Bandarban District Education Office BAN: …...Draft Initial Environmental Examination (IEE) _____...

Draft Initial Environmental Examination (IEE) ____________________________________________________

February 2015

Bandarban District Education Office

BAN: Secondary Education Sector Investment Program (SESIP)

Prepared by the Ministry of Education

CURRENCY EQUIVALENTS (as of 5 February 2015)

Currency unit - taka (Tk) Tk1.00 = $0.0129

$1.00 = Tk77.3

ABBREVIATIONS

ADB Asian Development Bank CFL Compact Fluorescent Light DEO District Education Office DSHE Directorate of Secondary and Higher Education EARF Environmental Assessment Review Framework EED Education Engineering Department EMP Environmental Management Plan GRM Grievance Redress Mechanism HSE Health, Safety, and Environment IEE Initial Environmental Examination LED Light Emitting Diode MOE Ministry of Education PPE Personal Protection Equipment REA Rapid Environmental Assessment SESIP Secondary Education Sector Investment Program Tk Bangladesh taka

NOTE

This Initial Environmental Examination (IEE) is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of directors, Management, or staff and may be preliminary in nature. Your attention is directed to the “terms of use” section of the ADB website.

In preparing any country program or strategy, financing any projects, or by making any designation of or reference to a particluar territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Table of Contents

Page

I. Executive Summary 1 II. Introduction 2 III. Project Description 2 IV. Government of Bangladesh and ADB Regulatory Requirements 5 V. Preliminary Analysis of Alternative Locations 5 VI. Description of Existing Environment in the Selected Project Area 11

A. Physical Environment 11 B. Biological Environment 13 C. Socioeconomic and Physical Cultural Resources 14

VII. Potential Environmental Impacts and Mitigation Measures 15 A. Beneficial Impacts and Enhancement Measures 15 B. Adverse Impacts and Mitigation Measures 17 VIII. Institutional Arrangements 21 IX. Environmental Management Plan and Monitoring 21 A. Environmental Management Plan 21 B. Monitoring Program 25 X. Information Disclosure, Public Consultation and Participation 29 XI. Grievance Redress Mechanism 29 XII. Conclusion and Recommendations 30

I. Executive Summary

1. The proposed project, within the Secondary Education Sector Investment Program (SESIP), involves design and construction of a three-storey District Education Office (DEO) in Bandarban (Chittagong Hill Tracts). Assessment of alternative sites in and near Bandarban Town (undertaken in January 2015) indicated the optimal site for the DEO is a bare plot near the entrance to the District Council campus, about 3 km southwest of the town, on the Chittagong-Bandarban highway. This site presents few challenges for construction of the building.

2. The construction of the Bandarban DEO will not result in any adverse environmental or social impacts that cannot be mitigated to acceptable levels. Most minor adverse effects will be confined to the pre-construction and construction phases of the project and will be very localized, as well as transient. Standard construction best practices, which will be made explicit in the builder’s contract, should address all issues associated with noise, air quality, vegetative cover, site drainage, as well as water quality in the adjacent artificial lake. The design of the building and the layout of the site can be manipulated to produce a net positive environmental effect, with energy and water conservation operation in the DEO and a net gain in vegetative cover on the site. It is therefore recommended that this project can proceed, at the suggested location, with the specified EMP and monitoring plan in place.

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II. Introduction 3. The Secondary Education Sector Investment Program (SESIP) was approved by Asian Development Bank’s Board on 27 September 2013, and the Periodic Financing Request 1 (Tranche 1) for $90 million (2013–2017) was approved by the ADB President on 21 October 2013. SESIP supports secondary education in Bangladesh over 10 years, using a multitranche financing facility (2013–2022). SESIP will support the implementation of key reforms envisaged in the National Education Policy, 2010 in a phased manner. SESIP will also adopt a sector-wide approach that supports a government-led common secondary education program framework with enhanced harmonization of ADB and other development partner’s assistance. The Ministry of Education (MOE) is the executing agency and the Directorate of Secondary and Higher Education (DSHE) is the implementing agency. Strengthened fiduciary oversight arrangement and management is one of the key features of the program. 4. While the focus of SESIP is mostly on institutional aspects in the secondary education sector, some civil works (building of structures and associated components) is planned, according to the 5-year infrastructure development plan. This will include: developing school information hubs (640 schools); extra classrooms for pre-vocational and vocational courses; 385 new upazila education offices; vertical extensions and outfitting for training venues in 64 District Education Offices (DEOs); provision of solar power to off-grid secondary level institutes (approximately 3,000 installations); upgrading of 100 priority schools/madrasahs; new DSHE building construction; and, construction of the Bandarban DEO. The latter is the focus of this Initial Environmental Examination (IEE). III. Project Description 5. The proposed project is quite straightforward. It will involve construction of a 3-storey District Education Office in the vicinity of Bandarban Town (Bandarban Sadar, which is about 90 km road distance from Chittagong in the Bandarban Hill District; see Figure 1), according to the existing DSHE design templates for these structures. There are two design templates for a DEO in Bangladesh: one is a rectangular building with optimal use of the building footprint (assuming constrained availability of land), and the other is a more open structure, with a small courtyard, which assumes DSHE ownership of an adequate amount of land (less constrained availability of land); see Figures 2 and 3. Figure 4 shows an example of a DEO in Barisal. As is common in most Government buildings in Bangladesh, the outer façade is brick, and staircases are accommodated in an external adjunct to the main building. The roof is flat (with a very slight slope for drainage). 6. The more sprawling building (almost square, with an internal courtyard) has maximum building dimensions of 23 m x 18 m (approximately), whereas the more efficient building design (a denser use of building footprint) is approximately 26 m x 10.5 m. Building height (to the main roof level) is about 10.7 meters. The larger building footprint takes up about 414 m2, whereas the more efficient building footprint takes up about 273 m2. In both cases, the DSHE land for the building plot must also, obviously, include additional land for pedestrian and vehicle access, services, and a buffer for green space and security. The specified ratio of building footprint to total plot size for government buildings in Bangladesh is not known, but observations indicate that un-built buffer area in a Government plot can range from almost non-existent (in some urban areas) to quite spacious (in more rural locations, such as Bandarban). Ideally, the building footprint might take up only 50% of a plot, which would leave at least 4 meters buffer, on average, around the rectangular building (as an example; this is taken up later in the discussion of environmental enhancements).

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Figure 1. Location of Bandarban Sadar, in relation to Dhaka, and the location within

Bandarban District

Figure 2. DEO Design Template #1 (a square plot of approximately 414 m2 required)

town

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Figure 3. DEO Design Template #2 (a rectangular plot of approximately 273 m2 required)

Figure 4. Example of a District Education Office (Jalokhati, Barisal)

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7. The exact scheduling and pacing of the construction of the Bandarban DEO are not yet set. However, it is expected that land acquisition, final detailed building design, and construction could take at least two years. It is also expected that most site preparation would be undertaken during the dry season (winter) to avoid site drainage issues (monsoon rains being an issue from about May to September).

IV. Government of Bangladesh and ADB Regulatory Requirements 8. This IEE is responsive to the ADB environmental safeguards process, as summarized in the SESIP EARF. The overall SESIP program is categorized as “B” for environmental management purposes, requiring at least an IEE (with EMP) and a public consultation process (project disclosure, as well as consideration of local concerns). 9. As a single building of three storeys, this project is considered to be Category “Green” according to the Environmental Conservation Rule (1997) Schedule 1. As such, it does not even require an IEE, but must still have an Environmental Clearance Certificate, with associated approvals (land ownership document and a No Objection Certificate from the local authority). It must also adhere to Government of Bangladesh environmental standards for air quality and noise limits, as well as current building codes and worker safety standards. For example, the National Building Code (2006) and National Labor Act (2006) have defined certain measures to ensure a proper safe work environment, as well as the compensation measures for laborers. The implementing agency must ensure that the appropriate occupational health and safety provisions have been included in the bidding documents and are being implemented by contractor.

