ADB - Camp 4

Initial Environmental Examination
Project No. 52174-001

December 2019
Emergency Assistance Project

ADB Project 52174-001 | Grant 0582-BAN
Construction and operation of 2 integrated waste management and resource recovery

facility with collection system at camp 4 in Ukhia and camp 23 in Teknaf
(EAP/DPHE/W9A)
This Initial Environmental Examination is a document of the borrower. The views expressed herein do
not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be
preliminary in nature.
In preparing any country program or strategy, financing any project, or by making any designation of or
reference to a particular territory or geographic area in this document, the Asian Development Bank does
not intend to make any judgments as to the legal or other status of any territory or area.
November 2019
G0582-BAN: Emergency Assistance Project
Construction and operation of 2 integrated waste management

and resource recovery facility with collection system at camp 4
in Ukhia and camp 23 in Teknaf (EAP/DPHE/W9A)
Prepared by Department of Public Health Engineering for the Asian Development Bank.
Construction and operation of 2 integrated waste management and resource recovery facility with collection system at camp 4 in
Ukhia and camp 23 in Teknaf (EAP/DPHE/W9A)
TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................................ 1

I. INTRODUCTION ............................................................................................................................. 4
A. Background ................................................................................................................................. 4
B. Need for the Project .................................................................................................................... 4
C. Impact and Outcome ............................................................................................................... 4
D. Outputs .................................................................................................................................... 4
E. Subproject ................................................................................................................................... 5
F. Objectives and Scope of the Report ........................................................................................... 6
G. IEE Methodology ..................................................................................................................... 6
H. Structure of the Report ............................................................................................................ 6
II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ............................................................ 8
A. Introduction.................................................................................................................................. 8
B. Environmental Legislation Framework ........................................................................................ 8
1. Overview of the Project Approval Process .............................................................................. 8
2. Environmental Approval Framework ....................................................................................... 8
C. National Policies, Laws, Regulations .................................................................................... 10
D. Relevant Occupational Health and Safety Laws and Rules ................................................. 13
E. Conventions, Treaties and Protocols ........................................................................................ 14
F. Environmental Categorization and Standards .......................................................................... 14
1. Environmental Category: Bangladesh .................................................................................. 14
2. ADB Safeguard Policy (ADB Safeguards Policy Statement, 2009) ...................................... 15
G. Institutional Capacity ............................................................................................................. 16
III. DESCRIPTION OF THE PROJECT.......................................................................................... 17
A. Need for the Subproject ............................................................................................................ 17
B. Subproject Scope ...................................................................................................................... 17
C. The Study Area ..................................................................................................................... 17
D. Current State of Waste Management in the Camp ............................................................... 19
E. Description of the Proposed Integrated Waste Management System ...................................... 20
1. Facilities of the Proposed Integrated Landfill with Resource Recovery Facility ................... 21
2. Faecal Sludge Treatment Process in Camp 4 Extension ..................................................... 25
3. Proposed Solid Waste Management Facility in Camp 23 ..................................................... 26
F. Implementation Schedule .......................................................................................................... 28
IV. DESCRIPTION OF THE ENVIRONMENT ................................................................................ 29
A. Physical Environment ................................................................................................................ 29
1. Topography and Geomorphology ......................................................................................... 29
2. Geology ................................................................................................................................. 29
3. Soil ........................................................................................................................................ 29
4. Climate and Meteorology ...................................................................................................... 30
5. Natural Disasters ................................................................................................................... 32
6. Seismicity .............................................................................................................................. 33
7. Flooding, Water Logging and Drainage Pattern.................................................................... 34
8. Hydrology and Water Resources .......................................................................................... 35
9. Air Quality and Dust .............................................................................................................. 38
10. Noise Level........................................................................................................................ 38
B. Biological Environment .............................................................................................................. 38
1. Diversity of Floral and Faunal Species ................................................................................. 38
2. Fisheries ................................................................................................................................ 40
3. Asian Elephants .................................................................................................................... 40
4. Protected Areas .................................................................................................................... 41
C. Socio-economic Environment ............................................................................................... 42
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1. Population ............................................................................................................................. 42
2. Occupation ............................................................................................................................ 43
3. Income and Expenditure ....................................................................................................... 44
4. Land Use ............................................................................................................................... 44
5. Education .............................................................................................................................. 45
6. Healthcare Facility ................................................................................................................. 46
7. Sanitation .............................................................................................................................. 46
8. Energy ................................................................................................................................... 46
9. Physical and Cultural Heritage .............................................................................................. 46
V. ANALYSIS OF ALTERNATIVES................................................................................................... 47
A. No Project Scenario .................................................................................................................. 47
B. Site Evaluation .......................................................................................................................... 47
1. Site Selection Criteria ............................................................................................................ 47
C. Technology Alternatives ........................................................................................................ 48
1. Option 1: Biomethanation...................................................................................................... 48
2. Option 2: Incineration ............................................................................................................ 48
3. Option 3: Composting ........................................................................................................... 48
4. Option 4: Vermicomposting ................................................................................................... 49
VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES ..................... 51
A. Project Boundaries .................................................................................................................... 51
B. Impact Assessment ................................................................................................................... 51
1. Methodology .......................................................................................................................... 51
2. Summary of Impacts ............................................................................................................. 52
3. Positive Impacts Expected from the Proposed Subproject ................................................... 55
4. Screening Out Areas of No Significant Impact...................................................................... 55
5. Anticipated Impacts and Mitigation Measures during Pre-Construction Phase .................... 55
6. Anticipated Impacts and Mitigation Measures during Construction Phase ........................... 57
7. Anticipated Impacts and mitigation Measures during Operation Phase ............................... 62
C. Potential Cumulative Impacts................................................................................................ 63
1. Current and Future Development Projects ........................................................................... 64
2. Identification of Cumulative Impacts ..................................................................................... 66
VII. ENVIRONMENTAL MANAGEMENT PLAN .............................................................................. 69
A. Objective of the EMP ................................................................................................................ 69
B. Environmental Monitoring Plan ................................................................................................. 69
C. Components to be Monitored ................................................................................................ 70
D. Contractor’s Environmental Management Plan .................................................................... 70
E. Institutional Arrangement and Responsibilities ......................................................................... 97
1. Oversight Body ...................................................................................................................... 97
2. Executing and Implementing Agencies ................................................................................. 97
3. Project Management Unit and Project Implementation Unit ................................................. 97
4. Design and Supervision Consultants (DSC) ......................................................................... 97
5. Civil Works Contracts and Contractors ................................................................................. 97
F. Capacity Building ...................................................................................................................... 98
G. Environmental Costs ............................................................................................................. 98
H. Monitoring and Reporting .................................................................................................... 101
VIII. GRIEVENCE REDRESS MACHANISM ................................................................................. 103
A. First Level of GRM .................................................................................................................. 103
B. Second Level of GRM ............................................................................................................. 103
C. Third Level of GRM ............................................................................................................. 103
IX. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION ........................... 105
A. Stakeholder Consultation ........................................................................................................ 105
1. Stakeholder Consultation Strategy for Emergency Assistance Project .............................. 105
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B. Key Target Stakeholders......................................................................................................... 105

