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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


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7.7Environmental Management Plan (EMP)

7.7.1Guideline Principles of EMP





  1. Efforts should be made and practiced to mitigate and minimize negative environmental impact from the project design phase of CEIP. The possible impacts from the project activities have been identified in Chapter 6 and reflected in the proposed EMP. The following EMP will be followed for the identified environmental impacts during pre-construction, construction and O&M stages due to implementation of CEIP project. The key steps of the methodology (MRDI, 2011) includes:

  • Deriving mitigation/protection measures for identified impacts for each of the Project activity and environmental component;

  • Recommend mitigation, compensation and enhancement measures for each identified impacts and risks;

  • Developing a mechanism for monitoring the proposed mitigation measures,

  • Estimating budget requirements for implementation mitigation and monitoring measures, and

  • Identifying responsibilities of various agencies involved in the Project for implementation and monitoring of mitigation measures




  1. The methodology followed for preparing the EMP is presented in Figure 7.2.






Monitoring Mechanism



Mitigation/compensation/Enhancement Measures



Institutional Framework for Implementation, supervision and operation & Maintenance







Budget for Mitigation and Monitoring










Figure 7 18 Framework for Preparation of EMP during Construction and O&M (MRDI, 2011)

The EMP should be included in all the bid documents of the Project and will become a part of the civil works contract. The strict implementation of the EMP and project management’s strict enforcement of the adequate construction practices and standards will greatly reduce the negative impacts of the Project.


7.7.2Mitigation Measures


  1. Mitigation is an integral part of impact evaluation. Where mitigation is deemed appropriate, a proponent should strive to act upon effects, in the following order of priority, to:

    • Eliminate or avoid adverse impacts, where reasonably achievable.

    • Reduce adverse impacts to the lowest reasonably achievable level.

    • Regulate adverse impacts to an acceptable level, or to an acceptable time period.

    • Create other beneficial impacts to partially or fully substitute for, or counter-balance, adverse effects.




  1. Mitigation measures should be considered starting with Environmental Assessment process. It is important therefore, that there is good integration between the EIA team and project design engineers. Project specific environmental construction guidelines should be developed. These guidelines should specify precautions and mitigation measures for construction activities, and to be included with the EMP. Good Environmental Construction guidelines has been compiled in Appendix 10.




  1. Impacts identified severe in consequence category and or likelihood category will be further analyzed to identify additional mitigation measures that are potentially available to eliminate or reduce the predicted level of impact. Potential mitigation measures will include:

    • habitat compensation program

    • species specific management program

    • engineering design solutions

    • alternative approaches and methods to achieving an activity‘s objective

    • stakeholders participation in finalizing mitigation measures

    • construction practice, including labor welfare measures.

    • operational control procedures

    • management systems




  1. Based on the past experience, a generic Mitigation Measures for EMP has been presented in Table 7.4 below for reference. This can be used as a reference material for comprehending the scope of the EMP. BWDB will be responsible for implementing the EMP with the help of Contractor and Construction Supervision Consultants. Detail responsibility of the agencies should be given in the EIA study reports.


Table 7 12 Generic Mitgation/Compensation Meaqsures/Guideline

Parameter/Activities

Mitigation/Compensation Measure/Guideline

ECoP 1: Soil/ Land Management

Sources of Material for Earthwork

  • During design the segment wise soil requirement and location of the sources of soil for earthwork for each polder construction/rehabilitation should be identified.

  • Selection of Borrow Areas for earthen material collection.

  • No objection from land owner/Revenue authorities as applicable

  • Contractor shall ensure that borrow materials used for embankment filling is free of pollutants

  • Disposal of excess soil should be done at site with no objection from DoE and local authority

Borrowing of Earth

Borrow Area Selection

Borrowing close to the toe line on any part of the embankment is prohibited. Earth available from dredging as per design, may be used as embankment material (if necessary and applicable), subject to approval of the Engineer, with respect to acceptability of material. Borrowing to be avoided on the following areas:



  • Lands close to toe line and within 0.5 km from toeline.

  • Irrigated agricultural lands (In case of necessity for borrowing from such lands, the topsoil shall be preserved in stockpiles.

  • Grazing land.

  • Lands within 1km of settlements.

  • Environmentally sensitive areas such as reserve forests, protected forests, sanctuary, wetlands. Also, a distance of 500 m should be maintained from such areas.

  • Unstable side-hills.

  • Water-bodies (only if permitted by the local authority, and with specific pre-approved redevelopment plans by the concerned authority and engineer-in-charge)

  • Streams and seepage areas.

  • Areas supporting rare plant/ animal species.


Documentation of Borrow Pit

The contractor must ensure that following data base must be documented for each identified borrow areas before commencing the borrowing activity that provide the basis of the redevelopment plan.