V. Preliminary Analysis of Alternative Locations 10. Two locations near Bandarban Town have been under consideration for the DEO. These are shown in Figure 5. One is the Girl’s College site north of the Sangu River (within the walled perimeter of the college) and the other is the District Council “campus” on the Bandarban-Chittagong Highway, about 3 km southwest of the town. There are two feasible sites within the District Council land (referred to as #1 and #2). All possible locations were examined for size, engineering feasibility, and environmental/social constraints during field work in January 2015 (undertaken with local authorities), in order to select one optimal site for the observations required for the IEE. The main requirement for consideration of these two locations, in the first place, was an adequate area for the building footprint and associated buffer in a relatively flat and accessible area, with minimal competing land uses or impingements on services. 11. Figures 6 - 9 show the site conditions at each of the three sites. The Girl’s College north of the Sangu River is situated adjacent to a relatively busy road that heads north. The road in this area supports mostly lumber businesses. The Girl’s College land is completely walled, with an internal access road that leads to the lecture room buildings and, further to the west, a student dormitory. The site is completely flat and is covered with scrub vegetation, a bean garden, and a small grove of trees (on the northern edge of the site), as well as perimeter trees along the wall (see Figure 6). While the site is relatively accessible and would be suitable for building construction, the DEO would crowd the existing buildings and its construction would create a disturbance during the college terms. In any case, it was learned after the site visit, that the administration of the Girl’s College wants to maintain the option of using the land in front of the lecture room buildings for future expansion. This, and more positive features at the District Council campus, eliminated the Girl’s College location from further consideration.

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12. The District Council land southwest of Bandarban Town is dedicated to Council administrative buildings, as well as the Council meeting building and the residence of the Council Head. There is a paved access road that comes off the south side of the Bandarban-Chittagong Highway that leads to a relatively sparse array of buildings in a site layout that includes a relatively pleasant combination of fields, gardens, forested areas, and lakes (see Figure 7). While there are several relatively flat sites further inside the District Council campus, the largest and most suitable potential sites for the Bandarban DEO are located almost immediately adjacent to the main gate (see Figures 8 and 9). The workable areas at these two sites (#1 and #2) were measured out to determine their capacity to accommodate the proposed DEO (see Figure 10).

Figure 5. The two locations under consideration for the Bandarban DEO (the Girl’s College north of the Sangu River, and the District Council land southwest if Bandarban

Town).

13. Site #2 at the District Council campus is the smaller of the two, with about 670 m2

available in an irregular shape (an asymmetrical pentagon). This available area is surrounded by a mosque, shed, and latrine on the north side of the site, the Fisheries building on the east side, and a communications tower hill on the south side. There is a mango grove on the south side of the site, adjacent to the lake. Several erosion gullies are evident between the brick access road and the lake. At least one mango tree would have to be cut down to allow for building construction and the communication tower hill would also have to be cut and supported with a near-vertical revetment wall. There is an access road that crosses the site, heading

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south. This road would have to be displaced to an area immediately adjacent to the mosque, shed, latrine, and Fisheries building wall. The edge of the brick access road (next to the slope leading to the lake) would need significant revetment support to prevent further erosion and slumping (already evident).

Figure 6. Site features at the Girl’s College north of Bandarban Town (from left-to-right, top-to-bottom: the road in front of the College; bean field near the main gate; perimeter

trees along the front wall; and, the lecture room buildings at the rear of the site).

14. Site #1, on the west side of the campus access road, is larger than Site #2, with about 1,110 m2 available in a symmetrical rectangle, with immediate access to the campus entrance road. While there are mature perimeter trees (especially a fine rain tree near the campus wall), no trees would have to be cut to allow for construction. A road that creates access to a council building near the Holiday Inn would have to be displaced to allow for construction, but there is adequate space on the north and south side of the site. There is a bus passenger facility and shop located in the northeast corner of the site (facing the highway) and there is also a single-family building (squatting, it appears) adjacent to the bus passenger facility/shop. Given the lack of adjacent buildings, no need for cutting trees, easy access to the campus entrance, and most notably the larger size of the site, #1, after discussion with local authorities, was selected as the optimal available site for the Bandarban DEO, and was the one subsequently considered in the IEE process.

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Figure 7. The entrance area at the District Council campus.

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Figure 8. Site #1 at the Bandarban District Council campus (from left-to-right, top-to-bottom: lake adjacent to site #1; main potential construction area; trees at the western

edge of the site; rain tree on the north side of the site; the bus passenger facility, entrance facing the highway; access road at the campus entrance).

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Figure 9. Site #2 at the Bandarban District Council campus (from left-to-right, top-to-bottom: access road to the site; edge of the mango grove, in front of the mosque; latrine and Fisheries building at the eastern edge of the site; access road heading east past the communication tower; mango grove at the southern edge of the site; erosion gully near

the access road, leading to the lake).

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Figure 10. Potential building plots near the entrance to the Bandarban District Council campus; #1 has an area of about 1,110 m2 and #2 has an area of about 670 m2.

VI. Description of Existing Environment in the Selected Project Area A. Physical Environment 15. Topography, Geology, and Soils: The selected project site is typical of the general topography and geology in this part of the Chittagong Hill Tracts, with frequent occurrence of small, relatively steep-sloped, hills interspersed with narrow valleys, some of which (especially in the District Council campus area) have been dammed to create a series of artificial lakes; see Figures 7 and 11. The hilly ridges in this area run mostly northwest-southeast, in the same orientation as the mountain divide between Bangladesh, India, and Myanmar, and have been subjected to considerable folding, faulting, tilting and dissection. Most of the hills in this area are composed of dense, compacted sediments, with a few that have been exposed to show underlying uplifted sedimentary rocks (sandstone, siltstone, clay stone, and sandy shale; old Pleistocene sediment deposits). The most extensive hill soils are brown, loamy and strongly acid, with rapid permeability and low moisture-holding capacity. Except over hard rocks, they are generally deep. The steep soil slopes are subject to erosion and erosion gullies are frequently observed in areas that have been cut, and not protected with overlying vegetation (see Figure 12). The Chittagong Hill Tracks experience some tectonic activity, with the latest recorded in 2002, at 5.5 on the Richter scale, with no damage evident. 16. Climate: The Chittagong Hill Tracts experience at least three main seasons, including: the dry season (November to March), characterized by relatively sunny, cool, and dry weather;

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the pre-monsoon season (April and May), which is very hot and sunny, with occasional showers; and, the rainy season (the monsoon period from June to October), which is warm, cloudy, and frequently wet. In this region of Bangladesh, mean monthly maximum temperatures range between about 25-34oC; mean monthly minimal temperatures range between 12 and 25oC. Daily temperature extremes are greatest during the dry season; sometimes a difference of 17oC between night and day temperatures can be recorded. The annual rainfall is generally more than 3,000 mm annually, with about 85% of the rain falling during the monsoon. Monsoon rainfall typically results in torrent downpours and flash floods in the valleys and gullies in the Bandarban area (evident in the gully erosion observed during the field trip in January 2015). Winds during the monsoon generally come from the south and southwest and from the north and northeast during the dry season. The area can experience the edge of cyclones that come off the Bay of Bengal. 17. Groundwater and Surface Water: Groundwater resources are not substantial in this area, due to the underlying geology, and are therefore not favorable for extensive withdrawal. However, this area is deemed to be arsenic-free.1 Water supplies in the Bandarban area are pumped or drained from local lakes that fill during the monsoon. The lakes in the project area are characterized by a brown-green color and low levels in the dry season (evident during the field trip, reflecting high levels of algae, which may be stimulated by residual nutrients from land runoff at the end of the monsoon). Figure 11. The characteristic hill formation in the Bandarban area, including the District

Council campus.

1 Hussein, M.M and S.K.M. Abdullah. 2001. Geological Setting of the Areas of Arsenic Safe Aquifers. Groundwater

Task Force, Bangladesh.

