection Mn Ml Md Mn Md Md H M Ml
Deterioration of water quality by dumping toxic/ polluted soil for the land development
Mn Md Md Md Md Md H M Ml
purpose, and improper waste and wastewater management
Deterioration of air quality because of dust and gaseous emissions from vehicles and
Md M Mn Md M M Md Md Ml
equipment
Increased noise level due to construction activities, transportation, equipment running, etc. Mn Md Mn M Md Md Md Md Ml

13 Magnitude has been assessed considering temporal aspect, spatial aspect, reversibility, compliance and likelihood.
14 Significance of an impact has been assessed by its magnitude and sensitivity
15 Residual impact is the significance of an impact which was judged considering mitigation measures proposed in Chapter-9

148
 Environmental and Social Impacts

Temporal Aspects

Residual Impact15
Spatial Aspects

Significance14
Reversibility

Magnitude13
Compliance

Sensitivity
Likelihood
Potential Impacts

Accumulation of construction debris and solid waste in the environment Mn Md Md Md Md Md Md Md Ml

As per land development work all habitats with associated vegetation will permanently be
damaged. In addition, wildlife habitat in project influence area will also get deterioration M Md M Ml M M H M Md
during sand mining.
Loss of flood plain, beels and waterbodies due acquisition and land development M Mn M Mn M M H M Ml
Loss of fish production due to land development on fish habitat M Mn M Ml M Md Md Md Ml
Change of land use in the project area, and adjacent area for induced development M Md M Ml M M Md Md Ml
Damage of standing crop in the project area and area adjacent area Mn Md M Md Md Md Md Md Ml
Occupational health and safety issue for the labors Mn Mn M Md Md Md Vh M Md
Community health, safety and security Mn Md M Md Md Md Vh M Md
Creation of Employment opportunity Mn M - - M M - - -
Disruption of communication and road damage due to construction activities and
Md Md Md M Md M H M Ml
transportation of raw materials
Operation Phase
Impact of water availability due to high amount of groundwater abstraction M Md M Mn Md M H M Ml
Deterioration of water quality due to accidental discharge from CETP/ETP/STP Md Md M M Mn M H M Ml
Deterioration of water quality of Komol Beel due to the disposal of untreated storm water as
Md Mn M M Md M H M Ml
well as contamination of pollutants from storm water, accidental discharge from ETP.
Drainage congestion and water logging due to the disruption of natural drainage network Md Md Md Ml Md Md H M Ml
Delayed recession of flash flood and monsoon flood due to disrupted drainage system and
M Md M M Md M H M Ml
reduction of flood water retention area

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 Environmental and Social Impacts

Temporal Aspects

Residual Impact15
Spatial Aspects

Significance14
Reversibility

Magnitude13
Compliance

Sensitivity
Likelihood
Potential Impacts

Stress on existing water management infrastructures due to alteration of land type M Md M Mn Md M H M Ml

Deterioration of air quality because of dust and gaseous emission from industries and vehicle M Md M Md Mn M H M Ml
Generation of noise from industrial units and vehicles M Md M Md Md M H M Ml
Contamination of toxic materials with the soil, surface water and groundwater due to the
M Md M Mn Mn Md H M Ml
irresponsible management of hazardous waste
Deterioration of aquatic ecosystem in an event of accidental discharge from CETP/STP/ETP
Md Md M M Mn M H M Ml
or illegal discharge of effluent
Non-functional ETP, illegal or accidental spillage of industrial waste water might affect fish
Md Md M M Mn M H M Ml
habitat of the nearby water bodies which to be connected with the discharge channel.
Stock susceptibility of fish (SIS) would be increased of the adjacent fish habitat area M Md M Ml Md Md H M Ml
Change in land use due to induced development M Md M Mn M M Md Md Ml
Loss of crop production due to induced infrastructural and industrial development. M Md M Ml Md Md Md Md Ml
Impact on Community health, safety and security M Md M Ml Md Md Vh M Md
Risks (i.e. fire, explosion and accident) for workers and employee will be created because of
M Md M Ml Md Md Vh M Md
the use of machineries and other project’s equipment.
Extension of industrialization will generate additional employment opportunities and
M M - - M M M
associated facilities in future for the local people.

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 9. Environmental and Socio-economic Impact Mitigation
Measure

The mitigation measures of impacts have been assessed according to three basic
subsequent principles: avoidance, minimizing and off-setting of impacts. In the assessment,
“impact avoidance measures” refer to the adoption of any mitigation measure to avoid those
impacts. “Impact minimizing measures” refer to mitigation measures that can minimize
impacts at best. Finally, “impact off-setting measures” refer to mitigation measures that
would be adopted to compensate the impacts. In the following table, both environmental and
Socio-economic Impacts and associated Mitigation Plan are given. In the table, all three
principles are not discussed; instead, the applicable proposed measures are given only.

9.1 Environmental Impact and Mitigation Plan during Pre-Construction Phase

A1 Potential Impacts Mitigation Measures Institutional Responsibilities
1 IEC: Land use
Impact Offsetting Measures:
 A regional development plan should
be prepared by the concerned
Government Authority to guide the BEZA,
economic development in a planned Independent
way and to conserve agricultural Environmental
land from the invasion. and Social
Land use of the BEZA, DoE,
Monitoring
project area will be  Fallow lands should be under crop District
Consultant
permanently cultivation. Commissioner
(IESMC),
changed.  Cropping intensity needs to be (DC), Contractor Contractor,
increased outside the project area to District
overcome the problem. Commissioner
 The farmers should be trained for (DC), DoE
adopting new technology and
cultivating modern variety of crops in
the field.
2 IEC: Rice production
Impact Offsetting Measures:
About 2,161 tons  Project Affected Persons (PAPs)
rice production of losing agriculture land should be
project area would compensated as per the Law of the BEZA, DoE,
BEZA, DoE
be permanently lost Land. IESMC
per year due to the  Adequate compensation should be
acquisition of land. given for loss of crop production for
three years for development of EZ.
3 IEC: Fish habitat
During land Impact Minimizing Measures
acquisition total Adequate compensation should be
BEZA BEZA
392 acres fish provided to the pond owner for loss of
habitat will be lost. their land

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 Environmental and Socio-economic Impact Mitigation Measure

9.2 Socio-Economic Impact and Mitigation Plan during Pre-Construction Phase

Institutional Responsibilities
A2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
1 ISC: Land Acquisition and Dispossession
Impact Off-setting Measures
 Proper compensation should be
ensured to legal owner(s)
according to the provisions in
existing Land Acquisition and
Requisition Act of Bangladesh;
 Affected people should get proper
compensation in terms of
grants/allowances for structure
and for displacement;
 If possible, ensure the alternative
500 acres of land will
livelihood for project affected
acquire which would
people using/living in the khas
result in Project
land; Appointed
dispossession of implemented
landowners and  Give priority to the affected people authority
consultancy firm
eviction of structures by engaging them in different
within the area. project activities based on their
skill;
 An appropriate resettlement plan
may be prepared to enumerate
affected persons and estimate
compensation for all types of their
losses for payment;
 Employment opportunity for the
adversely affected people should
be provided by engaging
evacuees in the project
construction activities;
2 ISC: Local Conflict of Interest
All landholders of the
proposed 500 acres
of land do not have
legal entitlements, Impact Offsetting Measures:
and some have  Ensure the alternative livelihood
incomplete or no for project affected people
legal documents using/living in the khas land;
although they Project
 Give priority to the affected people Appointed
purchased or implemented
by engaging them in different consultancy firm
occupied land. Thus, authority
project activities based on their
people “without
skill;
documents” are not
eligible to get  Arrange capacity building training
compensation program;
(according to Law)
but will be affected,
which might lead to

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
A2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
local
agitation/conflict.
3 ISC: Loss of Livelihoods
Impact Offsetting Measures:
 Proper compensation should be
ensured (cash/land for land);
 Introducing deferent training
scheme (capacity building,
vocational, agricultural, fisheries,
livestock and SME training) for the
About 150 project affected people;
households earn their  Arrange different special training
livelihoods (either scheme (sewing, cattle, livestock
fully or partially) from and SME training) for the Project
Appointed
the proposed land. vulnerable project affected implemented
consultancy firm
Therefore, the land women; authority
acquisition would  Ensure the alternative livelihood
affect their for project affected people
livelihoods. using/living in the khas land;
 Give priority to the affected people
by engaging them in different
project activities based on their
skill;
 Ensure special scheme for the
ethnic community for the
restoration of livelihood;

9.3 Environmental Impact and Mitigation Plan during Construction Phase

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
1 IEC: Air quality
Impact Minimizing Measures:
Deterioration of air
quality from dust  Low emission fuel should be Contractors
due to the used for operating all kinds of operating inside
engines. the project area
vehicular
movements and  Incineration of any waste must be
gaseous emissions avoided. BEZA
of the construction Impact Offsetting Measures:
vehicles,
 Green belt along the boundary of
equipment and NEZ can be developed by BEZA
dredger
planting trees.
2 IEC: Noise Quality
Increased noise Impact Minimizing Measures: Contractors
BEZA
level due to the  Engines that produce high noise operating inside

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Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
mobilization and need to be kept isolated form the the project area
operation of the environment by keeping the
construction doors shut or putting layer of
vehicles, equipment curtains to minimize the
and dredger loudness.
 Dredging activities should be
limited to daytime only.
 Unnecessary honking should be
avoided.
3 IEC: Groundwater Availability
Impact Minimizing Measures:
Depletion of  Surface water from the nearby
BEZA and
groundwater level rivers should be used for
Contractors
due to additional construction purposes at least in BEZA
operating inside
demand for the the wet periods of the year.
the project area
construction works  Consumption of water should be
optimized and efficient.
4 IEC: Water Quality
Impact Avoiding Measures:

Deterioration of
water quality by  The pollution/ toxicity level of the Contractor
dumping toxic/ soil that will be dumped for land deployed for the
4.1 development should be tested BEZA
polluted soil for the land development
land development before dumping. activities
purpose  Polluted soil must not be used for
land development or any other
construction activity.
Impact Avoiding Measures:
 Construction of wastewater
treatment plant at the very
begging of land development
phase or at least before other
construction works start should
be initiated and wastewater
Deterioration of
treatment should be practiced. If
water quality due to BEZA and the
not possible to make proper
improper solid contractors
4.2 drainage collection network, BEZA
waste and operating inside
ditches can be excavated to carry
wastewater the project area
the wastewater.
management
 Solid wastes should be
preliminarily managed by the
workers at wherever the
construction work is going on.
Then collection, gathering and
proper dumping should be
ensured by a common authority.

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
Impact Minimizing Measures:
 Temporary wastewater retention
basin should be installed at the
proposed site for wastewater
treatment plant and ditches
should be excavated to carry the
wastewater. Wastewater should
retain there for a certain period
before disposing into the
environment. Moreover, planting
of aquatic vegetation in the BEZA and/or the
retention basin would enhance main land
BEZA
the performance of it. development
 The contractors should be contractor
complied to manage their solid
waste in a competent manner
and monitoring activities should
be operated at a regular basis to
check if any soil is dumped on
the open environment.
 Natural drainage pattern should
be kept open and active so that
no clogging of wastewater or
construction effluents occurs.
Impact Avoiding Measures:
 No solid waste and wastewater
produced inside dredger should
not be disposed into the river,
rather collected inside the
Deterioration of dredger and disposed at
designated places. Dedging
4.3 water quality due to BEZA
contractors
dredging activiteis Impact Minimizing Measures:
 Re-suspension of dredged soil
could be minimized by pausing
the dredging activities during high
discharge scenarios (rainy day,
flooding)
5 IEC: Drainage Congestion and Water logging
Impact Avoiding Measures:
 Natural drainage connections
Temporary water could be kept unchanged and BEZA and/or Civil BEZA and/or
logging due to the untouched contractors Civil contractors
disturbance of  No blocage could be caused by working for NEZ working for NEZ
natural drainage the placement of dredger
pattern equipment
Impact Minimizing Measures: BEZA and/or
BEZA
 Regular monitoring should be another

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
applied to check if any perennial consultant
natural drainage way is clogged engaged by
or reduced in capacity by any BEZA
intervention
6 IEC: Flooding
Impact Avoiding Measures:
 The formation level of the land
should be designed at an
elevation higher than the
historical peak flood level (say at
100 yr. return period flood level
plus free board). Considering the
historical maximum flood level
BEZA and/or Civil
around 12 mPWD or more than
contractor
this can be chosen as the BEZA
deployed by
minimum land elevation.
BEZA
 To avoid the monsoon flood,
temporary high dykes should be
built around the project area.
Dykes would be helpful at the
preliminary stages of land
development. This will be a hard
measure on the environment and
not certainly preferable.
Flooding due to Impact Minimizing Measures:
loss of flood  Temporary water storage could
retention area and be developed by excavating pond
natural drainage alike water bodies inside the
connection project area.
 Major rivers and canals around
BEZA and/or Civil
the project area should be
contractor
enhanced in terms of discharge BEZA
deployed by
capacity so that they would not
BEZA
overflow during wet periods
 To minimize the effects of internal
flooding, local drainage system
should be developed by
excavating temporary canals to
flash out the storm water.
 Temporary wastewater retention
basin should be installed at the
proposed site for wastewater
BEZA and/or the
treatment plant and ditches main land
should be excavated to carry the BEZA
development
wastewater. Wastewater should
contractor
retain there for a certain period
before disposing into the
environment. Moreover, planting

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
of aquatic vegetation in the
retention basin could enhance
the performance of it.
 Natural drainage pattern should
be kept open and active so that
no clogging of wastewater or
construction effluents occurs.
7 IEC: Solid waste and Wastewater
Impact Avoiding Measures:
 Solid wastes should be
preliminarily managed by the
workers at wherever the
construction work is going on.
BEZA and the
Then collection, gathering and
contractors
proper dumping should be BEZA
operating inside
ensured by a common authority.
the project area
 Wastewater produced anywhere
should be carried out through
proper collection network and
discharge with the existing and
the closest sewerage network.
Impact Minimizing Measures:
 Contractors should spray water to
Accumulation of avoid the dispersion of debris
construction debris, while the land development
solid waste and works.
wastewater that  Curtains should be used around
might impact the each site of construction works.
environment
 Construction wastes should be
collected by each contractor and
transport to the proper dumping
site. Contractors
 Wastewater retention area could operating inside BEZA
be developed where all the the project area
wastewater would be retained for
a certain period before disposing
outside of the project site.
 The contractors should be
complied to manage their solid
waste in a competent manner
and monitoring activities should
be operated at a regular basis to
check if any soil is dumped on
the open environment
8 IEC: Wildlife habitat
The project area is Impact Minimizing Measures: BEZA and
DoE
the combination of  Sand should not be collected contractors

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
terrestrial and from the vegetative area to fill the
aquatic ecosystem proposed project area;
include large trees  Loading and carrying sands to
and roadside destination should be done in a
vegetation as well careful manner to avoid damage
as lowland with five to outside wildlife habitats;
beels which has
 Spray water to entire land filling
been recognized as
area to keep adjacent location
feeding habitats to
out of dust pollution; and
many resident and
migratory  Do not overload truck in order to
waterfowls. keep sand amount manageable
Wetland associated not to damage other wildlife
with different habitats on the way.
aquatic vegetation  Dredging activities should not be
is providing support done during night time
to this wildlife for
breeding and
escape from
predators. Due to
land development
work, all habitats
with associated
vegetation will
permanently be
damaged. In
addition, wildlife
habitat in project
influence area will
also get
deterioration during
sand mining.
9 IEC: Fish habitat
Impact Minimizing Measures:
 The Komol Beel area might be
conserved for fisheries
 Land development activities
The proposed land
should be done by making wall or
development would
fencing. BEZA,
cause permanent
loss of flood plain,  Land development should be
Independent
beels and avoided during fish breeding BEZA, Environmental
season (May-September). Contractor, DoF and Social
waterbodies
Consultant, DoE
prevailing within the  Land development activities
and Local DoF
proposed 500 acre should be done in dry season.
of land  Collaboration could be made with
BIWTA and BWDB for dredging
the Kangsha river and the
dredged materials might be used
for land development after proper

158
 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
test of dredged materials.
 A detail feasibility study and ESIA
should be conducted for dredging
as well
 A detail survey should be carried
out under this study before
selecting the dredging alignment
in the Kangsha River for avoiding
important fish habitat area.
Impact Offsetting Measures:
 DoF might promote and
strengthen fish conservation
activities in nearby beels and
permanent wetlands.
 DoF could also extend training
program on advance aquaculture
technology in other beels and
wetland areas surrounding the
proposed NEZ.
10 IEC: Fish Production
Impact Minimizing Measures:
 The proposed Lake (converted
from the Komol Beel) of the NEZ
should be used for fish
production.
 The lake should be connected to
nearby canal outside of the
project area.
About 243 MT of
 The water quality of the lake
fish production
should be conserved and
would loss annually BEZA, Contractor BEZA, DoE and
monitored.
due to conversion and DoF Local DoF
of fish habitat to Impact Offsetting Measures:
NEZ  DoF might promote and
strengthen fish conservation
activities in nearby beels and
permanent wetlands.
 DoF could extend training
program on advance aquaculture
technology in other beels and
wetland areas surrounding the
proposed NEZ.
10 IEC: Land use change
Existing land use Minimizing measures
would be changed
into permanent  The government should restrict BEZA, contractor BEZA, IESMC,
unplanned and unsustainable contractor
structures in the
growth of industries outside the
project area.

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
Besides, adjacent NEZ area.
area might also get  The local government should
changed due to prepare an integrated plan to
induced guide overall economic
development. development, land use change,
transition from rural to urban area
etc.
 Agricultural land, permanent
wetland, important ecological
area, etc. should be protected
from unplanned and
unsustainable development.
11 IEC: Production loss
Minimizing measures
 The notice of economic zone
activities would be circulated to
the affected farmers before
starting of farming activities.
 The work should not be
continued through the ripened
crop fields.
 The project work should be
Damage of
delayed for allowing the farmers
standing crop in the
to harvest their standing crop. BEZA, IESMC,
project area and BEZA and DoE
area adjacent to the  Adequate compensation should
Contractor, DoE
project area. be provided to the farmers for
loss of crop production for three
years for economic zone.
 Proper fencing, run-on and run-
off drainage should be
constructed to prevent spillage of
sediment during rain or flood.
 The construction activity must be
confined within the project
boundary.

9.4 Socio-Economic Impact and Mitigation Plan during Construction Phase

Institutional Responsibilities
B2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
1 ISC: Occupational health and safety
The construction Impact Minimizing Measures:
activities with heavy  Use of Personal Protection
machinery might Equipment (PPE);
N/A N/A
have impact on  Wear mask and hands gloves
occupational health during the construction work;
and safety  Maintain a social distancing;

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
 Be careful of touching eyes, nose
or mouth.
 Clean hands often. Use soap and
water, or an alcohol-based hand
rub.
 Equipment to be used by
competent (trained) operators;
 One/two paramedics doctors for
preliminary treatment, first aid
tool box, all time ambulance
facilities should be arranged;
 Some basic facilities e.g. safe
drinking water, proper sanitation,
labor shed with light and air
should be arranged for the labor;
 Provide health insurance to avoid
accidental events like disabilities
or death of workers during this
phase of the project;
Impact Offsetting Measures
 An induction training on
occupational health & safety
should be arranged for all the
labors and professionals before
starting the construction;
 Arrangement of firefighting
equipment with training to the
staffs from workers to officers;
 Staff should be trained on
emergency hazard handling
procedures;
 Safety and awareness talk should
be ensured through EPC Project
Appointed
contractor in each day prior to implemented
consultancy firm
starting the work; authority
 Awareness knowledge should be
disseminated using local
language and instruments;
 EPC contractor should establish
grievance mechanism for the
labors with proper
documentation;
 Modern equipment and
machinery should be deployed to
reduce noise;
 Provision and use of high visibility
clothing by workers;
 Air plug should be used by the

161
 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
workers;
2 ISC: Community Health and Safety
 Impact Offsetting Measures
 Using modern and properly fit
equipment and machineries so
that sound generation is reduced;
 Using noise absorptive Panels in
order to reduce noise levels in
buildings and enclosed spaces.
 Using Sound Barrier Walls;
 Need proper danger signs/
posters to avoid accident at
construction site;
 Public awareness campaign on
The adjacent living COVID-19, safety and health
community might risks should be conducted with
get affected during local communities prior to and
Project
the construction during construction phase of the Appointed
implemented
phase by means of project; consultancy firm
authority
noise, dust,  Waste management plan, air,
accident and other soil, noise and water pollution
risks controls are required to be
adopted;
 Project area should be well
fenced;
 Ensure regular water spraying
vehicle to reduce dust (at least
twice in a day) at both project
area and adjacent project area;
 Directions given by DoE should
be obeyed during implementing
noise producing activity;
 Using water spraying vehicle to
absorb dust;
3 ISC: Employment opportunity
Impact Offsetting Measures
Construction of the
 Project surrounding unemployed
proposed EZ
potential people should get
requires both skilled
prioritized in recruitment;
and non-skilled
 Labor wage should be fixed
laborers, which Project
based on the current wage rate of Appointed
would create implemented
the project area; consultancy firm
employment authority
opportunities for  Equal employment opportunities
poor people in the should be given to women;
vicinity of the study  Provide the skill enhancement
area. training to locals to carry out
specific tasks and enhance the

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
B2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
skill of local people;
 Process of labor recruitment and
their payment process should be
transparent and influenced free
by the local influential parties.
4 ISC: Roadway and Communication
Impact Avoiding Measures:
 Construct an alternative road for
movement of the people to go to Project
Appointed
the other side of the project or implemented
consultancy firm
allow people to use the authority
The development connecting road through the
project site.
project may disrupt
the communication Impact Offsetting Measures:
of the two village.  Should deploy traffic guards in
Besides, for the the entry gate with using
operation and adequate traffic management
movement of heavy tools;
equipment, vehicle,  The existing road should be
Project
machineries, the widened to four lane road; Appointed
implemented
normal  Using adequate signs and signals consultancy firm
authority
communication to the adjacent areas;
might be disrupted  Existing earthen road should be
and might damage converting to paved road;
the road.  If possible, equipment movement
should be carried out in non-peak
hours;
5 Off-site development
During the
construction period,
many infrastructural
development will Impact Offsetting Measures:
take place, which
 Recruit local people in the Project
on the one hand, Appointed
development work implemented
will provide facilities consultancy firm
 Provide compensation to the authority
to the local
affected landholders
communities; on
the other hand,
landowners will lose
their land

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 Environmental and Socio-economic Impact Mitigation Measure

9.5 Environmental Impact and Mitigation Plan during Operation Phase

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
1 IEC: Air Quality
Impact Minimizing Measures:
Deterioration of air  The large and most potential
quality because of the emitting industries should
gaseous emission of adopt emission reduction
the industries and the technologies. Low-emission
vehicles as well as fuels should be used to run
additional particulate the factories.
matters from the  Industries should practice
additional green technologies and
anthropogenic incentives should be
interventions rewarded to the industries
based on their effectiveness
to promote the emission
control activities. NEZ authority,
industries and the NEZ authority
 Industries should be
vehicle owners
monitored whether those are
operating their emission
reduction measures efficiently
or not.
 Vehicles plying within the
NEZ should possess latest
‘fitness certificates’ which
should be checked on a
regular basis.
 Open incineration of any type
of solid waste should be
banned from the whole area
of NEZ.
Impact Offsetting Measures:
 Large and small trees should
be planted on both sides of
the circular and internal roads
respectively. NEZ Authority NEZ Authority
 Green areas should be
maintained according to the
environmental management
plan.
2 IEC: Noise Quality
Impact Minimizing Measures:
 Distinction of residential,
Increased level of commercial and industrial
NEZ authority,
noise due to industrial areas should be made and
industries and the NEZ Authority
activities and different standard for the
vehicle owners
movement of vehicles different zones should be
acknowledged by the noise
producers.

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Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
 Regular monitoring should be
carried out to check the noise
level generated from the
industries. Penalty should be
imposed in case of n
exceeding event of the
permissible standards.
 Noise minimizing measures
such as isolation of the
engine rooms, putting layers
of curtain to cover open noise
sources should be practiced
by the industries.
 Sensitive areas including
school, hospital and office
areas should be declared as
‘silent area’ and honking
within these areas should be
restricted.
 In addition, unnecessary
honking in the industrial areas
should be discouraged.
3 IEC: Groundwater Availability
BEZA, NEZ BEZA, NEZ
Impact Avoiding Measures: authority, authority,
 Alternate source like surface authorities authorities
water or other sustainable mandated to mandated to
source of water should be supply water and supply water and
explored. manage water manage water
resources resources
Impact Minimizing Measures:
 Facilities to harvest rainwater
should be set up to reduce
the pressure on groundwater
as water source.
Water scarcity due to
high amount of water  Recycle and Reuse principle
should be adopted i.e. waste BEZA, NEZ BEZA, NEZ
abstraction
water should be treated and authority, authority,
used in flushing toilet,
authorities authorities
gardening, car washing etc. mandated to mandated to
 Efficient and reduced use of supply water and supply water and
water should be practiced. In manage water manage water
this regard good quality resources resources
fittings should be used to
avoid leakage and misuse.
 Nearby water bodies should
be regularly maintained to
facilitate the safe recharge of
groundwater.

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
 Abstraction from groundwater
during wet period could be
restricted.
Impact Offsetting Measures:
 Water meter should be set to
measure water usage for
each consumer and introduce
‘pay per use’ policy.
 The rate of groundwater
should be set comparatively
higher than the other NEZ authority NEZ authority
sustainable sources to
discourage groundwater
abstraction. Moreover, the
extra earning from
groundwater could be
invested to install the other
options of sustainable water
sources.
4 IEC: Water quality
Impact Avoiding Measures:
 Open discharge of
wastewater specially from the
NEZ authority, all
industries must be restricted NEZ authority
the water users
by enforcing law, introducing
penalty and effective
monitoring
Impact Minimizing Measures:
 The sewerage and
Deterioration of wastewater networks should
groundwater quality be monitored and maintained
due to contamination regularly. Minimum leakage
of pollutants from from the source to the
4.1
storm water, sewerage disposal point should be
NEZ authority NEZ authority
pipes, open discharge achieved.
of wastewater and  Regular monitoring to
industrial effluents etc. maintain a good water quality
of the Komol Beel and other
water bodies nearby should
be done for safe recharge of
groundwater.
Impact Offsetting Measures:
 Water treatment plant could
be set up to treat groundwater NEZ authority NEZ authority
before supply and additional
payment could be imposed.
Deterioration of water Impact Avoiding Measures:
4.2 quality of Komol Beel,  The CETP and STP should NEZ authority NEZ authority
Kangsha River and be properly maintained so

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Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
other water bodies that treatment of waste water
nearby due to, and effluents is properly done.
discharge of improper  The disposal network should
treated wastewater be frequently checked
and industrial effluents undertake necessary
etc. due to fault in measures to repair leakage, if
treatment plants. any.
Impact Minimizing Measures:
 The industries could be
provided with incentive for
proper treatment of effluents
and waste water by operating
treatment plants
efficiently.The CETP, STP
and the pre-treatment plants
should be regularly monitored
and appropriate actions
should be undertaken
including replacement of the
plants if necessary. Regular
monitoring should be
conducted to prevent all types
of open discharge of NEZ authority NEZ authority
wastewater as well as
effluents.
 The quality of water of the
water bodies should be
monitored and eco-friendly
measures should be adopted
to restore water quality.

