Government of the People’s Republic of Bangladesh

Local Government Engineering Department

Environmental and Social Management Framework

(Draft)
for
Resilient Infrastructure for Adaptation and Vulnerability Reduction
(RIVER) Project

Part- I: Main Report

January 2022
 People’s Republic of Bangladesh
Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

List of Acronyms
ARAP Abbreviated Resettlement Action Plan
ARIPA Acquisition and Requisition of Immovable Property Act
BBS Bangladesh Bureau of Statistics
BDT Bangladeshi Taka
BOD Biological Oxygen Demand
BWDB Bangladesh Water Development Board
CBO Community Based Organization
CC Climate Change
COD Chemical Oxygen Demand
DoE Department of Environment
DoF Department of Fisheries
ESA Environmental and Social Assessment
ECA Ecological Critical Area
ECA Environmental Conservation Act
ECC Environmental Clearance Certificate
ESCoPs Environmental and Social Codes of Practices
ECR Environment Conservation Rules
EHS Environmental, Health and Safety
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EMU Environmental Management Unit
ESA Environmental and Social Assessment
ESCP Environmental Social Commitment Plan
ESIA Environmental and Social Impact Assessment
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESR Environmental Screening Report
ESS Environmental and Social Standards
FAO Food and Agriculture Organization
FGD Focus Group Discussion
FPIC Free, Prior and Informed Consent
GAP Gender Action Plan
GBV Gender Based Violence
GDP Gross Domestic Product
GoB Government of Bangladesh
GRC Grievance Redress Committee
GRM Grievance Redress Mechanism
ha Hectare
HH House Hold
IEE Initial Environmental Examination
IFC International Finance Corporation
IP Indigenous Peoples
IPDP Indigenous Peoples Development Plan
LGED Local Government and Engineering Division
LMP Labour Management Procedures
M&E Monitoring and Evaluation
MLGRD&C Ministry of Local Government, Rural Development and Co-operatives
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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

MoEFCC Ministry of Environment, Forest and Climate Change

MoF Ministry of Finance
NGOs Non-Government Organizations
NOC No Objection Certificate
O&M Operation and maintenance
PA Protected Area
PAD Project Appraisal Document
PAP Project Affected Persons
PIU Project Implementation Unit
PPE Personnel Protective Equipment
PSC Project Steering committee
RAP Resettlement Action Plan
ROW Right of Way
RPF Resettlement Policy Framework
SECDP Small Ethnic Community Development Plan
SEP Stakeholders Engagement Plan
TBD To Be Determined
ToC Table of Contents
ToR Terms of Reference
USD United States Dollar
WB World Bank

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

EXECUTIVE SUMMARY
Introduction
Bangladesh has made rapid social and economic progress in recent decades and reached lower
middle-income status in 2015, though the country has suffered from a huge economic blow caused by
the recent outbreak of COVID -19. While realizing the actual benefit from progressing economic
activities and active population dividends, the effects of climate change has always been a strong
impediment, and recurrence of floods in every alternative year is one of those negative striking forces.
Floods like other disasters disproportionately affect the poor, who have less disposable income, assets
and more limited access to public services. The impacts of floods on vulnerable communities extend
beyond short-term asset losses to long-term human capital impacts. In light of recent study conducted
by a third-party firm, community needs in flood-prone districts revolve around flood shelters, early
warning systems, community preparedness, and response capacity.

The Government of Bangladesh has made significant progress in reducing casualties from extreme
events or disasters in last couple of decades, with support from development partners. Policy
improvement and investments in multi-purpose disaster shelters, Early Warning Systems (EWSs), and
government capacity to mitigate the risks and impacts of extreme natural events have been proved to
be effective in reducing losses to lives and assets. There is a need to further develop and extend these
investments in infrastructure and capacity enhancement to encompass a wider range of geographies
and hazards, particularly riverine and flash floods in non-coastal areas in Bangladesh as climate
change increases the risks and impacts. Hence, the GoB, thorough its implementing agency- Local
Government Engineering Department (LGED) with financial assistance from the World Bank is
preparing a project under the title ‘Resilient Infrastructure for Adaptation and Vulnerability Reduction
(RIVER)’ with an aim to reduce the vulnerability of people in targeted communities to riverine and
flash floods, improve the country’s capacity in disaster preparedness and response, and respond
promptly in the event of any crisis or emergency.

Project Description
The project area covers the most severely affected flood-prone districts in the Teesta-Brahmaputra-
Jamuna (Nilpamari, Lalmonirhat, Kurigram, Rangpur, Gaibandha, Bogura, Pabna, Sirajganj), Padma
(Rajbari, Faridpur, Gopalganj, Madaripur), and Surma-Meghna river systems in the North East
(Sunamganj, Habiganj), and these districts and concerned upazilas have been selected through Multi-
criteria Analysis (MCA) by feasibility study. However, each of these areas, although similar, have
important geographical and demographic differences.
There are four distinct components under the project: (i) Resilient flood shelters and community
infrastructure: This component will finance land raising and construction of climate-resilient flood
shelters in targeted flood-prone villages in non-coastal districts, installation of lightning protection
systems, construction repair and/or rehabilitation of associated climate resilient shelter connecting
and community roads, and resilient infrastructure as identified by the community including small scale
climate resilient culverts and bridges, repair, rehabilitation of rural markets, repair and rehabilitation
of landing stages (river jetties), and installation of solar powered street lights; (ii) Strengthening
capacity for disaster preparedness and response and technical assistance: Finance will be provided for
good and services to increase the capacity of LGED and communities to plan, manage, and recovery
from floods, and strategic studies to increase long-term disaster and climate resilience; (iii) Project
Management, Design and Supervision, Monitoring and Evaluation: This component will support the
government in implementing the project, and in coordinating all project related activities, monitoring,
technical assistance, and training; (iv) Contingency Emergency Response: This component will furnish
unforeseen emergency needs, for which funds will be channelized to this component through re-
allocation upon the Government’s request to support response and reconstruction.

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Preparation of Environmental and Social Management Framework

Detail information regarding project location/design is not available at this stage of project appraisal
and hence a framework approach has been adopted for identification and management of
Environmental and Social risks associated at various stages of project preparation, implementation
and operation & maintenance. The implementing agency (LGED) has therefore prepared this
Environmental and Social Management Framework (ESMF) for assessment, identification and
attending E&S risks and impacts during various phases of the Project. The particular objectives are to
ensure that all project interventions are environmentally sustainable and socially feasible; all relevant
environmental and social issues are taken into account during the design and implementation of the
sub-projects; possible environmental and social risks, benefits, and consequences are analyzed and
measures adopted to avoid, reduce, and manage risks and impacts while maximizing benefits. This
would also ensure that national rules and regulations, as well as World Bank obligations are followed
and complied with and guide Environmental and Social (ES) screening and conducting environmental
and social assessment and preparing various ES management plan for the sub-projects once design
and locations are finalized. This framework has been prepared primarily on the reliable secondary
data. However, several effective and successful consultation events with various relevant stakeholders
were also conducted in this respect.

Policy, Legal and Regulatory Framework

The project will follow all the relevant policies, plans and regulatory framework of Bangladesh
Government, and Environmental and Social Framework (ESF) of the World Bank. The key GOB
legislations relevant for environmental assessment for the project components are the
Environmental Conservation Act 1995 (ECA'95) and the Environmental Conservation Rules 1997
(ECR'97). Environment Conservation Act ’1995, clearly states the requirement of obtaining
environmental clearance certificate in a prescribed manner from the Director General of DoE before
commencing operation and one of the key procedures to obtain the Environmental Clearance
Certificate is to undertake an environmental assessment. As part of a government entity, LGED is
obliged to abide by all these acts and rules, in addition of other GOB acts, rules or guidelines. World
Bank’s ESF contains ten Environmental and Social Standards (ESSs) which are applicable in all the
stages of a development project. But, the ESS 9: Financial Intermediaries will not be applicable in this
RIVER Project. However, there are few gaps between the GOB and world bank’s regulatory
requirements for which measures have been suggested to bridge these gaps. One of the key
differences is that none of the GOB regulatory instruments/guidelines suggests covering all
Environmental and Social Standards (ESSs) while doing an E&S Screening or scoping study; therefore,
it is suggested to follow relevant sections of Environmental Management Procedures under the ESS1,
which covers these gaps. Again in Bangladesh, projects do not require to formulate their own Labor
Management Procedures/Plans and labor related laws do not require assessment of labor influx,
OHS or management issues, which has been addressed through preparation of a detail labor
management procedure (LMP).Moreover, issues related to stakeholder engagement/ public
consultation, OSH, CSH, hazard and risk analysis, mitigation hierarchy, etc. are absent in GOB
legislative/regulatory documents, which will be complemented by adopting WB ESSs. Few more gaps
between the GOB and WB regulations have been identified for which most stringent actions have
been suggested in the relevant chapter.

Environmental and Social Baseline Condition

The baseline environmental and social condition in the locality of the project site serves as the basis
for the identification, prediction, and evaluation of impacts. These baseline conditions have been
generated mostly based on secondary information. The project sites are spread across 108 upazilas of
14 non-coastal districts and fall under five climatic sub-regions, within the Teesta-Brahmaputra-

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Jamuna, Padma and Surma-Meghna river systems. The proposed districts are also varied in
stratigraphic and seismic features, even the recurring flood patterns that differ from river to flash
flooding of different scales. All the project districts are diverse in terms of environmental settings and
socioeconomic baseline. The air quality of the project districts is within the tolerable/ country
standard in all parameters, while the surface water in major rivers of the districts shows varied results
with river Jamuna having the highest pollutants loads and Madhumati in Gopalganj having the lowest
pollution load. Among the districts, north-east and north-central region has some bigger water bodies,
which are rich in biodiversity, but not likely to be affected by the project activities. It is anticipated
that project locations are not likely to affect any protected area or ecologically critical areas. The
vulnerability profiles among the districts shows higher poverty level in the districts of Rangpur
division, and Kurigram, Gopalganj and Habiganj has got the higher percentage of female-headed
households. There are some small ethnic community habited areas in project districts, but further
site-specific survey and assessment will determine whether the project activities will have any impacts
to those groups or their livelihoods.
Potential Environmental and Social Impacts
Direction of change relative to baseline conditions, magnitude and sensitivity of impact, spatial extent
and duration were considered while assessing the risks and impacts. Project activities have been
classified based on a four-category risk classification system under the World Bank ESF domain such as
High, Substantial, Moderate or Low.
Project activities would entail small scale construction works, so the impact would be low to moderate
mostly, site-specific and well-mitigable. All the shelters will be constructed within the school
boundaries, and land area of school premises will be used. Roads and community infrastructure will
be constructed along the existing alignment, rural markets will be repaired/rehabilitated in the same
places, and smaller bridge/culverts will be constructed/rehabilitated. No land will be acquired for any
of the construction/rehabilitation or repair interventions under this project. Raised land will have the
same requirement. Therefore, the impacts will be primarily of construction induced, which may
include temporary air pollution, surface water and ground water pollution, drainage congestion and
water logging during the construction period, and some operation related impacts such as dust, air
and noise pollution etc. may occur. Construction activities and inefficient management practices may
also trigger risks on community health and safety, particularly of teachers and students near the
shelter construction areas. As the shelters will be steel structures, there might be some associated
occupational health and safety risk of workers during construction phase.
However, small scale civil and construction works under this project will not induce significant labor
influx, therefore the risk of GBV and SEA/SH can be anticipated to be insignificant. During the
construction phase, all potential consequences are amenable to substantial mitigation using both
accessible and viable approaches. Many operation-phase consequences can either be avoided or
considerably reduced by thoughtful design considerations. Another potential but indirect impact may
arise from the use of solar system in sub-project facilities; many of the companies who sell solar panel
reportedly use child labors in their production facilities, which should be very carefully taken care of
while purchasing equipment or panels from any of those companies.
After taking into consideration all the Project's risks and impacts associated with the proposed
activities, the Environmental and Social risks to the project has been rated as ‘Moderate’ under the
World Bank ESF and ‘Orange-B’ as per the GoB risk classification system.
Methodological Framework for Environmental and Social Management
As stated above, the Project will take a framework approach to environmental and social
management, allowing the project life cycle to follow the World Bank ESF including the applicable

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Environmental and Social Standards, and the applicable government rules and regulations as well as
the mitigation hierarchy of avoidance, minimization, mitigation, and compensation/offset for negative
impacts and enhancement of positive impacts where practical.
Sub-project/component specific environmental and social screening is required to analyze the
project's environmental and social risks and impacts. Based on the outcome of the screening exercise,
the subsequent site-specific ES assessment and/or ESMPs will be prepared following the procedures
set out in the ESMF. The ES assessment/ESMPs should clearly describe: (a) ES risks and impacts of
subprojects, (b) the measures to be taken during both construction and operation phases of a sub-
project to eliminate or offset adverse ES impacts, or reduce them to acceptable levels; (c) the actions
needed to implement these measures; and (c) a monitoring plan to assess the effectiveness of the
mitigation measures employed.
Considering potential environmental and social risks and impacts and their significance, ES risk of most
of the sub-projects appear to be moderate to low during an initial assessment. The ESMF describes
detail procedure to be followed for such categories of sub-projects.
Stakeholder Engagement and Disclosure
A separate Stakeholders Engagement Plan (SEP) has been prepared for RIVER Project which will be the
main guiding document for the project. The coordination and monitoring mechanisms established in
the SEP would be overseen by LGED and D&SC (Design and Supervision Consultants), and other
relevant agencies at the district and Upazila level. Consultations with different stakeholders were
carried out to obtain their views on project interventions and 18 such meetings were carried out on
different days in four selected project districts, and the participants were come from different
stakeholders groups. Those consultation meetings have come up with some suggestive measures to
undertake, such as, (i) 40-50 years’ flood nature, extent and duration to be considered before site
selection and design, (ii) shelter to be constructed above the highest flood level, (iii) shelters to have
facilities for health care, water supply, separate toilets for male & female, separate places for cattle,
ramp for disabled and elderlies, provision of wheel chairs, etc. (iv) shelter connecting roads to be
elevated, (v) coordination committee to form and alternative schooling for students to be arranged
during the construction period, etc. Their views or comments were recorded and has been considered
in project activities as well.
The proposed RIVER Project will also establish a grievance redress mechanism (GRM) for addressing
grievances and complaints received from the project affected/interested persons due to project
activities. A four tier GRCs (Grievance Redress Committees) have been proposed, keeping
representations from all respective group of stakeholders. The PIU would ensure that grievance
redress procedures are in place and would monitor those procedures to ensure that grievances are
handled properly.
The mechanism of information dissemination should be simple and be accessible to all. The draft
ESMF, RPF, SEP, LMP, and ESCP of RIVER Project will be disclosed to the local and national level
stakeholders, preferably in electronic format.
Institutional Framework and Capacity Building
The Local Government Engineering Department (LGED) will be responsible for implementing the
project. LGED will implement the project through a dedicated Dhaka-based PIU, headed by a Project
Director (PD). The PD will be supported by a dedicated Deputy Project Director (DPD), Senior Assistant
Engineer, Assistant Engineer as well as the associated technical and safeguard support staff. A
majority of the implementation will be based on the district and upazila levels, where the associated
LGED field officials (i.e., Executive Engineer, Sr. Assistant Engineer, Assistant Engineer, Sub assistant
Engineer etc.) will act as the focal person(s) responsible for supervision and monitoring of work
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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

implementation in their respective districts and upazilas. The PIU would provide support to implement
the ES instruments during implementation of the project. The staffing requirements and capacity
building program are included in the project design. The PIU will have a Senior Environmental
Specialist and a Senior Social Development Specialist. These ES specialists will be stationed for full
time at PIU to ensure that World Bank’s ESSs and Government requirements are realized throughout
the project life cycle. The PIU will also be supported by a Design & Supervision Consulting (D&SC) firm
having specialists with expertise in environment, social, communication, gender and disability. The
Terms of Reference (ToRs) and duration of engagement of these specialists and firms will be agreed
with the Bank.

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Contents
Executive Summary ................................................................................................................................... 4
Chapter 1: Introduction ........................................................................................................................... 12
1.1 Background .................................................................................................................................... 12
1.2 Resilient Infrastructure for Adaptation and Vulnerability Reduction (RIVER) Project .................. 13
1.3 Purpose of the ESMF ..................................................................................................................... 14
1.4 Rationale of the ESMF ................................................................................................................... 14
1.5 Approach and Methodology of the ESMF ..................................................................................... 15
1.6 Content of the ESMF Report ......................................................................................................... 15
Chapter 2 : Project Description ............................................................................................................... 16
2.1 Description of RIVER Project ......................................................................................................... 16
2.2 Project Development Objectives (PDO) ........................................................................................ 16
2.3 Project Components ...................................................................................................................... 16
2.4 Project Location............................................................................................................................. 17
Chapter 3: Policy, Legal and Regulatory Framework .............................................................................. 19
3.1 Introduction................................................................................................................................... 19
3.2 Review of National Environmental Policy, Legal and Regulatory Framework .............................. 19
3.2.1 Environment Related Policies in Bangladesh ......................................................................... 19
3.2.3 Environment Related Legislations in Bangladesh................................................................... 24
3.3 Review of National Social Policy, Legal and Regulatory Framework............................................. 27
3.4 Applicable International Treaties Signed by the GoB.................................................................... 30
3.5 World Bank’s Environmental and Social Framework .................................................................... 31
3.6 Gap Analysis of World Bank Requirements and National Laws .................................................... 40
3.7 Application of GoB Policies, Acts and Rules on RIVER Project components and Project
Categorization ..................................................................................................................................... 42
3.8 Application of WB ESSs.................................................................................................................. 44
Chapter 4: Environmental and Social Baseline........................................................................................ 45
4.1 Introduction................................................................................................................................... 45
4.2 Description of Environmental Baseline ......................................................................................... 45
4.3 Socioeconomic Environment ......................................................................................................... 56
Chapter 5: Potential Environmental and Social Impacts ........................................................................ 61
5.1 Risk Classification Methodology .................................................................................................... 61
5.1.1 Assigning Risk ......................................................................................................................... 61
5.1.2 Impact Assessment................................................................................................................. 62
5.1.3 Magnitude of Impact .............................................................................................................. 63
5.1.4 Sensitivity of Receptor............................................................................................................ 64
5.2 Anticipated Potential Impacts ....................................................................................................... 64

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5.2.1 Construction of Resilient Flood Shelters (including raising lands) and rehabilitation/repair of
Rural Markets .................................................................................................................................. 64
5.3 Typical Mitigation Measures ....................................................................................................... 744
Chapter 6: Methodological Framework for Environmental and Social Management .......................... 755
6.1 Introduction................................................................................................................................. 755
6.2 Environmental and Social Management Procedure.................................................................... 755
6.2.1 Overall Procedure................................................................................................................. 755
6.2.2 Environmental and Social Screening and Categorization of Sub-Projects ........................... 799
6.2.3 Preparation of ES Documents .............................................................................................. 809
[Link] Moderate Risk Sub-Projects ................................................................................................ 80
[Link] Low Risk Sub-Projects .......................................................................................................... 80
[Link] National Environmental Clearance Requirements of the Proposed Investments and Sub-
projects ............................................................................................................................................ 81
6.2.4 Integration of Environmental and Social Assessment with the Design ................................. 82
6.2.5 Environment and Social Management Plan (ESMP)............................................................... 84
6.2.6 Required Site Specific Management Plans (ESS 1-10) ............................................................ 86
6.2.7 Labor Management Procedures (ESS2) ................................................................................ 865
6.2.8 Guideline for Preparation of Environmental and Social Monitoring Plan............................ 866
6.2.9 Monitoring Framework ........................................................................................................ 877
6.2.10 ESMP Implementation Cost.................................................................................................. 88
Chapter 7: Stakeholder Engagement, Grievance mechanism and Disclosure ........................................ 90
7.1 Introduction................................................................................................................................. 990
7.2 Stakeholder Consultations and Disclosure .................................................................................... 90
7.2.1 Objective of the Consultations ............................................................................................... 90
7.2.2 SEP revision and updating ...................................................................................................... 99
7.3 Grievance Redress Mechanism (ESS10) .................................................................................... 9999
7.4 Information Disclosure .......................................................................................................... 102102
Chapter 8: Institutional Framework and capacity building ................................................................. 1066
8.1 Project Implementation Arrangements .................................................................................... 1066
8.2 Other Relevant Institutions in Implementation Arrangements ................................................ 1088
8.3 Monitoring Mechanism for ESMP Implementation ................................................................ 10909
8.4 Reporting Requirement ........................................................................................................... 11010
8.5 Institutional and Project Capacity Development .................................................................... 11212
8.5.1 Capacity Assessment of LGED .............................................................................................. 11212
8.5.2 Requirement of additional experts ...................................................................................... 11313
8.5.3 Training Requirement........................................................................................................... 11414
8.5.4 Capacity Building Action Plan ................................................................................................. 1155

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

List of Tables:
Table 1.1 Project Component wise cost allocation 13
Table 2.1 Project Districts under RIVER Project 17
Table 3.1 Summary of Relevant Environmental Policies of GoB 19
Table 3.2 Summary of Relevant Environmental Plan & Policies of GoB 22
Table 3.3 Summary of Applicable Environmental Laws and Regulations of GoB 24
Table 3.4 Summary of Applicable Social and Resettlement Laws and Regulations of GoB 28
Table 3.5 International Conventions, Treaties and Protocols Signed by Bangladesh 30
Table 3.6 WB ESS Requirements and Relevance to the RIVER Project 33
Table 3.7 Gaps between GoB Laws and World Bank ESSs 40
Table 4.1 Administrative divisions and areas in project districts 45
Table 4.2 Climatic Sub-Regions of project districts 46
Table 4.3 Major rivers in the covered districts 48
Table 4.4 Major water bodies/Haor-baor/lake 48
Table 4.5 Physiography and soil type of the proposed districts 49
Table 4.6 Land cover categories in the proposed districts 50
Table 4.7 Air quality in reference districts 51
Table 4.8 Surface water quality in reference rivers 52
Table 4.9 Seismic zoning and risk potential of the project districts 53
Table 4.10 Major rivers and flood hazard pattern in project districts 54
Table 4.11 Population size and sex ratio in the project districts 56
Table 4.12 Socio-economic vulnerability of population 57
Table 4.13 Area and population density of project districts 57
Table 4.14 Literacy rate and educational institutions in project districts 58
Table 4.15 Major professional engagement of people in project districts 59
Table 4.16 Types and number of health service facilities in project districts 59
Table 5.1 Assessment of Risk Classification 62
Table 5.2 Impact Categorization and Typology Adopted for This Study 62
Table 5.3 Parameters for Determining Magnitude of Impact 63
Table 5.4 Criteria for Determining Sensitivity 64
Table 5.5 Summary Impact Assessment & Risk Rating Matrix School-cum-flood shelters and rural 71
markets
Table 6.1 National requirement for general environmental assessment 82
Table 6.2 Environmental and Social Consideration in Construction of Resilient Shelters 82
Table 6.3 Environmental and Social Consideration in Construction/Rehabilitation of road sub-projects 83
Table 6.4 Environmental and Social Consideration in Construction/Rehabilitation of Jetties/Landing 84
Stations (Ghat)/Bridge or culverts
Table 6.5 Monitoring responsibilities in phases 87
Table 6.6 Cost Estimates for ESMP implementation of the RIVER Sub-projects 89
Table 7.1 Summary of Consultation Meetings and FGDs 92
Table 7.2 Stakeholder Discussion Outcome 95
Table 7.3 Disclosure Requirement of RIVER Project 105
Table 8.1 Institutional Responsibilities, Environmental Protection and Compliance 109
Table 8.2 Reporting requirement and responsibilities 111
Table 8.3 Capacity Development Support (Training) 114
Table 8.4 Action Plan for Project Capacity Development 116

List of Figures:
Figure 2.1 Project Coverage Area (in districts) under the RIVER project 18
Figure 3.1 Process of Obtaining Clearance Certificate from DoE 44
Figure 4.1 Climatic Sub-Regions in Bangladesh 46
Figure 4.2 Tectonic map of Bangladesh and adjoining areas 53
Figure 4.3 Seismic zoning map of Bangladesh (Source: BNBC'2020) 53
Figure 6.1 Environmental and Social management procedure/steps during different phases 78
Figure 7.1 Grievance Redress Committees (GRCs) at different levels (excerpted and modified from SEP) 102
Figure 8.1 Project Implementation Arrangements 108

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Chapter 1: Introduction
1.1 Background
Bangladesh is one of the most vulnerable countries to natural disasters where almost every year,
mainly during monsoon season, either by upstream river floods and or by coastal cyclones from the
Bay of Bengal disaster happens to varied extent. There are 57 trans-boundary rivers passing through
Bangladesh to the sea. Typically, high rainfalls during monsoon season, full-flowing floods of upstream
rivers (which the country has no control to regulate beyond its boundary) results in extensive
inundation on the floodplains mainly alongside the rivers and its tributaries. Flooding is a recurring
phenomenon in Bangladesh, and in each year on an average about 22 percent of the country is
inundated. Floods pose a serious threat as two thirds of the country is less than 5 meters above sea
level. A rise in sea level will make an additional 14% of the land extremely vulnerable to floods by
2030. Among 61 % of land area that is characteristically vulnerable to flood, 23 % is generally affected
by flash flood in a normal flooding year. Floods and riverbank erosions affect some one million people
annually. The north-eastern part of Bangladesh, particularly Sunamganj, Sylhet and Netrokona
districts are especially vulnerable to floods, with flash floods being common (Page at 623, 7th Five
Year Plan). In recent years propensity of flood has further increased such as floods in 2004 and 2007
with affected area 42% and 25% causing heavy damage to lives and property of the people. Even in
2017 about 68 lac people were affected and more than 121 people died1. Impact of last year’s flood
(in 2021) was even worse due to its co-appearance with the devastation caused by the COVID-19. It
was the most prolonged flood in Bangladesh after the 1988 flood inundating around 25% of the
country. More than 5 million people are affected and around 1 million houses are inundated. Around
56,000 people are already displaced in around 1000 flood shelters in the affected areas2. During
floods, people, their essential belongings and livestock in the affected areas need to take shelters for
few days to as long as 8 weeks. But there is great insufficiency of flood resilient shelter including killas,
raised public infrastructure for them to take shelter. People often took shelters in high embankment,
schools & colleges in high land affecting their normal operation and spreading diseases among them
and others. Sometimes floods take considerable time to recede even 70 days as in 1998. If flood
resilient shelters are constructed with living facilities this huge loss of lives and properties will not
occur and contagious disease will be lessened to a great extent. It will also facilitate effective relief
operation. Besides the impact on agricultural production due to floods, short-term measures are also
needed to help the victims of those disasters immediately. It is necessary to invest and build more
centers where the potential victims can take shelters. This will in turn help any relief activity that
would be taken after the disaster (Page at 98, 7th Five Year Plan).
In recent years, lightning hazard is becoming more deadly than ever before. According to the Ministry
of Disaster Management and Relief (MoDMR), over 2,000 people died in lightning strikes in the
country from 2011 to 20203. At least 177 people, including 122 farmers, were killed and 47 others
injured by lightning strikes across the country between March 31 and June 7 in 2021.4 By observing
the scenarios of fatalities due to lightning hazard, MoDMR declared this hazard as a natural disaster
on May 17, 2016.

1 https:// [Link]/ report/ bangladesh/ bangladesh-flood-situation-august-22-2017; Nirapad Report

2 [Link]
3 Bangladesh: National Plan for Disaster Management: 2021-2015
4 Lightning Bangladesh’s deadliest natural disaster (June 18, 2021), Dhaka Tribune

([Link]

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In the backdrop of people’s plight or sufferings caused by recurring flood events and lightning,
Government of Bangladesh has planned to construct and rehabilitate several hundred of resilient
flood shelters and community structures, install lightning protection systems, and strengthen the
capacity for disaster related adaptation, preparedness and response, among other interventions,
through undertaking a new project titled ‘Resilient Infrastructure for Adaptation and Vulnerability
Reduction (RIVER) Project, which will be implemented by Local Government Engineering Department
under Ministry of Local Government, Rural Development and Cooperatives, Bangladesh and funded by
World Bank.
The Environmental and Social Management Framework defines the steps, processes and procedures
to be followed by LGED as Borrowers, and for the environmental and social assessment, monitoring
and management of the environmental and social issues associated with the implementation of
proposed activities. In addition, the ESMF gives an overview of the relevant environmental national
legislation and legal regime of the GOB and the World Bank Environmental and Social Standards (ESS);
presents the assessment of the institutional capacity required to ensure proper environmental and
social management; and describes mandatory principles, objectives and approach to be followed
while designing environmental mitigation measures for planned project activities. The ESMF should be
used as a practical tool during design, implementation, and monitoring of sub-projects under the
proposed Project.
The Environmental and Social Management Framework (ESMF) document is prepared based on the
World Bank’s newly developed ‘Environmental and Social Framework (ESF)’ to determine the
optimum approach to be adopted for RIVER Project to deliver the right Environmental and Social
Management result. The location of the site, criteria for selection, and key performance indicators will
depend on the feasibility study. As location, design and scale of operation of these sub-projects are
not yet known; this ESMF has been prepared to set out detail procedures to be followed once detail
information would be available.

1.2 Resilient Infrastructure for Adaptation and Vulnerability Reduction (RIVER) Project
The proposed project would be implemented by the Local Government Engineering Department
(LGED), with the objective to enhance the resilience of target vulnerable villages to floods, and
improve the disaster preparedness and response capacity of government agencies. More specifically,
the project aims to (a) increase the number of people with reduced flood vulnerability due to resilient
protective infrastructure; and (b) improve disaster preparedness capacity of the GoB and
communities. The proposed project will finance infrastructure and systems to increase the flood
resilience of vulnerable rural populations in selected areas through: (i) raising of community land,
construction of shelters and community facilities, connecting roads, and flood resilience infrastructure
in flood-prone villages; and (ii) improving community disaster preparedness including early warning
system, evacuation, awareness, response capacity, sheltering, and recovery. The project also aims at
contributing to the COVID-19 recovery process by facilitating investments in public works that provide
local employment opportunities. Overall scope of the Project would be around USS400 million
depending upon the availability of financing the project. Table 1.1 below shows the component wise
cost of the project.

Table 1.1 Project Component wise cost allocation

Cost
Project Component
(US$ million)
1. Resilient Flood Shelters and Community Infrastructure 350.00
1.A: Resilient Flood Shelters 300.00
1.B: Resilient Community Infrastructure 50.00
2. Strengthening Capacity for Disaster Preparedness and Response and Technical
30.00
Assistance
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2.A: Strengthening LGED’s Capacity for Disaster Preparedness and Response 20.00
2.B: Technical Assistance for Long-Term Community Flood Resilience 10.00
3. Project Management, Design and Supervision, Monitoring and Evaluation 20.00
4. Contingent Emergency Response Component (CERC) 0
Total 400.00

1.3 Purpose of the ESMF

The ESMF is intended to be used as a practical tool for identification of Environmental and Social risks
and preparation of management plan during project formulation, design and implementation. For
ensuring effective environmental and social management in the proposed RIVER Project , the ESMF
will provide guidance on pre-investment works/studies (such as environmental and social screening,
environmental and social assessment, environmental and social management plans, etc.), provide set
of steps, process, procedure, and mechanism for ensuring adequate level of environmental and social
consideration and integration in each investment in the project-cycle and describes the principles,
objectives and approach to be followed to avoid, minimize or mitigate impacts. While this ESMF
document has been prepared to identify the potential impacts of the RIVER Project, the specific
objectives are to:
• integrate the environmental and social concerns into the identification, design and
implementation of all project interventions in order to ensure that those are
environmentally sustainable and socially feasible;
• ensure all relevant environmental and social issues are mainstreamed into the design and
implementation of the projects/sub-projects and also in the subsequent phases of the
RIVER Project ;
• consider in an integrated manner the potential environmental and social risk, benefits and
impacts of the project and identify measures to avoid, minimize and manage risks and
impacts while enhancing benefits;
• ensure compliance with national laws and regulations, and World Bank requirements. The
ESMF presents potential impacts of the RIVER Project, mitigation, enhancement,
contingency and offsetting measures, environmental and social management and
monitoring plan, and institutional framework for implementing ESMP. The ESMF will
facilitate compliance with the Government of Bangladesh’s policies, acts and rules as well
as with the World Bank’s environmental and social standards (ESSs) of the newly adopted
Environmental and Social Framework (ESF), and
• guide preparing and conducting the site specific ESA/IEE/ESMPs during implementation of
various sub-project under the project.

