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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List of FiguresFigure 1 1: Methodology of EMF 3 Figure 3 2: Process of obtaining Clearance certificate from DoE 22 Figure 4 3: Polders in Coastal area of Bangladesh 26 Figure 4 4: Land Use Map of Coastal Area 28 Figure 4 5: Historical water level in major rivers in coastal zone of Bangladesh 29 Figure 4 6: Agricultural Landuse Pattern in Coastal Area 34 Figure 4 7: Coastal fish habitats 36 Figure 4 8: Important fish species in coastal region 36 Figure 4 9 Damaged Coastal Polder 35/1 near Rayenda along Baleswar due to Sidr 39 Figure 4 10: Water logging affected areas in coastal zone 40 Figure 4 11: Soil salinity (dS/m) in coastal area of Bangladesh in 2009 42 Figure 4 12: Surface water salinity (dS/m, maximum in January 2010) distribution in coastal area 43 Figure 4 13: Groundwater Studies of Arsenic Contamination in Bangladesh (DPHE/BGS/DFID, 2000) 44 Figure 5 14: Overtopped Polders in Coastal Area Under Different Scenarios (World Bank, 2010) 48 Figure 5 15: Salinity Condition In Coastal Area (for 2005 and 2050) 48 Figure 5 16: Existing Alignment of Polder 35/1 at Khuolia 51 Figure 7 17 Diagram: Environmental Assessment Process 75 Figure 7 18 Framework for Preparation of EMP during Construction and O&M (MRDI, 2011) 86 Figure 7 19 GRM Process Flow Chart 104 Figure 8 20 BWDB Institutional Arrangement for CEIP Implementation 106 Abbreviations and AcronymsBWDB Bangladesh Water Development Board CCP Chittagong Coastal Plain CEGIS Center for Environmental and Geographic Information Services CEIP Coastal Embankment Improvement Project DPM Design Planning & Management Consultants ECA Environmental Conservation Act ECR Environmental Conservation Rules ECRRP Emergency 2007 Cyclone Recovery and Restoration project EIA Environmental Impact Assessment EMF Environmental Management Framework EMP Environmental Management Plan ES Environmental Screening ESC Environment, Social and Communication unit GTPE Ganges Tidal Plain East GTPW Ganges Tidal Plain West HYV High Yielding Variety IEE Initial Environmental Examination IESCs Important Environmental and Social Components KJDRP Khulna-Jessore Drainage Rehabilitation Project LLP Low Lift Pump MDP Meghna Deltaic Plain MT Metric Ton PCD Project Concept Document PIC Project Implementation Consultant PID Project Information Document SEA Strategic Environmental Assessment SLR Sea Level Rise SWT Sallow Tube well TOR Terms of Reference UNFCCC United Nations Framework Convention on Climate Change UNESCO United Nations Educational, Scientific and Cultural Organization WMIP Water Management Improvement Project Executive SummaryIntroduction Bangladesh is a hydraulic civilization situated at the confluence of three great trans-Himalayan rivers—the Ganges, the Brahmaputra (or Jamuna), and the Meghna (GBM). The GBM river system marks both the physiography of the nation, as well as the culture and livelihood of the people. While over 90 percent of the GBM catchment lies outside of Bangladesh, approximately 200 rivers and tributaries of the GBM drains through the country via a constantly changing network of estuaries, tidal inlets, and tidal creeks, before emptying out into the Bay of Bengal1. Thus, the coastal zone of Bangladesh, the lowest landmass of the country, is continually influenced by these Himalayan drainage ecosystems. Figure 1 shows the coastal area of the country. 
Figure E.1: Coastal Area of the Country Primarily, the coastal embankment system brought immense benefits to the people living along low lying areas. The system was designed originally to protect against the highest tides, without much attention to storm surges. Recent cyclones brought substantial damage to the embankments and further threatened the integrity of the coastal polders. In addition to breaching of the embankment due to cyclones, siltation of peripheral rivers surrounding the embankment caused the coastal polders to suffer from water logging, which lead to large scale environmental, social and economical degradation. Poor maintenance and inadequate management of the polders have also contributed to internal drainage congestion and heavy external siltation. As a result, in some areas (e.g. Satkhira, Khulna, Bagerhat districts) soil fertility and good agriculture production are declining because of water logging and salinity increase inside polders. 