Impact Offsetting Measures:

 ‘Polluters pay’ principal could
be adopted and the penalty
could be used for treatment
water of Komol Beel and
others.
5 IEC: Drainage congestion and Water Logging
Impact Avoiding Measures:
 Natural drainage system NEZ authority,
should be maintained by
water
Drainage congestion connecting the Komol Beel NEZ authority
management
and water logging due with the Fazar Ali canal in the
authorities
to the disruption of north and Krishna Khali canal
natural drainage at the east.
network Impact Minimizing Measures:
 The drainage network as well NEZ authority NEZ authority
as the wastewater and
stormwater collection

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Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
networks should be regularly
cleaned to eliminate the
clogging problems.
 The retention capacity of
Komol Beel should be
adequate to store drainage
disposal.
6 IEC: Flooding
Impact Avoiding Measures:
 Regulators should be
constructed at the connection
points of Komol Beel and the
existing drainage canals to
control the water level inside NEZ authority NEZ authority
the project area.
 Storm water collection
network should function
efficiently and regular
maintenance should be done.
Impact Minimizing Measures:
 Dykes could be built around
the NEZ area to prevent flood
water entering from Kangsha
River. However, this might
occur additional flooding in
the surrounding areas.
Occurrence of flash  Water retention capacity of
flood and monsoon the surrounding area should
flood due to reduction be enhanced by rejuvenating
of flood plain by land the dried up beels nearby.
filling  Emergency management
plans should be developed NEZ authority and NEZ authority
integrating automatic water and water
monitoring of water level, management management
simulation and forecast of
authorities authorities
climate conditions, effective
regulation of water
management structures and
provision for emergency water
diversion facilities.
 Volume of induced flood
generated due to filing of land
could be worked out through
model and find out quantum
of runoff that could be
retained in Komol Beel,
neighboring area and balance
tothe Kangsha River.
Impact Offsetting Measures: NEZ authority and NEZ authority

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
 Compensation should be paid water and water
to private land owners for management management
taking their lands, if structures structures
necessary, to convert it for
flood water retention basin.
7 IEC: Solid Waste and Wastewater
Impact Avoiding Measures:
 All types of industrial and
residential wastes (solid
waste and wastewater) must
be disposed to the designated
BEZA and water BEZA and water
dumping place after proper
management management
treatment according to the
authorities authorities
available best practices.
 No wastewater should be
discharged in the open nature
but through the proper
collection networks.
Impact Minimizing Measures:
Accumulation of solid  Industries should adopt new
wastes and dispersion technologies to reduce the
of wastewater due to production of wastes. 3R
illegal and principle of Waste
irresponsible management (encouraged by
discharge GoB) should be included in
the production cycle.
 Recycling and reusing of BEZA and water BEZA and water
wastewater should be
management management
practiced viz. after treatment
authorities authorities
of waste water could be
recycled for use in cooling of
plants, gardening, toilets, car
washing etc.
 Efficiencies of the waste
management measures
should be monitored regularly
and incentive policies might
be adopted.
Impact Minimizing Measures:
 Industries and hospitals
Contamination of soil, should have special plans to
surface water and handle the hazardous and
groundwater by toxic toxic wastes. NEZ authority,
materials due to the  The pre-treatment plants of industries, NEZ authority
irresponsible the industries should have hospital
management of special features according to
hazardous waste the specific hazardous waste
produced.
 Potential hazardous wastes

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
should be dumped and
carried by separate collection
system and final disposal
should be integrated with the
waste management systems
of the Netrokona Sadar area.
10 IEC: Wildlife habitat
Air borne particles
(PM10, PM2.5) will be
produced during
industries daily Impact Minimizing Measures:
activities. Similarly,  Keep air and noise quality as
chemicals, oil, grease, per standard directed by the
etc. might be released Department of Environment
to the main river (DoE)
system. Pollutants  Set CETP, ETP and STP as
would deteriorate per standard prescribed by
BEZA DoE
water qualities (WQs). DoE
As a consequence,  Regular monitor the effluent
aquatic habitat health treatment plant to take care of
would be deteriorated. any problem if occur.
Feeding habitats to  Do not release untreated
waterfowls might also garbage outside of the
decline habitat quality industrial park.
due to industrial
pollution in the nearby
aquatic habitats.
11 IEC: Fish Habitat Condition

Impact Minimizing Measures:

 All types of industrial effluent
should be discharged after
proper treatment as per DoE
standard.
Non-functional ETP  Strong monitoring should be
illegal or accidental conducted to prevent any
spillage of industrial environmental hazards due to
waste water might industrial effluents.
DoE and Local
affect fish habitat of  CETP, ETP, STP etc. should DoE and DoF
DoF
the nearby water be operated automatically and
bodies which would be it should be equipped with
connected with the online monitoring system.
discharge channel.  Penalty should be imposed in
case of illegal discharge.
 Additional reservoir should be
maintained to temporarily
retain untreated WW in case
of maintenance to ETP,
CETP, STP.

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
 DoE should regularly inspect
the industrial activities and
treatment plants.
Impact Offsetting Measures:
 DoF might promote and
strengthen fish conservation
activities in nearby beels and
permanent wetlands.
 DoF might extend training
program on advance
aquaculture technology in
other beels and wetland areas
surrounding the proposed
NEZ.
12 IEC: Stop Stock Susceptibility
Impact Avoiding Measures: DoE and DoF DoE and Local
Stock susceptibility of
 Natural waterbody/adjacent DoF
fish (SIS) would be
beel should be conserved so
increased of the
that these waterbodies could
adjacent fish habitat
be used as a shelter ground
area.
for fish.
13 IEC: Land use change
Minimizing measures
 The government should
restrict unplanned and
unsustainable growth of
industries outside the NEZ
area.
 The local government should
Change in land use prepare an integrated plan to BEZA, NEZ,
BEZA, District
due to induced guide overall economic DC/Local
Commissioner
development. development, land use Government
change, transition from rural
to urban area.
 Agricultural land, permanent
wetland, important ecological
area, etc. should be protected
from unplanned and
unsustainable development.
13 IEC: Crop production loss
Minimizing measures

Loss of crop  The government should

restrict unplanned and BEZA, NEZ,
production due to BEZA, DoE,
unsustainable growth of DC/Local
induced infrastructural District
industries outside the NEZ Government,
and industrial Commissioner
area. DoE
development.
 The local government should
prepare an integrated plan to

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C1 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
guide overall economic
development, land use
change, transition from rural
to urban area.
 Agricultural land, permanent
wetland, important ecological
area, etc should be protected
from unplanned and
unsustainable development.
Offsetting measures
 Pest infestation that would
increase due huge lighting of
area could be minimized by
Integrated Pest Management
(IPM) through “Light Trap”.

9.6 Socio-Economic Impact and Mitigation Plan during Operation Phase

Institutional Responsibilities
C2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
1 ISC: Community Health and Safety
Industrial development Impact Offsetting Measures:
will involve generation  Waste management plan, air,
of emissions, effluents, soil, noise and water pollution
waste and increased controls are required to be
vehicular movements. adopted;
These altogether might  Use good quality and properly
have overall negative fit machineries so that noise
impact on the health of level could be maintained as
the people and per DoE standard.
aesthetics of area.  Public awareness campaign
on COVID-19, safety and
health risks should be
conducted with local Project
Appointed
communities in operation implemented
consultancy firm
phase of the project; authority
 Use noise absorptive
panels to reduce noise levels
in buildings and enclosed
spaces;
 Use interior or exterior walls
to reduce sound reflected
from noisy equipment;
 Use Sound Barrier Walls,
Open top enclosures to
effectively contain noise of
equipment keeping provision
airflow;

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
2 ISC: Occupational Health and Safety
Minimizing measures
 Wear mask and hands gloves
during the construction work;
 Maintain a social distancing;
 Be careful of touching eyes,
nose or mouth.
 Clean hands often. Use soap
and water, or an alcohol-
based hand rub.
Impact Offsetting Measures:
Risks (i.e. fire,
explosion and  Arrangement for firefighting
accident) for workers equipment with appropriate
training to all concerned Project
and employee will be Appointed
workers and officers; implemented
created because of consultancy firm
use of machineries  Staff should be trained on authority
and other equipment emergency hazard handling
of the project. procedures;
 Safe handling and storage of
flammable chemicals and
fuels;
 Equipment to be used by
competent operators;
 Appropriate choice of modern
equipment and machinery to
reduce risk of accident; and
 Keep provision for use of high
visibility clothing by workers.
3 ISC: Employment opportunity
Impact Offsetting Measures:
 Project surroundings
unemployed potential people
should get prioritized in
recruitment;
 Labor wage should be fixed
Expansion of
based on the current wage
industrialization will
rate of the project area;
generate additional Project
employment  Equal employment implemented Appointed
opportunities should be given consultancy firm
opportunities and authority
to women;
associated facilities in
future for the local  Provide the skill enhancement
people. training to locals to carry out
specific tasks;
 Process of labor recruitment
and their payment process
should be transparent and
influenced free by the local

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 Environmental and Socio-economic Impact Mitigation Measure

Institutional Responsibilities
C2 Potential Impacts Mitigation Measures Supervision
Implementation
and Monitoring
influential parties;
 Affected ethnic community
should get priority in
recruitment;
4 Urbanization & economic development
The establishment of
economic zone in this
area, and coming of
various industries will
lead to transform this Impact Offsetting Measures:
area into an urban
 Proper compensation and
center; eventually,
rehabilitation of
regional/national poor/smallholders
economy will be Coming industries NEZA
 Prefer affected people into the
developed. However,
recruitment of industrial jobs
this process will
transform agricultural  Arrange training for local
youths for employment
land into industrial
enterprises, and
dispossessed
poor/smallholder
people.

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 10. Public Consultation and Disclosure

10.1 Introduction
Stakeholder consultation (a two-way flow of information and opinion exchange), or simply
consultation, is a regulatory process of EIA by which the people's input on matters affecting
them is sought. Its main goals are to improving the efficiency, transparency and community
involvement in policies, programs and projects. Stakeholder Consultation is mandatory for
any development project according to guidelines of DoE, which includes approaching people
to engage them in the project and take their concerns about the impact and benefit of the
project from their point of view.
During the consultation process, the proposed Netrokona Economic Zone as well as its
impacts were discussed with local people. In the consultation process, the stakeholders got
involved with the study consultants in reforming/ developing the project interventions
considering the local needs and aspirations in line with the problems and solutions
suggested by them. The proposed interventions, findings of the EIA and the EMP were
shared with the project stakeholders for obtaining their perceptions, views and feedbacks on
the probable changes likely to happen within the project area.

10.2 Objectives and Purpose of Stakeholder Consultation

The main objectives of the stakeholder consultation/meetings were to:
 Inform local people about the goal and objective of the proposed project;
 Make people knowledgeable about the components and interventions of the
proposed project;
 Aware people about the problems that could be created from the proposed
project;
 Obtain suggestions (mitigation measures, enhancement measures, contingency
measures, compensation measures) to resolve those problems;
 Confirm that all the affected parties and stakeholders have been adequately
consulted and have been part of the various decision-making processes.

10.3 Identification of Stakeholders

Stakeholders include all those who may affect or are being affected by policies, decisions or
actions within a particular system. Stakeholders can be groups of people, organizations,
institutions and sometimes even individuals. Stakeholders can be divided into primary and
secondary categories. In the consultation meeting, both the primary and the secondary
stakeholder have been selected.
The following Table 10.1 presents the identified stakeholders at a glance-

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 Public Consultation and Disclosure

Table 10.1: Stakeholders Involved into the Project

Type of
Sl. Stakeholders
stakeholders
Local representatives, project affected people, household owners, small
1 Primary
business community, shopkeepers, pedestrians, students and women group.
Zila Parishad, Upazila Parishad, Union Parishad, BWDB, Department of
2 Secondary
Forest, civil society representatives, NGOs and others.
Source: CEGIS, 2019

10.4 Approach and Methodology

In this study, a participatory approach was followed during the consultation with both primary
and secondary stakeholders of the project. A checklist was prepared in relation to the project
intervention and to explore stakeholders’ opinion on the project and its impact. During
consultation the techniques like: a) stakeholder consultation meeting b) focus group
discussion c) informal discussion and d) key informant interview were used to explore
problems and possible suggested measures; to share the project activity and to obtain
perception on tentative impacts of environmental and social components. List of stakholders
and photographs are given respectively in Appendix- II & III.

Table 10.2: Location of Consultation and Discussion during the Field Visit

Type of Number of
District Upazila Place Date Time
consultation Participants
Netrokona Upazila
Netrokona PCM 12.01.2020 11.00 AM 40
Sadar Parishad
Netrokona Key Informant
Netrokona Zila Parishad 11.01.2020 2.30 PM 1
Sadar Interview
Netrokona Upazila Key Informant
Netrokona 12.01.2020 10.00 AM 1
Sadar Parishad Interview
Netrokona Singher Bangla Key Informant
Netrokona 11.01.2020 3:00 PM 1
Sadar Union Parishad Interview
Netrokona Thakurakona Informal Group
Netrokona 11.01.2020 4:30 PM 8
Sadar village Discussion
Netrokona Informal
Netrokona Project area 11.01.2020 9.00 AM 8
Sadar Discussion
Netrokona Informal
Netrokona Jamtola village 12.01.2020 4.30 PM 3
Sadar Discussion
Netrokona Informal
Netrokona Barni village 11.01.2020 10:30 AM 35
Sadar Discussion
Netrokona Bhadrapara Informal
Netrokona 11.01.2020 12.30 AM 10
Sadar village Discussion

10.5 Major Problems and Suggested Measures

During all the Consultation Meeting, the project and its related activities as well as several
issues with reference to the project were discussed. The CEGIS team found that the people
of the area showed an overall positive attitude toward the proposed project in general as

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 Public Consultation and Disclosure

they feel that implementation of this project would play great role for development of the
region as well as the country. However, the participants expressed their concerns on several
issues which seemed reasonable.
People’s suggestions about the site are presented below in brief:
 Local people expressed positive attitude toward the proposed project
interventions as people will get employment, business opportunity;
 People are aware about the project and expect good employment generation
from the EZ;
 Local people should be provided employment opportunity in the EZ as most of
the people of this area are labor and practice agriculture;
 They emphasized that jobs should be given to locals during both construction and
operation phase preferably as there is large scale unemployment;
 People expect agro based industries to come up in region which will help them
selling their products easily. Also they expect the authority will train them to
enhance their productivity by using HYV seeds and modern equipment’s.
 Fish based industries should be established as there are lots of people are
dependent on fishing;
 People of Bhadrapara, Singher Bangle and other villages expressed their positive
attitude regarding the quick implementation of the project;
 They also aware about the pollution and they want only non-polluting industries
should come up in this region and measures should be taken by industries to
control the pollution levels;
 They insisted that polluting industries should not be set up in the EZ zone;
 They (local people) suggested that the water discharge from the EZ should be
handled properly;
 The land acquisition and compensation process should be in proper way;
 Construct an alternative road instead of the connecting road passing through the
project site; or the road will be open for the local people;
 There is no problem to construct a EZ but the proposed EZ should be eco-
friendlier;
 According to the Barni village people, about 30% of land is three cropped land
and they would not lose the land permanently;
 They also showed their negative attitude about the project as they would lose
their livelihood (both agriculture and fisheries);
During consultations, local people identified that the proposed project might create some
problems but they showed keenness to proactively work to resolve these minor problems.
They expressed that after implementation, the project would be beneficial for the region as
well as for the country.
A combined table on multidisciplinary problems/issues and solutions/measures is given
below.

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 Public Consultation and Disclosure

Table 10.3: Major Problems and Suggested Solution by the Stakeholders

Issues Problems Solution
 Change in land type should be limited within
Land type of project area will project area.
be changed due to land filling.  Soils for land development should not be taken
from agricultural land.
 Construction of labor shed, site office and
stockyard of construction materials and machinery
should be within a limited area in the project
Change of visual landscape boundary.
and also reduce the scenic
 The project area should be fenced prior to initiate
beauty.
construction activities.
 Limiting site clearance and base stripping activities
within the project boundary.
 A regional development plan should be prepared
by the concerned Government Authority to guide
the economic development in a planned way and
to conserve agricultural land from damage due to
project related activities.
 Land use of the project area  Fallow lands should be put under crop cultivation.
will be permanently  Cropping intensity needs to be increased outside
changed. the project area to overcome the problem.
Land and  In the adjacent areas, land  The farmers should be trained for adopting new
Agricultural use may also be changed technology and cultivating modern variety of crops
Resources for induced development. in the field.
 The government should restrict unsustainable
growth of industries outside the NEZ area.
 Agricultural land, permanent wetland, important
ecological area, etc. should be protected from
unplanned and unsustainable development.
 The notice of economic zone activities would be
circulated to the affected farmers before starting of
farming activities.
 About 2,161 tons rice  The work in the project area should be carried out
production of project area after harvesting of standing ripened crops.
would be permanently lost  Adequate compensation should be provided to the
per year due to acquisition farmers for loss of crop production for three years
of land. for due to implementation of the economic zone.
 Crop damage may also  Proper fencing, appropriate drainage network
occur nearby NEZ area due should be constructed to prevent spillage of
to induced infrastructural sediment during rain or flood.
and industrial development.  The construction activity must be confined within
the project boundary.
 Pest infestation can be minimized by Integrated
Pest Management (IPM) through “Light Trap”.

 The proposed land  The Komol Beel area might be conserved for
Fisheries development will cause fisheries.
Resources permanent loss of flood  Adequate compensation should be provided to the
plain, beels and waterbodies pond owner for loss of their land.

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 Public Consultation and Disclosure

Issues Problems Solution

prevailing within the  DoF may promote and strengthen fish culture
proposed 500 acre area. activities in nearby beels and permanent wetlands.
 Non-functional ETP illegal or  All types of industrial effluent should be discharged
accidental spillage of after proper treatment as per DoE standard.
industrial waste water might  Additional reservoir should be maintained to
affect fish habitat of the temporarily retain untreated in case of
nearby water bodies which maintenance of ETP waste water.
would be connected with the
 Strong monitoring should be conducted to prevent
discharge channel.
any environmental hazards due to industrial
 Fish species diversity might effluents.
decline due to river water
 DoF can extend training program on advance
pollution if industrial waste
aquaculture technology in other beels and wetland
water would not properly
areas surrounding the proposed NEZ.
treat before discharge.
 To construct the proposed
enormous project activities,
it will require a large number  Project authority should ensure that the local
of manual skilled and labors would get priority in recruitment by the
unskilled labor. In this contractor.
regard, the recruitment could  The labors including the local labors should be
be influenced by the local trained properly before engagement in the project
influential parties. The local work including occupational health and safety.
people can be deprived from
recruitment.
 The local people expressed
their anxiousness as the
water discharged from the  Ensuring proper drainage channel inside and
NEZ might contaminate and outside the EZ location and if possible, the drained
inundate the surrounding water could be treated or recycled for reuse.
Socio- crop lands in absence of
Economic proper drainage system.
Condition  Connecting road inside the
project site might be
 Alternate road should be constructed to facilitate
disrupted or demolished due
movement of the local people;
to construction of the
project.

 Health safety and security should be ensured

during the construction and the post construction
phases of the project. The accidents and unusual
events should be avoided to the extent possible
 Health and safety security of during construction of the proposed EZ which
the local community might affect peoples’ health especially that of
aged, women and children. As such, during
construction work, a safety plan and its
implementation should be ensured through
monitoring.

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Public Consultation and Disclosure

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 11. Environmental and Social Management Plan

11.1 Introduction
With the aim of ensuring avoidance, minimization, and offsetting of adverse environmental
impacts and enhancement of beneficial impacts The Environmental and Social Management
Plan (ESMP) has been prepared. The ESMP includes Environmental Code of Practices, and
ESMP during pre-construction phase, construction phase and operation phase, and special
ESMP. Generally, the impacts, which are minor or moderate, will be mitigated by adopting
Environmental Code of Practices during construction and operations. On the other hand,
impacts which are critical or major are to be prevented or mitigated by adopting mitigation
measures as discussed in the earlier chapter.

11.2 Objective of Environmental and Social Management Plan

The basic objective of the EMP is to manage adverse impacts of proposed NEZ in a way,
which minimizes the adverse impact on the environment and surrounding community. The
specific objectives of the EMP are to:
 Facilitate the implementation of the mitigation measures identified during the
present EIA to comply with regulatory requirements and discussed earlier in the
document.
 Maximize potential project benefits and control negative impacts.
 Include measures beyond compliance to enhance the community well-being.
 Draw responsibilities for project proponent, contractors, consultants, and other
members of the Project team for the environmental and social management of
the Project;
 Define a monitoring mechanism and identify monitoring parameters in order to:
o Ensure the complete implementation of all mitigation measures
o Ensure the effectiveness of the mitigation measures
 Maintain essential ecological process, preserving biodiversity and where possible
restoring degraded natural resources; and
 Assess capacity building and training requirements for different stakeholders at
various levels.
The EMP will be managed through a number of tasks and activities and EMP Sub-plans.
One purpose of the EMP is to record the procedure and methodology for management of
mitigation and enhancement measures identified for each negative impacts of the NEZ. The
management will clearly delineate the responsibility of various participants and stakeholders
involved in planning, implementation and operation of the Project.

11.3 Management Responsibility/Inclusion of EMP in Contract Documents

In order to make the Contractors fully aware of the implications of the EMP and responsible
for ensuring compliance, technical specifications in the tender documents will include
compliance with mitigation measures proposed in the EIA as well as IFC EHS guidelines.

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The Contractor must be made accountable through contract documents for the obligations
regarding the environmental and social components of the project.

11.4 Environmental Code of Practices

A set of environmental codes of practice (ECPs) has been prepared for various
environmental and social management aspects: ECP 1: Waste Management; ECP 2: Fuels
and Hazardous Goods Management; ECP 3: Water Resources Management; ECP 4:
Drainage Management; ECP 5: Soil Quality Management; ECP 6: Erosion and Sediment
Control; ECP 7: Top Soil Management; ECP 8: Topography and Landscaping; ECP 9:
Quarry Areas Development and Operation; ECP 10: Air Quality Management; ECP 11:
Noise and Vibration Management; ECP 12: Protection of Flora; ECP 13: Protection of
Fauna; ECP 14: Protection of Fisheries; ECP 15: Road Transport and Road Traffic
Management; ECP 16: Construction Camp Management; ECP 17: Cultural and Religious
Issues; ECP 18: Workers Health and Safety, and ECP 19: Construction and Operation
Phase Security. The Contractors will be contractually obligated to comply with these ECPs,
presented in Appendix-IV.
The contractors need to prepare site specific construction management plans to address
various environmental issues, and to demonstrate the manner in which the Contractor will
comply with the requirements of ECPs and EMP. It will be reviewed and approved by
Construction Supervising Consultant, ESHS Unit, and Project Implementation Unit before
implementation of construction works.

11.5 ESMP during Pre-construction

Compensation Plan
About 2,161 tons rice production of project area would be permanently lost per year due to
the acquisition of land for development of NEZ. The following measures should be followed:
 Project Affected Persons (PAPs) losing agriculture land should be compensated
as per the Law of the Land.
 Adequate compensation should be provided to the farmers for loss of crop
production for three years for economic zone.
 Proper compensation should be given to the land owners by their bank account.

Labor Recruitment Plan

A number of manual labor and technical labor would be engaged for land development and
dismantle the existing structures at the project site. The labor recruitment policy should be
formulated in such a way that the local laborers would get preference in employment in the
project works. The local labors should get priority in dismantling activities in pre-construction
phase. The experienced and semi-skilled local people should also get priority in project
activities. Technical and vocational training might be provided so that these labors could be
engaged in the construction and operation phase of this project.

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Livelihood Restoration Plan

The Project will use both khas and private land which causes loss of livelihood resources
and income. The livelihood restoration plan as a part of the Environmental and Social
Management Plan of this study sets the livelihood restoration program so that the Project
can take initiative to avoid severe long term hardship and impoverishment of the Project
affected households following the relevant national law (the Acquisition and Requisition of
Immovable Property Act 2017) and international good practices. Therefore, a mitigation of
physical and economic displacement of the Project affected households needs to establish
to ensure improvement or at least restored the land owners’ and land users’ livelihoods.

i) Project Impact on the Affected Households

The Project affected land is used mainly for crop cultivation and fishing; a few households
(7) use the land for petty business purpose. There is also a community property – a kinder
garten school in the Project area. About 178 households will lose their access to the land
due to loss of the agricultural land, fishing ground, a small market place where seven (7)
small shops are situated. Out of 178 households, 150 are farming and 28 (including 13 Garo,
the ethnic people) fishing households. The farming and fishing households depend on their
land seasonally. From among the affected households about 30-40% are private land
owners and the remaining are users of the khas land. The Project, however, will cause
economic displacement of 171 households, physical displacement of the kinder garten
school, and both physical and economic displacement of seven (7) households out of 178.
Besides, there might be some sharecroppers, agricultural laborers, and wage laborers (in
the shops) who will be impacted.
All private/titled land owners will be compensated for loss of their land and standing crops.
The non-titled farming and fishing households will be compensated for their standing crops
also. The affected businesses owners will receive cash assistance for loss of business
premises and income. Loss of employment of the affected wage labors due to impact on
income will be supplemented with cash allowance. All the affected households irrespective
of title will be assisted with cash allowances for the transition period. This assistance is
intended to help them re-establish their enterprises in new locations and to continue their
previous occupations and commercial activities in the new locations.

ii) Additional Benefit Package for the Affected Households

In addition to the compensation and cash allowances this Livelihood Restoration Plan (LRP)
suggests the package of the livelihood restoration program to the economically affected
households. The economically affected households are provided with benefit of the targeted
set of livelihood restoration programs training (table 11.1). This training should include
financial training for the sustainable use of cash compensation and allowances on small
household investments, saving strategy and financial planning on the household level.
These programs should be able to support the affected persons to gain a similar or even
better livelihood, independently. One adult member, however, from each of the affected
households will be given chance for livelihood restoration program training. Below table
shows proposed livelihood restoration program by affected households and implementing
organization.

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Table 11.1: Proposed livelihood restoration program

Training Implementing
Selected business/enterprise Households
components organization
Vegetables and crops 150 farming households BEZA
(depending on need
Agriculture assessment and crop (any other affected (by appointing
suitability of the settlement households willing to implementing
area) participate) agency)

Cattle in zero grazing

BEZA
Poultry production 28 fishing households (any
Livestock other households willing to (by appointing
Goat keeping participate) implementing
agency)
Apiculture (beekeeping)
Hair dressing
Tailoring BEZA
7 shop keeping households
Off-farm (by appointing
Restaurant (any other households willing
Business implementing
to participate)
Stock and sale of agricultural agency)
commodities
Business plan
All (187) BEZA
Business Linkage to financial institutions
development affected households (by appointing
trainings Entrepreneurship (depending on willing to implementing
participate) agency)
Cooperative formation

Other than those benefits the Project should higher unskilled laborers from the affected
households for the construction activities under the Project. The contractor will give
preference to hiring affected persons willing to work in Project construction activities. In the
operation phase the Proponent can take initiative for employment opportunities in different
industries based on their (affected persons) skill. Employment in the Project construction and
post construction periods will act as an added source of income in the income and livelihood
restoration processes of the affected households.
Relocation of Kinder Garten School
The affected Kinder Garten School should be relocated before the commencement of the
Project implementation so that the Project activities do not interrupt the regular educational
activities of the school.

Stakeholder Engagement Plan

The project authority should prepare a stakeholder engagement plan in detail before
implementation of the Project construction works. During construction, a close liaison with
community and local government institution should be maintained. The local community and
local government institution should be made aware of all the construction activities and
possible environmental and socio-economic disturbances. A community liaison officer or
Health and Safety Manager should be given responsibility of maintaining close
communication with community groups, local government institutions and concerned
government departments.

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Grievance Redress Mechanism

Grievance Redress Mechanism (GRM) is an important criterion for development Projects to
reduce potential risks of Projects. GRM also offer communities an effective avenue for
expressing concerns and achieving remedies, and promote a mutually constructive
relationship. The fundamental objective of the GRM will be to resolve any Project related
grievances locally in consultation with the aggrieved party to facilitate smooth
implementation of the EMP. As a general policy, Project Implementation Unit (PIU) will work
towards preventing grievances through implementation of impact mitigation and community
liaison activities that anticipate and address potential issues before they become grievances.
Minor issues will be solved by the EPC contractor.
Two Grievance Redress Committees would be formed: one at the local level- Local
Grievance Redress Committee (LGRC), and another is project level- Project Grievance
Redress Committee (PGRC). The LGRC comprises a representative of the Contractor,
Project Authority, Local Government (LGI), and locally respected persons. On the other
hand, PGRC comprises the Project Director, a member of BEZA, and other member from
the Ministry.
Most of the grievances should be resolved at LGRC within 7 days of receipts of compliant,
while a few might be forwarded to the PGRC, which will take two weeks to resolve the
compliant. It will be finalized after being shared with the LGRC and getting their consent.
Otherwise, this issue will be forwarded to the Project Steering Committee (PSC) in the
Ministry for redressing the grievance.

11.6 ESMP during Construction

Land Development Management Plan

Land development management plan should be maintained during construction phase.
According to the existing plan, land filling materials will be collected by dredging materials
from Kangsa River. Since this assessment study does not focus on impacts in the dredging
site exclusively (because of the study limitation), a separate assessment study is highly
recommended for managing the dredging site.
The following management plan should be considered during the land development stage:
 All topsoil should be retained and reused where possible e.g. in landscape and
garden area;
 Scheduling activities (as far as possible) to avoid extreme weather events, such
as heavy rainfall and high winds;
 Covering or spraying water on stockpiles of excavated material;
 Collection of surface runoff or extracted groundwater contaminated by silt and
suspended solids by the on-site drainage system and removal of silt in silt
removal facilities prior to discharge into storm drains;
 Appropriate surface drainage should be designed and provided where necessary;
 Drainage systems, erosion control and silt removal facilities should be regularly
inspected and maintained to ensure proper and efficient operation at all times
and particularly following rainstorms. Deposited silt and grit should be removed
regularly.