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Figure 12. Gully erosion near Bandarban Town.

18. Air Quality and Noise Levels: Air quality in the project area is generally quite good, due to the lack of industrial activity, and relatively low vehicle frequency on the Chittagong-Bandarban highway (in the specific locale of the District Council campus). However, any vehicle movement on the side roads and tracks during the dry season certainly raises dust. Noise levels in the project area are quite low given the lack of industry and few vehicles (bird songs are evident most of the time, as a measure of this). B. Biological Environment 19. Vegetative Cover and Natural Habitats: In general, this part of the Chittagong Hill Tracts is characterized by tropical semi-evergreen, wet-green, and deciduous forest, as well as bamboo and sun grass (see Figure 11), although greatly altered in many places, due historical and recent local community (indigenous tribe) Jhum cultivation practices, which involve clearing and burning natural vegetation to accommodate cultivation of crops, traditionally over a twelve-year rotation; more recently reduced to about five years, due to increased pressure on land (from the flooding of the Kaptai lakes, and Bengali settlement in the hill tracts. Naturally occurring trees, in residual forest areas, include sal, teak, chapalish, kari, chambal, and mahogany. Other plantation areas support exclusively pine and teak. The optimal project site (#1) has previously been cleared, and has no residual natural vegetation within the footprint shown in Figure 10. Perimeter trees (the large rain tree on the north side of the plot, some coconuts along the access road wall, and several mature trees at the eastern end of the plot provide some shape (especially the rain tree; which is possibly Albizia saman); none of these will need to be cut to allow for construction of the DEO. The only vegetative cover in the footprint comprises sparse grass and some scrub bushes, none of which have any natural habitat value. About 80% of the plot is bare, hard-packed soil (see Figure 8). 20. Fauna: Given the lack of natural habitat in the preferred plot, there are no animal dependencies on the site. Birds (at least fifteen species observed) are evident in the forested areas that are scattered throughout the District Council campus, and squirrels were seem nearby, but these animals would have no specific habitat needs in the preferred plot. Similarly, various species of butterflies are evident throughout the campus area. There is an artificial lake

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on the southwest corner of the plot, which presumably would support some fish and amphibians, but this lake is located at least 30 m away from the plot, and would not be directly affected by construction works. The slope between the lake and the plot is fully vegetated, which provides some protection to the lake (consolidating the slope and filtering sediments/nutrients). Beyond the District Council campus, wildlife that are known to occur throughout the Chittagong Hill Tracts, especially in undisturbed habitat, include monkey, elephant, fox, jungle cat, fishing cat, wild boar, hedge hogs, rabbits, land turtle, king cobra, reticulated python, rattle snake, other non-poisonous snakes, a large number of species of lizards and amphibians (frogs, toads, tree frogs), and more than sixty families of birds, including aquatic birds which are associated with the lakes, and seasonal migrants.2 None of these animals is evident in the immediate area of the preferred plot (#1). 21. Protected Area Status: The District Council campus is not located in a protected area of any kind. The actual proposed project footprint (the DEO area and surrounding buffer) has no value as critical habitat for any floral and faunal species in the Bandarban area (being a relatively flat area, with compacted soils, little vegetative cover, and crossed by people accessing the council buildings near the Holiday Inn). C. Socioeconomic and Physical Cultural Resources 22. Population and Cultural Composition: Bandarban Hill District is one of three hill districts in Bangladesh (all part of the Chittagong Hill Tracts, which has special administration, including some autonomy for several portfolios, instituted after the 1997 Peace Accord between the Government of Bangladesh and the Parbatya Chattagram Jana Sanghati Samiti). Bandarban Hill District is the remotest district of the country, and also is the least populated (a population of 292,900, as of 2003). The District has a male:female ratio of 0.546:0.454, which is quite highly skewed to males. The reported religious make-up in the district is as follows: Muslim 47.62%; Buddhist 38%; Christian 7.27%; Hindu 3.52%; and, others 3.59%.3 There are at least eleven hill tribes in the District, including: the Marma (which make up the majority of indigenous tribes in Bandarban Hill District, about 54%); the Murang (about 20%); followed by Tripura; Bawm; Tanchonga; Chakma; Chak; Kheyang; Khumi; Lushai; and, Pankhu. 23. Land Use: Bandarban Town (Sadar), with an administrative area of 52 km2, has a population of about 32,000. Most people live in the dense town area adjacent to the Sungu River. The population along the Chittagong-Bandarban highway is much sparser, with scattered houses on hills adjacent to the highway. Traditionally, local people in this area practiced the jhum cultivation methods (slash-and-burn), as noted above, but now most families are sedentary. Local cultivation includes bananas, papaya, pineapple, jackfruit, ginger, turmeric, rice, potato, eggplant, cotton, maize, and tobacco. Trade in fruit is actually mostly managed by Bengalis, rather than the indigenous tribes. Bamboo is also maintained in groves for construction and furniture purposes; teak as well. Several tree species are used for fuel wood, and this and the jhum cultivation have resulted in sparse vegetative cover in many areas near Bandarban Town. Dry winter months sometimes result in reduced production of food crops, and nutritional status in some communities, and health, are more constrained. The District Council campus, being Government land, is not used by local people, except for access to their houses

2 Nishrat, A. and S.R. Biswas. 2005. Community-Based Restoration of Degraded tropical Hill Forests: experiences

from Krykhong Para, Chittagong Hill Tracts, Bangladesh. Bulletin of the National Institute of Ecology (India) 16: 1-11.

3 Bandarban Hill District Council data, from their website.

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on more remote hills; there are many paths throughout the whole campus, that seem to be in use much of the time. 24. Services: Electricity transmission lines run along the highway and serve most buildings in the immediate area. Brown-outs are experienced. Phone communication is reliable (communication towers are evident in the area). Water is pumped from the local artificial lakes, and there is a primary treatment plant on the District Council campus for the water supply to the administrative buildings. Bus service is available in the area, linking to Chittagong and also towns further into the Hill Tracts. There is a bus passenger facility/shop immediately adjacent to the entrance to the District Council campus. There is a fairly well-developed tourist infrastructure in the vicinity of Bandarban Town (several hotels, motels, resorts, and restaurants), and these provide job opportunities, depending on the extent of tourism at any given time (this can fluctuate, depending on prevailing security concerns). Sewage from most sources is discharged through septic fields back to the groundwater aquifer. Solid waste management in the vicinity of the proposed DEO site is an issue (there are many slopes that have been used as garbage tips).

25. Physical Cultural Resources: The District Council campus has already been developed for the current administrative buildings. As such, there are no physical cultural resources, or archaeological remains, evident at the preferred site for the Bandarban DEO.

VII. Potential Environmental Impacts and Mitigation Measures A. Beneficial Impacts and Enhancement Measures 26. Overview of Project Activities: Construction of the Bandarban DEO will involve a fairly standard sequence of activities associated with building construction, including the following (listed below, to understand the risk of negative impacts and the potential for environmental enhancements): Pre-construction:

(i) acquisition of land and registration of title to the Ministry of Education (assumed to be a straightforward transfer from the District Council to MOE);

(ii) setting up the site for construction work (installation of fencing; creating staging areas for equipment, fuel, and materials; securing the access road from the entrance to the District Council campus); and

(iii) site clearing and leveling (removing scrub vegetation, bushes, rubble overburden, and waste, with proper disposal; with replanting of vegetation during landscaping, there should be a policy of “net gain” in greening of the building site);

Construction:

(i) laying in below-foundation any required service connections; (ii) pouring the foundation/ pillars; (iii) framing the building (to the required number of storeys; three expected); (iv) installation of walls and roof; (v) interior work and finishing; (vi) landscaping (with a net gain in vegetation; planting relatively mature trees and

shrubs on the building perimeter); (vii) site clean-up; (viii) service hook-ups; and (ix) commissioning of building.