Figure E.2: Coastal Polder Map of Bangladesh Given that most polders have been built during the 1960’s, which were damaged by cyclone Sidr (2007) and Aila (2009), the entire embankment system needs to be upgraded to protect vulnerable community from tidal inundation, drainage congestion, storm surge and salinity intrusion. The long term objective is to increase the resilience of the entire coastal population to tidal flooding and natural disasters by upgrading the whole embankment system. With an existing network of embankment of nearly 6,000 km long with 139 polders, the magnitude of such a project is enormous. Hence a multi-phased approached will be adopted over a period of 15 to 20 years. The proposed Coastal Embankment Improvement Project –Phase 1 (or CEIP-I) is the first phase of this long term program. A strategic polder assessment was undertaken and a multi criteria analysis was developed to guide the gradual selection of polders. The key criteria are: physical condition of the embankment and the drainage system, economic activities in the polders (agriculture or fishery), population and socio economic conditions, environmental condition and economic efficiency considerations. Based on this assessment a first priority group of 17 polders was selected. Among the seventeen, 4 will be considered for the first package of investment. Environmental Management Framework (EMF): The proposed interventions of CEIP project will have significant impacts on the natural environment and the people living in that area. Proper environmental assessment and environmental management plan are essential to address the impacts of the project. This Environmental Management Framework (EMF) has been developed to ensure that neither the project activities (both in terms of needs and quality) nor the environment is compromised through the program intervention This document will also provide a framework for screening, identification, assessing, evaluating and mitigating the environmental risks emerging from work on Polders. The EMF presents possible impacts of the CEIP-1, mitigation, enhancement, contingency and compensation measures, environmental management and monitoring plan, and institutional framework including inter-agency cooperation for implementing EMP. The EMF will facilitate compliance with the World Bank’s environmental safeguard policies and with the Government of Bangladesh’s policies, acts and rules. The EMF will provide guideline to the implementing agency to prepare a site specific EA/EMP for doing the following items to ensure environmental sustainability by:
The implementing agency BWDB prepared The ‘Environmental Management Framework (EMF)’ by following five major steps (a) Reviewing policies, regulations and administrative frameworks; (b) Reviewing information on the polders and consultation with stakeholders; (c) Developing a Screening Matrix for identifying Important Environmental Component (IEC) and assessing impacts; (d) Developing guidelines for preparing sub-project specific environmental management plan; and (e) Identifying of assessment criteria for strengthening institutional capacity for EMP implementation as well as mechanism for inter-agency co-ordination. Project Description The project will comprise the following components. Component A – Rehabilitation and Improvement of Polders ($291 million). Component A1: Rehabilitation and Improvement of Polder ($286 million). This component will finance activities that aim to increase community resilience to tidal flooding and storm surges. Investments include: (i) rehabilitation of critical portions of polder embankments including slope protection work, (ii) increasing embankment height in some stretches to improve resilience, (iii) repairing and upgrading drainage and flushing systems within polders, and (v) improving operations and maintenance (O&M). The reconstruction and rehabilitation works will be designed with improved standards so that protection is for both tidal flooding and frequent storm surges. It is expected that about 17 polders will be rehabilitated under this component. The final polder selection will depend on technical, environmental and social conditions. Stakeholders and beneficiaries consultations and participation would be central to carrying out the improvement works to the polder system. The beneficiaries, through their formal and informal water management organizations (WMOs), will be involved in all stages of project implementation from identification of works, prioritization, design, and construction. Consultations will be carried out by the consultants and NGOs with support from the BWDB under component B1. Improving the embankment system will provide stronger protection to people living inside polders from storm surges; hence reducing the recovery time after a natural disaster such as a cyclone. Improving the internal drainage system will enhance agriculture production, which is the primary source of livelihood for coastal population. Protecting assets and enhancing agricultural production will bring in much needed economic growth to the coastal population. Component A2: Afforestation ($5 million). Afforestation is critical to the security of embankment. Planting of selected mangrove and other salt tolerant species are planned as a protective belt on the tidal inundation zone on the riverside of the embankment. Planting of a range of commercial wood, fruit and other tree species in phase with livelihoods needs of landless, marginalized and poor villagers are proposed on the inside of embankments. Plantings would commence after clarification of land-use and land ownership issues