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Occupational Health and Safety (OHS) Plan

Use of Personal Protective Equipment (PPE) should be made mandatory for each project
personnel, worker and even for the visitors. Necessary OHS training should be provided to
the project employees. Awareness program should be arranged regularly. Safety talk, safety
meeting, safety motto, etc. are good techniques of raising awareness which should be
practised. A detailed Occupational Health, Safety and Environment (OHSE) Plan should be
prepared by the Project authority considering the following:
 Occupational Hazard Identification and Control Plan
 Inspection and Auditing Plan
 Leadership and Administration Plan
 HSE Communication Plan
 Required PPEs
 Site Security Plan
 OHSE Program for the Contractors/Sub-Contractors
 Preventative Maintenance Plan
 Incident Investigation Mechanism

Drainage and flood management plan

The drainage connectivity of the NEZ with the surrounding area is very important as
drainage congestion and flooding incidents are highly undesirable in the industrial areas.
The management plan for drainage system and flood risks should include the following
aspects:
 drainage canals to control the water level at an emergency situation.

Water pollution management plan

 Pollution of the surface The natural connectivity of the Komol Beel with Fazar Ali
canal at the north and Krishna Khali canal at the east should be established.
 The connection channels should regularly be maintained and any types of
clogging should be removed to restore the fluent flow of drainage water.
 Hydrological model should be developed to estimate the maximum water
retention demand of the NEZ and adequate storage capacity should be provided
by adjusting the area of Komol Beel and excavating waterbodies in the green
areas to retain water.
 The land should be developed at an elevation higher than the mean peak flood
level.
There should be regulating gates on the both connection points of the Komol Beel with the
water within the NEZ area ( Komol Beel and the drainage network) and the surrounding area
as well as the groundwater could be an important issue. The management plan to control the
water pollution during construction phase should include the following manners:
 The natural drainage connectivity of the Komol Beel with the surrounding canals
should be given priority. It should be ensured that the connection does not get
hampered at any stage of construction.

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 The wastewater treatment plants should be built at the beginning of the

construction works start. If not possible, a temporary water retention basin should
be built to collect the wastewater, which would retain wastewater before
disposing into the nature for certain time period. Facilities to provide nitrification
and denitrification processes should be available in the retention basin.
 The treated water from the wastewater or the retention basin should be dumped
at the Komol Beel which will eventually mix with the natural waterways and be
diluted further.
 Washing of construction vehicles and equipment in the nearby water bodies
should be strictly avoided.
 Septic tanks near the labor sheds should be provided for maintaining better
hygienic and sanitation condition.
 Disposal of any type of waste in the water bodies should be strictly avoided.
 Contractor should prepare facilities for the disposal of solid and liquid wastes
produced during construction.

Air pollution management plan

During the construction phase, air pollution from the heavy vehicles and equipment would
deteriorate the ambient air quality which should be handled carefully. The management plan
to control air pollution should encompass the following issues:
 Operational efficiency of the vehicles and machineries should be tested by the
contractors before deploying for the works.
 Low emission fuels should be used and monitoring of the fuel uses should be
scheduled by the BEZA.
 The emission points should be equipped with available techniques to dilute the
emission before disposing into the atmosphere.
 Sufficient number of trees should be planted along the boundary of the NEZ
before start of the infrastructural activities.
 Construction sites of the residential buildings, offices, supporting facilities and
other structures should be properly covered to stop dispersion of debris and
dusts.

Noise pollution management plan

The heavy construction vehicles and equipment might increase noise level and cause noise
pollution. Noise level should be maintained within acceptable range by initiating the following
plans:
 Engine rooms should be kept shut during the operation periods.
 Civil interventions that produce loud noise should be operated during day times
only.
 Construction sites should be fenced to contain noise.
 Honking of any vehicle inside the project area should not be allowed. Contractors
should be given proper instruction on this particular issue.

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 Workers should use ear muffs while operating heavy equipment and machinery
generating noise of >85 dBA continuously for 8 hours or more.
 Equipment and machineries should be of good condition and should be operated
carefully to avoid disruption of the daily activities of the project site.
 The contractors should mobilize all construction equipment, machineries and
materials during night time instead of day due to existence of school and
Paurashava office in front of the project area
 Equipment and machineries should be of good quality and should be operated
carefully so that it does not make high noise that might disrupt the daily activities
of nearby educational institutions, offices and religious centers;
 Construction machineries should have proper mufflers and silencers;
 Noise levels from the construction machineries should comply with national noise
standards;
 Provision should be made for noise barriers at construction sites if needed.

Waste management plan

The various wastes produced during the land development and construction phase should
be managed properly to control the environmental pollution. The waste management plan
should include the following methods:
 Solid wastes should be gathered preliminarily by the contractors at each site.
 Central collection system should be introduced and sustainable dumping
techniques should be undertaken.
 Incineration of solid wastes inside the project area should be avoided.
 The labor sheds should be provided with latrine and septic tanks for maintaining
better hygienic and sanitation.
 Liquid wastes including construction effluent should be collected through
temporary or permanent sewerage and effluent network and carried to the
permanent treatment plants or temporary water retention basin. The retention
basin should be facilitated with natural nitrification and de-nitrification processes
to treat the wastewater.
 The quality of the treated wastewater should be regularly checked.
 The treated wastewater could be disposed into the Komol Beel through the
natural drainage connectivity.
 The workers should be aware of the appropriate handling of the hazardous
chemicals and materials.
 Open disposal of hazardous wastes must be avoided.
 Monitoring of the overall waste management activities should be operated at a
regular basis and charging penalty to the contractors in terms of violating the
management plans should be practiced.

Transportation management plan

During construction period for proposed EZ, usual traffic might be disturbed. Construction
work will be executed in consideration of the busy traffic of both vehicles and pedestrians in

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appropriate times of the day to limit disruption. The transportation problems should be solved
according to the following plans:
 Mobilization and transportation of construction materials carrying vehicle should
be limited during day time and could be mobilized at off-peak hour or at night
 There should be new temporary road network for the mobilization of the
construction vehicles. The road should be designed especially for heavy vehicles.
 For the local people there should be a separate road or a separate lane in a
newly developed road that will cross the project area from the north to the south
so that the existing communication would not get interrupted.
 If possible the Netrokona-Sunamganj highway which is adjacent to the project
area should be improved at this stage. In the master plan of off-site
infrastructures, this highway is proposed to be widened from 2 lanes to 4 lanes.
This should be implemented simultaneously so that traffic congestion could be
avoided.
 There should be two temporary gates and surveillance should be available there
including temporary office room, guards, monitoring panel with footage from close
circuit cameras etc. The guards should play active roles while entering or exiting
of any construction vehicle which could potentially cause traffic congestion at the
gates.
 Traffic signs and flagmen should be placed at the strategic locations to facilitate
easy movement of traffic.

Fisheries Resources Management Plan

Fisheries management plan has been developed with the aim of avoiding big loss for
fishermen and degradation of fish habitat of the Kangsha River. The EMP includes the
followings:
 Enforcement of ECR 1997, IMO Conventions to avoid or little disturbance to
aquatic habitats;
 Survey should be done before selecting the dredging alignment in the Kangsha
River for avoiding important area of interest from fishery point of view.
 The land filling activities should be done in dry season so that monsoon season
can be avoided.
 Land development should be avoided during fish breeding season (May-
September).

Prevention of Soil Spillage to adjacent Agricultural Land Management Plan

The rain or flood might cause spillage of sediment to nearby agricultural land of NEZ area
which might cause crop damage of nearby lands. The following measures should be
followed to prevent of soil spillage to NEZ area adjacent agricultural land:
 The construction activity must be confined within the project boundary
 Proper fencing, run-on and run-off drainage should be constructed to prevent
spillage of sediment during rain or flood.

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Protection of Standing Crop Management Plan

The standing crops could be impacted in the project and adjacent area due to induced
infrastructural development.
 The project work should be started after harvest of the standing ripened crops.
 Adequate compensation should be provided to the farmers for loss of crop
production for three years for construction of economic zone.
 Agriculture land of the nearby NEZ area should be avoided to transportation of
construction materials.

11.7 ESMP during Operation Phase

Water resources management plan

A huge impact can be expected on the water resources during the operation phase of NEZ
as a large amount of water demand will be added with the existing demand. Water resource
should be managed in an integrated way so that potential impacts can be mitigated.
Following measures should be included in the water resource management plan of NEZ:
 A comprehensive study must be done including a water budget model with the
aim to identify the existing and future demand as well as the availability of the
resources.
 The model should assess the potential negative impacts in case of heavy
groundwater abstraction for a long-term period.
 Sustainable sources such as surface water, rain water should be assessed in
terms of feasibility including environmental benefits.
 Separate facilities for both groundwater and surface water abstraction should be
operating simultaneously at the beginning of the operation phase. A focus of
shifting the major water source from the groundwater to the other sustainable
sources should be set.
 ‘Pay per use’ policy should be adopted by the water supplier of NEZ. Water
meters should be set and the readings should measure the water usages by the
consumers.
 The payment rate of groundwater should be set comparatively higher than the
surface water/ rain water to discourage groundwater abstraction.

Drainage and flood management plan

As the land use type will be changed and existing low lands will be elevated to a higher
elevation, the drainage and flooding issues can occur during the operation phase of NEZ.
The issues could be tackled through a separate drainage and flood management plan and
the important initiatives include the followings:
 The natural drainage connectivity with the Komol Beel should be restored and
maintained active throughout the year.
 If required, excavation works should be introduced at the canals that connects
the Komol Beel with Kangsha River and Mogra River.
 The drainage canals inside the project area should regularly be monitored to
avoid clogging problems.

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 If any water retention basin is excavated to increase the water storage capacity,
their maintenance should be done periodically considering the accumulation in
the basin bed and decrease of capacity.
 Regulators at the both connection points of the Komol Beel with the surrounding
canals should be operating according to the requirements.
 Other water management structures should be constructed or improved to
enhance the drainage pattern of the overall basin of Kangsha River.
 Planning for the irrigation requirements should be taken into account while
planning for new water management infrastructures.
 Flood warning system should be developed and in the time of emergency the
operation of the sluice gates and regulators within the overall hydrological area
should be done accordingly.

Water pollution management plan

The industrial and residential interventions might have negative impacts on the water quality
of the area. The Komol Beel inside the NEZ could be polluted by the storm water and
irresponsible disposal of solid and liquid wastes. The groundwater quality could get affected
by the accumulation of pollutants in the beel, leaching from the collection pipes of
wastewater and effluent. Besides, the Kangsha River might potentially be polluted as the
treated wastewater and effluents are planned to be disposed into the river. Integrated
management plan should be followed to control water pollution and the plan should include
the following actions:
 The collection of all the industrial and domestic wastewater should be ensured
through proper network. No wastewater should be disposed in the open
environment.
 The collection network for wastewater should regularly be checked if any repair or
improvement is needed and maintained in adequate condition.
 The large industries must have their own pre-treatment plants and should pre-
treat all of the effluent generated before discharging into the common collection
network.
 The industries should be provided with the permissible standards for their pre-
treated effluents.
 The NEZ authority should monitor the industries at a regular basis as well as on
sudden basis to investigate their environmental compliances, such as the validity
of their ‘environmental clearance certificates’, operational efficiency of their pre-
treatment plants, quality of their effluents, solid waste management facilities,
maintenance of the green areas within their plots etc.
 The design capacity of the CETP and STP should be accurately determined.
There should be techniques available to measure the inflow of wastewater into
the treatment plant so that the potential failure scenarios of the plants could be
tracked.
 The standard for the treated water should be aligned to the national and
international standards.
 The technical and operational aspects of the STP and CETP should regularly be
checked. Cleaning, repairing and upgrading should be done whenever needed.

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 A smart payment system should be developed. This should include subsidies for
the industries to run their pre-treatment plants and charges on the basis of the
volume or quality of their effluents. Win-win situations for both the industries and
the treatment plant operators should be considered. Subsidies will encourage the
industries to operate their pre-treatment plants and payment for their effluents will
encourage them to maintain the efficiency of their plants.
 The treated wastewater from both the STP and CETP should be disposed into
the Komol Beel considering the quality of the treated discharge will be safe for
disposing into the nature. This will at the same time refrain the surrounding water
bodies from being potentially polluted and highlight the urge of the effectiveness
of the treatment plants.
 There should be provisions for storm water to be treated up to a certain level of
degree before disposing into Komol Beel. Dry retention areas could be
established at the outfall points of the storm water into the Komol Beel. The
retention basins should be designed in such a way that in the times of rainfall
water could be captured as well as detained at the basin for some period of time.
It will increase the storage capacity, reduce the velocity of storm water inflow into
the beel and in the process improve the quality of water naturally. Screening
facilities should also be available at the connection points of the retention basin
and Komol Beel to capture the coarse solids and other large materials. The
retention basin, especially the screening points must be cleaned after a rainfall
event occurs.
 The Komol Beel should be cleaned after periodic intervals to maintain the good
water quality of the beel and eradicate water-logging problems in the natural
drainage system.

Air pollution management plan

The full swing operation of the NEZ might have potential impacts on the air quality of the
surrounding area. To control the air pollution, the following management actions should be
undertaken:
 The industries should consider green technologies to be introduced in their
manufacturing cycles. Any change in the manufacturing cycle to reduce the
emission should be considered for awarding subsidies.
 Low emission fuels should be use for operating the machineries.
 The output points of the emission nozzles should be set at a higher elevation
than the general practice and equipped with facilities to screen and dilute the
concentrations of the gaseous pollutants.
 Pre-treatment facility of gaseous emissions should be present at the emission
points of every industry, particularly the type of industries with higher emissions.
 ‘Adaptation to climate change’ should be addressed and acknowledged in the
features of the industries.
 ‘Life cycle assessment’ studies should be done for the products manufactured by
the industries to calculate the total emission approximately for the production
cycle. They should submit the emission report to the NEZ authority and propose
for offsetting measures. Combining the efforts from both the industries and NEZ
authority, the potential offsetting measures should be achieved.

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 Buffer zone should be constructed by planting trees around each plot of the
industries.
 The vehicles plying within the NEZ must have ‘fitness certificates’ and the
certificates must be renewed periodically after proper examinations.
 The authorities of the industries and the vehicle owners should be acknowledged
about the permissible standards of emissions.
 NEZ authority should monitor the emission quality of the industries as well as the
vehicles occasionally and penalty should be charged in case of exceeding of
permissible standards
 Plantation of trees along the boundary of the NEZ and at the both sides of the
roads should be done and maintained properly. The green areas, parks should
also be preserved in pristine conditions.

Noise pollution management plan

The noise level of the NEZ should be managed technically, as several types of settlements
will be integrated in a single boundary. There will be heavy industries, small and medium
industries as well as residential and commercial units including park, school, hospital, open
water body within the same compound. The noise pollution management plan should include
the following actions:
 The particular chambers of the industries which produces loud noise such as the
main engine rooms, sub-stations, and big manufacturing units should be built with
walls having more thickness than the conventional walls. Concrete walls could be
considered for extreme noise producing places.
 The doors of such loud places should be kept shut all the time.
 Proper distinction of zoning should be declared along with the standards of noise
level.
 Adequate signs of the zones, instructions according to the standards should be
placed at the roads and clearly visible.
 The school, hospital and office areas should be declared as ‘silent area’ and
monitoring of the violations should be executed regularly.
 Honking of the vehicles should be restricted by putting ‘no honk’ signs at places
that require calm environment.
 Monitoring activities should be operated at a regular basis or on sudden basis to
check if any industry is exceeding the permissible limits and penalty should be
incorporated in case of violations.
 Permissions should be required to use loud noise producing sources for
recreational purposes such as sound boxes, mikes, fireworks etc. The application
should state the purposes and number of noise producing sources and
permission should be given for a selected time period.

Waste management plan

Huge amount of waste will be produced per day at the full operation phase of NEZ. The
waste should be managed sustainably otherwise the environment may be affected adversely

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and the consequences will hamper the smoothness of NEZ operation. The waste
management plan of NEZ should address the following activities:
 Overall solid waste management should be handled centrally by NEZ authority
along with the primary management by the waste generators.
 A team of waste collectors should go from door to door in the residential areas to
collect the solid waste and dump in the primary dumping site built at a suitable
location close to the residential area. The collection could be done twice/ thrice a
week. Dustbins and communal waste dumping facilities should also be placed at
certain locations within the community.
 In the industrial and commercial areas, primary dumping sites should be placed
at several locations where the industries would dump their solid wastes every
day.
 The waste collection team will plan for effective routes to collect the wastes from
all the primary dumping sites and dump into the secondary dumping site located
within the project area.
 Organic and inorganic wastes should be collected separately. The community
and the industries should be trained and well informed about the sorting of
organic and inorganic. Inorganic wastes should be accumulated separately in the
secondary dumping site and materials such as plastic, paper, glass etc. should
be used for recycling purposes.
 The domestic and industrial wastewater should be collected to the STP and
CETP respectively. Industries should pre-treat their effluent before discharge.
The treated wastewater from the plants should be disposed into Komol beel
considering the treatment standards will be within the acceptable limits. This will
help the wastewater not to be dispersed into the surrounding nature of NEZ as
well as provoke the treatment mechanisms to be perfect.
 The storm water should be collected through separate network and transported to
the Komol Beel. There should be provisions for the storm water to be detained
and preliminarily treated before flowing into the beel. The storm water network as
well as the detention basins should be regularly cleaned. The solid wastes and
the sludge should be carried out to the secondary dumping site and sludge
treatment plant respectively.
 The hazardous wastes should be separately gathered by the generators and
collected by the NEZ authority. Depending on the nature of the wastes, suitable
site/s should be selected for the best possible management of the hazardous
wastes.

Transportation Management Plan

The communication within the NEZ as well as between NEZ and the surrounding areas are
important because smooth development depends on convenient transportation system. The
transportation of local people, logistics should be according to well-defined management
plan.
 There should be two main gates- one at the southwest corner and the other at
the northern part of the NEZ.

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 Along with the official vehicles of the industries, offices and private vehicles of the
residents, there should be provision for a public transportation facility. The people
living adjacent to the project area will use no other mode of transportation but the
public transportation.
 Vehicles plying inside the NEZ should have recognizable sign/ sticker on their
bodies. Vehicles having no sticker should have permission from the NEZ
authority to enter the NEZ area.
 There could be rickshaws/ auto-rickshaws of a fixed amount of numbers for the
local transportation within the residential areas. However, these vehicles should
not be allowed into the industrial units. If required, a large industry should have its
own transportation system for the workers and professionals inside its area
 At the crossings, automatic road signals should be placed and the traffics should
comply the traffic rules.
 Appropriate authority should monitor the traffics if they are obeying the laws.

Traffic Management Plan

Traffic management plans are important to reduce the impacts of additional traffics
particularly outside the NEZ. The EMP includes the followings:
 The off-site infrastructures such as extension of adjacent highway from two-lane
to four-lane, improvement of adjacent railway and river ports should be
established as soon as possible.
 While designing the extension works of the adjacent road, the factor of additional
load of traffics from heavy trucks and lorries must be considered.
 Dedicated small lanes at both sides of the highway should be provided for the
small vehicles such as rickshaws, bicycles, motor bikes, 3 wheeler easy bikes
etc.
 Traffic signals should be placed at every crossing of the adjacent road, especially
within the stretch from Netrokona Sadar to Sunamganj Sadar.
 Speed limits should be placed at every 4 km interval.
 Traffic signs such as ‘demarcation of lanes’, ‘no parking’, ‘bus stop’, ‘market
area’, etc. should be present with high visual coloring.
 The adjacent road specially the stretch from Netrokona Sadar to Sunamganj
Sadar could be brought under CCTV surveillance.
 Police boxes could be built at important areas where traffic policemen can rest,
keep patrolling the surrounding area and monitor the CCTV cameras.

Fisheries resources management plan

Fisheries management plan has been developed with the aim of avoiding pollution causing
activities and to protect fisheries of the Kangsha River. The EMP includes the followings:
 Natural waterbody/adjacent beel should be conserved in study area so that these
waterbodies can be used as a shelter ground for fish.
 The proposed Lake (converted from the Komol Beel) of the NEZ could be used
for fish production

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 The lake should be connected to nearby canal outside of the project area.
 DoF might promote and strengthen fish conservation activities in nearby beels
and permanent wetlands.
 Awareness building program should be carried out for the local fishermen.
 DoF could extend training program on advance aquaculture technology in other
beels and wetland areas surrounding the proposed NEZ.

Green park management plan

The green areas and parks should be managed in environment friendly manners and should
take the following aspects into account:
 Trees should be planted in such a way that most of the park areas are covered
under the sheds.
 Grass should be incorporated over the whole area except for the walking paths.
 There should be no boundary wall of the parks so that people can get in or out
from any side. However, people should not be allowed to stay at the park at night.
 Trash cans should be placed at a convenient distance of interval and signs
should be visible to encourage the proper use of the trash cans.
 Team of guards and cleaners should be employed to look after the parks. The
guards will check the park areas if any illegal activities would occur and the
cleaners will clean the parks at a periodic schedule.
 There should be several selected spots preserved for the birds and other animals
where the people should maintain very low voice.
 Public toilets with separate chambers for male and female should be available at
suitable locations.

Sustainable Land Use Management Plan

Agricultural crop lands might reduce for the induced infrastructural and industrial
development in the adjacent to the NEZ area. Therefore, the following measures should be
followed:
 The government should restrict unsustainable growth of industries outside the
NEZ area.
 The local government should prepare an integrated plan to guide overall
economic development, land use change, transition from rural to urban area.
 Agricultural land, permanent wetland, important ecological area, etc. should be
protected from unplanned and unsustainable development.

Reduce Crop Damage by Integrated Pest Management (IPM)

Insect infestation might increase in the surrounding agricultural land due to lighting of the
economic zone. So, the following measures should be followed:
 Farmers should be properly trained about Integrated Pest Management (IPM).
 The government should ensure training system to build up knowledge about IPM
to the farmer’s level.

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 NEZ area boundary light should be protected with proper shading.

 Outdoor illumination must be optimum.

11.8 Special Environmental and Social Management Plan

There are several important sites in the NEZ which need integrated management plans
because of their influences on the project area. Site-specific management plans are drawn in
the following sections.

Dredging and Land Development Management Plans

According to the feasibility study, the soil required for the land development of the project
area will be collected through dredging of nearby rivers. The dredging activities should be
considered as a separate project as this involves hydro-morphological studies of the nearby
rivers to find the potential locations to collect soil. The study should particularly assess the
historical development of the river beds, erosion-accretion behaviour, quality of soil and the
feasibility to transport the dredged materials to the project area. Based on the locations, site-
specific environmental and social impacts should be identified and management plans
should be proposed accordingly. However, some general and tentative management plans
regarding the dredging and land development activities are proposed in the following:
 Sand for the land development should be collected from nearby rivers, Kangsha
and Mogra which should be assessed through historical morphology study.
Places with higher siltation rate should be selected as tentative
dredging/excavation location. The assessment should also consider dredgring of
the rivers to re-establish the natural drainage connection of the surrounding area.
For this purpose, dried up lakes could be considered as well. Figure 11.1 shows
a schematic diagram of dredging pipeline options for the land filling purpose.
 Historical data of at least 30 years should be assessed to understand the
morphological changes of the rivers.
 If possible dredging locations should be selected far from denser vicinity.
 Excavation from the project area itself for the development of Kamal beel could
also be option for sand to develop project area.
 Toxicity level of the river bed soil should be tested before disposing into the
project area.
 Locations known for fish breeding sites, healthy habitat for aquatic organisms
should be avoided from dredging.
 Sand traps should be used to prevent the dispersion of dredged soil into the river.
 Dredging activities should be limited to daytime to avoid disturbance at night time.
 Local navigation should not be hampered due to the dredging activities.
 No natural drainage channel should be blocked or damaged due to the dredging
activities.
 No bilge water, fuel and other chemicals should be discharged into the river.
 The quality of fuel of the dredger should be regularly monitored to ensure low
soothing emission
 Waste management of the temporary construction camps built for dredging
should be handled with the best available practices.

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 No disposing of dredged soil in the community area should be ensured by proper

monitoring of the technical aspects
 A monitoring team should be deployed to monitor the targets, outputs and
efficiency of dredging as well as the environmental and social management plans
and environmental compliances.
 During the disposal of dredged soil into the project area the project area should
be fenced properly to avoid runoff from the water mixed soil into the adjacent
community.
 The extra water from the dredged soil should properly be drained into the river.
The settlement of land and transportation of dredged soil should be synchronized
and timed in such a way so that the runoff of extra water do not overflow or leak
the outgoing channel.
 BEZA should monitor by themselves or a separate agency to check the accuracy
of land elevation and layout as planned.

Figure 11.1: Tentative layout options of dredging pipeline

Industrial Symbiosis Plans

For the sustainable management of industrial wastes, industrial symbiosis is a modern and
innovative concept which allows a set of various industries to handle their wastes or by-
products in a circular way. Application of this concept creates an interconnected network,
among the industries, of ecological system functions such as recycling, reusing, and the
continuity of energy and materials remain with production of minimum or zero waste. It not
only reduces the environmental impacts of industrial wastes but also fosters economic
efficiencies (European Commission, 2018).

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Source: (European Commission, 2018)

Figure 11.2: General waste flow diagram for industrial symbiosis

To apply such a concept into the operational framework of NEZ the following steps could be
undertaken:
 Industries should have their own facilities where wastes would be primarily sorted
into recyclable, reusable, residual and green wastes.
 Responsible division for waste management of NEZ should collect the industrial
wastes separately and transport to distinguished chambers of solid waste
management facility. Final separation of wastes should be done here based on
the requirements of raw materials and market opprotunities.
 Reusable wastes can directly be transported to the industries where those could
be used as secondary raw materials.
 Facilities such as recycling plant, mechanical treatment plant, composting plant
and biological treatment plant should be available at the solid waste management
and sludge management facility.
 A technical committee should be formed to apply and monitor the symbiosis
process comprising of specialists from both the NEZ waste management team
and the industries. The industries should share their information regarding
production cycle, production capacity, requirements for raw materials, amount
and quality of their wastes etc. Based on the information, the industries should
come to an agreement of applying industrial symbiosis into their production
pathway.
 Third parties from outside the NEZ could be involved for the production of
recycling materials usable for secondary uses from wastes such as paper, glass,
metal, plastic etc. The industries of NEZ should have provisions to buy these
products at a lower cost than the usual market price. In this case, the NEZ could

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provide subsidies to those third party producers by either selling the raw materials
at cheaper cost or providing certain amount of money on monthly or yearly basis.
 A composting plant at the sludge management facility should handle the organic
wastes and sludge from the wastewater treatment plant. One major part of this
type of waste could be decomposed to fertilizers through aerobic processes.
These fertilizers should be used for the green areas inside NEZ and could also
be sold to the local market. The residual part of these wastes could be used for
biogas production into an anaerobic digestion chamber. The biogas could be
directly used as raw fuel or turned into electricity which could contribute to the
energy source of the composting plant itself.
 NEZ should promote recycling and attract investors to create a market for the
recycled products at a national level. If proper sorting of solid wastes of not only
the industries but also from the residential wastes could be done NEZ could sell
various types of wastes as raw materials for the production of building materials,
furniture, fuel and textile. The revenue could be used for the operation of
management facilities as well as the subsidies for the industries.
 The symbiosis efficiency and waste flow should be regularly monitored by the
technical committee using available ICT tools. Based on the monitoring, the
committee should suggest changes and adaptations required at any step.
 Workshops and meetings should be conducted at a regular interval to share the
observations of the monitoring aspects as well as to raise knowledge and
awareness.

Resource Efficiency and Cleaner Production (RECP) Plans

Resource Efficiency and Cleaner Production (RECP) is an integrated and continuous
method of applying preventive environmental strategies into industrial processes. This
method promotes green economy by addressing the improvement of productive use of
natural resources, the minimization of impacts on nature and the reduction of risks on the
social communities (UNIDO, 2016). Mainly energy (fuel), water and materials used are the
types of resources that can be handled efficiently. The types of pollutions that can be
minimized for cleaner production are mainly air emission, waste water and solid wastes.

