SOCIAL DEVELOPMENT FOUNDATION(SDF)
SOCIAL INVESTMENT PROGRAM Project(SIPP)
Operational ManualVolume III: Environmental Assessment Manual
September 2002
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TABLE OF CONTENTS
LIST OF ABBREVIATIONS I
I EXECUTIVE SUMMARY __
2. INTRODUCTION I
2.0 Project Description 1
2.1 Purpose of this Document 1
2.2 Methodology for Preparing this Report I
2.3 Project Areas 2
2.4 Environmental Profile: Jamalpur 2
2.5 Environmental Profile: Gaibandha 3
3. LEGAL FRAMEWORK FOR ENVIRONMENTAL MANAGEMENTAND ENVIRONMENTALIMPACTASSESSMENT 5
3.0 Environmental Legislation in Bangladesh 5
3.1 Environmental Impact Legislation in Bangladesh 5
3.2 International Environmental Conventions, Treaties and Protocols 6
3.3 Sectoral Environmental Guidelines in Bangladesh 7
3.4 The World Bank and Environmental Assessment 8
3 5 The Bank's Environmental Screening Process 9
4 ENVIRONMENTALLY POSITIVE SUB-PROJECTS 10
4.0 Overview of Environmentally Positive Sub-projects 10
5. ENVIRONMENTAL IMPLICATIONS OF THE SIPP 12
5.0 Potential Environmental Impacts of the SIPP 12
5.1 Oversight 12
5.2 Indirect Impacts 12
5.3 Cumulative Effects 12
5.4 Environmental Impacts of Various Sub-project Types 12
6. ENVIRONMENTALLY SENSITIVE AREAS 15
6.0 Environmentally Sensitive Areas (ESA) in Bangladesh 15
6.1 ESAs and the SIPP 15
7 ADMINISTRATIVE STRUCTURE FOR ENVIRONMENTAL ASSESSMENTIN THE SIPPPROJECT CYCLE 18
7.0 Environmental Assessment Procedures in SIPP 18
7.1 Environmental Assessment in SIPP Project Cycle 18
7.2 ~Taimng for Adequate Environmental Management of SIPP 20
71.3 RqunaOlie: Training for the SDF staff 20
7 4 Round Two: Training for the CSO and PAST members 20
7.5 Environmental Routing Slip by PMC of CG 20
7 6 Environmental Screening (ES) by CSOs 20
7.7 Environmental Review (ER) by CSO 22
7.8 Limited Environmental Assessment (LEA) by Envirornrrental Specialist (s) 22
7.9 Appraisal and Approval by SDF's PAST 22
7.10 Implementation & Supervision by CSOs and PAST 23
7 11 Monitoring, Evaluation & Environmental Auditing by CDOs, PAST and IndependentAuditors 23
8. ENVIRONMENTAL SUPERVISION, MONITORING & AUDITING 24
8 0 Environmental Supervision and Monitoring 24
8.1 Environmental Baselines 24
8 2 Cumulative Impacts of SIPP Sub-projects & Key Parameters for Monitoring 28
8.3 Independent Environmental Auditing 28
LIST OF TABLES
Table I - Overview of Environmentally Positive SIPP Sub-projects 10Table 2 - Environmentally Sensitive Areas in Bangladesh 16Table 3 - Screening Categories 22Table 4 - Data Sources for the Monitoring Program 25Table 5 - Cumulative Impacts and Kcy Monitoring Parameters for SIPP Sub-projects 30
LIST OF FIGURES
Figure I - Environmental Assessment and the SIPP Project Cycle 19
LIST OF APPENDICES
Appendix I - Routing Slip for Environmental Management of SIPP Sub-projectsAppendix 11 - Environmentally Sensitive Areas (ESA) (FORM 11)Appcndix III - Format for Environmental Screening of Sub-projccts (FORM 111)Appendix IV - Generic Environmental Review (ER) Check list, Showing Potential
Negative Environmental Impacts & Proposed Standard MitigationMeasures for each SIPP Sub-project Category (FORM IV)
Appendix V - Limited Environmental Assessment (LEA) Format (FORM V)Appendix VI - Instruction Manual for Environmental Assessment of SIPP Sub-projects (in English)Appcndix VII - Protccted Areas and Important Wetlands of Bangladesh
LIST OF BOXES
Box 1 - Environniental Perfoniance Rating 29
LIST OF ABBREVIATIONS
ADAB Association of Development Agencies in BangladeshBCAS Bangladesh Centre for Advanced StudiesBIDS Bangladesh Institute of Development StudiesBWDB Bangladesh Water Development BoardCDO Community Development OfficersCEGIS Center for Environment and GIS Support to Water Sector Planning (to be
formed out of EGIS by 2000)CEN Coalition of Environmental NGOsCG Community GroupCHT Chittagong Hill TractsCSO Community Support OrganizationsDoE Department of EnvironmentDPHE Department of Public Health EngineeringEA Environmental AssessmentECA Environmental Conservation ActECR Environmental Conservation RulesEGIS Environment and GIS Support Project for Water Sector PlanningEIA Environmental Impact AssessmentEIE Environmental Impact EvaluationER Environmental ReviewES Environmental ScreeningESA Environmentally Sensitive AreaFAP Flood Action PlanFRMP Forest Resources Management Project (1995-97)GoB Government of BangladeshHPI Human Poverty IndexIEE Initial Environmental ExaminationIFRD Institute of Fuel Research & DevelopmentIPI Income Poverty IndexITN International Training Network Center for Water Supply and Waste ManagementLEA Limited Environmental AssessmentLGED Local Government Engineering DepartmentMoEF Ministry of Environment and ForestNACOM Nature Conservation Management (formerly Nature Conservation Movement)NGO Non-Governmental OrganizationODs Operational Directives (of the World Bank)OPs Operational Policies (of the World Bank)PAST Project Appraisal and Supervision TeamPMC Project Management CommitteeREB Rural Electrification BoardRIMS Resource Information Management System (within Forestry Department, MoEF)SDF Social Development FoundationSIPP Social Investment Program Project
OPERATIONAL MANUALENVIRONMENTAL ASSESSMENT
1. EXECUTIVE SUMMARY
The objective of the Social Investment Program Project (SIPP) is to develop effective and efficientfinancing and institutional arrangements for improving access to local infrastructure and basicthrough the implementation of community-driven and private provisioning of, small scaleinfrastructure works and social assistance programs The SIPP will be managed by an autonomousbody, the Social Development Foundation (SDF). Under the SIPP, investment proposals for small-scale community infrastructure will be prepared and implemented by Community Groups assisted byCommunity Support Organizations (CSO) appointed by SDF Subprojects to be supported by SDFwill include a menu of options covering trade and transport infrastructure and arsenic free water andsanitation facilities
Many of these small-scale subprojects are not expected to lead to environmental impacts of anysignificance. However, to avoid potentially adverse environmental impacts, all proposed requests forfunding subprojects will be subject to environmental screening exercise in order to: prevent executionof projects with significant negative environmental impacts, decrease potential negative impactsthrough adaptations in subproject design, location or execution; prevent or mitigate negativecumulative impacts; enhance the positive impacts of subprojects; and prevent additional stress onenvironmentally sensitive areas.
During Environmental Screening (ES), SIPP subprojects will be classified as categories C+, C, B orA, which will require an Environmental Review (C+ & C), Limuted Environmental Assessment (B).In this process, special regard will be paid to Environmentally Sensitive Areas, and activities thataffect these areas will be discouraged. Category A sub projects will not be funded
In this Environmental Assessment Manual, a separate "Instruction Manual for EnvironmentalAssessment of SIPP Subprojects" has been developed and translated into Bangla, along with therequired forms. Proponents of SIPP subproject proposals will be required to follow the instructions aselaborated in the instruction manual, and all subproject proposals will have a Routing Slip attachedwhich will visualize the environmental history of the subproject.
To a large extent, however, the need for environmental assessment capacity will be reduced by activepromotion of environmentally positive subprojects, and discouragement of subprojects that adverselyimpact the environment; using impact/mitigation measure checklists for the Environmental Review,which can be used at local level (with limited external assistance or training); and the use oftranslated Routing Slips, and translated checklists for environmental screening and environmentalsensitivity assessment, which can be used at local level (with limited external assistance or training)
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2. ENTRODUCTRON
2.0 Project Description
The objective of the Social Investment Program Project (SIPP) is to develop effective and efficientfinancing and institutional arrangements for improving access to local infrastructure and basicthrough the implementation of community-driven and private provisioning of, small scaleinfrastructure works and social assistance programs. The SIPP will be managed by an autonomousbody, the Social Development Foundation (SDF). The project is at developing institutions, promotingcommunity driven principles, pioneering performance based social assistance programs for thepoorest, and leveraging private financing for basic utilities. During the four-year project period, itwill operate in two districts (Gaibandha and Jamalpur) to cautiously develop procedures, testdifferent products and approaches, and demonstrate impact. At mid-term review, the project'simplementation arrangement and design would be assessed in terms of achievement of the expectedoutcomes and outputs and successful mechanisms identified for scaling up.
Under the SIPP, investment proposals for small-scale community infrastructure will be prepared andimplemented by Community Groups assisted by Community Support Organizations (CSO) appointedby SDF. Subprojects to be supported by SDF will include a menu of options covering trade andtransport infrastructure and arsenic free water and sanitation facilities. The menu of the differenttechnological options will be dissemmnated to the community through the information communicationcampaign enabling them to choose the most affordable and technically efficient option. It is possiblethat during the needs assessments exercise, other investment options will be requested. If justified,these would be considered by SDF for financing after review of the various of technological options.
As lead implementation agency, SDF will need to ensure that all subprojects are screened for possibleenvironmental implications, and that environmental assessment occurs in conformity with theGovemment of Bangladesh Environment Conservation Act (1995) and Environment ConservationRules (1997), World Bank Operational Directive (OD) 4.01 on Environmental Assessment of 1989,as well as other ODs and Operational Policies (OPs) which may be of relevance to SIPP.
Many of these small-scale subprojects are not expected to lead to environmental impacts of anysignificance. However, some subprojects may have environmental ramifications, where proposedmitigation measures may not be adequate, or result in adverse impacts in case proposed mitigationmeasures are not adequately implemented To avoid potentially adverse environmental impacts, allproposed requests for funding subprojects will be subject to an environmental screening exercise.
2.1 Purpose of this Document
This document provides an assessment of the potential environmental implications of the proposedproject and a manual for carrying out environmental assessment of the sub-project investments thatare envisaged under the project. The report sets out the various procedures required by SDF toreview the subprojects for their environmental ramifications, in accordance with Government ofBangladesh (GOB) regulations and World Bank Operational Directives and Operational Policies. Tofacilitate the SDF operations, and promote transparency and accountability, these procedures havebeen standardized for environmental screening.
2.2 Methodology for Preparing this Report
This report was first produced in 1999 and then updated in 2002. The manual is based on thefeedback from wide consultation with key stakeholders. Information about the project design wasobtained from SDF and the World Bank sector specialists based in Dhaka, and about social funds
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from World Bank publications on Social Development Funds in Peru, Eritrea, Egypt and Pakistan(World Bank 1996b,c,d; 1998b). Extensive use was made of the Bank's "Environmental Guidelinesfor Social Funds" (World Bank, 1998a), which provides a clear format for environmental assessmenton all World Bank funded social development projects. General information about environmentalassessment and Bank guidelines were obtained from the Environiental Assessment Sourcebooks(World Bank, 199 1a,b,c), and various Sourcebook Updates. Background information about the targetgroup was obtained from the SIPP Social Assessment Team from Dhaka University. Infomiationabout NGOs and environmental assessment was obtained from Mahtab (1993), information from theSocial Assessment Team, and from the field visits (see below).
Information about existing EIA regulations in Bangladesh was obtained from Farooque (1993), andfrom the recent publications by Syed (1998) and BCAS (1999) on the Environment Conservation Act(1995) and the Environment Conservation Rules (1997). Various institutes and (semi-) governmentagencies were visited in order to obtain existing sectoral EIA guidelines. These guidelines wereavailable on water resources (LGED, undated), physical planning (LGED, 1994), solid wastemanagement (ITN Bangladesh, undated) and efficient fuel use (IFRD, undated).
