Environmental Management Framework (emf) coastal embankment improvement project phase-i project (ceip-i) April 29, 2013 Dhaka Bangladesh Water Development Board Ministry of Water Resources Government of the People’s Republic of Bangladesh

7.5Environmental Assessment Process

61. 
    Soon after the commencement of planning and design process, based on desk study, reconnaissance survey and experience of earlier projects, detailed methodology and schedule should be prepared for the effective and timely execution of the Environmental Assessment.
    

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  Focus on the main issues: It is important that the EA does not try to cover too many topics in too much detail. Effective scoping can save both time and money by focusing the EA studies on the key issues.
  
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  EA requires the formation of a multidisciplinary team and the leadership of a strong EA coordinator. The range of effects considered in the EA requires the skills of CEIP mix of technical experts to be employed on an assessment team, lead by a Team Leader/EMU. It is important to involve the right people (e.g., scientists, engineers, policymakers, government 0prepresentatives, representatives of public interest groups and the local community) and agencies (e.g., the developer, the aid agency, regulatory authorities and politicians) in the EA process. Selection will be made through consultation at different stages.
  
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  Make maximum use of existing information before engaging expensive field studies.
  
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  Cumulative impact of the project. Based on reconnaissance survey and desk study and modeling, project influence area will be finalized.
  
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  Present clear and appropriate options for mitigation of impacts and for sound environmental management. Mitigation is an integral part of impacts assessment. Application of appropriate mitigation can eliminate or reduce negative impacts, and improve the net overall environmental performance of a project. Hence public consent, practical viability will be considered in proposing the mitigation measures.
  
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  Post-EIA audits and monitoring programs are essential to ensuring that EA commitments are carried out and that future EA improve. An effective monitoring plan will be proposed in consultation with the client and the World Bank. Proper budgeting will be ensured for smooth functioning of monitoring plan proposed.
  

61. 
    Scoping will identifies which of the activities has a potential to interact with the environment. Scoping will be conducted early in the EA process so that a focus on the priority issues (i.e. those that have the greatest potential to affect the natural and/or environment) can be established for the rest of the EA process. Necessary consultation with stakeholders will be made after scoping to incorporate any unattended issues. Key elements/inputs to the scoping exercise will be as follows:
    

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  Gathering and reviewing existing environmental data like atmosphere, climate, topography, congestion area, alternative requirement, land use pattern, hydrology and drainage pattern, major river and waterways, religious, cultural and archaeological sites and sensitive areas.
  
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  Identifying project stakeholders; including PAPs, Government and non-government agencies (utilities), Bangladesh Water Development Board, Forest Department, Agricultural Department, Department of Environment (DOE) etc.
  
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  Assemble and review relevant legislative requirements, environmental standards and guidelines (national and international) associated with the proposed development as well as the World Bank‘s operational policies and standards.
  
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  Gathering existing information sources and local knowledge;
  
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  Informing stakeholders of the project and its objectives and get input on the EA;
  
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  Identifying the key environmental concerns (community and scientific) related to a project and the relative importance of issues;
  
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  Defining/preparing the EA work program, including a plan for public and stakeholder involvement;
  
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  Carrying out monitoring of natural environment including air, water, soil, noise etc.
  
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  Defining the range of project alternatives to be considered.
  
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  Obtaining agreement/consensus on the methods and techniques to be used in EA studies and document preparation;
  
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  Determining/freezing the spatial and temporal boundaries for the EA studies.
  

61. 
    Focus of scoping will be on the collection and analysis of pertinent data and the assessment of significant environmental attributes. The end result will be a work program which is well focused and cost-effective. The following issues will be addressed through scoping, but will not be limited to.
    

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  To improve the quality of EA information by focusing scientific efforts and EA analysis on truly significant issues;
  
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  To ensure environmental concerns identified and incorporated early in the project planning process, at the same time as cost and design factors are considered;
  
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  To ensure research efforts are not wasted on insignificant issues, rather focused on core issues.
  
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  Reducing the likelihood of overlooking important issues;
  
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  Thinning the chance of prolonged delays and conflicts later in the EA process by engaging stakeholders in a constructive participatory process early in the EA process.
  

61. 
    The EIA of the selected polders should be conducted following the Guideline for Environmental Assessment of Water Management Projects (WARPO, 2005) and the Environmental Assessment requirements of World Bank . After conducting IEE, the EIA should be conducted, as per TOR for EIA suggested in IEE study and approved by DOE. The process of EIA study is briefly described below.
    

1. 
   Analysis of the Project Design and Components: All the components of the CEIP and design specifications will be analyzed to get insight of the project interventions. This will guide detail environmental baseline survey and particular investigations.
   