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Source: (UNIDO, 2019)

Figure 11.3: Overall concept of Resource Efficiency and Cleaner Production

RECP approach can be implemented by the industries through three basic steps:
i) Inventory of sources: where are wastes and emissions generated?
ii) Analysis of cause: why are wastes and emissions generated?
iii) Generation of efficient options: how can those causes be avoided or minimized?
In order to establish a sustainable economic zone NEZ authority should encourage the
industries to adapt RECP techniques by addressing the following aspects and management
plans:
 The industries should conduct ‘Life Cycle Assessment’ for each of their products
to identify use of resources, generation of wastes and emissions per unit of
production.
 Considering on the resource efficiency and pollution intensity, industries should
review their production methodologies to find alternative measures to achieve
greater resource efficiency and lesser pollution intensity.
 If required, the industries should opt for alternative and environmentally better
final product which might not be conventional.
 In case of water resources, NEZ authority should impose ‘polluters pay’ and ‘pay
per use’ concepts for the industries. Both the water use and discharge of
wastewater by each of the industry should be measured separately and billing
criteria should be set accordingly. This could introduce the urges of achieving
efficiency within the industries.
 Energy efficiency should be considered from an architectural point of view while
constructing any building (both offices and plants). NEZ authority should enforce
all the industries to have provision for solar energy with a capacity of at least 20%

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to 40% (depending on the scale of the industries) of total energy requirement for
each industry.
 Waste heat can be produced due to thermal and mechanical processes by
means of sources like hot combustion gases, heated wastewater etc. Industries
should adopt technologies to capture and transform the heat into energy in form
of electricity to be used as an extra energy source.
 Vertical gardening at possible places should be promoted by NEZ authority by
financing the initial cost. This could contribute to minimize the emission of net
carbon gases as well as heat stress from NEZ.
 In case of gaseous emission, the plants should have facility to treat the emission
to minimize the release of greenhouse gases. For the plants which produce
greater amount of carbon gases, provision for facilities to filter and capture
carbon gases from the outflowing channel and later the captured carbon gases
should be sequestrated underground following the best available practices.
 ‘Eco-labelling’ on the products could be introduced by NEZ authority. Based on
the life cycle assessment results a grading criteria could be determined with
provisions for both positive and negative labels. The idea of eco-labelling should
be explained well and decently to the consumers so that products with positive
eco-labels get promoted in the market. This could create competitions among the
industries to achieve greater efficiencies and lesser environmental impacts.
 NEZ authority should have provision for subsidies for industries which will
achieve positive eco-label certificates so that they could set the market price of
their products within the standard limit.
 The eco-labelling certificates should be re-examined and renewed after every
three or four years.
 Monitoring activities and sudden inspections should be undertaken by NEZ
authority at regular frequencies to validate the information shared by the
industries. If the industries fail to show that they do follow the operations as they
supposed to, penalty could be imposed and their eco-labelling certificates should
get downgrading.
 The industries should share technical knowledge among themselves to achieve
better technological advantages as well as apply industrial symbiosis.
 Workshops and technical training activities should be arranged by NEZ authority
at a regular interval to enhance the ‘capacity building’ of the industries by
promoting new ideas and innovations in the field of RECP.

Water Conservation and Saving Plan

Initially groundwater will be the major source of water for both industrial and domestic
purposes of NEZ. Eventually, according to the plan, the dependency of water will shift into
surface water as the major source. Although it will take several years for the economic zone
to reach up to its full capacity with all the industries operating with maximum setup, the
usage of water should be carefully managed. Along with the water resources management
plan mentioned in the subsection 'ESMP during operation phase’ the following water
conservation plans should be followed:

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 The operation of water treatment plant to treat surface water from potential
sources should be introduced as soon as possible. The major portion of water
demand should be supplied from surface water.
 Awareness should be spread to reduce the misuse of water both in domestic and
industrial sectors.
 Industries should be encouraged to have facilities to recycle water for their
production. Special incentives could be awarded for the industries with
exceptional techniques to optimize the use of water.
 All the industries need to be obliged to have rain water harvesting facilities to
meet up their water demand.
 For the domestic purposes a common water retention facility should be
established and connected with the water treatment plant.

Komol Beel Management plan

The Komol Beel will be an important component among the establishments of NEZ and
serve a number of purposes. The beel will be the designated water body within the project
area which will be the only habitat for the fishes as well as the aquatic ecosystem. The beel
should be connected with the adjacent canals and linked with Kangsha River and Mogra
River. The beel will serve as water storage and hence, it will take serious part in solving
drainage and flooding problem project area as well as the surrounding area. It will also be
used as the final dumping site of the storm water, treated domestic and industrial
wastewater. Moreover, it will also serve as a recreational site as the location of the parks,
food plaza, shopping mall would be set up beside the beel. The management plan for Komol
Beel should include the following aspects:
 High dykes should not restrict the beel, rather buffer zone with vegetation areas
should be provided at the banks of the beel.
 Natural drainage connection should be available and maintained at the Komol
Beel by linking the Fazar Ali canal in the north and Krishna Khali canal at the
west. There should be regulators at the both connection points to use in case of
emergencies.
 Several spots on the buffer zone area should be selected to be restricted from
human interventions. These places will be reserved for the birds, amphibians,
invertebrates etc. to provide a healthy trophic cascade.
 A team consisting of a biologist, a civil engineer, an environmental engineer, a
chemist executive/s, other professionals and workers should be formed to
manage and monitor the overall health of Komol beel. They should take
necessary initiatives to keep the water of the beel clean by removing coarse
materials, monitor the water quality, check the drainage fluency, maintain the
water level by manipulating the regulators and cleaning the beel bed, inspect the
reserved areas, maintain a healthy ecosystem and biodiversity etc. They should
also maintain liaison with the water management authorities for eco-friendly
solutions in case of any broader problems.
 Storm water should be allowed to flow into the Komol Beel after preliminarily
treatment at the retention basins located at the outfall points of storm water.

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 Swimming, bathing, washing etc. should not be allowed in the Komol Beel
considering health of aquatic ecosystem.
 There should be no point source of wastewater inflow into the beel except for the
discharge points of treated wastewater and storm water.

East-side Gate Management Plan

The project area is situated surrounded by Barni, Singher Bangla and Bhadrapara village
which is beside the Mymensing-Netrokona-Sunamganj highway and Netrokona- Mahanganj
railway line. But there is a road, connecting between Singher Bangla and Barni village
passing through the project site. If the project is implemented, the connecting road might be
disrupted or blocked. As a result, the communication of the two villages could be interrupted.
In this situation, a gate in the east side would need to remain open for the villagers. Besides,
an alternative road should be constructed beside the project site for undisturbed
communication. So, the authority should develop East site Gate Management plan.

Integrated plan for other on-going off-site infrastructure

Along with the construction works of NEZ there are plans for other off-site infrastructures
such as expansion of road lanes, improvement of adjacent railway, river ports etc. There are
some other development activities going on near the project area such as construction of
Sheikh Hasina University. Besides, during the construction phase of NEZ, there could be
some other development activities considering the potential business scopes. The various
types of construction works within a certain area may cause social and environmental
impacts which hamper the NEZ project activities. To mitigate the impacts integrated plan
should be acknoledged and addressed by the different stakeholders reponsible for other
infrastructures.
 Sourcing of construction materials should be integrated to reduce transportation
cost and traffic interventions.
 Project implementing agencies should share their individual demand of water
both for drinking and construction purposes to the authority responsible for water
supply so that the local community do not face any water shortage issue.
 Construction activities for different projects within a closer proximity should not be
run simultanously to reduce cumulative noise and air pollution impacts.
 Separate area could be designated for primary solid waste disposal purposes
during the construction period. Otherwise the collection of waste for final
management should be integrated.
 Project boundary for different projects should be well identified and present so
that construction works, impacts, management flaws can be easily assessed and
monitored.
 Authorities implementing different projects should communinacte regularly and
share their plans and progresses.

11.9 Environmental and Social Management (ESMP) Cost

In the following, items for ESMP implementation are given. Each item includes cost, but
since this cost is variable only items are given. The cost should be estimated by the project
office.

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Table 11.2: Cost for Environmental and Social management Plans

Cost (in
ESMP Item Purpose Responsibility Remarks
Million BDT)
Land Development and Construction phase
Rehabilitation and
Mitigating local
livelihood restoration of
agitation and Needs to be
dependent households 2.0 NEZA
compensating loss included in DPP
(compensation, training,
of livelihood
etc.)
Mitigating drainage
On-site run-on and run-off
problem, sediment Land
facilities (Fencing, Needs to be
runoff, water 0.2 development
wastewater and storm included in DPP
pollution during Contractor
water collection network)
land development
Construction waste Controlling
Land
management (use of dispersion of dust,
Development
sprinkler, curtain and gaseous emission,
Contractor Needs to be
barrier, separate vehicle other construction 0.25
and included in DPP
washing facility, storage, materials and
Construction
collection and disposal of minimizing the
Contractor
solid wastes) noise level
Land
Safety of the Development
Personal Protective
construction Contractor, Needs to be
Equipment (A standard set 0.5
worker and project Construction included in DPP
for each individual)
personnel Contractor,
and NEZA
Land
Construction of well Health and safety Development
facilitated labor sheds, of the workers, Contractor, Needs to be
0.5
hygiene toilets and Waste Construction included in DPP
adequate septic tanks management Contractor,
and NEZA
Provision for pure drinking Health of the Needs to be
0.25 NEZA
water workers included in DPP
Monitoring of Described in
Environmental
environmental quality Environmental
Monitoring (air, NEZA and/or
(Procurement of Monitoring
noise and water), 18.5 environmental
equipment, sampling, Chapter. Needs
Compliance consultant
testing or engagement of to be included in
requirement
consultants) DPP
Fish production
(Conservation of Komol
Beel by fencing, offsetting Minimize loss of Not Department
the production in the fish production Estimated of Fisheries
nearby beels/new
wetlands)
Temporary roads including Local
Needs to be
proper signboards of communication, 0.5 NEZA
included in DPP
instructions mobilization of

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Cost (in
ESMP Item Purpose Responsibility Remarks
Million BDT)
construction
vehicles and
equipment
Operation phase
Flood alert system
(stationary water level
Disaster
measuring equipment, 0.5 NEZA
Management
online monitoring, Data
logger, installation)
For monitoring
Online water quality Needs to be
discharge from the 0.5 NEZA
monitoring system included in DPP
CETP and STP
Establishing Environmental Environmental Needs to be
3.5 NEZA
Lab Monitoring. included in DPP
Daily weather Needs to be
Micro Weather Station 0.5 NEZA
recording included in DPP
Environmental monitoring Compliance Described in
51.5 NEZA
(three years cost) requirement Environmental
Third party Environmental Monitoring
Monitoring (3 years Compliance Chapter. Needs
50 NEZA to be included in
construction and 3-year requirement
operation period) DPP
Development of
‘Greenbelt’ along the
Minimizing air
boundary of NEZ, Needs to be
pollution, providing
roadsides and Parks at the included in DPP;
biological habitat 5 NEZA
designated areas recurring cost
and recreational
proposed in the master will be required
uses
plan (Tree plantation and
maintenance)
Needs to be
included in DPP;
Public toilets Public facility 0.5 NEZA
recurring cost
will be required
Provision for emergency
situations and accidents Management of Needs to be
(fire alarms, fire hydrants, risks, accidents, NEZA and the included in DPP;
50
emergency medical team, Health and safety industries recurring cost
training, central of the community will be required
communication)
Surveillance and security Needs to be
(CCTV coverage, central Ensuring safety NEZA and the included in DPP;
50
monitoring, security and security industries recurring cost
personnel) will be required

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Capital Investment for ESMP already considered in Project Cost Estimation

Estimated Cost
ESMP Item Purpose Responsibility
(million BDT)
Compensation for land
Land acquisition NEZA
and structures
Industrial wastewater
Central Effluent Treatment Plant management, Control 250 NEZA
water pollution
Wastewater
Water Supply and Sewerage
management, Control 2000 NEZA
Facilities
water pollution
Drainage System with utility duct Drainage 4731 NEZA
Integrated Waste Management
Facility (Collection, transportation,
Solid waste management,
storage, treatment and disposal of
Implementation of 3R
solid waste, sludge, toxic and 340 NEZA
(Reduce, Reuse and
hazardous waste) including
Recycle) principle
provision of separate management
for organic and inorganic wastes
Storm water network (installation of Controlling drainage,
collection pipes, dry retention basin water logging and 4,731 NEZA
before discharging into the lake) flooding problems
Retention for storm water,
Provision for biological
Improvement of Lake 700 NEZA
habitat and aesthetic
values

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 12. Disaster Impact, Hazard and Risk Assessment

12.1 Introduction
This chapter both covers Disaster Impact Assessment and the Hazard and Risk Assessment
which are newly practiced requirements of EIA and are always recommended by the
Department of Environment. The requirement of DIA is linked to the decision of the National
Disaster Management Council chaired by the Honorable Prime Minister of Bangladesh.
Hazard and Risk Assessment are required by national and international guidelines including
the IFC standards for environmental and social safeguards.

12.2 Hazard Identification and Risk Assessment Process

The hazard assessment has been carried out to identify the potential hazard associated with
or inherent in the design process and to identify possible measures to avoid the hazard
along with the safety plan for minimizing the risk. Incorporation of these measures and safety
plans in design, planning and operational procedure of the proposed NEZ would eliminate
the potential hazard points. The assessment process involved the following steps
 Identification of potential hazard
 Identification of causes and consequences
 Risk and safety management
The same methodological steps were followed while carrying out the DIA as well. In the
following sections, hazards including natural and technological, their causes and
consequences, and safety and management plan to reduce the risk associated with such
hazards are discussed.

12.3 Natural Disasters and Risk Management

The proposed area is highly prone to flash floods, monsoon flood and thunderstorms.
Presently, during monsoon, the entire area is inundated by floodwater for several months.
The proposed area will be elevated above the highest maximum flood level. During
monsoon, the area would be exposed to wind-driven waves and cause erosion as well if not
properly protected. The following table describes the possible impacts of natural disasters on
the proposed project and appropriate risk reduction measures.

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Table 12.1: Summary of the Natural Disaster, their Consequences and Management

Sl. Natural
Impact on NEZ Disaster Risk Reduction/management Implementation
No. Disaster
 Before developing the land, an embankment along the boundary of
the project should be constructed
 While developing the land proper drainage (run-on and run-off)
should be constructed
 Might affect the land
 The proposed lake (which to be constructed by conserving the
development activities
existing Komol Beel) and allied structures (e.g. regulator, gate)
 Might cause flooding of the should be properly maintained for ensuring its function as a flood
NEZ retention pond NEZ, Individual
 The 500 acres of land to be  The nearby flood management infrastructures (e.g. Thakurakona Industries, BWDB.
Flash Flood developed for NEZ would no sluice, an embankment along the Kangsha, and other infrastructure Monitored by BEZA, DoE
1 and Monsoon longer function as flood of Thakurakona project of BWDB, etc.) should be rehabilitated in line and an independent
Flood retention area which might with the proposed NEZ Environmental and Social
thereby impact on nearby
 To prevent waterlogging around the NEZ, existing canals should be Consultant (IESC)
water management
excavated regularly to ensure proper drainage
infrastructure.
 To prevent accidental discharge of effluent robust automatic system
 Might cause an accidental
should be established for monitoring
discharge of industrial effluent
 in the case of non-function ETP, the industrial discharge should be
stored in a temporary pond.
 Strict measures should be adopted to prevent running of industrial
operation in a case of non-functional ETP
NEZ, Individual
 While developing land wind-
Industries.
driven wave might cause  The boundary of the project should be protected from wave erosion
Monitored by BEZA, DoE
2 Wave erosion erosion  Bank of the proposed lake should be protected by in a combination
and an independent
 Erosion might take place at of biological and structural measures
Environmental and Social
the bank of the proposed lake
Consultant (IESC)

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Sl. Natural
Impact on NEZ Disaster Risk Reduction/management Implementation
No. Disaster
NEZ, Individual
 Heavy rain might cause wash  Before developing the land, an embankment along the boundary of Industries.
out of sand or sediment
the project should be constructed Monitored by BEZA, DoE
3 Heavy Rain spillage during land
development and construction  While developing the land proper drainage (run-on and run-off) and an independent
should be constructed Environmental and Social
phase
Consultant (IESC)
 There should be adequate numbers of shelters where workers could
 Thunder and lightning could
take shelter at the time of thunderstorm
cause injury and death of
labors, construction workers  Mandatory training should be conducted to aware all personnel of NEZ, Individual
and project staffs during land NEZ about the lightning and safety. Industries, Dept. of
development and construction  All the power transmission lines should be buried underground. Disaster Management
5 Thunderstorm activities  Equipment installed outside should be protected from lightning by Monitored by BEZA, DoE
 Lightning could damage installing proper measure (e.g. lightning arrester) and an independent
industrial complex, electric  Lightning arrester should be installed at each industrial complex, Environmental and Social
facilities (e.g. substation) or open space, parks of common facility area, etc. Consultant (IESC)
any equipment installed
 A safety distance should be demarcated around each open-air
outside
electric facility to keep away passerby/worker/personnel

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12.4 Climate Change Impact and Vulnerabilities

12.4.1 Historical Climatic Trends

The Northeast Region of Bangladesh has a typical tropical monsoon climate characterized
by the twice-yearly reversal of air movement over the region. The first reversal occurring in
spring (April-May) when the change of wind direction is from northeast to southwest via
northwest, and the second occurring in autumn (October-November) when the change is
from southwest to northeast via southeast. These periods of changing wind direction is
called the spring and autumn reversals. The southwest monsoon brings moist air into the
region from the Bay of Bengal. Rainfall in this season is abundant and it is often referred to
as "the monsoon", meaning the rainy season. Typically, the rainfall in this season increases,
northeastwards across the region and reaches a maximum on the southward-facing slopes
of the Shillong Plateau in Meghalaya; Cherrapunji, on these slopes, is well known as the
wettest place on Earth, with a mean annual rainfall over 12000 mm.

Rainfall
Rainfall is the most distinctive component of climate in Netrakona and in the haor region.
Climate is dominated by distinctive geographical characteristics of the region, which
ultimately plays a major role in determining the spatial and temporal distribution of rainfall,
evapotranspiration and hydrology of surface and groundwater.
The pre-monsoon season is characterized by increasing rainfall and flash floods. The bulk of
the annual rainfall occurs during the monsoon season when flash floods are regular and
frequent and the central part of the Northeast Region is flooded over to a depth of several
meters. The post-monsoon is characterized by decreasing rainfall and by the draining out of
flood water which is usually accumulated in the monsoon season. The dry season is one of
little or no rain, and river discharges are greatly reduced.
The available recent climate data in the study area show that the yearly average rainfall in
the study area is around 2300mm. Usually, most precipitation is recorded in the month of
June and the minimum in the month of January. Figure 12.1 presents the annual rainfall
trend in Netrakona based on BMD data.
Available rainfall data for Netrakona was collected from Bangladesh Meteorological
Department. Cumulative annual rainfall data from 1981 to 2017 was examined to conduct
the trend analysis for those locations.
Annual cumulative rainfall at Netrakona shows some variability. A slight increasing trend was
found in annual rainfall during the past-observed period. In addition to the cumulative annual
rainfall, an increase of pre-monsoon rainfall was reported in last few decades which might
increase the chances of extreme flash flood events during the pre-monsoon periods.
Evidence has been found from analysis of pre-monsoon rainfall that, pre-monsoon rainfall at
sylhet station has increased from 18%-24% (from the period 1691-1990) to 25%-27% in
recent years (1991-onwards) due to climate change (CEGIS, 2017).

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Figure 12.1: Annual Cumulative rainfall (1981-2017) at Netrakona

Temperature
The available data on temperature for the study area has been collected from BMD. The
annual trend analysis of maximum and minimum temperature are presented in figures 12.2
and 12.3. The figures show that the average maximum temperature in that area varies
between 24°C to 30°C and the average minimum temperature varies between 16°C to 22°C.
January is the coolest month of the year and August is the warmest month in this region. In
the recent time (1991-2017), the year 2009 was considered to as be the warmest year
having an annual maximum temperate of 30.4°C. In addition, trend analysis of temperature
data of Sylhet station was also performed. It has been seen that, the mean maximum annual
temperature varies between 29°C to 31.5°C.

Figure 12.2: Annual Average Maximum temperature (1981-2017) at Netrakona

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Figure 12.3: Annual Average Minimum temperature (1981-2017) at Netrakona

The figures show that there is increasing trend in both maximum and minimum temperatures
in the study area. The rate of change of increase is much higher in maximum temperature
than in minimum temperature. So, there are increasing tendency of hotter climate in the
area.

12.5 Future Climate Projection and Impacts of Climate Changes

12.5.1 Future Temperature and Rainfall Projections

The future climatic condition for the study area was assessed through statistical downscaling
of global climate model (GCM) dataset. The Statistical Downscaling Model (SDSM) which is
a software package designed to implement statistical downscaling methods to produce high-
resolution monthly climate information from coarse-resolution climate model (GCM)
simulations was used to predict the climatic scenario for the year 2030s, 2050s and 2080s
under both RCP4.5 and RCP8.5 climate change scenarios. In order to predict for this time
series, the base period was considered from 1971 to 2000. Table 12.2 show the future
projections of annual average maximum and minimum temperatures. According to
projection, considering extreme climate change scenario RCP8.5 the mean annual
maximum temperature may increase up to 1.6°C and minimum temperature may increase
up to 2.3°C in 2080s. The rate of increase of minimum temperature would be higher than
maximum temperature, which depict higher range of climate variability over the study area.
Table 12.3 shows the future projections of seasonal maximum and minimum temperatures in
the area. It is seen that the post monsoon temperature (both maximum and minimum) will
experience higher changes in the future.

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Table 12.2: Annual Average Temperature Anomalies in the North-East Bangladesh

Change in Temperature, ⁰C
RCP4.5 RCP8.5
2030s 2050s 2080s 2030s 2050s 2080s
MaxT 0.6 0.8 1.0 0.6 1.0 1.6
MinT 0.9 1.2 1.4 1.0 1.5 2.3

Table 12.3: Prediction for Change in Seasonal Maximum and Minimum Temperature

Maximum Temperature Minimum Temperature

RCP 4.5 RCP 8.5 RCP 4.5 RCP 8.5
Season Season
2030 2050 2080 2030 2050 2080 2030 2050 2080 2030 2050 2080
DJF 0.3 0.7 0.8 0.9 0.9 1.7 DJF 1.0 1.1 1.3 1.1 1.4 2.0
MAM 0.9 1.1 1.3 0.9 1.4 2.2 MAM 1.1 1.4 1.5 1.2 1.8 2.7
JJAS 0.5 0.6 0.6 0.6 0.7 1.0 JJAS 0.8 1.0 1.2 0.8 1.3 2.1
ON 0.8 1.1 1.6 0.9 1.5 2.6 ON 0.8 1.1 1.6 1.0 1.8 3.0

On the other hand, rainfall occurrence would increase during pre-monsoon season i.e.
March-April-May (MAM) and decrease in post-monsoon i.e. October-November (ON) (Table
12.5). Specially, pre-monsoon rainfall occurrence will be increased by 5%-6% in north-
eastern region than the base period, which clearly depicts that the study area will be more
prone to early rainfall as well as early flash floods in future.
Annual average rainfall anomalies reveal that total annual rainfall over the study area will be
increased up to 11%-12% by 2080s in consideration of both RCP4.5 and RCP8.5. Table
12.4 and 12.5 shows variations of future rainfall changes annually and in different seasons.

Table 12.4: Annual Average Rainfall Anomalies in the North-East Bangladesh

Change in Rainfall, %
RCP4.5 RCP8.5
2030s 2050s 2080s 2030s 2050s 2080s
Rainfall 8.0 10.0 12.0 8.0 8.0 11.0

Table 12.5: Prediction for Change in Seasonal Rainfall

Rainfall
RCP 4.5 RCP 8.5
Season
2030 2050 2080 2030 2050 2080
DJF 4 13 12 7 4 14
MAM 35 29 29 36 33 35
JJAS 35 35 36 2 3 9
ON -14 -15 -18 -16 -20 -23

12.5.2 Flash Flood

In a recent CEGIS (2017) study, available MODIS satellite images for the peak flood months
(March to May) from 2005 to 2017 were studied to evaluate the flash flood extents at the N-E
haor region and to understand the trend of flash floods. In general, the largest land area

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inundated with water were found in May. However, analysis results showed a time
dependent variations of peak flood extents for Netrakona district (Table 12.6). Most
importantly, the majority of the extreme flood events were found occurring during May. In
May of 2006, 2007, 2010 and 2015, more than 15% of the lands were flooded with water at
several haor districts. In May 2010, about 35% land areas were flooded in Netrokona.

Table 12.6: Summary statistics of the flood extents (% area inundated) in pre-
monsoon period (Year 2005 – 2017)
March April May
District
Min. Max. Median Min. Max. Median Min. Max. Median
Netrakona 0.079 8.45 2.7 1.15 5.17 2.05 0.98 35.15 4.02

Figure 12.4: Peak flood level at Sylhet during April against different return periods
(CEGIS, 2017)

Though the flood trends yet have not significantly increased over the past thirteen years’
period in the North-East haor areas, the frequency of high magnitude extreme flash flood
events have increased (CEGIS, 2017). Increase of the pre-monsoon rainfall as stated in the
earlier rainfall section, might be the most possible reason for such increase of extreme flash
floods in those areas, which comes earlier than usual time and hampers crop production.
Figure shows that flash floods for more than 10 years return period is increasing in recent
years, whereas flash floods of 5-year return period (before 2010) are a regular event
nowadays. These phenomena state that the intensity as well as frequency is increasing in
case of early flash floods. Under future climate scenarios, this will further increase as shown
from increase in pre-monsoon rainfall increases.

12.5.3 Monsoon Flood

The monsoon flood is occurring most of the areas of the study area due to its low elevation,
higher amount of rainfall and receiving of Hugh amount of water drained from the upstream
hilly catchments in India. The kangsha river is near the study area and is of very flashy
nature. In 2018, Kangsha river at Jariajanjail in Netrokona district showed rise and fall during
the monsoon-2018 and flowed below the danger level (9.75m). It attained its yearly highest
peak of 9.51 mPWD on 3rd August. The recorded maximum water level at this station is
13.37 mPWD and in 2017 flood, peak water level was 11.59 mPWD and the water level
stayed above the danger level for 82 days. Figure 12.5 shows the comparison of water

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levels at this station in Kangsha river during flood events of 1998, 2017 and 2018. Based on
the future projections of the rainfall distribution during pre-monsoon and monsoon seasons,
it is clear that rainfall is expected to rise by more than 30% in the future. So, the monsoon
flood events and their impacts will increase in the future due to climate change.

Source: FFWC

Figure 12.5: Water level hydrograph at Jariajanjail in Kangsha river Thunderstorm

According to the Department of Disaster Management information on fatalities and injuries

due to lightening during 1990 to mid-2017, the fatality rate is highest during pre-monsoon
(62%) and lowest during winter (2%); same has been observed in case of number of injuries.
Injury rate are highest during pre-monsoon (59%) and lowest during winter (1%); Figure 12.6
shows the pie diagram representing the percent of fatalities and injuries during monsoon,
pre-monsoon, post monsoon and winter.

(a) (b)
Figure 12.6: Rate of Fatalities and Injuries during different seasons

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Netrakona is in the sixth position in terms of causality and second position in terms of
injuries occurs due to thunderstorm in Bangladesh. 2.95% of total fatality of Bangladesh due
to thunderstorm occurs in Netrakona. With passage of time, intensity of lightening is
increasing as evident from Figure 127. From Figure 12.8 it can also be noted that, about
62% of total lightening in Netrakona happened during pre-monsoon. As the trend is
increasing in recent times, it can be concluded that, lighting events might increase in the
future due to climate change, as the pre monsoon rainfall amount and variability is expected
to rise.

Figure 12.7: Lightning occurrence from 1990-2017 in Netrakona

Figure 12.8: Number of Lightening at Netrakona from 1990-2017

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12.5.4 Hailstorm
Hail is a form of solid precipitation. It is distinct from ice pellets, though these two are often
confused. It consists of balls or irregular lumps of ice, each of which is called a hailstone.
Any thunderstorm which produces hail and reaches the ground is known as a hailstorm.
From the available data it is observed that, in Sylhet, a total of 50 hailstorm occurred from
1988-2012 with maximum 8 hailstorms in 1988 and minimum single hailstorm in 1997, 2001,
and 2012; Besides, hailstorm occurs mostly in monsoon (61%) and pre-monsoon (31%)
(Figure 12.9). A total of 28 hailstorm events occurred during monsoon while 17 hailstorm
events took place during pre-monsoon. The study area is closer to Sylhet and has similar
characteristics. So, hailstorm can also be an increasing phenomena in the future along with
the increase in thunderstorms.