and the completion of earthworks in restored embankments. The afforestation component will engage community participation in pro-poor approaches to encourage ownership and benefit sharing in an attempt to achieve social, environmental and economic sustainability. The component will finance efforts to build capacity of local government institutions, Water Management Organization, NGOs and community organizations in secondary maintenance schemes for improved O&M, foreshore and embankment afforestation and protection of embankment toe against erosion. Component B–Implementation of Social Action and Environment Management Plans (US$56 million). Component B1: Implementation of Social Action Plan (US$3 million). This component will support consultation with and strengthening of polders’ stakeholders and beneficiaries as well as formal and informal water management organization (like water management groups, water management associations and embankment management groups). Under this component, intensive social mobilization will be piloted in 6 polders to establish participatory WMOs that will be responsible for the operation and minor maintenance works of the polders. The establishment of WMOs will follow an eight step process, as identified in the Guidelines for Integrated Planning for Sustainable Water Resources Management, published by BWDB in 2008. Social mobilization is expected to last around two years, during which time the WMOs will be established and trained in participatory planning, as well as in operation and minor maintenance activities. It is expected that the detailed design of the polders identified under the pilot scheme will engage in a participatory planning exercise with BWDB in the identification of civil works, and that construction activities will be supported by local community members, where possible. Finally, small works, including minor periodic maintenance and operation of minor hydraulic infrastructure would be undertaken by the WMOs under a memorandum of understanding with BWDB. In the remaining polders, Polder Committee(s) will be established to determine the competing needs and uses for water resources, and to decide on the operation of hydraulic infrastructure. Should the participatory approach prove to be successful, it would be scaled up under the next phase of investments. Technical assistance will be provided to local NGOs executing the social mobilization for this sub component. It will also support the implementation of social action plan identified during the consultative, design and implementation phases. Component B2: Implementation of Resettlement Action Plans (US$49 million). Polder scheme rehabilitation is a complex project that involves a variety of issues ranging from land acquisition, physical and economic displacement of people and other unanticipated impacts. Generally there are squatters on the embankments as they are safe structures. A Social Management and Resettlement Policy Framework (SMRPF) has been prepared and will be disclosed in accordance with Bank guidelines. This component will finance the implementation of the Resettlement Action Plans (RAP), embankment monitoring and public consultation plans. The component will finance the resettlement and rehabilitation of persons adversely affected by the project. It will also support the development of a system to computerize land acquisition and resettlement data with Global Position System (GPS) reference and independent institute to undertake surveys and verify field data in order to guard against improper targeting of beneficiaries and/or false delivery of benefits in case of SAP/RAP. Component B3. Implementation of Environment Management Plan (US$4 million). An overall environmental assessment of the polder system; an Environmental Management Framework (EMF) for the project; and Environment Impact Assessment (EIA) for polders targeted under the first package of investment have already been prepared. This component will finance: (i) the preparation of EIAs for all remaining polders; (ii) the implementation of the Environment Management Plan (EMP) and environmental mitigation and enhancement measures; and (iii) the establishment of an environmental monitoring system in BWDB to enable it to track continuous improvement in environmental performance of the polder system. Some of the items under EMP will be integrated with the civil works and included in the budget of Component A1. Component C- Construction Supervision, Monitoring & Evaluation of Project Impact, Supervision of Social and Environment Plans, and Delta Monitoring (US$32 million) Component C1: Detailed Design and Construction Supervision (US$16 million). This component will cover consulting services for (i) surveys, designs of remaining polders to be included in the project (other than the 5 for which detailed designs have already been completed), and (ii) construction supervision of rehabilitation and improvement of coastal embankments. This will include facilitating consultations with local communities in identifying needs and suitable design of the embankment as well as with other stakeholders such as local government, upazilla and union level governments. The component will finance surveys required prior to construction work. Component C2: Monitoring and Evaluation of Project Impact and Supervision of EMP, SAP/RAP (US$4 million). This component will cover consulting services for continuously monitoring project activities and providing feedback to the government and the implementing agency on the project’s performance. This includes supervising the implementation of the EMP, SAP and RAP. In addition, it