The Environmental Assessment forms (Forms I-V) included in this document (Appendices I-V) weretested in the field by the Arcadis Euroconsult team, on existing social development projects atTangail (9/12/98) and Netrakona (10/12/98). Several local NGOs' were involved in testing theseforms, to assess if these were suitable for use by potential end users. Based on their findings, theseforms were modified and tested during a second round of field visits, this time in Gaibandha (21-22/12/98) and Pabna (23/12/98). Again, several NGOs2 were involved in the field-testing of theseforms. Following translation of these forms, they were tested a third time, with the Buro Tangail, anNGI operating in Tangail District. The translated forms (+ instructions) were tested for the final timewith Sabalamby Unnayan Samnty, an NGO based in Netrokona. The field-testing were successfulindicating that the instruction manual and EA forms are appropriate and workable.
2.3 Project Areas
The two project districts represent the poorest regions of the country According to the BangladeshHuman Development Report 2000 prepared by Bangladesh Institute of Development Studies (BIDS)for GOB, these two districts score high Human Poverty Index (HPI) and Income Poverty Index (IPI)values. Jamalpur scored above 50 in HPI and IPI while Gaibandha ranks above 50.1 in IPI and HPI isbetween 40.5 and 50
Table 1 - Project Area Profile
Districts Area Household Population Upazila Union Village Municipality(sq kmn) (numbers) ('000)
Gaibandha 2,179 372,467 1,949 7 82 1,230Jamalpur 2,032 379,545 1,874 7 67 1,362 2
2.4 Environmental Profile: Jamalpur3
The district of Jamalpur falls under Dhaka division. Kurigram and India lay to its north, towards itseast are Sherpur and Mymensingh. Tangail is to its south and towards it's west lay Sirajgonj, Bograand Gaibandha zilas It has a total area 2032 sq Kms, of which 150.01 sq Km is riverine and 18.16 sqkm is forested According to the 1991 census, its population is about 1,874,440, of which 88% livein rural areas. Around 0.25% of the population are tribal, mostly Garos. The land is alluvial
' In Tangail Buro Tangail, and in Natrakona Sabalamby Unnnayan Samily.2 In Gaibanda: Gano Unnayan Kendra, and in Pabna Bachtcchai Samaj Unriayan Samity and CARE3Sources of Data BBS Bangladesh Population Census Series on Jamalpur, 1994, various pages, and WARPONational Watcr Management Plan, Volume 6 Environment, pages 6 to 39
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floodplains and is prone to regular flooding by the Jamuna. The range of habitats includes openfields, artificial and natural water bodies, wetlands, rural villages, homesteads, sandbanks anduncultivated charlands.
Rivers: Jamalpur is located on the banks of the Jamuna and is a part of the country's largesthydrological region. The Old Brahmaputra river cuts across Jamalpur . it takes off from the left bankof the Brahmaputra to the north of Bahadurabad. It passes through Jamalpur and Mymensingh andfalls into the Meghna at Bhoirab Bazaar. Its right bank is higher than it's left bank throughout most ofits course. It's off-take, the Jinal nver, takes off at Jamalpur and joins the Chatlai channel of theJamuna and joins the Jamuna at Sharishabari.
Water Resources: The seasonal pattern of river levels in the monsoon season normally shows aninitial peak caused by in-country rainfall in June/July and a second peak resulting from cross-borderflows in late August/early September. Major flows occur in the Jamuna and Old Brahmaputra andflood levels are increased by the backwater effect from the Ganges/Padma. Surface water pollution isnot an acute problem in Jamalpur.
Forests: There are some forested areas in Jamalpur. While the exact number of species of flora andfauna native to Jamalpur is not known, there are some areas of Sal forests. However, increasingtrends in deforestation is causing soil erosion problems.
Main Environmental Concerns: The key environmental concerns for Jamalpur (as well as the NorthCentral region of the country) include:
o Flooding;o Drainage;o River bank erosion;o Surface water quality;o Seasonal fluctuations in ground water table.
2.5 Environmental Profile: Gaibandha 4
The district of Gaibandha falls under Rajshahi division. Fonnerly it was a sub division of theRangpur district. Kurigram and Bogra lay to its north, towards its east are Kurigram and Jamalpur.Bogra is to its south and towards it's west lay Joypurhat, Dinajpur and Rangpur zilas. Galbandha'stotal area is 2179 sq Kms, of which 150 sq Km is riverme. According to the 1991 census, itspopulation is about 1,949,274, of which 93% live in rural areas. Around 0.4% of the population aretribal, mostly Garos and Sautaals. The land is alluvial floodplains and is prone to regular flooding.
Rivers: Gaibandha is a part of the country's largest hydrological region. The Ghagat, Dhaljan,Jomuneshwari and Sarbamangla are the major river in and around Gaibandha. The Ghagat is atributary of Teesta and it flows past Rangpur and Giabandha and joins the Brahmaputra at Fulcharighat. A distributary's of Ghagat flows south through Gaibandha. The Ghagat is a sluggish stream,while the Bangali river has a larger flow.
Water Resources: Gaibandha suffers from a shortage of surface water during the summer monthsAdditionally this resource is at risk of contamination due to low prevalence of sanitary latrines andfrom planned industrial development. The Northwest region of Bangladesh is generally rich ingroundwater sources and generally the incidence of arsenic contamination is lower than otherregions. According to the BGS data, tube wells in Gaibandha have a 7% rate of contaimnation. Themain area of concern in this region is the high rates of groundwater abstraction durng the dry season,as the rivers tend to dry up, compounded by low rainfall. However, according to the National Water
4 Sources of Data BBS Bangladesh Population Census Series on Gaibandha, 1994, various pages, and WARPONational Water Management Plan, Volume 6 Environment, pages 6 to 39.
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Management Plan, Gaibandha is not at risk of groundwater table dropping below 7m of the suctionpoint.
Forests: There are no major forested areas in Gaibandha. The only reserve forest North West regionof Bangladesh is situated in Dinajpur. There are a few other important areas of natural environment,however, most of the landscape and wetlands of this region have undergone massive transformationand exploitation Wildlife, flora and fauna have suffered considerably.
Main Environmental Concerns: The key enviromniental concems for Gaibandha (as well as theNorth west region of the country) include
* River bank erosion;* Seasonal fluctuations in ground water table;
Fish and fisheries resource management,* Flooding;* Drainage, and* Groundwater quality
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3. LEGAL FRAMEWOR FOR ENVIIRONMENTALMANAGEMENT AND) ENVRONMENTAL EMPACT
ASSESSMEN7T
3.0 Environmental Legislation in Bangladesh
A wide range of laws and regulations related to environmental issues are effective in Bangladesh.Many of these laws are cross-sectoral, however, and only partially related to environmental matters.Some of the most important legislations are:
o The Canals Act, 1864o The Irigation Act, 1876o The Private Fisheries Protection Act, 1889o The Agnculture and Sanitary Improvement Act, 1920o The Forest Act 1927o The Tanks Improvement Act, 1939o The Protection and Conservation of Fish Act, 1950o The Embankment and Drainage Act, 1952o The Agricultural Pest Ordinance, 1962o The Agncultural Pesticides Ordinance, 1971o The Wild Life (Preservation) (Amendment) Act, 1974o The Environment Pollution Control Ordinance, 1977o The Environment Conservation Act, 1995o The Environment Conservation Rules (under the ECA, 1995), 1997.
The most important of these are the Environment Conservation Act, 1995 (ECA, 1995), and theEnvironment Conservation Rules (of this Act), 1997 (ECR, 1997). The ECA 1995 is primarily aninstrument for establishing the Department of Environment (DoE), and for controlling industrialpollution.5 The Act also defines in general terms that if "any particular activity is causing damage tothe eco-system... the person responsible <will have to> apply corrective measures". Until theappearance of ECR, 1997, enforcement of the Act was not possible, as many of the clauses refer tospecifications spelled out in the Rules.
3.1 Environmental limpact Legislation in Bangladesh
Under the ECR, 1997, a wide range of industries and projects are listed in four different categories,depending on the extent of impact on the environment, and the accompanying complexity ofobtaining an Environmental Clearance from the DoE. The four categories are: Green, Orange A,Orange B and Red. Green category industries, which includes toy and TV assembly plants, matmaking plants, and various packaging industries, are to be granted Environmental Clearances within15 days. The Green Category Schedule does not list specific projects. For proposed industries andprojects in categories Orange A & B and Red, an application for Environmental Clearance is to beaccompanied by a Feasibility Report, Initial Environmental Examination (IEE), and for industries,also a Process Flow Diagram and Layout Plan. For Red Category industries and projects, the IEEreport is also to include a Terms of Reference for the Environmental Impact Assessment (EIA). Forfinal approval and issuing of an Environmental Clearance for Red Category industries and projects,an EIA report is also required. The ECR, 1997 lists the contents required for both IEE and EIAreports. Table 2. lists project types included in the ECR, and their ECR environmental impact
5 "Law Enacted for Conservation, Improvement of Quality Standard and Control, and Mitigation of Pollution of theEnvironment".
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categories. Only projects similar to subprojects that may be included in the SIPP are listed here It isto be noted that initially SIPP does not expect to fund all of the options discussed below. Theseoptions have been included here in order to provide guidance in case these options are taken up laterin the project cycle
Table 2 - ECR Environmental Impact Categories of SIPP Subprojects(Projects and Categories as Listed in the ECR)
Green Category Orange A Orange B Red
Automatic Environmental Environ m ental Environmental Clearance RequiresApproval of Clearance Clearance Requires IEE, IEE, Feasibility Report, EIA
Environmlental Requires IEE, Feasibility ReportClearance Feasibility Report
. No Projects * Small-scale . Mcdium to Largc * Power Plants4
Listed in the Cattle or Scale Cattle or . Earth Filling,ECR (Only Poultry Poultry Farms3
* Industrial, Domestic,Industries) Farmns* . Feeder Road or Local Commercial Waste4
Street Construction . Sewerage Treatment Plant4
* Bridge Construction * Hospitals(<lOOm length) . Water Trcatment Plant**
* Public Toilets * Water/Electricity SystemExtension
. Flood Control Dam, DikeConstruction or Extension
* Poultry and caile farnis will not be directly funded by the SIPP as they are commercial enterprises Stocking ofconimunal ponds with fish may be inicluded. as this is deemed to befor subsisienice. and notfor conmmercial purposesFish farnniig is inot included in the ECR, 1997 schedules, but may be conisidered sinilar to poultir and cattlefariming,i e smiall scalefishfarming in calegory Orange A. and large scale in Orange B.
** Projects proposed under the SIPP do not include large-scale investments such as hospitals, large landfills, water andsewerage treatment plants or power plamits However similar projects of a (iuchl) smaller scale are envisaged such ascli,iics, small power-generating units (diesel powered), small solid ivaste disposal systems and systemsfor disposing ofsewage Because of the difference in scale, such SIPP subprojects are likely to be assignied to the Oranige Categomy
While the Environment Conservation Act and the Environment Conservation Rules cover manyenvironmental issues, there are areas of ambiguity Environmental protection is deemed particularlyrelevant in "Ecologically Critical Areas", which are designated by the Government as areas wheredegradation of the environment has reached or threatens to reach a critical state Specifically, theGovernment will take into consideration areas such as human settlements, ancient monuments,archeological sites, Forest Sanctuaries, National Parks, Game Reserves, wildlife habitats, wetlands,mangroves, forested areas, biodiversity areas, and other simnlar areas. However, these types of areasare not defined, and in practice this guideline will be very difficult to enforce. Wetlands, for instance,are not defined, and using the definition adopted by the Ramsar Convention6 would include morethan half of Bangladesh
3.2 International Environmental Conventions, Treaties and Protocols
Bangladesh is party to an array of international environmental conventions, treaties and protocols,which may affect the implementation of SIPP projects in cases where these threaten to impinge upon
6 The "Convention on Wetlanids of Initernational Importanice, especially as Waterfowl Habital", or Ramsar Convention, as itis commonly called after the place of adoption in Iran in 1971, defines wetlands as "areas of narsh,fen, peatlaid or water.whether niatural or artificial, pernianent or teniporary , with water that is static orflowing, fresh, brackish or saline.including areas of marinie water, the depth of which at low tide does not exceed six netres"
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these agreements. These agreements are summarized for the Bangladesh context by Islam (1996),and include:
o International Plant Protection Convention, Rome, 1951 (Ratified 1978)o International Convention for the Prevention of Pollution of the Sea by Oil, London, 1954
(Ratified 1981)o Convention on Wetlands of International Importance, especially as Waterfowl Habitat,
Ramsar, 1971 (Ramsar Convention) (Ratified 1992)o Convention Concerming the Protection of the World Cultural and Natural Heritage, Paris, 1972
(World Heritage Convention) (Ratified 1983)• Convention on International Trade in Endangered Species of Wild Fauna and Flora,
Washington, 1973 (CITES Convention) (Ratified 1982)o Montreal Protocol on Substances that Deplete the Ozone Layer, Montreal, 1987 (Ratified
1990), (London Amendment, 1990) (Ratified 1994)o Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their
Disposal, Basel, 1989 (Ratified 1993)o Umted Nations Framework Convention on Climate Change, New York, 1992 (Ratified, 1994)o Convention on Biological Diversity, Rio de Janeiro, 1992 (Ratified 1994).