Figure 12.9: Season wise Intensity of Hailstorm in Sylhet

12.5.5 Drought
Drought is a serious concern for agriculture during winter season. As, the haor areas receive
large amount of rainfall during pre- and monsoon seasons, the soil moisture and
groundwater conditions are better in the area. As a result the effect of absence of rainfall
during winter is negligible in the study area. The area does not face drought impacts as
prominently as other areas of the country. So, drought condition is not of much concern for
the area at present and also in future scenarios.

12.5.6 Cold Snap

Cold wave in Haor area may be severe for the livelihood of people and may hamper their
daily life and health. In winter season (December – February) when minimum temperature
drops below 10°C, it is called a Cold wave situation. In such case, Bangladesh
Meteorological Department (BMD) issues cold wave warnings depending upon its intensity
and duration. Based on climate data, Sylhet station has faced, maximum 6 cold wave days
in 1993 and minimum 3 cold wave days in 2003. Analysis of time series cold wave data
shows a slowly decreasing trend. Figure 12.10 shows the trend of cold wave days in Sylhet.

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Based on future climate data of minimum temperature and trend, it is expected that, cold
wave events will decrease in the future.

Figure 12.10: Cold Wave Days in Sylhet from 1990-2017

12.6 Emission of Short Lived Climatic Pollutant

Short-Lived Climate Pollutants (SLCPs), including black carbon (BC), methane and
tropospheric ozone have significant adverse impacts on health, agriculture, and climate. In
Bangladesh, black carbon (BC) and methane (CH4) is the major SLCPs having significant
impacts on health, crop production and climate change. Black carbon (BC) emissions mainly
result from traditional cookstoves, rice parboiling, brick kilns, industrial emission and open
waste burning while methane emissions result from agriculture (livestock and rice cultivation)
and from domestic wastewater. These emissions and those of other pollutants from the
same sources have a substantial negative impact on public health in Bangladesh.
Considering all emission sources, Bangladesh National Action Plan for reducing SLCPs
estimated that exposure to fine particulate matter (PM2.5), of which black carbon is a
component, was associated with 106,000 premature deaths during the year 2010.
Traditional biomass cookstoves, traditional brick kilns, open burning of municipal solid
wastes (MSW), transport vehicles, traditional rice parboilers and crop residue burning have
been identified as the major sources of BC, which collectively contributed to more than 50
thousand metric tons of BC in 2010. This quantity is predicted to be more than 81 thousand
metric tons in the year 2040. Domestic wastewater, livestock enteric fermentation and
manure management, flooded rice cultivation, MSW in landfills and gas transmission and
distribution are identified as the main sources of CH4 emission. These sources emitted
about 2.5 million metric tons of CH4 in 2010. The amount is estimated to be about 3.2 million
metric tons by the year 2040. As the study area is going to experience industrial activities,
certain measures should be taken to control SLCPs as it is increasing with climate change
and industrial development in Bangladesh.

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12.7 Climate Change Adaptation and Mitigation

The study area is specifically vulnerable to climate change induced disasters like floods,
flash flood, extreme rainfall, thunderstorm, lightning etc. Based on the future climate
projections, drought and cold snap will not be a significant issue in the study area. Based on
the overall scenario, several adaptation and mitigation measures are suggested for the study
area as follows.
 In order to keep the project area protected from flooding either developing the
project land above the maximum historical flood level or constructing an
embankment along the project boundary could be done. The current elevation of
the project area is between 6.8 mPWD to 8.1 mPWD whereas the maximum
monsoon flood level at Kangsha river was 11.7 m. Therefore, the land should be
developed around 12 mPWD. Alternatively, along with a high elevation of the
land, the boundary wall of the project could be designed as embankment.
 The land development plan should include proper drainage (run-on and run-off)
plan to handle the extreme rainfall events common in the study area that is
projected to be further increased in future.
 The proposed lake (which to be constructed by conserving the existing Komol
Beel) and allied structures (e.g. regulator, gate) should be properly maintained for
ensuring its function as a flood retention area.
 The nearby flood management infrastructures should be rehabilitated and
properly maintained to ensure flood protection for the proposed NEZ.
 The NEZ should establish a connection with the FFWC and BMD to receive
regular forecasts on weather events and floods. To reduce damages due to
floods, proper measures like, elevated structures should be planned from starting
periods to further climate and disaster proof the NEZ.
 To prevent waterlogging around the NEZ, existing canals should be excavated
regularly to ensure proper drainage. In case of excess rainfall event, pumping
could be used for the NEZ. This pumping facility should be designed properly
considering future climate change and drainage needs for the area.
 The NEZ should have proper effluent treatment plant and keep it operational
maintaining environmental standards. In case of non-functioning of ETP, the
industrial discharge should be stored in a temporary pond.
 Strict measures should be adopted to prevent running of industrial operation in a
case of non-functional ETP.
 The project boundary should be protected from wave erosion, which is very
common in the haor area.
 Bank of the proposed lake should be protected by in a combination of biological
and structural measures.
 There should be adequate numbers of shelters where workers could take shelter
at the time of thunderstorm.
 All structures and facilities in the NEZ should include properly designed and
working lightning arrester devices and mechanisms. This is very important for this
area, as it is a hotspot for lightning related deaths.

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 Mandatory training should be conducted to aware all personnel of NEZ about the
lightning and safety measures.
 All the power transmission lines should be buried underground. A safety distance
should be demarcated around each open-air electrical facility to keep away
passerby/ worker/ personnel.
 As the NEZ will include industrial activities, proper measures should be
maintained and implemented to reduce SLCPs from the area and also to reduce
environmental pollutants (e.g., exhaust gas, solid waste, chemical waste,
industrial effluents, heavy metal etc.). Regular monitoring and environmental law
enforcement is essential in this regard.

12.8 Technological Disasters and Risk Management

This section covers two types of disasters – i) technological disasters e.g. fire, industrial
accident, failure of ETP, etc. and ii) natural hazard induced technological disaster (NATECH)
e.g. sediment spillage from the land development site due to heavy rain, accidental
discharge of industrial effluent during a flood. The following table 1.2 identifies possible
hazards and NATECH events along with preventive or safety measures for risk
management. Under the scope of this EIA of NEZ, the hazards of an individual industry is
briefly addressed because each industry must prepare its own ESIA/EIA with a detail study
of its hazards and risk for obtaining approval from DoE.

12.9 Occupational Hazard and Safety

The hazard and risk assessment is included in the identification of occupational hazards
related to land development activities. It also covers very briefly the general occupational
hazards that might be associated with the operation of the NEZ when all industries would be
in operation. At this stage, what would be the industrial process of each industry is unknown
which limits the detail investigation of occupational hazards of industrial operation. However,
each industry would prepare its own ESIA/EIA including a detailed assessment on
occupation hazard and safety for obtaining necessary approval from DoE.
Table 12.7 describes occupational hazards and safety associated with the proposed NEZ.

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Table 12.7: Hazards and Risk Assessment

Potential Hazard/
Consequence Safety/ Risk Reduction Measures
NATECH
Spillage of Sediment  Construction/installation of Adequate drainage system
during
Environmental  Protection of boundary
landfilling/development
Pollution/Damage  Construction of embankment along the project boundary before starting the land development to
due to heavy rain or
flood impound the area of land development

 Strict enforcement of fire safety rules e.g. BNBC, Bangladesh Economic Zones (Construction of
Fire due to any Building) Rules, 2017
accidental event, Human death/Injury  Conduction of regular training including a drill for all personnel related to the NEZ construction and
explosion or human error operation
 A detailed assessment should be carried out by each industry at the time of carrying out ESIA
Accidental Discharge of  Strict enforcement of ECR 1997
Industrial Effluent due to
 The CETP should be automatic and robust. It should be equipped by an automatic shutdown of the
human error, technical Environmental
discharge in case of any accidental event, a rise of any pollution parameter above the danger level, etc.
error or a natural Pollution/Damage
disaster like heavy rain,  Automatic and online monitoring of water quality at the discharge canal.
flood, etc.  NEZ authority should regularly inspect each industry confirm operation of ETP
 Strict enforcement of fire safety rules e.g. BNBC, Bangladesh Economic Zones (Construction of
Building) Rules, 2017
 The NEZ authority should prepare a detail traffic operation and management plan
 Each road should be properly equipped with traffic safety lights and signs.
 Provide signs at strategic locations of the roads complying with the schedules of signs contained in the
Traffic Accident Human death/Injury National Traffic Regulations as well as engagement of flagman at strategic locations.
 The entrance and exit of the NEZ should be equipped with an automatic system to alarm the passerby or
other vehicles when any vehicle approaches to enter or exit
 Enforce on-site speed limits, especially close to the sensitive receptors, schools, health centers, etc.
 NEZ authority should have a mechanism of mandatory safe driving training for all drivers, each industry
must send their drivers to such training

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Potential Hazard/
Consequence Safety/ Risk Reduction Measures
NATECH
 The utility services including gas distribution should be monitored automatically
Human  The check valve and regulators should be automatically and centrally operated
Explosion of any Gas death/Injury,  Integrated and Smart (monitor & control, GIS interface) Utility (Gas, Water, Power, Firefighting, etc.) The
Pipeline or Storage Environmental design would further ensure the interest of investors
Pollution/Damage  Strict enforcement of Gas Safety Rules, BNBC, and Bangladesh Economic Zones (Construction of
Building) Rules, 2017
 The NEZ authority should instruct each industry to prepare its hazardous chemical handling and safety
procedure. The procedure must include the following:
 Collect chemical wastes in 200liter drums (or similar sealed containers), appropriately labeled for safe
transport to an approved chemical waste depot.
Human  Store, transport and handle all chemicals avoiding potential environmental pollution.
Accidental Leakage of death/Injury,  Store all hazardous wastes appropriately in bunded areas away from watercourses.
Hazardous Chemicals Environmental  Make available all Safety Data Sheets (SDS) for hazardous materials on-site during construction.
Pollution/Damage  Collect hydrocarbon wastes, including lube oils, for safer transport off-site to reuse, recycle, treatment or
disposal at approved locations.
 Construct concrete or other impermeable hard-stand to prevent seepage in case of spills.
 Keep sufficient stock of absorbents for generally used chemicals or for petrochemicals (e.g., dirt,
sawdust, etc.) within the storage area to contain accidental spills.

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Table 12.8: Occupational Hazards and Safety

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
 Keeping all safety and precautionary measures in order;
 Enforcement of BNBC and relevant law to ensure workplace safety
Physical injury,
Unsafe work place  Strict enforcement of safety rules relevant to the use of PPEs
electrocution, disease
during and post Lack of management;  Strict enforcement of Bangladesh EZ Labor Law
breakout, loss of health,
construction
loss of life;  Responsibility: During construction and prior to handover: Engineering,
Procurement and Construction (EPC) Contractor. Post-handover: Industry
operator/owner and NEZ.
Health hazards such as
Heavy transports,  Use of water spraying during SPM generating activities to reduce the
respiratory problems,
Air pollution during construction machines degradation of air quality; vehicles and heavy machines should have
visibility issues etc. Low
construction and trucks, demolition proper fitness to perform the activities; water-spraying may be taken into
visibility may trigger an
works; consideration to reduce flying dust particles in the air;
accident;
 Building codes should be followed to withstand an earthquake up to
Potential damage to civil certain level; Muster points during earthquakes will be defined and made
Earthquake during
structure of the station, part of drills; Responsibility: NEZ, EPC Contractor; Control Guideline:
and post A natural phenomenon;
loss of life, properties, BNBC; Responsibility: During construction and prior to handover:
construction
process etc.; Engineering, Procurement and Construction (EPC) Contractor. Post-
handover: Industry operator/owner and NEZ.
 Waste management of both human-generated and project component
An outbreak of diseases
Waste generation Not handled properly, generated should be handled accordingly; Coolants, insulation gas
and other health related
and leakage during no adequate waste leakage should be monitored; painting will be done as sealant; SF6 will be
issues; impairment of
and post management/ disposal sucked out before maintenance works; Responsibility: During construction
environment due to air
construction process; and prior to handover: Engineering, Procurement and Construction (EPC)
and water pollution;
Contractor. Post-handover: Industry operator/owner and NEZ.
 Construction site should be kept under surveillance and made
Site invasion Site invaded by
Physical injury and inaccessible to outsiders; The facility should be under constant
during construction outsiders during land
damage to property; surveillance and personnel should be in place of active duty to look out for
and post filling and preliminary
trespassers at all times; Close-Circuit Television (CCTV) monitoring to be

225
 Disaster Impact, Hazard and Risk Assessment

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
construction construction works; in place to assist catching trespassers or any suspicious activity in and
around the vicinity of the facility; Responsibility: During construction and
prior to handover: Responsibility: During construction and prior to
handover: Engineering, Procurement and Construction (EPC) Contractor.
Post-handover: Industry operator/owner and NEZ.
 Keeping all safety and precautionary measures in order; Responsibility:
Diseases outbreak Construction workers, Health loss due to During construction and prior to handover: EPC Contractor. Post-
during and post staff, employees having disease, loss of handover: Responsibility: During construction and prior to handover:
construction contagious diseases; productivity; Engineering, Procurement and Construction (EPC) Contractor. Post-
handover: Industry operator/owner and NEZ.
 Follow the national building code; Provide proper fire-fighting equipment,
May result in tripping, or such as fire extinguisher, water hose and adequate capacity water
Short circuit, reserve, installation of Active Fire Suppression (AFS) system (if possible,
temporary forced
thunderstorm and in selected locations); proper grounding of power outlets, installation of
Fire and/ or shutdown resulting in
lightning, presence of lightning arrester at each Building to avoid damage through thunderstorm;
explosion during power outage, injury of
flammable substances
and post personnel, loss of life,  Strict enforcement of Bangladesh Economic Zones (Construction of
such as lubricants;
construction and damage to Building) Rules, 2017
explosion of cylinders
properties, working hours,  Responsibility: EPC Contractor; Control Guideline: BNBC Part 7-Section
etc.;
etc.; 2.1.2 and 2.2.17: Storage, Stacking and Handling of Flammable Materials;
BNBC Part 7- 3.10.2.2: Flammable Material and Explosive;
High humidity is a Will damage the
No humidity/  Appropriate Heating, Ventilation, and Air Conditioning (HVAC) system
natural condition of equipment and age the
condensation must be engineered so that the internal humidity is controlled. A
almost the entire internal structures faster;
control, inadequate centralized system should be in place; Responsibility: Land development
country and this respiratory problems will
ventilation and air contractor, EPC Contractor; Control Guideline: BNBC and: Worker Health
condition is not an arise in occupational
circulation during and Safety; Bangladesh Economic Zones (Construction of Building) Rules,
exception for Dhaka environment inside the
post construction 2017
Metropolitan; Bhaban;
Transportation of Bringing in or taking out  Transportation should be conducted during off peak hours; Responsibility:
Traffic congestion will
heavy and large of the site using the EPC Contractor; Land development contractor; Control Guideline: Road
impact the daily lives of
components during existing road; use of Transport and Road Traffic Management and construction best practices,
city dwellers;
construction oversized local traffic laws and signage;

226
 Disaster Impact, Hazard and Risk Assessment

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
transportation;
 All emergency exits should be properly designed considering the nearest
occupancy, the maximum number of occupancy etc.; Emergency exits
should always be open from the inside and have proper guide towards it in
Improper emergency exit case of a power-outage resulted from any kind of incident; the exits should
Unplanned may result in dire also never have anything on the way, and for this proper management
emergency exits Emergency evacuation situations leading to practice should be in place; emergency drills should be conducted from
during and post process; failure of evacuation, time to time; Responsibility: During construction and prior to handover:
construction stampede causing severe EPC Contractor and Post-handover: NEZ authority and Emergency
injury and/ or death; Response Plan (ERP) Team;
 Control Guideline: Worker Health and Safety and Construction and
Operation Phase Security; Bangladesh Economic Zones (Construction of
Building) Rules, 2017
Existing road-size and
 Alternative access route should be considered; Responsibility: During
Narrow and only the surrounding May lead to slow
construction: NEZ authority, Land development contractor, EPC
access route environment including construction activity and
Contractor; Control Guideline: Road Transport and Road Traffic
during construction immovable structures, delay in the project;
Management;
private properties, etc.;
 Drivers/ operators should strictly follow the rules and regulations; Drivers,
During site visit for operators, operator guides, site visitors should take care before coming
inspections, surveying, out of or getting onboard any vehicle; Proper traffic marking on the road
planning, equipment and effective signaling system should be implemented in and around the
and components project site; Oversized vehicle permit from the authority should be taken
Traffic or heavy
transportation, use of Physical injury, loss of before mobilizing such vehicles; Traffic safety should be ensured for
vehicle accident
oversized vehicle, life, vehicle and/ or oversized and slow moving vehicles; Provision and use of high visibility
during and post
onsite and offsite property damage, etc.; clothing for workers, operators, operator guides; Provision of safe
construction
activities including walkways onsite etc. Underground parking facility should have proper
movement of guiding marks/ signs to ensure they are well instructed. Personnel should
construction trucks, be included to guide vehicle entry, exit and parking; Responsibility: During
employee vehicles etc.; construction and prior to handover: EPC Contractor and Post-handover:
NEZ Authority and ERP Team; Control Guideline: Road Transport and

227
 Disaster Impact, Hazard and Risk Assessment

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
Road Traffic Management, Protection of Public and Workers and Worker
Health and Safety;
 Use of Personal Protective Equipment (PPE), such as lineman’s gloves,
Cutting and welding
safety goggles, safety shoes, or welding shield etc.; Proper training and
activity, short circuit,
awareness; Proper tools usage; Proper grounding of equipment, keeping
faulty grounding in
safe distance from hazardous points; Prepare regular maintenance and
equipment; faulty
inspection of electrical outlets, switch panels, electronics such as
wiring, loose Physical injury including
computers, printers etc. appliances as air conditioners, refrigerators,
Electrocution connections, during burning and loss of life;
ovens etc., lighting arresters; Maintain the inspection schedule properly
during and post repair and maintenance May cause station
through experienced technicians; Proper warning signs and labels in
construction work of cable gallery, shutdown due to an
place; Use of lock outs and tag outs and maintain hot work permit during
control panel, incident;
any work on electrical components; Keep all the personnel present in the
switchyard,
workplace aware of any undergoing hot work at all times; Responsibility:
instrumentation, etc.;
During construction and prior to handover: land development contractor,
power cable cut due to
EPC Contractor and Post-handover: NEZ Authority and ERP Team;
thunderstorm;
Control Guideline: Worker Health and Safety;
Welding activity,
electric works, come in
contact with hot surface  Use of proper PPEs including safety goggles, appropriate gloves,
(ex. heat sink); Cutting Physical injury, eye injury, appropriate tools, or welding shield, appropriate training, warning signs
Burning and
and welding, arc temporary blinding and labels identifying potential hazards; Responsibility: EPC Contractor;
blinding during
flashovers, sparks due resulting in falling, Control Guideline: BNBC Part 7- 3.10.3: Health Hazards, BNBC Part 7-
construction
to faulty or loose tripping, electrocution 3.10.4: Skin Hazard, BNBC Part 7- Section 3.10.2 Fire Hazards;
connections, Bangladesh Economic Zones (Construction of Building) Rules, 2017
component malfunction
etc.;
Noise and vibration Hearing complexity and  Compliance with the National Noise Control Rules and Regulations;
generated by heavy cause of headaches for Equipment should be used by competent operators; Provision of
Hearing
machineries, placing human beings resulting in equipment with low noise and vibration outputs i.e., equipment that come
impairment during
electrical heaving loss of concentration with dampers where possible or appropriate choice of modern equipment
construction
components such as resulting in the trigger of and machinery to reduce noise; Personal Protective Equipment (PPEs)
power transformers another potential hazard, provided and used where necessary; Consider suitable timing of

228
 Disaster Impact, Hazard and Risk Assessment

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
and civil construction Scare local people, health construction work to reduce disturbance to the locality; Use components
works such as drilling, hazard for people with with lower noise level that falls in the same category or under the regular
piling, excavation weak constitution or heart decibel level of the locality and silencer where possible; Responsibility:
works etc.; conditions amongst Land development contractor, EPC Contractor; Control Guideline: ECP 7:
workers or employees as Noise and Vibration Management and BNBC Part 7- 3.10.4: Noise
well as bystanders; Hazard; Bangladesh Economic Zones (Construction of Building) Rules,
2017
 Proper path management, such as use of bamboo base for walking during
Muddy plain during
construction; Regular scheduled maintenance and hire cleaners to remove
construction, leading to
moss from the path below the bus bars; Proper PPE shoes with slip grip
slipping/ falling off
will reduce chance of slipping significantly; use of sands and gravels in the
workers, water or any
pathway; Clean moss grown on the pathways; Wipe any water or liquid
liquid spilled on facility
(proper procedure for wiping corrosive, flammable or toxic) off using
floor and not wiped off.
appropriate cleaning materials/ tools; Use of warning signs/ labels in
Tripped by stray pipe,
places that may trigger a tripping incident and properly managed items
rope, rods, unmanaged
Slipping, tripping and equipment; Use of PPEs; Manage items at all times to keep the site
tools, cables, May cause physical injury
and falling during tripping free; Keep the outdoor pathways clear of weeds; Fall protection
miscellaneous items, such as fracture, broken
and post such as use of nets or temporary boundary; creating awareness; use of
and equipment in the bones;
construction PPEs such as hard hat, gloves, safety belts; Proper signs/warnings in
station, construction
locations where falling can result to an incident; Use proper climbing tools
equipment and tools,
such as harnesses, lanyards, capstan hoists etc. to support activities that
weeds on the outdoor
require hanging and working; Use buddy system to work on elevated
pathways etc. Fall from
areas; Responsibility: During construction and prior to handover: EPC
elevated areas in the
Contractor and Post-handover: NEZ Authority and ERP Team; Control
station such as steps,
Guideline: BNBC Part 7-Section 2.1.3, BNBC Part 7- Section 3.10:
ladders, other high
Construction Hazards; Bangladesh Economic Zones (Construction of
heights;
Building) Rules, 2017
Potential damage to civil  Structures should be designed to withstand thunderstorms and lightning
Thunderstorm and
structures of the station, using well-established procedures in accordance with relevant national
Lightning during
A natural phenomenon; loss or interruption of and/ or international standards; Fire extinguishing facilities to be provided;
and post
power, loss of life, Lightning arresters will be checked for condition at regular intervals;
construction
process, triggering Preparation should be in place during a moderate or severe weather alert;

229
 Disaster Impact, Hazard and Risk Assessment

Risk/ Hazard/
Source/ Activity Consequences Safety Measures/ Precautions/ Contingency Plans
Incident
hazards such as fire/ Responsibility: During construction and prior to handover: EPC Contractor
explosion; and Post-handover: NEZ Authority and ERP Team; Control Guideline:
BNBC Part 7-Section 2.1.2 Protection Against Fire; Bangladesh Economic
Zones (Construction of Building) Rules, 2017
 Maintain connection with local police; Maintain vigilance of the
surroundings for any suspicious activities around the station area; Station
Evil intention of
Injury or loss of life, loss trained security guards at the entrance at all times and security round at
damaging or disrupting
Sabotage post of power, interruption of intervals during night time; Active CCTV surveillance at all times; Provide
the operation in the
construction power, loss of process, adequate lighting inside the facility for high visibility during night time;
facility by planned
etc.; Responsibility: During construction and prior to handover: EPC Contractor
carnage, intrusion, etc.;
and Post-handover: NEZ Authority; Control Guideline: Protection of Public
and Private Property, Utility, Construction and Operation Phase Security;

230
 Disaster Impact, Hazard and Risk Assessment

12.10 Emergency Management Strategy

The emergency management and response should be prepared on the basis of the strategy
which includes four basic principles- i) Prevention, ii) Preparedness, iii) Response, iv)
Recovery. The prevention comes with the design and plans of the NEZ and each industry.
The preparedness is built by regular training, awareness campaign, motivation and
resources. Response and recovery are pre-planned, designed and equipped with
institutional, technological and logistic setup.

12.10.1 On-site Emergency Response Plan

The NEZ should enforce each industry to prepare their own emergency management plan.
Besides, the NEZ authority shouldl prepare an overall emergency response plan and
establish Emergency Response Group. The emergency management plan must include the
following:
 Structure and Composition of the Emergency Response Group
 Defined roles and responsibility of each member of the ERG
 Communication plan of ERG chair
 General plan which must be followed by each industry
 Detail evacuation plan demarcating the evacuation route, assemble point, rescue
mechanism, etc.
 The plan should also include the coordination mechanism and plan among the
emergency facilities e.g. firefighting unit, medical unit, security unit, etc.
 The emergency plan should specify step by step procedure on how to act at the
event of an emergency. Such steps might be different for a different incident.
Therefore, the plan would envisage all possible scenarios of the incident and
prescribe emergency response procedure

12.10.2 Communication Plan

Each industry must have a communication plan which would specify whom to communicate,
how to communicate at the event of an emergency. The communication plan must list the
contact number and address of IRT leader, ERG leader, fire department, local government
office, etc. The following table could be used to prepare the communication plan
Position/Role Contact Numbers
Emergency Hotline
Incident Response Team Leader/Chair
Emergency Response Group Leader
Fire Department
Emergency Medical Service
Emergency Ambulance Service
Emergency Utility Services (Gas, Water, Electricity, IT, etc)
Emergency Security Contact
Ops / technical Coordinator
EHS Coordinator

231
 Disaster Impact, Hazard and Risk Assessment

Position/Role Contact Numbers

HR & Service Coordinator
Logistics Coordinator
Public Affairs Coordinator
Local UNO Office
Local DC Office

12.10.3 Emergency Evacuation

NEZ authority should prepare a detail emergency evacuation plan once the layout and land
use are finalized. The NEZ could keep a provision of assembly space at each block with a
connection to a central or larger assembly point. The ESIA team has examined the master
plan of the NEZ and identified all the green zones, walkway around the lakes, playground as
assembly points. A tentative emergency plan is provided in Figure 12.1 to help NEZA to
finalize the emergency evacuation plan. While finalizing the evacuation plan,
 Each industry must have its temporary assembly point
 NEZ must create a common assembly point for each zone (a tentative one is
illustrated in Figure 12.1) with an intention to rescue assembled people from the
industry-end assembly point to the block/zonal assembly point
 The evacuation route should be well demarcated with signs and directional
arrows to guide evacuation. All signs and information must be in Bangla and
English.
 NEZ must conduct an evacuation drill regularly (once in every six months).
 After each recruitment, the industry operator must organize a disaster safety and
evacuation training for each newly recruited employee and his/her family (if they
wish to live in the residential area of the NEZ). NEZ authority should also conduct
a yearly training for all.

12.10.4 Emergency Response Organization

Incident Response Team (ERT)

The NEZ authority should enforce each industry to establish an Incident Response Team
(IRT) to respond instantly whenever any incident takes place. The ERT must be trained and
assigned with specific responsibility to deal with all envisaged incidents and emergencies at
their industrial unit. The IRT would communicate with Emergency Response Groups,
established by NEZ authority for any additional support.
Each IRT would be chaired by an Environmental Manager of the Industry and includes
senior staff from HR, OHSE and logistic department. Each IRT would be responsible for
taking emergency measures at the time of any emergency, monitoring the safety of the
industries, and maintaining communication and coordination with the NEZ-ERG.

Emergency Response Group (ERG)

The NEZ Authority must establish an Emergency Response Group (ERG) within the
structure of NEZ authority. The ERG should be chaired by an Environmental Manager and
includes senior staff from HR, OHSE and logistic department. The ERG shouldl keep close

232
 Disaster Impact, Hazard and Risk Assessment

communication with IRT of each industry, on-site and off-site emergency facilities e.g. fire
service, hospital, security forces, etc. and the local government e.g. Netrokona UNO office
and DC office. The ERG would also keep close communication with the BEZA. ERG would
mobilize its resources at the event of any industrial accidents, social crisis, un-rest.
Whenever ERG would mobilize its resources, it should inform the Incident Management
Team of the BEZA Head Quarter.

233
 Disaster Impact, Hazard and Risk Assessment

Figure 12.11: Emergency Evacuation Plan

234
 13. Environmental and Social Monitoring Plan

13.1 Monitoring Plan

With the aim to ensuring implementation and making functional of all the ESMP, a three-tire
monitoring plan has been proposed in the EIA. The monitoring plan comprises compliance
monitoring, impact monitoring and external or independent monitoring.