1.4 Rationale of the ESMF

The exact locations, size and extent of the sub-projects are unknown and the details of the sub-
projects to be implemented under RIVER Project will be finalized during project implementation phase
and therefore, a framework approach has been adopted for Environment and Social risk assessment
and management. The objective of an ESMF is to ensure that all subprojects are adequately screened/
assessed for the environmental and social issues, and site specific Environmental and Social
Management Plan (ESMP) are prepared accordingly. The ESMF will provide necessary background for
environmental and social considerations, a checklist of potential issues of the project activities to be
considered and built into the design of the project, environmental and social screening of subprojects
and guidance on the preparation of specific assessments and plans.
This ESMF will also serve as the guideline for the staff designated by the implementing agencies to
oversee and monitor the safeguards compliance of the project components under their

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implementation responsibility. The ESMF will be a living document and will be reviewed and updated
periodically as needed.

1.5 Approach and Methodology of the ESMF

The ESMF has been prepared following the standard methodology consisting of the steps listed below:
 Review Project documents and meeting/discussions with various stakeholders including
concerned government departments, local media and NGOs.
 Review of the policy and regulatory requirements of the country as well as the financing
agency
 Conduct extensive literature review since COVID-19 situation restricted the movement for
field visit and initial scoping and screening to determine the key environmental and social
parameters and issues those are likely to be impacted by the project activities
 Collection and analysis of baseline environmental and social data with the help of secondary
literature review
 Consultations with the stakeholders including beneficiary/affected communities, consultants
from world bank, LGED officials, and developing the consultation process
 Assess the potential and likely impacts of the project activities
 Prepare an outline of environmental and social management issues according to the
requirements of the newly adopted 10 ESSs of the ESF
 Compile of the individual thematic reports into ESMF

1.6 Content of the ESMF Report

The ESMF has been structured as follows:

 Executive Summary giving an overview of the ESMF

 Chapter 1 Introduction provides a brief overview of the project background, purpose &
Rationale of the ESMF, Approach & methodology of the project ESMF.
 Chapter 2 provides a description & objective of the project, its various components, and
project Location.
 Chapter 3 outlines the relevant policies, legislative and regulatory framework for this project
 Chapter 4 gives information about the baseline conditions in the project influence areas or
project districts.
 Chapter 5 describes potential/expected environmental and social risks and impacts of the
project
 Chapter 6 describes the Methodological framework to be followed for environmental and
social management of the project.
 Chapter 7 includes stakeholder consultation and disclosure objective, methodology & tools for
the stakeholder consultation. This chapter also summarizes the stakeholder consultations
undertaken to date and also proposed for the project. Grievance redress mechanism outline is
also provided within this section.
 Chapter 8 outlines Institutional framework for the project.

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CHAPTER 2 : PROJECT DESCRIPTION

2.1 Description of RIVER Project
The proposed project will finance infrastructure and systems to increase the resilience of vulnerable
populations in non-coastal areas of Bangladesh against riverine and flash floods through: (i)
construction and rehabilitation of resilient flood shelters and community infrastructures; and (ii)
strengthening capacity for disaster preparedness and response of government agencies and
communities. The project also aims to contribute to the COVID-19 recovery process by facilitating
investments in public works, improving the communication, accessibility, and facilitating economic
activities that provide local employment opportunities. The project area is proposed to cover a
number of the highest flood prone districts in the Teesta-Brahmaputra-Jamuna (Nilphamari,
Lalmonirhat, Kurigram, Rangpur, Gaibandha, Bogura, Pabna, Sirajganj), Padma (Rajbari, Faridpur,
Gopalganj, Madaripur, and Surma-Meghna river system in the North East (Sunamganj, Habiganj). Each
of these areas, although similar, have important geographical and demographic differences and
targeting them will allow the development of a diverse set of appropriate solutions that can be scaled-
up. The criteria for selecting districts and upazilas are based on the associated flood risk in the area
and has taken into consideration some other relevant factors, such as poverty, human capital index,
and availability of suitable land; and the final selection of location (districts and upazilas) was
conducted through MCA (Multi-Criteria Analysis) method by the consultants employed for the study
of project feasibility.

2.2 Project Development Objectives (PDO)

The project development objective is to reduce the vulnerability of people in targeted communities to
riverine and flash floods, improve the country’s capacity in disaster preparedness and response, and
respond promptly in the event of an eligible crisis or emergency.
Achievement of this objective will be measured through the following key indicators:
a. Increased number of people with reduced flood vulnerability due to resilient infrastructure
constructed under the project.
b. Enhanced damage and needs reporting methodology for LGED.
c. Number of communities with improved basic disaster preparedness and response capacities.

2.3 Project Components

The project objectives form the basis of four distinct components as described below:
Component1: Resilient Flood Shelters and Community Infrastructure
This component will finance land raising and construction of climate-resilient multi-purpose flood
shelters (functioning primarily as primary schools) in targeted flood-prone areas in non-coastal
districts, installation of lightning protection systems, construction and/or rehabilitation of associated
climate resilient shelter connecting and community roads, and resilient infrastructure as identified by
the community including climate resilient culverts and bridges, repair, rehabilitation of rural markets,
repair and rehabilitation of landing stages (river jetties), and installation of solar powered street lights.
The construction, repair and rehabilitation of infrastructure conducted under this component will
implement energy efficient practices and equipment to reduce GHG emissions associated with the
project activities. Selected shelters will include distributed renewable energy systems using solar
photovoltaic nano-grid schemes to increase access to clean and sustainable electricity. Additionally,
where possible, the activities will use locally sourced material to reduce GHG emissions associated
with transportation for procurement. This component will also cover the social and environment
management in the proposed project intervention areas.

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Component 2: Strengthening Capacity for Disaster Preparedness and Response and Technical
Assistance
This component will finance goods and services to increase the capacity of LGED and communities to
plan, manage, and recovery from floods, and strategic studies to increase long-term disaster and
climate resilience. To enhance the capacity of LGED, these include setting up contingency planning for
emergency preparedness and evacuations, updating the shelter database, improving the disaster loss
and damage assessments and reporting system, and establishing one Emergency Operation Center
(EOC) in a district as a pilot. To enhance the capacity of communities, activities include CBDRM
(Community-Based Disaster Risk Management) activities with local organizations such as the Union
Disaster Management Committees (UDMCs) on basic competencies to improve health and safety
including for GBV during floods, community risk mapping, training of School Management Committees
(SMCs) on shelter management, and updating and training on community operation and maintenance
guidelines of shelters.

Component 3: Project Management, Design and Supervision, Monitoring and Evaluation

This component will support the Government in implementing the project, and in coordinating all
project related activities, monitoring, technical assistance, and training. It will include: (i)
establishment of a Project Implementation Unit (PIU) within the Local Government Engineering
Department, and consultancy and technical assistance for construction detailed design, procurement
support, and construction supervision, preparation and implementation of safeguard instruments; (ii)
capacity development of the PIU and communities in participatory planning and investment; (iii)
monitoring and evaluation; and (iv) technical assistance and training in such areas as disaster
management and preparedness, climate change adaptation and mitigation, construction, contract
management, financial management, preparation of environmental and social assessments, and
preparation of safeguard instruments. It will also provide resources for strengthening the flood
preparedness and management program. The management, design and M&E activities under this
component will integrate climate adaptation and mitigation measures and parameters. Under this
component, an ICT Monitoring System will be developed to track the progress of the project in near
real-time basis, and detailed assessment of existing ICT and GIS infrastructure with forecasting the
demand of the ICT/GIS system up until 2030, along with necessary support systems/options will be
adopted to enhance the remote supervision capacity of LGED and data security in the event of any
disasters, including necessary software, hardware and associated integration activities.

Component 4: Contingency Emergency Response

The objective of this subcomponent is to cater to unforeseen emergency needs. In case of a major
natural disaster, the Government may request the Bank to re-allocate project funds to this component
(which presently carries a zero allocation) to support response and reconstruction.

2.4 Project Location

Physical interventions under RIVER Project will be taken place across fourteen districts of Bangladesh
(Table 2.1), which are recurrently affected by different types of floods, from severe river flooding to
flash flooding, and washed away by the swelling water of rivers the districts are located by, passed
through, or simply caused by the flashing water from sudden excessive rainfall.
Table 2.1: Project Districts under RIVER Project
Division Districts Major Rivers in the areas Flood Hazard Pattern
Rangpur Nilphamari, Brahmaputra, Dharla, Ghaghat, Low flood to Severe
Lalmonirhat Karatowa, Tista River Flooding
Kurigram
Rangpur

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Gaibandha
Rajshahi Bogura Jamuna, Bangali, Karatowa, Nagar, Moderate River
Sirajganj Hurasagar, Ganges (Pabna) Flooding
Pabna
Dhaka Madaripur Madhumati, Chandana, Arial Moderate to Severe
Faridpur Khan, Padma Flooding
Rajbari
Gopalganj
Sylhet Sunamganj Zadukata, Khoyal, Longla, Severe Flash Flood to
Habiganj Kushiyara Moderate River
Flooding
However, all these districts are characteristically varying in having different climatic conditions, soil
and physiographic features, flooding patterns, and some other environmental and social features
including very different demographic profiles (Fig 2.1).

Figure 2.1: Project Coverage Area (in districts) under the RIVER project

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CHAPTER 3: POLICY, LEGAL AND REGULATORY FRAMEWORK

3.1 Introduction
Regulatory requirements towards protection and conservation of environment and various
environmental resources and also towards protection of social environment from adverse impact of
projects and activities associated with them have been enunciated by the requirements of GoB as well
of the World Bank ESF. A review of the pertinent requirements of GOB and WB and a gap analysis
have been summarized in this chapter.

3.2 Review of National Environmental Policy, Legal and Regulatory Framework

3.2.1 Environment Related Policies in Bangladesh

Governance and management of the environmental sector is molded to a large extent by some key
specific policies. The polices which are relevant to RIVER Project have been briefly mentioned in Table
3.1.
Table 3.1: Summary of Relevant Environmental Policies of GoB
Policy Key Features Applicability
National The NEMAP built on the NEP to address NEMAP covers a number of
Environmental specific issues and management sectoral issues and actions;
Management Action requirements during the period 1995-2005, some of the specific actions
Plan (NEMAP), 1995 and remains a backbone of efforts to proposed in relation to
articulate national sustainability strategies. reducing the vulnerability to
The plan includes a framework within which natural disasters like flood,
the recommendations of a National cyclone, etc. are integrated
Conservation Strategy (NCS) are to be into RIVER Project activities.
implemented. The NEMAP was developed This plan also puts emphasis
with the following objectives: on sustainable use of water
(i) Identify key environmental issues resources, preventing
affecting Bangladesh degradation of water
(ii) Identify actions to halt or reduce the bodies, tree plantation,
rate of environmental degradation protection of biodiversity,
(iii) Improve management of the natural ensuring health and
environment sanitation, taking flood
(iv) Conserve and protect habitats and proof measures,
biodiversity compensation for project-
(v) Promote sustainable development affected people, among
(vi) Improve the quality of life others.
To this end, the NEMAP grouped all the
relevant necessary actions under four heads:
institutional, sectoral, location-specific and
long-term issues. The institutional aspects
reflect the need for inter-sectoral
cooperation to tackle environmental
problems requiring new institutional
mechanisms at national and local levels. The
sectoral aspects reflect the way the
ministries and agencies are organized and
make it easier to identify the agency to carry
out the recommended actions. The location-

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specific aspect focuses on particularly acute

environmental problems at local levels. And
the long-term issues include environmental
degradation trends that threaten to emerge
as serious threats to the country's
environmental quality and well-being if not
proactively addressed.
Bangladesh Climate The GoB prepared the Bangladesh Climate Relevant as the country is
Change Strategy and Change Strategy and Action Plan (BCCSAP) in vulnerable to climate
Action Plan (BCCSAP) 2008 and revised in 2009. This is a change effect and
2009 comprehensive strategy to address climate vulnerability to different
change challenges in Bangladesh. Bangladesh disasters is increasing across
Climate Change Strategy and Action Plan the country, and the project
built on and expanded the NAPA. It is built is targeting those vulnerable
around the following six themes: groups as the key
 Food security, social protection and beneficiaries of the project.
health to ensure that the poorest and
most vulnerable in society, including
women and children, are protected from
climate change and that all programs
focus on the needs of this group for food
security, safe housing, employment and
access to basic services, including health.
 Comprehensive disaster management
to further strengthen the country’s
already proven disaster management
systems to deal with increasingly
frequent and severe natural calamities.
 Infrastructure to ensure that existing
assets (e.g., coastal and river
embankments) are well maintained and
fit for purpose and that urgently needed
infrastructure (cyclone shelters and
urban drainage) is put in place to deal
with the likely impacts of climate
change.
 Research and Knowledge management
to predict that the likely scale and timing
of climate change impacts on different
sectors of economy and socioeconomic
groups; to underpin future investment
strategies; and to ensure that
Bangladesh is networked into the latest
global thinking on climate change.
 Mitigation and low carbon
development to evolve low carbon
development options and implement
these as the country’s economy grows
over the coming decades.
 Capacity building and Institutional
strengthening to enhance the capacity
government ministries, civil society and
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private sector to meet the challenge of

climate change.
There are 44 specific programs proposed in
the BCCSAP under the above six themes.
National Bangladesh adopted the National With regards to the
Environmental Policy, Environmental Policy (NEP) in 1992 to chart a components under RIVER
1992 (amended in path towards the country's sustainable Project, the NEP directly
2018) development. The NEP 2018 is a revision of relates to some of the
the NEP 1992 in the context of the new sectoral areas, such as land
reality of climate change. The NEP 2018 also and water resources
outlines a more up to date understanding of management, air pollution
the extent and magnitude of environmental control, biodiversity,
degradation that has become a fact of life in ecosystem conservation and
the world in general, and in Bangladesh in biosafety, energy and
particular. The NEP 2018 outlines the mineral resources, Climate
problems of population growth, poverty, change preparedness &
illiteracy, lack of awareness and healthcare adaptation, disaster
services, limitation of arable land, unplanned management, inter alia,
development and urbanization, and which are applicable within
industrialization as the major impediments to the scope of the project.
the conservation of the environment. The
NEP sets out the basic framework for
environmental action together with a set of
broad sectoral guidelines for action. Major
elements of the policy are:
(i) maintaining the ecological balance
for ensuring sustainable
development;
(ii) protection against natural disasters;
(iii) identifying and controlling activities
which are polluting and/or
destroying the environment;
(iv) ensuring environment-friendly
development in all sectors;
(v) promoting sustainable and sound
management of natural resources;
and
(vi) active collaboration with
international initiatives related to the
environment.
The NEP, amongst other aims, seeks to
ensure that transport systems, including
roads and inland water transport, do not
pollute the environment or degrade
resources. The policy states that
environmental impact assessment should be
conducted before projects are undertaken.
The NEP 2018 includes additional elements
addressing climate change mitigation and
adaptation as key environmental issues
facing the country, and integrating a
comprehensive 3R approach to the massive
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and growing problem of industrial and

household waste that has swelled along with
the country's urbanization.
National Plan for This strategic plan to guide the This project interventions
Disaster Management implementation of disaster management in have the clear objective to
(2021-2025), 2020 the light of the government’s vision, mission enhance the resilience of
and national and international approaches target vulnerable villages to
plans and programs on disaster risk floods, and improve the
management. The plan includes areas of disaster preparedness and
investment for disaster risk management response capacity of
through a Risk Informed Development Plan government agencies.
and emphasized its implementation with
participation of all concerned.

3.2.2 Other Environment-Related Plan and Policies

In addition to the environmental policy instruments mentioned in table 3.1, a number of other
national policy efforts have significant environmental content. Additional Bangladesh policies, their
key features, and applicability to the subject Project are detailed in Table
Table 3.2: Summary of Relevant Environmental Plan & Policies of GoB
Policy Key Features Applicability
National Water Policy, The policy aims to provide guidance to the major Applicable for the
1999 players in water sector for ensuring optimal preservation of water
development and management of water. The quality.
policy emphasizes efficient and equitable
management of water resources, proper
harnessing and development of surface and
groundwater, availability of water to all
concerned and institutional capacity building for
water resource management. It also addresses
issues like river basin management, water rights
and allocation, public and private investment,
water supply and sanitation and water need for
agriculture, industry, fisheries, wildlife,
navigation, recreation, environment,
preservation of wetlands, etc. The policy has
several clauses related to the project for
ensuring environmental protection.
National Land Use The National Land Use Policy was adopted by Applicable as the project
Policy, 2001 Bangladesh government in 2001, setting out will by and large focus
guidelines for improved land-use and zoning on conserving nature at
regulations. The main objectives of this policy its original state, and
are to ensure criteria-based uses of land and to not cause any
provide guidelines for usage of land for the transformation of land
purpose of agriculture, housing, afforestation, use.
commercial and industrial establishments, rail
and highway and for tea and rubber gardens.
Overall, this policy promotes a sustainable and
planned utilization of land.
The main contents of this policy are:
 Stopping the high conversion rate of

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agricultural land to nonagricultural purposes;

Utilizing agro-ecological zones to determine

maximum land use efficiency;
 Adopting measures to discourage the
conversion of agricultural land for urban or
development purposes;
 Improving the environmental sustainability of
land-use practices.
Bangladesh Delta Plan Bangladesh Delta Plan 2100 is the most Among the five specific
2100 comprehensive and holistic plan ever goals of Delta Plan 2100,
formulated and undertaken by the Government the project will focus
of Bangladesh. Considering the exceptionally directly on ensuring
strong development record throughout the last safety from floods and
decade, aspirations to reach the Upper Middle climate change related
Income (UMIC) country status level by 2030 and disasters and at the
so many development challenges still persisting same time, will put
including huge population pressure and climate emphasis on conserving
change vulnerability, the government has and preserving wetlands
formulated this plan in order to reap the and ecosystems and
synergistic benefit from all actions, activities, promoting their wise
plans, strategies and programs of all different use across all stages of
ministries and wings of the government. This the project period.
Delta Plan has divided Bangladesh into 8
hydrological regions and corresponding six
Hotspots based on the similar vulnerabilities
they are exposed to. With the grim effects of
climate change and other delta related
challenges, the country is facing more other
challenges from growing urbanization, declining
land availability, infrastructure shortages,
energy supply constraints and labor skills, and all
these challenges also need an overarching
solution or efforts far more than sectoral plans
or programs. Delta plan comes up with all these
effective efforts with numbers of long- and
short-term course of actions and plans. Among
many others, following specific issues are
considered more holistically in Delta Plan 2100:
 Climate Change, Environment and Ecological
Issues,
 National and Trans-boundary water
management
 Sustainable land use and Spatial Planning
across dynamic delta
 Sustainable agriculture, food security, nutrition
and livelihoods
 Dynamizing Inland Water Transport system
 Urban Water Management
 Governance and Institutions
 Delta Knowledge hub and data management,
etc.
Eighth Five Year Plan July Eighth Five Year Plan (FYP) is envisaged as the The project will
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2020 to June 2025 (8FYP) first phase of the four phased Perspective Plan contribute directly to
2041 (PP2041) that actually aims to the start of the Government’s
the implementation of PP2041 in a way that it strategies by taking a
brings Bangladesh closer to the goals of community
attaining UMIC status, attaining major SDG participatory approach
targets, and eliminating extreme poverty by to build and maintain
FY2031. This FYP has six core themes, including flood resilient
establishing a sustainable development pathway infrastructure and social
that is resilient to disaster and climate change structures that aim to
and entailing sustainable use of natural reduce flood risks of
resources. affected communities.

3.2.3 Environment Related Legislations in Bangladesh

The GOB Acts and Regulations, which are guiding environmental protection and conservation in
Bangladesh and are relevant to the RIVER Project have been outlined in the Table 3.3 below.
Table 3.3: Summary of Applicable Environmental Laws and Regulations of GoB
Act/Rules Key Provisions and Purpose Applicability to RIVER Project
Environment The Environment Conservation Act authorizes the According to this law no
Conservation DoE to undertake any activity to conserve and industrial unit or project shall
Act, 1995 enhance the quality of the environment and to be established or undertaken
control, prevent and mitigate pollution. The DoE is without obtaining, in the
designated as the regulatory body and manner prescribed by rules, an
enforcement agency for all environment-related Environmental Clearance
activities. The Act enables the following critical Certificate from the Director
components of DoE's remit: General of DoE.
i. declaration of Ecologically Critical Areas;
ii. administration of the procedure for obtaining
Environmental Clearance Certificates for new
industrial projects;
iii. regulation with respect to vehicles emitting
smoke harmful to the environment;
iv. environmental regulations for development
activities;
v. standards for quality of air, water, noise, and
soils (including river bed materials) for different
areas and for different purposes;
vi. acceptable limits for discharging and emitting
waste; and
vii. formulation of environmental guidelines to
control and mitigate environmental pollution,
conservation and improvement of the
environment.
Amendments to the ECA in 2000, 2002 and 2010
added significant substantive and procedural scope,
defining the following new areas of authority:
i. ascertaining responsibility for compensation in
cases of damage to ecosystems;
ii. increased provision of preventive measures,
including fines and imprisonment, and the
authority to take cognizance of offences;

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iii. restrictions on polluting automobiles;

iv. restrictions on the production and sale of
environmentally harmful items like polythene
bags;
v. obtaining assistance from law enforcement
agencies for environmental actions;
vi. definition and enforcement of punitive
measures;
vii. authority to try environmental cases;
viii. prohibition on hill cutting except where
established to be in the national interest;
ix. authority to regulate management of hazardous
waste produced by ship breaking yards;
x. prohibition of filling or alteration of waterways
except when judged to be in the national
interest; and
xi. additional powers to compel compliance with
emissions standards.
Environment These are a set of rules, promulgated under the In accordance with the
Conservation ECA, 1995 and its amendments. The Environment Environment Conservation
Rules, 1997 Conservation Rules provide categorization of Rules (ECR) of 1997, the Project
and industries and projects and identify types of is classified as Orange-B
amendments environmental assessment required against Category, requiring an Initial
respective categories of industries or projects. The Environmental Examination
Rules set: (IEE) to obtain clearance for
 The National Environmental Quality Standards construction.
(NEQS) for ambient air, various types of water,
industrial effluent, emission, noise, vehicular
exhaust etc.;
 The requirement for and procedures to obtain
environmental clearance; and
 The requirement for IEE and EIA according to
categories of industrial and other development
interventions.
The Environment Conservation Rules, 1997 were
issued by the GOB in exercise of the power
conferred under the Environment Conservation Act
(Section 20), 1995. Under these Rules, the following
aspects, among others, are covered:
 Declaration of ecologically critical areas;
 Classification of industries and projects into four
categories;
 Procedures for issuing the Environmental
Clearance Certificate (ECC); and
 Determination of environmental standards.
Rule 3 defines the factors to be considered in
declaring an 'Ecologically Critical Area’ as per
Section 5 of the ECA (1995). It empowers the
Government to declare the area as the Ecologically
Critical Areas (ECA), if it is satisfied that the
ecosystem of the area has reached or is threatened
to reach a critical state or condition due to
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environmental degradation. The Government is

also empowered to specify which of operations or
processes may be carried out or may not be
initiated in the ecologically critical area. Under this
mandate, the Ministry of Environment, Forest and
Climate Change (MoEFCC) has declared
Sundarbans, Cox's Bazar-Teknaf Sea Shore, Saint
Martin Island, Sonadia Island, Hakaluki Haor,
Tanguar Haor, Marzat Baor and Gulshan-Baridhara
Lake as ecologically critical areas and prohibited
certain activities in those areas.
Rule 7 of the 1997 ECR provides a classification of
industrial units and projects into four categories,
depending on environmental impact and location.
These categories are:
 Green;
 Orange A;
 Orange B; and
 Red.
The categorization of a project determines the
procedure for issuance of an Environmental
Clearance Certificate (ECC). All proposed industrial
units and projects that are considered to be low
polluting are categorized under "Green" and shall
be granted Environmental Clearance. These are
Orange B for work that requires Initial
Environmental Examination (IEE) and Red for work
that requires full environmental assessment.
A detailed description of those four categories of
industries has been given in Schedule-1 of ECR'97.
Environment The Environment Court Act, 2000 has been enacted According to this act, the
Court Act, to establish one or more Environment Court/s in Department of Environment
2010 each district with a Joint District Judge and the said (DoE) can take legal actions if
judge shall in addition to his ordinary function any environmental degradation
dispose of the cases that fall within the jurisdiction occurs due to project
of an Environment Court. This Act sets out an interventions.
effective adjudication system for protecting,
conserving and preserving the environment and
promoting the environmental justice. The act has
mandated the Department of Environment (DoE) to
file a case and investigation thereof. It also has set
to resolve the disputes and establish justice over
environmental and social damage raised due to any
development activities. This act allows government
to take necessary legal action against any parties
who creates environmental hazards/ damage to
environmentally sensitive areas as well as human
society.
The Forest Act The Forest Act (1927) was enacted to control The act is relevant to the
(1927) and trespass, illegal resources extraction from forests project as some of the project
amendments and to provide a framework for the forestry intervention may require
revenue collection system. It is the main legislative cutting of trees.
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context for forestry protection and management in

Bangladesh. The Act allows for the notification of
forest reserves in which the government, through
the Forest Department, regulates the felling,
extraction and transport of forestry produce in
Bangladesh. The Act grants the government several
basic powers, largely for conservation and
protection of government forests, and limited
powers for private forests.
The Ground Describes the management of ground water Yes, construction sites of the
Water resources and licensing of tube sub-projects may require deep
Management wells tube wells for meeting up
Ordinance water use.
(1985)
The Water Regulates the management and control of water Yes, sub-projects will include
Supply and supply and sanitation in urban areas. construction of water supply
Sanitation Act and sanitation facilities.
(1996)
Bangladesh The Bangladesh National Building Code (BNBC) Follow the guidelines to ensure
National clearly sets out the constructional responsibilities structural integrity of buildings
Building Code according to which the relevant authority of a
(BNBC), 2020 particular construction site shall adopt some
precautionary measures to ensure the safety of the
workmen. The BNBC also stipulates the general
duties of the employer to the public as well as
workers.
Biodiversity It provides for the creation of the National Project needs to include these
Act, 2017 Committee and the Biodiversity Management and local committees, so that they
Surveillance Committees at local levels (i.e., can monitor project impact on
Districts, Upazilas, Municipalities, and Unions). In the local biodiversity.
general, all these committees are mandated to:
assist the Government in implementing the
National Biodiversity Strategy and Action Plan
(NBSAP) and to visit the biodiversity enriched areas
in their respective territories; and, monitor the
progress of implementation of the NBSAP.
Public Applies to the procurement of goods, works or The PPR (2008) will be followed
Procurement services by any government, semi-government or during procurement process of
Rule, 2008 any statutory body established under any law; the subprojects
includes measures regarding the safety, security
and protection of the environment in construction
works; requires contractors to take all reasonable
steps to safeguard the health and safety of all
workers on site, protect the environment on and
off the site, and avoid damage or nuisance to
persons or to property of the public or others.

3.3 Review of National Social Policy, Legal and Regulatory Framework

The resettlement principles adopted for the project recognizes the Acquisition and Requisition of
Immovable Property Act 2017, the requirements of the World Bank ESS5 on land acquisition,
restriction on land use and involuntary resettlement and corresponds to the relevant local laws,

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policies and guidelines related to this project interventions. This project will also put due emphasis on
labor rights and benefits under the existing labor laws and Rules of Bangladesh along with World
Bank’s ESS2. Besides, having access to all relevant information regarding project management and
implementation by the stakeholders is a prerequisite under an existing act of the GOB and ESS 10
administered by the bank.
Table 3.4: Summary of Applicable Social and Resettlement Laws and Regulations of GoB
Act/Rules Key Provisions and Purpose Applicability to RIVER
Project
Bangladesh Labor It is a comprehensive law covering labour Compliance to provisions
Law, 2006 issues such as conditions of services and on employment
(amendment 2018) employment, youth employment, benefits standards, occupational
including maternal benefits, compensation health and safety, welfare
for injuries, trade unions and industrial and social protection,
relations, disputes, participation of workers labor relations and social
in company’s profits, regulation of safety of dialogue, and
workers, penalty procedures, administration enforcement.
and inspection. Prohibition of engaging
This Act pertains to the occupational rights children and adolescents
and safety of factory workers and the in work force.
provision of a comfortable environment for
working. It also includes rules on registration
of laborers, misconduct rules, income and
benefits, health and fire safety, factory plan.
The amendment of 2018 further ensures the
occupational health and safety rights of the
worker by replacing some of the clauses of
2006 law, such as paid leave and associated
facilities, parental leave etc.
Bangladesh Labor Includes rules on registration of laborers, Contractors to implement
Rules, 2015 misconduct rules, income and benefits, occupational health and
health and fire safety, factory plan. safety measures
The Acquisition and It is the principal legislation governing ARIPA 2017 defines the
Requisition of eminent domain land acquisition in land acquisition process
Immovable Property Bangladesh. The Act requires that and contains pertinent
Act (ARIPA), 2017 compensation be paid for: (i) land and assets information related to
permanently acquired (including standing compensation payment to
crops, trees, houses); and (ii) any other titleholders; though the
damages caused by such acquisition. The Act project will avoid all kinds
also provides for the acquisition of properties of acquisition of lands or
belonging to religious organizations like properties.
mosques, temples, pagodas and graveyards if
they are acquired for the public interest. The
Ministry of Land (MoL) is the authorized
government agency to undertake the process
of land acquisition. The MoL partly delegates
its authority in relation to land acquisition to
the Commissioner at Divisional level and to
the Deputy Commissioner at the District
level. The Deputy Commissioners (DC) is
empowered by the MoL to process land
acquisition under the act and pay
compensation to the legal owners of the
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acquired property. Khas (government-owned

land) lands should be acquired first when a
project requires both Khas and private land. If
a project requires only khas land, the land
will be transferred through an inter-
ministerial meeting following the acquisition
proposal submitted to DC or MoL. The
Government of Bangladesh does not have a
national policy on involuntary resettlement.
The new Act of 2017 has incorporated
specific provisions to address social and
economic impacts that were not previously
included in the 1982 land acquisition
ordinance and therefore these provisions
under the new law would reduce the gaps
between the national legislative framework
of the government and WB policies.
Right to Information The act says in its preamble -the Act makes World Bank ESF also put
Act, 2009 provisions for ensuring free flow of emphasis on project
information and people’s right to information to be publicly
information. The freedom of thought, disclosed, and extensive
conscience and speech is recognized in the stakeholder consultations
Constitution as a fundamental right and the having to be conducted
right to information is an alienable part of it. before, during and after
Since all powers of the Republic belong to the the project
people, it is necessary to ensure right to implementation, in order
information for their empowerment. The to integrate local people
right to information shall ensure that with the project
transparency and accountability of all public, objectives and make
autonomous and statutory organizations and necessary plausible
of other private organizations constituted or changes in project design/
run by government or foreign financing shall decision making according
increase, corruption shall decrease and good to the requirement
governance of the same shall be established. expressed by the local
It is expedient and necessary to make stakeholders. In all cases,
provisions for ensuring transparency and project documents
accountability. However, under the clause 4 relevant to
of this law, every citizen shall have the right implementation shall be
to information from the authority, and the disclosed publicly.
authority shall, on demand from a citizen, be
bound to provide him with the information.
This law also inscribes relevant clauses on
preservation, publication, procedure to
request and provide information with
legitimate exceptions on grounds when
publication or providing certain types of
information is not mandatory.
EIA Guidelines for This guideline sets out detailed and This guideline will help
Industries, 2021 systematic guidance on EIA study for minimizing the gaps
industries. Starting from screening, through among the GoB and
scoping, baseline data generation, impact World Bank regulatory
assessment, mitigation of impacts to drawing instruments, and making
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up an EMP-all stages are incorporated clearly, the decisions to adopt the

with an emphasis on Stakeholder ES standards more
engagement/ public consultation, OSH, CSH, effectively and justifiably
hazard and risk analysis, mitigation hierarchy, for this project.
etc. which have been absent in most other
legislative documents prepared and
promulgated by the GoB.

3.4 Applicable International Treaties Signed by the GoB

Bangladesh has signed most international treaties, conventions and protocols on environment,
pollution control, bio-diversity conservation and climate change, including the RAMSAR Convention,
the Bonn Convention on Migratory Birds, the Rio de Janeiro Convention on Biodiversity Conservation,
and the Kyoto Protocol on Climate Change. An overview of the relevant international treaties signed
by GoB are shown in Table 3.5.
Table 3.5: International Conventions, Treaties and Protocols Signed by Bangladesh
Conventions/ Treaties Years Ratified/Accessed Relevance
(AC)/Accepted (AT)/
Adaptation (AD)
Convention on Wetlands of 20.04.1992 Protection of significant wetland and
International Importance (“Ramsar (ratified) prevention of draining or filling during
Convention”:1971) construction
Convention Concerning the 03.08.1983 (AT) Prevention of damage or destruction of
Protection of the World Cultural and 03.11.1983 (ratified) culturally and/or historically significant
natural Heritage (Paris, 1972) sites, monuments, etc.