will provide third party assessment and monitoring of key aspects of project implementation. The project will also look into the feasibility of undertaking an impact evaluation. Component C3: Long Term Monitoring, Research and Analysis of Bangladesh Delta and Coastal Zone (US$12 million). The Bangladesh Delta and its coastal zone is a crucial region for Bangladesh, and it is subject to a multitude of complex natural phenomena that are not fully understood as of now. The region is experiencing fast paced changes due to changes in river morphology, fluvial processes, human intervention, and climate change. To tackle this knowledge gap and enhance people’s understanding of this complex environment, the project will support a comprehensive monitoring and morphological assessment of the Bangladesh Delta. A program to extend the current monitoring systems in Coastal Bangladesh is also essential to generate data, information, and new knowledge for assessments of effects of multiple drivers on the environment of coastal zone and guide future design, rehabilitation and improvement requirements. The monitoring will cover sediment rates and composition; erosion rates; sea level rise; subsidence rates; tidal dynamics changes; river cross section changes and meander migration; shoreline changes; and any relevant geomorphological attributes. This work will be carried out by key institutions in Bangladesh, such as IWM, CEGIS, Dhaka University, BUET, and BWDB, in cooperation and twining arrangements with international institutions and experts in the topic of estuarine and coastal morphology and geomorphology. This twining arrangement is needed to build in-house capacity and guide local institutions and experts to improve their understanding of the physical processes of such a complex delta system. The project will support the installation and operation of needed equipment and systems on the ground, technical expertise, provision of advanced technology and equipment, high resolution specialized remote sensing images, and the capability to analyze these images. The project will support procurement of goods, services, and incremental operation costs in carrying out this research and analysis, and the development of databases and information systems that will be made available widely both within and outside of Bangladesh. Component D – Project Management, Technical Assistance, Training and Strategic Studies (US$21 million). This component will support BWDB in implementing the project through the establishment of a fully functioning Project Management Unit (PMU). It will provide resources for needed strategic studies (including the continuous updating of the strategic polder assessment as well as all necessary preparatory studies for following phases of the CEIP), institutional capacity building, technical assistance and training. Component E – Contingent Emergency Response Component ($0 million) In case of a major natural disaster, the Government may request the Bank to re-allocate project funds to this component (which presently carries a zero allocation) to support response and reconstruction2. This component would allow the Government to request the Bank to cancel project funds from Immediate Response Mechanism (IRM) portfolio projects and designate them as IRM funds to be engaged to partially cover emergency response and recovery costs. This component could also be used to channel additional funds should they become available as a result of the emergency. Policies, Legal and Administrative Framework A wide range of laws and regulations like Environment Conservation Act, 1995 (ECA, 1995), and the Environment Conservation Rules (ECR, 1997) related to environmental issues relevant to this project have been reviewed. Under the Environmental Conservation Rules (1997) a classification system was established for development projects and industries on basis of the project objective. These categories are: Green, Orange A, Orange B, and Red. The construction/reconstruction/expansion of flood control embankment, polder etc is categorized as Red in accordance DOE’s classification. For ‘Red’ category, it is mandatory to carry out Environmental Impact Assessment (EIA) including Environmental Management Plan (EMP) and where necessary develop a Resettlement Plan for getting environmental clearance from DoE. According to the World Bank requirement, the project has been classified as “Category A” considering the risk associated with widely involved major civil works by reconstruction and rehabilitation of the coastal embankment to protect against tidal flooding and storm surges. Since the coastal area is populated and used for cultivation widely certain negative environmental impacts may occur during the implementation and operational phase on overall polder system. Baseline Information The coastal area covers different types of land uses ranging from agriculture/fallow lands (63%), settlements (19%), and remaining water bodies/rivers to forest. The GTPW (Ganges Tidal Plain West) and CCP (Chittagong Coastal Plain) zones are mostly covered by mangroves and other forests. Inside the polder areas about 64% and 30% of the total area of 139 polders is being as agriculture/fallow lands and settlements respectively. The remaining areas are water bodies and fallow land. The coastal areas comprises three climatic such as South-eastern, South-western, South-central zone out of seven climatic zones of Bangladesh. In the coastal zone of Bangladesh, maximum and minimum temperatures range from 300C to 360C and 110C to 230C respectively. Annual rainfall ranges from a little over 1,700 mm in the west to