13.1.1 Compliance Monitoring

The objective of the compliance monitoring is to ensure that i) operation of NEZ is running in
line with the environmental legal requirements and ii) the ESMP suggested by the EIA are
implemented. Thus, the compliance monitoring becomes an essential component of
environmental management to safeguard environment and community. The details of the
plan including monitoring indicators, locations, frequency and responsible agency is
described in Table 13.1.
However, the actual monitoring time and location would be decided by BEZA and NEZ
authority. The overall responsibility of the ensuring monitoring in action would fall on BEZA
during construction and later during operation of NEZ. However, the actual implementation
would be carried out by the contractor during construction phase and industry owner and
NEZ authority during operation.

13.1.2 Impact Monitoring during Construction

The purpose of the impacts monitoring is to ensure that the contractor implements the
mitigation measures given in the EMP effectively and implements timely. This monitoring
would generally be carried out by the BEZA during construction phase and NEZ authority
and Industry Owner during operation phase.

13.1.3 Independent/External Monitoring

In addition to the compliance monitoring and impact monitoring, an Independent
Environmental and Social Consultant must be engaged to monitor EMP implementation. The
main purpose of the Independent monitoring would be to ensure that all key entities
including Environmental and Social Health and Safety Unit, NEZ Authority, contractor,
Industry Owner and their contractors, etc. would effectively and adequately fulfil their
designated role for EMP implementation, and that all the EMP requirements are being
implemented in a timely and effective manner.

235
 Environmental and Social Monitoring Plan

Table 13.1: Environmental Compliance Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
1. Pre-construction phase monitoring
Consultation with the Third party
Compensation for land owner and shop Monitoring and
Compensation Project
land and existing Project site Half yearly keepers, school authority submit report to
received or not Authority
structure and other relevant the project
authority authority.
Third party
Project area and Monitoring and
Livelihood and Occupational change Household survey and Project
adjacent project - submit report to
Employment In employment FGD Authority
area (within 2 km) the project
authority.
Third party
Project area and Monitoring and
Local conflict of Movement and Project
adjacent project - FGD and KII submit report to
interest agitation Authority
area (within 2 km) the project
authority.
2. Construction phase monitoring
a. 1.5km North-
westward of the
Ambient Air NOx, SOx, SPM, NEZ OE,
 Monthly 24 hour Contractor
Quality PM10, PM2.5, CO, O3 b. 1.5 km South- PDO/PIU
eastward of the
NEZ

Day time (6:00 – Three Sample during day

21:00) and Night time 7 locations in and time and one sample OE,
Ambient Noise Monthly Contractor
(21:00 – 6:00) L10, around NEZ during night, 15 min PDO/PIU
L90 sampling each time.

pH, TSS, TDS, Oil and a. At the point of OE,

Water Quality Monthly Grab Sampling Contractor
Grease, Total effluent PDO/PIU

236
 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
Residual Cl, Total Cr, discharge
Fe, Ca, Zn, Pb, Cd, b. 500m u/s of the
Hg, As, total alkalinity, discharge point
Ammonium Nitrogen, c. 500m d/s of the
Free Ammonia, BOD5, discharge point
COD, EC Temperature
outside the mixing
zone, etc.
Habitat composition,
Green belt area NEZ
Plant Growth, Canopy OE,
Complex Yearly Plot Survey Contractor
Ecosystem and Coverage, PDO/PIU
Biodiversity etc.
Construction Site, OE,
Tree felling Monthly Direct Counting Contractor
Stockyards PDO/PIU
Diversity Index,
River reach 1: Three
Fish Diversity and Richness, Fish Catch Assessment,
(3) km reach u/s of Quarterly Contractor OE
Composition Composition, Habitat Fishers’ interview
the discharge point
Suitability Index, etc.
Six monthly
Five locations
Agricultural following
Crop Production Loss around the NEZ Agricultural Survey Contractor OE
Production cropping
area
patterns
Three Sample during day
time and one sample
Two locations: during night, for noise 15
Occupational
LAeq Construction site, Weekly min sampling each time. Contractor OE
Noise
Labor shed by using: ANSI Type II
Noise Meter, and
vibration meter
Availability of Potable
Inspection and interview
Health and Water, Drinking water
NEZ Complex Monthly of labor, project Contractor OE
Sanitation quality, Availability of
personnel
Hygienic Toilet

237
 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
Livelihood and Third party
Employment Monitoring and
Household survey and Project
(Labor - Quarterly submit report to
FGD Authority
Engagement for the project
project activity) authority.
Third party
Monitoring and
Occupational Institutional survey, RRA, Project
- Quarterly submit report to
Health and Safety Workshop & Seminar Authority
the project
authority.
Inspection and interview
Community
Implementation of As specified in the of labor, project
Health, Safety Quarterly Contractor OE
EMP EMP personnel followed by a
and Security
checklist
3. Operation phase monitoring
1. 1.5km North-
westward of the
Ambient Air NOx, SOx, SPM, NEZ NEZ
 Continuous 24 hour IESC
Quality PM10, PM2.5, CO, O3 2. 1.5 km South- Management
eastward of the
NEZ
1. Housing
colony Three Sample during day
Day time (6:00 –
2. Township Area time and one sample
21:00) and Night time NEZ
 Ambient Noise 3. Outside the Monthly during night, 15 min IESC
(21:00 – 6:00) LAeq, Management
NEZ Boundary sampling each time.
L10, L90
4. Nearest
Community
Temperature, Rainfall,
Humidity, Evaporation, NEZ
 Meteorology Plant Area Continuous Continuous IESC
Sun shine hour, wind Management
speed, wind direction

238
 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
Effluent Discharge
pH, TSS, TDS, NEZ
Channel Continuous Continuous IESC
Temperature, EC Management
Effluent (Waste
 Oil and grease, Total
Water) Effluent Discharge
Residual Cl, Cu, Fe, NEZ
Channel Weekly Grab Sampling IESC
Zn, Pb, Cd, Hg, As, Management
COD, BOD
Combined NEZ
 Storm Water As above Monthly Grab Sampling IESC
Discharge Channel Management
pH, TSS, TDS, Oil and
Grease, Total
1. At the point of
Residual Cl, Total Cr,
effluent
Fe, Ca, Zn, Pb, Cd,
discharge
Water Quality: Hg, As, total alkalinity, NEZ
 2. 500m u/s of the Monthly Grab Sampling IESC
Surface Water Ammonium Nitrogen, Management
discharge point
Free Ammonia, BOD5,
3. 500m d/s of the
COD, EC ,
discharge point
Temperature outside
the mixing zone, etc16
pH, Total Hardness,
Water Quality: Color, Cl, Total NEZ
 Plant Area Monthly Grab Sampling IESC
Ground Water Coliform, F, Fe, Mn, Management
As, PO4, SO4, etc
Generation of
Types and Quantity, Waste Disposal Visual Inspection, waste NEZ
Non-Hazardous Quarterly IESC
Characteristics Point classification Management
Solid Waste

16These monitoring parameters will be revised after monitoring the effluent water quality from the discharge channel. Some parameters might become redundant if
the effluent water does not contain them.

239
 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
(Domestic waste,
Office Waste,)
Generation of Waste Disposal
Types and Quantity, Visual Inspection, waste NEZ
Hazardous Solid Point, Waste Quarterly IESC
Characteristics classification Management
Waste Generation Sources
Generation of
Hazardous Liquid
Waste, Sludge
Hazardous Liquid
(return from Quality of Water in
Waste and Sludge Visual Inspection, waste NEZ
Water Treatment effluent pit e.g., Quarterly IESC
Disposal site (i.e. classification Management
Plant, Sludge corrosivity, reactivity.
effluent pit)
from clarifier,
neutralization
pond)
Condition of waste
Visual inspection and NEZ
bins, waste N/A Quarterly IESC
document checking Management
transportation vans,
Capacity of Waste Waste Disposal Visual inspection and NEZ
Waste Quarterly IESC
Disposal Site Point document checking Management
Management
leaks, drips or other
From Waste
indications of waste Visual inspection, and NEZ
generation to Quarterly IESC
spill during handling document checking Management
disposal site
and transporting
Labeling of Hazardous Chemical Storage,
Materials, hazardous Hazardous Material
Hazardous Waste Visual inspection, and NEZ
waste, documentation Storage area, Quarterly IESC
Management document checking Management
of hazardous chemical Hazardous Waste
use, etc Disposal Area.
1. Proposed Green Proposed Greenbelt area
Plant Growth, Canopy belt area near around the Neutralization
NEZ
Plant Health Coverage, Disease, neutralization Yearly pond and asbestos IESC
Management
etc. Pond disposal site: Whole area
2. Proposed Survey

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 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
Greenbelt area Other Vegetative area in
near Asbestos GSP:
Disposal Site Four Plots of 25m X 25m
3. Other Greenbelt (one plot at each corner
area in NEZ of GSP Complex)
Complex Plot Survey
Occurrence of Species Composition NEZ
Same as above Six monthly Same as above IESC
Wildlife and Status Management
River reach 1: Three
Diversity Index, (3) km reach u/s of
Fish Diversity and Richness, the intake point NEZ
Quarterly NEZ IESC
Composition Composition, Habitat River reach 2: Three Management
Suitability Index, etc. (3) km reach d/s of
the discharge point
Land use and Satellite Image (5km
Land cover and Land 5km buffer area of Once in three NEZ
Land Cover buffer area of NEZ) IESC
use the plant years Management
change Analysis
Agricultural land Farmers’ Interview,
Agricultural NEZ
Crop Production Loss around the NEZ Yearly Secondary Data from IESC
Production Management
complex DAE
Three Samples during
day time and one sample
a. Inside Plant
during night,
Area (Turbine
Occupational For noise 15 min
LAeq, L10, L90, Noise hall, RMS, etc.) NEZ
Noise and Quarterly sampling each time. IESC
Exposure b. Control room Management
vibration by using: ANSI Type II
c. Administrative
Noise Meter Inspection
building
of record of shifting hour,
workers’ roster
Exposure to Outside the safety Measurement by EMF
Electrical Field, NEZ
Electro-magnetic fence of Substation, Quarterly Meter IESC
Magnetic Field Management
Field Power evacuation Inspection of workers’

241
 Environmental and Social Monitoring Plan

Components of Monitoring Type/Duration of Implemented by

Sl. No. Locations Frequency
EHS Monitoring Indicators Sampling Monitoring Supervision
bay, other EHV area roster shifting hours etc.
General Health
Workers involved in
Condition, Hearing NEZ
Worker Health the Plant operation Quarterly Health Check up IESC
health, skin disease, Management
and maintenance
etc
Availability of Potable Visual Inspection and NEZ
NEZ Complex Monthly IESC
Water Record Checking Management
Drinking water quality
(pH, TS, EC, F, Cl, As, Three samples from
Water Supply NEZ
Mn, Fe, Total Monthly Drinking water supply IESC
Health and System Management
Hardness, Total system
Sanitation
Coliform, PO4, SO4)
Office Building,
Availability of Hygienic Township Area, NEZ
 Monthly Visual Inspection IESC
Toilet Common Places, Management
etc.
Status of
Inspection of Disease
Communicable
Community Township Area, Two times in a Profile/Records in Health NEZ
Diseases IESC
Health Nearest Community year Camps/Clinic in NEZ, Management
Status of Vector Borne
nearby area Hospital
Diseases
Emergency
Two times in a Visual Inspection and NEZ
Preparedness and N/A IESC
year Record Checking Management
Response of NEZ
Safety and
Community Relation
Security
Program/ Community Two times in a NEZ
N/A IESC
Awareness Program, year Management
Training

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 Environmental and Social Monitoring Plan

Table 13.2: Impact Monitoring Plan

Responsible Agency
Parameter / Means of
Location Frequency Implemented Supervised
Activity Monitoring
By By
During Construction
Disposal of
Visual Inspection OE/
Dredged Construction
of site Monthly Contractor Independent
material/land camps
management Monitor
filling
Approach Visual inspection
OE/
Damage to Roads to the to ensure local
Monthly Contractor Independent
local roads construction roads are not
Monitor
sites damaged
Visual inspection
to see whether
proper traffic signs OE/
Traffic Safety Haul Roads are placed and Monthly Contractor Independent
flag-men for traffic Monitor
management are
engaged
Visual inspection
to ensure good
standard
equipment is in
OE/
Construction use and dust
Daily Contractor Independent
sites suppression
Monitor
measures (eg,,
Air Quality spraying of
(dust, - smoke) waters) are in
place.
Visual inspection
to ensure batch OE/
Near Singher
plant is located Monthly Contractor Independent
Bangla School
>500 m from Monitor
residential areas
Physical
inspection to
OE/
Construction ensure good Twice
Contractor Independent
sites standard Weekly
Monitor
equipment are in
use;
Visual inspection
Noise to ensure ear OE/
Twice
plugs are in use by Contractor Independent
Weekly
the construction Monitor
Construction workers
sites
Ensure work OE/
restriction between Twice
Contractor Independent
20:00-06:00 close Weekly
Monitor
to the sensitive

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 Environmental and Social Monitoring Plan

Responsible Agency
Parameter / Means of
Location Frequency Implemented Supervised
Activity Monitoring
By By
locations
Visual inspection
to observe growth
of saplings around OE/
Designated
Plantation neutralization Monthly Contractor Independent
sites
pond and Monitor
asbestos disposal
site
Excavation of
OE/
Lake/Conserva
NEZ area Visual Inspection Monthly Contractor Independent
tion of Komol
Monitor
Beel
Visual inspection
that solid waste is
disposed at OE/
Waste Construction
designated site Monthly Contractor Independent
Management camps
Solid Wastes are Monitor
managed in
efficient way
Hazardous Visual Inspection
Material of safe handling
Hazardous OE/
Storage Area and storage of
Waste Monthly Contractor Independent
Hazardous hazardous waste
Handling Monitor
Waste and hazardous
Disposal Area materials
Ensure the
construction
workers are OE/
Drinking water Camps,
provided with Weekly Contractor Independent
and sanitation offices
potable water and Monitor
sanitation facilities
in the site
OE,
After
Restoration of Independent
All Work Sites Visual Inspection completion Contractor
Work Sites Monitor,
of all works
BEZA
Usage of Personal
Safety of
Protective OE,
workers
equipment, Safety Independent
Monitoring and At work sites Monthly Contractor
Sign, Safety Monitor,
reporting
Documentation, BEZA
accidents
safety training, etc.
Inspection of
OE,
Emergency Emergency
Independent
Response At work sites Preparedness and Monthly Contractor
Monitor,
Plan Response
BEZA
mechanism

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 Environmental and Social Monitoring Plan

Responsible Agency
Parameter / Means of
Location Frequency Implemented Supervised
Activity Monitoring
By By
visual inspection
OE,
and enquiry to
Grievance Independent
At work site know the Monthly Contractor
Mechanism Monitor,
Grievance
BEZA
Mechanism.
During Operation and Maintenance
Monitoring of
Inspection and
Environmental
Record checking
Quality
As specified in of Monitoring
(Ambient Air, Quarterly IESC BEZA
Table 1.1 activities carried
Noise, Water,
out by EHSU circle
effluent, Soil,
of NEZ
etc)
Inspection of
laboratory
Environmental Condition,
NEZ Complex Six-monthly PIU IESC, BEZA
Laboratory accreditation and
certification (from
GOB) status
Checking and
compiling climatic
Meteorological data collected and
NEZ Quarterly IESC BEZA
Condition recorded by micro
weather station
installed in NEZ
Noise nuisance/
Township
disturbance
area,
perceived by NEZ
Ambient Noise Administrative
personnel and Six-monthly IESC BEZA
Level area and
nearby community
nearby
to be surveyed by
community
interview and FGD
Treat effluent
Visual inspection
discharge
of fish mortality
Fisheries point at Six-monthly IESC BEZA
Interviewing local
Kangsha
fishermen
River
Blooming of
flowers and
fruits in plants
Plant Health Visual inspection Six-monthly IESC BEZA
within the
NEZ, number
of tree felling
Satellite image
10km buffer
Land use and analysis of land
area of the yearly IESC BEZA
land cover use and land
plant
cover
Hazardous Hazardous Visual Inspection Quarterly EHS Circle IESC, BEZA

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 Environmental and Social Monitoring Plan

Responsible Agency
Parameter / Means of
Location Frequency Implemented Supervised
Activity Monitoring
By By
Waste and Material of safe handling
Hazardous Storage Area and storage
Material and Use Area hazardous waste
Handling Hazardous and hazardous
Waste materials
Disposal Area
At monitoring
well location
Interview of local
population to
check whether
NEZ complex grievance
Grievance
and nearby mechanism is Quarterly EHS Circle IESC, BEZA
Mechanism
community working or not.
Checking records
of complaints and
redresses
Inspection of
Emergency Emergency
Response At work sites Preparedness and Quarterly EHS Circle IESC, BEZA
Plan Response
mechanism
Inspection of
training list, safety
Health and
meetings records,
Safety NEZ Complex Quarterly EHS Circle IESC, BEZA
means of
Preparedness
awareness
growing
Inspection of
community relation
NEZ Complex, maintaining
Community
Nearby procedures, Quarterly EHS Circle IESC, BEZA
Relation
Community relation building
activities, FGD
with community
Inspection of
NEZ Complex, record completed
CSR Program Nearby and planned CSR Six-monthly IESC BEZA
Community programs and
activities

13.2 Implementation of Environmental Monitoring Plan

13.2.1 Responsible Agency

The Project Director of the NEZ construction would be the responsible authority for
administrating and implementing Monitoring plan during Construction. After completion of the
construction, the responsibility would go to the NEZ Authority and each Industry Owner.

246
 Environmental and Social Monitoring Plan

During construction stage, the Environmental Compliance Monitoring would be conducted by

the Contractor(s) supervised by the Project Director Office (PDO) or Project Implementation
Unit (PIU) and Environmental Impact Monitoring would be carried out by the by the Owner’s
Engineer. In addition, an independent Monitor/Independent Environmental and Social
Consultant (IESC) would also be retained by PDO during three years of construction and by
NEZ authority during three years of post-construction (operation stage). Thereafter, the
EHSU of NEZ Authority would implement the monitoring program during operation stage.

13.3 Action during Emergent Operation

The NEZ Authority would assign a director/manager as the NEZ Operation in-charge who
will be responsible to look after overall operation of the NEZ. Besides, each industrial unit
shall have a plant-in-charge to look after operation of the industrial unit. In case of any
emergent situation, for example a major failure of control system, plant component, grid
failure, etc. the NEZ operation in-charge shall be responsible to act. If the emergent situation
arises at an industrial unit end, the plant in-charge would be the responsible person to act.
Each plant must be operated ensuring all pollution control devices are in order. In case of
any event of malfunction of a pollution control device, immediate action of resolving the
problem would be taken. If any emergent situation arises during operation, the shift in-
charge would be immediately notified to take corrective measures and action.

13.4 Performance Indicators

For evaluating the performance of the environmental management and monitoring plan,
performance indicators are identified for efficient and timely implementation of
measures/actions proposed in EMP. The indicators are defined both for construction and
operation phases. OE/Project Implementation Unit would be responsible for compiling the
information on these indicators and report to PDO/BEZA/NEZ Authority.
Separate performance indicators for each environmental issue have been specified in
compliance monitoring and impact monitoring plan. To measure the overall environmental
performance of the project, an additional list of performance indicators is provided below:
 Number of inspections carried out by OE per month
 Number of non-compliances observed by OE or EHSU.
 Continuous period of non-compliance
 Number of grievances received
 Number of grievances resolved
 Number of construction and occupational related accidents
 Timely reporting of documents (as defined in EMP and monitoring plan)
 Availability of environmental and H&S specialists in EHSU
 Availability of environmental and H&S specialists in OE
 Availability of environmental specialists and H&S with contractors
 Number of trainings imparted to stakeholders/other capacity building initiatives

247
 Environmental and Social Monitoring Plan

13.5 Reporting and Feedback Mechanism

The monitoring activities would require proper documentation. In case of Independent
monitor, the monitoring results and relevant document should be properly reported to the
project implementation authority. The project authority would submit the report to the
Department of Environment.
During construction stage, the environmental specialist of OE would be engaged in monthly
discussion meeting with the project implementation unit and the Contractor(s) for giving
necessary feedback. The project implementation unit might arrange a discussion meeting
quarterly with the financer regarding environmental compliance.
During the operation phase, the EHSU Circle would carry out the monitoring activities and
keep all the records and results of monitoring with proper documentation and will produce
quarterly reports on Environmental Monitoring. Besides, the IESC would prepare and submit
environmental compliance monitoring report annually to the PDO/NEZ authority. All the
reports should be submitted to DoE which is a condition of renewing the Environmental
Clearance Certificate from DoE. Besides, each industrial unit would be required to conduct
their environmental monitoring and obliged to submit the report to the DoE for renewing of its
Environmental Clearance Certificate
During operation, the EHSU Circle would give necessary feedback instantly to the person in
concern. The EHSU Circle would arrange a monthly meeting to disclose the results of
environmental monitoring to the personnel.

13.6 Budgets for Monitoring

Summary costs of monitoring including investments costs are presented in the Table below:

Table 13.3: Environmental Compliance Monitoring Cost

Estimated Cost
Sl no Activities
(In million BDT)
During pre-construction and Construction (borne by EPC/Land Development Contractor) for
three years
1 Environmental quality (air, water, noise, soil) monitoring 8.5
2 Occupational health, safety, and sanitation 5.0
Ecosystem, Biodiversity, Fisheries Resources and Agricultural
3 5.0
Resources Monitoring
Subtotal 18.5
During 3 years of operation (to be included in O/M cost) for three years
1 Environmental quality (air, water, effluent, noise, soil) monitoring 8.0
2 Waste Generation and Management 5.0
3 Ecosystem and biodiversity 5.0
4 Land and agriculture resources 5.0
5 Health, safety, and sanitation 5.0
6 Monitoring beyond compliance 5.0
Subtotal 33.0
Total Monitoring 51.5

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 Environmental and Social Monitoring Plan

Table 13.4: Investment Cost of Environmental Monitoring

Sl no Activities Estimated Cost (Million BDT)
1 Continuous Ambient Air Quality Monitoring Stations 22
2 Continuous Effluent Quality Monitoring Instrument 13
3 Micro Weather Station 3.5
4 Environmental Laboratory 35
Estimated Total Cost 73.5

Table 13.5: Cost of Independent Monitor

Sl no Activities Estimated Cost (Million BDT)

Independent Monitor for a six (6) years period including
1 50
3 years of operation (only fees and cost)

13.7 Organogram and Staffing for Ensuring ESMP and Environmental Monitoring
For ensuring effective implementation of ESMP and environmental and social monitoring the
NEZ construction project and the NEZ management (during operation) must have special
unit/department focusing on environmental management and compliance. Figure 13.1 and
13.2 illustrate organogram for the proposed environmental management and compliance
unit.

Figure 13.1: Proposal Institutional Setting for Environmental Compliance and EHS
Unit during Construction

249
 Environmental and Social Monitoring Plan

Figure 13.2: Proposed Institutional Setting and Organogram for the Environmental
Compliance and EHS Unit during the Operation of the NEZ

250
 14. Conclusions and Recommendations

The aim of the proposed NEZ is to promote local as well as regional and national economic
development by establishing appropriate industries in an enabling environment. The
economic benefits of the project as envisiged in the master plan includes contribution to
increasing GDP,value addition by creating employments opportunities, increase of national
foreign reserve through inflow of direct foreign investment.. However, these benefits may
also incur some environmental cost.
 The proposed acquisition of 500 acre land may result permanent loss of seasonal
waterbodies including beels, agricultural lands (mostly signle crops), fish habitats
and livelihood of some people.. However, the people owning the land would get
compensation as per the rules of the country. Unfortunately, people who do not
have appropriate paper to produce their land right would not get any
compensation which might cause a social tension.
 The proposed land acquisition would cost 2160 MT of rice and 243 MT of fish
production annualy.
 The proposed land development for establishing NEZ by converting seasonal
flooded area to flood free area would have impacts on surrounding drainage and
flooding situation. The surrounding water management infrastructures e.g. sluice
gates, canals, embankment which are not effectively functioning at present,
would be under further stress due permanent loss of flood retention area and
groundwater recharge potential areas. However, the poposed lake in the NEZ
might minimize the impacts.
 The construction activities might increase SPM in the local air . Construction
activities might also generates noise. The EIA proposes appropriate mitigation
measures to control such impacts.
 The EIA proposes automated monitoring system for CETP/ETP/STP/pollution
mitigation measures. However, during operation, pollution (air pollution, water
pollution) might take place due to non-functioning of CETP/ETP/STP/pollution
mitigation measures.
 Ground water has been considered as a major source of water supply.
Considering the large demand of water for operating NEZ, the impact on
groundwater availability is inevitable unless the NEZ apply water saving
technology and make arrangement for groundwater recharge. The Master plan
includes a large lake and several green areas which might enhance groundwater
recharge.The feasibility study did not cover detail assessment on groundwater
availability. Therefore, a further study should be carried out to evaluating
sustainability of groundwater.
 The proposed NEZ and allied infrastructural development would induce local and
national economic development which would directly benefit the local community.
Living standard of local people would be improved.
An important objective of establishing EZ is to promote planned industrial development by
creating enabling environment and facilities at a place equipped with environmental
management rules and regulations and pollution abatement measures,which would prevent

251
 Conclusions and Recommendations

unplanned and isolated growth of industries and thereby would prevent diffusive
environmental pollution. It is quite common that unplanned and isolated growth of industries
do not always comply environmental regulation and it often stay out of the reach of
environmental regulating agencies. Therefore, an EZ looks better in the context of
implementing environmental regulation and environmental monitoring. Such benefit of EZ is
also forseeable in case of NEZ. However, to ensure minimum environmental and social
impacts during land acquisition, construction and operation, the EIA recommends the
following:
 An autometed and online monitoring system should be established to operate
and monitor CETPs. The NEZ authority should establish a strict environmental
compliance policy and practice with strict penalty for any non-compliance.
 An integrated approach of infrastructural development is needed to ensure
attractiveness of the NEZ to investors
 Integrated and Smart (monitor & control, GIS interface) Utility (Gas, Water,
Power, Firefighting, etc.) Design would further ensure interest of investors
 Industries should adopt water saving technology
 The Komol Beel which will be converted to a lake for the sake of NEZ, should be
maintained ensuring its ecological and hydrological functions. It should be
maintained in such a way that it it would provide local biodiversity an important
shelter.
 The mitigation measures proposed in EIA should be strictly implemented.
 This EIA should be a part of all the tender documents and contracts related to the
establishment of the NEZ.
 The monitoirng plan proposed in the EIA should be strictly followed.
 Since the local people have a high hope of local, regional and national economic
benefit from the project, long delay of the construction and operation may cause
public disappointment. Therefore, the project schedule should be strictly followed.