In relation to the SIPP, the Ramsar Convention is the most relevant as apart from protection ofinternationally important wetlands (Ramsar Sites7), signatories of the convention are bound to adhereto the "wise use of wetlands". Draining and converting wetlands, using them as land-fills for solidwaste, polluting them with agrochemicals or human waste, blocking of streams and rivers, are allexamples of unwise use of wetlands that could occur if the SIPP were not to follow stringentenvironmental procedures
3.3 Sectoral Environmental Guidelines in Bangladesh
Sectoral Guidelines for environmental assessment and for conducting EIAs in Bangladesh weredeveloped well before the issuance of Environment Conservation Act (1995) or the establishment ofthe DoE. These Guidelines were developed by government agencies such as the Local GovernmentEngineering Department (LGED), and programs such as the Bangladesh Flood Action Plan.
The Bangladesh Flood Action Plan (FAP) produced guidelines for conducting EIAs, specificallytailored to address developments proposed under this program (FAP, 1992). These developmentsincluded embankment construction, drainage, dams and dikes. The LGED developed sectoralguidelines on environmental issues related to physical planning in rural areas, which cover:
o potential impacts of rural roadso potential impacts of irrigation schemeso potential impacts of drainage and embankment projectso small scale water resources development projects.
Details are provided by LGED (1994) for conducting and evaluating IEEs and EIAs, and fornats areprovided for both. In addition, questionnaires are provided for field assessment of the potentialenvironmental impacts of various infrastructure projects.
In essence, the IEE includes a number of checklists, upon which the person(s) assessing the impact ofa project can indicate (by ticking a box) per environmental parameter, what the type and magnitudeof the impact may be: positive, no impact, or a low, moderate or severe adverse impact. If one or
7Bangladesh has two designated Ramsar Sites, namely part of the Sunderbans mangrove forest and Tangoar Haor
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more impacts are moderate or severe, an EIA will be required, otherwise the IEE serves as the EIAand the project has met LGED requirements for approval
3.4 The World Bank and Environmental Assessment
The World Bank has several policies goverming environmental assessment (EA) of projectsOP/BP/GP 4.01, issued in January 1999, is the central document that defines the Bank's environmentalassessment requirements. Tuis directive outlines Bank policy and procedures for the environmentalassessment of Bank lending operations Environmental consequences should be recognized early m theproject cycle and taken into account in project selection, sitmg, planning, and design by preventing,minimizing, mitigating or compensating for adverse environmental impacts and enhancing positiveimpacts. EA includes the process of mitigating and managing environmental impacts throughoutproject implementation. The Environmental Assessment Sourcebook (World Bank 1993a, 1993b and1993c) and its updates (e.g. World Bank, 1996a; 1997a; 1997b) provide technical guidance on theseissues
The World Bank has mandatory EA guidelines in the form of OPs. In addition to OD/BP/GP 4 01,there are other directives that cover a number of specific environmental issues, including:
* Conservation of Natural Habitats (OP 4.04): The Bank does not support projects involving thesignificant conversion of natural habitats unless there are no feasible alternatives for the projectand its siting, and comprehensive analysis demonstrates that overall benefits from the projectsustainably outweigh the environmental costs. If the EA indicates that a project significantlyconverts or downgrades natural habitats, the project must include mitigation measures acceptableto the Bank.
* Pest Managemenit (OP 4.09): This policy supports safe, effective, and environmentally soundpest management. It promotes the use of biological and environmental control methods. In Bank-financed projects, pest management is carried out by the borrower, usually as part of the project'senvironmental assessment. An assessment is made of the capacity of the country's regulatoryfraniework and institutions to promote and support safe, effective, and environmentally soundpest management
* Indigenous Peoples (OD 4.20): This directive provides guidance to ensure that indigenouspeoples benefit from development projects, and to avoid or mrtigate adverse effects of Bank-financed development projects on indigenous peoples. Measures to address issues pertaining toindigenous peoples must be based on the informed participation of the indigenous peoplesthemselves.
* Involunttary Resettlement (OD 4.30): Involuntary resettlement as used in this policy covers both(a) the involuntary displacement (physical and nonphysical) of affected people that arises fromchange in land or water use, loss of productive assets, or loss of income or means of livelihood,whether or not the people must move to another location; and (b) the measures for mitigating theimpacts of displacement. The policy applies whether or not the Bank is financing the part of theproject that may require involuntary resettlement, and it covers resettlement resulting fromactivities that are not part of the Bank-financed project, but are necessary to achieve theobjectives of the project. Displaced persons are assisted in their efforts to improve their formaleducation levels, income-earning capacity, and living standards, or at least restore them to thelevels they would have been without the project.
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o Management of Cultural Property (OPN 11.03)8: Bank policy is to assist in the preservationof cultural property where it is part of a Bank-financed operation, and to avoid its destruction.The Bank normally declines to finance projects that will significantly damage irreplaceablecultural property, and assists only projects that are sited or designed to prevent such damage.
o Forestry Maniagement (OP 4.36): The policy statement provides guidance to Bank staffinvolved in forestry projects, detailing that the Bank will not finance commercial loggingoperations or acquisition of equipment for use in primary moist tropical forests; in forests ofhigh ecological value, the Bank will finance only preservation and light, non-extractive uses offorest resources. Objectives are to provide for a sustainable stream of direct or indirect benefitsto alleviate poverty and to enhance community income and environmental protection.
Particularly useful Sourcebook Updates related to environmental issues include
o No. 1 The World Bank and Environmental Assessment: An Overview (1993)o No 2 Environmental Screening (1993)o No. 5 Public Involvement in Environmental Assessment: Requirements,
Opportunities and Issues (1993)o No.7 Coastal Zone Management and Environmental Assessment (1994)o No.8 Cultural Heritage in Environmental Assessment (1994)o No 11 Environmental Auditing (1995)o No.14 Environmental Performance Monitoring and Supervision (1996)o No.16 Challenges of Managing the EA Process (1996)o No.17 Analysis of Altematives in Environmental Assessment (1996)o No.18 Health Aspects of Environmental Assessment (1997)o No.19 Assessing the Environmental Impact of Urban Development (1997)o No.20 Biodiversity and Environmental Assessment (1997)o No.21 Environmental Hazard and Risk Assessment (1997)
3.5 The Bank's Environmental Screening Process
A screening process for all World Bank projects classifies them into one of three environmentalassessment categories (World Bank, 1993a). Projects in Category "A" potentially cause significantand irremediable environmental impacts. Category "B" projects cause lesser impacts, which are oftenessentially remediable or mitigable. Category "C" projects can be expected to have little or noenvironmental impact. Category A projects require a full, detailed Environmental Impact Assessment,which needs to be approved before the Bank can give its support. Category B projects require theimplementation of an Environmental Impact Evaluation (EIE), which requires far less detail than anEIA. Category C projects do not require an EIE or EIA.
The potential subprojects under the SIPP are classified as Category "B" because as a whole they mayresult only small-scale, and remediable impacts. Upon closer scrutiny, most subprojects are likely tobelong to Category C, some will be assigned to Category B, and subprojects that are classified asCategory A will not be eligible for funding.
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4. ENVIRONMENTALLY POSITIVE SUB-PROJECTS
4.0 Overview of Environmentally Positive Sub-projects
The proposed project will support approximately 1,800 small subprojects (with average cost notexceeding US$6034), many of which will have little or no effect on the environment, while some mayhave linmted negative environmental impacts. Subprojects that affect the environment in a positiveway, for example by addressing environmental degradation or reducing impacts on natural resources,are included in the manu of sub-project options in SIPP. An overview of environmentally positivesubprojects is provided below in Table 1.
Experience with these types of sub-projects implemented elsewhere in the world has shown,however, that even apparently environmentally benign projects have the capacity for inflictingenvironmental damage if not properly designed or inadequately followed up with training andawareness activities. Potential problems may arise due to oversight, indirect impacts, or cumulativeimpacts of positive projects.
Table 1 - Overview of Environmentally Positive SIPP Sub-projects
No. Type of Sub-project
A Drinking water upgrading of existing facilities or rehabilitation ofvillage reserve ponds, rainwater harvesting in arsenic-affected areas
B Sanitation pit latrines (mceting strict design criteria)C I Minor construction repair of existing cominunity buildingD Electrical supply linking up with existing gridE Awareness RaisingF Community Development
A. Driikitng Water Supply: Providing access to arsenic-free drinking water has been a majorfocus in Bangladesh. Although about 96% of the rural population have access to water supply, it isunfortunate that many of the tube-well water is affected by levcls of arsenic that are high enough toaffect human health It is estimated that some 16 million people are currently at risk, especially in thesouthern and northwestern part of the country, and some 30-40% of the country's area is affected(EGIS II, 1998) The village reserve pond system has largely broken down, and these ponds havebecome multi-purpose ponds, used for washing, bathing, duck keeping, jute retting and as fishponds.It is expected that the SIPP will support subprojects aimed at providing safe drinking water, forexaniple, to replace arsenic contaminated tube-well sources
Environientally positive subprojects may include the rehabilitation of village reserve ponds,upgrading of existtng wells and the provision of rainwater collection/storage facilities. As these typesof projects involve improvement of existing facilities, or simply supplying water storage tanks9 , thiswill result in improved access to good quality drinking water (and positive impacts for human health),without the negative impacts that may result from installing new facilities (e.g new ponds or wells).
B. Latrines: Only a small proportion of the population of Bangladesh have lavatories connectedto waterbome sewerage systems, and it is estimated that in Dhaka, for instance, access is limited toabout 15-18%. Outside Dhaka sewerage systems are poorly developed or non-existent. About 70-80%
9 Water storage tanks here refer to aboveground vessels or containers, consisting of plastic, fiberglass, ferro-cement orconcrete, that serve to store run-off collected from roofs.
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of Dhaka's population depends on pit latrines for human waste disposal Countrywide, about 43% ofthe rural population has access to latrines, while in urban areas coverage is about 50%. Provision ofaccess to sanitary latrines has a high priority because of the health risks associated with unsanitarydisposal methods. Environmental impacts are normally positive, but improper design and operationsmay lead to contammnation of groundwater, drinking water, and surface waters (see 4.2).
C. Minor Construction Sub-projects: The small-scale infrastructure construction subprojectsthat are likely to have only positive environmental impacts are those involving the rehabilitation ofmarkets, sidewalks and pedestrian bridges. Certain basic safety requirements will have to be observedto avoid accidents, and any waste material must be disposed of in an environmentally responsiblemanner.
D. Electrical Supply Systems The Rural Electrification Board (REB), which was established in1977, aimed to provide electricity to all rural areas by 1995, in order to cut pressures on fuel woodsupplies. By 1992, however, REB was only able to meet 43% of rural demand (Hasan & Mulamoottil,1994), and this is unlikely to have advanced beyond 50% at present. SIPP may support small-scaleelectrification schemes linking up of a community to an existing power grid Providing electncitywill reduce the need for using fuel for lighting (including the use of wood, petroleum, oils), andimprove lighting conditions in general.