Convention on Biological Diversity, 1992 05.06.1992 Protection of biodiversity during

(Rio de Janeiro, 1992.) construction and operation.
United Nations Framework 1992 15.04.94 Reduction of emission of greenhouse
Convention on Climate Change, gases.
(New York, 1992.)
Kyoto protocol to the United 21.8.2001 (AC) Reduction of emission of greenhouse
Nations Framework Convention on 11.12.1997 (AD) gases.
Climate Change
International Convention for 1950 Signed Protection of the birds in their wild state.
Protection of Birds, Paris
Convention Concerning the 1974 Signed To protect workers against hazards arising
Prevention and Control of from occupational exposure to
Occupational Hazards caused by carcinogenic substances and agents.
Carcinogenic Substances and
Agents, Geneva.
Convention Concerning the 1977 Signed Protection of workers’ health against
Protection of Workers Against occupational hazards in the working
Occupational Hazards in the environment due to air pollution, noise
Working Environment due to Air and vibration.
Pollution, Noise and Vibration,
Geneva
Convention Concerning 1981 Signed Ensuring occupational health and safety of
Occupational Safety and Health and workers in all branches of economic
the Working Environment, Geneva. activity.
Vienna Convention for the 1985 02.08.90 (AC) Preventing human activities that may have
Protection of the Ozone Layer, 31.10.90 (entry into adverse effects on ozone layer.
Vienna force)
Convention Concerning 1985 To promote a safe and healthy working

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Occupational Health Services, environment. Broadly applicable to the

Geneva. construction and
O&M activities under the project.
Appropriate mitigation and protective
measures will be included in the sub-
project ESMP.
Montreal Protocol on Substances 1987 31.10.90 Reduction of the abundance of the
that Deplete the Ozone Layer, (entry into substances that deplete the ozone layer in
Montreal. force) the atmosphere, and thereby protect the
earth’s fragile ozone Layer.
Convention Concerning Safety in the 1990 Signed Regulating the management of chemicals
Use of Chemicals at Work, Geneva. in the workplaces, in order to protect
workers from the harmful effects of these
substances.
London Amendment to the 18.03.94 (AC) Apply the protocol on substances that
Montreal Protocol on Substances 16.06.94 (entry into deplete ozone layer.
that Deplete the Ozone Layer, force)
London.
Convention on Biological Diversity, 05.06. 03.05.94 Conservation of biological diversity (or
Rio De Janeiro 92 biodiversity) and sustainable use of its
components.
Agenda 21, UNCED, Rio de Janeiro 1992 Signed Conservation of bio-diversity, sustainable
use of its components and access to
genetic resources.
Copenhagen Amendment to the 1992 27.11.2000 (AT) Apply the protocol on substances that
Montreal protocol on Substances 26.2.2001 (Entry into deplete ozone layer.
that Deplete the Ozone Layer, force)
Copenhagen, 1992
Montreal Amendment of the 27.7.2001 (Accepted) Controls in the trade of ozone depleting
Montreal Protocol on Substances 26.10.2001 (Entry substances and the use of licensing
that Deplete the Ozone Layer, into force) procedures to control the import and
Montreal export of new, recycled and reclaimed
ozone depleting substances.
Sendai Framework for Disaster Risk 2015 Adopted The project is aligned with three of the
Reduction (2015-2030) four priorities for action to prevent new
and reduce existing disaster risks, namely:
(i) Understanding disaster risk; (ii)
Investing in disaster reduction for
resilience and; (iii) Enhancing disaster
preparedness for effective response, and
to "Build Back Better" in recovery,
rehabilitation and reconstruction.

3.5 World Bank’s Environmental and Social Framework

Since October 01, 2018, all WB funded Investment Project Financing (IPF) are required to follow the
Environmental and Social Framework (ESF) consisting ten (10) Environmental and Social Standards
(ESS). The Environmental and Social Standards are designed to manage the risks and impacts of the
project through the means that are appropriate to the nature and scale of the project/interventions
and proportionate to the level of environmental and social risks and impacts, and improve the
environmental and social performance, through a risk and outcomes-based approach. These
standards, therefore, set out the requirements for the identification and assessment of environmental
and social risks and impacts associated with the project through Investment Project Financing and will
(a) support in achieving good international practice relating to environmental and social sustainability;
(b) assist in fulfilling the national and international environmental and social obligations; (c) enhance

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nondiscrimination, transparency, participation, accountability and governance; and (d) enhance the
sustainable development outcomes of project through ongoing stakeholder engagement.
Table 3.6 shown below discusses the relevance of ESF, each of the ten standards (ESS1 to 10) and
associated Directive and their requirements. Additionally, it also discusses the relevance and
requirements relating to other guidance notes of World Bank. In case requirements of Bangladesh law
differed from those of ESF, the more stringent requirements will apply.

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Table 3.6: WB ESS Requirements and Relevance to the RIVER Project

World Bank ESS Objectives Requirements Relevance to the sub-project/project
Policy, Standards,
Directive
ESS-1 Identify, assess, evaluate, and manage The types of E&S risk and impacts that should be Assessing, managing and monitoring of
Assessment and environment and social risks and considered in the environmental and social environmental and social risks and impacts
Management of impacts in a manner consistent with assessment. The use and strengthening of the are the prerequisites in every stages of the
Environmental and the ESF. Adopt differentiated measures Borrower’s environmental and social framework for project. Assessment will be proportionate to
Social Risks and so that adverse impacts do not fall the assessment, development and implementation of the risks and impacts, and management of
Impacts disproportionately on the World Bank financed projects where appropriate. those throughout the project life cycle will
disadvantaged or vulnerable, and they commensurate with the nature and scale of
are not disadvantaged in sharing Relevant GoB Laws/Regulation the project. As the overall risk rating for this
development benefits and (a) ECA 1995 project fall in ‘moderate’ category, sub-
opportunities (b) ECR 1997 project specific screening exercise and
(c) EIA guidelines for Industries subsequent preparation of IEE are suggested
accordingly. Mitigation hierarchy approach
will be followed while designing and
implementing every single sub-project and
reflected in measures to be delineated in
Environmental and Social Management Plan
(ESMP).
ESS-2 Promote safety and health at work. Requirements for the Borrower to prepare and adopt Engaging labor and workers of different
Labor-and-Working- Promote the fair treatment, non- labor management procedures. Provisions on the types, capacities, and backgrounds (including
Conditions discrimination, and equal opportunity treatment of direct, contracted, community, and level of vulnerabilities) with proper
of project workers. Protect project primary supply workers, and government civil accommodation (if required), health & safety
workers, with particular emphasis on servants. Requirements on terms and conditions of measures at work, fair-nondiscriminatory-
vulnerable workers. Prevent the use of work, non-discrimination and equal opportunity and equal opportunities and provision for CBA &
all forms of forced labor and child workers organizations. Provisions on child labor and access to grievance redress services, within
labor. Support the principles of forced labor. Requirements on occupational health World Bank standards/policies and national
freedom of association and collective and safety, in keeping with the World Bank Group’s legal framework is to be ensured.
bargaining of project workers in a Environmental, Health, and Safety Guidelines (EHSG).
manner consistent with national law. Relevant GoB Laws/Regulation
Provide project workers with accessible a) Labor Law 2006 (Amendment 2013)
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means to raise workplace concerns. b) Occupational Health and Safety Policy 2013
c) Public Procurement Rule 2008
ESS-3 Promote the sustainable use of Requires an estimate of gross greenhouse gas With respect to Resource Efficiency, the
Resource-Efficiency- resources, including energy, water, and emissions resulting from project (unless minor), where project preparation and the ESA process will
and-Pollution- raw materials. Avoid or minimize technically and financially feasible. Requirements on identify feasible measures for efficient (a)
Prevention-and- adverse impacts on human health and management of wastes, chemical and hazardous energy use; (b) water usage and
Management the environment caused by pollution materials, and contains provisions to address historical management to minimize water usage
from project activities. Avoid or pollution. ESS-3 refers to national law and Good during construction, conservation measures
minimize project-related emissions of International Industry Practice, in the first instance the to offset total construction water demand
short and long-lived climate pollutants. World Bank Groups’ EHSGs. and maintain balance for demand of water
Avoid or minimize generation of resources; and (c) raw materials use by
hazardous and non-hazardous waste. exploring use of local materials, recycled
Minimize and manage the risks and aggregates, use of innovative technology so
impacts associated with pesticide use. as to minimize project’s footprints on finite
Requires technically and financially natural resources. During the sub-project
feasible measures to improve efficient design and implementation pollution to air,
consumption of energy, water, and raw water and land mostly by the lacking of best
materials, and introduces specific work practices and the improper handling of
requirements for water efficiency hazardous and non-hazardous products,
where a project has high water chemicals and wastes, unscrupulous
demand. consumption of finite resources like water,
energy and different raw materials, etc.
need to be properly addressed, as these may
otherwise threaten people, ecosystem
services and the environment at the local
and regional level.
ESS-4 Anticipate or avoid adverse impacts on Requirements on infrastructure, considering safety Impact assessment relating to every sub-
Community-Health- the health and safety of project- and climate change, and applying the concept of projects on the health and safety of the
and-Safety affected communities during project universal access, where technically and financially affected communities including of the
life-cycle from routine and non-routine feasible. Requirements on traffic and road safety, vulnerable groups (because of their
circumstances. Promote quality, safety, including road safety assessments and monitoring. particular circumstances, e.g., child, women,
and climate change considerations in Addresses risks arising from impacts on provisioning old-aged, people of smaller ethnic groups,
infrastructure design and construction, and regulating ecosystem service. Measures to avoid etc.) is required to undertake prior to any

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including dams. Avoid or minimize or minimize the risk of water-related, communicable, physical intervention is taken place, and the
community exposure to project-related and non-communicable diseases. Requirements to assessment will also identify the risks for
traffic and road safety risks, diseases assess risks associated with security personnel, and Gender-Based Violence (GBV) or Sexual
and hazardous materials. Have in place review and report unlawful and abusive acts to Exploitation and Abuse (SEA) of children, or
effective measures to address relevant authorities. communicable diseases which may arise
emergency events. Ensure that from different circumstances, and the
safeguarding of personnel and property Relevant GoB Laws and Regulation necessary preventative/risk mitigation
is carried out in a manner that avoids a) ECR 1997 measures taking into account relevant
or minimizes risks to the project- b) BLA 2006 engineering safety considerations,
affected communities. c) Public Procurement Rule,2008 authorized certification, universal access in
d) Water Act 2013 project design, awareness trainings,
publicized codes of conduct, grievance
system, etc. are suggested to be included as
part of management plan options.

However, establishing a quality

management system to avoid occupational
health & safety risks for involved workers
and risks related to pollution and ecosystem
services for the communities may lessen the
overall risk to a significant level. Further
consideration of climate change effects and
emergency preparedness and response will
surely be embedded into proposed sets of
measures as indicated in this ESS.
ESS-5 Avoid or minimize involuntary Applies to permanent or temporary physical and A separate RPF has been prepared to
Land-Acquisition- resettlement by exploring project economic displacement resulting from different types address ESS5. The Project will screen out
Restrictions-on-Land- design alternatives. Avoid forced of land acquisition and restrictions on access. Does not land acquisition. Also no voluntary land
Use-and-Involuntary- eviction. Mitigate unavoidable adverse apply to voluntary market transactions, except where donation will be there. Informal settler and
Resettlement impacts from land acquisition or these affects third parties. Provides criteria for land requisition for labor rest areas and
restrictions on land use by providing “voluntary” land donations, sale of community land, construction material storage are illustrated
compensation at replacement cost and and parties obtaining income from illegal rentals. in RPF
assisting displaced persons in their Prohibits forced eviction (removal against the will of

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efforts to improve, or at least restore, affected people, without legal and other protection
livelihoods and living standards to pre- including all applicable procedures and principles in
displacement levels or to levels ESS5). Requires that acquisition of land and assets is
prevailing prior to the beginning of initiated only after payment of compensation and
project implementation, whichever is resettlement has occurred. Requires community
higher. Improve living conditions of engagement and consultation, disclosure of
poor or vulnerable persons who are information and a grievance mechanism.
physically displaced, through provision
of adequate housing, access to services Relevant GoB Laws and regulation
and facilities, and security of tenure. Acquisition and Requisition of Immovable Property
Conceive and execute resettlement Act, 2017
activities as sustainable development
programs.
ESS-6 Protect and conserve biodiversity and Requirements for projects affecting areas that are At this preliminary stage, all the sub-project
Biodiversity- habitats. Apply the mitigation hierarchy legally protected designated for protection or sites are not identified yet, therefore,
Conservation and and the precautionary approach in the regionally/internationally recognized to be of high sensitive places around the sites having rich
Sustainable design and implementation of projects biodiversity value. Requirements on sustainable biodiversity or living natural resources are
Management of that could have an impact on management of living natural resources, including not identified yet. However, all the sites in
Living Natural biodiversity. To promote the primary production and harvesting, distinguishing rural settings and Haor areas in North-East
Resources sustainable management of living between small-scale and commercial activities. region of the country are more likely to have
natural resources. Requirements relating to primary suppliers, where a biodiversity in closer proximity to the sites,
project is purchasing natural resource commodities, which need to be conserved very cautiously.
including food, timber and fiber. All these biodiversity rich areas including the
location of Ecologically Critical Areas will be
identified the screening of each sub-project,
and necessary assessment and mitigation
(preferably conservative) plan will be put in
place that will be proportionate to the
potential risks and impacts.
ESS-7 Ensure that the development process Applies when the Indigenous Peoples are present or Some parts of Rangpur, Rajbari and Habiganj
Indigenous- fosters full respect for affected parties’ have a collective attachment to the land, whether they are inhabited by different indigenous groups
Peoples/Sub-Saharan human rights, dignity, aspirations, are affected positively or negatively and regardless of of people, and if the project implement any
African Historically identity, culture, and natural resource- economic, political or social vulnerability. The option sub-projects in those areas, those groups

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Underserved based livelihoods. Promote sustainable to use different terminologies for groups that meet will be rigorously and meaningfully
Traditional Local development benefits and the criteria set out in the Standard. The use of national consulted from the design stage of each
Communities opportunities in a manner that is screening processes, providing these meet World Bank subproject, in order to ensure that their
accessible, culturally appropriate and criteria and requirements. Coverage of forest dwellers, rights, dignity, aspirations, identity, culture,
inclusive. Improve project design and hunter gatherers, and pastoralists and other nomadic natural resource based livelihoods are not
promote local support by establishing groups. Requirements for meaningful consultation affected at all. Every measures have to be
and maintaining an ongoing tailored to affected parties and a grievance put forth to avoid any adverse impacts on
relationship based on meaningful mechanism. Requirements for a process of free, prior the people and promoting development
consultation with affected parties. and informed consent in three circumstances. benefits and opportunities for that group in
Obtain the Free, Prior, and Informed a manner that is accessible, culturally
Consent (FPIC) of affected parties in appropriate, inclusive and sufficiently
three circumstances. Recognize, informed.
respect and preserve the culture,
knowledge, and practices of Indigenous
Peoples, and to provide them with an
opportunity to adapt to changing
conditions in a manner and in a
timeframe acceptable to them.
ESS-8 Protect cultural heritage from the Requires a chance finds procedure to be established. It is very less likely that any cultural heritage
Cultural-Heritage adverse impacts of project activities Recognition of the need to ensure peoples’ continued will be affected or in threat to be affected by
and support its preservation. Address access to culturally important sites, as well as the need the project intervention, as sites will be
cultural heritage as an integral aspect for confidentiality when revealing information about selected and finalized from a set of potential
of sustainable development. Promote cultural heritage assets that would compromise or sites’ listing (based on the findings of a
meaningful consultation with jeopardize their safety or integrity. Requirement for comprehensive survey to be conducted),
stakeholders regarding cultural fair and equitable sharing of benefits from commercial which are already occupied by primary
heritage. Promote the equitable use of cultural resources. Provisions of archaeological school facilities or established community
sharing of benefits from the use of sites and material, built heritage, natural features with infrastructures (incl. public buildings,
cultural heritage. cultural significance, and moveable cultural heritage. drainage structures, etc.) or designated sites
for jetties, embankments, and so on.

ESS-9 Sets out how Financial Intermediaries Financial Intermediaries (FIs) to have an Not relevant as there is no financial
Financial- (FI) will assess and manage Environmental and Social Management System (ESMS) intermediary involved.
Intermediaries environmental and social risks and - a system for identifying, assessing, managing, and

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impacts associated with the monitoring the environmental and social risks and
subprojects it finances. Promote good impacts of FI subprojects on an ongoing basis. FI to
environmental and social management develop a categorization system for all subprojects;
practices in the subprojects the FI with special provisions for subprojects categorized as
finance. Promote good environmental high or substantial risk. FI borrowers to conduct
and sound human resources stakeholder engagement in a manner proportionate to
management within the FI. the risks and impacts of the FI subprojects.
ESS-10 Establish a systematic approach to Requires stakeholder engagement throughout the A separate SEP has been prepared to
stakeholder engagement that helps project life cycle, and preparation and implementation address ESS10.
Stakeholder- Borrowers identify stakeholders and of a Stakeholder Engagement Plan (SEP). Requires An open, transparent, constant and effective
Engagement-and- maintain a constructive relationship early identification of stakeholders, both project- engagement between the LGED and relevant
Information- with them. Assess stakeholder interest affected parties and other interested parties, and stakeholders will ensure the environmental
Disclosure and support for the project and enable clarification on how effective engagement takes place. and social sustainability of RIVER project and
stakeholders’ views to be taken into Stakeholder engagement to be conducted in a manner enhance project acceptance, and will make
account in project design. Promote proportionate to the nature, scale, risks and impacts significant contribution to successful project
and provide means for effective and of the project, and appropriate to stakeholders’ design and implementation. On this account,
inclusive engagement with project- interests. Specifies what is required for information an effective engagement with stakeholders
affected parties throughout the project disclosure and to achieve meaningful consultation. has been initiated at the very early stage of
life-cycle. Ensure that appropriate the project development process through a
project information is disclosed to series of events following different
stakeholders in a timely, modalities and those engagement activities
understandable, accessible and are continued as per scoping and
appropriate manner. requirement.
Establishing an effective project GRM is also
very vital for an all-inclusive and timely
responsive project design and
implementation Environmental and social
performance of this project significantly rely
on the fact that the grievances are redressed
in an appropriate manner within a strict
timeframe. However, GRM system in no way
will make constraint to the access of
national judicial system.

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Environmental and This Directive applies to the Bank and It lays down the following responsibilities of the Bank Applies to Bank in addressing
Social Directive for sets out the mandatory requirements to manage ES risks and impacts as below: a) undertake E&S aspects of this project
Investment Project for the its own due diligence of the ES risks and impacts
Financing implementation of the Environmental related to the Project; b) support the Borrower to
and Social Policy for Investment Project engage in meaningful consultation with stakeholders,
Financing in particular affected communities, and in providing
(IPF). Project-based grievance mechanisms; c) assist the
Borrower Applies to Bank in addressing E&S aspects of
this project in identifying appropriate methods
Bank Directive This Directive establishes directions for It requires the Bank task team to support the Applies to Bank in addressing E&S risks and
Addressing Risks and Bank staff regarding due diligence borrower in establishing arrangements for the impacts on disadvantaged and vulnerable
Impacts on obligations relating to the identification undertaking and preparation of the environmental and persons or groups that are identified in this
Disadvantaged or of, and mitigation of risks and impacts social assessment of the project as required by ESS1. It project
Vulnerable on, individuals or groups who, because reviews the terms of reference for the environmental areas.
Individuals or Groups of their particular circumstances, may and social assessment to verify that (a) identifies (or
be disadvantaged or vulnerable requires the identification of) groups or individuals
affected by the project that may be disadvantaged or
vulnerable; and (b) requires an assessment of project
risks and impacts, and identification of differentiated
mitigation measures, as they pertain to the
disadvantaged or vulnerable
individuals or groups that are identified.
General EHS The General EHS Guidelines contain Requirements on environmental, health, and safety Applicable to all sub-project construction
Guidelines, information on cross-cutting issues during construction of project road. sites where workers are employed, and H&S
April, 2007, IFC environmental, health, and safety risks can be generated for all who
issues potentially applicable to all uses/works in the site or living in the
industry sectors surroundings.

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3.6 Gap Analysis of World Bank Requirements and National Laws

A gap analysis between WB’s ESSs and GoB Regulations was conducted and the results of the gap
analysis indicated that the Environmental and Social risk assessment and management system for
development projects in Bangladesh is open-ended and similar to other country's ESA systems, does not
cover all the World Bank ESF's ES Standards. The ECR’97 that categorizes the industries based on
potential risks/impacts has not put any guidance on the ways to classify a project, which includes
different industries (e.g., construction of bridges, culverts or roads, buildings, etc.) under a single title.
The Department of Environment (DoE), which is the legislative body for upholding this instrument,
generally gives a clear indication when the project proponent approaches to the authority and there are
also several guidelines for industries promulgated from the DoE which in principal cover most of the
project activities undertaken in the country. Further, the ECA/ECR does not even define the scope of the
EIA study (or the IEE), leaving it to the argument for EIA preparation and the scope is determined
through initial assessment/screening. The coverage of the EIA study therefore would depend on the
expertise of the EIA team or the DoE reviewers. There is no assurance that each ES Standard (1-8 and
10) are considered in the EIA study and the formulation of the ESMP. Although the EIA is heavy towards
the environmental aspects, more and more social issues are incorporated in the assessment. Moreover,
the practice under normal circumstances does not include labor management issues. Another critical
gap pertains to lack of provisions for requiring the preparation of project-specific ES management plans.
The eminent domain land acquisition system for example does not require the preparation of RAP in
case of having only the non-titled entities. The projects are also not required to formulate their own
Labor Management Procedures/Plans. Given the gaps, this ESMF will follow the most stringent
standards and requirement. Table 3.7 below has given an overview of the gaps between GoB laws and
WB’s ESSs and steps to be adopted to address those gaps for this project.
Table 3.7: Gaps between GoB Laws and World Bank ESSs
WB ESF Standard Gaps in National Policy/Legal Instruments Gap Filling Measures
(in relation to ESSs)
ESS1: Assessment and (i) EIA study screening and scoping do not ESMF has has put forth all relevant
Management of guarantee coverage of all ESSs in the measures to follow the ESS1
Environmental and assessment. requirements, given in the relevant
Social Impacts and (ii) EIA study does not advocate to include sections of Environmental Management
Risks both the environment and social impacts at Procedures.
same scale but the ESF does. It’s obvious from all the previously
(iii) The stakeholder engagement during the promulgated document from the
conduct of the EIA is limited and the EIA department of environment (DoE) that
report is not disclosed. none of the acts, rules or guidelines put
adequate emphasis on addressing social
impacts in Environmental Assessment,
and stakeholder engagement or
disclosure of information was not set
obligatory (the requirement was not
evident in any legal documents).
However, in recently (Feb’ 2021)
circulated ‘EIA Guidelines for Industries’
by the DoE has incorporated both of the
said requirements, which supplements
the requirement set by the relevant ESSs.

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ESS2: Labor and (i) The Labor Act does not specifically A separate LMP has been prepared which
Working Conditions require that development be assessed and will guide requirements for OHS plan.
reviewed in terms of labor and working
conditions including OHS requirements The labor management procedure will be
before approval. prepared to regulate working condition
(ii) The Labor Act does not require and management of workers relation
development projects to prepare Labor including worker specific GRM, terms and
Management Plans/Procedure or OHS Plan. conditions of employment, non-
discrimination and equal opportunity,
GBV, protection of workforce, the
prohibition of child/forced labor, safe
working conditions, and provision of OHS.

ESS3: Resource Existing energy and water conservation ESMP to be developed for each sub-
Efficiency and policies, laws and regulations do not require projects to address this issue, and
Pollution Prevention development projects to assess resource incorporate mitigation measures for
and Management efficiency issues and incorporate resource efficient use of water resources.
efficiency measures in their ES risk
management plans.
ESS4: Community Covered under ‘EIA Guidelines for DoE Environmental clearance in general
Health and Safety Industries’ but the systems/laws do not always recommends to careful vigilance
provide clear requirements for the or oversight on Community health and
development project and implementation. safety issues, irrespective of project
nature and location.
Risks related to sub-project specific
community health and safety will be
screened out, and necessary assessment
and mitigations measures will be in
place as part of Environmental and Social
Management Procedure..
ESS5: Land Acquisition, ARIPA 2017: Though a separate RPF has been
Land Use Restriction (i) does not require the preparation of RAP prepared for the project, any potential
and Involuntary in case of non-titled entities; sites which are at risk of requiring land
Resettlement (ii) does not provide compensation or acquisition will be dropped out from the
assistance to those who do not have formal proposed through a negative list.
legal claim to the land;
(iii) does not provide transitional allowances If any unavoidable issues/circumstances
for restoration of livelihoods for informal arise, for example, informal settler on a
settlers; public land in a school premises need to
(iv) relies on cash compensation, no be resettled and compensated;
developmental objectives; requirements set in ESS5 will be followed
(v) no provision to give special attention to and incorporated in RAP (Resettlement
the vulnerable groups Action Plan).
(vi) valuation of lost asset is not based on
"replacement cost' standard
ESS6: Biodiversity No equivalent requirements on: (i) the The project will apply mitigation
Conservation and application of hierarchy of measures; (ii) the hierarchy measures in Environmental and
Sustainable preparation of Biodiversity Management Social Assessment process as directed in
Management of Living Plan; (iii) differentiated measures on types ESS1, and differentiated measures will be
Natural Resources of habitats. in any of the national adopted based on the types of habitats
instruments. that a sub-project/activity may find
within the influence area.

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ESS7: Indigenous None of the national legal binding Appropriate assessment on relative
People /regulatory documents articulates the vulnerabilities and impacts due to the
equivalent requirements on: (i) coverage of project activities will be conducted or
IP impacts in the IEE/ESIA; (ii) special identified, if any IP community is found
treatment or differentiated approach to IPs at or near any sub-project sites;
and vulnerable groups; (iii) conduct of FPIC; Indigenous People Development Plan
(iv) development of IP Plan. (IPDP) may be necessary to develop by
the consultants, in light of ESS7 and ESS1.
Differentiated approaches for different
groups/clans will be rationalized as well
in the plan and monitoring on
implementation will be stringent
Activities requiring FPIC shall be screened
out and no sub-project will be
implemented without having full consent
from the respective Indigenous Groups
(Smaller Ethnic Communities, SEC).
ESS8: Cultural Heritage No equivalent requirements on: (i) the World Bank’s Chance Finding procedure
application of hierarchy of measures; (ii) the will be followed, if cultural heritage or
development of Cultural Heritage resources are found at any point.
Management Plan; (iii) the development
and adoption of project-specific Chance
Find Procedures; and (iv) the engagement
of cultural heritage experts.
ESS9: Financial Not applicable to country system. Project N/A
Intermediaries proponents regardless of funders are
subject to the same country laws.
ESS10: Stakeholder The ECA/ECR does not specifically require A separate SEP has been prepared.
Engagement and consultation but the IEE/ESIA guidelines Guideline for stakeholder’s engagement
Information Disclosure issued by DOE and other agencies provided in the project SEP/ESMF will be
recommends public consultations during followed.
scoping and the preparation of the IEE/ESIA.
There is also no provision for any
stakeholder engagements during project
implementation

3.7 Application of GoB Policies, Acts and Rules on RIVER Project components and
Project Categorization
The legislations relevant to the environmental assessment for the RIVER project components are the
Environmental Conservation Act 1995 (ECA'95) and the Environmental Conservation Rules 1997
(ECR'97). Article-12 of Environment Conservation Act ’1995, the key Act governing environmental
protection in Bangladesh, clearly states the requirement of obtaining environmental clearance
certificate in a prescribed manner from the Director General of DoE before commencing operation or
establishment, and one of the key procedures to obtain the Environmental Clearance Certificate is to
undertake an environmental assessment. This assessment might simply be a screening and
categorization or an IEE or a comprehensive EIA. In order to set an illustrative directive for abiding by
the act, Bangladesh Government through the Environmental Conservation Rules ’1997 and its
subsequent amendments, as specified in rule 7(2), present a categorization of all the potential industrial

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

interventions or projects into four distinct types- Green, Orange A, Orange B and Red, considering the
site of the interventions and impact on the environment.
The procedure and required documents for obtaining environmental clearance in favor of each category
have also been mentioned in the ECR. As part of a government entity, LGED is obliged to abide by all
these acts and rules, in addition to other GOB acts, rules or guidelines.
As per ECR’97, most the components/sub-components and associated activities under this project are
more likely to fall in ‘Orange B’ Category. Activities such as ‘ repair/rehabilitation of Jetties/ Landing
Stations’ , ‘repair/rehabilitation of rural markets, ‘Installation of solar PV/Nano-grid/thunder protection
system’ are not in the listed items under the ECR’1997 and may not fall under any specific category
suggested by the DoE. However, activities of these subprojects involve minor civil works and
construction impacts will be very less to negligible and confined within a tiny/smaller areas. Considering
the nature and size of the project activities it is expected that the impacts associated with those project
components would be similar to the other listed components, which are of either ‘Orange-A’ or ‘Orange-
B’ Category. During the detailed design stage, the study team and LGED should consult with the DoE to
take the final decision for the level of assessment and further clearances. Initially, it is suggested that
the project should conduct Environmental and Social Assessment and prepare ESMP for those activities
prior to the start of actual intervention.
It is the responsibility of the IAs to conduct ESA and prepare ESMP of the project activities, the
responsibility to review ESA and ESMP for issuing Environmental Clearance Certificate rests on DoE.
Though, the project involves a good number of sub-projects/activities under different work packages, a
sample ESA (IEEs) along with respective site-specific ESMP will suffice the requirements for obtaining
clearance certificate in favor of the project. The Department of Environment (DoE), the technical arm of
the Ministry of Environment, Forest and Climate Change (MoEFCC) is the regulatory body and the
enforcement agency of all environmental issues. Like all other projects, this project also needs to meet
the requirement of the DoE. The procedures for “Orange B” Category include submission of:
 An Initial Environmental Examination (IEE) [sample IEE reports for this project], and
 An Environnemental Management Plan (EMP) [i.e., respective ESMPs]
Environment clearance has to be obtained by the respective implementing agency or project proponent
(private sector) from DoE. The environmental clearance procedure, as presented in figure 3.1, for
Orange-B Category projects can be summarized as follows:
(1) Application to DoE for Obtaining Site Clearance
(2) Applying for Environmental Clearance with submitting necessary documents (NOC, Feasibility
Study Report, sample IEEs, ESMF, etc.) online and presenting the same as hardcopies
(3) Obtaining Environmental Clearance
(4) Clearance Subject to Annual Renewal.

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Figure 3.1: Process of Obtaining Clearance Certificate from DoE

3.8 Application of WB ESSs

All ESSs will be applicable in the RIVER Project, except the ESS 9: Financial Intermediaries. The project
components will involve minor civil works confined within smaller sites, and on government lands only.
Anticipated environmental impacts will be addressed through implementation of various mitigation
measures under supervision of PIU. The project will use mostly the local labors from the local
communities, therefore, risks related to social issues and gender based violence/SEA are likely to be
limited. Moreover, the project will follow standard Environmental and Social Codes of Practices
throughout the cycle. Considering all the backgrounds, possible site locations and interventions, and
LGED’s capacity to sound implementation, the Environmental and Social Risk Classification (ESRC) of the
RIVER Project has been classified as ‘Moderate’,

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CHAPTER 4: ENVIRONMENTAL AND SOCIAL BASELINE

4.1 Introduction
The objectives of the baseline study were to gather information on the existing physical and ecological
surveys and other studies (e.g., physical infrastructures, water supply and sanitation, solid waste
management, water quality, and noise level measurements) of the areas within and around the project
sites, and to assess peoples’ perception on different aspects of the proposed project. The data and
information gathered during the baseline study provide a detailed description of the existing conditions
of physical and biological environment in and around the project areas. The possible environmental
impacts of the sub-projects will be evaluated against these baseline environmental conditions.