2. 
   Data collection on Environmental and social baseline: Environmental and social baseline condition of the proposed sub-projects should be collected through several field visits, surveys and intensive consultation with local people. Detailed data on land resources, water resources, agriculture, fisheries, ecosystems and socio-economic condition should be collected. Intensive consultation with the stakeholders should be carried out to obtain their perceptions on the proposed interventions and the possible impacts.
   

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  Primary data/monitoring to define characteristics of the existing environmental condition including soil, water, air, noise, land use, cultural properties and flora and fauna.
  

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  Secondary data to define meteorological, geology, seismicity, quarries, borrow areas, disposal sites etc.
  

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  Social data including ownership pattern, identification of tribals, vulnerable social groups, land estimates etc.
  

3. 
   Project Area of Influence: At the outset of the study, the Project area of influence (or Project area for short) will be broadly demarcated. This included the area inside the polder where most of the Project interventions would take place, area immediately outside the polder embankments (this area could be used for staging of construction works, material stockpiling, and/or earth borrowing), access routes for the polder, borrow as well as spoil disposal areas if located outside the polder, and labor camps/contractor facilities if located outside the polder. The bounding water bodies on the surrounding of the river will be included in the Project Area of Influence.
   
4. 
   Scoping and bounding: Important Environmental and Social Components (IESCs), likely to be impacted directly and indirectly by the project interventions, selected at the IEE stage will be revisited for finalizing their selection based on detailed information on the proposed interventions. A bounding exercise will be carried out to delineate area likely to be impacted by polder
   
5. 
   Major Field investigations: At this stage, detailed field survey (social and environmental) will be carried out to obtain information on the possible impact of the interventions on the IESCs.
   
6. 
   Assessment of Environmental and social Impacts: The impacts of the proposed CEIP project on the environmental and social components will be identified through consultation with experts and local community. The impacts will be analyzed and graded qualitatively (e.g. high, medium, low) in order to identify the major impacts. The future-without-project (FWOP) condition will be generated through trend analysis using information collected. The future-with-project (FWIP) condition will be predicted using professional judgment of the multi-disciplinary team members based on information collected. Difference between the two (FWIP-FWOP) conditions will be taken as impact of the proposed interventions. Moreover, cumulative impacts of the project inside or outside the project area will be analyzed. Possible mitigation measures for alternatives of the project will be identified in this stage. For true impacts prediction following questionnaire will be attempted to answer:
   

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  How will a particular project activity give rise to an impact?
  
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  How likely is it that an impact will occur?
  
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  What will be the consequence of each impact?
  
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  What will be the spatial and temporal extent of each impact?
  

7. 
   Analysis of Alternatives: Since the existing structures of coastal polders will be improved under CEIP project, alternative options for designing the project interventions will be analyzed. The potential impacts of alternative design of structure will be evaluated.
   

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  With or without the project.
  
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  Analysis criteria to include environmental, social, technical/design and economic options.
  
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  Alignment options within existing positions
  
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  Suitable locations of Hydraulic Structure
  
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  Other engineering alternatives
  
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  Site and Selection of Plant Species
  

8. 
   Evaluation of impacts: Impact assessed on different IESCs will be evaluated assigning score ranging from 1 to 10 for both positive (+) and negative (-) impacts considering magnitude, immediacy, reversibility and sustainability.
   
9. 
   Preparation of environmental management plan: The EMP will be prepared suggesting mitigation measures for minimizing the effect of the negative impacts, compensation measures for the negative impacts which cannot be mitigated, enhancement measures for increasing the benefits of the positive impacts, contingency plan for taking care of natural hazards and accidental events. An environmental monitoring plan will also be suggested in the EMP. Each component of the EMP will be divided into pre-construction, during construction, post construction and operation and maintenance phases. Responsibilities of the institutions in the implementation of the EMP will be suggested to ensure efficient utilization of all the parties involved. The EMP should also include institutional capacity assessment and capacity building plan.
   
10. 
    EIA Report Preparation: All the findings would be presented in the EIA reports as per outline given in Appendix – 9. A preliminary TOR for EIA is given in Appendix – 9.
    

61. 
    “Public consultation” refers to the process by which the concerns of local affected persons and others who have plausible stake in the environmental impacts of the project or activity are ascertained with a view to taking into account all the material concerns in the project or activity design as appropriate. All Category ‘A’ projects or activities shall undertake public consultation. The key points of public consultation are given below:
    

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  Identification of primary and secondary stakeholders.
  

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  Structured Consultation
  

61. 
    After completion of the public consultation, the design consultant shall address all the material environmental concerns expressed during this process, and make appropriate changes in the draft EIA and EMP. The final EIA report, so prepared, shall be submitted by the client to the concerned regulatory authority for appraisal.