  • Chainage along with offset distance;

  • Area (Sq.m);

  • Photograph and plan of the borrow area from allsides;

  • Type of access/width/kutcha/pucca etc. from theroadway;

  • Soil type, Slope/drainage characteristics;

  • Water table of the area or identify from the nearest well, etc;

  • Existing land use, for example barren / agricultural /grazing land;

  • Location/name/population of the nearest settlement from borrow area;

  • Quantity excavated (likely and actual) and its use;

  • Copy of agreement with owner/government; and

  • Community facility in the vicinity of borrow pit.

  • Rehabilitation certificate from the land owner along with at least four photograph of the rehabilitated site from different angles.

Excavation operation and Management of Excavated Material

To minimize the adverse impact during excavation of material following measures are need to be undertaken:

  • Adequate drainage system shall be provided to the excavated area

  • At the stockpiling locations, the Contractor shall construct sediment barriers to prevent the erosion of excavated material due to runoff.

The followings precautions shall be undertaken during quarry operations.

  • Overburden shall be removed.

  • During excavation slopes shall be flatter than 20 degrees to prevent their sliding.

  • In case of blasting, the procedure and safety measures shall be taken as per DOE guidelines.

  • The Contractor shall ensure that all workers related safety measures shall be taken.

  • The Contractor shall ensure maintenance of crushers regularly as per manufacturer‘s recommendation.

  • During transportation of the material, measures shall be taken to minimize the generation of dust and to prevent accidents.

Handling Dredged Material from River Dredging

  • Deposition of dredged material should be away from the channel edge to limit damage to streamside habitats. This also allows a degree of flooding to occur on the floodplain, thereby creating opportunities for wet grassland, scrub/wet woodland, wetlands and seasonally grazed rough grass.

  • Where possible biotechnical engineering, for example geotextiles, may be used to help stabilize the material and aid re-colonization.

  • Other possibilities include: drying and spreading the spoil over adjacent land, which can improve soil fertility in some cases, but may also smother important flora and habitats; excavating a trench and infilling it with spoil, thus minimizing disturbance to agriculture and the local environment; dumping off-site is possible but expensive, using spoil to create artificial wetlands.

Contamination of soil by fuel and lubrication




ECoP 2: Water Resource & Hydrology Management

Hazardous Waste Management

The contractor will minimize the generation of sediment, oil and grease, excess nutrients, organic matter, litter, debris and any form of waste (particularly petroleum and chemical wastes).

Ponding of water/water logging

  • Do not allow ponding of water especially near the waste storage areas and construction camps

  • Discard all the storage containers that are capable of storing of water, after use or store them in inverted position

  • Reinstate relief and landscape

  • Monitor drainage pattern after high down pouring and recession flood

  • Connect water pockets to the nearest drainage structures/canals

Soil Erosion and siltation

The Contractor shall

  • Water the material stockpiles, access roads and bare soils on an as required basis to minimize dust. Increase the watering frequency during periods of high risk (e.g. high winds)

  • All the work sites (except permanently occupied by the road and supporting facilities) should be reinstated to its initial conditions (relief, topsoil, vegetation cover).

  • Ensure that roads used by construction vehicles are swept regularly to remove sediment

Dredging

  • Disturbance can be minimized if mechanical excavators work from one bank. If the channel is too wide, the digger must work within the channel. Disruption can be minimized by diverting the river down one side of the channel and dredging the other side while it is 'dry’. Smaller plant equipment generally limits the level of impact on bank-side and in-stream habitats.

Construction activities in water bodies

  • Protect water bodies from sediment loads by silt screen or bubble curtains or other barrier.

  • Do not discharge cement and water curing used for cement concrete directly into water courses and drainage inlets

  • Monitor the water quality in the runoff from the site or areas affected by dredge plumes, and improve work practices as necessary

ECoP 3: Air Management

Construction vehicular traffic

The Contractor should

  • Fit vehicles with appropriate exhaust systems and emission control devices. Maintain these devices in good working condition.

  • Operate the vehicles in a fuel efficient manner

  • Cover haul vehicles carrying dusty materials (cement, borrow and quarry) moving outside the construction site

  • Impose speed limits on all vehicle movement at the worksite to reduce dust emissions

  • Control the movement of construction traffic

  • Water construction materials prior to loading and transport

  • Service all vehicles regularly to minimize emissions

  • Materials will be transported to site in off peak hours.

Construction activities

  • Water the material stockpiles, access roads and bare soils on an as required basis to minimize the potential for environmental nuisance due to dust.

  • Increase the watering frequency during periods of high risk (e.g. high winds).