Operation:

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(i) building operation; and (ii) limited parking area for staff, associated traffic; expected to be minimal.

Decommissioning:

(i) not anticipated in this analysis, as the building life is expected to exceed 75 years.

27. Potential environmental impacts (both positive and negative) associated with all project phases were identified by using the Rapid Environmental Assessment (REA) template included in the appendix. Beneficial impacts and enhancement measures are considered here, followed by consideration of potential adverse impacts and required mitigation measures. 28. “Green” cover and site drainage: Building and operation of the Bandarban DEO will be quite innocuous from the environmental perspective, with few potential negative environmental effects, and some opportunities for beneficial impacts and enhancement measures. In the first instance, the proposed site (#1) is fairly barren, with hard-packed soil and scrub vegetation. While its perimeter is quite attractive aesthetically, due to several groves of mature trees (that will remain undisturbed), the majority of the site is quite unattractive and dusty (at the time of observation in January 2015), and presumably muddy during the monsoon (with subsequent sediment entry to the artificial lake to the southwest of the site). There is, therefore, a significant net positive effect possible with the design of the building and its surroundings, to allow for proper site drainage, preventing soil erosion, establishment of a porous paving stone access area and parking space (allowing percolation of rainwater to the underlying soil and aquifer), and fully vegetating all buffer areas around the DEO that will not be required for pedestrian and vehicle access. In fact, it should be possible to accommodate both the DEO itself and a net increase in green cover (grass and shrubs, which would provide increased habitat for birds and small mammals) on the site (compared to the bare soil itself, as it is at present). The site can be designed to accommodate a perimeter drainage ditch that can direct site drainage to the lake slope (which is vegetated) without causing any erosion gullies. If the rectangular building concept described previously is used, then the building footprint would be approximately 273 m2

in an available area of 1,110 m2, which is only about 25% utilization of the available area, leaving plenty of room for service areas, a building buffer, and a much increased vegetative (“green”) area. 29. “Environment-smart” building design and operation: The current DEO building design options do not accommodate any particular water or energy conservation measures. With some design modifications and perhaps a budget premium of 10-15% (estimated, which might be paid back in reduced building energy costs over about 10 years), several enhancements may be possible (these will need discussion with MOE, DSHE, and ADB). These possible building enhancements are itemized below:

(i) The DEO should accommodate possible increased frequency and scale of weather extremes (higher wind speeds and increased rainfall during storm events, as predicted in sub-regional climate change models4). In particular, the roof and associated drainage will need to address rainfall extremes. Rainwater harvesting (roof collection with underground storage, for non-drinking water requirements in the DEO) should be considered.

4 Islam, F., H. Hove, and J-E. Parry (Adaptation Partnership) (2011). Review of Current and Planned Adaptation

Action: South Asia.

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(ii) Energy and water conservation systems, with small-zone light switches (for LEDs and CFLs), use of passive lighting for work areas, and hand-activated, automatic shut-off faucets for water in all locations.

(iii) Solar photovoltaic (PV) panels for supporting electricity demand in the building and for individual outdoor lights.

(iv) Solar hot water supply. (v) Building insulation, depending on temperature extremes experienced in the

Bandarban area, to increase passive warmth in winter (December-January) and sustained cooling in summer (April-October); combined with passive heating and cooling of the building (use of sun, ventilation, and adjustable shading, as appropriate).

(vi) Gray water separation (for toilet flushing and irrigation of site vegetation). (vii) Simple in-building infrastructure and receptacles for appropriate solid waste

management, allowing collection and handling of recyclable materials, hazardous materials, and compostable items.

30. Indigenous building design features: Local consultations raised the concept of incorporating some traditional building designs and motifs into the appearance of the Bandarban DEO. These were not specifically itemized; they would therefore need some research to determine what exactly is suitable and appropriate to incorporate in the way of building facades, roofline, windows, doors, common areas, specific building materials, etc.

31. Provision of employment opportunities: It is expected that many jobs specific to site clearing, preparation, and building construction can be filled by local people, as long as these jobs are advertised clearly and allocated fairly, according to the interest and availability of local people and their various areas of expertise. There is also an opportunity to establish more local businesses to supply consumables for workers (food and drink); perhaps along adjacent parts of the Chittagong-Bandarban highway, which already has some businesses of that sort. B. Adverse Impacts and Mitigation Measures 32. Almost all possible adverse environmental impacts associated with the Bandarban DEO have been precluded by selecting a site (#1) in the District Council campus that has no natural habitat, does not require cutting down any trees (yet will retain a perimeter of mature trees, for good aesthetics), is not immediately adjacent to watercourses, and does not impose on any current land uses (with the minor exception of a path that is used informally by local people; this can be shifted to one side, discussed below). The minor, temporary adverse environmental impacts that have been identified are itemized below, according to each project phase. Most of these relate to the building construction process, and can be relatively easily mitigated with standard best practices that are increasingly being required of the construction industry.

Summary Analysis of Adverse Impacts by Project Activity: Bandarban DEO

Project Activities Possible Impacts (on all baseline parameters; positive impacts are also noted where relevant)

Pre-Construction

1. Permanent land acquisition.

Loss of access to the site (local communities crossing the area); inconvenience.

Clearing of scrub vegetation (minimal, and of little consequence).

Reduction in visual aesthetics of the current land (access road, truck traffic, construction equipment in a relatively quiet, pristine area, eventually a building on site).

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Summary Analysis of Adverse Impacts by Project Activity: Bandarban DEO

Project Activities Possible Impacts (on all baseline parameters; positive impacts are also noted where relevant)

No loss of habitat for terrestrial wildlife or birds (positive).

Tree and shrub planting in buffer area around building a visual positive, and providing new habitat for birds and small mammals.

2. Land clearing and cuts (at work site).

The main concern is sediment mobilization and erosion on the edge of the site, especially at the southwest corner, closest to the artificial lake; risk of reduced water quality in lake (proper site drainage and slope stabilization required).

Generation of dust (transient).

Associated noise (transient).

Health and safety issues associated with construction, as well as local communities using the work area.

When land clearing is complete, work area is finished, and facilities are in place, all of the above impacts and risks are neutralized.

3. Influx of workers (exact number unknown).

Generation of waste (risk of reduced water quality from sewage; solid waste), and noise.

Health and safety issues associated with construction work.

On the other hand, increased business opportunities associated with worker consumption.

4. Construction equipment mobilized.

Mostly a concern with noise, emissions, and dust; all transient and in sporadic occurrence, although centered on the work site; vehicles may transport mud and sediments to other locations along the Chittagong-Bandarban highway, if not washed properly on-site.

Health and safety issues associated with construction equipment (accidents).

Poor aesthetics of vehicles and equipment in a relatively pristine environment.

Possible disruption of traffic on the Chittagong-Bandarban highway.

5. Fuel storage. Risk of spill, if not properly controlled and bermed; risk of contamination of groundwater and surface water (aquatic habitat in artificial lake compromised; possible impact on fish and amphibians).

Explosion risk.

Construction

6. Influx of more workers.

As in #3 above, except that numbers ramp up (somewhat) and risks increase accordingly.

Water requirements will increase (sourced from the adjacent artificial lake); most water will go back into the watershed.

Sewage treatment facilities in worker areas should be located as far away as possible from the lake.

7. More construction equipment used.

As in #4 above, except that more equipment over a longer period will be activated, so risks increase accordingly.

8. More fuel storage. As in #5 above, except that the risk of a spill increases (higher volumes in more locations).

Operation

9. Vehicle and pedestrian traffic adjacent to DEO.

Slightly more congestion near the main entrance to the District Council campus.

10. More consumables generated by building operation.

Risk of poor solid waste management.

11. Increased demand on local services.

Increased risk of water shortages and electricity load shedding.