E. Awareness Raising: Awareness raising on sanitation practices, nutrition and generalenvironmental issues are likely to have only positive environmental impacts, since these focus onmaking the people conscious of healthy living. These activities will be targeted at the poorest andvulnerable groups in the project areas.
F. Community Development: Community development subprojects will generally have apositive environmental impact, especially if they primarily focus on women and women's groups, theelderly, and on the physically or mentally disabled.
5. ENVIRONMENTAL IMPLICATIONS OF THE SIPP
5.0 Potential Environmental Impacts of the SIPP
SIPP will fund different types of subprojects, and likely examples are listed in Appendix III. Many ofthese projects will have little or no effect on the environment. Experience that even apparentlyenvironmentally benign projects have the capacity for inflicting environmental damage if notproperly designed or inadequately followed up with training and awareness activities Suchenvironmental impacts may be due to oversight, indirect impacts, or cumulative impacts
5.1 Oversight
Certain aspects of project design and follow-up may be neglected, or are insufficiently emphasized.In El Salvador, for example, on a project consisting of the construction of compost latrines, thebeneficiary community did not receive proper guidance on the care and maintenance of the facilities.Consequently, the comiipost was removed before it had time to decay sufficiently and allow theanaerobic conditions to kill infectious bacteria. As a result, the compost caused human healthproblems when used as a fertilizer on gardens, or when deposited as refuse near the homestead(World Bank, 1998a).
5.2 Indirect Impacts
A SIPP subproject may set in motion a chain of events that may end up having significant impacts onthe environment. A typical example is rehabilitate an existing road The upgrading of the road itselfmay have negligible impacts, but it simply facilitate the extraction of natural resources by providingaccess to trucks. Development of markets without proper drainage system can indirectly result inhealth problem due to stagnant water
5.3 Cumulative Effects
Because the SIPP will fund a large number of small subprojects, the question of cumulative impactsmerits special consideration While individual subprojects may have a negligible impact, thecumulative effect of many small subprojects in a particular area may be significant For example,large numbers of tubewells in a limited area may significantly affect groundwater levels by depletingaquifers, even though the effect of a single tube-well in a small community may be negligible.
Many of the subprojects will result in upgrading of local conditions, and lead to an increased value ofproperties. For example, provision of safe drinking water, latrines, a better road and electricity willadd to the value of a particular property. If ownership rights are unclear, or if a property is leased, thismay lead to ousting of the intended beneficiaries of the subproject. This may be indirect, for example,if the landowner increases the tenancy or lease rates to beyond what can be afforded by thesubproject recipient.
5.4 Environmental Impacts of Various Sub-project Types
Appendix IV summarizes typical impacts that may result from subprojects that may be funded by theSIPP, and summarizes mitigating measures that may be taken to prevent or minimiuze these impactsNote that this list is not comprehensive but includes only main impacts that may occur Minor,temporary impacts such as noise and dust production during construction have not been included
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Regarding resettlement and compensation, the approach by SIPP will be in line with OD.4.30. SIPPwill not finance either land acquisition or compensation for resettlement, either to individuals orgroups.
Rural Roads: Rural road projects under the SIPP will mainly involve repair and upgrading. Roadrehabilitation and maintenance subprojects of such small scale usually do not result in significantimpacts on the environment Nevertheless, impacts may arise, such as land erosion along the roadbeddunng construction, stagnant pools of water left in borrow areas, or increased traffic accidents duringoperation. Typical impacts resulting from rural road subprojects, and ways by which these can bemitigated, are summarized in Appendix IV.
Foot Bridges: Small-scale bridge construction is expected to be supported by the SIPP. Suchstructures will include shore-to-shore suspension spans and permanent structures with a pier supportbridge. Materials will include poured reinforced concrete, steel support beams, timber andcombinations of these materials. Typical impacts resulting from bridge subprojects, and ways bywhich these can be mitigated, are summarized in Appendix IV.
Drinking water Supply: SIPP will support subprojects to replace arsenic contaminated tube-wellsources. Initially, technical options include community tubewells, dug-wells, rainwater harvestingtechnology and small surface water filters. Most of the environmental considerations with regard towater supply subprojects involve avoiding water contamination, and measures need to be taken toensure good water quality, both directly after construction and during long-term operation. The latterwill involve avoiding contammnation from agricultural sources, livestock, poultry and human waste.Typical impacts resulting from drinking water supply subprojects, and ways by which these can bemitigated, are summarized in Appendix IV. Regarding the arsenic problem, SIPP should liaise withthe World Bank funded Arsenic Project that has just been initiated by the Department of PublicHealth Engineering in Dhaka. If new tube-wells are to be constructed, there should be coordinationwith BWDB, as aquifer depletion may become a problem in some areas, especially as a cumulativeresult of many small water abstraction (sub-)projects supported by SIPP or other programs.
Latrines & Sewerage Systems. Provision of access to sanitary latrines has a high prionty because ofthe health risks, and it is likely that SIPP will support proposals for latrine construction, tocompliment existing programs in this field. Environmental impacts are generally positive, butimproper design and operations may lead to contamination of groundwater, drinking water, andsurface waters. Pit latrines should be lmed, where possible, to prevent lateral seepage, and be locatedat least 10 meters from (tube-)wells. If possible, the bottom of the pit latnne should be located 2meters above the groundwater level; in much of Bangladesh this requirement is difficult to meet.Pipes leading from the latrine (i.e. "the squatting point") should be located at least 0.5 meters aboveannual high water levels, to avoid contamunation of surface waters during floods. In urbanenvironments, connection to an existing sewerage system might be considered under the SIPP
Low cost designs have been developed for both urban and rural pit latrines, lined with either concreteor bamboo, and brochures developed to increase sanitation Under this program, maps have beenproduced that combine soil type and flooding regime, and the intention is that, in the near future,latrine designs may be modified to meet local conditions. Typical impacts resulting from latrines andsewerage system subprojects, and ways by which these can be mitlgated, are summarized inAppendix IV.
Electrical Supply Systems: SIPP may support small-scale electrification schemes involving thelinking up of a community to an existing power grid. Environmental impacts associated withelectrification schemes are generally linked with accidents (electrocution). Electrification may alsolead to an influx of polluting (small-scale) industries. Impacts can be mitigated by means of anawareness campaign (regarding safety and polluting industries), and linking up the community with
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an existing grid during the dry season Sites for placing a diesel-powered generator should becarefully selected, and a concrete base provided to reduce the infiltration of oil
Training, Education, Institutional Strengtheninlg & Conunnuity Development: Training, education,institutional strengthening and community development subprojects are likely to receive support fromthe SIPP In general, such subprojects have a positive impact on the environment. However, aconsensus should be achieved beforehand as to whom is to benefit from such subprojects, in order toavoid social conflicts.
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6. ENVIRONMENTALLY SENSITIVE AREAS
6.0 Environmentally Sensitive Areas (ESA) in Bangladesh
Environmentally sensitive areas are defined by the World Bank (OP4.04; see also World Bank,1993a) as being "areas that are of significant value in their natural state", or areas that are of socio-cultural significance or sensitivity. Cultural or historical sites and densely populated urban centers areexamples of the latter category. In such areas, impacts tend to be more severe than elsewhere, andtherefore, extra precautions must be taken to avoid significant environmental impacts. In many cases,this will mean extra investments in mntigation measures, while in some cases these areas will simplyhave to be avoided, resulting, for example, in the abandonment of a project or the re-alignment of asection of road. For all projects that will potentially affect environmentally sensitive areas, an EIA islikely to be required.
Ecologically Sensitive Areas as defined by the World Bank (OP4.04) are areas that may containunique features, maintain key natural processes, support endangered, endemic or threatened plants oranimals and their habitats, or provide important breeding areas for wildlife. Some EcologicallySensitive Areas are natural, while others may have been significantly altered by certain humanactivities. In terms of management, some Ecologically Sensitive Areas will prosper through "benignneglect" while others will require intensive management to restore or maintain their natural values.Criteria given by the World Bank for Ecologically Sensitive Areas, and corresponding areas inBangladesh, are listed in Table 3 under categories A-E. Areas that are socio-culturally sensitive arelisted under categories F and G.
The Environment Conservation Act, 1995 and the Environment Conservation Rules, 1997, also referto Environmentally Sensitive Areas (called Ecologically Critical Areas in the legislation; see Chapter2). According to this legislation, environmental protection is deemed particularly relevant inEcologically Critical Areas, which are defined by the Government as areas where degradation of theenvironment has reached or threatens to reach a critical state. Specifically, under the EnvironmentConservation Act and Rules, the Government will take into special consideration areas such ashuman settlements, ancient monuments, archeological sites, forest sanctuaries, national parks, gamereserves, wildlife habitats, wetlands, mangroves, forested areas, biodiversity areas, and other similarareas. In practice, however, this piece of legislation is likely to remain toothless, as no definitions areprovided of these ESAs, and once a threat is removed (which is desirable) the area may theoreticallyno longer be deemed an Ecologically Critical Area.
6.1 ESAs and the SIPP
SIPP will not fund any sub-projects in ESAs without adequate mutigation measures.
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Table 2 - Environmentally Sensitive Areas in Bangladesh
Category Environmentally Sensitive Location in BangladeshAreas
A Areas that provide protection of Forests on steep watcrsheds generally thesesteep slopes, especially in areas occur in the Chittagong Hill Tractswatershed areas, against erosion.
B Areas that regulate and purify Wetlands 10 More-or-less permanent wetlandswater flow such as rivers, beels, haors, baors, dhours and
djeels, containing water at the height of the dryscason; + wetlands included in the Directory ofAsian Wetlands (Appendix VII)
C Areas that provide conditions Mainly Forest Reserves (esp the Sundcrbans)essential for the perpetuation of and important wetlands (listed in Directory ofspecies of mcdicinal and genetic Asian Wetlands, and Nishat el al 1993), but alsoconservation value unusual habitats such as St Martin's Island
(coral reef) See Appendix VIID Sites that maintain conditions Mainly Forest Reserves (esp. the Sunderbans)
vital for the perpetuation of and important wetlands (listed in Directory ofspecics that enhance the Asian Wetlands, and Nishat et al 1993), but alsoattractivencss of the landscape or unusual habitats such as St Martin's Islandthe viability of protected areas (coral recf) Sec Appcndix VII
E Sites that provide critical habitat Freshwater and coastal wetlands, sites recordedthat threatened species use for in the Directory of Asian Wetlands (seebreeding, feeding or staging Appendix Vll)
F Areas of cultural or historical Graveyards, tombs, forts, mosques, temples,significance churches, ctc
G Areas that are denscly populated All urban centersand are important for humanhabitation
When information about the SIPP is dissemunated to potential recipient communities, backgroundinformation about ESAs (and how projects should avoid impinging on these areas) must be included,to avoid formulation of proposals that will face rejection on these grounds. Nevertheless, allproposals should be screened for possible adverse effects on ESAs, and to detemnune this, a simpleform has been designed (Appendix II) which requires only basic knowledge of ecology and EIA Inthe absence of an official MoEF definition of ESAs, the following criterion have been developed forSIPP and it is recommended that subprojects should be redesigned if they occur:
* on steep slopes (slope >30%)* in or directly adjacent (<10m distance) to a (more-or-less) permanent freshwater wetland such
as a river, streamn, beel, djeel, dhour, etc* on an unstable char* in or directly adjacent (<10m distance) to marine or estuarine wetlands, such as mangroves,
saltmarshes, dunes, creeks, beaches or mudflats* in or directly adjacent (<10 m distance) to a significant stand of natural vegetation (e.g forest,
reedland, mangrove, swamp forest)* on an unstable marine island
10 Using the Ramsar Convention dcfinition of wctlands is untenable, as these areas extend over half of the country Evensemi-pemianent wetlands such as rivers, beels, haors, baors, dhiours and djeels, extend over about 6.9 milliol ha, or 48% ofthe country (Khan ei al, 1994) A narrower definition of (more-or-less) permanent wetlands, is therefore used here
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o in or directly adjacent (<lOm distance) to a gazetted Forest Reserve, Game Reserve, orNational Park
o in or directly adjacent (<lOm distance) to a site, building or monument that is of cultural orhistorical significance (e.g. graveyard, mosque, temple, tomb).