  • Stored materials such as excavated earth, dredged soil, gravel and sand shall be covered and confined to avoid their being wind-drifted

  • Minimize the extent and period of exposure of the bare surfaces

  • Reschedule earthwork activities or vegetation clearing activities, where practical, if necessary to avoid during periods of high wind and if visible dust is blowing off-site

  • Restore disturbed areas/side of the embankment as soon as practicable by plantation/vegetation/grass-turfing

  • Establish adequate locations for storage, mixing and loading of construction materials, in a way that dust dispersion is prevented because of such operations

  • Crushing of rocky and aggregate materials shall be wet-crushed, or performed with particle emission control systems

Odor from Construction labor Camps

  • Construction worker‘s camp shall be located at least500 m away from the nearest habitation.

  • The waste disposal and sewerage system for the camp shall be properly designed, built and operated so that no odor is generated.

ECoP 3: Agriculture Management

Loss of Top Soil

  • Soil from fallow lands/ non-agricultural lands should be used in earthwork in embankments

  • Collect/strip top soil before earth filling and store and reuse it for final surfacing of embankment top and tree plantation/afforestation.

  • Strip the top soil to a depth of 15 cm and store in stock piles of height not exceeding 2m

  • Remove unwanted materials from top soil like grass, roots of trees and similar others

  • The stockpiles will be done in slopes of 2:1 to reduce surface runoff and enhance percolation through the mass of stored soil

  • Locate topsoil stockpiles in areas outside drainage lines and protect from erosion

  • Spread the topsoil to maintain the physico-chemical and biological activity of the soil.

  • The stored top soil will be utilized for covering all disturbed area and along the proposed plantation sites

  • Topsoil stockpiles will be monitored and should any adverse conditions be identified corrective actions will include:

o Anaerobic conditions-turning the stockpile or creating ventilation holes through the stockpile;

o Erosion – temporary protective silt fencing will be erected;



Soil salinity

  • Use of duckweed will remove soil salinity

  • Flushing with pre-monsoon rain water will reduce soil salinity.

  • Saline tolerant crops need to be cultivated.

  • Environmentally and socially responsive shrimp farming e.g. shrimp-rice farming system is encouraged.

  • Increasing upland discharge of fresh water will push back ingress of saline water from the sea

  • Green manure application is promoted

  • Ground water abstraction for shrimp farming should be avoided.

ECoP 4: Noise Management

Construction vehicular traffic

  • Maintain all vehicles in order to keep it in good working order in accordance with manufactures maintenance procedures

  • Organize the loading and unloading of trucks, and handling operations for the purpose of minimizing construction noise at the work site.

Construction machinery

  • Appropriately site all noise generating activities to avoid noise pollution to local residents

  • Maintain all equipment in order to keep it in good working order in accordance with manufactures maintenance procedures.

Construction activity

  • Notify adjacent landholders/Schools prior any typical noise events outside of daylight hours

  • Employ best available work practices on-site to minimize occupational noise levels

  • Install temporary noise control barriers where appropriate

  • 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 working during 09:00pm to 06:00 am within 500m from residences.

ECoP 5: Ecology Management

Flora

Vegetation Clearance

  • Tree felling should be performed upon preliminary notification to the relevant authority (District Forest Office, DoE).

  • Preparation of maps in GIS format, cadastral description of trees to be felled, marking, and supervision of Forest Department are necessary elements of the procedure.

  • Provide adequate knowledge to the workers regarding nature protection and the need of avoid felling trees during construction

  • Fruit and timber trees owned by local population will be compensated at their replacement cost according to market prices

Plant Management

  • Tree seedlings are planted in a way that minimizes damage to the soil, while facilitating seedling survival. Tree seedling species are selected appropriate for maintaining long-term productivity.

  • Focus on tree species suitable for site condition

  • Prevent unreasonable species resulting in slow growth, less water and soil conservation and pest or disease outbreaks

  • Local species as planting materials, since natural selection and succession are most suitable for local climates and natural conditions

  • Ensure avoid single species or clone monoculture

  • Choose suitable species for berm, turfing and side

Planting

  • Leave set back requirements around streams, restricted areas e.g. native vegetation, protected riparian strips, historic and heritage sites, research areas.

  • For nursery raising, physical and biological controls are practiced to control the pests and diseases in the nurseries.

  • Do not plant spread-prone species on sites where there is a high risk of uncontrollable wilding spread beyond the boundaries of the plantation.

  • Consider appropriate species, patterns and layout when planting areas with high visual values and/or with important recreational values

Polypropylene Bags Handling

  • Make a Borrow Pit at each site for collection of poly bags

  • Collect all bags at the pits after plantation

  • If feasible, inform private sector to collect those bag for recycling

Pest Management to Nursery

  • During outbreak of any deadly plant disease develop a plan to manage pest in coordination with neighbors by identifying existing pests and diseases and the risks for the introduction of new pests and diseases.