4.2 Description of Environmental Baseline

General Background of the project area
The project area is spread over fourteen districts of Bangladesh, which fall in four different
administrative divisions of the country. Among the districts, Sunamganj is the biggest district in areas
covered, while Rajbari is the smallest one. Rangpur, Bogura, Faridpur, and Sunamganj are among the
districts in respective divisions to have the highest numbers of administrative units (Upazila/Union);
therefore, these districts seem to be more capable of taking coordinated efforts in disaster
management.
Figure4.1: Administrative divisions and areas in project districts

Division Districts Area (sq. km) No. of No. of

Upazilas/ Pourashavas/
Unions Municipalities
Rangpur Nilphamari 1643.40 06/60 04
Lalmonirhat 1247.371 05/45 02
Kurigram 2245.04 09/72 03
Rangpur 2400.56 08/76 City Corporation-01,
Pourashava-03
Gaibandha 2179.27 07/81 04
Rajshahi Bogura 2919.00 12/108 12
Sirajganj 2497.92 09/83 07
Pabna 2371.50 09/74 09
Dhaka Madaripur 1144.96 04/59 04
Faridpur 2072.72 09/81 07
Rajbari 1092.30 05/42 03
Gopalganj 1489.92 05/68 04
Sylhet Sunamganj 3747.18 11/87 04
Habiganj 2636.58 09/77 06
Total 29,687.72 108/1013 72/ CC-01
(20.12%)

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Presence of municipalities or pourashavas in a district demonstrates the progress of urban development

in the areas along with associated urban support services that supports the population to secure
knowledge in disaster management and preparedness options, and develop urges for education for their
children.
The project area comprising of fourteen districts, covering 29,688 square kilometer of area that shares
20.12% of the total area of the country. This project intervention, thus, are targeting one-fifth areas of
the country, where the recurring flooding events take the tolls at enormous scale, and building
resilience/adaptation against the flood is pivotal for realizing the economic development in course of
time.

Bio-Physical Environment
Climate
Bangladesh has a subtropical monsoon climate characterized by wide seasonal variations in rainfall, high
temperatures and humidity. The most striking feature of its climate is the reversal of the wind
circulation between summer and winter, which is an integral part of the circulation system of the South
Asian subcontinent. There are three distinct seasons in Bangladesh: a hot, humid summer from March to
June; a cool, rainy monsoon season from June to October; and a cool, dry winter from October to
March. In general, maximum summer temperatures range between 30°C and 40°C. April is the warmest
month in most parts of the country. January is the coldest month, when the average temperature for
most of the country is about 10°C.
Table 4.2: Climatic Sub-Regions of project districts

Division Districts Climatic Sub-Regions

Rangpur Nilphamari, Northern part of
Lalmonirhat Northern Region and
Kurigram North-Western
Rangpur Climatic Region
Gaibandha
Rajshahi Bogura North-Western
Sirajganj Climatic Region
Pabna (part of Pabna- South
Western Zone)
Dhaka Madaripur South-Western and
Faridpur South-Central Region
Rajbari
Gopalganj
Sylhet Sunamganj North-Eastern and
Habiganj South-Central Region

Figure 4.1: Climatic Sub-Regions in Bangladesh

There are widespread differences in the intensity of the seasons at different places of the country and
based on these differences, Bangladesh can be divided into seven distinct climatic zones (refer to table

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

4.2 and figure 4.1). The project districts under the Rangpur division fall within Northern part of the
northern region and North-western climatic region. The first climatic zone is an area of extremes, mean
max. temperature goes well above 32°C whereas in winter the mean temperature becomes below 10°C.
Dry summer, with a scorching westerly wind, and wet rainy season with 2,000 to 3,000 mm of rainfall
further characterize the variation. The later region are of lesser extreme, the rainfall is lower that makes
the area both atmospherically and pedologically drier.
The project districts under Rajshahi division, especially Bogura, Sirajganj and western part of Pabna fall
into the same North-western climatic region, except South-eastern part of Pabna falls in South-western
climatic zone, where rainfall is between 1500 mm and 1800 mm and the mean summer temperature is
below 35°C, but heavier dew-fall in winter.
Rajbari and part of Faridpur under Dhaka division show the climatic characteristics of South-Western
climatic zone; Madaripur and Gopalganj demonstrate the characteristics of South-central climatic zone
where the rainfall is abundant (above 1,900 mm) and the range of temperature is much lesser than
western part, and most of the several hail storms, nor’westers and tornadoes are recorded in this area.
Greater part of Habiganj district fall in the South-central climatic zone, but Sunamganj lies within North-
eastern climatic zone where the mean maximum temperature rises rarely above 32°C, but mean
minimum is 10°C or below. Average humidity in this zone is relatively higher and this zone is the
cloudiest part of the country. Winter rain is much appreciable, where the Fog is also very common in the
same season.
These prevailing climatic conditions contribute in soil formation, local hydrology and sometimes the
types of natural disasters the respective zone faces.
Hydrology and Water Resources
Availability of fresh water in Bangladesh is highly seasonal and depends on monsoon rainfall both inside
and outside of Bangladesh in the GBM (Ganges-Brahmaputra-Meghna) catchments. Monsoon accounts
for 70 – 85% of annual rainfall, and about 92% of the annual run-off; 8% is generated by rainfall within
the country. The entire water ecosystem of Bangladesh, comprised of the GBM Rivers, their tributaries
and distributaries, and perennial and seasonal water bodies like haors, baors and beels, is characterized
by this seasonality of rain and its variability. All three river systems originate outside Bangladesh. Of the
230 rivers in the country 57 are trans-boundary rivers and Bangladesh is situated at their lowest points.
Of the 57, 54 come down from India and 3 from Myanmar. The same pattern of seasonality in rainfall is
applicable to river flows as well, as river flows greatly depend on monsoon rainfall and the summer
snow melt in the upper Himalayas.
The hydrology of the proposed project districts are inextricably related to the presence of some big
rivers flowing across or through the areas, some of those are tabulated in Table 4.3. Among the districts,
Rangpur is crisscrossed by the river Donai, Ghagat, Tista, and Brahmaputra-Jamuna, while Karatoya
flows through the district Bogura, and the hydrology of Faridpur district is largely dependent on the
flows of river-Padma, Kumar, Arial Khan and Banar. Pabna sees the presence of two mighty river system-
Ganges-Padma and Brahmaputra-Jamuna. All these rivers contribute in replenishing the groundwater
reserves in the districts as well as maintaining the total water budgeting that has a tremendous effect on
local agricultural yields.

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Table 4.3: Major rivers in the covered districts

Name of the rivers Length (Km) District Covered (covered length)
Donai-Charalkata-Jamuneswari- 363 Rangpur (120), Bogura (98),
Karatoya Pabna(62)
Tista 113 Rangpur (70)
Ganges-Padma 355 Pabna (60) Faridpur (80)
Brahmaputra-Jamuna 150 Rangpur (75) Pabna (75)
Ghagat 247 Rangpur (237)
Banar 162 Faridpur(96)
Kumar 130 Faridpur (101)
Arial Khan 163 Faridpur (64)
Source: Bangladesh Water Development Board 2018

Sunamganj, among all the 14 project districts is very rich in terms of having presence of large
number of standing water bodies, especially haors and Beels, including Tanguar Haor, Kahabil
Matin Haor, Banuar Haor, Sanir Haor, Rahimpur-Dupkushi Beel and so many other water bodies.
Habiganj also has got many of such kind of water bodies. Eklaspur Hazhagi Beel in Bogura and
Kagdir Baor in Faridpur are also famous for their presence with affluent aquatic habitats
including different varieties of fishes and other aquatic faunal species. Table 4.4 presents some
of the major water bodies in the project districts. These water bodies also has a great
contribution as large water reservoirs providing aquatic ecosystem-based support services and
a significant source of protein based nutrition for the poor people in the country.
Table 4.4: Major water bodies/Haor-baor/lake
Major Water Bodies/Haor-Baor/Lake District
Tanguar Haor, Kahabil Matin haor, Chaular Haor, Kanamiya Haor, Pasua Haor, Sanir Haor, Sunamganj
Banchapar Haor, Bohabula-Baldar Beel, Rahimpur-Dupkushi Beel
Eklaspur Hazhagi Beel Bogura
Kagdir Baor Faridpur
Haitula haor, Raoband Haor, Pipir Haor, Haitula Haor, Medarkandi Haor, Sat Halia Haor Habiganj

Though it is not confirmed yet whether or which water bodies exist by or near to any sub-project sites,
necessary precautions or code of conducts have to be followed in order to avoid/ minimize potential
events of water pollution that may disrupt the quality of water, and pose threat to the aquatic
biodiversity and ecosystem services
Physiography and Soil
The country is divided into three broad physiographic units belonging to three distinct geological ages:
A. Tertiary hills occupying 12% area
B. Pleistocene terraces covering 8% area and

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C. Recent floodplains spreading about 80% area of the country

These three physiographic units are again categorized into 20 different physiography considering their
geomorphology and origin of soils.
All the project districts under Rangpur division fall in Teesta floodplain, with high to medium high land
coverage. The soil type is Sandy loam to Silty-clay-loam. Whereas, Barind tract dominates the area of
Bogura, and Sirajganj and Pabna relates to two other floodplain areas. All the districts in Dhaka division
are physiographically the part of Ganges floodplain, while the two districts in Sylhet division falls in
Sylhet Basin and partly in Old Meghan Estuarine Floodplain. Physiographic division and soil types of
project districts are given in table 4.5.

Table 4.5: Physiography and soil type of the proposed districts

Division Districts Physiography Land & Soil Type
Rangpur Nilphamari Teesta Floodplain High & Medium High Land;
Lalmonirhat
Sandy loam, loamy, Silt-Clay-
Kurigram loam soil
Rangpur
Gaibandha
Rajshahi Bogura Barind Tract, Bogura-Medium low, Grey, Silt
Karatowa-Bangali loam and silt clay-loam;
Floodplain,
Sirajganj Sirajganj and Pabna-High,
Medium High, Silt loam, Silt clay-
Lower Atrai Basin loam
Pabna (Pabna-Ganges FP)
Dhaka Madaripur Ganges Floodplain Medium high, medium low; Silt
Faridpur loam, Silt clay-loam
Rajbari
Gopalganj
Sylhet Sunamganj Sylhet Basin, Old Medium low to very low; Heavy
Habiganj Meghna Estuarine silt clay loam, Grey color
Floodplain (Habiganj)

Natural Land Coverage

Natural Land Coverage shows the potential sites for any development activities in a district. Terrestrial
barren land is suitable for every physical development works to take place, whereas extent of inland
water bodies in a district may restrict some of the development activities, or that may support
developing those projects, which are more related to the development of natural resources or so on.
Similarly, coastal water bodies and intertidal areas corroborate some very distinctive land cover
features, which may not be suitable for all kinds of development activities. However, none of the
sections in RIVER Project districts falls within the coastal water or inter-tidal areas; and Sirajganj has got
the biggest amount of terrestrial barren land area followed by Habiganj; and Sunamganj tops in having
the biggest area in Inland water bodies (refer to table 4.6).

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Table 4.6: Land cover categories in the proposed districts

Division Districts Major Land Cover Categories
(Area in Hectares)
Terrestrial Barren Land Inland Water Bodies
Rangpur Nilphamari 0.00 21833.46
Lalmonirhat 0.00 9559.70
Kurigram 0.00 57569.00
Rangpur 0.00 36118.40
Gaibandha 0.00 40701.00
Rajshahi Bogura 0.00 41851.89
Sirajganj 8595.22 100479.72
Pabna 0.00 52202.00
Dhaka Madaripur 650.00 47127.34
Faridpur
Rajbari 750.00 26248.00
Gopalganj 0.00 78598.20
Sylhet Sunamganj 0.00 111952.15
Habiganj 14238.00 60565.00
Source: Ministry of Fisheries 2019

Environmental Quality
i) Air Quality by reference districts
In 2019, Department of Environment conducted a survey campaign on air quality testing in several
selected districts in Bangladesh; none of those is the project districts of RIVER. However, considering the
close proximity from the districts in the respective divisions, Rajshahi from Rajshahi division,
Narayanganj form Dhaka Division, Sylhet from Sylhet division have been chosen as reference districts to
have a rough idea of how the air quality in those districts and surrounding project districts are evolved.
Data for any reference point/district of Rangpur division was not found from the same source; hence, no
information was presented for that division. The quality of air across the districts in Bangladesh should
differ significantly for the effects of urbanization, temperature/climatic difference, and effects of
blowing wind directions, density of people and commuters, and such other criteria. In comparing with
the Country standard for all the parameters’ value in following table, Air quality in the districts near to
Dhaka is more likely to have much high concentration of pollutants as observed in the table 4.7,
specifically particulate matter (may originating from construction works) and NOx (from vehicular
movement). Particulate matters also can be originated from agricultural fields, car engines, power
plants, etc. However, air quality in most of the project districts is expected to be within the tolerable and
country standard limit, as those districts do not have a good industrial setups; but the elevated level of
PM2.5 from the agricultural fields and construction works and this level of PM2.5 may get further elevated
if suggested code of conducts/ mitigation measures are not followed in the working sites. In fact, effects
of winds during the dry season and vehicular movement for construction works at site will also
deteriorate the air quality for the time being. Table 4.7: Air quality in reference districts

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Division Reference Concentrati Concentrati Concentratio Concentrati Concentrat Concentra

Districts on level of on level of n level of on level of ion level of tion level
particulate Particulate tropospheric Carbon Sulphur of
matter matter Ozone (O3) monoxide Dioxide Nitrogen
(PM10) (PM2.5) (CO) (SO2) Oxides
(NOx)
Rajshahi Rajshahi 148.11 73.76 5.14 1.02 2.98 81.56
Dhaka Narayanganj 229.54 102.45 3.38 1.05 13.10 40.45
Sylhet Sylhet 98.70 50.37 5.50 1.29 10.03 18.27
Country Standard 150.00 65.00 157.00 10.00 80.00 100
Source: Department of Environment, 2019

ii) Surface Water Quality

Rivers are one of the prominent sources of surface waters in the project districts. As rivers are the final
and cumulative receptors of pollution loads from the respective areas and they are mostly
interconnected, they govern the hydrogeological settings and quality of a particular area.

River water quality is not measured in Bangladesh quite often, so data in general is not available in
secondary sources. However, Department of Environment, as part of their special campaign in 2018 to
record water qualities of several rivers across the country, and most of the rivers flowing through the
districts under RIVER project were not within the target list. Eight rivers passing by the sample collection
points of respective eight districts have been counted and shown in table 4.8. The mighty Jamuna,
flowing through Sirajganj district showed the highest pollution concentration in terms of BOD
concentration, while Madhumati through Gopalganj showed the lowest pollution concentration in it. It’s
simply because of the industrialization of Jamuna bank areas in recent years and also the proximity to
Dhaka and other nearby industrial or populous districts wherefrom pollution load may find its way to
Jamuna. Water from all the rivers tested and tabulated here was found moderately polluted, while the
pH level was found within the optimum range. Dissolved oxygen, in Jamuna river at Sirajganj also suffers
from oxygen deficiency which is another marker for containing pollution load. Surprisingly, Madhumati
in Gopalganj is the only river facing the salinity problem, which is alarming for the river ecosystem in the
area, also for all the potential industrial, agricultural and construction sectors, as saline water is
detrimental to the use of all these sectors.

Though it is not confirmed yet whether any of the rivers quoted here in the matrix are located at or
flowing through the areas which are close to any sub-project sites, this water quality results signifies
only a general picture of surface water qualities in those areas; this quality may vary significantly
whenever sub-project specific survey and screening procedure will be undertaken in the field. Updated
data of Dhaka division for the rivers covering the project area is absent.

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Table 4.8: Surface water quality in reference rivers

Division Districts Major Rivers Organic Matter Physical and Chemical Characteristics

Biochemical Chemical pH Salinity Dissolved

Oxygen Oxygen Oxygen (DO)
Demand (BOD) Demand
(COD)
1 2 3 4 5 6 7 8
Rangpur Nilphamari Ichamoti 2.2 13.33 7.83 - 6.4
Rangpur Tista 2.22 7.51 7.22
Gaibandha Brahmaputra 2.2 7.51 7.07
Rajshahi Bogura Karatowa 2.15 7.5 7.08
Sirajganj Jamuna 4.02 6.94 3.42
Pabna Ganges 2.30 7.47 7.14
Gopalganj Madhumati 0.75 7.46 0.2 5.06
Sylhet Sunamganj Kushiyara 1.98 11 7.97 6.92
Country Standard 0.2 4.0 6.5-8.5 6.0
Source: Department of Environment, 2018

Stratigraphy and Seismicity

The major structural elements of the Bengal Basin (Bangladesh) areas are identified by a combination of
existing, observable surface features. To the north of Bengal Basin is the Shillong Plateau, a Precambrian
block believed to have been moved upward during Pliocene-Pleistocene time. The Dauki Fault borders
the southern margin of the plateau. The Indo-Burman Ranges define the eastern margin of the basin,
comprising a folded, thrusted and wrench faulted arc complex, developed along the edge of the
Eurasian Plate due to subduction of oceanic crust and overlying sediments. In the Bengal Basin the
Eastern Fold Belt marks the outermost part of this compression zone. The Rangpur Saddle, a Pre-
Cambrian basement high located between the Indian Craton and the Shillong Plateau, to the southwest
and northeast respectively, separates the Bengal Basin from the Himalayan Foredeep. The Bogura Shelf
area rests on a Pre-Cambrian surface, gradually dipping towards southeast. The shelf itself is 60 to 130
km wide and its southeastern margin is defined by the continental slope. To the east of the slope is the
foredeep, where the eastern part is folded as a result of plate collision and currently the folded belt
connects the foredeep to the east subdividing the foredeep into two depocentres, the Surma Trough to
the north-east and the Hatiya Trough to the south-east, separated by the Tangail-Tripura High. The
tectonic map of Bangladesh and adjoining areas is given in figure 4.2 for clearer understanding.

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

Figure 4.2: Tectonic map of Bangladesh and adjoining Figure 4.3: Seismic zoning map of Bangladesh (Source:
areas BNBC'2020)
As shown above (figure 4.3) the seismic zoning map divides the country into four seismic zones with
different expected levels of intensity of ground motion. Each seismic zone has a zone coefficient, which
provides expected peak ground acceleration values on rock/firm soil corresponding to the maximum
considered earthquake (MCE). Those coefficient has been counted based on the presence of different
seismic plates in and around the country and adjoining areas, the risk potential caused by the
movement of plates and release of internal energies; and the project districts fall within the seismic
zones as per following table.
Table 4.9: Seismic zoning and risk potential of the project districts
Division Districts Seismic Zone Risk Potential/ Seismic
Intensity
Rangpur Nilphamari Zone-II Moderate
Lalmonirhat Zone-III Severe
Kurigram Predominantly Zone-IV Severe to Very Severe
Some parts in Zone-III
Rangpur Predominantly Zone-III Moderate to Severe
A small part in Zone-II
Gaibandha Zone-III Severe
Rajshahi Bogura Predominantly Zone-III Moderate to Severe
A small part in Zone-II
Sirajganj Zone-II & III Moderate to Severe
Pabna Zone-II Moderate
Dhaka Madaripur Zone-II Moderate
Faridpur Zone-II Moderate
Rajbari Zone-II Moderate
Gopalganj Zone-I Low

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Sylhet Sunamganj Zone-IV Very Severe

Habiganj Zone-IV Very Severe

The seismic forces on structures should be determined considering seismic zoning, site soil
characteristics, structure importance, structural systems and configurations, height and dynamic
properties of the structure. The structural system and configuration types for a building or a structure
should be determined in accordance with the provisions of Sec [Link] in BNBC 2020.
Flooding as natural disaster
Flood is a recurring natural disaster in Bangladesh that occurs into four different forms: i) flash Flood, ii)
riverine Flood, iii) localized rain-fed flood and iv) coastal flooding. Flash flood is characterized by rapid
rise and attenuation in streamflow or water levels with duration ranging from a few minutes to few
hours. It occurs mostly in the north-eastern, south-eastern and north-western part of the country. Local
rain-fed flood, occurs generally in the Gangetic deltas in the south-western part of the country, and in
the flood plains. This type of flood is caused by excessive local rainfall and drainage congestion. Riverine
flood, is a common phenomenon in the country caused by bank overflow and occurs mainly during the
monsoon. 80% of total rainfall and river discharge occur during this period. The skewed temporal
distribution of streamflow and rainfall results in abundance of water in monsoon, frequently resulting
into floods and occasionally causing water scarcity during the dry season. More than a third of the
country’s population is concentrated on the 100-year’s floodplains. The primary source of livelihood of
these people is climate-sensitive agriculture. Therefore, when a major flood hits the country, these
people suffer the most.
Table 4.10: Major rivers and flood hazard pattern in project districts
Division Districts Major Rivers Flood Hazard Pattern
Rangpur Nilphamari Brahmaputra, Dharla, Ghaghat, Low flood to Severe River
Lalmonirhat Karatowa, Tista Flooding
Kurigram
Rangpur
Gaibandha
Rajshahi Bogura Jamuna, Bangali, Karatowa, Nagar, Moderate River Flooding
Sirajganj Hurasagar, Ganges (Pabna)
Pabna
Dhaka Madaripur Madhumati, Chandana, Arial Khan, Moderate to Severe
Faridpur Padma Flooding
Rajbari
Gopalganj
Sylhet Sunamganj Zadukata, Khoyal, Longla, Kushiyara Severe Flash Flood to
Habiganj Moderate River Flooding

Biological Environment
The Rajshahi division can be discussed with the three bio-ecological zones; and these are i) Himalayan
Piedmont Plain (1), ii) Barind Tract (2), iii) Teesta Floodplain (4a), iv) Ganges Floodplain (4b) and iv)
Chalan Beel (5b). Barind Tract is the largest Pleistocene physiographic unit of the Bengal basin, covering
an area of about 7,770 sq km. It has long been recognized as a unit of old alluvium, which differs from
the surrounding floodplains. The Barind Tract covers most parts of the greater Dinajpur, Rangpur,
Pabna, Rajshahi, Bogra, Joypurhat, and Naogaon districts of the Rajshahi division. Barind Tract is located
in the centre and western part of Rajshahi division. The greater part of the tract is almost plain and is

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Resilient Infrastructure for Adaptation and Vulnerability Reduction(RIVER) Project

crisscrossed by only a few minor rivers. This tract is considered an ecologically fragile ecosystem with
extremely low vegetation cover.

On the other hand, Chalan Beel, one of the largest inland depressions of marshy character and also one
of the richest wetland areas of Bangladesh is extended over four adjacent districts, Rajshahi, Pabna,
Sirajganj, and Natore. Besides, large parts of Habiganj and Sunamganj are covered with a lot many haors
and baors, which are also fresh examples of having rich natural habitats and biodiversity. However, at
this preliminary stage, as all the sub-project sites are not identified yet, sensitive places around the sites
having rich biodiversity or living natural resources cannot be confirmed. It is noted that all the activities
under this project is very site-specific, and impacts of construction/rehabilitation works will be confined
within a small sub-project boundary or predefined alignment. Nevertheless, if any of the sites is found in
closer proximity to a rich biodiversity area, special cautionary measures will be taken and site specific
ESMP will cover the measures and stringent monitoring activities will be implemented as well.

Apart from the regional scenario, the biotic environment in the project areas consists of several
ecological subsystems e.g., open agricultural land, homesteads, and roadside vegetation. The open
agriculture land ecosystem dominates the area providing widespread habitat types for various species of
flora and fauna. The vegetation covers of agricultural lands are different crop species, weeds and other
herbaceous plants species. The faunal species in the agriculture land and roadside bush ecosystems
include birds, amphibians, snakes rodents and a few mammals. The homestead ecosystem provides the
main tree covered areas within rural Bangladesh including the project site. The homesteads are covered
by fruit, timber, fuel wood, medicinal plants and various multipurpose tree species. The wildlife species
in homestead ecosystem include the birds, amphibians, reptiles, rodents and mammals like mongoose,
jackal, cats, etc.
National Parks/Wildlife Sanctuaries/ Ecologically Critical Areas
Only Habiganj district hold the presence of some type of conserved areas, which provide optimum
benefits and support services to the habitats of wild species of mixed or some specific types. Among
those, Satchari National Park (242.91 ha) and Rema-Kalenga Wildlife Sanctuary (1795.54 ha) are
particularly notable, which are of IUCN category II and VI protected areas respectively. It’s a broad
picture of the presence of any conserved sites in any RIVER project districts; though it is not confirmed
whether any sub-projects sites are located in or nearby the identified conserved areas. If any of the sub-
projects is found located in or within the close proximity of any reserved places, strict adherence to the
relevant ESCoPs and mitigation/management measures shall be attained throughout the project life
cycle. It should be noted that none of the Ecologically Critical Areas are located in any of the fourteen
proposed districts for targeted implementation under the project.

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4.3 Socioeconomic Environment

Demographic and socio-economic baseline helps identify the target beneficiaries, other stakeholders,
vulnerable groups and social issues associated with the project. These also present the basis for
assessing potential social and economic impacts both during the construction and in the operation
phase, and the project outcome in later period. Screening out of the social development factors (literacy
rate, health facilities, etc.) in the project areas and its vicinity helps assess the receptor/ beneficiaries’
coping capacity and design the social services that may be provided by the project in order to improve
the quality of life and achieve the project's socio-economic goal.

Demographic Profile:
According to Population Census 2011, Sirajganj had the highest population in numbers, and the lowest
populated district among the project districts was Rajbari, containing only little more than 1 million
people, which is manifested from table 4.11. Considering the sex ratio (male-female ratio) Lalmonirhat,
Rangpur, Sirgajganj and Sunamganj are in nearly equal in numbers, while highest discrepancies were
observed in Kurigram.

Table 4.11: Population size and sex ratio in the project districts
Division Districts Population size Male: Female
Rangpur Nilphamari 19,07,497 9,59.857: 9,47,640 (1.01:1)
Lalmonirhat 12,56,099 6,28,799: 6,27,300 (1:1)
Kurigram 20,69,000 10,10,000: 10,59,000 (0.95:1)
Rangpur 29,96,336 15,01,647: 14,94,689 (1:1)
Gaibandha 24,71,681 12,14,563: 12,57,118 (0.96:1)
Rajshahi Bogura 29,88,567 50.84:49.16 (1.03:1)
Sirajganj 32,20,814 16,13,173: 16,07,641 (1:1)
Pabna 22,60,540 11,56,809: 11,03,731 (1.04:1)
Dhaka Madaripur 11,46,349 5,84,016: 5,62,333 (1.03:1)
Faridpur 19,12,969 9,63,529: 9,49,440 (1.01:1)
Rajbari 10,15,519 5,24,624: 4,90,895 (1.07:1)
Gopalganj 11,72,415 5,77,868: 5,94,547 (0.98:1)
Sylhet Sunamganj 24,67,968 12,36,106: 12,31,862 (1:1)
Habiganj 20,89,001 10,25,591: 10,63,410 (0.96:1)
Source: Population Census’ 2011

Vulnerability Profile:
Bangladesh Bureau of Statistics (BBS) reported a district level poverty map of Bangladesh, where among
the RIVER project districts, Kurigram has the highest numbers of poor people (70.8%, below the upper
poverty line) and poverty level in all the project districts in Rangpur division is miserable. Pabna, Rajbari
and Sunamganj has the highest poverty among the respective districts in the divisions (table 4.12).
Female-headed households are the other vulnerable groups, who may face certain obstacles in getting
the assistance during an event of disaster, and Kurigram district has the highest percentage of female-
headed households among all the project districts, followed by Habiganj and Gopalganj.
Small ethnic groups also are more likely to face challenges in getting similar help or assistance during the
disaster period, even sometimes in recovery period after the disasters. However, relatively a large
number of ethnic population lives in Habiganj; two other popularly inhabited districts are Sirajganj and
Rangpur, though percentage of the ethnic groups are very meagre in comparison to the native Bengalis.

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Table 4.12: Socio-economic vulnerability of population

Division Districts Poverty level Female Headed Ethnic Population
(HCR Upper, %)* Households (%) ** (numbers & %) **
Rangpur Nilphamari 32.3 11.09 495 (0.03%)
Lalmonirhat 42.0 11.66 126 (0.01%)
Kurigram 70.8 17.88 486 (0.02%)
Rangpur 43.8 13.18 18,561 (0.64%)
Gaibandha 46.7 16.13 4,312 (0.18%)
Rajshahi Bogura 27.2 12.37 7,981 (0.23%)
Sirajganj 30.5 12.22 19,772 (0.64%)
Pabna 33.0 11.24 1973 (0.08%)
Dhaka Madaripur 3.7 16.12 76 (0.0065%)
Faridpur 7.7 15.32 3,233 (0.17%)
Rajbari 33.8 11.61 1285 (0.12%)
Gopalganj 29.5 17.81 2,066 (0.18%)
Sylhet Sunamganj 26.0 14.88 6,911 (0.28%)
Habiganj 13.4 17.87 65,802 (3.15%)
Source: *Poverty Maps of Bangladesh, BBS 2016
**Population and Housing Census, BBS 2011

Area and Population Density:

Among the 14 project districts, highest number of population live in Siragjonj, and the population
density is highest in Sirajgong as per Population Census’2011. Madaripur, Nilphamari and Rangpur are
the three major densely populated districts after Sirajganj as shown in table 4.13. However, Sunamganj
is the least densely populated district, followed by Kurigram. A large areas in Sunamganj is occupied by a
large numbers of haors, which narrows down the habitable places in Sunamganj.

Table 4.13: Area and population density of project districts

Division Districts Area (sq. km) Popn Density
(per [Link])
Rangpur Nilphamari 1643.40 1215
Lalmonirhat 1247.371 1007
Kurigram 2245.04 667
Rangpur 2400.56 1101
Gaibandha 2179.27 981
Rajshahi Bogura 2919 1040
Sirajganj 2497.92 1842
Pabna 2371.50 918
Dhaka Madaripur 1144.96 1036
Faridpur 2072.72 920
Rajbari 1092.30 908
Gopalganj 1489.92 787
Sylhet Sunamganj 3747.18 659
Habiganj 2636.58 792
Source: Population Census’ 2011

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Education and Institutions:

Sirajganj, being located close to the capital and having large urban population across the district, gets
top ranking in educational attainment among all 14 districts, as per the Census result shows. Sirajganj
has the highest numbers of educational institutions (1563 primary schools) among the districts, which
helped the district to come up such high. However, Lalmonirhat and Gaibandha also have very high
literacy rate, more than 60%; though Lalmonirhat got much lesser number of schools than many other
districts. Sunamganj got the lowest literacy rate, followed by Habiganj. More details are given in table
4.14.
Table 4.14: Literacy rate and educational institutions in project districts
Division Districts Literacy Educational Institutes
Rate (%)
Rangpur Nilphamari 49.69 Primary School-940; Secondary-295; College-45; Technical Training
Centre (TTC)-19; PTI-01; University-0
Lalmonirhat 65 Primary School-776; Secondary-197; College-45; Polytechnic
Institute -03
Kurigram 56 Primary School-1115; Secondary-257; College-43; Polytechnic
Institute -01; Technical School & College (TSC)-01; University-0
Rangpur 48.5 Primary School-1292; Secondary-510; College-62; University-01
Gaibandha 64.2 Primary School-1251; Secondary-353
College-75; University-0
Rajshahi Bogura 49.38 Primary School-1603; Secondary-390;
College-16+36+45; Govt. Technical College-04; University-01
Sirajganj 68 Primary School-1563; Secondary-374;
College-77; Polytechnic Inst.-01; Private Medical Collge-02
Pabna 47.4 Primary School-1086; Secondary-202; College-49; Cadet College-01;
University-01; Medical College-01; Polytechnic Inst.-01; Textile
Inst.-01; Nursing Inst.-01
Dhaka Madaripur 48 Primary School-677; Secondary-128;
Junior High School-27; College-21
Faridpur 43.95 Primary School-783; Secondary-195;
Junior High School-52; College-31; Medical College-01; Teachers
Training College-01; Polytechnic Institute-01
Agri Inst.-01; PTI-01; Technical Training Centre-01
Rajbari 52.3 Primary School-419; Secondary-140
College-25; Technical Inst.-06
Gopalganj 58.1 Primary School-765; Secondary-157; College-21; University-01;
Medical College-01
Sylhet Sunamganj 35.00 Primary School-860; Secondary-209; College-26; University-01;
Medical College-01
Habiganj 40.50 Primary School-1311; Secondary-95
College-20; Polytechnic Institute-01; Technical School & College-03
Source: Population Census’ 2011

Professional Engagement:
Agriculture is still the dominant profession across the districts; shows the dominance where literacy rate
is relatively poor. Highest engagement of population in agriculture is in Habiganj, followed by
Madaripur, with 82% and 81% respectively. Lowest engagement in agriculture is manifested in
Niphamari, where Agri-labor is 2nd in professional engagement. An overall idea of dominant professional
engagement by the population in project districts is depicted in table 4.15.