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7. ADMINISTRATIVE STRUCTURE FORENVIRONMENTAL ASSESSMENT IN THE
SIPP PROJECT CYCLE
7.0 Environmental Assessment Procedures in SIPP
The Social Investment Program as a whole has been designated as "Category B" by the World Banki.e. with moderately significant environmental impacts, which are often essentially remediable ormutigable (World Bank, 1991a,b,c, 1993b). The vast array of subprojects will include many that haveonly positive or no environmental impacts, or have only minor impacts (these are essentially"Category C" projects). A simple screening process was devised to filter out Category C projects atan early stage, to avoid unnecessary detailed environmental assessments. Also, the screening processis designed to identify at an early stage potential "Category A" subprojects, that may potentiallycause significant irremediable environmental impacts. "Category A" subprojects will not be fundedunder SIPP In addition, guidelines are provided for avoiding cumulative effects of numerous small-scale subprojects, that when taken on an individual basis are exempt from EA because of their lowimpact, but as a whole may have a significant environmental imipact. These guidelines will form anintegral part of the Operational Manual.
7.1 Environmental Assessment in SIPP Project Cycle
All subprojects proposed for financing under the SIPP will be subjected to an environmentalassessment, in order to:
* prevent execution of projects with significant negative environmental impacts,* decrease potential negative impacts through adaptations in subproject design, location or
execution,enhance the positive impacts of subprojects;
* prevent additional stress on environmentally sensitive areas.
During screening, SIPP subprojects will be classified as categories C+, C, B or A, which will requirean Environmental Review (C+ & C), Limited Environmental Assessment (B). Details of these areprovided in this chapter.
This document includes an "Instruction Manual for Environmental Assessment of SIPP subprojects",along with the required forms I-V for enviromnuental management of the subprojects. The forms areincluded in Appendices I-V of this report; the English version of the manual is attached as AppendixVI. Important Note. ALL APPENDICES/ FORMS NEED TO BE TRANSLATED TO BANGLA.
The environmental assessment procedure described in the manual consists of the following steps:
Step one. Filling out the Routing Slip (Form I) by the Project Management Committee (PMC)of the Community Group (CG)
Step two Filling out the Environmental Sensitivity Form (Form II) by CSOStep three: Filling out the Environmental Screening Form (Form III) by CSOStep four: Filling out the Environmental Review Form by CSO, orStep five: Filling out the Limited Environmental Assessment Fonr by environmental specialist.
Figure 1 illustrates how these various stages follow one another, and includes the various types ofenvironmental assessment required for the various screening categories.
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Figure 1 - Environmental Assessment and the SIPP Project Cycle
(if requircd, assisted by CSO)
Subproject proposal request for reformulation of proposal made byand Environmental CSO
Routing Slipprepared by PMC of
C G _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Environmental SensitivityAnalysis and Environmental candidates for design modificationScreening (ES) to determine (and lowenng EA category)ESA category (0,1,2,3) andEnvironmental assessment
category (C+, C, B or A) camedout by CSO
Categones C+ & C OR Categorv B OR Categorv A***
Environmental Limited Environmental AssessmentReview(ER) (LEA) bycarried out by Environmental Specialist (s)
CSO contracted by SDF's PAST
Appraisal by SDF Appraisal by SDFEnvironment Environment
Specialist Specialist |camed out by|____ _________________ SDF's PAST
Implementatio Implemen camed out byF I Community Groups
Supervision Supervio camed out byI | I | SDF's PAST
Monitoring & Monitonng & camred out byEvaluation Evaluation SDF's PAST and
Environmental Audit Environmental Audit camed out by(for 5% of (20-30% of Independent NGO
subprojects) subprojects) contracted by SDF
Category A Projects will NOT be eligible for financing under the SIPP
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7.2 Training for Adequate Environmental Management of SIPP
The Technical Officer and the Community Development Officers (CDOs) under SDF will require acertain level of envirornental assessment capacity in order to insure that environmental assessmentfor the subprojects are carried out in accordance with the Operational Manual, as well as making surethat mitigation measures are adequately implemented by the proponents. Similarly, the ProjectAppraisal and Supervision Team (PAST) team members and CSOs will also need someenvironmental awareness and environmental assessment skills. Therefore, it is recommended thatSDF organize two rounds of training on environmental safeguards and screening.
7.3 Round One: Training for the SDF staff
It is recommended that the SDF arrange for environmental training for the Technical Officer and the2 CDOs as soon as they are recruited. The SDF should contract out this training activity to anenvironmental agency which has proven experience in these areas. The environmental agency will beresponsible for holding a training workshop based on the SIPP Operational Manual requirements forenvironmental management of SIPP subprojects The training should focus on the environmentalroles and responsibilities of the Technical Officer and the CDOs, as well as responsibilities of thePASTs and CSOs The training should also highlight the environmental profile of the project areas aswell as Environmentally Sensitive Areas, cumulative impacts and the mitigation measures of negativeimpacts. After this training activity the Technical Officer should be able to train the CSOs and PASTmembers.
7.4 Round Two: Training for the CSO and PAST members
After the Teclnical Officer has received training, he/she should be able to train the CSOs and PASTmembers. The Technical officer may be assisted by the CDOs The training should focus on theenvironmental roles and responsibilities of the PASTs and CSOs. The training should also highlightthe environmental profile of the project areas as well as Environmentally Sensitive Areas, cumulativeimpacts and the mitigation measures of negative impacts. After this training activity the PASTmembers should be able to monitor and evaluate the environmental activities of the CSOs andCommunity Groups. The CSOs should be able to advise the PMC on how to fill out theEnvironmental Routing Slip using Fonr I of this manual. Most importantly, the CSOs should be ableto undertake Environmental Screening and Environmental Review and be adept at using Forms II, IIIand IV of this Manual.
7.5 Environmental Routing Slip by PMC of CG
Subproject formulation is to be done by the PMC for the CG. Each subproject proposal is supposed toinclude an Environmental Routing Slip (See form I) which is to be filled in by the PMC, after beingtrained by the CSOs on how to do this After the subproject proposal is completed, it will be reviewedby the CGs and VDC with facilitation by the CSOs. The CSOs will then undertake an EnvironmentalScreening of the subproject proposal.
7.6 Environmental Screening (ES) by CSOs
Environmental screening involves classifying a subproject into one of several categories of likelyenvironmental impact (World Bank, 1993b). Four subproject categories have been identified forSIPP.
* 'C+' those that have only positive or no environmental impacts, providing that they followstandard design prescriptions, requiring no special study other than a simple EnvironmentalReview;
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o 'C' those whose expected impacts are small in scale, do not require special study other than ER,and can be addressed through standardized environmental techniques or technical methods (asoutlined in Appendix IV);
o 'B' those whose impacts are larger and more complex, requiring preparation of a LimitedEnvironmental Assessment (LEA) and incorporation of recommended mntigation measures intosubproject design; and,
o 'A' those whose potential impacts involve significant environmental risk, and which will notreceive funding under the project.
Appendix III provides a Generic Subproject Screening Checklist for various subproject types thatmay be supported by the SIPP. While the list has 34 subproject types listed, it is not expected thatSIPP will fund such a great variety of project types. The additional types have been provided inAppendix II as simply a guideline. Each subproject type includes operations that are different in sizeand scope, and therefore are assigned to different scoping categories. Rehabilitation of existing pondsor dams, for instance, is classified as category C, construction of a new small pond category B andconstruction of a new large pond (>1 ha) as category A.
Step one in Environmental Screening involves classifying the subproject in terms of EnvironmentallySensitive Areas (ESAs). A form for determining ESAs is provided in Appendix II. The CSOs will betrained in using this form. Subprojects that are permussible for ESA categories 2 and 3 only, will notbe allowed in ESA categories 0 and 1. In the latter case, the subproject will not receive SIPP supportunless the proposal is reformulated. Reformulation can consist of either re-designing (e.g. upgradingof existing road, instead of new road), or re-siting (e.g. road located further away from affectedwetland than in orginal design).
Step one in Environmental Screening involves screening the subproject proposals for potentialimpacts. A form for determining this has been provided as Form III, which has space to record inwhich ESA categories a particular subproject type may be carried out. The CSOs will be trained inusing this form.
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Table 3 - Screening Categories
SIPP Action required SIPP World BankScreening Process before screening screening
subproject can category category*proceed
subprojects witlh positive environmental YES Environimlental C+ Cimpacts or without negative impacts on the Review (ER) by CSOenvironment
v NO
projects likely to have somc minor impacts YES Environmental C Con the environment but for which suflicient Review (ER) by CSOstandard mitigation measurcs have beenidentified
NO
projects that have some moderately YES Limited B Bsignificant environmental impacts, for which Environmentalmitigation measures can be readily identificd * Assessment (LEA)
NO
projects that potenitially have significant these projects will A Aimpacts on the environiment, (mitigation YES NOT be eligible formeasures may be identified, but there SIPP fundingremains a risk of significant impacts) *_
* World Bank (199la, 1993b)
7.7 Environmental Review (ER) by CSO
Environmental Reviews (ER) will be required for category C and C+ subprojects Most SIPPsubprojects are expected to require only an ER, which is the simplest level of environmentalassessment. CSOs will undertake Ers using Form IV of this manual. The CSOs will be trained inusing this form.
The ER will involve the use of the checklist whereby likely imlpacts of the subproject will beidentified along with appropriate mntigation measures proposed for the subproject. Completion of theER should not take more than lor 2 days as the ER is not expected involve lengthy fieldwork.
7.8 Limited Environmental Assessment (LEA) by Environmental Specialist (s)
Limnted Environmental Assessments (LEAs) will be required for Category B subprojects. An LEArequires more environmental expertise than an ER, and will have to be carried out by anenviromnental specialist (local consultant or NGO). Due to the limited scope of LEAs, completionshould not take more than a week, including fieldwork. A format for a LEA is provided inAppendix V.
7.9 Appraisal and Approval by SDF's PAST
Subproject proposals, Routing Slips, Environmental Review reports and Limited EnvironmentalAssessments will need to be reviewed by SDF. Therefore, it is recommended that SDF recruitsomebody who can fulfill the role of an Environmental Specialist. The duties of this person may becarried out by a PAST member in addition to her/his other duties
22
Desk and field appraisals should involve assessing if impacts have been correctly gauged, and if themitigation actions proposed are sufficient to alleviate the potential impacts. If shortcomings aredetected during the appraisal, the environmental assessment (usually a Routing Slip with attachedER, or LEA) should be returned to the subproject formulators, along with recommendations formodifying the proposal. After modifications have been made, the proposal and Routing Slip(Appendix I) with revised ER, or the revised LEA, may be re-submutted. If the appraisal assesses thatsufficient mitigation measures have been incorporated in the project design, the environmentalassessment of the proposal is to be approved by SDF.
As per GOB regulations, all subprojects require MoEF approval, but in practice this blanketrequirement of having to seek approval does not appear to be implemented for most public sectorprojects in Bangladesh. In this case, it is recommended that the SDF should have this environmentalassessment report and manual endorsed by the MoEF.
7.10 Implementation & Supervision by CSOs and PAST
Environmental supervision will be carried out by SDF's PAST, together with CSOs, so that stronglinks with field-based activities are maintained by the Foundation. The CSOs (see 6.5) will play apivotal role in project implementation and supervision, as they will be present on a daily basis, andwill stand to benefit directly from successful project implementation.
In theory, subproject supervision will require the preparation of a supervision plan (as required byOD 13.05 on Project Supervision), but for SIPP it would be more practical to lump together varioussubprojects (e.g on a subdistrict basis) under a joint supervision plan. The supervision plan can beprepared by the SDF's PAST, or its preparation contracted out to consultants, contractors or nationalNGOs.
During the construction or implementation phase, it is possible that certain unforeseen impacts mayoccur due to the subproject. If significant, these should be reported to the SDF's Technical Officer,along with proposed mitigation measures, if these are known, and a revised subproject budget. In theevent of non-compliance, the proponents of the subproject run the risk that the IndependentEnvironmental Auditors (see 10.3) will identify the problem and report this to SDF. In the case ofgross negligence, this may result in punitive actions such as non-payment of further installments.