over 3,200 mm at Cox’s Bazar in the east. Coastal areas are endowed with both fresh and brackish water resources. Brackish waters are mainly in the estuarine part of the rivers and tidal cannels/ creeks. Major rivers flowing though the coastal area are Gorai – Madhumati -Baleswar River and Rupsha - Pussur River in the GTPW zone; Buriswar River in GTPE (Ganges Tidal Plain East) zone; Meghna River in MDP (Meghna Deltaic Plain) zone; and Karnafuli River and Feni River in CPP zone. The air quality is not of much significant concern in the coastal area of Bangladesh. The present air quality is within the standard limits of Government of Bangladesh in most areas. In case of water quality both surface and ground water parameters are found within drinking water quality except chloride content. Most of the soils of the coastal area are saline and non-calcareous, except for some soils of the Old Ganges and Meghna floodplain area. The coastal area covers about 3.6 million acres of net cultivated area (NCA) with average cropping intensity of 175% where mostly local and HYB rice crops area grown. Soil salinity is the most dominant limiting factors for agricultural practices in this region especially during the dry season. The ecosystems mainly includes marine, brackish water, freshwater, mangrove, Sundarbans, floodplain, island, peninsula, and terrestrial ecosystem (roadside and homestead). Moreover, shrimp farming pond (Gher) ecosystem is found in this area. The world largest mangrove forest- the Sundarbans are located in this area. The mangrove forests are not only the transitional zones between fresh and marine water ecosystems but also serve as a natural fence against cyclonic storm and tidal surges. The major natural hazards and disaster are cyclonic storm, river floods, water logging, salinity (both soil and water), river erosion. Many parts of the coastal area of Bangladesh is facing water logging problem, especially in southwestern region (Khulna, Satkhira, Jessore districts) and Noakhali region. Water logging is created due to natural process of sedimentation in the river and drainage channels as well as improper maintenance of regulators and drainage channels in the coastal polders. About 30% of all polders are now experiencing water logging in the coastal area. Saline water intrusion in coastal area is highly seasonal in Bangladesh. Salinity and its seasonal variation are dominant factor for coastal ecosystem, fisheries and agriculture. Freshwater flow decreases in the Pasur-Sibsa river system during dry season, the saline front moves upward by 30-40 km. In the Baleswar-Bishkhali river systems, in the dry season 5ppt saline front moves landward by 20-25km from the coastline. In the middle part of coastal zone along the Meghna estuary, landward salinity intrusion is low because of huge freshwater flow coming through the Meghna river system. The livelihood activities of coastal population are multidimensional. According to Population census 2001, agriculture, livestock and fisheries provide the principal source of income for around 60% of households in most parts of the coastal zone. The economic activities of farmers usually are concentrated to land and water resource based activities such as agriculture, fisheries, salt farming, etc. The economic activities of wage labors are more diversified than other groups, although most of them are engaged in agriculture works. Women are usually engaged in household based works like homestead gardening, poultry and livestock farming, cottage industry, small business, fish fry collection, etc. Alternative Analysis The alternative analysis for CEIP project will be conducted for two scenarios . (a) Scenario1 will analyze the "no action" alternative of the project which will be reflected in this document and during embankment specific environmental assessment. It has been found the project will bring reduction of drainage congestion, reduction of tidal flood/storm surge, increasing flood free land type, increasing cropping intensity, increase of cropped area and crop production, increase of fish pond and production and increasing employment opportunity. Scenario 2 will conduct embankment specific alternative analysis for the project design, technical options, and implementation method in terms of environmental impact. The second scenario analysis will be conducted separately for each of the embankment and will be reflected in the Environmental Impact Assessment and Initial Environmental Examination report. The parameters to be considered for alternative analysis are but not limited to construction method, sources of material, disposal of sludge material, protection measures for reducing bank erosion, location and type of plantation and mode of transportation. Environmental Impacts Anticipated environmental impacts of the Project, are broadly classified into three categories: preconstruction, construction, and operation. Preconstruction: The anticipated impacts are loss of agricultural land, encroachment of fish habitat, loss of biomass, siltation due to loose soil, air and noise pollution, change in landscape and displacement of people. Construction: The anticipated impacts are air pollution, noise pollution, degradation of land scape, collection of soil material for earthen work from surrounding areas may create destruction of nearby structures, erosion from collection site., borrow pit may induce nuisance plant growth which will effect agriculture production, increased siltation in the water bodies. During dredging substrate removal will inevitably affect spawning, suspended sediment in the water affects the respiratory system