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33. Pre-construction: The pre-construction phase involves land acquisition and site preparation (prior to digging the hole for the building foundation and then actual building construction). The proposed site is not currently being used for any District Council or community purposes, or providing natural habitat, so there are no negative environmental effects associated with acquisition of the land for the Bandarban DEO. One small issue is the need to have the current informal right-of-way (a path used by local people to cross the District Council land) shifted to the perimeter of the proposed DEO plot (perhaps near the wall between the campus and the Chittagong-Bandarban highway). This would still allow pedestrian and vehicle access to the council building near the Holiday Inn. 34. There will be a negative impact on the aesthetics of this location, as construction equipment, stockpiling of materials, and vehicle movements increase through the pre-construction phase. While somewhat barren, the site is currently quiet and pastoral, with the mature perimeter trees providing a pleasant visual frame for the location. This visual effect will be lost temporarily, but with completion of the DEO and planting of new shrubs and small trees in the buffer area around the building, the DEO site should recover the visual aesthetics that characterize at the moment, depending on the actual design of the building (as noted previously, there is an opportunity to incorporate some design features that characterize more traditional buildings in the Chittagong Hill Tracts). 35. During the pre-construction phase, with the staging of equipment and supplies, and site preparation (clearing scrub vegetation and leveling), the main concern is sediment mobilization and erosion on the edge of the site, especially at the southwest corner, closest to the artificial lake. If this were to occur, there is a risk of reduced water quality in lake (especially during the monsoon). Therefore, proper site drainage and slope stabilization is required, which will require installation of a perimeter drainage channel leading to a sediment catchment pond and check dams at the low point of the site, a gabion rock revetment along the southwest corner of the building site, and installation of sediment fences around most of the site. These mitigation measures will keep any mobilized sediments on the site and will prevent erosion due to rainfall and surface drainage from the site. Undertaking most of the construction work during the dry season would also help (dustier, but fewer sediments mobilized by site drainage). 36. Construction equipment and vehicles required for site preparation will generate dust and noise (generally 80-100 decibels on site), as well as emissions from engine exhaust (hydrocarbons and particulates). Both these adverse effects will be transient, depending on the conditions at the time of activities, and the duration of works. Both these effects can be mitigated: noise can be reduced by using proper silencers and mufflers, and keeping vehicle speeds to a minimum (which should be relatively easy, given the confined nature of the proposed site); and, dust can be controlled by keeping the work site damp (with water sprinklers) during the dry season, and keeping all soil, sand, and aggregate piles covered (whether on the site, or on trucks). It would also be very helpful to have a tire washing protocol for trucks leaving the work site, to ensure that sediments from the work site do not track onto the Chittagong-Bandarban highway and create dust and mud problems there. Vehicle emissions (engine exhaust) are more difficult to control, and depend on engine maintenance, fuel quality, emission controls in each vehicle, and speed. In any case, it is not expected that many vehicles will be required for construction of the DEO, and there is generally good air dispersion at the proposed site (being somewhat elevated), so perhaps air quality will not be a big concern at the site. Noise and air quality issues are mostly a concern for the construction workers, as there are few other people expected to be within the zone of influence of the project (perhaps some on the campus entrance road, and a few who live in the small house next to the bus passenger facility (but they mostly face onto the highway).

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37. Health and safety issues associated with pre-construction activities (as well as during the construction phase) will be an issue, both for workers and local communities that may continue to use the work area or adjacent locations. Workers will have to be briefed on the risk associated with construction activities, and provided with personal protection equipment (PPEs). The main concern is usually lack of protection of heads and feet, the risk of falling from elevated work places (no safety nets), lack of ear protection, and the risk of vehicle accidents in congested working areas. The whole work site will have to be fenced off and marked, so that any local people trying to cross the site will be re-directed to a pedestrian path on the perimeter of the site. When land clearing is complete, the work area is finished, and facilities are in place, all of the above impacts and risks will be neutralized. 38. The influx of workers, required for site preparation and eventual construction works, will result in increased amounts of solid waste, which will require a rigorous system of containment, separation, and proper disposal at the local landfill site. As noted previously, there is already an issue with garbage being dumped down most slopes, and this practice should be reined in, with provision of workable alternatives, so that the project does not contribute to the issue. On-site sewage treatment will also be required; either portable toilets or a temporary septic tank, which might then be converted to the septic field required for operation of the DEO. The intention is to prevent entry of nutrient-rich water into the artificial lake; it will be better if it percolates slowly through the soil into the aquifer. As such, the sewage treatment facilities (whatever is decided in the end) should be located as far away from the lake as possible (perhaps near the entrance road to the campus, behind the bus passenger facility.

39. There is a small concern with the risk of traffic disruption on the Chittagong-Bandarban highway, due to trucks and construction equipment having to access the highway from the entrance road at the District Council campus. This can be easily managed by having a worker with signage posted at the campus entrance, when needed. In any case, it is not expected that there will be a significant amount of truck traffic associated with the project, and traffic density on the Chittagong-Bandarban highway appears to be fairly low (at least, as observed in late January 2015).

40. Finally, fuel storage will need careful attention, in order to avoid the risk of spills or explosions, and the possible contamination of the artificial lake to the southwest of the site. While there should not be large requirements for fuel storage, as not many vehicles or construction equipment are expected to be involved in the project, any fuel required for building the DEO should be stored in a covered, sealed, bermed area away from busy parts of the work site. The berms need to be high enough to contain the full volume of fuel if there is a catastrophic failure of storage tanks.

41. Construction: As noted in the table above, all identified activities and possible impacts in the construction phase are in fact the same as the ones identified and initiated in the pre-construction phase; the scale of activities will just scale up to maximum levels during the construction phase. The discussion above therefore applies to the expected construction phase adverse impacts as well. The zone of influence (spatial boundary) of the construction activities is expected to be about 30-40 meters around the site (reflecting dissipation of noise and air pollutants associated with construction vehicles and equipment). Beyond that, direct impacts due to construction should not be detectable. Water required for various aspects of construction is expected to be pumped from the artificial lake to the southwest of the proposed site. Extracted water volumes will have to be carefully monitored, especially during the dry season, to make sure that the lake is not drawn down too much. Much of the water that is used on site

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(especially for washing and dust control) will just enter the drainage system on the construction site and re-enter the aquifer or the lake (subject to the sediment controls described earlier).

42. Operation: There are few adverse environmental impacts expected with operation of the DEO. The building will require services (notably water and electricity), which could cause additional demand during periods of low water availability and grid load-shedding. The proposed building design features that address water and energy conservation (described above under enhancements) would help considerably in this regard.

43. Operation of the DEO will result in more human activity in and around the building, which may increase vehicle traffic and congestion near the entrance to the District Council campus (exact numbers are difficult to predict; perhaps up to 20 people will occupy the DEO when it is in full operation). In any case, there should be adequate parking in the buffer area around the DEO (there is plenty of available space within the proposed plot) and traffic management can evolve to handle whatever volumes may occur on the main campus entrance road (still not expected to be high).

44. Operation of the DEO will result in production of solid waste, which will require careful storage, separation and handling, as described previously under enhancements. It is important that the DEO does not contribute to an already obvious solid waste issue in the area (indiscriminate dumping down slopes, much of it quite visible). Sewage from the DEO should not be an issue, with proper design and maintenance of a septic system.

VIII. Institutional Arrangements

45. It is expected that the Ministry of Education, through the Directorate of Secondary and Higher Education (DSHE), will be responsible for letting the contract for construction of the Bandarban DEO, and then will supervise the construction process, via local staff in Bandarban, with occasional oversight and monitoring by Education Engineering Department (EED) staff from Dhaka. EED is expected to maintain the direct responsibility for environmental safeguards associated with all the SESIP civil works. Building contractors will have all required environmental mitigation measures (itemized in the EMP, below) as covenants of their individual contracts.