7.11 Monitoring, Evaluation & Environmental Auditing by CDOs, PAST and IndependentAuditors
Environmental monitoring is directed towards measuring and evaluating changes brought about bySIPP subprojects, and assessing the effectiveness of the mitigation measures proposed in thesubproject design. SDF will not be involved in direct monitoring of the effects of subprojects oraggregates of subprojects (i.e. groups of subprojects), but carry out monitoring of the environment ingeneral. Procedures for monitoring and evaluation are described in detail in Chapter 9.
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8. ENVIRONMENTAL SUPERVISION, MONITORING &AUDITING
8.0 Environmental Supervision and Monitoring
Environmental monitoring is directed towards measuring and evaluating changes brought about bySIPP subprojects. In the case of the SIPP, environmental monitoring will focus on monitoring of theenvironment in general, rather than on the monitoring of impacts of individual SIPP subprojects, orthe cumulative impacts of many subprojects Monitoring of the environmental impacts of individualsubprojects is impractical, as the subprojects are often very small, there are very many of them, andthe costs entailed will be too great a burden Monitoring of cumulative environmental impacts will bedifficult, as in many parts of the country there are numerous projects going on simultaneously. Inmost cases, it will be nigh impossible to ascribe particular changes to certain (aggregates) ofsubprojects Monitoring of SIPP subprojects will not be abandoned entirely, as this is likely to lead tonon-compliance with environmental standards, but be addressed through environmental auditing (see10.3).
8.1 Environmental Baselines
For the purpose of monitoring and evaluation (e.g. via auditing), and monitoring of the environmentin general, the SDF needs to establish baselines of various environmental parameters, especially ofhuman health indices, water quality, water levels, forest cover and biodiversity
SIPP should not launch or undertake data gathering programs itself, but should make use of existingdata gathering/monitoring programs, for example, those of WARPO, CEGIS, Department ofFisheries, Ministry of Health, or national NGOs (see Table 6, below). For most parameters, datagathering programs already occur, but where they are absent, SDF may need to draft datarequirements so that this can be incorporated into existing data gathering programs, or included inother environmental prograimis, such as the UNDP-supported SEMP.
SDF needs to ensure that i) the data is useful and of a reasonable quality; n) mechanisms or channelsexist for obtaining data on a regular and timely basis; and in) the data is interpreted by, or on behalfof SDF
Through the above, changes in the environment may be identified by SIPP, and used to direct theprogram. For example, if a decline in forest cover emerges as the trend in a particular sub-district,SIPP may promote subprojects on reforestation, use of fuel efficient stoves, and electrification in thatparticular area Sinularly, if there is a significant decline in the incidence of gastro-intestinal diseasesfollowing a series of subprojects providing safe drinking water and promoting latrines, SIPP maydecide to promote these in other areas.
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Table 4 - Data Sources for the Monitoring Program
Parameter Agencies (to be) Ilnvolved Availability, and Mechanism by which this Datacan be Accessed
Physical
o Water Levels in Rivers o WARPO, BWDB, CEGISo Groundwater Levels o WARPO, BWDB, DPHE, CEGIS Io Water Quality in Rivers o WARPO, BWDB, CEGIS I Access via the National Water Sectoro Water Quality of Groundwater o WARPO, BWDB, DPHE, CEGIS Database, based at
I CEGIS and WARPO
o Extent of Surface Water Coverage o WARPO, CEGIS, SPARSSO Jo SPARSSO has surface water data (hardcopy
maps) of small waterbodies (1985) and larger
o Use of Agrochemncals o CEN, Department of Agncultural waterbodies (1986/7); this is digitized byExtension (Mi. of Agriculture) CEGIS; newer not being collected, at present
o Annual statistics on pesticide use can beobtained at the Department of AgriculturalExtension, but the level of resolution is Distnct(sometimes Thana) level only
Biological
o Concentration of Coliform Bacteria in Surface o Min. of Health & Public Welfare o Mm. of Health & Public Welfare does notand Groundwater monitor this nationwide, only incidentally during
o Biodiversity. o MoEF, CEN project implementationo Amphibians (# species and absolute figures) o Amphibian database as such does not exist, only
site or regional reports (e.g. FAP6 reports,Giesen & Rashid, 1997; FRMP reports);overview of records in Bangladesh will soon bepublished by NACOM
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Parameter Agencies (to be) involved Availability, and mechanism by which this datacan be accessed
Biological (ctd...)
* Birds (# Species and Absolute Numbers) . MoEF, CEN * Asian Waterfowl Census data"3 , repository inBangladesh at NACOM (all records are to bepublished this year); internationally at WetlandsInternational Asia Pacific, in Kuala Lumpur
* Area of (Semu) Natural Forest . MoEF (RIMS), SPARSSO" * RIMS (Forestry Department) maintains a GISdatabase of forest cover in Bangladesh
* FRMP established a forest database for
* Min of Agriculture Bangladesh's protected areas (see Appendix VII)* Area of Village Tree Plots in 1995-7;
. Min of Agriculture keeps annual statistics(resolution up to subdistrict level) on production
* Fisheries Production . Min ofFisheries Livestock, of certain crops, including various types of fruit;*MmoEF Fihre12Lvsok areas known only for specific crops
* National Fisheries Database, based at CEGISand DoF
SPARSSO does not have an overview of total forest cover, only specific areas have been studied (e g Chokona Sundarbans, Modhipur forest), no ongoing monitonng program,12 Since colonial times, the Forestry Department (now under MoEF) has collected fishenes data in the Sundarbans region, which is primanly a managed mangrove forest area TheDepartment of Fishenes is excluded from this area13 The Asian Waterfowl Census is carried out annually between 6-24 January, and in Bangladesh several NGOs have been involved in collecting this data since 1991 Counts are ofwater-birds at 33 sites throughout the country, mainly along the coast and in the haor region of northeast Bangladesh, but also along the Ganges-Brahmaputra
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Parameter Agencies (to be) involved Availability, and mechanism by which this datacan be accessed
Social
* Level of Environmental Awareness . certain NGOs * BCAS and Shomunnoy have been involved inassessing environmental perception; no country-wide coverage; no baseline of target group SIPP;baseline study estimated by BCAS to cost inrange of US$ 25-50,000.-; coordination throughWB's External Relations Section, as this hasexpenence in studies of perceptions.
. Number of Environmental NGOs * ADAB &* NGO Affairs Bureau . ADAB (produces an annual directory of NGOs)
* Incidence of Gastro-intestinal Diseases * NGO Affairs Bureau (registers NGOs)* Incidence of Lung Disease Min. of Health & Public Welfare
. MHPW produces annual statistics, withresolution at (sub) district level, re the incidenceof specific diseases
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8.2 Cumulative Impacts of SIPP Sub-projects & Key Parameters for Monitoring
The vast majority of SIPP subprojects are expected to have only positive or mlinor environmentalimpacts, or no impacts at all. The SIPP must bear in mind the cumulative consequences of numeroussmall-scale subprojects, and ensure that these do not adversely affect the environment in anirreversible manner Likely cumulative effects of the various subproject types are outlined below inTable 5.
In general, most subproject types are likely to have positive cumulative impacts on the environment.
* reforestation, improved stoves, electrification, replanting with aquatic plants, restocking withindigenous fish, establishing parks or protected areas and establishing new ponds all have apositive effect on biodiversity and/or forests, and
* training, education and institutional strengthening lead to increased awareness of, and increasedcapacity to deal with environmental issues.
However, some subproject types are more likely to have negative cumulative impacts on theenvironment:
small-scale irrigation, small scale drainage, and small scale embankment construction may affectthe aquatic environment, by lowering or raising water levels, and decreasing water quality. ?
Other subproject types may have both positive and negative cumulative impacts on the environment:
* waste water disposal, latrines and improved drinking water supplies may all have positivecumulative effects on human health, but the first two (if improperly implemented) may affectground and surface water quality, while the latter may affect groundwater levels;
. rural roads increases mobility and access; what this leads to environmentally, depends on manyother variable, many of which are related to economic issues. ?
Ideally, in order to establish if cumulative effects are indeed occurring, environmental assessmentshould involve the monitoring of key environmental parameters. For each of the subproject types,these are listed below in Table 5 Note that baseline infonration will be required for many of these,especially those related to water levels, water quality and biodiversity, in order to assess if anychanges have indeed occurred. Baseline data required for monitoring of cumulative effects of theSIPP are summarized in Table 6, along with agencies that are already involved with collecting suchdata, or agencies that should be involved in collecting such data if this does not yet exist
8.3 Independent Environmental Auditing
As local level agencies are responsible for execution and supervision, there is a distinct danger thatcomers will be cut. Some potential pitfalls are.
* ignoring the occurrence/proximity of environmentally sensitive areas;* attributing a lower screening category to a particular subproject (e g assigning C or C+ category
to a Category B or A subproject);* omitting certain impacts and mitigation measures (as indicated in Form IV/Appendix IV) from the
Routing Slip (Appendix I),* not implementing proposed mitigation measures;* significantly changing the design during the construction phase without infonning SDF.
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Without some form of external environmental control, one or more of the aforementioned is likely tooccur in a significant number of cases. Therefore, it is recommended that mdependent environmentalauditing should be carried out for SIPP subprojects by an independent agency that:
• is not formally linked with SIPP subproject implementation in any way,* has proven environmental assessment capacity,o has a large degree of financial and political independence; ando has a good reputation in the field of environment.
Potential candidate organizations for implementation of the auditing should submit a bid to SDF, andselection should be based primarily on quality of work. An international environmental NGO mightbe considered, but other local organizations may also meet the requirements and be able to operateeffectively at a lower cost.
It would not be necessary to carry out an Independent Environmental Audit of all subprojects. It isrecommended that this is limited to 5 % of subprojects requiring an ER, 20-30 % of all subprojectsrequiring a LEA The Independent Environmental Audit should include an assessment of whether:
* the subproject has little or no effect on environmentally sensitive areas;* the screening category attributed to a particular subproject is correct;o expected impacts and recommnended mutigation measures are correctly indicated on the Routing
Slip (Appendix I), or mentioned in the LEA;o proposed mitigation measures are carried out as planned;• the subproject has been implemented according to design;* no unexpected environmental impacts have surfaced, which have not been reported to the SDF
Environment Unit.
The overall environmental performance rating of a particular subproject should be based on theWorld Bank standards, and reported to the SDF.
Box 1 - Environmental Performance Rating
I Highly satisfactory Environmental components are being implemented in atimely and satisfactory manner.
2 Satisfactory Implementation of the critical aspects of theenvironmental components is proceeding in a timely andsatisfactory manner. There are some problems withcertain other aspects, but these are not undermining theprogress of implementing the components and are beingaddressed by the implementing agency.
3 Unsatisfactory There are major problems in implementing some or allof the environmental components of the subproject,including aspects critical to the success of thecomponents and the subproject as a whole. However,appropriate measures are being taken by theimplementing agency to address the problems.