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Table 4.15: Major professional engagement of people in project districts

Division Districts Literacy Profession (%)
Rate (%)
Rangpur Nilphamari 49.69 Agri-45.28; Agrolabor-27.81
Lalmonirhat 65 Agri-48.03; Agrolabor-22.81
Kurigram 56 Agriculture 70.41%, commerce 9.45%
Rangpur 48.5 Agriculture 62.99%, Commerce 13.28%
Gaibandha 64.2 Agri-65.08%; Commerce-11.85%
Rajshahi Bogura 49.38 Agriculture 57.32%; commerce 13.63%
Sirajganj 68 Agriculture 51.14%; Commerce 14.47%
Pabna 47.4 Agriculture 53.75%; Commerce 14.97%
Dhaka Madaripur 48 Agri-81%; Commerce 5.97%
Faridpur 43.95 Agri-68%; Commerce 11.97%
Rajbari 52.3 Agri-73%; Commerce 9.97%
Gopalganj 58.1 Agri-76%; Commerce 8.92%
Sylhet Sunamganj 35.00 Agri-79%; Commerce 13.7%
Habiganj 40.50 Agri-82%; Commerce 7.97%
Source: Population Census’ 2011

Access to Health Facilities:

Access to Health facilities is one of the key criteria of development efforts that is taken place in
respective districts by the government and also measures the status of living. Among the available
information (table 4.16), Sunamganj has got the highest number of government hospitals, thereafter
Gopalganj having 6 hospitals under government control. Faridpur, Rangpur and Bogura-each got medical
college hospitals. Upazila health complex provides the basic treatment facilities to the local people;
small scale surgery is also done in those complexes.
Table 4.16: Types and number of health service facilities in project districts
Division Districts Literacy Health facilities (numbers)
Rate (%)
Rangpur Nilphamari 49.69 Hospital-09; Diabetic Clinic-02
Mother & Child Welfare Centre -02
Family Planning Centre-55
Lalmonirhat 65 Hospital-01; Private Clinic-12
Comm. Clinic-160; Upazila Health Complex -05
10-bed hospital-01; Mother &Child welfare centre-01
Kurigram 56 Govt. Hospital-01; Upazila Health Complex-08
Private Hospital-02; Eye Hospital -01; TB Clinic-01
Mother &Child welfare centre-01
Rangpur 48.5 Medical College Hospital-01; Sadar Hospital-01
Gaibandha 64.2 General Hospital-01; Govt. Hospital-06
Upazila Health Complex-06; Women & Child Welfare Centre-01;
TB Clinic-01
Rajshahi Bogura 49.38 Medical College-01
Sirajganj 68 General Hospital- 01; Govt. Hospital-15
Private Hospital-09; Eye Hospital-02
Govt. Medical College-01; Upazila Health Complex-08
TB Clinic-01; Mother & Child Welfare Centre-01

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Pabna 47.4 Mental Hospital-01; General Hospital-01

Upazila Health Complex-08; TB Clinic-01
Health Service Centre -02; Health Service Sub-Centre-13
Dhaka Madaripur 48 General Hospital-01; Upazila Health Complex-03
Health & Family Welfare Centre-50
Faridpur 43.95 Medical College Hospital-01; General Hospital-01
Upazila Health Complex-07; Union Health Complex-36
Rajbari 52.3 Govt. Hospital-01; Upazila Health Complex-03
Family Welfare Center-24; Health Sub-Centre-28
Gopalganj 58.1 Govt. Hospital -06; Private Hospital-02
Sylhet Sunamganj 35.00 Govt. Hospital-12; Health Centre-22
Habiganj 40.50 100-bed Hospital-01; Upazila Health Complex-07
Sub-Health Centre-18 (outdoor health facilities only)
Source: Population Census’ 2011

Presence of Ethnic Minorities

There are several ethnic minority groups living in the project districts; primary information based on
secondary sources has confirmed their presence. If any site for implementation works under the RIVER
project comes closer to the areas where ethnic minority people are living, a specific management plan
(Indigenous People Management Plan/ Small Ethnic Community Development Plan) has to be developed
and their rights to have an uninterrupted access to their daily activities and resources they are living on
must be reinstated. However, negligible impacts may turn to substantial to some of the ethnic minority
community for his/her ethnic background. Habiganj district has the highest numbers of ethnic
population from different sects/casts, such as Kormokar, Voumik, Bauri, Santal, Munda, Uria, Tati,
Kondo, Telenga, Relikhashia, Monipuri, Chouhan, Ohir, Chotri, Bakti, Urang, Utkole, Vojpuri, Vumij,
Telegu, etc.; some areas in Rangpur district also is inhabited by Santal, Urao, Pahari, Mushhor, Pahan,
Turi, and a very small group of Buno, Bindi, Behara, Bagdi, and Kole live in Rajbari district.

Presence of Historical/Cultural Heritage sites

There are good numbers of important touristic, historical and cultural heritage sites, which have
different socio-cultural, economic, religious and touristic values to consider. All these sites need to be
conserved and protected from any kind of potential impacts caused by any development activities.
Among those, Chandamari Mosque, Chandi Temple, Dolmoncho Temple, Sindurmati Dighi, and Chilmari
Port in Kurigram; Mohasthangarh, Pundrabardhan, and Archeological Museum in Bogura; Orakandi
Thakur Bari, Ulpur Jaminder bari, House of Jamindar Girish Chandra Sen in Gopalganj, Tanguar Haor,
Lauer Gor, Pagla Mosque, Dohalia Jamindar Bari, Gourarang Jamindar Bari, House of Hason Raja, and
Shrine of Asim Shah in Sunamganj are some of the known sites, and there are many more in other
districts, which might be encountered when the contractors are mobilized in the field and may face the
effects of construction works’; every possible measures should be taken to avoid those sites or protect
those during the entire project cycle. However, World Bank has a specific guidance on ‘Chance Find
Procedure’ for unidentified heritage/cultural sites which suggests measures if any archeological, cultural
or religious sites are found incidentally in or nearby areas of physical interventions, and need to be
recovered or conserved in a well-guided ways.

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CHAPTER 5: POTENTIAL ENVIRONMENTAL AND SOCIAL IMPACTS

5.1 Risk Classification Methodology
The assessment of effects and identification of impacts takes into account of any incorporated
mitigation measures, and will be largely dependent on the extent and duration of change, the number
of people or size of the resource affected and their sensitivity to the change. Potential impacts can be
both negative and positive (beneficial), and the methodology defined below will be applied to define
both beneficial and adverse potential impacts.
The criteria for determining significance are generally specific for each environmental and social aspect
but the magnitude of each potential impact is defined along with the sensitivity of the receptor. Generic
criteria for defining magnitude and sensitivity used for the Project are summarized below.
Environmental and social risk classification takes into account relevant potential risks and impacts, such
as:
a. the type, location, sensitivity and scale of the Project including the physical considerations of the
Project; type of infrastructure (e.g., power plants, airports, major roads, bridges and culverts,
etc.); volume of hazardous waste management and disposal;
b. the nature and magnitude of the potential ES risks and impacts, including impacts on greenfield
sites; impacts on brownfield sites including (e.g., rehabilitation, maintenance or upgrading
activities); the nature of the potential risks and impacts (e.g., whether they are irreversible,
unprecedented or complex); resettlement activities; presence of Indigenous Peoples; and
possible mitigation measures considering the mitigation hierarchy;
c. the capacity and commitment of the Borrower to manage such risks and impacts in a manner
consistent with the ESSs, including the country’s policy, legal and institutional framework; laws,
regulations, rules and procedures applicable to the Project sector, including regional and local
requirements; the technical and institutional capacity of the Borrower; the Borrower’s track
record of past Project implementation; and the financial and human resources available for
management of the Project;
d. other areas of risk that may be relevant to the delivery of ES mitigation measures and outcomes,
depending on the specific Project and the context in which it is being developed, including the
nature of the mitigation and technology being proposed, considerations relating to domestic
and/or regional stability, conflict or security.

5.1.1 Assigning Risk

Risk or impact classification considers the assessment of magnitude, quality or sensitivity of the
receiving environment and social receptor in order to determine the significance of each potential
impact established using the risk classification matrix given below and in accordance with the ESS1. Risk
classification can be divided into four distinctive categories- High, Substantial, Moderate and Low.

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Table 5.1: Assessment of Risk Classification

Sensitivity of Receptors
Magnitude of
Low Negligible
Potential impact Very Severe Severe Mild

Very High High High Substantial Substantial Moderate

High High High Substantial Moderate Moderate

Moderate Substantial Substantial Moderate Moderate Low

Low Moderate Moderate Moderate Moderate Low

Nil Moderate Moderate Low Low Low

5.1.2 Impact Assessment

This section discusses the guideline to predict the potential and mostly typical impacts on the key
environmental and social parameters of the RIVER Project area based on the overall baseline,
assessment of project components/sub-components and the primary assessment of the activities.
Demonstration of environmental and social impacts from infrastructure development is a function of
the activities that take place during project preparation, construction and operation of the
infrastructure, on the one hand, and the particular environmental and social attributes of the local
setting on the other. The people, communities and ecosystems that may be affected by a project
(receptors) are variable in terms of their proximity to the infrastructure; their sensitivity to influences
such as noise, disturbance and emissions; and their ability to adapt to change. The activities involved in
construction and operation of infrastructure also vary based on the nature of the project, and how long
different activities are carried out in one place. The significance of impacts depends on the particular
juxtaposition of activities and receptors in specific locations.
The impacts that arise from particular configurations of infrastructure development activities and
landscape features may emerge in different forms and through various pathways. It is useful to consider
the types of impacts that may come into play - some of which may be more immediately obvious than
others - when assessing the potential effects of a project on people and nature in the surrounding
environment. Table 5.2 below explains the Impact categorization and typology adopted for this study.
Table 5.2: Impact Categorization and Typology Adopted for This Study
Impact parameter Types of impact Sign
Direction of change relative to baseline POSITIVE NEGATIVE +/-
conditions
Magnitude of impact in relation to ability of NONE MINOR MAJOR SEVERE D/C/B/A
people and ecosystem to cope with change
Spatial extent of effects LOCALIZED WIDESPREAD Loc/Wid
Duration of effects experienced TEMPORARY PERSISTENT Tem/Per
Timing of effects experienced INTERMITTENT CONTINUOUS Int/Con
Nature of cause-and-effect linkage between DIRECT INDIRECT Dir/Ind
project activity and impact experienced by
receptors
Relationship of project activities to impacts ISOLATED CUMULATIVE Iso/Cum
from other sources in landscape

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5.1.3 Magnitude of Impact

The assessment of magnitude shall be undertaken in two steps. Firstly, the key issues associated with
the RIVER Project are categorized as beneficial or adverse. Secondly, potential impacts shall be
categorized as Very High, High, Moderate and Low based on consideration of the parameters such as:
 Ability of people and ecosystem to cope with change
 Spatial extent of the potential impact;
 Duration of the potential impact;
 Timing of effects experienced;
 Likelihood of potential impacts occurring;
 Relationship of project activities to impacts from other sources in landscape
The magnitude of potential impacts of the Project shall be identified according to the categories
outlined in Table 5.3.
Table 5.3 Parameters for Determining Magnitude of Impact
Parameter Very High High Moderate Low/Nil
Ability of people The capacity of The resilience and Ecosystem can Ecosystem can
and ecosystem to ecosystem and adaptive capacity to cope with the cope with the
cope with change people to cope the impacts is changes with changes with
with the impact is regenerative with specific planning limited
not certain extensive and management responses
management
Spatial extent of Widespread far Beyond immediate Within project Specific location
the potential Beyond site Project boundary within Project
impact specific project components, site component or
boundaries boundaries or local site boundaries
area with no
detectable
potential
impact
Duration of Long term (more Medium Term Less than Project Temporary with
potential impact than 20 years) Lifespan of the lifespan no detectable
Project (5 to 10 potential
years) impact
Timing of effects Potential impact is Potential impact Baseline returns Baseline
experienced effectively requires a year or so Naturally or with remains
permanent, with some limited constant
requiring interventions to intervention within
considerable return to baseline a few months
intervention to
return to baseline
Likelihood of Occurs under Occurs under Occurs under Unlikely to
potential impacts typical worst case abnormal, occur
occurring operating or (negative impact) exceptional or
construction or best case emergency
conditions (positive impact) conditions
(Certain) operating (occasional)

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conditions (Likely)
Relationship of The activity will The activity will The activity will Temporary with
project activities cause several cause effects and cause effects and detectable
to impacts from effects and difficult relatively easier to easy to predict and potential
other sources in to predict and predict and manage manage impact
landscape manage with all of its negative impact
its negative impact

5.1.4 Sensitivity of Receptor

The sensitivity of a receptor shall be determined based on review of the population (including
proximity/numbers/vulnerability) and presence of features on the site or the surrounding area. Criteria
for determining receptor sensitivity of the Project’s potential impacts are outlined in Table 5.4.
Table 5.4: Criteria for Determining Sensitivity
Sensitivity Determination Definition
Very Severe Vulnerable receptor with little or no capacity to absorb proposed changes or
minimal opportunities for mitigation.
Severe Vulnerable receptor with little or no capacity to absorb proposed changes or
limited opportunities for mitigation.
Mild Vulnerable receptor with some capacity to absorb proposed changes or moderate
opportunities for mitigation
Low/Negligible Vulnerable receptor with good capacity to absorb proposed changes or/and good
opportunities for mitigation

5.2 Anticipated Potential Impacts

The proposed RIVER Project will construct resilient flood shelters and rehabilitate/repair a good number
of community infrastructures, such as smaller climate resilient shelter connecting and community roads,
culverts, bridges, rural markets, landing stages (river jetties), and so on. The size of this type of
subproject component is relatively smaller and identical, and the extent of civil works is not significant.
In some areas, the resilient shelter needs to be connected through a new connecting road or the existing
road needs to be rehabilitated; but the road will be of smaller length and must follow a pre- defined
alignment and further acquisition of land will not be entertained from the project end. In some of the
proposed shelter areas, the playground/open spaces will be elevated to a flood-free level so that the
spaces could be used for sheltering livestock, storage area for fodders, and to cater additional people. As
a framework document, potential Environmental and Social impacts of the activities under the resilient
flood shelter and rural market components are discussed here for clear understanding and guidance for
doing the same for other components.

5.2.1 Construction of Resilient Flood Shelters (including raising lands) and rehabilitation/repair of
Rural Markets
The investment on these physical component yields net positive benefit to the local community. The
shelters constructed so that they are used as primary schools when there is no disaster. The shelters will
be constructed with separate bathrooms for men and women. Safe water supply will be ensured, rain
water harvesting facilities is included and provision of solar panels are provided. In addition, connections
to existing road will be ensured by constructing a link, if needed. One floor will be constructed for
livestock and animals and top floor is for human shelter. Ramp will be provided for disable people and

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easy movement of livestock. Rural markets also need to similar type of physical interventions- only
smaller civil works for different types of market sheds, and health and sanitary facilities will be ensured.
The negative environmental impacts for both of these components will be triggered mostly from the
construction related activities. These impacts are mostly temporary and limited within the project
boundary. The anticipated impacts are air pollution, noise, drainage congestion and water logging during
the construction period, temporary surface water and ground water pollution, etc. Also, the
Environmental Health and Safety (EHS) issues like occupational safety of workers and safe movement of
teachers & students/people living nearby is vital during the construction period. Alternative schooling
facilities have to be ensured during the construction period, by the contractor, so that academic
activities is not hampered and continued uninterrupted.
The potential impact assessment has been described below for construction of resilient flood shelter
and rehabilitation/repair of rural markets components. These types of subprojects have the similar type
of construction activities, covers a wide range of geographical locations, and may use the local
workforce to implement the subprojects. The associated potential impacts of these types of
components would be mostly similar to other subprojects for the construction period and in some cases
during the operation period too in its life cycle.

[Link] Planning and Design Phase

Land Cover and Land Use Changes (ESS 1, 3, 6)
Construction of different infrastructures including school-cum-flood shelters and raising land may change
existing land use and land cover at the local level, though these will be constructed within existing school
premise he improvement works are relatively small in nature, and confined within school/market
boundary but their quantity is significantly high and will be spread over villages/ unions under different
districts. For the ease of construction works or storage of construction materials, roadside land-cover
may face some changes.
Loss of natural vegetation and trees (ESS 6)
Siting of proposed infrastructures may require cutting of trees and removal of natural vegetation, which
would not be significant in number.

Site readiness (ESS 1, 6)

Law of Bangladesh Government requires that any construction needs permission from local authorities
prior to the starting the construction phase. Failure to obtain necessary consents, permits, No Objection
Certificate (NOC) can result in design revisions and/or stoppage of the Works. Failure to obtain NOC
from the local authority can hamper the entire project, even stop the construction project. In this
project, the land is already available to the authority as it is government owned land for all the
subprojects. However, the final locations will be selected during the detailed design stage.
The required actions during the pre-construction stage are to (i) Obtain Site Clearance Certificate (SCC)
and later Environmental Clearance Certificate (ECC) from Department of Environment; (ii) acknowledge
in writing and provide report on compliance all obtained permits, clearance, NOCs, etc.; (iii) collect
permission from School Management Committee (SMC) prior to construction.

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Contractor Selection (ESS 1)

The success or failure of environmental and social mitigation in infrastructure development hinges to a
significant degree on the primary contractor's sense of ES responsibility and commitment to compliance
with prescribed safeguards measures.

Labor Sourcing (ESS 2)

Procurement of labor has two main potential impacts, which can be either positive or negative,
depending on where most workers come from. First, use of mostly or exclusively non-local labor means
that a construction camp will be needed, and this has significant potential for environmental and social
impacts. Second, hiring mostly non-local workers is a missed opportunity for the project to bring
benefits to the local community. The people who live in nearby areas will bear the brunt of any negative
impacts that arise during the construction and operation phases, and employment opportunities will go
some way in compensating for inconveniences and discomforts experienced.
In order to minimize and prevent construction camp impacts and maximize the project's benefits to the
local community, the primary contractor and all of its sub-contractors should be contractually required
to hire mostly or exclusively local residents for construction jobs. This should be stipulated in the bidding
documents and contracts. However, a separate LMP has been prepared to minimize the risk associated
with labor influx.

Gender Based Violence (GBV) (ESS 1, 2, 4, 10)

The supply of labor is abundant in all the project districts, so labor influx will not significant in any
construction works, and labor management will not be critical as well. Hence, incidence of gender based
violence/SEA/SH in the construction and labor camp sites, will be very less likely.
The Project’s GBV risks are assessed as “Moderate” due to the labor requirements to deliver civil works.
The project will develop a stand-alone GBV action plan, if required. The action plan will include a
separate grievance redress mechanism with GBV referral pathways and response protocol that will be
set up during the project preparation phase. In addition, a supervision team comprising of social and
Gender specialists of the PIU and D&SC will monitor and support the implementation of the action plan.
The action plan will suggest specific provisions to ensure safety for and feedback from women and girls
engaged as workforce. Besides, stakeholders’ involvement, GBV sensitization training for the
contractors, workers and affected community will be organized to mitigate the potential risks. PIU will
include a GBV referral system in its project GRM as the components will not require major civil works. A
GBV service provider mapping will also be included in the plan. During the implementation, ESMP and
the implementation of GBV Action Plan will be monitored. Training of contractor personnel on GBV
issues and relevant expectations/ requirement will be conducted.
Seismic risk (ESS 1, 4)
Seismic risk profile of project districts shows that some districts have severe to very severe risk
potential, though the history of seismic hazards is not so prominent in those areas. However, as the
areas are situated on active seismic zone, and any events of seismic tremor of more than 6.0 in Richter
scale may cause significant casualty or fatality, proper care should be taken while designing the
structures. BNBC 2020 has provided due guidance on building structures in seismic zone and that will be
adopted in the design. Strong movement of earth or tremor is riskier when construction works are
ongoing; so contractors will take initiative in providing recurrent training to the workers/staffs to avoid
any potential human loss or damage to properties.

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Flooding risks (ESS 1,4)

All the project districts are prone to flooding, especially during the monsoon, from river flooding.
However, flash flooding is also very common in some project areas. Flooding, irrespective of its cause,
leaves huge losses on agriculture, livestock, lives and livelihood, and losses tend to bigger as the
retention time gets wider. During the design phase, intensive consultation events will be conducted to
understand the localized nature of flood potentials and destructions, and knowledge/suggestions from
local people will be incorporated in shelter/community infrastructure design, optimally within the
project scope. Adaptive management options during a flood events will be sought and putting those
options in place for building people’s resilience against the disaster is very crucial to avoid or minimize
the loss to the least.

[Link] Construction Phase

Air Quality (ESS 1, 3)

Construction shelter buildings/ rehabilitation of rural markets may generate emissions from excavation
equipment, other machinery and construction traffic. The emissions may also include greenhouse gases
(GHGs) from engine fuel combustion (exhaust emissions) and evaporation and leaks from vehicles
(fugitive emissions) and emissions from asphalt works. The emissions from construction activities will
deteriorate the ambient air quality and affect the public health. The densely populated areas and
crowded market places (bazaars) are particularly vulnerable to these impacts. In addition, dust
generated from the above activities will also have impacts on crops and livestock if not properly
managed.

Noise Pollution (ESS 1, 3)

Noise and vibration from construction activity can be a serious nuisance for teachers and students in the
school and people living near active construction sites, if there are residences in close proximity to the
development sites. People staying temporarily (in school) and living in any nearby settlements
experience some measure of nuisance during the construction works, particularly if any pile-driving is
carried out, or if construction activity is conducted at night. People living along the roads, that will
inevitably be used to bring bulk materials to the construction sites, may notice an increase in noise from
haul trucks and construction activities such as mixing, hammering etc.

Water Pollution (ESS 1, 3)

Construction activity involving excavation and earthworks inevitably exposes loose soil and dust
particles will be blown away to nearby water bodies causing turbidity and water pollution. If soils and
stockpiles of erodible materials are inadequately protected from rain and surface runoff, sediment will
make its way to local surface waters, and the result will be siltation and sedimentation. These processes
will degrade the quality of local waters as habitat for aquatic species, and also lead to clogging of
channels and culverts with sediment. If not properly controlled, process water from concrete mixing and
pouring can also carry large amounts of fine silt to local waterways, especially where the drains are
leading. This increase in turbidity is not likely to have any significant impact on overall water quality and
the aquatic fauna primarily because of its temporary and localized nature. The construction camps and
other site facilities such as offices and warehouses will also generate considerable quantities of waste
effluents.
During construction, both surface and groundwater are at risk of contamination with noxious fluids used
in the construction process, including fuels, lubricants. Spills and leaks soak into the soil and make their

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way to the groundwater table. Construction camps are a common source of surface water
contamination, as toilet facilities are typically rudimentary and likely to leak raw or virtually untreated
effluent. This may exacerbate existing surface water quality problems.
Soil Contamination (ESS 1, 3)
Much like water pollution discussed above, soils in the construction area and nearby lands that are used
for agriculture will be prone to pollution from the construction activities, construction yards, workers
camps and other construction areas. Fuel and hazardous material storage sites and their handling are
also the potential sources for soil and water pollution. Improper siting, storage and handling of fuels,
lubricants, chemicals and hazardous materials, and potential spills from these will severely impact the
soil and water quality and also cause safety and health hazards. If contaminated soil is used for land
raising, that will trigger spread of pollution in shelter land as well as health and safety risks of students,
users and nearby communities.

Traffic Congestion (ESS 1, 4)

Majority of the project sites will be located in rural settings, or in urban fringe areas. Therefore, the
burden of usual traffic will be less in comparison to any urban busy areas. However, it is expected that
during peak construction time when heavy vehicles and machineries will be transported at full scale, the
extra traffic movement will disrupt the normal traffic, though not significantly. A group of trained
personnel can be deployed to manage the traffic at different sections and traffic control measures such
as sign posting at strategic places and placing traffic cones to divide/direct the lanes, etc. may be
adopted.
Site Clearance and Restoration (ESS 1, 6)
After the completion of the construction activities, the left-over construction materials, debris, spoils,
scraps and other wastes from the working sites, and camp areas can potentially create hindrance and
encumbrance for the local communities in addition to blocking natural drainage.
Occupational Health and Safety (ESS 1, 2)
Generally, the construction activities will involve small to medium scale excavation, installation of
steel structures, operations of construction machinery, and vehicular traffic. These activities may
pose health and safety hazards to the workers at site during the use of hazardous substances, lifting
and handling of heavy equipment and steel frames, operating machinery and electrical equipment,
working near water or at height and more. The project will need fuels, oils, and asphalt during the
construction phase. Inappropriate handling or accidental spillage/leakage of these substances can
potentially lead to safety and health hazards for the construction workers as well as the local
community.
Impact on labor, working Conditions and labor risks, including risks of child labor and forced labor,
human trafficking (ESS 2)
The proposed sub-projects will entail employment of a significant number of labor especially during
construction. The majority of labor will be locally hired, with the exception of skilled workers who
may not be found in the project areas. However, potential risks engaged both for the hired skilled
and non-skilled workers especially during construction period includes health hazards, poor living
condition, accidental hazards risks, etc. Similarly, hiring labor from external area may cause social risk
on the local communities includes gender based violence, price hiking of daily used products/foods,
etc. Substantial risks are associated in-terms of hiring child labors or forced labors, and also due to

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border districts risk associated to the labor trafficking is also very high. However, a separate LMP has
been prepared to minimize the risk associated with labor influx.
Involuntary Resettlement Impacts (ESS 5)
The project will try to avoid taking any private land through involuntary acquisition and avoid any
physical displacement of residents for activities under the project. Most of the works will be carried out
within the existing available lands. However, acquisition of private lands would be required in some
areas, likelihood that infrastructures construction may involve displacement of formal and informal
private users. For all these reasons, and largely as a precautionary measure, the project triggers ESS5 on
involuntary resettlement. A Resettlement Policy Framework (RPF) has been prepared by the LGED. Site-
specific RAPs will be developed - if and as necessary - during the project implementation. The RPF and
any RAP will ensure the proper calculation and recording of the involuntary displacement impacts as
well as identification of the affected people and mitigation of their loss and impacts. The purpose of the
RPF and implementation of the RAPs is to ensure that there is no adverse effect on the living conditions
and livelihoods of the affected people because of the project.
Community Health and Safety (ESS 1, 4)
Community health and safety risks associated with construction activity are primarily related to
proximity; works carried out in densely populated localities offer many more opportunities for members
of the public to come into contact with heavy machinery, fall into holes, and get injured by unstable
stockpiles of materials. All the sites will offer heightened risk in this regard, given the high density of
residents nearby. Additionally, the community may be infected with COVID-19 by the workers when the
construction works will be in heavily congested areas.
Community safety - especially the safety of women and girls - can also be threatened by operation of
construction camps in proximity to local settlements, especially when camps house non-local workers
who may feel unencumbered by the norms and mores of their far away home communities. Camps may
become a locus for prostitution, and the violence that often accompanies it. Sometimes, local
resentment over the hiring of non-local workers, perhaps exacerbated by cultural misunderstanding or
racial and religious animus, can lead to violent conflict between resident workers and local people.
Community health is most often affected by construction activity when dust levels are very high for long
periods, and also when poorly managed construction camps are situated near existing settlements.

Livelihoods (ESS 1, 4)
Construction activity typically affects livelihoods in a few ways. On the negative side, poor management
of the construction site can lead to property damage in adjacent areas. In particular, crops in nearby
areas may get trampled or damaged by operation and parking of machinery without regard to the site
boundary, or by materials stockpiles spreading across the property line. Careless management of the
construction process can also sometimes impair access to nearby businesses, leading to loss of revenue;
this is also not expected to be relevant at either site. In addition to such negative impacts, construction
activity can also have a strong positive impact for local communities, especially if all or most workers are
hired from the local population.

Impacts on Small Ethnic Communities (ESS 7)

Small Ethnic Communities (SECs) if present in the project area can be characterized as indigenous
peoples in view of their unique characteristics including language, culture, occupation, and traditions.
They might be affected disproportionately by the construction works, and may not get access to the

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grievance services for making complaints or so. If any of the sub-project sites find IPs within or around
the site or influence area, Safeguards team from D&SC must conduct survey, prepare relevant action
plan, and follow the measures strictly.

Impact on Cultural Heritage (ESS 8)

There might have some mosques, temples and graves along the proposed sub-projects area, which may
be affected by project works (road construction/rehabilitation). However, project ESCoPs and site-
specific ESMP will guide about and ascertain necessary measures to take for avoiding or minimizing the
impacts to the least. Chance Find Procedures will be included in the ESMP and chance find clause will be
included in work contracts requiring contractors to stop construction, if cultural heritage is encountered
during construction.

Demolition & Construction Waste (ESS 1, 3)

Demolition of existing dilapidated school building/market structures will be required in some sites. The
demolition will create modest amounts of waste that will need to be disposed of. Hazardous waste viz.
waste oil etc. and the scrap material generated from the demolition of structures, and parts of
construction debris (Brick, concrete and masonry) may cause pollution or nuisance. Further, waste
generated during construction will consist mainly of packaging, from both construction materials and
food products consumed by workers. The volume of waste produced is likely to be relatively small, but
can easily get strewn and blown across the landscape and end up in local water bodies, if not
appropriately managed.

Solid Waste and Sewage Effluent (ESS 1, 3)

Untreated sewage from the pit latrines may enter surface water if not adequately designed and
positioned. Periods of high rainfall could lead to the overflow of the pit and overland flow, or rapid
through-flow of the effluent to surface water prior to its full digestion in the soil. Raw sewage can
potentially impact surface water quality by promoting the growth of algae and delivering pathogens may
be harmful to human and ecological receptors. Use of toxic materials such as solvents and vehicle
maintenance fluid (oil, coolant) and diesel fuel may contaminate surface and groundwater if these are
disposed of directly into the ground or washed into the streams. Human waste from construction
workers may also contaminate surface water and groundwater if there are no adequate sanitary
facilities.
The waste stream during construction at most project sites can be expected to consist of (i) process
water; (ii) excavated material not used in backfilling; (iii) packaging and containers; (iv) solid waste
generated by workers (food and food packaging); (v) sewage from any temporary on-site toilets; and (vi)
grey water from any temporary on-site kitchens and wash-up facilities. Based on the limited scale of the
proposed buildings and absence of plans for any batch plants, process water is likely to be quite limited.
Similarly, waste management facilities, if improperly managed, may result in potential impacts to
surface water by the introduction of harmful substances during runoff events. It is important to
establish formal solid waste management strategy to properly handle solid waste generated in all
sites.[Link] Operation & Maintenance phase.
Air Pollution (ESS 1, 3)
During the operation phase, small amount of dust and exhaust gas might be produced by the vehicles
bound to the school, or the market; the quantity of exhaustion is expected to be bit high only for a small

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period of time, when a disaster hit the area and relief distribution works are intensified for the sheltered
people and during the market day. This impact is temporary, but may cause public nuisance and
deteriorate the air quality for the time being.

[Link] Operation & Maintenance Phase

Air Pollution (ESS 1, 3)

During the operation phase, small amount of dust and exhaust gas might be produced by the vehicles
bound to the school, or the market; the quantity of exhaustion is expected to be bit high only for a small
period of time, when a disaster hit the area and relief distribution works are intensified for the sheltered
people and during the market day. This impact is temporary, but may cause public nuisance and
deteriorate the air quality for the time being.

Decreased Energy Consumption (ESS 1, 3)

Flood shelters and rural markets will be equipped with solar-based energy system. Solar lights will be
installed in or around shelters and markets, or will be connected to a Nanogrid or individual PV system
for having an uninterrupted energy source both in regular and disaster period. This will significantly
decrease the dependence on fossil fuel based energy (electrification) sources and consumption. This
impact will be moderate in view of the measures that will be put in place to reduce consumption of
fossil fuels as well as enhance the economic benefits.

Decreased Energy Consumption (ESS 1, 3)

Flood shelters and rural markets will be equipped with solar-based energy system. Solar lights will be
installed in or around shelters and markets, or will be connected to a Nanogrid or individual PV system
for having an uninterrupted energy source both in regular and disaster period. This will significantly
decrease the dependence on fossil fuel based energy (electrification) sources and consumption. This
impact will be moderate in view of the measures that will be put in place to reduce consumption of
fossil fuels as well as enhance the economic benefits.