IX. Environmental Management Plan and Monitoring A. Environmental Management Plan 46. Most possible adverse environmental impacts that could be associated with construction of the Bandarban DEO have been addressed by selecting a site that precludes any environmental concerns associated with natural habitats, vulnerable species, or the aquatic environment, and also results in virtually no negative social or economic impacts. The proposed site within the District Council campus is very acceptable from an environmental and social perspective. As discussed above, the few possible adverse impacts, mostly associated with actual construction processes, can be completely mitigated with standard best construction processes. These are itemized in the Environmental Management Plan (EMP) tabulated below.

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Activity Possible Adverse Impacts that Require

Mitigation

Mitigation Measure

Responsibility Estimated Cost of

Mitigation Measure

Implementation Compliance Monitoring

Pre-construction and Construction Phases of Bandarban DEO.

Permanent land acquisition.

Loss of access to the site (local communities crossing the area); inconvenience.

Reduction in visual aesthetics of the current land (access road, truck traffic, construction equipment in a relatively quiet, pristine area, eventually a building on site).

Re-route the path from the center of the work site to the perimeter near the District Council campus wall (north side of plot).

Loss of visual aesthetics will be temporary (approximately 2 years); tree and shrub planting in the buffer area around the DEO will create a visual “positive”, and will provide new habitat for birds and small mammals.

District Council, in coordination with building contractor.

Building contractor to plant; oversight from District Council and DSHE.

DSHE and District Council.


550,000 tk (about 50 meters of new paved path).

400,000 tk (about 50 new shrubs and small ornament-al trees).

Land clearing and cuts (at work site).

The main concern is sediment mobilization and erosion on the edge of the site, especially at the southwest corner, closest to the artificial lake; risk of reduced water quality in lake (proper site drainage and slope stabilization required).

Generation of dust (transient).

Associated noise (transient).

Health and safety issues associated with construction, as well as local communities using the work area.

Flat work site with perimeter drainage ditch that is directed to a sedimentation pond and check dams, before going down a vegetated slope; gabion rock revetment at southwest corner of site.

All sediment piles to be covered (on site and also trucks); slow vehicle speeds on site; regular water sprinkling during dry season.

Mufflers on all equipment; slow vehicle speeds on site.

Worker safety briefing; PPEs for all workers; safety nets; organized work site; completely fenced off to avoid public access; signage to indicate unsafe areas.

Building contractor.




DSHE.

DSHE.

DSHE.

DSHE.

950,000 tk for materials (rocks, geo-textile).

200,000 tk, for tarps and water tanks.

Contractor cost.

300,000 tk, estimated PPEs for 30 workers.

Influx of workers (exact number

Generation of waste (risk of reduced water quality from sewage; solid waste), and noise.

Temporary toilets or septic tanks for sewage containment (as far away from lake as possible);


DSHE.

200,000 tk, materials for toilets and waste corrals.

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Mitigation

Mitigation Measure


Mitigation Measure


unknown).

Health and safety issues associated with construction work.

solid waste management system on site.

As above, for worker safety.


DSHE.

-

Construction equipment mobilized.

Mostly a concern with noise, emissions, and dust; all transient and in sporadic occurrence, although centered on the work site; vehicles may transport mud and sediments to other locations along the Chittagong-Bandarban highway, if not washed properly on-site.

Health and safety issues associated with construction equipment (accidents).

Poor aesthetics of vehicles and equipment in a relatively pristine environment.

Possible disruption of traffic on the Chittagong-Bandarban highway.

Sediment and dust controls as noted above; tire washing protocol for vehicles leaving the site; noise controls, as noted above.

Worker safety protocols, as noted above; organized work site.

Temporary; no mitigation possible.

A traffic management person, with appropriate signage, to control construction vehicle access to the highway.



-


DSHE.

DSHE.

-

DSHE.

300,000 tk for tire washing service.

-

-

200,000 tk for signage services.

Fuel storage. Risk of spill, if not properly controlled and bermed; risk of contamination of groundwater and surface water (aquatic habitat in artificial lake compromised; possible impact on fish and amphibians).

Explosion risk.

All fuel stored in a sealed, bermed, and covered area away from busy parts of the construction site; appropriate signage regarding safety issues and protocol for fuel transfers

As above.



DSHE.

DSHE.

400,000 tk for fuel depot materials.

-

Operation Phase of Bandarban DEO.

Vehicle and pedestrian traffic adjacent to DEO.

Slightly more congestion near the main entrance to the District Council campus.

Keep DEO parking area away from the campus entrance road; appropriate signage at junction.

Local staff (DSHE), in coordination with District Council.

DSHE.

Within building cost.

More consumables generated by building operation.

Risk of poor solid waste management.

Proper solid waste management for the DEO, including sorting of recyclables and compostable materials.

Local staff (DSHE).

DSHE.

200,000 tk for solid waste containers

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Mitigation

Mitigation Measure


Mitigation Measure


Increased demand on local services.

Increased risk of water shortages and electricity load shedding.

Implementation of “green” technologies, including rainwater harvesting, water conservation measures, use of passive lighting, zone controls for electricity, and use of solar panels.

DSHE (EED) building designers; local staff (DSHE).

DSHE.

Estimated to be about 10-15% of the building cost.

Total Incremental Cost of Mitigation

Measures (tk)

3,700,000 tk (approx. US$ 47,865)

+ 10-15% of building cost

47. Specific mitigation measures are itemized in the table above, as part of the EMP. In general, construction best practices should be encouraged, anyhow, as a way of precluding any environmental and social issues during construction of the Bandarban DEO. The best practices listed below should be considered for inclusion in the DSHE contract with the selected builder:

(i) Make all efforts to keep local residents and business owners, as well as the municipality, informed of construction activities, sequences, and schedules, and especially give warning of any potential disruptions due to road closures, or other forms of traffic congestion.

(ii) Install fencing around the work site, including contingency for trapping mobilized sediments and surface water drainage (properly channeled on-site, as noted previously), to help control dust and keep any muddy slurry from entering roadways and watercourses (sediment mobilization and the risk of local landslides can be minimized or prevented altogether by undertaking site clearing and excavation during the dry season).

(iii) Provide an alternative, secure walkway for pedestrian traffic that would normally cross the site.

(iv) No civil works should be carried out during evening hours, normal times of rest, or when any cultural procession or activity is underway.

(v) The use of horns by construction vehicles should be minimized. (vi) Construction vehicles and generators to have adequate mufflers. (vii) Movement of all construction vehicles and personnel should be restricted to

within work areas, as much as possible, to avoid noise disturbance. (viii) Avoid excessive dust emissions from the work sites by sprinkling construction

areas with water. (ix) Control dust emissions due to vehicle movement by regulating vehicle speed in

and near the work site. (x) Water for construction needs to be provided by the contractor (either tanker

supply, or pumped from the artificial lake, with District Council approval). (xi) Temporary sewage collection facilities to be provided and managed by the

contractor (portable toilets, or temporary septic tank system). (xii) All solid waste related to construction activities and daily subsistence of workers

to be properly stored and disposed at an accepted landfill. (xiii) Fuel required for trucks, generators, and heavy equipment to be stored in a

sealed, bermed, and covered area that exceeds the volume of fuel stored.

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(xiv) Vegetation clearing should be minimized; no cutting of large shrubs or any trees, unless absolutely necessary and then such vegetation replaced through replantation during the landscaping phase (a net gain in vegetation).

(xv) A maximum number of unskilled laborers (required during construction) should be hired from within the local community (need for identification of work requirements and creation of a system of fair access to such jobs).

(xvi) All workers to be trained in basic health, safety, and environmental (HSE) matters, especially knowing the contract covenants that are intended to mitigate the short-term negative environmental effects expected during the construction phase.

(xvii) Create a facility for the local community to observe and comment (complain, if necessary) on the DEO construction project.