4 Highly Unsatisfactory As with 'unsatisfactory', but problems are not beingaddressed properly.
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Table 5 - Cumulative Impacts and Key Monitoring Parameters for SIPP Sub-projects
Type of Subproject Cumulative Impact on the Environment Key Environmental Monitoring Parameter
Rural Roads * positive or negative: increased mobility in rural areas; * difficult to monitor, as parameters are affected by manymay lead to increased migration or access to natural factors, included an improved road networkresources in rural areas (negative), or better access tomarkets, schooling and clinics (positive)
Drinking Water Supply* New (tube)wells * negative possible drop in groundwater level . regional water levels to be monitored for changes. New Ponds * positive impact on local biodiversity (especially . monitor blodiversity: amphibians and waterfowl
waterfowl, amphibians and fish)
Wastewater Disposal. For Less than 100 Persons * negative effects on surface water quality * momtor bacterial contamination of surface water
Latrines * negative or positive effects on surface water quality * monitor coliforms in surface waters* negative or positive: effects on groundwater quality * monitor coliforms in groundwater
Ponds and Small Dams . positive impact on local biodiversity (especially * monitor biodiversity: amphibians and waterfowl(New Construction) waterfowl, amphibians and fish)
* positive: incompatible uses of water become possible
Small Scale Irrigation negative: reduced waterlevels in streams, nvers and lakes a monutor water levels establish water level monitoringnetwork, effectuate regular recording
Small Scale Drainage . negative. loss of wetlands * monitor wetlands areasnegative: lowered water quality in rivers, lakes and streams * monitor water quality, establish network for regular
_________________________ ___________________________________________________ sam pling and sim ple analysis of basic param eters
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Type of Subproject Cumulative Impact on the Environment Key Environmental Monitoring Parameter
Flood/Erosion Protectiono Embankments o negative: loss of fisheries production o monitoring of fisheries production
o negative: increased flooding outside protected areas o monitoring of water levels: establish water levelmonitoring network, effectuate regular recording
Solid Waste Disposal o positive: lowered incidence of diseases o difficult to monitor: masked by many other factors
Electrical Supply System o positive: reduction of pressures on fuel sources (oil, o area of natural forests/village forest plots.wood); increase, stabilization, or reduced rate of declineof natural forests and village forest plots
o positive: health improvement: lowered incidences of lung o health statistics indicating lowered incidences of lungdiseases (linked with fires, lamp-oil, etc..) diseases
Improved Cooking Stoves o positive. reduction of pressures on fuel sources (wood); o area of natural forest/village forest plots:increase, stabilization, or reduced rate of decline of natural
forests and village forest plotso positive: health improvement: lowered incidences of lung o health statistics indicating lowered mcidences of lung
diseases (Imked with fires, lamp-oil, etc. ) diseases
Biogas Installations o positive: reduction of pressures on fuel sources (esp. o area of natural forest/village forest plots:wood); increase, stabilization, or reduced rate of decline o crop production increase (difficult to measure, asof natural forests and village forest plots influenced by many other factors)
o positive: residues can be used to improve soil fertility o improved hygiene situation, lower incidence of diseaseso positive: hygienic disposal of solid waste
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Type of Subproject Cumulative Impact on the Environment Key Environmental Monitoring Parameter
(Re)Forestation * positive lowermg of pressures on natural forests; * area of natural forestincrease, stabilization or reduced rate of decline ofnatural forests
* positive: improved situation for wildlife, increase, . wildlife populations; no. of bird species in given areasstabilization, or reduced rate of decline of wildlife may be a good indicatorspecies,
* positive: land accretion (in wetland areas), or at leaststabilization of land,
Non-timber/Non-fuelwood * positive higher incentive to maintain or increase forest * wildlife populations, no. of bird species in given areasForest Products cover has positive effects on biodiversity may be a good indicator
Homestead Gardening * positive improved nutrition and health; communal * agrochemical usecomposting
* negative potential increase in use of agrochemicals, andsaturation of the market
Replanting with Aquatic * positive impact on blodiversity, loss of biodiversity is * fish and waterfowl species diversity and abundancePlants stabilized, or blodiversity may be increased (species
retuming to revegetated areas)
Rcstocking with Indigenous * positive: impact on biodiversity; loss of biodiversity (fish * fish species diversity and relative abundanceFish Species species) is stabilized
Protected Areas positive impact on biodiversity; loss of biodiversity is * wildlife populations; no. of bird species in given areasstabilized, or biodiversity may be increased (species may be a good indicatorretuming to revegetated areas)
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Type of Subproject Cumulative Impact on the environment Key environmental monitoring parameter
Training & Education * positive. greater awareness m general about * monitoring of level of environmental awareness, e.g.environmental issues about key issues such as water quahty, samtation and
biodiversity
Institutional Strengthening * positive: greater capacity to deal with environmental * monitor number of agencies effectively dealing withissues environmental issues
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APPENDIX I
ROUTING SLIP FOR ENVIRONMENTAL MANAGEMENT OF SIPP SUB-PROJECTS(FORMI
1 - Sub-project:
Name
Location
2 - Proponent:
Name
Position/qualification
Address
3 - Environmental screening on ............. .......... (date) by:.
Name
Address
4 - Results of Environmental Screening (Circle both Category and follow-up):
Screening category (form II) C+ C B
Follow-up required ER LEA
5 - ER Progress:
ER report delivered I (date) |carried out by:
Main adaptations in proposal (list ticked negative imnpacts and applied mitigating Ineasures).
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6 - LEA Progress:
Requested from/contracted (name)
to:
(Date) (address)
| Report/format delivered to: (name)
(Date)
Decision/remarks/actions:
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APPENDIX II
ENVIRONMENTALLY SENSITIVE AREAS (ESAS) (FORM II)
CHARACTERISTICCategory*
A. Slopes
* steep slopes (slope >30%), OR 2* rolling or moderate slopes (slope 3-30%), OR I* flat or almost flat area, or valley bottom (slope less than 3 %). 0B. (Semi-) natural freshwater wetlands
* located in or directly adjacent (less than lOim distance) river, stream, beel, 2jheel, dchour or any other body of water that remains submerged during thedry months, OR
. located on an unstable char, OR 2* located 10-100 m from a river, stream, beel, jheel, dchour or any other body of I
water that remains submerged during the dry months, OR* located more than I 00m from a river, stream, beel, jheel, dchour or any other 0
body of water that remains submerged during the dry monthsC. (Semi-) natural marine & estuarine wetlands
* located in or directly adjacent (less than 10m distance at mean high water 2level) mangroves, saltmarshes, creeks, beaches, dunes or mudflats OR
* located on an unstable marine or estuarine island, OR 2* located 10-100 m (at mean high water level) from mangroves, saltmarshes, I
creeks, beaches, dunes or mudflats, OR. located more than 100 m (at mean high water level) from mangroves, 0
saltmarshes, creeks, beaches, dunes or mudflatsD. Natural habitats/vegetation
. located in or adjacent (less than 10 m distance) from a significant stand of 2natural vegetation (e.g forest, reedlands, mangrove, swanmp forest), OR
* located 10-lOOm from a significant stand of natural vegetation (e.g. forest,reedlands, mangrove, swamp forest), OR
. located more than 100m from a significant stand of natural vegetation (e g 0forest, reedlands, mangrove, swamp forest)
E. Forestry Reserves and National Parks
* located in or adjacent (less than 10 m distance from) a gazetted Forest 2Reserve or National Park, OR
. located 10-100 m from a gazetted Forest Reserve or National Park, OR I
. located more than 100 m from a gazetted Forest Reserve or National Park 0
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CHARACTERISTICCategory*
F. Sites of cultural or historical significance
o located in or adjacent (less than 10 m distance from) a site, building or 2monument that is of cultural or historical significance OR
o located 10-100 m from a site, building or monument that is of cultural or Ihistorical significance, OR
o located more than 100 m from a site, building or monument that is of cultural 0or historical significance (e.g. graveyards, tombs, forts, mosques, temples,churches,)
G. Population density
o located in a densely populated urban area, OR 3o located in a densely populated village, OR 3o located well outside (more than 200 m from) densely populated areas 0
o 0 means areas with low environmental sensitivity;o 1 means areas with moderate environmental sensitivity;o 2 means areas with high environmental sensitivity (areas with high blodiversity or important
natural resources); ando 3 mean areas with high population sensitivity (areas with high population pressure).
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APPENDIX III
FORMAT FOR ENVIRONMENTAL SCREENING OF SUB-PROJECTS (FORM III)
Sub-project Type Screening category(follow-up required)
C+ C B__________ (ER) (ER) (LEA)
Rural roads- repair 0,1,2,3- upgrading, without embankment construction 0 1,3Foot-Bridges- construction of new bridge (small, rural) 0Drinking water (arsenic-free) supply- provision of rainwater collection/storage 0,1,2,3- upgrading of (disused) village rescrve ponds 0,1,2,3- upgrading of (tube-)well (lining, new pump,..) 0,1,2,3- sinking of new well 0 1,3- sinking of new tubewells 0 1,3Latrines & sewerage- for less than 100 persons in total 0,1,2,3- community latrines/septic tanks 0Drainage channels- rehabilitation of existing channels 0 1,3Small Rural Markets 0,1Small conmmunity works (sidewalks, pedestrian 0,1,3 2bridges, etc.)Electrical supply system- linking with existing REB grid or repair 0,1,3 2Training and education 0,1,2,3- health and nutrition- resource maniagement- environmental conservation- nutrition and sanitation awarenessInstitutional strengthening 0,1,2,3Conimunity development (e.g. programs for 0,1,2,3empowerment of women, or targeting the elderlyand disabled)
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APPENDIX IV
GENERIC ENVIRONMENTAL REVIEW (ER) CHECKLIST, SHOWING POTENTIAL NEGATIVE ENVIRONMENTAL IMPACTS & PROPOSED STANDARD MITIGATIONMEASURES FOR EACH
SIPP SUB-PROJECT CATEGORY (FORM IV)
Subproject Potential Negative Environmental Impacts tick, if Mitigation Measures tick, ifl ________________ relevant proposedRural roads o creation of stagnant pools of water dunng construction o O => construction in the dry season, special attention to drainage, and => O
o introduction of hazardous wastes O not only limited to the road reserve => Oo involuntary settlement O => proper disposal of oil, bitumen and other hazardous wastes =, O
=> no involuntary resettlement = O
Foot Bndges o creation of stagnant pools of water => construction dunng dry season =, Oo traffic accidents O > adequate regulating and sign-posting, speed humps, and footpaths :=:> U
Drinking Tubewells/wells => proper drainage near pumps => O(arsenic-free) o over-exploitation of aquifers o O =:> at least 1Om distance from latnnes =, Owater supply o creation of stagnant pools of water 0 O =:> proper siting to avoid stagnant pool fornation => O
o contamination from sewerage systems =, ground water quality testing (via DPHE World Bank funded '> Oarsenic project)
=:> no tubewell if Arsenic is an issue, or in case of groundwater =' Odepletion
Pit-latnnes, o contamination of groundwater (+ dnnking water) because of o =, lining to prevent or minimize lateral seepage => Ucommunity seepage =:, siting so that located in permeable soils (with lining, this leads to => Ulatnnes and o contamination of surface waters due to flooding or over- 0 O vertical infiltration)septic tanks flowing => where possible, located so that bottom of latrine is 2m above => U
o source of diseases o U groundwater levelo offensive smells, social problems 0 => in regularly flooded areas, pipe leading from 'squatting point' of =, U
latrine should be located at least 0 5m above annual high waterlevel
=> awareness campaign to maintain sanitary condition and keep pits => U________________ __________ ~~~~~~~~~~~covered
Electncal supply a nsk of accidents (electrocution) o U => construction dunng the dry season = Usystem o attraction of polluting industnes U => couple electnfication with awareness campaign re mitigation of = U
environmental impacts of small-scale commercial industries
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Training & * social conflicts (between recipients and non-recipients of * Ol =z> consensus regarding whom is to receive training/education, is to be => LIeducation training/education) reached in the project preparation phaseInstitutional * social conflicts (between beneficianes and non-beneficianes of . O => consensus regarding which agency/organization is to receive => LIstrengthening institutional strengthening) institutional strengthening, is to be reached in the project
preparation phaseCommunity . social conflicts (between beneficianes and non-beneficiaries of . Ol = consensus regarding whom is to receive development is to be => ldevelopment community development) _ __ reached in the project preparation phase _
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APPENDIX V
LIITED ENVIRONMENTAL ASSESSMENT (LEA) FORMAT (FORM V)
NOTE: The LEA requires short descriptions, and should not exceed a total of 10 pages. This meansthat (some) descriptions may consist of only several lines/sentences (e.g. regarding groundwater:"the village has two tubewells with good quality water"). Information may not be availablefor alllisted items; for example, groundwater resources may be unknown because only reserve pond wateris being used by the local community.