[Link] Impact & Risk Categorization

Given the assessed level of impacts for the School-cum-flood shelters and rural market subprojects
discussed in the earlier sections, Table 5.5 gives a summary assessment (not showing all the potential
impacts) based on the method explained in Section 5.1, as an example.
Table 5.5: Summary Impact Assessment & Risk Rating Matrix School-cum-flood shelters and rural markets
Activity / Potential Impact Relevant ESS Impact Ratings Magnitude &
(when not mitigated) Sensitivity of
Risk Ratings (when not

Impact
Impact on Ecosystem

mitigated)
Spatial extent

Relationship

Magnitude

Sensitivity
Duration

Timing

Nature

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Planning & Design Phase

Site Clearance ESS 1, 3, 6 C- Loc Tem Int Dir Iso M L M
Involuntary Resettlement ESS 5 B- Loc Tem Int Dir Iso L L L
Flora & Fauna ESS 1, 6 C- Loc Tem Int Dir Iso L L L
Community Health & Safety ESS 1, 4 C- Wid Per Con Dir Iso L L L
Waste Management ESS 1, 3 C- Loc Tem Int Dir Iso L L L
Contractor Selection ESS 1 B- Loc Tem Int Dir Iso M L M
Labour Sourcing ESS 2 C- Loc Tem Int Dir Iso L L L
Gender Based Violence (GBV) ESS 1, 2, 4 B- Loc Per Int Dir Cum L L L
Construction Phase
Air Quality ESS 1, 3 B- Loc Tem Int Dir Iso M L M
Noise and Vibration ESS 1, 3 B- Loc Tem Int Dir Iso M L M
Water Quality ESS 1, 3 C- Loc Tem Int Dir Iso L L L
Soil Quality ESS 1, 3 C- Loc Tem Int Dir Iso L L L
Impact on Vegetation ESS 1, 3 C- Loc Tem Int Dir Iso L L L
Traffic Congestion ESS 1, 4 B- Loc Tem Int Dir Iso L L L
Occupational Health & Safety ESS 1, 2 B- Loc Tem Int Dir Iso M L M
Community Health & Safety ESS 1, 4 C- Loc Tem Int Dir Iso L M M
Livelihoods ESS 1 C- Loc Tem Int Dir Iso L L L
Demolition and Construction ES 1,3 C- Loc Tem Int Dir Iso M L M
wastes
Impacts on SEC ESS 7 D - - - - - - - -
Cultural Heritage ESS 8 D - - - - - - - -
Operation & Maintenance Phase
Air Pollution ESS 1, 3 B- Loc Per Con Dir Cum M L M
Decreased Energy Consumption ESS 1, 3 B- Wid Per Con Dir Iso M L M

Impact Ratings:
/- : positive/negative impact
D/C/B/A : none/minor/major/severe
Loc/Wid : localized/widespread
Tem/Per : temporary/persistent
Int/con : intermittent/continuous
Dir/Ind : direct/indirect
Iso/Cum : isolated/cumulative
Magnitude and Sensitivity of Impact:
VH/H/M/L/N : Very High/High/Moderate/Low/Nil
VS/S/M/L/N : Very Severe/Severe/Mild/Low/Negligible
Risk Ratings:
H/S/M/L : High /Substantial / Moderate / Low

[Link] Key Issues relating to Impact Assessment for Community Infrastructures

Repair/rehabilitation of different types of community infrastructures, such as climate resilient shelter
connecting or community roads, Jetties/Landing Station and Bridges/Culverts, etc. will have some similar
construction and operational impacts, and there are also some additional or unique risks/impacts for

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each type of components. Site-specific detail assessment will reveal the risks and impacts for the specific
type of sub-project components.
However, road construction or rehabilitation will be confined within pre-defined alignment and will not
make any changes to land use. It is expected that improved road condition will increase motorized
traffic levels and may lead to little higher PM10 and PM2.5 pollution levels, which may result in causing
public health risks, nuisance and other impacts on bio-physical environment.
Some of the anticipated potential impacts during the pre-construction and construction period are
almost similar to other subprojects, such as dust, noise, occupational health and safety etc.
Furthermore, all the activities with repair/rehabilitation of Jetties/Landing Stations, and bridges/culverts
are to be undertaken on government land therefore site preparation may not cause any resettlement or
significant vegetation clearance. However, the anticipated potential impacts for this subproject a bit
different from other subprojects.
As Jetties will be repaired/rehabilitated at the bank of a river or canal, impacts during the planning &
Design stage (Pre-construction stage) are limited to site clearance, aquatic flora & fauna, contractor
selection and labor sourcing; and impacts during the construction phase include air pollution, water
pollution, noise and vibration, aquatic vegetation and habitats, OHS, navigation and river traffic and
Occupational Health and Safety. During the construction of small culverts/bridges, impacts on aquatic
habitats, sediment pollution, and special consideration on the free passage of water and for fish species
has to be made.
Installation of solar PV nano-grid system and lightning protection systems on some existing community
infrastructure, or solar powered streetlights along the road length will pose risk related to occupational
health and safety, among others. Solar infrastructures would create disposal problem for batteries and
solar panels, once their active lifetime is over.
Another potential but indirect impact may arise from the use of solar system in sub-project facilities;
many of the companies who sell solar panel reportedly use child labors in their production facilities,
which should be very carefully taken care of while purchasing equipment or panels from any of those
companies.

[Link] Summary of Impact Assessment

This section of the ESMF has analyzed the negative and positive impacts likely to be raised from
development of the school cum resilient shelters, and rehabilitation of rural markets based on
preliminary details of the infrastructure plan and knowledge gathered on the physical, environmental
and social characteristics of the potential sites. All the sites that are proposed for all these components
are predefined, so no significant changes of land use is involved; all these components will be
built/developed in smaller sites, construction induced impacts will not be spread over large areas; no
complex nature of works are involved and OHS protocol are relatively easier to maintain. All potential
impacts during the construction phase are considered amenable by moderate to low mitigation
measures that are both available and feasible. Similarly, many operation-phase impacts can be avoided
or greatly minimized by sensible design decisions. Moreover, standard ESCoPs are effective in avoiding
any significant negative impacts in relation to all these sites.
Considering the overall the ES risks associated with the investments it has been determined as
‘Moderate’. Similar procedure can be adopted for other sub-project components and risk rating can be
identified accordingly.

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5.3 Typical Mitigation Measures

The ESMF suggests a broad range of mitigation and enhancement measures to reduce negative impacts
and enhance benefits from different sub-project interventions under the RIVER Project. Mitigation
measures are identified and designed to avoid or eliminate or offset adverse environmental impacts, or
reduce them to acceptable levels during both construction and operation phases of a sub-project
intervention. Example of mitigation measures for environmental and social issues for each sub-project
are provided in Annex-D and a guideline of preparing ESMP is given in Annex -F.

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CHAPTER 6: METHODOLOGICAL FRAMEWORK FOR ENVIRONMENTAL AND

SOCIAL MANAGEMENT
6.1 Introduction
The RIVER project has primarily identified the types of infrastructures and facilities to be built across
the places in fourteen non-coastal flood-prone districts. However, the sites for interventions have not
been identified or finalized yet. Therefore, the sub-project locations, site-specific socio-environmental
conditions, and design orientation are yet to be known at this project appraisal level. This level of
preparedness suggests using a framework approach to environmental and social management to allow
the project development process following the newly developed 10 ESSs of WB ESF along with
applicable regulatory frameworks of Government of Bangladesh and following the mitigation hierarchy
of avoidance, minimization, mitigation and compensation/offset for negative impacts and enhancement
of positive impacts where practically feasible. Following sections describe what needs to be done at
each stage of the overall project life – preparatory works for sub-projects implementation,
implementation of the project activities, and reporting on progress.
Similarly, the project will repair or rehabilitate Jetties/landing stations in several designated places,
where government land is available. Identification and finalization of sub-project sites for this special
cluster are still under way by the feasibility team; and very much site-bounded and temporary adverse
impacts are anticipated for the intervention for this type of sub-projects.

6.2 Environmental and Social Management Procedure

6.2.1 Overall Procedure
Due to the nature of the proposed activities under this project and potential environmental and social
risks and impacts, the project falls under ‘Orange B’ category according to ECR, 1997 and also falls
under “Moderate Risk Project’ as per the World Bank ESF. The ESMF is prepared based on the following
principles that can lead the planning and implementation of the LGED’s sub-project activities under the
project.
• The Project Director at PIU, LGED is responsible for the compliance with national policies,
regulations and World Bank ESSs and Guidelines, as mentioned in this ESMF report. The ESMF
will serve as the basis for ensuring the compliance for the project. LGED is also responsible for
obtaining environmental clearance from DoE (Department of Environment), by submitting all
necessary documents and design and fulfilling the due requirements.
• After the sub-project has been identified with outline design and location/alignment options,
screening of environmental and social risks -will be conducted by D&SC firm. The outcomes of
screening determine the requirement of conducting further in-depth assessment or survey for
an IEE study. A Design & Supervision Consultancy (D&SC) firm (or a consortium for the same
purpose) will be employed to carry out all forms of interventions after the identification of sub-
project sites. Among the preparatory works before floating the biddings or the selection of
contractors, the major tasks include ES Screening, design modification, site-specific detailed ES
survey, preparation of ES documents incorporating site-specific ESMPs and recommendations
from consultations and enhancement measures, incorporation of ESMP suggestions to the
detailed design and preparation of BoQs, preparation of bidding documents incorporating the
safeguards clauses as part of due diligence. E&S Specialists at PIU will complement the efforts of
reviewing and finalization of all documents, on project’s behalf, and simultaneously are

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responsible for coordinating all ES safeguards works including continued cooperation with the
world bank safeguards team, conducting trainings on ES issues, monitoring & supervision of
contractors’ works and the responsibilities undertaken by the E&S consultants of D&SC, among
others World Bank needs to review the screening outcomes, categorization process and ES
documents and after giving the concurrence from their end, the ES documents are disclosed
publicly and ESMPs become the guiding documents for the respective contractor(s).
• IEE/ ESA and ESMP need to be prepared for each sub-project specific activities as determined/
administered by DoE and this ESMF. In this project, a mitigation hierarchy needs to be followed
which is to be reflected in sub-project specific ESMPs. The first step in the Mitigation Hierarchy
is to locate the sub-project site or design it in such a way so that the impacts can be avoided.
However, in some situations, there might be some sub-project activities in/near
environmentally sensitive sites and also with vulnerable communities, it is not possible to
completely avoid risks and impacts. Therefore, the second step in the hierarchy is to reduce the
potential risks and impacts of the proposed sub-project activity to acceptable levels through
design considerations. When there are no further design solutions and the potential risks or
impacts remain significant, then the third stem in the hierarchy is to develop feasible mitigation
measures. The final step in the Mitigation Hierarchy is to offset any remaining significant
residual impacts by technically and financially feasible means. This can be in the form of
compensation or enhancement of similar environmental/social component in another location.
However, proposed measures need to be practical given availability of appropriate skills,
materials, equipment given the local conditions (geographical, natural, socio-political,
infrastructure, security and disaster vulnerability).
• Suitable contractor(s) are selected through a requisite bidding process guided by the project
PPSD (Project Procurement Strategy for Development) and contractor’s suitability entails the
capacity to follow the social and environmental due diligence for (the specific package of) the
project. After mobilizing in the field, contractor(s) require to update the ESMPs and formulate
necessary plans as directed in this ESMF in later part.
• LGED must ensure that contractor(s) follow every relevant Environmental and Social Codes of
Practices (ESCoPs) during the preparatory, construction and post-construction
(decommissioning/ site clearance after finishing of construction works) phases along with all the
recommended measures that delineated into the ESMPs and other relevant plans. Though a
Monitoring and Evaluation (M&E) consulting firm will be engaged as the individual third party
monitoring entity (ToR included in annex-J) for the entire implementation period, other parties
including the PIU and D&SC will be responsible for carrying out an effective monitoring and
supervision of contractors’ accomplishment of ESMP.
•
• Monitoring responsibilities for environmental and social issues appropriately relevant to
operational period of the sub-project lie with LGED district/local offices and local administration
(such as Upazila Nirbahi Officer/ DC) and further adjustment to any adverse outcomes could be
mediated under the regular maintenance program of LGED or the respective authority
responsible for the sub-project.

There are certain other considerations, which need to be carefully evaluated or followed throughout the
project period, especially during the preparatory and construction phases of each sub-projects. Such as:
• PIU must ensure that planning and design of any additional activities should ensure minimal
cumulative impacts.
• Environmentally Sensitive areas, cultural sites, restricted or disputed lands should be taken care
of with appropriate mitigation or compensation measures during implementation.

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• Participation of stakeholders (especially local community) should be ensured by the project in

planning, implementation and monitoring of each sub-projects and associated activities.
• LGED will ensure appropriate institutional set up for implementing environmental and social
management plan and inter-agency coordination (whenever required).
• As with mitigation measures, the expected costs of the enhancement measures need to be
included in the project costs. Furthermore, monitoring is required to not only ensure that the
enhancement measures are being properly implemented but also to determine whether the
benefits of these measures are being realized over time. Again, the costs of monitoring needs to
be included in the project budget.
• LGED will undertake public disclosure about the project interventions and potential impacts.
The following figure shows the steps or procedures to be followed under different stages of the sub-
project implementation in a concise outlook. Some of the steps need more clarification for the sake of
better implementation of ESMPs and other safeguards plans, which are described briefly in next
sections.

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Figure 6.1: Environmental and Social management procedure/steps during different phases
Phases Environmental and Social Management Procedure/ Steps Timeframe* Review & Monitoring
Requirement
1. Environmental and Social Screening of Sub-project 2 days WB Review and
(Survey, consultation and screening by ES team at D&SC) Concurrence for the
Pre-Construction

2. Outline Design Preparation 2 days screening results

(by the design team at D&SC with support from ES team)
3. Preparation of ES documents for sub-projects, 3 days WB Review and
incorporating (Site-Specific) ESMP, recommendations Concurrence for
and enhancement measures proposed design,
(by the ES team of D&SC in consultation with ES team at PIU) IEE/ESMP
4. Detailed Design Preparation incorporating ESMP 2 days
Requirements
(by the design team at D&SC, in consultation with ES teams of
D&SC/PIU)
5. Incorporation of ESMP requirement in Bidding 2 days
Documents
(by the ES team of D&SC in consultation with ES team at PIU)
6. Tendering, Evaluation and Selection of Contractor(s) 45 days WB Review and
(by LGED/other procuring authority, as per PPSD) (max.) Concurrence
7. Commencement of ESMP Implementation including 18-24 Monitoring by WB,
Construction

regular consultation with stakeholders months PIU, D&SC, M&E

(Starts immediately after mobilization of contractor) Consultants and
(by the Contractor in consultation with ES teams of D&SC and PIU) Contractor(s)
Construction works start as
per Design

Site Clearance and Removal

of Temporary Facilities
before formal ends of works

End of construction works

8. Environmental and Social Monitoring (During Operation Monitoring by LGED

O&M

Stage) of Sub-projects and Local

(by the PIU/PSC during the project period and LGED for rest of the Government (UNO)
lifetime)

*Timeframe is indicative for a single component under a package

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6.2.2 Environmental and Social Screening and Categorization of Sub-Projects

Environmental and Social screening is essential to gather information on existing baseline status and to
assess potential environmental impacts of the sub-project activities. Screening identifies the
consequence of the proposed project in broader sense based on project interventions, locations of the
project and its surroundings, anticipated impacts, stakeholder’s perceptions and expert judgment,
without having very much detailed investigation. Critical issues are also identified through the
screening, which needs detailed investigation. Based on the extent of environmental and social impacts
obtained from the screening, the decision for further environment and social impact assessment will be
taken. It is intended to provide the first level of information for a key decision to be made as to
whether further assessment of the project is required., The screening process can result in one of the
two following outcomes under this project:
• no further level of assessment is required and a simple ESMP would be prepared;
• a more limited ESA is required (often called Initial Environmental examination) including ESMP
•.

In this project, environmental screening procedure would involve: (i) reconnaissance of the sub-project
area and its surroundings; ii) identification of the major sub-project activities; (iii) preliminary
assessment of the risks and impacts of sub-project activities on the socio-economic, ecological and
physio-chemical environment of the sub-project surrounding areas; (iv) identification of applicable
environmental safeguard standards; (v) determine the risk category of the subproject; and, (vi)
determine the specific instrument(s) to be prepared for each subproject.

Screening is usually carried out with the help of simple matrix that includes a set of check list to identify
the baseline status and proposed potential impacts of the project intervention. A screening format has
been developed for all the components under this project and provided in annex-A. The forms will help
to identify issues which can be verified during field investigations and also provide a preliminary idea
regarding the nature, extent, and timing of environmental and social issues that would need to be
handled during the subsequent stages. During screening, if it is found that any or cumulative effects of a
sub-project activities may create major irreversible damage or violate an existing rules/regulations, the
sub-project may be dropped from the implementation list.
ES Screening for a single component under a sub-project or package may require only 2 days (max.) to
complete, but should be conducted within 2 weeks of identifying the potential location for the
component. ES team at D&SC will conduct the screening survey and reporting, in consultation with the
PIU (ES team) and World Bank safeguard team will review the screening results.
In order to ensure that the project meets its overall objectives, and that the national legal as well as
Bank’s safeguard requirements are met, the following will constitute criteria for the exclusion of
subproject sites from project finance: (i) require involuntary acquisition of land and displacement of tribal
peoples; (ii) affect mosques, temples, graveyards, cremation grounds, and other places/objects that are
of religious and cultural significance; (iii) may significantly restrict access to common property resources
and livelihood activities of groups and communities; (iv) threatens cultural/traditional way of life of
indigenous peoples, restrict their access to common property resources (forests, water bodies, etc.) and
livelihood activities, and affect their places/objects of cultural and religious significance (places of
worship, ancestral burial grounds, etc.). (v) community agreement cannot be reached on sites and
adequate public land area is not available for construction. These are also termed as the negative list for

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screening criteria, and may create substantial project risks. After screening any high-risk and substantial
risk sub-project will be excluded and will not be financed under this project.

6.2.3 Preparation of ES Documents

After preparing an outline design of project component considering the site specifications, relevant
legal/guiding boundaries and available resource options, Environmental and Social documents are
prepared befitting the risk categories. As all the subproject components of RIVER project fall under the
‘moderate to low risk’ categories, the procedures for the preparation of relevant documents are laid out
below

[Link] Moderate Risk Sub-Projects

As per the procedures provided in the table below, Moderate Risk Category sub-projects will require an
IEE/ESA with a site-specific ESMP. The IEE/ESA is a review of the reasonably foreseeable effects of a
proposed development intervention/activity on the environment. Participation and consultation with local
communities are important in identifying the potential impacts and suitable mitigation measures.
Structure of Environmental and Social Assessment is provided in Annex-B. The major activities involved in
carrying out an IEE/ESA include the following:
• Preparation of an environmental baseline within the sub-project influence area, against
which impacts of the proposed sub-project would be evaluated;
• Assessment and evaluation of impacts of major project activities on the baseline
environment during construction phase and operational phase;
• Identification of mitigation and enhancement measures and Environmental and Social
Codes of Practice (ESCoPs);
• Development of site-specific environmental and social management plan (ESMP) including
preparation of environmental monitoring plan with responsibility and estimation of
budget for implementation of ESMP.

[Link] Low Risk Sub-Projects

A site-specific ESMP will be required to ensure enhancements measures are implemented. The ESMP
should clearly lay out: (a) the measures to be taken during both construction and operation phases of a
sub-project to eliminate or offset adverse environmental and social impacts, or reduce them to
acceptable levels; (b) the actions needed to implement these measures; and (c) a monitoring plan to
assess the effectiveness of the mitigation measures employed. The major components of an ESMP
include:
 Mitigation and enhancement measures
 Monitoring plan
 Estimation of cost of ESMP
Guideline for preparation of ESMP is given in Annex-F and Monitoring Plan are provided in Annex-E.
Preparing the ESMP and IEE in an integrated manner to meet both WB and national requirements is an
efficient step to be followed under this project. The project ES team will consider the more stringent or
tougher actions or design modifications within the scope of the project, among the measures/
requirements suggested by both WB and national instruments. In this way, the adopted measures will
satisfy both the requirements, and design team at D&SC will be notified on this provision.

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[Link] National Environmental Clearance Requirements of the Proposed Investments and Sub-
projects
The legislations relevant for environmental assessment for proposed investments and sub-projects are
the Environment Conservation Act 1995 (ECA'95) and the Environment Conservation Rules 1997
(ECR'97). Department of Environment (DoE), under the Ministry of Environment, Forest and Climate
Change (MoEFCC), is the regulatory body responsible for enforcing ECA'95 and ECR'97.

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Table 6.1: National requirement for general environmental assessment

Category General Environmental Assessment Requirement

Green No environmental assessment required to support application for environmental clearance
No environmental assessment required, but detailed project information, including process flow
Orange-A diagrams and effluent treatment arrangement, must accompany application for environmental
clearance
Initial Environmental Examination (IEE) required, and project can proceed to environmental
Orange-B
clearance application once IEE is approved by DoE
Brief IEE required to establish ToR for comprehensive Environmental Impact Assessment (EIA),
Red and project can proceed to environmental clearance application after EIA and Environmental
Management Plan (EMP) have been approved by DoE, often subject to conditions

It is the responsibility of the RIVER-PIU as a proponent to conduct IEE/ESAs of the sub-projects; the
project authority would submit application for granting Environmental Clearance Certificate (ECC) in
favor of the project, with submitting sample IEE/ESAs, project ESMF, NOC from local authorities, and
appropriate fees and so on. Though the project involves a good number of sub-projects/activities under
different work packages, a sample ESA (IEEs) along with respective site-specific ESMP will suffice the
requirements for obtaining clearance certificate in favor of the project. The responsibility of DoE is to
review the documents including the sample IEE/ESAs for issuing Environmental Clearance Certificate
(ECC). Bidding documents for tendering a contract is prepared by the D&SC with inclusion of design and
specifications. Cost estimate of a single component/package is drawn by the BoQ engineer/estimator,
where budgeting for ESMP including monitoring cost is included. ES team at D&SC prepares the ESMP
cost, which is reviewed and finalized by the ES team at PIU. Final estimate of cost requires formal
approval from the Project Director. The specifications in bidding documents contains a section on
Special Environmental Clauses (SECs) incorporated under General/Particular Specification. As shown in
above table, development works are classified into four categories Green, Orange A, Orange B and Red.

6.2.4 Integration of Environmental and Social Assessment with the Design

After conducting reconnaissance site inspection, a general design philosophy aimed at integration of the
environmental and social concerns to the infrastructure designs may be developed. Screening reports
incorporating necessary design modifications/suggestive mitigation measures will be shared with the
design team of D&SC, so that integration of ESA in project design is clearly realized. ES team at PIU will
keep in constant contact and cooperation with the D&SC design and ES team. ES team at PIU will take
administrative measures in receiving the concurrence from the Project Director and the World Bank on
every specific design. Some sample examples on suggestions/design modifications are given in the
following Tables 6.2.
Table 0.2: Environmental and Social Consideration in Construction of Resilient Shelters
Sl. Category of land use/ social and Recommended suggestions/ design modification options
No. environmental features for the
proposed Subproject
1. Waste management  Inclusion of adequate number of color separated waste
bins
 Ensuring the regular management of collection and
disposal of wastes
 A well-bunded brick-built temporary waste dumping area

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to be included in site layout and periodic collection and

dumping to a designated site away from the construction
site; and using part of the construction debris for the
preparation of temporary access road.
2. Energy efficiency  Adopt the design to use of day light
 Provision of adequate ventilation
 Use of renewable energy
3. Universal access  Adopt the design of universal access considering all ages,
gender, and people with disabilities.
4. Gender consideration  Availability of adequate gender separated rooms and toilet
provision, both during the normal and disaster time.
 Regular cleaning provision of the shelter (along with toilets
and waiting room)
5. Health & safety  Design would consider availability of safety equipment
within the building

Table 0.3: Environmental and Social Consideration in Construction/Rehabilitation of road sub-projects

Sl. Category of land use/ social and Recommended suggestions/ design
No. environmental features for the proposed modification options
Subproject
1. Presence of homestead, shop, commercial Minimize social impacts by reducing standard
buildings etc. in a village section, on one or road cross-section, say restricting top width to
both sides of the proposed road 5.7 m instead of 7.3 m (i.e. eliminating the
provision of the soft shoulder; provide side
drains.
2. Presence of paddy field or water bodies along Concentric/eccentric widening based on local
the road (on one side or both sides) community consultation; reduce embankment
slope by providing piling, retaining walls towards
the side of the waterbodies.
3. Presence of school/ mosque/ grave/paddy Widen the opposite side of the features
field/ pond/ ditch/ borrow pits on one or presented, if government land is available.
both sides, along the road
4. Presence of avenue trees along the road side Concentric/eccentric widening based on local
site condition and/or based on community
consultation.

Table 0.4: Environmental and Social Consideration in Construction/Rehabilitation of Jetties/Landing Stations

(Ghat)/Bridge or culverts
Sl Category of land use/ social and Recommended suggestions/ design
No. environmental features for the proposed modification options
Subproject
1. Availability of suitable khas land inadequate  Reduce size and number of infrastructures
as per available space
 Fill the low khas lands to make suitable for
construction

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2. Erosion prone area  Arrange to protect the area by suitable

protection measures.
 Avoid the site if it seems that the area would
be eroded in next 20 years
3. No approach road available  Keep special provision for construction of
approach road to connect the Jetty/landing
station
4. No suitable site for final disposal of  Additional filter bed after the conventional
wastewater septic tank and soak pit arrangement

6.2.5 Environment and Social Management Plan (ESMP)

This section presents the outline of environmental and social management plan (ESMP) of the RIVER
Project. A more detailed version of ESMP will be included in the assessment documents (IEE/ESA) of
respective subprojects.

[Link] Scope and Objectives of ESMP

The basic objective of the ESMP is to manage adverse impacts of project interventions in a way that
minimizes the possible adverse impact on the environment and people of the project influence area.
The specific objectives of the ESMP are to:
 Identify the mitigation measures during ESMF and ESA; and facilitate implementation of those
during implementation of RIVER;
 Maximize and sustain potential project benefits and mitigate negative impacts;
 Draw responsibilities for project proponent, contractors, consultants, and other members of the
project team for the environmental and social management of the project as a whole;
 Define a monitoring mechanism and identify monitoring parameters in order to:
o Ensure the complete implementation of all mitigation measures,
o Ensure the effectiveness of the mitigation measures,
o Maintain essential ecological process, preserving biodiversity and where possible restoring
degraded natural resources and habitats; and
o Assess environmental training requirements for different stakeholders at various levels.
The ESMP will be managed through a number of tasks and activities and site-specific management plans.
One purpose of the ESMP is to record the procedure and methodology for management of mitigation
identified for each negative impacts of the activities under the project. The management will clearly
delineate the responsibility of various participants and stakeholders involved in planning,
implementation and operation of every single sub-projects under the RIVER.

[Link] Inclusion of Relevant Components of ESMP in Bidding and Contract Documents

Bidding documents for tendering a contract is prepared by the D&SC lead by a Team Leader, with
inclusion of design and specifications. Cost estimate of a single component/package is drawn by the BoQ
engineer/estimator, where budgeting for ESMP including monitoring cost is included. ES team at D&SC
prepares the ESMP cost, which is reviewed and finalized by the ES team at PIU. Final estimate of cost
requires formal approval from the Project Director and the World Bank. The specifications in bidding
documents contains a section on Special Environmental Clauses (SECs) incorporated under
General/Particular Specification. These clauses are aimed at ensuring that the Contractor carries out his
responsibility of implementing the environmental and social management plan (ESMP), monitoring plan

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as well as other environmental and safety measures. Such clauses may specify, for example, penalties
for non-compliance as well as incentives to promote strong compliance. The contractors must be made
accountable to implement the plans and mitigation measures, which pertain to them through contract
documents and/or other agreements of the obligations and importance of the environmental and social
components of the project. In addition, the contractor will be asked to submit an Environment
Management Action Plan (EMAP) with all detailed plans, measures and management systems those are
required to develop and implement, based on the ESMF recommendation and findings of the
assessment, their work methodology, work force involvement, equipment’s standard, and work
scheduling. This document will be forwarded to the ES specialists at PIU for detailed review and
concurrence.

[Link] Payment Milestones

Payments to contractors would be linked to environmental performance, measured by completion of
the prescribed environmental and social mitigation measures. Contractors would be required to
coordinate with the executing agency, project implementation unit, supervising consultants and local
population for the mitigation of adverse impacts of the project activities. For effective implementation
of the proposed mitigation and monitoring measures they should employ trained and experienced
environmental management staff.

[Link] Environmental and Social Codes of Practice (ESCoPs)

The environmental and social codes of practice (ESCoPs) are generic, non-site-specific guidelines. The
ESCoPs consist of environmental and social management guidelines and practices to be followed by the
contractors/ implementation organizations for sustainable management of all environmental and social
issues. The contractor will be required to follow them and also use them to prepare site-specific
management plans. Details of the ESCoPs listed below are in Annex- G.
 ESCoP 1: Waste Management
 ESCoP 2: Fuels and Hazardous Substances Management
 ESCoP 3: Water Resources Management
 ESCoP 4: Drainage Management
 ESCoP 5: Soil Quality Management
 ESCoP 6: Erosion and Sediment Control
 ESCoP 7: Top Soil Management
 ESCoP 8: Topography and Landscaping
 ESCoP 9: Borrow Areas Management
 ESCoP 10: Air Quality Management
 ESCoP 11: Noise and Vibration Management
 ESCoP 12: Protection of Biota
 ESCoP 13: Road Transport and Road Traffic Management
 ESCoP 14: River/Canal Transport management
 ESCoP 15: Construction Camp Management
 ESCoP 16: Cultural and Religious Issues
 ESCoP 17: Workers Health and Safety
 ESCoP 18: Stakeholder Consultation

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[Link] Mitigation Measures to Address Environmental and Social Impacts

Possible environmental and social impacts during pre-construction, construction and operation phases
from subproject activities should be identified beforehand. Detail activities need to be identified first
and thereafter set of actions or interventions are to be demarcated and any possible effects due to an
action is to be determined. Best practice mitigation or enhancement measures should be explored
accordingly and deployed in the field. For giving an instance, a set of mitigation measures against
possible environmental and social impacts due to the subprojects at its different phases is proposed in
Annex-D.

6.2.6 Required Site Specific Management Plans (ESS 1-10)

Site Specific Management Plans will be prepared by the contractors of the sub-projects/work packages
as and when required. Selection of the management plans required by the sub-projects will be
determined by the ESS requirements, applicable ESCoPs and recommendation of ESMP. These
documents will be reviewed and cleared by the PIU.
Construction Camp Management Plan: will be prepared by each contractor. The Plan will include the
camp layout, details of various facilities including supplies, accommodation, water supply & sanitation,
toilet, storage, and disposal. The Plan will be submitted for review and approval before camp
establishment.
Occupational Health and Safety (OHS) Plan: will be prepared and implemented by each contractor on
the basis of the WBG EHS Guidelines (1997), ESCoPs, mitigation plan, and other GIIP. The Plan will be
submitted for review and approval before contractor mobilization. For labor-intensive maintenance
works to be carried out by poor people in different areas, OHS measures outlined in the Labor
Management Procedures will be implemented by RIVER-PIU. Further, to inspect the OHS plan at
construction sites and its evaluation will be carried out with different checklist.
Traffic Management Plan: will be prepared by each contractor after discussion with PIU/LGED local
office and authorities responsible for roads and traffic. The Plan will be submitted for review and
approval before contractor mobilization. The Plan will identify the routes to be used by the contractors,
procedures for the safety of the local community particularly pedestrians, and monitoring mechanism to
avoid traffic congestion.
Emergency Preparedness Plan: will be prepared by each contractor after assessing potential risks and
hazards that could be encountered during construction. The Plan will be submitted for review and
approval before contractor mobilization.

6.2.7 Labor Management Procedures (ESS2)

A standalone LMP has been prepared to fulfill the requirement of ESS2 and will be disclosed by PIU.
Besides the LMP, separate OHS management plan will be developed and implemented at the project
activities.

6.2.8 Guideline for Preparation of Environmental and Social Monitoring Plan

The monitoring plan is the key element of ESMP to be prepared on the basis of impact assessment
described in earlier section. The Plan describe the potentially negative impacts of each sub-project
activity, lists mitigation and control measures to address the negative impacts, and assigns

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responsibilities for implementation and monitoring of these measures. The Plans for the RIVER project
will be prepared and included in the ESA.