48. It will be important that the building contractor fully understands his obligations and is aware of the possibility that the DSHE and/or Department of Environment will monitor for compliance with the EMP and enforce where and when necessary (compliance monitoring may occur at regular intervals, but without warning; see details below). B. Monitoring Program 49. Given the lack of negative environmental effects expected with construction of the Bandarban DEO, specific scientific effects monitoring (to determine the interaction between the project and the environment) is not required. However, as some adverse impacts and annoyances associated with the construction process can be expected, and these are expected to be mitigated (as per the EMP described above), compliance monitoring is required, to make sure that all required mitigation measures are in place and working properly.

50. Project activities that require mitigation measures and the respective compliance monitoring actions are summarize in the table below.

Project Activity Mitigation Activity Monitoring Action and Frequency

Monitoring Responsibility*

Estimated Monitoring

Cost

Pre-construction and Construction Phases of Bandarban DEO.

Permanent land acquisition.

Re-route the path from the center of the work site to the perimeter near the District Council campus wall (north side of plot).

Loss of visual aesthetics will be temporary (approximately 2 years); tree and shrub planting in the buffer area around the DEO will create a visual “positive”, and will provide new habitat for birds and small mammals.

Visual check during construction of re-aligned path, and on completion.

Pre-planting check on appropriate locations and species; visual observations during planting; final visual check on completion of planting; then, ongoing maintenance.



Within routine DSHE oversight activities; no additional cost.**

Within routine DSHE oversight activities; no additional cost.

Land clearing and cuts (at work site).

Flat work site with perimeter drainage ditch that is directed to

Visual check on plan and location of various structures, prior to

DSHE.

Water quality; sample collection and

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Cost

a sedimentation pond and check dams, before going down a vegetated slope; gabion rock revetment at southwest corner of site.

All sediment piles to be covered (on site and also trucks); slow vehicle speeds on site; regular water sprinkling during dry season.

Mufflers on all equipment; slow vehicle speeds on site.

Worker safety briefing; PPEs for all workers; safety nets; organized work site; completely fenced off to avoid public access; signage to indicate unsafe areas.

installation; monthly visual checks on effectiveness of drainage scheme and revetment; water quality samples (2, for dissolved oxygen, suspended solids, and nitrogen) at edge of lake (once in dry season and once in monsoon).

Just visual checks on effectiveness of dust controls and vehicle emissions (monthly); air quality sampling should not be necessary, given expected low volume of activity.

As above.

Visual checks on work site safety and signage (monthly).

DSHE.

DSHE.

DSHE.

analysis, 250,000 tk (over 2 years); other visual checks within routine tasks.




Influx of workers (exact number unknown).

Temporary toilets or septic tanks for sewage containment (as far away from lake as possible); solid waste management system on site.

As above, for worker safety.

Visual checks on sewage and solid waste management on-site (monthly); water quality sampling noted above to apply here.


DSHE.

DSHE.



Construction equipment mobilized.

Sediment and dust controls as noted above; tire washing protocol for vehicles leaving the site; noise controls, as noted above.

Worker safety protocols, as noted above; organized work site.

A traffic management person, with appropriate signage, to control construction vehicle access to the highway.

Just visual checks on effectiveness of dust controls and vehicle emissions (monthly), as described above.


Visual checks (monthly).

DSHE.

DSHE.

DSHE.




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Cost

Fuel storage. All fuel stored in a sealed, bermed, and covered area away from busy parts of the construction site; appropriate signage regarding safety issues and protocol for fuel transfers.

Visual checks (monthly).

DSHE.


Operation Phase of Bandarban DEO.

Vehicle and pedestrian traffic adjacent to DEO.

Keep DEO parking area away from the campus entrance road; appropriate signage at junction.

No specific monitoring required; manage parking and traffic according to prevailing conditions.

DSHE.

-

More consumables generated by building operation.

Proper solid waste management for the DEO, including sorting of recyclables and compostable materials.

Routine observations and awareness of how the solid waste system is operating; assign someone in the DEO with this responsibility (e.g., building caretaker).

DSHE.


Increased demand on local services.

Implementation of “green” technologies, including rainwater harvesting, water conservation measures, use of passive lighting, zone controls for electricity, and use of solar panels.

Routine observations and awareness of how the various technologies are performing; maintaining a log on effectiveness and cost savings would be very useful.

DSHE.


Incremental Cost of Compliance Monitoring (beyond the cost of routine visual checks).

250,000 tk

* The building contractor should be examining all site conditions and operations, specifically the required mitigation measures, on a daily basis, and putting in corrective measures, as needed, with monthly reporting to DSHE; this report should also include any fuel spills and work site accidents and how they were handled. ** There may be some minor operational costs, such as local transportation, depending on how routine DSHE tasks are budgeted on an annual basis.

51. Routine visual inspections will be required of DSHE prior to and throughout the construction of the Bandarban DEO (as noted in the table above). Certain inspection protocols are suggested, to facilitate the effectiveness and accuracy of visual inspections. Inspections should be undertaken without any warning or advance notice, in order to observe the construction sites in their normal mode (otherwise, contractors will often do a temporary “quick fix” of issues that they think might catch the eye of inspectors). The following points should be checked during construction site inspections:

(i) Record the time and weather at the time of inspection (especially incidence of rain in the previous 24 hours and during the inspection), as these details affect site conditions.

(ii) Make a note of any unusual conditions or situations at the construction site, such as areas that are roped off and apparently not accessible, lack of workers, few vehicles at the site, etc. (anything that suggests the situation is not “routine”).

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(iii) Take date and time-imprinted photographs of all features that are observed; all observations are properly recorded, and reviewed with site engineer upon leaving.

(iv) Specific site inspection should include an assessment of all measures required to control site drainage and movement of surficial sediments, including the following:

a. the location, condition, and effectiveness of diversion structures to allow off-site storm water to make it around and past the construction site, without mixing with site surface water;

b. the location, condition, and effectiveness of site drainage features, including diversion ditches, check dams, sediment traps, sedimentation ponds, etc.;

c. exposed surfaces that may be subject to erosion by rain or vehicle movements, including sediment stock piles that are left uncovered;

d. use of sediment fences to contain mobile sediments on the construction site, keeping them from entering watercourses or roadways;

e. the extent of cleaning of sediments from sediment trap features (are they properly cleaned of sediments, to avoid overflow during monsoon rains?);

f. washing of vehicles prior to leaving the construction site; g. dust control for dirt roads (watering); h. trucks carrying sediments (sand, gravel) are covered; i. the quality of water in adjacent watercourses and water bodies (i.e., the

artificial lake): any evidence of turbidity from the construction site?; j. trees and other vegetation not required to be cleared for site-specific

construction are properly retained and protected; and, k. is there an accurate erosion and sediment control plan that shows all the

site features for controlling mobile sediments and site drainage? l. all required corrective actions should be noted and shown on a map (and,

have previous corrective actions been effective?).

(v) Chemicals and fuel are stored in a secure, covered, bermed area; no evidence of leakage.

(vi) These hazardous material storage areas are located at least 20 meters from water courses.

(vii) All hazardous material containers are properly sealed and labeled. (viii) There is a clear emergency response plan in place for any spills of hazardous

materials or other accidents on site; this is documented, placed in public areas, and routinely practiced; any emergency or spill incidents have been recorded and reported.

(ix) All workers have PPE (personal protection equipment) that includes at least helmets, boots, and goggles, ear protectors, visibility jackets, safety harnesses, and face masks, as necessary; fire-fighting equipment is accessible and fully functional.

(x) The construction area is fenced off and inaccessible to the public; alternative pedestrian and vehicle traffic routes are established to avoid the construction site.

(xi) Safety signs and warnings are evident at all high-risk areas on the construction site.

(xii) Safety nets for falling equipment are in place around the building.

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(xiii) Work is limited to specific daytime hours, and all noise repressing equipment (mufflers, etc.) is functional.

(xiv) Waste is properly managed (separated, in a designated area, with re-usable or recyclable materials isolated); no on-site burning of waste.

(xv) On-site sewage generation is properly contained and treated, or trucked to a treatment area.