252
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254
 Appendix I: Matrix of Comments and Reponses on the Draft
Report

Sl.
Comments Responses by CEGIS
No.
1. Paban Chowdhury, (Secretary) Executive Chairman, BEZA
All the alternative economic opportunities for the
Discussed in Livelihood Restoration Plan,
1.1 people dependent on the land of the project area
in EMP Chapter
should be discussed properly.
Abstraction of water from the nearby surface water
Agreed. The EIA also recommends the
1.2 sources should be encouraged along with the
same.
uses of groundwater.
2. Dr. Md. Sohrab Ali, Director, Department of Environment, Dhaka Metropolitan Office
2.1 Executive summary should be brief and conscinse Executive summary has been rearranged
The government planned to establish 100
EZ throughout the county, which covers
Why Netrokona was selected as a potential place
almost all district. In that sense, selction
to establish Economic Zone? - a more logical
2.2 of Netrokona is normal. Anyway, a bit
explanation should be presented at the relevant
description is given in Introduction
section.
Chapter

The socio-economic condition around the project

area after establishing NEZ should be discussed.
2.3 The relevant section has been updated.
The impact of urbanization should also be
discussed.
The distance from the Indian border to the project
The project is far from the Indian boarder,
area should be considered. The necessity of
2.4 therefore, this issue is not addressed in
additional security due to the proximity of border
the report
should be discussed whether it is required or not.
Road network plan along with the
Detailed road network plan should be incorporated dimensions based on the information of
2.5 including cross-sectional details of main road, feasibility study has been presented in
utility roads, footpaths etc. the subsection 4.4.5 under the heading
‘Road Network’
Impacts of additional traffics have been
discussed at the subsection 8.4.3 under
the heading ‘impacts of additional traffic’
Impact of additional traffics should be assessed
2.6 and to tackle the impacts separate EMP
and discussed.
has been prepared in the subsection 11.7
under the heading ‘Traffic management
plan’
The allocated area for different zones such as Allocated area for different zones and
2.7 industrial areas, residential areas, green areas etc. facilities are indicated in the subsection
should be specified according to the master plan. 4.4.1 (table 4.4)
Why single crop area is dominant in the project
Land is F4 type, which is suitable for
area? – this should be answered properly. Loss of
2.8 single crop only. Detail explanation is
agricultural production should be considered with
given in Cropping Pattern Section
critical point of view.
2.9 Approximate quantification of the generation of all The idea of waste generation and the

255
 Appendix

Sl.
Comments Responses by CEGIS
No.
types of wastes could be identified. The capacity, capacity of treatment plants have been
design and layout of the treatment plants should discussed in the ‘project description’
also be included. The operation of the pre- chapter (4.4.5) which are based on the
treatment plants by the industries should be available information of the feasibility
should be ensured. Also, the technological, study.
managerial and financial aspects of the treatment However, at this stage, the numbers and
plants should be re-considered as the experiences types of the industries are not certain and
of the existing examples of such treatment plants so, the design capacity of the treatment
in our country are not pleasant and favorable. plants are not possible to identify.
The ESIA report expects that BEZA will
design the treatment plants according to
the actual scenario of the types of the
industries and there will be provision for
further improvement of the plants. BEZA
should also ensure the proper
maintenance of the treatment plants.
Water discharge data have been included
in the subsection 6.2.5 under the heading
‘discharge and water level of nearby
rivers’.
Actual water discharge and seasonal variation of Water modeling could not be done
the rivers could be included. In case of the because, at this stage, the types and
2.10 abstraction of groundwater for the industrial uses, numbers of the industries are not certain.
the availability of drinking water for the local At the same time, according to the
people should be assessed and included. master plan, the dependency of water for
NEZ will be shifted from groundwater to
surface water eventually with connection
to the operational progress of NEZ from
initial stage to maximum production.
Baseline water quality report has been
Baseline water quality report should be included included in the subsection 6.2.5, under
2.11 according to Environment Conservation Rules the heading ‘quality of surface water’ and
1997, schedule 3. ECR, 1997, schedule 3 has been
followed to present the data.
Possible measures to treat gaseous
Possible measures that could be taken by the emissions by the industries have been
2.12 industries to treat the gaseous emission should be discussed in the subsection 11.7 under
discussed. the heading ‘Air Pollution Management
Plan’.
Monitoring of biodiversity should be included in the Monitoring indicators have been
2.13
‘Environmental Monitoring’ chapter. mentioned in monitoring Chapter
3. Syed Nazmul Ahsan, Director (ECC), Department of Environment
Update the missing acronyms and correction of
3.1 Action Taken
wrong ones (PPR, STP)
Map of project location should be updated. Two
Two updated map have been inserted in
3.2 maps should be included in the report which are
Introduction Chapter
one km. and 10 km radius;
Conservation of lake has been discussed
In the project description chapter the conservation
3.3 in the project description under the
of existing lake should be discussed;
subsection 4.4.5

256
 Appendix

Sl.
Comments Responses by CEGIS
No.
The proportionate distribution of land into
The proportion of public and private land among
government and private cannot be given
3.4 the total of the project area should be presented in
in EIA report, since it is a part of Land
the report;
Acquisition Plan (LAP) study.
There is a confusing information in the report
Data on beel area has been changed
3.5 about the beel area. Provide accurate information
(please see relevant Sections)
about the nature of the land particularly beel area;
Mitigation of hydrological impacts of the
There might be created hydrological impact by the
project area have been addressed in the
3.6 development of the project. Provide proper
subsection 11.7 under the heading
drainage management system during flooding;
‘drainage and flood management plan’
4. Dr. Tanveer Ahmed, Environment Specialist, Support to Capacity Building of BEZA Project,
BEZA
Executive summary has been rearranged
Executive Summary sections should include key
following other comment as well (see.
findings of each chapter beside the general
Comment 2.1). Also, a summary of
4.1 descriptions along with site specific critical
concerns and a wayforward has been
environmental concerns and ways forward for the
given at the concluding remark of the
study area in the conclusion;
executive summary
Indicative outline along with environmental
Environmental guideline and description
guideline and description on CETP, STP, Solid
on CETP, STP and Solid waste
waste Treatment Plant and Integrated waste
management facility have been
4.2 management plan with 3R strategies based on the
discussed in the project description
projected demand should be discussed in the
based on the available information of the
project description chapter of the report as part of
feasibility study.
the EIA guideline requirements by DoE for EZ.
Physiography, geology and seismic analysis in
page 22 is missing, this section should also Physiography, Geology and Seismic
4.3 include relevant environmental implications for analysis have been included in the report
implementation of the proposed project under the subsections: 6.2.8 and 6.2.9
interventions in the study area;
Surface water quality data along with its
environmental interpretation for the proposed Water quality data of surface water and
project is missing inn page 70; Status of Arsenic groundwater along with their
4.4
(As) and its environmental implication for the study interpretation have been included in the
area should be included in the groundwater subsection 6.2.5.
monitoring data in page 77;
Baseline soil Elemental composition data and Action Taken: A brief soil quality
graphical interpretation is missing in the report information is presented based on
4.5
although it is mentioned in page 22 under the available data in Upazila Nirdeshika of
section of soil and land resources; SRDI.
Primary laboratory report of water quality
All primary Air/noise/ water/soil quality data should
has been included in the annexures.
4.6 be backed by original lab test reports and
Noise and air quality was monitored by
references in the annexures;
field tests.
Noise quality section in page 127, it is mentioned Noise modeling could not be conducted
the project activities shall cause high noise because, at this stage, the types and
4.7 impacts on the nearby community receptors. numbers of the industries are not certain.
However, no quantitative noise quality baseline However, an indication of noise during
data as well as predicted spatial impacts during operation phase has been addressed in

257
 Appendix

Sl.
Comments Responses by CEGIS
No.
construction and operation of the EZ have been the subsection 8.4.1
included in the report;
The caption for figure 4.7 has been
Figure 4.7 caption in page 44 under wastewater
4.8 corrected under the wastewater
treatment section should be corrected;
treatment section
In page 125 it is mentioned that 455 acres of
agricultural land out of 500 acres will be converted
to industrial area with an annual loss of 2161 tons
of rice due to the NEZ. This statement should be Verified and found ok. Also, discussed in
4.9
verified with specific field/land use data and similar Alternative Analysis Chapter.
findings should be discussed in alternative
analysis section as agricultural/socio-economic
section which is missing in page 52.
Considering observation no. 6 alternative
4.10 Livelihood Restoration Plan (LRP) for project Agreed: included in EMP Chapter
affected people should be included in the report.
Dredging impacts was not possible to
It is mentioned in page 148 that a detailed explore extensively because the selection
feasibility and ESIA should be conducted for of dredging location and the design
dredging and land filling the project site which is layout requires separate study including
not correct as land filling is an important hydro-morphological and social
component of onsite EZ development activities assessments of the nearby rivers.
4.11
and lies within the scope of this study. Therefore, However, a general and tentative
the ESIA study should include an indicative land dredging and land development
development plan with the source and layout of management plan has been prepared
dredging considering the identified environmental and presented in the subsection 11.8
impacts in the study area. under the heading ‘dredging and land
development management plan’
As the report identifies the study area as
groundwater stressed as mentioned in page132,
the report should suggest environmentally viable Suggestions and measures regarding the
supply mix of industrial and drinking water sources sustainable use of water have been
considering the projected demand and local particularly addressed in two subsection:
4.12
available natural resources of the study area. In i) water resource management plan in
this context, the provision of surface/groundwater 11.7 and ii) water conservation and
treatment plant, water storage reservoir, rainwater saving plan in 11.8
harvesting should be discussed as integrated
water management plan for the entire project.
Identified impacts of global pandemic outbreak
of COVID-19 disease on the project affected
people in the study area due to project activities
and their associated occupational health safety Preventive measures have been
4.13
precautionary measures should be discussed in suggested in Mitigation Chapter
the relevant section of the environmental social
impacts and occupational health safety measures
in the report.
Promotion of Green EZ practices such as role of Measures to optimize energy efficiency
renewable energy (roof top/floating solar panels) and greener production have been
4.14 in the total energy supply mix, necessity for green discussed in the subsection 11.8 under
building, environmental audit, ISO certification of the headings ‘ Industrial Symbiosis Plans’
the EZ and individual investors should be and ‘ Resource Efficiency and Cleaner

258
 Appendix

Sl.
Comments Responses by CEGIS
No.
discussed in the environmental management plan Production plans’.
of the study with a view to develop sustainable
and resilient EZ.
Table nos. in page 216 and 179 is section II of
Table nos. are corrected at page 220 and
4.15 Additional Benefit Package for the affected HHs
181.
should be corrected.
Minimum level of land elevation and development
of the project area in MPWD unit based on
historical flood level analysis in the report should Minimum level of land elevation has been
4.16
be clearly recommended in the climate change recommended in both sections.
adaptation & mitigation section page 214 and in
EMP section page 151.
Depth of the three sampling GW tube-wells along
with status of Arsenic and its environmental Depths of collected groundwater are
4.17
interpretation in the Quality of Groundwater mentioned in table 6.8 (page 79)
section should be discussed in page 78.
Section 11.8 details the general guideline for
dredging and landfilling but the section also needs
Tentative source of sand for the lad
to discuss the tentative source of sand from the
development purpose and tentative
nearest location for the proposed landfilling along
4.18 pipeline for sand transportation have
with a layout of the dredging pipeline network from
been addressed in section 11.8 (page
the source should be discussed: (ref: similar ESIA
195, 196)
reports on other EZs may be consulted for this
issue).
General and indicative impacts of Dredging on
Indicative impacts and mitigation
soil, water, aquatic ecology, socioeconomic
measures have been addressed for
4.19 condition of the project area along with their
different IECs in the section 8.3 and 9.3
mitigation measures should be discussed in the
respectively.
EMP section 9.0.
List of on-going (not the proposed one) off-site
development activities around the project area and Plan to mitigate the cumulative impacts
their cumulative environmental impacts along with has been addressed in the section 11.8
4.20
the proposed on-site development activities with under the title ‘integrated plan for other
mitigation measures should be discussed in the off-site infrastructure’ (page 202)
report.
Proportion of the total land area allocated for Proportions of allocated lands of different
4.21 different zones and facilities in percentages inside zones to total area are mentioned in table
NEZ should be mentioned in table 4.4. 4.4 (page 35)
Comments on CETP, STP, solid waste treatment
and integrated waste management issues in
section 2.9 from DoE and 4.2 from BEZA were not General description, and management
addressed which needs to be addressed in the aspects of waste, CETP, STP etc. are
report prior to the review by DoE for final approval mentioned in section 4.2 and 11.8.
4.22 of the ESIA report; (it is suggested to provide a Details design criteria of STP, CETP are
general and tentative detail of the layout, process not possible to mention as the number
flow description for liquid/solid waste management and scales of the industries are not
including construction, dredging debris, hazardous finalized yet.
and E-waste etc. addressing the regulatory
requirements of ZLD, ZDHC, 3R strategies, sludge

259
 Appendix

Sl.
Comments Responses by CEGIS
No.
management guideline of DoE. The study should
be more technical than descriptive as pointed out
in the presentation by DoE.
5. Md. Abdul Quader Khan, Social Specialist, Support to Capacity Building of BEZA Project, BEZA
Environmental and social impacts and mitigation
measures: The consultancy firm can highlight the
5.1 only social impacts in separate head. Though the Action Taken (See, Impact Chapter)
heading is Environmental and social impacts but
here is no major discussion on social part.
Please provide the summary of social impact in
5.2 the Executive summary including affected HHs Action Taken
and number of persons
In Impact Assessment Chapter, an ISC
Please add separate section for off-site for assessing Social Impact of off-site
5.3 development plan and its social impact both in developed has been considered and
executive summary and details. discussed in relevant Section including
Executive Summary.
An ISC on off-site development has been
Please provide the mitigation measures for social
considered, impacts have been assessed
5.4 point of views in the report based on proposed
and mitigation measures have been
utility connection e.g. .road, gas, electricity etc.
suggested (in Impact Chapter)
National Legislations Relevant to Environment: In
this chapter there is no discussion about
Economic Zone labor law 2019. They have National Child Labor Elimination Policy,
5.5 discussed only National Child Labor Elimination 2010 has been deleted and Economic
Policy, 2010 which is not applicable according to Zone labor law 2019 has been discussed
BEZA Act-2010. Please update this chapter
according to comments.
In the social part, please incorporate the socio-
The general description of socio-
economic profile of land owner including their
economic profile of population living in
education, male-female ratio, Occupation Status,
5.6 the study is presented. However, profile
Literacy Rate, Employment Status, Age structure,
of landowners –to be dispossessed- by
source of drinking water, Household Income and
the project
Expenditure etc.
Please add chapter for livelihood restoration plan
5.7 Action Taken
for affected land owners

260
Appendix II: Approved ToR and Exemption of IEE

261
Appendix

262
Appendix

263
Appendix

264
Appendix III: Participants List

265
Appendix

266
 Appendix

Sl. no Name Profession Mobile no.

1. Moyeenul Islam Deputy Commissioner, Netrokona 01715-123128
2. Mashuda Akter UNO, Netrokona Sadar 01793762106
3. Md. Abdul Rahim Chairman, Singher Bangla 01718716766
4. Md. Abdul Razzak Chairman, Thakurakona 01713548440
5. Abdul Amin Farmer 01743352500
6. Gorango Sarker Teacher 01712851805
7. Salman Hossain Farmer 01949957250
8. Jagodish Chandro Sarker Farmer 01780502169
9. Chand Mia Farmer -
10. Mujib Sarker Farmer 01747895020
11. Juhira Begum Farmer 01784411568
12. Soab Ali Farmer -
13. Nur Islam Farmer 01912499352
14. Liton Sarker Farmer -
15. Nandan Sarker Farmer -
16. Mahabubur Rahman Farmer 01732729575
17. Sahid Islam Farmer 01714643318
18. Asad Mia Farmer 01738862335
19. Abdul Jalil Farmer 01737018747
20. Masadul Mia Farmer -
21. Ranjit Mia Farmer -
22. Mujibur Rahman Farmer -
23. Rukka Mia Farmer 01770568841
24. Poran Sarker Farmer -
25. Khalil Khan Business -
26. Mangal Sarker Business 01766866211
27. Uzzal Khan Business -
28. Shakiul Alam Service 01714647072
29. Mr. Alius Selim Farmer 01718756577
30. Abdul Sattar Farmer 01725889274
31. Shahid Mia Farmer -
32. Komol Mia Business -
33. Ataur Rahman Service 01989828429
34. Shafiqul Islam Service 01749414548
35. Abdul High Service 01712094787
36. Nurul Amin Service 01717625302
37. Joj Mia Politician 01718914718
38. Abdulah Razzak Farmer 01728978237
39. Chand Mia Farmer 01728012459
40. Fazlu Mia Farmer 01718490188
41. Abdur Sattar Farmer 01725889274
42. Juwel Mia Farmer 01735060310

267
 Appendix

Sl. no Name Profession Mobile no.

43. Kadir Farmer 01715625509
44. Rokon Mia Farmer 01927046211
45. Md. Kanchan Mia, Business 01715739991
46. Yusuf Ali Farmer -
47. Rafiqul Islam Farmer 01725005791
48. Mahammud Ali Service 01718813795
49. Md. Abu Taher Farmer 01752644687
50. Md. Selim Mia Farmer 01721517643
51. Md. Abdul Jalil Teacher 01712458796
52. Angur Mia Farmer 01759575008
53. Md. Arab Ali Farmer 01727708220
54. Rana Mia Student 01714591599
55. Md. Babul Mia Farmer 01714486249
56. Tara Sarker Farmer 01727454563
57. Usha Rani de Housewife -
58. Srey Tagar Farmer -
59. Md. Rusam Ali Farmer -
60. Sohel Mia Student 01754484539
61. Sharif Mia Buisness 01710597777
62. Md. Shohel Mia Student 01760617860
63. Ratan Chanda Farmer -
64. Ranjit Chanda Farmer 01745222776
65. Sona Mia Farmer -
66. Tara Mia Farmer -
67. Kaman Ulla Member 01745189333
68. Sangher Gotriyo Farmer -
69. Binod Chandra Farmer -

268
 Appendix IV: Photographs of the Stakeholder Consultation
Meetings

Formal Stakeholder Consultation Meeting at Key Informant Interview (KII) with Netrokona
Netrokona upzila parishad Deputy Commissioner (DC) at Netrokona zila
parishad

Meeting with Upazila Nirbahi Officer (UNO) at Meeting with Chairman at Singher Bangla union
Netrokona upazila parishad parishad

Meeting with Chairman at Thakurakona union Discussion meeting with local people at Singher
parishad Bangla village, Netrokona

269
 Appendix

Discussion with local people at project area Discussion meeting with Garo Community at
Netrokona

Discussion meeting with local people at Barni Discussion meeting with local people at Barni
village, Netrokona sadar village, Netrokona sadar

Discussion with local people at Bhadropara

Discussion with local people at project area
village, Netrokona sadar

270
 Appendix V: Environmental Code of Practices

Introduction
The objective of the Environmental Code of Practices (ECPs) is to address all potential and
general construction related impacts during the land development and construction phase of
Netrokona Economic Zone. The ECPs will provide guidelines for best operating practices
and environmental management guidelines to be followed by the contractors for sustainable
management of all environmental issues. These ECPs shall be annexed to the general
conditions of all the contracts, including subcontracts, carried out under the Project.
The list of ECPs prepared for the Project is given below.
ECP 1: Waste Management
ECP 2: Fuels and Hazardous Goods Management
ECP 3: Water Resources Management
ECP 4: Drainage Management
ECP 5: Soil Quality Management
ECP 6: Erosion and Sediment Control
ECP 7: Top Soil Management
ECP 8: Topography and Landscaping
ECP 9: Quarry Areas Development and Operation
ECP 10: Air Quality Management
ECP 11: Noise and Vibration Management
ECP 12: Protection of Flora
ECP 13: Protection of Fauna
ECP 14: Protection of Fish
ECP 15: Road Transport and Road Traffic Management
ECP 16: Construction Camp Management
ECP 17: Cultural and Religious Issues
ECP 18: Worker Health and Safety
ECP 19: Construction and Operation Phase Security
Contractors will prepare site specific management plans, namely Construction
Environmental Management Plan (CEMP), in compliance with the World Bank and
Environmental Conservation Rules, 1997 of Bangladesh and based on the guidance given in
the ECPs. The CEMP will form the part of the contract documents and will be used as
monitoring tool for compliance. It is mandatory for the main contractors procured directly by
the project to include these ECPs in their subcontracts. Violation of this requirements will be
treated as non-compliance leading to the corrections or otherwise imposing penalty on the
contractors.

271
 Appendix

ECP 1: Waste Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Develop site specific waste management plan for
various waste streams (e.g., reusable waste,
flammable waste, construction debris, food waste
etc.) prior to commencing of construction and submit
to supervision consultant for approval.
 Organize disposal of all wastes generated during
construction in the designated disposal sites
approved by the Project authority.
 Minimize the production of waste materials by 3R
(Reduce, Recycle and Reuse) approach.
 Segregate all wastes, wherever practical.
 Vehicles transporting solid waste shall be totally
confined within an enclosed vehicle or is fully
covered with a tarp to prevent spilling waste along
the route.
 Tarp must be undamaged (not torn or frayed)
Soil and water
properly secured to the body of the vehicle or trailer
pollution from the
with ropes, chains, straps, or cords so that no waste
improper
is exposed. The edges of the tarps shall extend 12
General Waste management of
inches over the permanent sides and back of the
wastes and excess
open top vehicle or trailer and must be secured to
materials from the
the permanent vehicle. All loads must be tapped
construction sites.
from the point of origin of the waste to the tipping
area of the final disposal/landfill.
 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 clean, tidy and safe
and provide and maintain appropriate facilities as
temporary storage of all wastes before transporting
to final disposal.
 Potable water should be supplied in bulk containers
to reduce the quantity of plastic waste (plastic bins).
Plastic bag use should be avoided.
The Contractor shall
Health hazards and
 Collect chemical wastes in 200-liter drums (or similar
environmental
sealed container), appropriately labeled for safe
impacts due to
Hazardous Waste transport to an approved chemical waste depot.
improper waste
management  Store, transport and handle all chemicals avoiding
practices potential environmental pollution.
 Store all hazardous wastes appropriately in bounded

272
 Appendix

Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts
areas away from water courses.
 Make available all Material Safety Data Sheets
(MSDS) for hazardous materials on-site during
construction.
 Collect hydrocarbon wastes, including lube oils, for
safer transport off-site to reuse, recycle, treatment or
disposal at approved locations.
 Construct concrete or other impermeable hard-stand
to prevent seepage in case of spills.
 Keep sufficient stock of absorbents for generally
used chemicals or for petrochemicals (e.g., dirt,
sawdust, etc.) within the storage area to contain
accidental spills.

ECP 2: Fuels and Hazardous Goods Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare spill control procedures and submit them for
supervision consultant for approval.
 Train the relevant construction personnel in handling
of fuels and spill control procedures.
 Refueling shall occur only within bounded areas.
 Store dangerous goods in bounded areas on top of a
Materials used in sealed plastic sheet away from watercourses. Store
construction have a all liquid fuels in fully bounded storage containers,
potential to be a with appropriate volumes, a roof, a collection point
source of and appropriate filling/decanting point.
contamination.  Store and use fuels in accordance with material
Improper storage and safety data sheets (MSDS). Make available MSDS
handling of fuels, for chemicals and dangerous goods on-site.
lubricants, chemicals,  Store hazardous materials at above flood level,
Fuels and
hazardous determined for construction.
hazardous goods.
goods/materials on-
 Make sure all containers, drums, and tanks that are
site, wash down of
used for storage are in good condition and are
equipment, and
labeled with expiry date. Any container, drum, or
potential spills may
tank that is dented, cracked, or rusted might
harm the
eventually leak. Check for leakage regularly to
environment or health
identify potential problems before they occur.
of construction
workers.  Sit 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 drain to a safe collection area in the event
of a spill.
 Take all precautionary measures when handling and
storing fuels and lubricants, avoiding environmental
pollution.
 All machinery is to be stored and away from any

273
 Appendix

Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts
water body, drainage inlets or natural drainage area,
where practical. Environmental control measures
such as appropriate barriers (i.e. bounding, sediment
fence, etc.) will be considered and/or implemented to
control runoff away from the machinery and prevent
any washout in to adjacent water body, drainage
inlets or natural drainage area.
 Transport waste of dangerous goods, which cannot
be recycled, to an approved waste disposal facility.
Safe transport of fuel or other hazardous liquids to
and from the storage container will be facilitated
through the provision detailed within the Material
Safety Data Sheets (MSDS).
 Wash down of equipment and vehicle servicing will
be performed only in isolated impervious areas away
from drainage inlets, connecting the drainage with
an oil interceptor. Pits/bunds located away from
waterways will be provided for concrete wash near
construction areas. The contractor’s environmental
officer with assistance from supervisors is to ensure
that pits/bunds are available, maintained at capacity
and drivers instructed regarding the location and
required procedures
 Keep stock of absorbent and containment material
(e.g., absorbent matting, dirt, sawdust, etc.) where
hazardous materials are used and stored; and
ensure staffs are trained in their correct use.
 Oil and chemical spills and washouts shall be
cleaned up and collected immediately, where safety
permits. Disposal of remediated / cleanup/ washout
materials shall be to an approved waste disposal
facility. Materials shall be transported by an
approved / licensed transporter. Contaminated
Material to be removed from site as soon as
reasonably practical after the incident.
 Provide appropriate personal protective equipment
(protective clothing, safety boots, helmets, masks,
gloves, goggles, etc.) to the construction personnel,
depending on the materials handled.
 Avoid the use of material with greater potential for
contamination by substituting them with more
environmentally friendly materials.

274
 Appendix

ECP 3: Water Resources Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Follow the management guidelines proposed in
Water pollution from the ECP 1: Waste Management and ECP 2: Fuels
storage, handling and and Hazardous Goods Management.
Hazardous
material and
disposal of hazardous  Minimize the generation of spoils, oil and
materials and general grease, excess nutrients, organic matter, litter,
Waste
construction waste, and debris and any form of waste (particularly
accidental spillage petroleum and chemical wastes). These
substances must not enter waterways or storm
water systems.
The Contractor shall
 Install temporary drainage works (channels and
check dams) in areas required for sediment and
erosion control and around storage areas for
Construction activities,
construction materials.
sewerages from
construction sites and  Install temporary sediment lagoons, where
work camps may affect appropriate, to capture sediment-laden run-off
the surface water from work site.
quality. The  Divert runoff from undisturbed areas around the
construction works will construction site.
modify groundcover  Stockpile materials away from drainage lines.
and topography,
 Prevent all solid and liquid wastes entering
changing the surface
Discharge from waterways by collecting spoils, oils, chemicals,
water drainage patterns
construction sites bitumen spray waste and wastewaters from
of the area. These
brick, concrete and asphalt cutting where
changes in hydrological
possible and transport to an approved waste
regime lead to
disposal site or recycling depot.
increased rate of runoff,
increase in sediment  Wash out ready-mix concrete agitators and
and contaminant concrete handling equipment at washing
loading, increased facilities off site or into approved bunded areas
flooding, and effect on site. Ensure that tires of construction
habitat of fish and other vehicles are cleaned in the washing bay
aquatic biology. (constructed at the entrance of the construction
site) to remove the mud from the wheels. This
should be done in every exit of each
construction vehicle to ensure the local roads
are kept clean.
The Contractor shall
At the land  Stabilize the cleared areas not used for
development stage, soil construction activities with vegetation or
erosion and dust from appropriate surface water treatments as soon
Soil erosion and the material stockpiles as practicable following earthwork to minimize
siltation will increase the erosion.
sediment and  Ensure that roads used by construction
contaminant loading of vehicles are swept regularly to remove dust and
surface water bodies. sediment.
 Water the loose material stockpiles, access

275
 Appendix

Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts
roads and bare soils on an as needed basis to
minimize dust. Increase the watering frequency
during periods of high risk (e.g. high winds).
The Contractor Shall
Untreated surface
water is not suitable for  Provide drinking water that meets National and
WHO Drinking Water standards. Drinking water
drinking purposes due
Drinking water to be chlorinated at source, and ensure
to presence of
presence of residual chlorine 0.1 ~ 0.25 ppm as
suspended solids and
E. coli. minimum after 30 minutes of chlorine contact
time.

ECP 4: Drainage Management

Project Activity/
Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
The Contractor shall
 Prepare drainage management procedures
and submit them for supervision consultant for
approval.
 Prepare a program to prevent/avoid standing
waters, which supervision consultant will verify
in advance and confirm during implementation.
 Provide alternative drainage for rainwater if the
construction works/earth-fillings cut the
established drainage line.
 Establish local drainage line with appropriate
silt collector and silt screen for rainwater or
Lack of proper drainage wastewater connecting to the existing
for rainwater/liquid waste
established drainage lines already there.
or wastewater owing to
Excavation and
the construction  Rehabilitate road drainage structures
earth works, and
activities harms immediately if damaged by contractors’ road
construction transports.
environment in terms of
yards  Build new drainage lines as appropriate and
water and soil
contamination, and required for wastewater from construction
mosquito growth. yards connecting to the available nearby
recipient water bodies. Ensure wastewater
quality conforms to National Standards, before
it is being discharged into the recipient water
bodies.
 Ensure that there will be no water stagnation at
the construction sites and camps.
 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.

276
 Appendix

Project Activity/
Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
 Regularly inspect and maintain all drainage
channels to assess and alleviate any drainage
congestion problem.
 Do not allow ponding of water especially near
the waste storage areas and construction
Health hazards due to camps.
Ponding of water
mosquito breeding  Discard all the storage containers that are
capable of storing of water, after use or store
them in inverted position.

ECP 5: Soil Quality Management

Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts

The Contractor shall

 Strictly manage the wastes management plans
proposed in ECP 1: Waste Management and
storage of materials and ECP 2: Fuels and
Hazardous Goods Management.
 Construct appropriate spill containment facilities
for all fuel storage areas.
 Establish and maintain a hazardous material
register detailing the location and quantities of
Storage of Spillage of hazardous
hazardous substances including the storage,
hazardous and and toxic chemicals will
and their disposals.
toxic chemicals contaminate the soils
 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.
Dumping of Polluted soil may The Contractor shall
polluted soil for contaminate surface  Test the quality of soil arranged for the land
the development water as well as ground development before dumping and ensure the
of land water in the long run toxicity level is within the permissible standards.
Erosion from The Contractor shall
Construction
material stock
construction material  Protect the toe of all stockpiles, where erosion is
stockpiles may likely to occur, with silt fences, straw bales or
piles
contaminate the soils bunds.