  • Share the plan with Bank before application.

Water Management

  • Install temporary sediment basins, where appropriate, to capture sediment-laden run-off from nursery

  • Divert runoff from undisturbed areas around the harvesting site

  • Stockpile of fertilizer or agrichemical away from drainage lines

  • Prevent all solid and liquid wastes entering waterways by collecting solid waste, oils, chemicals, fertilizer waste and transport to an approved waste disposal site

Fauna




Construction works in

the surrounding lands



  • Pre-entry survey and prevention of damage to fauna prior to start up

  • Limit the construction works within the designated sites allocated to the contractors

  • Not be permitted to destruct active nests or eggs of migratory birds

  • Provide adequate knowledge to the workers regarding protection of flora and fauna, and relevant government regulations and punishments for illegal poaching.

ECoP 6: Fisheries Management

Construction works in the rivers and on

the surrounding lands



  • Critical breeding areas of major fish species should be identified and declared as sanctuaries.

  • Creation of small lagoons and pools that may trap the fishes will be avoided.

  • Creation of artificial waterfalls and other barriers for migration will be avoided.

  • Natural river channel will be reinstated after completion of construction works

Hydraulic Structure

  • Sufficient free flow will be guaranteed in the design and construction work to ensure free pass of migrating fishes.

  • Hydraulic structure will be operated considering fish migration and spawning time

  • A guideline for area specific hydraulic structure operation guideline should be developed

Dredging

  • Ensure dredging activity will create minimum sediment load in the water

  • Avoid dredging during spawning period of fish

ECoP 7: Socio-Economic Management

Construction Camp Management

Siting and Location of construction

Camps (MRDI, 2011)



  • Locate the construction camps at areas which are acceptable from environmental, cultural or social point of view.

  • Consider the location of construction camps away from communities in order to avoid social conflict in using the natural resources such as water or to avoid the possible adverse impacts of the construction camps on the surrounding communities.

  • BWDB should endorse detailed layout plan for the development of the construction camp submitted by the contractor. The plan should show the relative locations of all temporary buildings and facilities that are to be constructed together with the location of site roads, fuel storage areas (for use in power supply generators), solid waste management and dumping locations, and drainage facilities, prior to the development of the construction camps.

  • Local authorities responsible for health, religious and security shall be duly informed on the set up of camp facilities so as to maintain effective surveillance over public health, social and security matters

Construction Camp Facilities

The following facilities should be provided by the contractor

  • Adequate housing for all workers

  • Safe and reliable water supply

  • Hygienic sanitary facilities and sewerage system.

  • Treatment facilities for sewerage of toilet and domestic wastes

  • Storm water drainage facilities

  • Provide in-house community/common entertainment facilities, dependence of local entertainment outlets by the construction camps to be discouraged/prohibited to the extent possible.

Solid Waste Management

  • Ensure proper collection and disposal of solid wastes within the construction camps

  • Store inorganic wastes in a safe place within the household and clear organic wastes on daily basis to waste collector.

  • Establish waste collection, transportation and disposal systems with the manpower and equipment/vehicles needed.

  • Do not establish site specific landfill sites. All solid waste will be collected and removed from the work camps and disposed in approved disposal sites

Fuel supplies for cooking and heating

purposes


  • Provide fuel to the construction camps for their domestic purpose, in order to discourage them to use fuel wood or other biomass.

  • Conduct awareness campaigns to educate workers to protect the biodiversity and wildlife of the project area, and relevant government regulations and punishments on wildlife protection.

Health and Hygiene

  • Provide adequate health care facilities within construction sites

  • Provide first aid facility round the clock. Maintain stock of medicines in the facility

  • Provide ambulance facility for the laborers during emergency to be transported to nearest hospitals.

  • Initial health screening of the laborers coming from outside areas

  • Train all construction workers in basic sanitation and health care issues and safety 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 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 monsoon.

  • Carryout short training sessions on best hygiene practices to be mandatorily participated by all workers.

  • Place display boards at strategic locations within the camps containing messages on best hygienic practices

Payment of Wages

  • The payment of wages should be as per the Minimum Wages Act, Department of Labor, and Government of Bangladesh for both male and female workers.

  • Display of the minimum wages board at camps and major construction sites should be done in local languages at the construction and labor camp sites.

  • Wages should be paid to the laborers only in the presence of BWDB staff;

  • Contractor is required to maintain register for payment of labor wages with entry of every labor working for him. Also, he has to produce it for verification if and when asked by the Engineer, EMUand/or the concerned BWDB staff/Engineer‘s representative

Rehabilitation of Labor and Construction Camp

At the completion of construction, all construction camp facilities shall be dismantled and removed from the site. The site shall be restored to a condition in no way inferior to the condition prior to commencement of the works.