6.2.9 Monitoring Framework

The objective of the monitoring framework is to ensure that the mitigation measures designed to
prevent, reduce and where possible offset any significant adverse on environmental and social impacts
throughout the Project lifecycle.
The project will adopt a real time monitoring procedure with support from project IT support unit,
whereby a good numbers of real time photographs with comments on implementation status, condition
of safeguards management and visible setbacks in different sites will be taken by field level staffs, sent
to the server for storage at once and readily accessible from any places in the world by the project
authority, consultants as well as world bank. Computer generated monitoring reporting and procedure
will be an added advantage from the system.
However, in order to reduce adverse impacts and enhance positive impacts from project activities, LGED
with support from the consultant will be responsible to monitor and make sure that the environmental
mitigation/enhancement measures (including health and safety measures) outlined in the ESMP for the
particular sub-project are being implemented in accordance to the provisions of the Tender Document.
Apart from general monitoring of mitigation/enhancement measures, important environmental
parameters to be monitored during the construction phase of the sub-projects including air quality,
noise level, water quality, drainage congestion, and traffic problems. However, the requirement and
frequency of monitoring would depend on the nature of sub-project and field situation. IEE report for
each sub-project will include every details of monitoring activities, including monitoring frequency,
responsible persons, monitoring indicators, etc. and a sample monitoring plan for environmental and
social management issues are given in Appendix- E. Based on monitoring outcomes, further course of
corrective actions is to be set up and implemented.
The PIU environment and social specialists will carry out ESMF monitoring to ensure that the mitigation
plans are being effectively implemented, and will conduct field visits on a regular basis. A synopsis of
ESMF monitoring plan is provided hereunder.
Table 6.5: Monitoring responsibilities in phases
Project Phase What When Who (monitoring How
authority)
Preparation Training and capacity Before PD with Safeguards Reviewing training
building preparation of Specialists at PIU records
tender documents
Preparation Ensure screening of After locations, PD with Safeguards Review completed
environmental and primary design Specialists at PIU screening reports
social issues, and and alignment are
conducting survey for confirmed
ESA reports.
Preparation and Consultation During the sub- PD with Safeguards Review of
Construction meetings with project screening Specialists at PIU Screening reports
stakeholders survey and and quarterly
feasibility; safeguards reports;
throughout and incidents

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project cycle reporting protocol

Construction Training and capacity Monthly PD with Safeguards Reviewing training
building Specialists at PIU records
Construction Grievance Records Monthly PD with Safeguards Review Grievance
Specialists at PIU Register
Construction Environmental and Monthly PD with Safeguards Review ESMP
Social mitigation/ Specialists at PIU monitoring
enhancement documents/progress
measures (including reports.
health and safety
measures) outlined in
the ESMP and
incorporated in the
bidding documents
and the approved
contracts.
Construction Environmental and Monthly PD with Safeguards Review ESMP
Social mitigation/ Specialists at PIU monitoring
enhancement documents
measures
Operation and Grievance records Monthly PIU Review GRM
maintenance Register
Operation and ESMP (including Monthly PIU Review ESMP
maintenance health and safety monitoring
measures) documents

A third party monitoring firm may be employed by the project as M&E Consultants within 1st year of the
project implementation under an open bidding process. This independent monitoring body is
responsible for systematic, regular and constant monitoring of all the activities undertaken in the field
with vigorous services by a specialized set of consultants, including Social, Gender and Environmental
specialists, adept in all their respective fields. The monitoring reports produced by the firm is forwarded
directly to WB and the office of the Project Director.

6.2.10 Adaptive Management during implementation

All ES documents are subject to amendment or changes from time to time during Project
implementation, to reflect adaptive management of Project changes and unforeseen circumstances or
in response to assessment of Project performance under those documents. In such circumstances, LGED
will make necessary changes in documents, obtain concurrence from the world bank and will promptly
disclose the updated versions.
Apart from documentary adaptation, adaptation in physical construction or to an evolved situation may
be required. For example, flood may occur during the construction period and people may need to take
immediate refuge in under-construction shelter (if the progress of physical works permit that) buildings,
adaptive management options will be put in place for minimizing the plights; similar experience was
very common in cyclone shelters under the ongoing MDSP project.

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6.2.11 ESMP Implementation Cost

Cost estimates will need to be prepared for all the mitigation and monitoring measures to be proposed
in the specific assessment in accordance with the ESMF. The cost estimates for some of the mitigation
measures to be identified in the ESMP will be part of civil works contract.
The Development Project Proposal (DPP) of LGED for the proposed project should reflect the ESMP
activities with budget for successful environmental and social management of the project. Total US$
3.12 million is estimated for implementation of ESMF, which should be embedded in the proposed total
project budget from World Bank. All the budgetary allocation for the components under table 6.6 will be
coming from the PA (Project Assistance) part of the project financing.
Table 6.6: Cost Estimates for ESMF implementation of the RIVER Sub-projects
SN Description Amount
million US$
1 Contractor’s Budget for development of management plans, staff, training, etc. 0.2
2 Water, soil and air quality monitoring during construction (quarterly for 5 years) 0.5
3 Tree plantation development and maintenance 0.2
4 Development of ES assessment, management and monitoring documents during construction 0.5
and operation (3 years), training to workers, monitoring of sites
5 Implementation of Resettlement Policy Framework (without requisition and resettlement) 0.08
6 Implementation of GBV Action Plan 0.06
7 Implementation of SEP 0.98
8 PIU Safeguards Consultants 0.4
9 Capacity building and institutional strengthening 0.2
TOTAL 3.12

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CHAPTER 7: STAKEHOLDER ENGAGEMENT, GRIEVANCE MECHANISM AND

DISCLOSURE
7.1 Introduction
Stakeholder refers to individuals or groups who are affected or likely to be affected by the project or
other interested parties who have an interest in the project; and the term “stakeholder engagement”
refers to a way to describe the process of engagement between a project developer and those
potentially affected by the subprojects or way of supporting the implementation. Stakeholder
engagement can cover a range of activities and approaches and those are; consultation, engagement,
external relations, information disclosure and dissemination, community participation etc. In the RIVER
project LGED has already designed a common stakeholder engagement plan (SEP) for all the sub-
projects to be developed or constructed across the fourteen selected districts. This project SEP has
primarily identified the potential stakeholders, requirements to the engagement with the project,
methods of engagement, and also delineated a set of strategy for engagement program, target
information to be disclosed with the relevant groups and pathways to review and inclusion of
views/perceptions/concerns/suggestions into the various decision making stages of the project. Specific
considerations on vulnerable groups from every possible circumstances have been taken into good care
of while drafting the project SEP.
As a part of the preparation of ESMF and other ES documents, a series of consultation events with the
potential stakeholders were carried out from 15 to 18 November 2021 in four project districts-
Kurigram, Sirajganj, Gopalganj and Sunamganj under four project divisions of the country. The mode of
consultations were limited to Public meeting, Focus group discussion, and the Key Informant Interviews
(KII) as the sub-projects will be spread across the districts, and were conducted in Bengali (with local
dialects, with the help of local LGED officials).
This chapter will put a glimpse of the project SEP along with the outcome of the carried out consultation
meetings (in person) and the project mechanism to resolve the grievances that may come throughout
the project life cycle and the project framework for disclosure of information.

7.2 Stakeholder Consultations and Disclosure

7.2.1 Objective of the Consultations

The World Banks’s Environmental and Social Framework (ESF) underscores the importance of open and
transparent engagement between the borrower and project stakeholders as an important pillar of good
practice. Effective stakeholder engagement through a robust consultation and disclosure mechanism
promotes environmental and social sustainability of the project, enhances its acceptance and makes
important contributions to design and aids in smooth implementation of the project. Stakeholder
engagement is an inclusive process and is carried out throughout the life cycle of the project. ESS10
refers to Stakeholder Engagement and Information disclosure requirements of the ESF. The following
are the objectives of ESS10:
 Establishment of a systematic approach to stakeholder engagement that will enable borrowers
to identify and form constructive relationships with the relevant stakeholders, including Project
Affected People (PAP).
 To assess the level of stakeholder interest and support for the project and ensure that through
this mechanism, the views of the stakeholders are incorporated into the project design.

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 Encourage and facilitate methods of effective, meaningful consultation and engagement with
PAPs throughout the project cycle on issues that could potentially have an impact on them
 Ensure that project information related to environmental and social risks and impacts is
disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and
format.
 To provide project-affected parties with accessible and inclusive means to raise issues and
grievances, and allow LGED to respond to and mange such grievances.
ESS10 promotes meaningful consultation and communication with all stakeholders, and the process of
stakeholder engagement involves the design and implementation of a Stakeholder Engagement Plan
(SEP).
7.2.2 SEP formulation and implementation arrangement
The SEP for this project has been prepared as a standalone document for the project life cycle. Mapping
the project stakeholders is the first and foremost task in the preparation, and similar to the other LGED
implementing projects, stakeholders primarily fall into two major groups (i) project affected parties who
are affected or likely to be affected by the project activities, and (ii) other interested parties who may
have an interest in the project. Communities in the subproject areas who could be directly affected by
the project activities, local boatmen, market goers, businessmen using the ghat/landing stations,
teachers and students, unemployed working class people, and people from different vulnerable groups,
such as, elderly, disabled, children, pregnant women, single mothers, informal settlers, among many
others fall into the first group, while civil society groups, local suppliers and businessmen, SMCs, NGOs
working on labor/GBV/SEA/SH issues in the locality, different government bodies including MoDMR,
MoPME, finance and planning ministry, and many others constitute the 2nd group of stakeholders in this
project. The level of engagement required for each group of stakeholders is based on their level of
interest and impact they may face or exert on the project. The overall coordination and monitoring
mechanisms established in the SEP are overseen by project PIU where one Social Development
Specialist and a Communication Specialist will be stationed, and the safeguards consultants at D&SC,
XEN, UE, district sociologist, will be taking care of day-to-day progress of the activities that sketched out
in the SEP.
7.2.3 Stakeholder Consultation in project districts
As part of the appraisal and formulation of this ESMF, eighteen (18) stakeholder consultations (three
consultations in each of the four selected project districts) were carried out on different days and the
participants included potential group of PAPs in the sub-project areas, different vulnerable groups, and
relevant government and non-government stakeholders. Officials from district level LGED offices,
government officials from relevant departments, NGOs, journalists were among the stakeholders too.
The consultation and participation process was carried out in person mode and was limited to selected
stakeholders in four project districts- Kurigram, Sirajganj, Gopalganj and Sunamganj under four project
divisions of the country. Though the country is not fully recovered from the outbreak of COVID-19, a
series of consultation meetings were necessary to apprehend the nearly precise outcomes.
During the consultation all the stakeholders were briefly informed about the project, its background and
components, environmental and social concerns/ impacts, and intended mitigation measures which
would also take into account the opinion/ suggestions of the stakeholders (it was instructed to the study
team to note down any specific suggestions/ possible concerns from the local people or stakeholders
about any parts or components of the project and whether they have any specific suggestions to
manage/mitigate environmental or social problems in the field.)

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Participants were also consulted about existence and status of any socio-cultural/ religious heritage or
(centennial) old trees/buildings, specific sites where people visit/gather, and so on, near to any of the
sub-project sites, including the approximate distances from particular sub-project sites. LGED Sub-
Assistant Engineers/ District Sociologists were the key informants in this regard. As the project will have
a well-functioning grievance redress mechanism/ formal complaint submittal / resolution mechanism,
and participants were informed that they would be able to lodge formal complaints/suggestions about
the project throughout the entire implementation period and complaints will be resolved very quickly by
different tiers of redressal committees.
The study group were also instructed to take into account the presence of any small ethnic or
indigenous group near to any sub-project sites (in that case, group/ caste name, distances of any sub-
projects from their residential areas, etc. were noted down) as per WB requirement, and consultation
would be carried out in an universally recognized method of Free, Prior and Informed Consent (FPIC)
process. However, none of such that group members were found during these series of events.
The consultation and participation process undertaken so far has adopted a highly participatory
approach through Focus Group Discussion (FGD) and Key Informant Interviews. General public meetings
were also carried out. Due to the selective nature of these consultation events, couple of meetings
found no presence of women representatives, though separate meetings with vulnerable women group
was also conducted. The discussion and the concerns and responses are extensively documented in SEP.
Table 7.1: Summary of Consultation Meetings and FGDs
Date Place Upazila/ Division No. of Mode of
District Participants Consultation
F M Total
District: Gopalganj
16/11/2021 Tuthamandra GPS, Sadar Upazila, Dhaka 9 26 35
Community
10 No Shahapur Gopalganj
consultation
Union Parishad
16/11/2021 -do- Sadar Upazila, Dhaka 0 17 17 FGD with
Gopalganj Vulnerable
women
15-17/11/21 Concerned UEO, XEN, Dhaka 2 4 6 Key Informants
Offices-LGED, LGED, SDE, Interview
UEO, WDB WDB,
Gopalgon
District: Sunamganj
16/11/2021 120 No. Sylhet 30 15 45
Shekhergaon GPS, Sadar Upazila, Community
Kurban Nagar Sunamganj consultation
Union
18/11/2021 -do- Sadar, Sylhet 10 0 10 FGD with
Sunamganj Women group
18/11/2021 Concerned Sylhet 0 13 13 Key Informants
Offices- LGED, Interview
Sadar,
UNO, UEO, WDB,
Sunamganj
DPHE, PIO,
BRAC,Newspaper

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Contractor’s Rep.

District: Kurigram
16/11/2021 Notan Para Govt. Rangpur 18 30 48 Public
Rowmari,
Primary School, consultation
Kurigram
Rowmari,Kurigram
16/11/2021 Notan Para GPS, Rangpur 7 3 10 FGD with
Rowmari,
4no. Rawmari School teachers
Kurigram
Union
16/11/2021 Nomodas para, Rangpur 20 0 20 FGD with Local
Rowmari,
4no. Rawmari women
Kurigram
Union
16/11/2021 Sobujpara, 4no. Rowmari, Rangpur 9 0 9 FGD with
Rawmari Union, Kurigram Adolescent girls
16/11/2021 Sobujpara, 4no. Rangpur 10 0 10 FGD with
Rawmari Union Rowmari, Vulnerable
Kurigram group (Elderly
women)
15-16/11/21 Different Offices- Rangpur 0 6 6 Key Informant
DEO, WDB, RDD, Rowmari, Interview(KII)
Tv, Press club & Kurigram
Grameen Bank.
District: Sirajganj
18/11/21 K R Kowkor Govt. Sirajganj Rajshahi 0 25 25
Primary School, Public
Ullapara, Sirajganj consultation

16/11/2021 K. R. Noukoir GPS, Sirajganj Rajshahi 0 6 6 FGD with

Solp Union, School teachers
Ullapara, Sirajganj.
16/11/2021 Halder para, Solp Sirajganj Rajshahi 18 0 18 FGD with Local
Union, Ullapara, women
Sirajganj
16/11/2021 Noukoit, West Sirajganj Rajshahi 7 0 7 FGD with
para, Solp Union, Adolescent girls
Ullapara, Sirajganj.
16/11/2021 Noukoit, West Sirajganj Rajshahi 20 0 20 FGD with
para, Solp Union, Vulnerable
Ullapara, Sirajganj. group (Elderly
People)
16/11/2021 Concerned Sirajganj Rajshahi 0 5 5 Key Informants
Offices- LGED, Interview (KII)
DSHE, DPE, BRAC
& Newspaper.
Total 16 150 310

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Prior to these consultation events conducted by LGED, a total of 2,415 face to face interviews, 16 mini
group discussions, 15 in-depth interviews, and 45 key informant interviews were conducted by the
project feasibility team in August 2021. All these meetings/consultation events demonstrates the fact
that various other tools should be used for consultations including household level interviews,
participatory rural appraisal, issue specific consultation meetings, and open meetings during the E&S
survey for screening and assessment of each sub-project/ components.
7.2.4 Outcomes of Consultation Meetings
During preparation of ESMF and other safeguards documents, the feasibility study team for this project,
has taken stakeholders opinion and those are incorporated with the entitlement matrix. A summary of
consultation outcomes is given in the Table 7.2..
Suggestions from the consultation meetings will be incorporated into the project design, and the extent
of incorporation will depend on the scope of design statement within the proposed activities of the
project. As the design of physical components and services is prepared and finalized in a consultative
process, stakeholders inputs or suggestions will complement to attain the project objectives. For
example, shelter design with higher plinth level and having provision for ramp and uninterrupted power
supply, as suggested from the consultation meetings, will ensure improved protection and resilience
against flood events for the target people. Provision of incorporating adequate window to allow natural
light and air inside the shelter while designing, and ensuring the use of safety gears, properly managed
stack yard during the construction works are also the suggestions from the consultation meetings, which
will be incorporated as mitigation measures
Consultations with vulnerable groups (adolescent girls, women, elderly, poor people, etc.) has revealed
some of the key concerns which are predominant in the rural settings of the country. Their suggestions
include provision of separate toilets and shelter room for male and female with high commodes in
toilets for aged & physically challenged persons, wheel chair for the elderly and physically challenged
people, breastfeeding corner cum changing room, primary medical facilities, installing 24-hour security
cameras in the shelters, job placement for women during the construction period, and so on. All these
requirements and suggestions have already been consulted for due inclusion with the design engineers
under the project feasibility study team who are also responsible for preparing the design and bidding
documents for the first two contract packages under the project. The same procedure will be replicated
when the D&SC services are put in place.
However, design prototypes including the facilities that are suggested by the target stakeholders are
being developed at this appraisal stage and will be finalized shortly. Adequate consideration will be put
in place while conducting and managing stakeholder engagement events in or around the sites so that
free, prior and informed suggestions/ comments are received and incorporated into the design and
mitigation measures with due priority as indicated in SEP. ES team under the D&SC will record the
outcomes of meetings and consult with the design team for adequate and functional incorporation.

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Table 7.2: Stakeholder Discussion Outcome

Issues Discussed Bottlenecks/ Problems Raised Suggestions come out through the discussions

Necessity of the Project Flood shelters and other facilities are not Participants are delightedly welcoming the project and would like to support the project
present in many areas; in some areas and putting an advice to take necessary precautions to mitigate various impacts during
existing facilities are not in usable the construction and operational stages of the project.
condition, and having access road and
ensuring security is still a matter of They also opined that shelters and associated facilities should be constructed evenly
concern. across the district, considering the population density of each area; and remote areas
should receive more priority. Identification of proper catchment area for each shelter
site is also crucial for the best use of the facilities.

Basic Design Requirement Many of the schools goes under water in Considering anticipated impacts while making design layout.
times of flooding events, some collapsed
into the river, and some are constructed Before selecting the sites and finalizing the design, last 40-50 years’ flood nature, extent
without considering the proper and duration should be considered.
catchment area or connecting pathways Shelter should be constructed to minimum 3-5 storied and highest flood level should be
or the differentiated facilities needed for considered for the ground level for shelters; even the entire premises within the school
different groups of people in the boundary could be elevated.
catchment area.
Adequate lighting in and around the shelters, health care services, separate place for
cattle, and proper shelter connecting road must be included in design.

Provision for uninterrupted power supply facilities and security measures (security
camera) in the shelters.

Elevated access road to the shelters in comparison to local roads considering highest
flood level in the area.

Provision for Ramp in the shelters for the older and physically challenged persons; and
living arrangements with toilet facilities for elderly people should be provided on 1 st
floor.

Provision for guide Wall around the Haor surrounded schools.

Integrating in design for the provision of ‘Wash Block’ and ramps on both sides.

Potential Environmental  Site selection was done not realizing Avoiding cutting down trees during the construction works.
and Health & Safety Issues the necessity of the community
people in case of constructing Provision for adequate medicinal supplies to the shelters during the flooding period,

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previous shelter buildings. and ensure health care services in that crisis moment.
 Occupational H&S during the
construction period was not Ensuring drinking water facilities in the proposed shelter for flooding period, and taking
maintained adequately. appropriate measures to avoid pouring polluted water into the tubewell.
 People’s apathy to coming to the Adequate window to allow natural light and air to enter the room while designing, and
shelters due to the insufficiency and preventing environmental pollution during construction works.
poor condition of provided facilities,
and serious mismanagement. Ensuring using of safety gears, properly managed stockyard during the construction
 Some dilapidated old school building works.
needs rehabilitation for the
Ensuring hygiene/ cleanliness and kitchen/dining, storage facilities, and separate
betterment of students and local
facilities for male and female persons inside the shelters, as people usually stay longer
community under this project (may
time in flood shelters.
not be included as disaster shelters).
 Insufficient classrooms in some of the Construction area within the school boundary should be fenced completely during
existing school buildings, and construction period, and ensuring cleanliness during construction and operation period.
waterlogging inside the shelter
premises. Making arrangement for keeping cattle on the ground floor/ shelter area and sufficient
fodders for the shelter period.

Provision for sufficient medical facilities & doctors during the flood period.

Potential Social and  Women’s sufferings due to the jobs Boat schooling during the flood period.
Gender Issues scarcity during the period from late July
to Early October, and with very low Provision of separate male & female toilets including high commode for aged &
payment in other times of the year. physically challenged persons. Provision of wheel chair for the transport through the
Eager to get engaged as labors during the ramp, for the elderly or physically challenged ones.
construction period. Provision for separate toilet facilities and shelter rooms for male and female,
 Feeling unsafe by women during breastfeeding corner cum changing room, and ensuring safety and security of the
flood/ disaster, and facing difficulties to women and children, while in the shelter.
get access to the WASH facilities, and
emergency food and health care Provision of good landscaping, including a playground, cycle stand, and cattle shed,
facilities. within the school premises and students may avail the facilities in regular time as well.

Ensuring proper facilities for physically challenged and older people, breast-feeding
corner, and primary medical facilities during sheltering.

Provision of wheel chair for the women and elderly persons. Other facilities for elderly
persons include living arrangement with attached toilet facilities on 1 st floor.

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Adequate security measures including installation of security camera at different

strategic places in the shelter to prevent any unlawful activities including GBV.

Provision of 24-hour security and surveillance all the year round.

Provision of supplying educational equipment (chairs, tables, cupboards etc.) for the
students of the school, and keeping arrangement for playground for children

Alternative and temporary arrangements for schooling of children during the

construction period, in consultation with the contractor, local communities, school
management committee, etc.

Expecting by the participants for relief and emergency health care support during the
flood; and financial and technical support after the flood for restoration of living/
livelihood.

Employment Opportunities Employment opportunities halted down Preference of unskilled local labours for shelter construction works and a separate GRM
severely, due to recent COVID-19 (Grievance Redress Mechanism) should be enacted for the labors only.
outbreak across the country.

Stakeholder Engagement  Lack of coordination, Before finalizing any shelter for construction, Upazila Education Officer should be
and Grievance mismanagement, and maintenance in consulted, and prioritizing the construction of access road to the shelter.
Redressment existing shelters, and unavailability or
poor maintenance of required Organizing a daylong seminar involving project related officials and public
facilities, including WASH facilities in representatives to let people know how and which sites are finally selected; and the
existing shelters are very common benefit of proper using and maintenance of shelter and associated facilities.
 Many of the vulnerable families opt to Coordination committee for each school with representation from LGED, WDB, School
stay at home or on nearby highlands, teachers, District Education Office, NGO, etc. could be formed for proper running and
and even many families do not know maintenance of the shelters, throughout the year.
if there is any shelter present in the
area. Enhancing regular coordination, monitoring and supporting among LGED officials,
contractors, SMC for good working condition.

Formation and properly activation/running a grievance redress committee at school

level to resolve any potential conflicts during the construction period.

Preparing multiple design options and sharing those with different stakeholders;
considering river erosion data during design to ensure embankment protection (if
required).
Information Disclosure There were some disasters shelters in the Emphasizing on public communication and awareness regarding the shelter placement,

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area, but many people didn’t even know facilities provided and proper use and maintenance of the facilities, and the disclosure
the existence of those shelters and didn’t of information to the local people with different events.
go for sheltering even in last prolonged
flooding period in 2020. Developing Standard Operating Procedure (SOP) for shelters, and public-private
partnership for public awareness and consultation, along with Upazila and Union level
committees for shelter management under the project; information disclosure and
public awareness by using local media.

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7.2.5 Stakeholder engagement during the implementation period

Consultation with the potential project affected people and other interested parties, including vulnerable
groups, will be conducted at regular intervals (e.g. quarterly) by the different entities under the project
implementation framework, as stated in the SEP. The mode of consultation may be public meeting, FGDs
for different vulnerable groups (women, female headed households, elderlies, ethnic communities, etc.),
communication through mass/social media, distributing brochure/leaflets, posting on notice boards and
so on, and the events will be conducted by the PIU team (during visiting a site), LGED officials from local
offices, ES consultants and support staff of D&SC, M&E firm, contractor/sub-contractors and other
skilled/contracted facilitators to inform about the project scope, activities, grievance system,
employment opportunities, etc. and learn on the suggestions/comments/ grievances that could be used
for sub-project specific rectification measures or further decision making process including design and
mitigation activities. Consultation with vulnerable groups will be conducted with great care and
sophistication in order to ensure that none of the project activities will cause a least harm to them, and
project design and implementation will put maximum emphasis on their needs and amelioration or
restoration of their livelihood, within the project scoping boundary. Moreover, contractors will employ
at least 75% of labors from the local communities/sources, and to avoid any dispute with the local
communities/potential stakeholders and if raised, settle the disputes amicably. However, contractor’s
activities relevant to ES issues must be presented in the compliance/progress reporting.

7.2.6 SEP revision and updating

The project may experience different scenario/ circumstances or new stakeholders of significantly
important for the project, at some point in project life cycle, when the proposed plan, method or
resources may not be found suitable or sufficient for addressing the newly evolved scenario or may found
inconsistent or obsolete in terms of effectivity. Considering such unforeseen situation or circumstances, if
arised, the SEP needs to be revised and updated incorporating the best available practices or required
plans. A periodic revision would be more feasible to get abreast with the contemporary scenario, by the
Social Development Specialists in consultation with the Communication Specialist, specifically in context
with the project requirement at that point of time and specific phases of development. Any major
changes in project related activities or its schedule, or inclusion of any missing stakeholder groups (that
may have significant effects in decision-making) shall be reflected properly in the newly revised
document. M&E consultants should also be communicated for their valuable observations/suggestions
regarding any required changes in SEP, and the revised version will have concurrence from the World
Bank’s safeguards team.

7.3 Grievance Redress Mechanism (ESS10)

As the implementing agency, LGED will respond to concerns and grievances of project-affected parties
related to the environmental and social performance of the project in a timely manner. For this purpose,
a well-functioning Grievance Redress Mechanism (GRM) will be established and implemented which is an
accessible, inclusive system, process, or procedure that receives and acts upon complaints and
suggestions for improvement in a timely fashion, and facilitates resolution of concerns and grievances
arising in connection with the project. This procedure will answer sub-project -related queries and
address complaints and disputes about any aspect of the implementation activities, including
disagreements regarding the assessment and mitigation of environmental and social impacts. An

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effective grievance mechanism provides project-affected parties with redress and helps address issues at
an early stage to receive and facilitate resolution of such concerns, complaints and grievances.
A separate GRM has been proposed under the LMP and SEP, which will guide the project GRM during
the implementation and is proportionate to the potential risks and impacts of the project. LGED would
ensure that grievance redress procedures are in place and would monitor those procedures to ensure
that grievances are handled properly. Details of the institutional arrangements and procedures are
discussed in the standalone LMP and SEP.
Overview, Scope and Principles. The proposed Grievance Redress Mechanism (GRM) will be answering
queries, receiving suggestions and addressing complaints and grievances that are likely to get raised in
the project cycle including identification, planning, design and implementation. It spans the entire
implementation period and will cater to both the beneficiary communities and the directly and indirectly
affected population including the workers employed by the contractors at different levels. Though the
GRM generally is meant to set a mechanism to redress or to address environmental and social problems
identified during the implementation, it will also cater to manage any disconnects that emerge from the
field level and that has significant implications for effective implementation of the project interventions.
Handling of grievances will be done in a culturally appropriate manner and be discreet, objective,
sensitive, and responsive to the needs and concerns of the project-affected parties. There are certain
principles that must be uphold during the functioning of GRM, such as
a. All grievances are to be treated impartially, objectively, and in a timely manner and users of a
grievance mechanism will not be subject to retaliation, abuse, or any kind of discrimination and
any allegations of retaliation, abuse, or discrimination must be remediated appropriately.
b. The grievance mechanism is expected to address concerns promptly and effectively, in a
transparent manner that is culturally appropriate and readily accessible to all project-affected
parties, at no cost and without retribution.
c. Any discrimination in providing access to the mechanism or system, under any circumstances is
completely prohibited and will be considered punishable offences.
d. Anonymous complaints, grievances or suggestions shall be treated with the same priority as
other regular cases and confidentiality of every single cases are to be strictly maintained, up
until the complainant gives concurrence on identity disclosure.
e. The mechanism, process, or procedure will not prevent access to judicial or administrative
remedies.
f. The results of every cases are to be communicated back with the complainants/affected
persons/ entities.

Objectives of Grievance Redress Mechanism. GRM will be well accessible and inclusive. The fundamental
objective of grievance redress mechanism (GRM) will be to resolve any project -related grievances locally
in consultation with the aggrieved party to facilitate smooth implementation of the social and
environmental action plans. Another important objective is to democratize the development process at
the local level and to establish accountability to the affected people. The procedures will however not
pre-empt a person’s right to go to the courts of law.
The GRM will be consistent with the requirements of the World Bank’s safeguard policies to ensure
mitigation of community concerns, risk management, and maximization of environmental and social
benefits. The overall objective of the GRM is therefore to provide a robust system of procedures and
processes that provides for transparent and rapid resolution of concerns and complaints identified at the
local level. It will be accessible to diverse members of the community, including women, senior citizens

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and other vulnerable groups. Culturally-appropriate communication mechanisms will be used at all sub-
project sites both to spread awareness regarding the GRM process as well as complaints management.
Where project intervention areas cover beneficiaries from the small ethnic communities, project GRM
will integrate traditional grievance management system available with the small ethnic communities.
Communication & Awareness raising on GRM. In order to make GRM accessible to all stakeholders, the
entire procedure should be simple and easy to understand. With this in mind, LGED will inform the
project-affected parties about the grievance process in the course of its community/stakeholder
engagement activities and will make publicly available a record documenting the responses to all
grievances received. All potential PAPs will be briefed on the scope of the GRC, the procedure for lodging
grievances cases and the procedure of grievance resolution at levels, and indicated about the expected
length of timelines for acknowledgment, response, and resolution and the provision of anonymous
complaints lodging.
The final processes and procedures for the GRM will be translated into local language (i.e., Bangla) and
disseminated at all project locations. These shall be made available (in both leaflet and poster format) to
all project locations with the staff on site and in the offices at Villages, Upazila, and District.
Proposed Structure of Grievance Redress Mechanisms (GRM). For addressing grievances, four tiers of
redress mechanism (GRM) as suggested in SEP and a single tier grievance redress system for labor
management will be established with representations from beneficiary communities including men and
women, civil society organizations, elected representatives and the project proponents (LGED). The first
and most accessible level of a grievance redress system lies at the Upazila Engineer (UE)’s Office. A
‘complaint box’ as well as a ‘Grievance Registry’ will be kept at UE office, where an aggrieved, affected or
interested person can either drop his/her letter of complaints into the box or hand-write the complaints
on the registry. Both the complaint box and the registry will be placed at a well-visible and strategic place
in the UE’s office, so that people do not feel intimidated or followed while the complaints are lodged.
Apart from these formal way of complaining, District Sociologist and other local level project officials
could make periodic visit to the sub-project sites to interact with the local communities, project workers,
or affected persons and to register any issues of concerns, complaints or suggestions. Whatever the
mode of receiving grievances, all must be registered and a notification of receipt and back-to-back
resolution processes and decisions has to be communicated with the aggrieved person in writings. For
resolving the grievances or issues of concerns, each of the four levels in the grievance redress mechanism
has respective Grievance Redress Committees (GRCs):
(i) the first GRC is at the Upazila level to be convened by the Upazila Engineer,
(ii) 2nd tier of GRC will be at the district level at Executive Engineer’s Office with the district XEN
being the Convener ,
(iii) 3rd tier of GRC will be at the Project Director’s Office/PIU level where the Project director will
convene the committee, and
(iv) the National level GRC will be functioning at LGED HQ level headed by an Additional Chief
Engineer as the Convener. The detail structures of each GRC is detailed out in SEP for more
clear understanding.
The structure and responsibilities of the GRCs in each level are described more comprehensively in the
project SEP. However, all the committees will have a Convener and a Member Secretary, and the
Member-Secretary will be coordinating and formally carry over the unresolved cases to the next
level/committees. Therefore, the Member-Secretary of a GRC will take a member position in the
subsequent level of GRC. The project will show highest integrity and commitment to address every
grievances received at the very first level. All the grievances will be brought to the respective committees

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for review and decision within three days of registration, and if the satisfactory resolution is not achieved
in the GRC meetings, the cases will be forwarded to the next level GRCs.
The Social Development Specialist/consultant with the PIU will be the Member-Secretary or the key
contact person at the project level. In case the issue is not resolved, the aggrieved person has the option
to adopt judicial procedure. In cases where vulnerable persons are unable to access the legal system, the
GoB will provide legal support to the vulnerable person(s). As well as, the PIU will assist the vulnerable
person(s) in getting this support from the GoB. The PIU will also ensure that there is no cost imposed
(such as for travel and accommodation) on the aggrieved person, if the person belongs to the vulnerable
groups including the small ethnic communities. The verdict of the judiciary will be final. Details of the
mechanism and structure are described in relevant documents.