277
 Appendix

ECP 6: Erosion and Sediment Control

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
Cleared areas and
 Prepare site specific erosion and sediment
slopes are
control measures and submit them for
susceptible for
Clearing of supervision consultant for approval.
erosion of top soils,
construction
which affects the  Reinstate and protect cleared areas as soon as
sites possible.
growth of vegetation
and causes  Cover unused area of disturbed or exposed
ecological imbalance. surfaces immediately with mulch/grass turf/tree
plantations.
The Contractor shall
 Locate stockpiles away from drainage lines.
 Protect the toe of all stockpiles, where erosion is
likely to occur, with silt fences, straw bales or
bunds.
 Remove debris from drainage paths and
sediment control structures.
 Cover the loose sediments of construction
Destruction of aquatic material and water them if required.
environment by  Divert natural runoff around construction areas
Construction
erosion and/or prior to any site disturbance.
activities and
deposition of  Install protective measures on site prior to
material
sediment damaging construction, for example, sediment traps.
stockpiles
the spawning
 Install ‘cut off drains’ on large cut/fill batter slopes
grounds of fish
to control water runoff speed and hence erosion.
 Observe the performance of drainage structures
and erosion controls during rain and modify as
required.
 Restrict construction during December-February
when appropriate to avoid temporary impacts to
habitat during critical life history stages (e.g.,
spawning, egg and embryo development, and
juvenile growth).
The Contractor shall
 Stabilize the cleared areas not used for
Soil erosion and dust construction activities with vegetation or
from the material appropriate surface water treatments as soon as
stockpiles will practicable following earthwork to minimize
Soil erosion and increase the erosion.
siltation sediment and  Ensure that roads used by construction vehicles
contaminant loading are swept regularly to remove sediment.
of surface water  Water the material stockpiles, access roads and
bodies. bare soils on an as required basis to minimize
dust. Increase the watering frequency during
periods of high risk (e.g. high winds).

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ECP 7: Top Soil Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Strip the top soil to a depth of 35 cm and store in
stock piles of height not exceeding 2m.
 Remove unwanted materials from top soil like
grass, roots of trees and others.
 The stockpiles will be done in slopes of 2:1 to
reduce surface runoff and enhance percolation
Earthworks will through the mass of stored soil.
impact the fertile top  Locate topsoil stockpiles in areas outside
soils that are drainage lines and protect from erosion.
Land clearing and enriched with  Construct diversion channels and silt fences
earth works nutrients required for around the topsoil stockpiles to prevent erosion
plant growth or and loss of topsoil.
agricultural
 Spread the topsoil to maintain the physico-
development.
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 bounding of
the soil layers, water penetration and
revegetation
Vehicular movement
outside NEZ or  Limit equipment and vehicular movements to
temporary access within the approved construction zone.
Transport
roads will affect the  Plan construction access to make use, if
soil fertility of the possible, of the final road alignment.
agricultural lands

ECP 8: Topography and Landscaping

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
Construction  Prepare landscaping and plantation plan and
activities especially submit the plan to supervision consultant for
earthworks will approval.
change topography  Ensure the topography of the final surface of all
Land clearing and and disturb the raised lands (construction yards, approach roads
earth works natural and rails, access roads, etc.) are conducive to
rainwater/flood enhance natural draining of rainwater/flood
water drainage as water.
well as change the  Keep the final or finished surface of all the raised
local landscape. lands free from any kind of depression that
causes water logging.

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 Undertake mitigation measures for erosion
control/prevention by grass-turfing and tree
plantation, where there is a possibility of rain-cut
that will change the shape of topography.
 Cover immediately the uncovered open surface
that has no use of construction activities with
grass-cover and tree plantation to prevent soil
erosion and better landscaping.
 Reinstate the natural landscape of the ancillary
construction sites after completion of works.

ECP 9: Quarry Areas Development and Operation

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare borrow/quarry area management plan and
submit the plan for supervision consultant approval.
 Use only approved quarry and borrow sites.
 Identify new borrow and quarry areas in
consultation with the client, if required.
 Reuse excavated or disposed material available in
the project to the maximum extent possible.
 Store top soil for reinstatement and landscaping.
Borrow areas will  Develop surface water collection and drainage
Development and have impacts on systems, anti-erosion measures (berms,
operation of local topography, revegetation etc.) and retaining walls and gabions
borrow areas landscaping and where required. Implement mitigation measures in
natural drainage. ECP 3: Water Resources Management, ECP 6:
Erosion and Sediment Control
 The use of explosive should be used as low as
possible to reduce noise, vibration, and dust.
 Control dust and air pollution by application of
watering and implementing mitigation measures
proposed in
 ECP 10: Air Quality Management
 Noise and vibration control by ECP 11: Noise and
Vibration Management.

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ECP 10: Air Quality Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare air quality management plan (under the
Pollution Prevention Plan) and submit the plan for
supervision consultant approval.
 Fit vehicles with appropriate exhaust systems and
emission control devices. Maintain these devices in
good working condition.
Air quality can be
adversely affected  Operate the vehicles in a fuel-efficient manner.
Construction by vehicle exhaust  Cover hauling vehicles carrying dusty materials
vehicular traffic emissions and moving outside the construction site.
combustion of  Impose speed limits on all vehicle movement at the
fuels. 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.
The Contractor shall
 Fit machinery with appropriate exhaust systems and
emission control devices. Maintain these devices in
good working condition in accordance with the
specifications defined by their manufacturers to
maximize combustion efficiency and minimize the
contaminant emissions. Proof of maintenance
register shall be required by the equipment suppliers
Air quality can be and contractors/subcontractors.
adversely affected  Pay special attention to control emissions from fuel
Construction by emissions from generators.
machinery machinery and  Machinery causing excessive pollution (e.g., visible
combustion of smoke) will be banned from construction sites.
fuels.  Service all equipment regularly to minimize
emissions.
 Provide filtering systems, dust collectors or
humidification or other techniques (as applicable) to
the concrete batching and mixing plant to control the
particle emissions in all stages, including unloading,
collection, aggregate handling, cement application,
circulation of trucks and machinery inside the
installations.
Dust generation The Contractor shall
from construction  Water the material stockpiles, access roads and
Construction sites, material bare soils on an as needed basis to minimize the
activities stockpiles and potential for environmental nuisance due to dust.
access roads is a Increase the watering frequency during periods of
nuisance in the high risk (e.g. high winds). Stored materials such as

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environment and gravel and sand shall be covered and confined to
can be a health avoid their being wind-drifted.
hazard, and also  Minimize the extent and period of exposure of the
can affect the local bare surfaces.
crops
 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
generation is minimized during such operations.
 Not use water as dust suppression on potentially
contaminated areas, to prevent generation of liquid
waste stream.
 Crushing of rock and aggregate materials shall be
wet-crushed, or performed with particle emission
control systems.
 Not permit the burning of solid waste.

ECP 11: Noise and Vibration Management

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare a noise and vibration management plan (under
the Pollution Prevention Plan) and submit the plan for
supervision consultant approval.
Noise quality will  Maintain all vehicles in order to keep it in good working
Construction be deteriorated condition in accordance with manufactures maintenance
vehicular traffic due to vehicular procedures.
traffic  Make sure all drivers will comply with the traffic codes
concerning maximum speed limit, driving hours, etc.
 Perform the loading and unloading of trucks, and
handling operations minimizing construction noise on the
work site.
The Contractor shall
 Appropriately organize all noise generating activities to
Noise and avoid noise pollution to local residents.
vibration may
 Use the quietest available machineries and equipment in
have an impact
construction work.
Construction on people,
machinery property, fauna,  Maintain all equipment in order to keep them in good
livestock and the working order in accordance with manufactures
natural maintenance procedures. Equipment suppliers and
environment. contractors shall present proof of maintenance register of
their equipment.
 Install acoustic enclosures around generators to reduce

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noise levels.
 Fit high efficiency mufflers to appropriate construction
equipment.
 Avoid unnecessary use of alarms, horns and sirens.
The Contractor shall
 Notify adjacent landholders prior to typical noise events
outside of daylight hours.
 Educate the operators of construction equipment on
potential noise problems and the techniques to minimize
noise emissions.
Noise and
vibration may  Employ best available work practices on-site to minimize
have an impact occupational noise levels.
Construction on people,  Install temporary noise control barriers where
activity property, fauna, appropriate.
livestock and the  Notify affected people if major noisy activities will be
natural undertaken, e.g. blasting.
environment.
 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.

ECP 12: Protection of Flora

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare a plan to protect flora and submit the
plan for supervision consultant approval.
Local flora are  Minimize disturbance to surrounding vegetation.
important habitats for  Use appropriate type and minimum size of
birds, provide fruit machine to avoid disturbance to adjacent
harvest, timber/fire vegetation.
wood, protect soil from  Get approval from supervision consultant for
erosion and overall clearance of vegetation.
Vegetation
keep the natural  Make selective and careful pruning of trees
clearance
balance for human- where possible to reduce need of tree removal.
living. As such
 Control noxious weeds by disposing of at
damage to flora has
designated dump site or burn on site.
wide range of adverse
environmental  Clear only the vegetation that needs to be
impacts. cleared in accordance with the engineering
plans and designs. These measures are
applicable to both the construction areas as well
as to any associated activities such as sites for
stockpiles, disposal of fill, etc.

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 Not burn off cleared vegetation – where feasible,
chip or mulch and reuse it for the rehabilitation of
affected areas, temporary water main and valve
access or landscaping. Mulch provides a seed
source, can limit embankment erosion, retains
soil moisture and nutrients, and encourages re-
growth and protection from weeds.
 Return topsoil and mulched vegetation (in areas
of native vegetation) to approximately the same
location from where it came from.
 Avoid work within the drip-line of trees to prevent
damage to the tree roots and compacting the
soil.
 Minimize the length of time the ground is
exposed or excavation left open by clearing and
re-vegetate the area at the earliest practically
possible.
 Ensure excavation works occur progressively
and re-vegetation 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 camps to
prevent fuel wood collection.

ECP 13: Protection of Fauna

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare a plan for protection of fauna and submit the
The location of plan for supervision consultant approval.
construction
 Limit the construction works within the designated
activities can
Construction sites allocated to the contractors.
result in the loss of
activities
wild life habitat  Check the site (especially trenches) for trapped
and habitat animals, and rescue them by the help of a qualified
quality, person.
 Provide temporary access to the animals to cross
the trenches.
The Contractor shall
 Not be permitted to destruct active nests or eggs of
Impact on local
birds.
and migratory
birds, their  Minimize the tree removal during the bird breeding
habitats and active season. If works must be continued during the bird
nests breeding season, a nest survey will be conducted by
a qualified biologist prior to commence of works to
identify and locate active nests.

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 If bird nests are located/ detected within the right-of-
way and roadside embankments, then those areas
should be avoided.
 Petroleum products should not come in contact with
the natural and sensitive ecosystems. Contractor
must minimize the release of oil, oil wastes or any
other substances harmful to migratory birds’
habitats, to any waters, wetlands or any areas
frequented by migratory birds.
The Contractor shall
 Restrict the tree removal to the minimum numbers
required.
 Relocate hollows, where appropriate.
Clearance of
vegetation may  Fell the hollow bearing trees in a manner which
impact shelter, reduces the potential for fauna mortality. Felled trees
feeding and/or will be inspected after felling for fauna and if
Vegetation identified and readily accessible will be removed and
breeding and/or
clearance relocated or rendered assistance if injured. After
physical
destruction and felling, hollow bearing trees will remain unmoved
severing of habitat overnight to allow animals to move of their own
areas volition. Care should be taken to make sure bird
habitats are not destroyed. If there is no option
available, rehabilitate them in other neighboring
trees. Also protect and rehabilitate injured or
orphaned birds.
The Contractor shall
Lighting from  Use lower wattage flat lens fixtures that direct light
construction sites down and reduce glare, thus reducing light pollution,
and construction
 Avoid flood lights unless they are absolutely
camps may affect
required.
the visibility of
Night time lighting night time  Use motion sensitive lighting to minimize unneeded
migratory birds lighting.
that use the moon  Use, if possible, green lights that are considered as
and stars for bird’s friendly lighting instead of white or red colored
navigation during lights.
their migrations.  Install light shades or plan the direction of lights to
reduce light spilling outside the construction area.
The Contractor shall
 Provide adequate knowledge to the workers
regarding protection of flora and fauna, and relevant
government regulations and punishments for illegal
Construction poaching.
Illegal poaching
camps  Ensure that staff and Subcontractors are trained and
empowered to identify, address and report potential
environmental problems.
 Provide sufficient food allowance to the workers so
that they don’t engage in illegal poaching or hunting.

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ECP 14: Protection of Fish

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare procedures for protection of fish and
submit them for supervision consultant
approval.
 Ensure the construction equipment used in the
river are well maintained and do not have oil
Construction The main potential leakage to contaminate river water.
activities around impacts to fisheries  Contain oil immediately on river in case of
the wetlands (beel are hydrocarbon accidental spillage from equipment; make an
areas) and existing spills and disposal of emergency oil spill containment plan (under the
drainage canals wastes into the beel. Fuels and Hazardous Substances
Management 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
impacts on river are
increased suspended The Contractor shall
Construction solids from
 follow mitigation measures proposed in ECP 3:
activities on the earthworks erosion,
Water Resources Management and
land sanitary discharge
from work camps,  ECP 4: Drainage Management.
and hydrocarbon
spills

ECP 15: Road Transport and Road Traffic Management

Project Activity/
Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
The Contractor shall
 Prepare a traffic management plan and
submit the plan for supervision consultant
approval.
 Strictly follow the Project’s ‘Traffic
Increased traffic use of
Management Plan’ and work with close
road by construction
coordination with the Traffic Management
Construction vehicles will affect the
Unit.
vehicular traffic movement of normal
road traffics and the  Prepare and submit additional traffic plan, if
safety of the road-users. any of this traffic route is not covered in the
Project’s Traffic Management Plan, and
requires traffic diversion and management.
 Include in the traffic plan to ensure
uninterrupted traffic movement during
construction: detailed drawings of traffic

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arrangements showing all detours, temporary
road, temporary bridges, temporary
diversions, necessary barricades, warning
signs/lights, road signs, construction
schedule etc.
 Provide signs at strategic locations of the
roads complying with the schedules of signs
contained in the National Traffic Regulations.
The Contractor shall
 Restrict truck deliveries, where practicable,
to day time working hours.
 Restrict the transport of oversize loads.
Accidents and spillage of
??????
fuels and chemicals  Operate vehicles, if possible, to non-peak
periods to minimize traffic disruptions.
 Enforce on-site speed limit, especially close
to the sensitive receptors, schools, health
centers, etc.

ECP 16: Construction Camp Management

Project Activity/
Environmental Impacts Mitigation Measures/ Management Guidelines
Impact Source
The Contractor shall
 Prepare a construction camp management
plan and submit the plan to supervision
consultant for approval.
 Locate the construction camps within the
designated sites or at areas which are
acceptable from environmental, cultural or
social point of view and approved by the
supervision consultant or the Client.
Campsites for construction  Conduct consultation with communities
workers are the important including local government institutes (Local
Siting and locations that have member of Union Parishad) prior to set-up
Location of significant impacts such as the camp.
construction health and safety hazards
 Consider the location of construction camps
camps on local resources and
away from communities in order to avoid
infrastructure of nearby social conflict in using the natural resources
communities.
such as water or to avoid the possible
adverse impacts of the construction camps
on the surrounding communities.
 Submit to the supervision consultant 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
access roads, fuel storage areas (for use in

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power supply generators), solid waste
management and dumping locations, and
drainage facilities, prior to the development of
the 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 surveillance over public
health, social, and security matters.
Contractor shall provide the following facilities in
the campsites
 Adequate housing for all workers.
 Safe and reliable water supply, which should
meet national/WHO standards. Drinking
water to be chlorinated at source, and ensure
presence of residual chlorine 0.1 ~ 0.25 ppm
as minimum after 30 minutes of chlorine
contact time (WHO guideline).
 Hygienic sanitary facilities and sewerage
system. The toilets and domestic waste water
will be collected through a common
Lack of proper sewerage. Provide separate latrines and
infrastructure facilities, bathing places for males and females with
such as housing, water total isolation by location. The minimum
supply, and sanitation number of toilet facilities required is one toilet
Construction facilities will increase for every ten persons.
Camp Facilities pressure on the local
 Treatment facilities for sewerage of toilet and
services and generate
domestic wastes.
substandard living
standards and health  Storm water drainage facilities.
hazards.  Paved internal roads.
 Provide child crèches for women working at
construction site. The crèche should have
facilities for dormitory, kitchen, indoor and
outdoor play area. Schools should 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.

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The Contractor shall
 Ensure proper collection and disposal of solid
wastes within the construction camps.
 Insist waste separation by source; organic
wastes in one container and inorganic wastes
in another container at household level.
Management of wastes is  Store inorganic wastes in a safe place within
Disposal of waste crucial to minimize impacts the household and clear organic wastes on
on the environment daily basis to waste collector. Establish waste
collection, transportation and disposal
systems with the manpower and
equipment/vehicles needed.
 Do not establish site specific landfill sites. All
solid waste will be collected and removed
from the work camps and disposed in
approved waste disposal sites.
The Contractor shall
 Provide fuel to the construction camps for
their domestic purpose, in order to
discourage them to use fuel wood or other
biomass.
Illegal sourcing of fuel
wood by construction  Made available alternative fuels like natural
Fuel supplies for
gas or kerosene on ration to the workforce to
cooking purposes workers will impact the
natural flora and fauna prevent them using biomass for cooking.
 Conduct awareness campaigns to educate
workers on preserving the protection of
biodiversity and wildlife of the project area,
and relevant government regulations and
punishments on wildlife protection.
The Contractor shall
 Provide adequate health care facilities within
construction sites.
 Provide first aid facility round the clock.
Maintain stock of medicines in the facility and
There will be a potential for appoint fulltime designated first aider or
diseases to be transmitted nurse.
including malaria,  Provide ambulance facility for the laborers
exacerbated by inadequate during emergency to be transported to
Health and health and safety nearest hospitals.
Hygiene practices. There will be an  Initial health screening of the laborers coming
increased risk of work from outside areas.
crews spreading sexually
 Train all construction workers in basic
transmitted infections and
sanitation and health care issues and safety
HIV/AIDS.
matters, and on 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

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basis.
 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 rainy season in
offices and construction camps and yards.
 Not dispose food waste openly as that will
attract rats and stray dogs.
 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 hygiene
practices.
The Contractor shall
 Provide appropriate security personnel
(police or private security guards) and
enclosures to prevent unauthorized entry in
to the 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
Inadequate security and construction of labor housing / site office.
safety provision in
Also, ensure that these houses/rooms are of
construction camps may sound construction and capable of
Security and
create security and safety
Safety withstanding wind storms/cyclones.
problems of workforces
and assets and fire  Provide appropriate type of firefighting
hazards equipment suitable for the construction
camps.
 All construction material storage should be sit
a visible location secured with fence or solid
walls with locks to avoid theft and vandalism.
 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.
The Contractor shall
 Dismantle and remove from the site all
facilities established within the construction
Restoration of the
camp including the perimeter fence and
construction camps to
lockable gates at the completion of the
Site Restoration original condition requires
construction work.
demolition of construction
camps.  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

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demolishing their camps/units.
 Maintain the noise levels within the national
standards during demolition activities.
 Different contractors should 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.
 Restore the site to its condition prior to
commencement of the works or to an agreed
condition with the landowner.

ECP 17: Cultural and Religious Issues

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Communicate to the public through community
consultation regarding the scope and schedule of
construction, as well as certain construction
activities causing disruptions or access
restriction.
 Not block access to cultural and religious sites,
wherever possible.
 Restrict all construction activities within the foot
prints of the construction sites.
Disturbance from
 Stop construction works that produce noise
construction works to
(particularly during prayer time) should there be
Construction the cultural and
any church/mosque/religious/educational
activities near religious sites, and
institutions and health center close to the
religious and contractors lack of
construction sites and users make objections.
cultural sites knowledge on cultural
issues cause social  Take special care and use appropriate
disturbances. equipment when working next to a
cultural/religious center.
 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 obtained by the
archaeological authority.
 Provide independent prayer facilities to the
construction workers.
 Show appropriate behavior with all construction

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workers especially women and elderly people.
 Allow the workers to participate in praying during
construction time, if there is a request.
 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.

ECP 18: Worker Health and Safety

Project Activity/ Environmental
Mitigation Measures/ Management Guidelines
Impact Source Impacts
The Contractor shall
 Prepare an Occupational Health and Safety plan
Construction works
and submit the plan for supervision consultant's
may pose health and
approval.
safety risks to the
construction workers  Implement suitable safety standards for all workers
and site visitors and site visitors, with sufficient provisions to comply
leading to severe with international standards (e.g. International
injuries and deaths. Labor Office guideline on ‘Safety and Health in
The population in the Construction; World Bank Group’s ‘Environmental
proximity of the Health and Safety Guidelines’) and contractor’s own
construction site and safety standards, in addition to complying with
the construction national standards.
workers will be  Provide the workers with a safe and healthy work
exposed to a number environment, taking into account inherent risks in its
of (i) biophysical particular construction activity and specific classes
Best practices
health risk factors, of hazards in the work areas.
(e.g., noise, dust,  Provide personal protective equipment (PPE) for
chemicals, workers, such as safety boots, helmets, masks,
construction material, gloves, protective clothing, goggles, full-face eye
solid waste, waste shields, and ear protection. Maintain the PPE
water, vector properly by cleaning dirty ones and replacing the
transmitted diseases, damaged ones.
etc.), (ii) risk factors
 Safety procedures include provision of information,
resulting from human
training and protective clothing to workers involved
behavior (e.g., STD,
in hazardous operations and proper performance of
HIV/AIDS, etc.) and
their job.
(iii) road accidents
from construction  Appoint an environment, health and safety manager
traffic. to look after the health and safety of the workers.
 Inform the local authorities responsible for health,
religious and security duly informed before

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 Appendix

Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts
commencement of civil works and establishment of
construction camps so as to maintain effective
surveillance over public health, social and security
matters.
???????? The Contractor shall
Child and pregnant  Not hire children of less than 14 years of age and
labor pregnant women or women who delivered a child
within 8 preceding weeks.
The Contractor shall
 Ensure health care facilities and first aid facilities
are readily available. Appropriately equipped first-
aid stations should be easily accessible throughout
the place of work.
 Document and report occupational accidents,
diseases, and incidents.
Lack of first aid
 Prevent accidents, injury, and disease arising from,
facilities and health
associated with, or occurring in the course of work
care facilities in the
by minimizing, so far as reasonably practicable, the
Accidents immediate vicinity
causes of hazards, in a manner consistent with
will aggravate the
good international industry practice.
health conditions of
the victims  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,
inside the tunnels, inside the powerhouse cavern
and along the roads.
The Contractor shall provide the following facilities in the
campsites to improve health and hygienic conditions as
mentioned in
ECP 16: Construction Camp Management:
Lack of proper  Adequate ventilation facilities
infrastructure  Safe and reliable water supply.
facilities, such as  Hygienic sanitary facilities and sewerage system.
housing, water  Treatment facilities for sewerage of toilet and
supply and sanitation domestic wastes
Construction facilities will increase
 Storm water drainage facilities.
Camps pressure on the local
services and  Recreational and social facilities
generate  Safe storage facilities for petroleum and other
substandard living chemicals in accordance with ECP 2
standards and health  Solid waste collection and disposal system in
hazards. accordance with ECP1.
 Arrangement for trainings
 Paved internal roads.
 Security fence at least 2 m height and security
guards at entrances and every corner of the facility.

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Project Activity/ Environmental

Mitigation Measures/ Management Guidelines
Impact Source Impacts
 Sick bay and first aid facilities
The contractor shall
 Provide portable toilets at the construction sites
Lack of Water with workforce size 25 people or more, work the
sanitation facilities at whole day for a month. Location of portable facilities
Water and construction sites should be at least 6 m away from storm drain
sanitation cause inconvenience system and surface waters. These portable toilets
facilities at the to the construction should be cleaned once a day and all the sewerage
construction sites workers and affect should be pumped from the collection tank once a
their personal day and should be brought to the common septic
hygiene. tank for further treatment.
 Provide safe drinking water facilities to the
construction workers at all the construction sites.
The Contractor shall follow the following ECPs to reduce
health risks to the construction workers and nearby
community
 ECP 2: Fuels and Hazardous Goods Management

Potential risks on
 ECP 4: Drainage Management
health and hygiene
Other ECPs of construction 
workers and general  ECP 10: Air Quality Management
public 
 ECP 11: Noise and Vibration Management

 ECP 15: Road Transport and Road Traffic
Management
The Contractor shall
 Train all construction workers in basic sanitation
and health care issues (e.g., how to avoid malaria,
transmission of sexually transmitted infections
(STI), and HIV/AIDS.
 Train all construction workers in general health and
safety matters, and on the specific hazards of their
Lack of awareness
work. Training should consist of basic hazard
and basic knowledge
in health care among awareness, site specific hazards, safe work
Trainings practices, and emergency procedures for fire,
the construction
workforce, make evacuation, and natural disaster, as appropriate.
them susceptible to  Implement malaria, HIV/AIDS and STI education
potential diseases. campaign targeting all workers hired, international
and national, female and male, skilled, semi- and
unskilled workforces, at the time of recruitment and
thereafter pursued throughout the construction
phase on ongoing and regular basis. This should be
complemented by easy access to condoms at the
workplace as well as to voluntary counseling and
testing.

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 Appendix

ECP 19: Construction Phase Security

Project Activity/
Impacts /Concerns Mitigation Measures/ Management Guidelines
Impact Source
The Contractor shall:
 Provide appropriate security personnel (i.e.
security guards) to prevent unauthorized entry
into the camp area.
 Employ night watchman for periods of significant
on-site storage or when the area necessitates.
 Ensure all assets (i.e., tools, equipment, etc.)
and construction materials at construction site
are identified, inventoried and tracked as closely
as possible. All assets should be clearly labeled
and marked. Keep records of tool serial numbers
and check inventory on a regular basis.
 All tools and equipment should have a check
out/in system, if not in use should be secured
and stored in a proper place to prevent theft or
loss. Provide storage sheds for the secure
Inadequate storage of equipment and tools when not in use.
construction site  Ensure there is proper fencing around
security poses a construction site perimeter. Fencing should be
significant risk to chain-link at least 2.4 m high and secured with a
assets, construction steel chain and lock. If possible the entire site
materials and property. should be fenced; if this is not possible, make
Theft/vandalism of sure construction trailer and any equipment
Construction
Phase assets, materials and storage areas are fenced.
property would increase  Ensure construction site has controlled access
construction costs and points (one or two entry points at most), allowing
cause delays in project for close monitoring of comings and goings from
completion. the site.
 Workers should be easily identified and have
credentials that indicate site access.
 No trespassing signs should be posted in
conspicuous areas throughout the job site.
 List of employees who have after hour access to
the property should be available to the PMU and
local authorities.
 Ensure job site is properly lighted at night. Well-
lit areas should include any office trailers and
equipment storage trailers. Floodlights operated
by sensors should also be installed where
appropriate.
 Pre-employment screening investigations should
be used to verify the applicants relating to their
employment, education and criminal history
background.
Improper security The Contractor shall:
measures may pose  Prepare site specific security plan.

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 Appendix

Project Activity/
Impacts /Concerns Mitigation Measures/ Management Guidelines
Impact Source
security risk for  Maintain register to keep track of number of
construction workers persons present in the camp at any given time.
and especially foreign  Provide appropriate security personnel at job
staff on construction sites as mentioned above.
sites.
 Ensure proper fencing as mentioned above.
 Ensure controlled access points to job site as
mentioned above.
 Ensure works have easily identified credentials
as mentioned above.
 Ensure job sites are properly lighted at night, as
mentioned above.

296
Appendix VI: Scanned Copy of Surface Water Test Results

Figure 1: Scanned Test Report of SW-1 (1)

297
 Appendix

Figure 2: Scanned Test Report of SW-1 (2)

298
 Appendix

Figure 3: Scanned Test Report of SW-2 (1)

299
 Appendix

Figure 4: Scanned Test Report of SW-2 (2)

300
 Appendix

Figure 5: Scanned Test Report of SW-3 (1)

301
 Appendix

Figure 6: Scanned Test Report of SW-3 (2)

302
Appendix VII: Scanned Copy of Ground Water Test Results

Figure 1: Scanned Test Report of GW-1 (1)

303
 Appendix

Figure 2: Scanned Test Report of GW-1 (2)

304
 Appendix

Figure 3: Scanned Test Report of GW-2 (1)

305
 Appendix

Figure 4: Scanned Test Report of GW-2 (2)

306
 Appendix

Figure 5: Scanned Test Report of GW-3 (1)

307
 Appendix

Figure 6: Scanned Test Report of GW-3 (2)

308