Various activities to be carried out for site rehabilitation include:



  • Oil and fuel contaminated soil shall be removed and transported and buried in waste disposal areas.

  • Soak pits, septic tanks shall be covered and effectively sealed off.

  • Debris (rejected material) should be disposed of suitably.

  • Underground water tank in a barren/non-agricultural land can be covered. However, in an agricultural land, the tank shall be removed.

  • If the construction camp site is on an agricultural land, preserve top soil and good earth can be spread back for a minimum 30cm for faster rejuvenation of the land.

  • Proper documentation of rehabilitation site is necessary.

This shall include the following:

    • Photograph of rehabilitated site;

    • Land owner consent letter for satisfaction in measures taken for rehabilitation of site; and

    • Undertaking from contractor;

In cases, where the construction camps site is located on a private land holding, the contractor would still have to restore the campsite as per this guideline. The rehabilitation is mandatory and should be include in the agreement with the landowner by the contractor. Also, he would have to obtain a certificate for satisfaction from the landowner.

Damage and Loss of Cultural Properties

Conservation of Religious Structures and Shrines

  • All necessary and adequate care shall be taken to minimize impact on cultural properties which includes cultural sites and remains, places of worship including temples, mosques, churches and shrines, etc., graveyards, monuments and any other important structures as identified during design and all properties / sites / remains notified. No work shall spillover to these properties and premises. The design options for cultural property relocation and enhancement need to be prepared.

  • All conservation and protection measures will be taken up as per design. Access to such properties from the road shall be maintained clear and clean.




  • During earth excavation, if any property is unearthed and seems to be culturally significant or likely to have archaeological significance, the same shall be intimated to the Engineer. Work shall be suspended until further orders from the PD. The Archaeological Department shall be intimated of the chance find and the Engineer shall carry out a join inspection with the department. Actions as appropriate shall be intimated to the Contractor along with the probable date for resuming the work.

  • All fossils, coins, articles of value of antiquity and structures and other remains or things of geological or archaeological interest discovered on the site shall be the property of the Government, and shall be dealt with as per provisions of the relevant legislation.

Worker’s Accident Risk

Risk from Operations

  • The Contractor is required to comply with all the precautions as required for the safety of the workmen as per the International Labor Organization(ILO) convention. The contractor shall supply all necessary safety appliances such as safety goggles, helmets, masks, books, etc., to the workers and staff. The contractor has to comply with all regulation regarding safe scaffolding, ladders, working platforms, gangway, stairwells, excavations, trenches and safe means of entry and outlet.

Risk from Electrical Equipment

  • Adequate precautions will be taken to prevent danger from electrical equipment. No materials on any of the sites will be so stacked or placed as to cause danger or inconvenience to any person or the public. All necessary fencing and lights will be provided to protect the public. All machines to be used in the construction will conform to the relevant Bangladesh Standards (BS) codes, will be free from patent defect, will be kept in good working order, will be regularly inspected and properly maintained as per BS provisions and to the satisfaction of the Engineer.

Risk from Hazardous Activity

  • All workers employed on mixing material, cement, lime mortars, concrete etc., will be provided with protective footwear and protective goggles. Workers, who are engaged in welding works, would be provided with welder's protective eye-shields. Stone-breakers will be provided with protective goggles and clothing and will be seated at sufficiently safe intervals.

Malarial Risk

  • The Contractor shall, at his own expense, conform to all anti-malarial instructions given to him by the Engineer and the EMU, including filling up any borrow pits which may have been dug by him.

Disruption to Users

Loss of Access

  • At all times, the Contractor shall provide safe and convenient passage for vehicles, pedestrians and livestock. Work that affects the use of existing accesses shall not be undertaken without providing adequate provisions to the prior satisfaction of the Engineer.

  • The works shall not interfere unnecessarily or improperly with the convenience of public or the access to, use and occupation of public or private roads, and any other access footpaths to or of properties whether public or private.

Traffic Management

  • Special consideration shall be given in the preparation of the traffic control plan to the safety of pedestrians and workers at night

  • The temporary traffic detours in settlement area shall be kept free of dust by frequent application of water

Traffic Control and Safety

  • The Contractor shall take all necessary measures for the safety of traffic during construction and provide, erect and maintain such barricades, including signs, markings, flags, lights and flagmen as may be required by the Engineer for the information and protection of traffic approaching or passing through the cross section.