of fish, growth may also be affected since food supply and feeding success are reduced in the turbid conditions, location of labor camp will create odor, solid waste management. Sources of material and disposal of dredged material are the main concern. Operation: Water logging, Soil erosion and sedimentation mismanagement, eutrophication in the borrow pit, Hydraulic Structures will create barrier for fish migration, Improper selection of plant will introduce nuisance plant, mosquito breeding in the ponding of borrow pit, removal of polypropelene bag etc are the issues during operation phase. Enhancement: The project will have a positive impact in preventing a substantial part of the people in the project area from becoming landless. All strata of the population will benefit from the protecting agricultural land, homesteads, markets, hospitals schools roads, irrigation systems etc. Increased agricultural production and the construction works of the project will generate more employment opportunities for the poor and landless. To maximize the benefit the contractor is required to recruit local laborers. Environmental Management System Based on an extensive literature review and expert consultation, a screening matrix has been developed for sub-projects under CEIP for collecting information through site visit, interview/ consultation with stakeholders, focus group discussion in the project site. Process of IEE study and preparation of TOR for EIA study is outlined briefly for IEE and EIA study of each sub-project. Also guidance for carrying out the detail environmental assessment studies (IEE and EIA) for specific sub-projects and implementing EMP as outlined in the framework. The format of environmental screening, IEE and EIA studies along with reporting structures are presented in this report. Moreover, process of preparing EMP and required institutional arrangement and capacity building are also presented. A comprehensive EMP which focuses on managing construction phase-related impacts should suffice in managing the potential construction and operation phase impacts. The EMP will be attached with the Bidding Document. The environmental management parameter will be included in the BoQ. Since many contractors do not have clear understanding the need of environmental management, some tend to quote 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. 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. Institutional Responsibility and Report Requirement BWDB will have special institutional arrangement to overall implementation of the EMP through Contractors. The contractor is responsible for implementation of EMP in the real field during construction works and Project Supervision Consultant is primarily responsible for supervision of the implementation of the EMP. The contractors should prepare EMP implementation plan. The Contractor should appoint part time or full time environment and social development specialist for the project. 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. The M&E consultant will be responsible for independent monitoring and implementation of EMP, and external monitoring and evaluation. DoE will be consulted if complicated issues arise during construction and operation stages. BWDB will apply for annual site clearance from DoE. WMOs will be trained to ensure environmental management during project operation. Environmental Management Unit of BWDB, strengthened through this project, will ensure and oversee the environmental management during project operation. BWDB will prepare the Half Yearly Progress Report on environmental management and will share with World Bank for review. Contributing development partners (if any) may join the field visit to understand the environmental compliance of the project. 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 the safeguards secretariat. The Environment, Social and Communication Unit (ESC) to be established to implement and manage the EMP will be structured to provide co-ordination, technical support and services during the environmental screening and preparation of EA, and implementation of the environmental mitigation measures. At least one of the two environmental specialists must be on board before effectiveness of the project. The specialists will prepare subproject specific environment screening/assessment report with EMP, supervise the implementation of EMP and support capacity building of the field level staff of BWDB and contractor. ESC will review the EMF and ensure quality of the environmental screening/assessment with EMP.
For all Category A (e.g. CEIP project) and B projects the borrower should consult the project-affected groups and local nongovernmental organizations (NGOs) about the project's environmental aspects and takes their views into account. The borrower should initiate such consultations as early as possible. For Category A projects, the borrower should consult these groups at least twice: (a) shortly after environmental screening and before the terms of reference for the EMF or EA are finalized; and (b) once a draft EMF or EA report is prepared. In addition, the borrower should consult with such groups throughout project implementation as necessary to address EA-related issues that affect them. During EMF preparation four consultation workshops have been carried out. Although this EMF will be the guiding framework for taking care of environmental concerns of the CEIP, and has been consulted before preparing, it may be required to update this in future to comply with policy, legal or institutional changes.
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