LGED HQ Level
(National Level)

PIU (PD level)

GRC (District)
Office of the Executive Engineer
District LGED

GRC (Local)
Upazila Engineer’s Office
Upazila LGED

Complaints & Suggestions on Complaints and Suggestions on

environmental, social and resettlement procurement, construction quality,
issues contract management, financial
management, and fraud & corruption
related issues

Complaints and Suggestions by

Community/Users/Beneficiaries and Affected Persons

Figure 7.1: Grievance Redress Committees (GRCs) at different levels (excerpted and modified from SEP)

7.4 Information Disclosure and Revision of Documents

Disclosure of project information in project websites of LGED is a common practice for long. However,
stakeholders are required to have open access to project appraisal documents including all the E&S
safeguards documents, in order to allow them to understand the risks, impacts or potential opportunities
from the project and the mechanism of information dissemination should be simple and understandable
to all. Under the recent guidance of World Bank’s Environmental and Social Framework, five key

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materials (to the least) are required to prepare by LGED as part of E&S Safeguards documents at the
appraisal level: (i) Environmental and Social Management Framework (ESMF)/ Environmental Impact
Assessment (EIA) Report, (ii) Resettlement Policy Framework (RPF), (iii) Stakeholder Engagement Plan
(SEP), (iv) Labor Management Procedure (LMP) and Environmental and Social Commitment Plan (ESCP),
which need to be disclosed in full length, both on the World Bank and Project websites. Some other
documents related to E&S safeguards are to be prepared and disclosed widely, based on the project
scope and circumstances arised, e.g., Small Ethnic Community Development Policy Framework (SECDPF)
will be required, if any project component will fall in or pass through an area where any small ethnic
community inhabits or have some livelihood activities.
Two of the important means for information disclosure or dissemination that have been followed until
now include briefing materials and organization of community consultation sessions. Besides the full-
length copies of the previously said documents to disclose electronically, executive summary or some
collected or excerpted portion of those documents need to be disclosed or circulated in the project sites
as briefing materials or brochures, preferably in Bengali for an ease understanding by the communities
and relevant stakeholders. The briefing materials and brochures should include project information,
applicable assistance to be given to the PAPs; grievance mechanism, etc. that can be kept in the offices of
local government (union parishad offices) and project offices. Posters on OHS, GRM, CoCs, GBV/SEA/SH,
etc. are to be displayed at strategically visible locations and leaflets on the same topics can be distributed
in the project areas. Consultation meetings should also be organized at regular intervals by the project to
acquaint the communities, target group beneficiaries and affected persons of the following:
 Timeline and progress of the project by components;
 Information on beneficiary participation;
 Information of involuntary displacement, compensation and entitlements;
 Information of participation of small ethnic communities;
Also, opinion and consensus of the community needs to be sought for livelihood transformation,
relocation of any community assets and involuntary resettlement management. Information disclosure
procedures are mandated to provide citizen centric information as well as all documentation necessary
for addressing any queries and it will enhance governance and accountability specifically with respect to
strengthening of monitoring indicators to help the World Bank monitor compliance with the agreements
and assess impact on outcomes. A set of disclosure requirement has been presumed and presented
hereunder in table 7.3 for tracking the progress and outcomes of the disclosure initiatives.
Revision of E&S documents including the progress monitoring documents are subject to revision if and
whenever required. The draft final E&S documents will be disclosed to the project website, after
necessary concurrence from the World Bank is received. An invitation notice for further
comments/suggestions will be posted on the same quoting a time frame (3 months) for submission
deadline; and simultaneously, the translated versions (in Bengali) of the executive summary of the
documents will be made available to the people/stakeholders in the project districts, in the form of
project briefing/leaflets. During the consultation meetings with stakeholders, especially while doing the
screening survey, project briefings including grievance redress mechanism shall be communicated, along
with distributing the hard copies (leaflets). Any suggestions/ recommendations concerning any topic in
the E&S documents will be recorded/ tabulated by the ES consultants at PIU and necessary
incorporation/amendment of the documents will be made by the ES documents revision committee
comprised of following personnel:

(i) Deputy Project Director at PIU

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(ii) Environmental, Social and Gender Specialists at PIU

(iii) Environmental and Social Development Specialist at D&SC

Apart from the review and revision induced by the suggestions/recommendations received from the
stakeholders, yearly review of the documents considering the evolved situation/available technology or
services options will be conducted by the committee. Revision should be made bi-annually if required, or
annually under regular procedure. Necessary concurrence on the review and revision of ES documents
will be received from the World Bank.

Progress monitoring reports will also be disclosed on the project website, as stated above. If any
discrepancies between the original project status (or any part of it) in the field and the progress reports
are found and notified by any means of communication, the circumstances/ status shall be
communicated by the respective receiving authority with the ES team at PIU, within 3 days of reporting.
Review and relevant revision of progress monitoring reports will be conducted in 2 weeks of reception.

All the revised documents will be posted in the project website, replacing the older versions of the
documents, within 2 weeks of receiving concurrence from the world bank.

Website link of every document (or the project website link) will be posted on the notice boards in LGED
local offices under the project districts and contractor’s site offices as well.

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Table 7.3: Disclosure Requirement of RIVER Project

Project List of documents/ Information  Methods Locations/Time Frame Target stakeholders Responsibilities
stage to be disclosed proposed
Preparation Documentary Disclosure: Project LGED and World Bank As soon as the documents are PAPs and Local Population including VG, LGED/PD
Appraisal Documents including websites, District and prepared, and before project marginalized population and tribal
SEP, ESMF, LMP, ESCP, RPF. Upazila administration appraisal. community; local administration and Project Feasibility team,
website and notice board, local business community, and Communication
Activity dependent Information Sub-Project office at the boatmen; Expert in the field of E&S Specialist /XEN/UE
Dissemination: Project LGED District HQ, matters, Journalists, NGOS/CBOs, etc.
Information relating to activities,
impacts and opportunities, access Social Media including Community Leaders, SMC members,
to GRM, etc. Facebook, mobile SMS, BDRCS volunteers, BWDB Officials,
FGD, KII, meetings etc. potentially project affected persons
(PAPs).
Implementa Documentary Disclosure: Sub- Documents at site offices/ Immediately after producing Community people, workers, PAPs Contractor, XEN/UE/
tion project Specific ESA/ ESMP UE’s office, disclosed on (and revising) the documents. including VG and SEC, Contractors, Social Development
including Gender Action project websites. commuters, including pedestrians and Specialist, D&S
Plan/SEA/SH Prevention and Training/motivation/consultati drivers, homestead owners whose land Consultants,
Response Action Plan/ Code of on meeting once in a month is planned to be raised, farmers, Communication
Conducts (CoCs)/Traffic and other activities as fishermen, boatmen etc. Specialist, District
management plan/ Labor Influx required. Sociologist in
Management Plan (LIMP)/ Community Leaders, SMC members, coordination with local
Community Consultation Plan/ BDRCS volunteers, SMCs, relevant administration
RAP and SECDPF (when stakeholders as identified.
Required)/ GRM leaflets/ All
progress and monitoring reports. Presents in meeting,
Signboard/posters at the
Activity dependent Information subproject sites,
Dissemination: Consultation, Brochures/leaflets,
meetings and regular on-the-job engaging safety workers,
training on the above topics. community consultation,
FGD, KII.

Operation Standard Operational Manual Formulation of Formulation of SOM before the PAPs, Community Leaders, SMC UNO/XEN/UE/District
(SOM) for Resilient Shelters, documents, preparing implementation is done, and members, BDRCS volunteers, Sociologist,
Traffic management along the Brochures and organizing placed at SMC offices; and Community at the sub-projects, NGOs, Communication
access roads. FGD, KIIs, and public other works as required/ daily. local elected leadership etc. Specialist, local
consultation. administration.

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CHAPTER 8: INSTITUTIONAL FRAMEWORK AND CAPACITY BUILDING

8.1 Project Implementation Arrangements
The Government will have overall responsibility for project implementation and management through
its Ministry of Local Government, Cooperatives and Rural Development (MoLGRD&C) and the Local
Government Engineering Department (LGED) will be responsible for implementing the project under
the ministry. LGED will implement the project through a dedicated Dhaka-based PIU, headed by a
Project Director (PD). The PD will be supported by a dedicated Deputy Project Director (DPD), Senior
Assistant Engineer, Assistant Engineer as well as the associated technical and E&S support staff. A
majority of the implementation will be based on the district and upazila levels, where the associated
LGED field officials (i.e., Executive Engineer, Sr. Assistant Engineer, Assistant Engineer, Sub assistant
Engineer etc.) will act as the focal person(s) responsible for supervision and monitoring of work
implementation in their respective districts and upazilas. The Project will have these LGED officials
dedicated for the Project approved by the manpower committee of Ministry of Finance. To the extent
possible, all staff will be expected to serve for the duration of the project in order to ensure consistent
implementation of the project. Following the Government’s Rules of Business, the PIU will report to
the respective Ministerial Project Steering Committee (PSC).
The PSC will be chaired by the Sr. Secretary/Secretary, LGD, MoLGRD&C and will include
representatives from ministries, division, departments/agencies that are part of overall
implementation, coordination, and strategy. PSC will be responsible for: (i) providing implementation
advice and operational guidance; (ii) reviewing financial and physical progress; (iii) resolving any
implementation problems (iv) providing any other necessary direction for effective implementation.
PSC will meet at least every six months.
Project implementation agency will have a Project Implementation Committee (PIC), chaired by the
head of the agency (CE of LGED), which will assist in the supervision of project components. The PIC is
expected to include relevant representatives from ministries, division, departments/agencies. The PIC
will ensure that implementation follows both Government and Bank rules and regulations.
Specifically, the PIC will be responsible for: (i) supervising and reviewing implementation and
providing necessary advice for timely delivery; (ii) monitoring and evaluating implementation progress
and suggesting necessary course corrections; (iii) resolving issues and conflicts that may emerge
during implementation; (iv) facilitation coordination and convergence with other line ministries,
division, and departments/agencies; and (v) keeping the PSC apprised on overall performance and key
issues relating to the project.
This PIU will be strengthened to implement the proposed Project. Therefore, it will hire a , Senior
Environment Specialist, Senior Social Development Specialist, and a Gender Specialist, to complement
its capacity in dealing with project ES issues. The E&S Specialists at PIU are responsible for overall
coordination, supervision and monitoring of environmental and social issues under the project. They
will also review and endorse the screening documents, training documents, support in ESMP
implementation, finalizing the specifications to be adopted in bidding/ contract documents and
provide guidance to the supporting consulting firms in upholding the ESMF and other ES documents.
The specialists will provide technical advice to the Project Director in all ES issues under the project
purview, including management of contractual obligations on ES instruments.
The LGED will hire and use the design and supervision consultancy (D&S) services of international
/national firm through competitive selection in engineering surveys, designs, environmental and social
assessments of subprojects, and preparation of ESMPs, along with RAP (if required) including data
collection and construction supervision including quality assurance, preparation of bidding documents
and final certification of quantity and quality compliance of works completed by the contractors. As
part of the activities of the safeguards team Environment Specialists of D&S consultants will conduct

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the site specific IEEs (where applicable) along with ESMPs. If additional environmental assessment is
necessary, LGED will take necessary steps for carrying out the assessment (e.g., through hiring a
Consultant). The cost of the environmental mitigation measures will be estimated and included in the
bill of quantities. The contractors will be assigned for implementation of these environmental
mitigation measures. The Social Development Specialist of Safeguards team of the D&SC will carry out
social screening, social impact assessment and prepare SMP and where applicable RAP for the
implementation before civil works construction. Preparation of bidding documents for the project
interventions incorporating special considerations in safeguards issues will also be undertaken by
D&SC firm.
A Monitoring and Evaluation (M&E) firm will assist LGED in monitoring project impacts and supervising
the implementation of the social and environmental compliance. Separate firms will also support
LGED for the activities related to environment and social safeguard and community participation. The
PIU support staff will comprise experts in environment and social safeguards, gender, procurement
and financial Management, GIS and other as necessary. More comprehensive roles of M&E firm is
articulated in the given ToR in Annex-J.
Contractor’s role and responsibilities commence at the tender preparation stage and continue until all
monitoring responsibilities end, which may extend beyond the construction phase. To facilitate
environmental and social management plan (ESMP) implementation, the contractors must be
prepared during the tendering and preconstruction phase to cooperate with PIU, D&SC and the local
population in the mitigation of impacts. Contractors will play a vital role in this project to ensure that
environmental and social risks and impacts are minimized effectively. They also play an important role
in ensuring adequate health and safety measures are put in place not only for their workers but also
for the surrounding communities.
Contractors have a duty to ensure that their activities do not cause significant and irreversible damage
to the environment they are working in and have the responsibilities to ensure that social risks and
impacts are managed adequately. They will make sure that no social conflict arises due to engagement
of labors and engage labors within the local communities as much as possible during construction. All
necessary measures, as specified in the Screening Form and/or ESMP, should be followed and
monitoring measures put in place. Special care needs to be taken during pre-construction and
construction phases when heavy machinery and equipment are used. Also, felling of trees or removal
of vegetation need to be carefully managed through consultation with the local communities. Specific
management plans, e.g. drainage management, traffic management, emergency preparedness and
response, etc. need to be prepared by the Contractor prior to commencing any physical works. In
addition, the Contractors need to ensure that proper induction and training is given to all of their
workers. A full-time, on-site ESHS Specialist by the contractor will be required for sub-projects working
in/near particularly sensitive environmental sites. Proper signage and fencing need to be used at all
times.

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Figure 8.1: Project Implementation Arrangements

Contractors employed during operation & maintenance as well as decommissioning phases have
similar roles and responsibilities of social aspects as described above. However, experience suggests
that contractors may have little interest in dealing with environmental and social problems in the
absence of performance-related criteria. Therefore, the contractor will be required (with the
assistance of the PIU) to update the draft site-specific ESMPs prepared by the D&SC during detailed
design phase. PIU environment and social specialists will monitor the safeguard related activities
including working conditions of the labors on a regular basis and clearances for payments to the
contractors will include certification from the D&SC as to the effective implementation of the ESMPs
and all other mitigation measures specified in the ESMP. The completion of implementation of
mitigation measures will therefore be linked to payment schedules.
Contractors, with active support of the PIU, need to ensure that the Grievance Redress Mechanism is
effective so that potential conflicts are avoided and claims by affected people are addressed in a
genuine manner.

8.2 Other Relevant Institutions in Implementation Arrangements

The progress in environmental and social due diligence within the project framework goes in parallel
with successful running of the project, and therefore couple of other organizations beyond the
umbrella of executing agency constitutes the roles of inevitable stakeholders in implementation
arrangements, which may continue throughout the various stages of the proposed project activities.
In this relation, the key responsible Government institutions are Department of Environment (DoE),
Ministry of Primary and Mass Education (MoPME) and Ministry of Planning (MoP) and so on.

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The table below presents a summary of key responsibilities of major government institutions who are
involved in different capacities for environmental protection and compliance along with project
implementation and progress.
Table 8.1: Institutional Responsibilities, Environmental Protection and Compliance
Institution Responsibilities related to the project implementation and compliance
Planning  Project Evaluation Committee (PEC) hosted at Planning Commission evaluates the
Commission, and project DPP and if evaluated positively, the DPP is forward to the ECNEC (Executive
Ministry of Committee of the National Economic Council) under the Chair of Prime Minister for
Planning and final approval for final approval of the project.
Ministry of Finance  ERD (Economic Relations Division) of Ministry of Finance and IMED
(Implementation Monitoring and Evaluation Division) under the Ministry of
Planning have a very pivotal role in project approval and progress monitoring and
evaluation.
Department of  With the mandate to Conserve environment and improve environmental standards,
Environment control, mitigate and prevent environmental pollution, DoE is the sole regulatory
(DoE), Ministry of entity of Bangladesh Government to enact environmental legislations and relevant
Environment, instruments against every physical interventions within the territory of the country.
Forest and Climate  As such, LGED requires to obtain Environmental Clearance Certificate from DoE
Change before any physical intervention is taken place, and this department has the
authoritative capacity to deny or void the clearance, make punitive actions, or limit
the access to the sites already selected for interventions.
 They may conduct inquiries on pollution of the environment and rendering
direction, guidance and assistance to LGED or PIU in upholding the EMPs or other
requirements delineated in the EMSF/EIA/special instructions by the DoE while ECC
is issued.
Ministry of Primary  LGED will develop approximately 550 school cum flood resilience shelter within the
and Mass selected school compounds that needs a primary regular coordination between two
Education line ministries, as the Ministry of Primary and Mass Education owns all the primary
(MoPME) schools across the country.
 The ministry is also responsible for successfully running the facilities embedded into
the new shelter infrastructure and extending hands to the local authorities for
combating any disaster scenario, whenever the school building is required to refuge
shelter to the local vulnerable population.
Local  LGED’s district and upazila offices are the key agents for the successful
Administration implementation of sub-projects along with attaining the necessary compliance in
(District/Upazila / relation to safeguards implementation, including implementation of ESMPs in the
Union) field.

8.3 Monitoring Mechanism for ESMP Implementation

Monitoring, as such, is required to ensure that the mitigation and enhancement measures are being
properly implemented and at the same time, to determine whether the benefits of these measures
are being realized over time. Monitoring responsibilities lie on all the responsible parties or
institutions directly involved with or oversee the construction works.
There will be several tiers in monitoring framework to ensure the proper implementation of ESMP.
Contractors, throughout the construction or implementation period, must ensure that environmental
and social risks and impacts are minimized effectively while working at sites and adequate health and
safety measures are put in place not only for their workers but also for the surrounding communities.
Contractors’ employed site managers and Environment, Health and Safety Specialist (EHSS or persons
with similar responsibilities) shall take all reasonable steps to protect the environment on and off the

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Site and to avoid damage or nuisance to persons or to the properties belong to public and private
individuals/entities or to different features and establishments, from pollution, noise or other
detrimental causes arising as a consequence of different methods of operation and activities.
Contractor, is thus, responsible for self-monitoring on the implementation of all E&S works, due to
having legal bindings under the contract document with LGED; and EHSS will act on Contractor’s
behalf to abide by every single E&S clauses under the bidding documents. S/he shall instruct as well
as supervise the day-to-day progress of ESMP implementation activities on contractors’ behalf. Apart
from the ESMP implementation, some specific management plans, e.g., drainage management, traffic
management, emergency preparedness and response, etc., whichever required, need to be prepared
by the Contractor and strong supervision for the implementation of those plans is also a part of the
said employees’ responsibilities. As the Contractor’s responsibilities lie in complying all the regulatory
or binding issues under the ES documents (including ESMP) within the purview of the contract, a
monthly compliance report will be sent to the PIU every month from his/her end, which is to be
reviewed and cleared by the E&S Specialists at PIU.
Design and supervision consultants shall stand at the first tier of the monitoring mechanism. When
the contractors are mobilized in the field, safeguards consultants from D&SC firm and the Resident
Engineer will ensure that contractors are adherent with every suggestive measure delineated in ESMP,
on top of the best engineering practices at sites including Occupational Health and Safety (OHS). D&SC
firm will prepare regular monitoring reports based on the findings of stringent supervision and
monitoring on its part.
PIU will have environmental and social specialists who will conduct field visits very frequently (at least
twice in a month). Moreover, Executive Engineer’s office in respective districts and Upazila Engineer’s
offices will play a vital role in upholding the proper monitoring and supervision of civil works and
associated project activities, including social and environmental safeguards in and around the sub-
project sites. Environmental and social specialists of PIU will monitor that all staffs of the contractors
and other counterparts who are involved in project implementation receive both initial and ongoing
environmental and social safeguard awareness and training sufficient to ensure the best practices in
the field. Local Engineers from LGED and PIU safeguards specialists shall ascertain that contractors
cleaning and reclamation works after the decommissioning of sites/ end of construction works are
perfectly done and will also suggest for punitive measures against the contractors if any negligence or
indifference is found in following the ESMP to the fullest effectiveness.
The highest tier in the monitoring system is bestowed upon the respective Ministerial Project Steering
Committee (PSC) chaired by the Sr. Secretary/Secretary, LGD, MoLGRD&C. The PIU, in collaboration
with the PSC, will also ensure that Environmental and social safeguards training are provided to all
Project personnel.
Widespread COVID 19 situations prevailing across the country has put further intense necessity for all
concerned parties to scale up their monitoring frequency and activities in line with the prescribed
guidelines to be followed in the field, camp site, and project offices. Frequent and abrupt visit to the
working sites and labor camps is quite necessary in this crisis period and is strongly suggested.

8.4 Reporting Requirement

Implementation of ESMF/ESMP in the field will be ensured by the Contractors, and D&SC under the
direct guidance of PIU will take care of every efforts to get Contractors and other Field staffs/workers
implementing the same in the field. The PIU environment and social specialists will carry out ESMF
monitoring on behalf of Project Director’s Office to ensure that the mitigation plans are being
effectively implemented, and will conduct field visits on a regular basis. However, The D&SC will
prepare quarterly safeguards progress report to be submitted to the PIU/and World bank. These
reports will summarize the following:

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 Progress in implementing this ESMF and subsequent ESA, ESMP, RAP/ARAP etc.;
 Findings of the monitoring programs, with emphasis on any breaches of the control
standards, action levels or standards of general site management;
 Any emerging issues where information or data collected is substantially different from the
baseline data reported in the Environmental and/or Social Assessment;
 Summary of any complaints by external bodies and actions taken / to be taken; and
 Relevant changes or possible changes in legislation, regulations and international practices.

Additional reporting requirements are summarized in the table below.

Table 8.2: Reporting requirement and responsibilities
Report/Documents Description Prepared By Submitted To Timeline
ICT Based Real time monitoring by all All field level Central Daily (during the
Monitoring field level staffs with worksite staffs and Project Server office hour)
photographs and description consultants/staffs
on field visit
ESHS Reporting Reports on the Environmental, D&SC Project Quarterly within 2
Social, Health and Safety Director weeks of a
(ESHS) performance of the calendar quarter
project, including
implementation of ESCP.
Compliance Compliance monitoring report Environmental Project Monthly (by 10th of
Reporting on ESHS management on each Health and Safety Director, every following
sub-project sites, including Specialists (of through month)
with staff/workers Contractor) Contractors.
management, SEH/SH
management, grievance
response, traffic
management, OHS and CHS
management, safety and
security breach and training
provided to
consultants/staff/workers.
Training Records Register of all trainings and Safeguards Project Within 3 weeks of
capacity building activities consultants at PIU Director any
conducted under the project training/capacity
building activities
Environmental and Status on environmental and M&E Specialist at Project Monthly
Social Screening, Social Screening and survey of D&SC, with Director
Survey and work packages for design support from
Reporting Status of phase Safeguards
work packages consultants
Stakeholder Objective, number and mode Safeguards Project Monthly during the
Meetings/Consultat of consultations as SEP Consultants from Director design period and
ions compliance report D&SC quarterly during
the construction
period.
GRM Records Register of Grievance Received GRC or Project Monthly
and Actions taken Consultants Director
during
construction
period
Incidents/Accidents Prompt notification of any Safeguards Project Initially notify
reporting incident or accident related Consultants from Director within 24 hours of
to the Project which has, or is D≻ with the learning of the
likely to have, a significant help of field level incident or
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adverse effect on the staffs accident. A

environment, the affected detailed report will
communities, the public or be provided within
workers including accidents 96 hours including
that could result in fatalities, classification of
injuries, and incidents of incident.
Gender Based
Violence/Sexual Exploitation
and Abuse/ Sexual
harassment (GBV/SEA/SH),
concerns of COVID-19
infections, serious
mismanagement in handling
waste, security breach, etc.
Specific If the project require to Safeguards Project As Necessary
Management prepare any specific Consultants at Director
Plans/Instruments assessment/management PIU, and D&SC
plans/instruments, under any Safeguards staffs
circumstances, those will be
provided.

8.5 Institutional and Project Capacity Development

8.5.1 Capacity Assessment of LGED
LGED has implemented a good number of projects funded by the World Bank, ADB, JICA, and other
donors. As per the organogram of LGED, circulated in December 2020, a Section or Division for
Environment and Gender is functional under the Human Resource Unit of LGED. Headed by an
Environmental Engineer, equivalent to an Executive Engineer (Senior Level), another Executive
Engineer for Environmental and Gender and an Assistant Engineer (Environment and Gender) are now
running the section. They are the officially responsible for ensuring environmental consideration along
with gender mainstreaming in all of the project activities of the LGED. The following organizational
chart shows the present manning structure in the central environmental and gender unit at LGED.

Human Resource Unit, LGED

Environment and Gender Division

Environmental Engineer
(1 Position)

Executive Engineer
(1 Position)

Assistant Engineer
(1 Position)

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Within the purview of LGED works across the country, majority of the development works are being
implemented under different projects, either government or donor funded. Being one of the largest
government organizations working across every corners of the country, primarily under development
projects, the institutional capacity both in governance and project management capacity has
improved a lot in last several decades. LGED has its own organizational safeguards documents,
training materials, organizational library facilities, quality control and environmental laboratories. It
also has a huge pool of Engineers, consultants, management officials, and so on, though within the
project structure. On the contrary, the optimum development in staffing structure in Environmental
and Social Safeguards is not at expected level, and the organizational instruments are not well
updated for combating new challenges in the ES issues; and these are the fields where LGED needs to
look upon in a fresh way.

8.5.2 Requirement of additional experts

In addition to that, qualified consultants will be recruited by the RIVER-PIU and Contractors in a
temporary basis to provide technical assistance, training and capacity building in the environmental
and social issues. In general, the roles and responsibilities of the environmental and social experts
should be as follows, but not limited to:
Senior Environmental Specialist and Environmental Specialist in PIU. The PIU will have dedicated
Environmental Specialists to ensure implementation of ESMP and other environmental management
responsibilities. They will maintain liaison with WB safeguards team, regulatory agencies, and other
stakeholders during the Project implementation, and advise the PIU on ES issues, challenges and
effective implementation of ESMP. The Specialists will also take active initiatives to establish GRM,
update ES documents, review and preparation of other safeguards documents, monitor construction
activities to ensure that environmental mitigation measures are properly implemented.
Senior Social Development Specialist in PIU. The PIU will have a dedicated Social Specialist to ensure
implementation of ESMP and other social management responsibilities. S/he will maintain liaison with
WB safeguards team, regulatory agencies, and other stakeholders during the Project implementation.
The Specialist will also take active initiatives to establish GRM, update ES documents, monitor
construction activities to ensure that social mitigation measures are properly implemented.
Gender Specialist in PIU. The PIU will have a dedicated Gender Specialist to ensure implementation of
gender safeguard responsibilities. S/he will maintain liaison with WB safeguards team, regulatory
agencies, and other stakeholders during the Project implementation. The Specialist will also monitor
gender aspects associated with construction activities are properly implemented, and take active
initiatives to establish GRM and update relevant ES documents.
Consultants at PIU will always be in continuous engagement with stakeholders and make necessary
steps to review and update of SEP and LMP, periodically.
Contractor’s Environmental Health and Safety Specialists (EHSS) . The construction contractors
should assign a dedicated, adequate qualified and experienced, site-based EHSS at the construction
site. The EHSS will be responsible for implementing various aspects of the ESMP particularly the
mitigation measures to ensure that the environmental and social impacts as well as the health and
safety issues of the construction works remain within acceptable limits. S/he will also be responsible
for implementing SEP, LMP, RPF and ESCP, and conducting environmental and social safeguards
training for the construction crew. The EHSS Supervisor needs to be a graduate preferably in
environmental science/engineering with at least 3 years’ experience in environmental management
and health and safety.

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8.5.3 Training Requirement

Advanced training on environmental and social management and monitoring would be useful for the
engineers of the LGED in successfully implementing environmental and social management. It is also
necessary to provide the basic training for key personnel on regulatory requirements, environmental
impacts, and environmental assessment and management in home or abroad. They can participate in
field based training including the environmental and social impact assessment, screening, scoping,
mitigation and monitoring of existing construction, rehabilitation and maintenance projects under
the LGED.
The training program for LGED Staff shall be based on their expanded functions and new and additional
safeguards areas covered by the World Bank ESF. Hence, a general introduction to the new World Bank
ESF should be a priority, followed by Labor and Working Conditions, Community Health and Safety and
Stakeholder Engagement.

Table 8.3: Capacity Development Support (Training)

Training to be provided Targeted Groups Responsibility Timeline of
Trainings
World Bank’s Environmental and Selected LGED staff, PSC, PIU/D&SC Prior to the start of
Social Framework: PIU, Contractors the Project
Training on ESF and the 10 ESSs activities. (To be
including preparation of ESMF, E&S repeated as
Screening, IEE, and ESMP needed)
Occupational Health and Safety Staff from PIU & District PIU/D&SC Prior to the start of
Personal protection equipment & UZ Offices, Contractors’ the construction
Workplace risk management representatives activities. (To be
Prevention of accidents at work sites repeated as
Health and safety rules needed)
Solid and liquid waste management
Hazardous waste management e.g.,
fueling of vehicles
Preparedness and response to
emergency situations
Awareness campaign on HIV/AIDS
Stakeholder Engagement Project Officials, District PIU Prior to the start of
Stakeholder identification and Sociologists, D&SC field the project
mapping, SEP Implementation Plan, level engineers and activities, and to be
Strategy and measures of Stakeholder consultants, Contractors. repeated once in a
Engagement, Grievance Mechanism year for first 3
and Reporting, Stakeholder years.
Engagement Reporting.
Health Safety and Practices under Project Officials, LGED PIU Prior to the start of
COVID situation XENs and UEs in project the construction
COVID Symptoms and Prevention districts, D&SC engineers activities. (To be
Measures; Construction Worksite and consultants, repeated as
management; Labor recruitment and Contractors. needed)
on the job training; Health Safety
Practices and personal Cleanliness;
Measures and contacts in Emergency
Situations.
Labour and Working Conditions Local officials, PIU Prior to the start of
Terms and conditions of employment Contractors Health Safety the construction
according to national working laws and Officer, Labour Sardars activities. (To be
regulations (Leaders) repeated as
Contractor and sub-contractor codes of needed)
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conduct
Worker’s organizations
Child labour and minimum age
employment rules
Grievance Redress Mechanism Local Government PIU/D&SC Prior to Project
Module, design and production of a Officials, LGED field office effectiveness and
training module addressing the staffs, Civil Society, Local thereafter once
following aspects: Registration and respected persons, and every six months
processing procedure, Grievance Contractors Each session for 1
redress procedure, Documenting and day
processing grievances, Use of the
procedure by different stakeholders
Construction Waste Management: LGED Field level officials, PIU /D&SC Prior to Project
Information about the risks, along with Contractors effectiveness and
health and safety advice, the World thereafter every
Bank Group Environmental Health and three months
Safety Guidelines on managing
construction waste and the relevant Each session for 1
international good practices, day
Basic knowledge about handling
procedures and risk management
Using protective and safety equipment
Information about the waste sorting
process, Safe procedures for managing
waste in dumps, Hazardous waste
management, Refueling procedure
Spillage of soil management
GBV Risk Module LGED officials, PIU/ D&SC Prior to Project
Raising awareness and measures to Contractors Health Safety effectiveness and
prevent and mitigate GBV risks Officer, Labour Sardars thereafter every six
The topics, activities and targeted (Leaders), Local NGOs months
groups will be developed in the GBV
Action Plan including GBV-specific GRM Each session for 2
days
Ancillary trainings on Staff from PIU & District PIU/D&SC and Training of PIU
i) Preparation of RAP and SECDP (if & UZ Offices, Contractors’ M&E Specialist staffs and
required) representatives consultants within 6
ii) GBV/SEA/SH risk in the project and months of
its implementation, need to effectiveness; and
understand and sign Code of prior to the start of
Conduct the construction
iii) Environmental and Social activities for others
compliance monitoring and to be repeated
iv) Efficient use of resources and as required.
prevention of pollution
v) Emergency procedure and response
including emergency reporting, Root
Cause Analysis (RCA) and Safeguard
Corrective Action Plan (SCAP)

8.5.4 Capacity Building Action Plan

Capacity building for environmental and social safeguard management will need to be carried out at
all tiers of the project. At the construction site, D&SC will take the lead in implementing the capacity
building plan, though the contractors will also be responsible to conduct trainings for their own staff
and workers.

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Training shall be imparted, on a regular interval, to the Project and LGED officials and Staff on
Safeguard Issues. There are some other areas, where target inventions are to be made in order to
strengthen the capacity of both LGED as an institution and the project as well.
Table 8.4: Action Plan for Project Capacity Development
Suggested interventions Rationale
1. Project Staffing Individual Consultants at PIU As part of the strengthening of the capacity of
within 2 months from signing the project PIU, certain numbers of individual
of legal agreement in the consultants have to be employed to fill the
Positions of: gaps or adjust the monitoring and supervision
(i) Senior Environmental capacity of the PIU at full swing with superb
Specialist strength.
(ii) Senior Social Development
Specialist
(iii) Gender Specialist

Environmental, Health, and

Safety Specialists (EHSS) to be
recruited by the contractors
within 1 month of the contract
award.
2. Training/Workshops Sated in Training section
3. Technical and Consulting services for Flood shelters and other community
Instrumental Awareness building on infrastructures to be developed/ implemented
Interventions (i) Adaptation Measures in under this project require a community based
the event of flood as a disaster, mobilization and awareness campaign as to
(ii) Sheltering to Flood the interventions, user’s protocol and other
Shelters and its management, adaptive (and cooperative) activities. To
(iii) Community based achieve an expected result, awareness
activities in the event of campaign and community mobilization can be
disasters. adopted through engaging the students of the
selected schools under the project and their
families would be a great choice at first hand.

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