7.7.3Monitoring Plan


  1. Extensive monitoring of the environmental concerns of the CEIP project will be required as per World Bank guideline. The monitoring program will help to evaluate: (i) the extent and severity of the environmental impacts against the predicted impacts and baseline; (ii) the performance of the environmental protection measures or compliance with pertinent rules and regulations; (iii) trends in impacts; and (iv) overall effectiveness of the project environmental protection measures. The monitoring plans should be included in the EMP for specific sub-projects. Moreover, for all type of monitoring, a comprehensive database of the polder specific Environmental Impact and Monitoring information should be created, which will help to evaluate the impacts easily.




  1. The Monitoring activities during design/preconstruction period are:

(i) checking the contractor’s bidding documents, particularly to ensure that all necessary environmental requirements have been included; and

(ii) checking that the contract documents’ references to environmental mitigation measures requirements have been incorporated as part of contractor’s assignment and making sure that any advance works are carried out in good time.




  1. Construction environmental monitoring is a function of supervision, and the essential purpose is to ensure adherence to the EMP. The monitoring is a daily process, which ensures that departures from the EMP are avoided or quickly rectified, or that any unforeseen impacts are quickly discovered and remedied.




  1. Post monitoring evaluation will be carried to evaluate the impacts of the Project during first three (3) years of operation of the Project. Regular monitoring of the condition of the embankment, drainage structures and slope protection structures and afforestation are important from an environmental management point of view. In addition to this activity, information on the locations, type and consequences of flooding, erosion, flora and fauna mortality, availability of fish, occupational shift, migration is required. Recommended air, noise and water quality monitoring, greening and landscaping and community feedback are also included in the Monitoring Plan. The monitoring plan and details of monitoring locations for environmental condition indicators of the project during the construction and operation stage are presented in Table 7.5 and Table 7.6



Table 7 13 Environmental Monitoring Plan during Construction and Operation of Rehabilitation and Improvement of Polders System

(Source: MRDI, 2011, LGED, 2011)



Parameter

Location

Means of Monitoring

Frequency

Responsible Agency

Implemented by

Supervised by

During Construction

Sources of Material

Work Site

Possession of official approval or valid operating license of suppliers materials

(Cement, soil).



Before an agreement for the supply of material is finalized.

Contractor

CS, M&E Consultant, BWDB

Operation of borrow site

Borrow pit/site

Visual inspection of borrow site

monthly

Contractor

CS, M&E Consultant, BWDB

Top Soil

Storage area

Top soil of 0.15 m depth should be excavated and stored properly

Beginning of earthwork

Contractor

CS, BWDB




do

The stored top soils should be used as cladding material over the filled lands

Immediately

after filling and

compaction of dredge materials


Contractor

CS, BWDB




Work Site

Some of the top soil are placed on top and berm of embankment for turfing and plantation

At the end of

filling activity



Contractor

CS, BWDB

Erosion

Side slopes of the embankments and material storage sites

Visual inspection of erosion prevention

measures and occurrence of erosion



At the end of filling activity

Contractor

CS, M&E Consultant, BWDB

Hydrocarbon and chemical storage

Construction camps


Visual Inspection of storage facilities

Monthly

Contractor

CS, BWDB

Traffic safety

Construction area

Visual inspection to see whether proper traffic signs are placed and flagmen for traffic management are engaged

Monthly

Contractor

CS, BWDB

Air quality (dust)

Construction site

Visual inspection to ensure good standard equipment is in use and dust suppression measures (spraying of waters) are in place.

Daily

Contractor

CS, BWDB




Material storage

sites



Visual inspection to ensure dust suppression work plan is being

implemented




Monthly

Contractor

CS

Air Quality (PM10, PM2.5)

Close to School/ Madrasha, Hospital & Villages

Air quality monitoring


Half Yearly

Contractor through a nationally recognized laboratory

CS, M&E Consultant, BWDB

Noise


Construction sites

Visual inspection to ensure good standard equipment are in use

Weekly


Contractor

CS, M&E Consultant, BWDB




Construction sites

Ensure work restriction between 09:00 pm- 6:00 am close to School/ Madrasha, Hospital & Villages

Weekly

Contractor

CS, M&E Consultant, BWDB

Surface Water Quality (TDS, Turbidity, pH, DO, BOD, COD etc)

Water sample at each of river for each polder

Sampling and analysis of surface water

quality


Half Yearly

Contractor through a nationally recognized laboratory

CS, M&E Consultant, BWDB

Drinking Water Quality (TDS, Turbidity, pH, FC, as if groundwater etc)

Sources of drinking water at construction camp/site

Sampling and analysis of water quality

yearly

Contractor through a nationally recognized laboratory


CS, M&E Consultant, BWDB

Sanitation

Construction camp/site

Visual Inspection

Weekly

Contractor

CS, M&E Consultant, BWDB

Waste Management

Construction camp and construction site

Visual inspection of collection, transportation and disposal of solid waste and solid waste is deposited at designated site