X. Information Disclosure, Public Consultation and Participation 52. Given the very limited scope of this project (construction of a 3-storey building on Government land), and the expected almost negligible environmental impacts associated with building construction, as well as the fact that only one squatter house may be exposed to the construction activities, public consultation and participation processes have been just preliminary to date. Initial information disclosure and consultation were undertaken during the field visit in January 2015. The following people were consulted with regard to possible social and environmental issues, and the selection of the preferred site on the District Council campus:

(i) Mr. Kyaw Sa Prue, Chairman (Acting), Bandarban Hill Tracts District Council. (ii) Mr. Mohammad Nurul Absar, Chief Executive Officer, Bandarban Hill Tracts

District Council. (iii) Mr. Mohan Chakma, Executive Engineer, Bandarban Hill Tracts District Council. (iv) Mr. Juri Mong, Public Relations Officer, Bandarban Hill Tracts District Council. (v) Mr. Towhid Talukdar, Upazila Secondary Education Officer, Bandarban Sadar. (vi) Mr. Swapon, Senior Assistant, District Education Officer, Bandarban. (vii) Mr. Alek Hossain Jewel, Sub-Assistant Engineer, EED, Bandarban. (viii) Lecturer, Philosophy, Bandarban Government Girl’s College. (ix) Lecturer, Physics, Bandarban Government Girl’s College. (x) Caretaker, Bandarban Government Girl’s College.

53. It is recommended that this IEE and subsequent detailed building designs be taken back to the people who have been consulted initially, as they will ultimately have some role in management of the DEO building project, and approvals required for land transfer and no-objection certificates. Public consultation (the wider public) can be accommodated with a small public meeting on the District Council campus, to explain the project (once details are firmer) and solicit any concerns about the construction process. This public meeting should be recorded and all public comments logged and responded to. In any case, it is expected that there will not be much public interest in this specific building project, given its location and small scale. However, there will be expectations of increased employment opportunities due to the construction project; available jobs will therefore have to be advertised and delegated fairly. XI. Grievance Redress Mechanism 54. It is unlikely, given the nature, scale, and location of the project, that the public will have specific grievances associated with either the design or construction of the Bandarban DEO. In any case, a simple Grievance Redress Mechanism (GRM) should be established to accommodate any concerns that may emerge. It is suggested that both the DSHE (local staff) and the District Council work collaboratively to receive comments at either the project work site, the DSHE office, or the District Council offices, including logging the concern or complaint, setting in place a mechanism to discuss and resolve the complaint, and ensuring appropriate feedback to the complainant in a timely manner (within two weeks), with the response also logged. This simple GRM should be sufficient to handle any expected issues coming from the

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public. A more elaborate GRM is not justified. Any issues that are perceived to remain unresolved can be taken up with the Government of Bangladesh legal system. All issues that arise through the proposed GRM should be reported in routine reports that go to DSHE and ADB. XII. Conclusion and Recommendations 55. It is concluded that the construction of the Bandarban DEO will not result in any adverse environmental or social impacts that cannot be mitigated to acceptable levels. Most minor adverse effects will be confined to the pre-construction and construction phases of the project and will be very localized, as well as transient. Standard construction best practices, which will be made explicit in the builder’s contract, should address all issues associated with noise, air quality, vegetative cover, site drainage, as well as water quality in the adjacent artificial lake. The design of the building and the layout of the site can be manipulated to produce a net positive environmental effect, with energy and water conservation operation in the DEO and a net gain in vegetative cover on the site. It is therefore recommended that this project can proceed, at the suggested location, with the specified EMP and monitoring plan in place.

31 Appendix 1

1. REA for Urban Development (including building construction):

Rapid Environmental Assessment (REA) Checklist Instructions:

This checklist is to be prepared to support the environmental classification of a project. It is to be attached to the environmental categorization form that is to be prepared and submitted to the Chief Compliance Officer of the Regional and Sustainable Development Department.

This checklist is to be completed with the assistance of an Environment Specialist in a Regional Department.

This checklist focuses on environmental issues and concerns. To ensure that social dimensions are adequately considered, refer also to ADB checklists and handbooks on (i) involuntary resettlement, (ii) indigenous peoples planning, (iii) poverty reduction, (iv) participation, and (v) gender and development.

Answer the questions assuming the “without mitigation” case. The purpose is to identify potential impacts. Use the “remarks” section to discuss any anticipated mitigation measures.

Screening Questions Yes No Remarks

A. Project Siting

Is the project area…

Densely populated? X There are no residences on the District Council campus, except the house of the Council head, at the southern end of the campus, and a squatter house next to the bus passenger facility near the entrance to the District Council campus.

Heavy with development activities? X There are only a few district administrative buildings on the campus near the Chittagong-Bandarban highway; there are several tourist-related buildings (resorts and hotels) along the highway in this area.

Adjacent to or within any environmentally sensitive areas?

X The proposed plot is not immediately adjacent to the artificial lakes in the campus (of which there are several).

Cultural heritage site X None present.

Protected Area X None present.

Wetland X None present.

Mangrove X None present.

Estuarine X None present.

Buffer zone of protected area X None present.

Special area for protecting biodiversity X None present.

Bay X None present.

B. Potential Environmental Impacts

Will the Project cause…

impacts on the sustainability of associated sanitation and solid waste disposal systems and their interactions with other urban services?

X The proposed plot is not linked to any urban services.

deterioration of surrounding environmental conditions due to rapid urban population growth, commercial and industrial activity, and increased waste generation to the point that both manmade and natural systems are overloaded and the capacities to manage these systems are overwhelmed?

X Operation of the DEO is not expected to lead to immigration or significantly increased demands on urban services.

degradation of land and ecosystems (e.g. loss of wetlands and wild lands, coastal zones, watersheds and forests)?

X No proximity to these ecosystems.

dislocation or involuntary resettlement of people? X There are no residences on the proposed plot.

degradation of cultural property, and loss of cultural heritage and tourism revenues?

X None present.

32 Appendix 1

Screening Questions Yes No Remarks

occupation of low-lying lands, floodplains and steep hillsides by squatters and low-income groups, and their exposure to increased health hazards and risks due to polluting industries?

x None present.

water resource problems (e.g. depletion/degradation of available water supply, deterioration of surface and groundwater quality , and pollution of receiving waters?

X Silt fences can keep mobilized sediments on site (during building construction), such that no sediments enter the artificial lake to the southwest. During building operation, water will be supplied via a pipe system from the water treatment plant on the District Council campus.

air pollution due to urban emissions? X No emission from the building.

social conflicts between construction workers from other areas and local workers?

X It is expected that most workers will be hired from the local communities.

road blocking and temporary flooding due to land excavation during rainy season?

X Construction at the proposed site will not obstruct any public roads or affect watercourses.

noise and dust from construction activities? X Dust will be managed by using water sprinkling during the construction phase; noise will be controlled with the use of mufflers on vehicles and construction equipment.

traffic disturbances due to construction material transport and wastes?

X Construction vehicles will have to occasionally use the Chittagong-Bandarban highway; but traffic density on that road is quite low, in any case.

temporary silt runoff due to construction? X Silt fences will be required to keep mobilized sediments from entering the small artificial lake to the southwest of the proposed site.

hazards to public health due to ambient, household and occupational pollution, thermal inversion, and smog formation?

X Negligible pollution from construction and operation of the DEO.

water depletion and/or degradation? X Water supply will come from the District Council campus water supply system, which is fed by pumped water from the artificial lakes within the campus.

Over pumping of ground water, leading to land subsidence, lowered ground water table, and salinization?

X Groundwater pumping is not expected.

contamination of surface and groundwater due to improper waste disposal?

X The DEO will have a septic tank system for treatment of sewage, and there will be minimal production of solid waste (which will go to the municipal landfill).

pollution of receiving waters resulting in amenity losses, fisheries and marine resource depletion, and health problems?

X No aquatic pollution from the DEO expected (septic tank system).

***

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