1. General Description of the Sub-project
1.1 Subproject location, size, title, and date of LEA completion1.2 Identity of the formulators of the subproject proposal1.3 Identity of LEA compilers1 4 Need for subproject (=justification) and subproject objective(s)1.5 Subproject Components or the vanous phases of construction1 6 Alternatives rejected by the formulators of the Subproject
2. Baseline Description of the Affected Environment
2 lDescription of the Physical-chemical Environmento surface watero groundwatero soil
o geomorphology (descnption of slopes, steepness, special landscape features)
2 2 Description of the Biological Environmento flora (general description of main plant species, mention rare, endangered or
economically important species)o vegetation (natural vegetation coverage in subproject area; special mention of forests,
wetland vegetation, special wildlife habitats, etc.. )o fauna other than fish (general description of main wildlife species; special mention of
rare, endangered or economically important species)o fish (general description of main fish species occurnng; main economic species;
special mention of rare species)
2 3 Description of Socio-economic Environmento size and composition of community (population, gender ratio, ages groups, ethnic
groups)o economic aspects (main economic activities)o public health aspects (related to potable water, other domestic water resources,
sanitation, waste disposal, latrines, incidence of diseases, accidents)o infrastructure (existing system: roads, bridges, electrical supply, fuel, water sources)o presence of culturally or historically important sites, buildings or objects
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3. Identification of Negative Environmental Impacts
3.1 Impacts on the Physical-chemncal Environment* surface water resources (stagnation of water, drainage, blockage of flow,
contanunation with disease sources, siltation, pollution, increased flooding, etc..)* groundwater resources (contamination, increased water-logging, over-utilization,salinization, etc )
* soil (contamilnation, enhanced erosion, effects on steep slopes, etc ..)
3.1 Impacts on the Biological Environment* impacts on flora or vegetation* impacts on important natural habitats wetlands, Forest Reserves, National Parks,
Wildlife Reserves, fisheries reserves, beaches)* impacts on wildlife
i Impacts on livestock and poultry* impacts on fish or fisheries
3.1 lImpacts on the Socio-economic Environment* impacts on culturally or historically important sites, buildings or objects* impacts on economrc livelilhood (property, sources of livelihood, domestic animals,
fisheries, etc...)* impacts on public health (effects on potable water sources, other domestic water
resources, sanitation, waste disposal, incidence of diseases, accidents)* impacts on infrastructure (blocking of waterways, fuel supplies, roads)
4. Mitigation Measures
Description of impacts Mitigation measures proposed
Impact #1 Mitigation measure #1
Impact #2 Mitigation measure #2
Impact #3 Mitigation measure #3
9etc.. etc.
5. Institutional Framework
5.1 Who is responsible for Implementation ?5.2 Who is responsible for Supervision ?5.3 Who is responsible for Monitoring ?5.4 Who is responsible for 0 & M 9
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APPENDX VI
INSTRUCTION MANUAL FOR ENVIRONMENTAL ASSESSMENT OF SIPP SUB-PROJECTS (TO BE TRANSLATED IN BANGLA)
All Subprojects proposed for financing under SIPP-Bangladesh are to be subjected to anenvironmental assessment, with the objectives
o to prevent execution of projects with significant negative environmental impacts;o to decrease potential negative impacts through adaptations in subproject design or execution;o to enhance the positive impacts of subprojects;
o to prevent that environmentally sensitive areas receive additional stress from human activities.
The environmental assessment procedure consists of a number of steps, specified in this manual.Step one: Filling out the Routmg Slip (Form I) by PMCStep two: Filling out the Environmental Sensitivity Form (Form II) by CSOStep three. Filling out the Environmental Screening Form (Form III) by CSOStep four: Filling out the Environmental Review Form by CSO, orStep five. Filling out the Limited Environmental Assessment Form by environmental specialist.
Step 1: Filling out the Routing Slip (Form I) by PMC of CG
Each and every subproject requires its own Routing Slip, as shown in Form 1. To all subprojectproposals a Routing Slip has to be connected: one is not valid without the other. The intention of theRouting Slip is to visualize the environmental history of a subproject for purposes of Monitoring &Evaluation, or for Environmental Auditing. The Routing Slip has to be part of the subprojectproposal, and has to be filled out as follows.
o the first two components by the subproject proponent during subproject preparation,o the third, fourth and fifth component by the proponent (or a facilitating institution) during
subproject preparation.
In most cases this will be the end. Only for projects where moderate or serious environmental impactsare possible, the second page (sixth component) will have to be filled out by a responsibleEnvironmental Officer, appointed by the Social Development Foundation. This Officer will also beresponsible for the decision to implement, or to stop the subproject concemed. In case of a fullEnvironmental Impact Assessment he is also responsible for provision of the Terms of Reference.
Step 2: Filling out the Environmental Sensitivity Form (Form II) by CSO
In order to determne the sensitivity of the area concemed, Form II is prepared. This Form is selfexplanatory for various types of landscapes or resources it indicates the whereabouts and limits ofthe highly and moderately sensitive areas through the use of figures with the following meaning.
o 0 means areas with low environmental sensitivity;o 1 means areas with moderate environmental sensitivity;
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* 2 means areas with high environmental sensitivity (areas with high biodiversity or importantnatural resources), and
* 3 mean areas with high population sensitivity (areas with high population pressure).
In the more sensitive areas some of the categories of subprojects will not qualify for financialassistance, or only after full-fledged environmental impact assessment.The proponent identifies in Form Il in which of the sensitivity categories (0,1,2, or 3) the concemedsubproject is located (encircling) If more figures are found, the highest should be used in thefollowing steps.
Step 3: Filling out the Enviro,imental Screening Form,r (Form III) by CSO
The purpose of environmental screening of subproject proposals is to determine in an early stage
* whether the subproject is environmentally qualified for financing;* whether the subproject is only qualified for financing if relocated in an environmentally less
sensitive area;* whether the subproject is only qualified for financing if some expected negative impacts are
excluded or minimized through "mitigating measures", identified through a EnvironmentalReview (ER),
* whether qualification for financing requires further environmental guidance through a LimitedEnvironmuental Assessment (LEA).
The environmental screening is carried out with the help of Fonr III. This table requires thefollowing sub-steps.
Sub-step 3a: Determination of the type of Sub-project
The first column of Fomi III shows a list of categories of subprojects, expected to be proposed underthe SIPP. The proponent should check in which category the subproject concemed belongs. If asubproject cannot be classified at all, the CSO should ask assistance from the Social DevelopmentFoundation.
Sub-step 3b: Determiniation of t/ e Environmental Screeniing Level
The remaining columns of Form III serve to determine what level of environmental screening isrequired. The significance of the columns is as follows:
C means that relatively little impact is expected, an ER will suffice;C+ means the same (only an ER); the difference with "C" is that the C+ subprojects will be favored
by SIPP because of their expected positive environmental effects;B means that some moderate impacts might evolve; an LEA needs to be carried out,A means that severe negative environmental impacts might evolve; and this project will not be
funded
In these columns, figures are indicated that correspond with the figures from Form II. Through thesefigures, the CSOS can see immediately whether the proposed subproject will qualify for financing,and which environmental follow-up has to be given The CSO simply observes in which column thesensitivity level of the subproject is indicated, and whether this subproject requires an ER or an LEA.
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When a figure is not available in any of the columns, the subproject will not qualify at all. When fora subproject only the figure 0 is shown, the subproject concerned only qualifies for financing underSIPP if it is located in an area with relatively low environmental sensitivity. In fact, most ofBangladesh is rated as a low-sensitive area for these small-scale projects. When the figure 0 is shown,but the proposed project is located in a area qualified as "1" (moderate sensitivity), the project willhave to be relocated somewhat in order to qualify.
Step 4: Filling out the Environmental Review Form (Form IJ9 by CSO
For subprojects with minor negative of only positive environmental impacts, preparation of an ER,the simplest level of environmental assessment, will be sufficient.
For the ER the checklist in Form IV is prepared The checklist again shows the categories ofsubprojects expected to be relevant for SIPP. The first section behind the subproject categories listspotential negative environmental impacts, whereas the second section lists the major mitigatingmeasures to minimnze or eliinuate these negative effects. Behind both sections the relevant impactsand measures are to be ticked.
Subsequently, all ticked items are included in the Routing Slip (Formn I), which is handed over or sentto the subproject approving authority. All identified mitigating measures should be included in (oradded to) the subproject proposal, to which the Routing Slip is connected. In cases of substantialadaptations, a reformulated proposal may be added as well.
Step 5: Filling out the Limited Environmental Assessment Form (Form D' by environmentalspecialist (s)
LEAs will be required for all subprojects that potentially have moderate environmental impacts, orfor which impacts are likely to be complex.
LEA requires more environmental expertise than an ER, and will have to be carried out by anenvironmental specialist (national consultant or contractor) or a large national NGO with relevant in-house capacity. This will need to be contracted out by the SDF. Form V presents general Terms ofReference. Because of the limuted scope, an LEA should not take more than two weeks (includingfield work) to be finalized. The results will be presented to the subproject approving authorities in theform of a report (maximum 10 pages).
NOTE: Forms 1, 11, 111, IV and V are attached to this report on Environmental Assessmentfor the SIIPP, as Appendices 1, 11, [1[, IV and V, respectively.
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APPENDIX VIIPROTECTED AREAS AND IMPORTANT WETLANDS OF BANGLADESH
Area Size (ha) Note(s)
GAZETTED PROTECTED AREAS _
Bhawal National Park 5,022 Dhaka Forest Division, coppiced Sal forest &cultivation**
Hirncharn National Park 1,729 Cox's Bazar Forest Division, degraded evergreenforest**
Lawachera National Park 1,250 Sylhet forest division, heavily disturbedModhpur National Park 8,436 Tangail Forest Division, Sal plantation**Ramsagar National Park 52 Dinajpur Forest Division, lake & picnic area**Char Kukri-Mukri Wildlife Reserve 40 Khulna Forest Division manigrove plantation**
(total area = 2,500 ha, of which 40 haprotected)
Chunati Wildlife Reserve 7,761 Chittagong Forest Division, miostly cleared**Hazankil Wildlife Reserve 2,903 Chittagong Forest Division, disturbedPablakhali Wildlife Reserve 42,087 CHT North Forest Division, hcavily disturbed**Rampahar-Sitapahar Wildlife Reserve 3,026 CHT South Division, disturbedRema-Kalenga Wildlife Reserve 1,795 Sylhet Forest Division; heavily disturbed**Sundarbans West Wildlife Reserve*** 71,502 Khuina Env Mgt Division, reasonable conditioniSundarbans South Wildlife Rescrve*** 36,970 Khulna Env Mgt Division, reasonable conditionSundarbans East Wildlife Reserve*** 31,227 Khulna Env Mgt Division; reasonable conditionTeknaf Game Reserve 11,615 Cox's Bazar Forest Division, degraded due to
illegal logging
IMPORTANT WETLANDS*
Ganges-Brahmaputra plains 650,000 dry season area, wet season = 5 millioni haAta Danga baor 102 part of Ganges-Brahmaputra plainChalan beel 26,000 now much smaller than 26,000 ha because of
siltation, early this century >1 00,000 haMeda Beel 122 part of hiaor basin in Sylhet-MymensinghTanguar Haor 1,566 part of haor basin in Sylhet-MymensinghAila Beel 160 part of hiaor basin in Sylhet-MymensinghDekhar Haor 325 part of haor basin in Sylhet-MymensinghKun Beel 73 part of haoar basin in Sylhet-MymensinghErahi Beel 320 part of haor basin in Sylhet-MymensinghDubriar llaor 156 part of haoar basin in Sylhet-MymensinighHakaluki I-laor 20,400 part of haor basin in Sylhet-MymilenisinghKawadighi Hlaor 414 part of haor basin in Sylhet-MymensinghHail lo-aor 8,906 part of haor basin in Sylhet-MymensinighKaptai Reservoir 76,600 in CHT, part of Karnafuli hydel projectBostami Pond 0 5 ancient artificial pond, only site worldwide for
Dark Soft-shell turtle Trionyx ,iigricansBogakine Lake 60 permanent lake, in CHTChokona Sundarbans 20,000 south of Cox's Bazar, 8,500 ha mangrovesSt Martin's (or Jinjira) Island 600 small island, surrounded by Bangladesh's only
coral reefTeknaf Peninsula 16,000 wetlands include 1,800 ha mangroves (Teknaf
Game Rescrvc = adjacent hills)Hatiya Island and Chars 75,000 islands, mudflats and channels, in outer cstuary
of Meghna nver
* Scott (1989), ** Thompson & Johnson (1996) Rosario (1996)*** Ramsar site, total area of Sundarbans = 577,000 ha, of which 170,000 coilsists of river channels, only part (<30%)
is gazetted as a protected area, the remainder is forest rescrvc
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