Weekly

Contractor

CS, M&E Consultant, BWDB

Flora and Fauna

Project area

Survey and comparison with baseline environment

Yearly

Contractor through nationally recognized institute

CS, M&E Consultant, BWDB

Cultural and

archeological Sites



At al l work sties


Visual observation for chance finding


Daily


Contractor


CS, M&E Consultant, BWDB

Reinstatement of Work Sites


All Work Sites


Visual Inspection

After completion of all works

Contractor


CS, M&E Consultant, BWDB

Safety of workers Monitoring and reporting accidents

At work sites

Usage of Personal Protective equipment

Monthly

Contractor

CS, M&E Consultant, BWDB

During Operation and Maintenance

Surface Water Quality (TDS, Turbidity, pH, DO, BOD, COD etc)

Water sample at each of river for each polder

Sampling and analysis of surface water quality

Yearly

BWDB through a nationally recognized laboratory


M&E Consultant

Air Quality (Dust PM10, PM2.5)

At the baseline monitoring site

24 hours Air quality monitoring


Yearly

BWDB through a nationally recognized laboratory

M&E Consultant

Flora and Fauna specially fisheries

In the project area

Detail species assessment and compare with baseline

Yearly

BWDB through a nationally recognized institution

M&E Consultant

Agriculture

In the project area

Compare the production with the baseline

Yearly

BWDB through a nationally recognized institution

M&E Consultant

Operation of hydraulic structure

In the project area

Visual inspection and public feedback

Yearly

BWDB


M&E Consultant


Table 7 14 Environmental Monitoring Plan during Construction and Operation of Afforestation


Parameter

Location

Means of Monitoring

Frequency

Responsible Agency

Implemented by

Supervised by

During Implementation

Plant Selection

Nursery

Visual inspection. Type and variety of plant species to be planted for turfing on the top of embankment and foreshore

Before plantation

Contractor

CS, BWDB, M&E Consultant

Water Quality

Water bodies near nursery

Odor and chemical testing

Half yearly

Contractor through nationally recognized laboratory

CS, BWDB, M&E Consultant

Waste Management

Work site and Nursery

Visual inspection of

collection, transportation and disposal of grasses, debris and is deposited at designated site



Weekly

Contractor

CS, BWDB, M&E Consultant




Work site and Nursery

Visual inspection of

Water bars & cut-offs .sediment traps to prevent water pollution caused by run-off from harvesting areas



Beginning of work

Contractor

CS, BWDB, M&E Consultant

Nursery Embankment Management

Nursery

Visual inspection of height of embankment, possibility of water logging and connection to the waterbodies

Beginning of each nursery

Contractor

CS, BWDB, M&E Consultant

During Operation and Management




Multilevel belt of trees

Polder top and along the polder

Visual inspection

yearly

BWDB through nationally recognized institution

M&E Consultant

Flora and Fauna

In the project area

Detail species assessment and compare with baseline

Yearly

BWDB through a nationally recognized

institution



M&E Consultant

Erosion

Along Alignment

Visual Inspection presence of gullies or erosion

Yearly

BWDB


M&E Consultant




  1. In addition to the critical locations selected during design stage, the environmental monitoring will also be done at the construction camp site and any other plant site during construction stage. List of critical locations for caring out monitoring should be presented in the IEE/EIA report

7.7.4Qualitative Spot Checking Indicators


  1. Moreover a rapid environmental monitoring will be carried out according the following checklist in terms of visual judgment during field visit as an indirect control to implement Environmental Mitigation plan.

Table 7 15 Spot Checking Indicator


Parameter

Visual Judgment

Poor

Moderate

Satisfactory

Workers Safety










Camp Site Management













Plant Site Management













Borrow Area Management













Top Soil Prevention













Waste Management













Reporting and Documentation












7.7.5Implementation of EMP & Report Requirement


  1. Contractor is responsible for implementation of EMP during construction works and Construction Supervision Consultant (CS) is primarily responsible for supervision of the implementation of the EMP.




  1. BWDB will conduct field inspections and surveys by the environment specialist (to be employed by BWDB on regular basis) at field. S/he will report to the Senior Environment Specialist at Head Quarter.




  1. The M&E consultant will be responsible for independent monitoring and implementation of EMP, and external monitoring and evaluation.




  1. DoE will be consulted if complicated issues arise during construction and operation stages. BWDB will apply for annual site clearance from DoE.




  1. BWDB will prepare the half yearly progress report on environmental management and will submit to the World Bank for review.




  1. The World Bank will review the screening report, environmental management plan, monitoring reports on random basis and will carry out field visit to cross-check. The contributing development partners may also join in the field visit to understand the environmental compliance of the project.




  1. Moreover, for all type of monitoring, a comprehensive database of the polder specific Environmental Impact and Monitoring information should be created, which will help to evaluate the impacts easily. The data base will be incorporated with the mainstream BWDB MIS. Environment, Social and Communication (ESC) unit will be responsible for updating the database for environmental information.




  1. Water Management organizations (WMO) will be formed under the Bangladesh Guidelines for Participatory Water Management (Nov 2000) and involve the beneficiary communities. WMOs will be trained by BWDB to ensure environmental management during project operation. Environmental Management Unit of BWDB will ensure and oversee the environmental management during project implementation and operation.




  1. In addition, the effectiveness of screening, monitoring and implementation of EMP will be carried out by the third party monitoring firm along with the project component activity monitoring annually. The Annual Environmental Audit Report prepared by the third party monitoring firm will be shared with World Bank.



7.7.6Guideline to Incorporate Environmental Management in Bid Document


  • Prepare cost estimates, to be incorporate in Bid Documents.

  • Environmental Management Plan along with the good environmental construction guidelines to be incorporated in the bid document‘s work requirements.

  • Preparation of work requirement (addendum/corrigendum to polder & hydraulic structure construction/afforestation) and

  • Corrigendum / Addendum to polder/embankment specification, if any, as special provisions to be incorporated in bid document.

  • Penalty clauses for not complying with EMP requirements to be incorporated. Indicative penalty clauses proposed in the CEIP are presented below (Addendum to Clause 17.2 Contractor‘s Care of the Works of FIDIC).

    • The contractor has to follow all traffic safety measures as defined in the technical specification. Damage shall be levied at the rate Tk. 3000/- per day per location for non – conformity of traffic safety measures as per the decision of the engineer.

    • The contractor has to follow all environmental mitigation measures as defined in the technical specification read along with the Environmental Management Plan for the specific CEIP activities. Damage shall be levied at the rate Tk. 3000/- per day per location for nonconformity of Environmental Management Plan measures as per the decision of the BWDB Engineer.

    • The contractor has to ensure that prior to every monsoon season, during the construction period; all the temporary and permanent cross drainage structures are free from debris as defined in the Technical Specifications read along with the Environmental Management Plan. Damage shall be levied at the rate of Tk.3000/- per day per location for non-conformity as per the decision of the Engineer.

    • The contractor has to ensure that sufficient numbers and good quality Personnel Protective Equipment (PPE), should be provide to staff and labor all time as defined in the labor codes read along with the EMP. Damage shall be levied at the rate of Tk. 1000/- per day for non-conformity as per the decision of the Engineer.




  • Since many contractors do not have clear understanding the need of environmental management, some quoted very low price for implementation of EMP and eventually cannot implement EMP as per design. To avoid this problem, Fixed Budget will be assigned for EMP implementation. The contractors may need orientation on the requirement of the EMP in the pre-bidding meeting. The contractor needs to submit an Environmental Action Plan (EAP) based on the EIA and EMF in line with the construction schedule and guideline. The EAP needs to be reviewed by the supervision consultant and cleared by BWDB and World Bank.

7.7.7Guideline for Compensation and Contingency Plan during Project Period


  1. Compensation becomes necessary when project impacts cannot be satisfactorily mitigated. This can be paid in cash or kind and the emphasis should be on ensuring fairness and causing minimum inconvenience to the affected party. The most common cause of compensation payment is displacement of people and loss of productive land due to land acquisition, tree cutting, or property damage. Such impacts can rarely be fully compensated. The compensation should be given as per provision of the Resettlement Action Framework. Any disputes over the compensation should be handles by the Grievance Redress Committee.




  1. In addition to the compensation, water management projects should also have a contingency plan to deal with emergencies and accidents. Such incidences encompass a whole range of situations from personal injury during operation of a machine to breaching of an embankment. Therefore, BWDB would prepare for the following emergency situations:

  • Embankment failure during a flood – keep sufficient number of sand bags in reserve.

  • Bank caving/erosion – keep sufficient number of concrete blocks and sand bags in reserve.

  • Have an emergency evacuation plan for the people in the line of danger.

  • Have a place designated as emergency shelter and ensure proper water supply, power supply and sanitation at this site.

  • Accidental spill of pesticide or similar harmful chemicals – train some members on how to confine such a spill and minimize potential danger to humans and other animals.

  • Fire – keep fire extinguisher or emergency water pump ready at local project office.

  • Personal injury – keep a first aid box at the project office. Have a plan for quickly transporting a seriously injured person to the nearest hospital.



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