C. Consultation and Disclosure to Date ................................................................................... 105
D. Findings of the Public Consultation ..................................................................................... 106
E. Future Stakeholder Consultation ............................................................................................ 107
F. Information Disclosure ............................................................................................................ 107
X. CONCLUSION AND RECOMMENDATION ............................................................................... 108
XI. REFERENCES ........................................................................................................................ 109
ANNEX 1: RAPID ENVIRONMENTAL ASSESSMENT (REA) CHECKLIST (SOLID WASTE
MANAGEMENT) ................................................................................................................................. 110
ANNEX 2: LIST OF ATTENDEES OF THE PUBLIC CONSULTATION ............................................. 114
ANNEX 3: LIST OF WILDLIFE (MAMMALS, BIRDS, REPTILES AND AMPHIBIANS) RECORDED IN
THE SUBPROJECT AREA ................................................................................................................. 116
ANNEX 4: LIST OF HIGHER PLANTS (MAMMALS, BIRDS, REPTILES AND AMPHIBIANS)
RECORDED IN THE SUBPROJECT AREA ....................................................................................... 118
ANNEX 5: IUCN GUIDELINE FOR PLANTATION IN THE CAMP ..................................................... 120
LIST OF TABLES
Table II.1: Required Permissions for Project under Bangladesh Legislation ........................................ 10
Table II.2: Summary of Environmental Legislations Applicable to the Proposed Project ..................... 11
Table II.3: occupational and health related rules .................................................................................. 13
Table II.4: International Environmental Conventions relevant to the project activities ......................... 14
Table II.5: Categorization of Subproject Components .......................................................................... 15
Table III.1: Land requirement for the integrated waste treatment facility .............................................. 21
Table IV.1: Rohingya volunteer incentive rates recommended by RRRC ............................................ 44
Table V.1: Rationale for site selection .................................................................................................. 47
Table V.2: Evaluation of alternate options ............................................................................................ 49
Table VI.1: Parameters for Determining Magnitude ............................................................................. 51
Table VI.2: Criteria for Determining Sensitivity ..................................................................................... 52
Table VI.3: Significance of Impact Criteria ............................................................................................ 52
Table VI.4: Summary of the potential impacts of the subproject .......................................................... 53
Table VI.5: Fields in which the subproject is not expected to have significant impacts........................ 55
Table VI.6: Anticipated Impacts and Mitigation Measures – Pre-Construction Phase ......................... 55
Table VI.7: Anticipated Impacts and Mitigation Measures – Construction Phase ................................ 58
Table VI.8: Anticipated Impacts and Mitigation Measures – O&M Phase ............................................ 62
Table VI.9: Potential to contribute to cumulative impacts ..................................................................... 67
Table VII.1: Environmental Management and Monitoring Plan – Pre Construction, Construction and
O&M Phase ........................................................................................................................................... 72
Table VII.2: Environmental Management and Monitoring Plan- Pre Construction, Construction and O&M
Phase for Camp 23 in Shamlapur ......................................................................................................... 86
Table VII.3: Indicative Capacity Building and Training Program on EMP ............................................. 98
Table VII.4: Cost Estimates to Implement the EMP .............................................................................. 99
Table IX.1: Summary of consultation outcomes ................................................................................. 106
LIST OF FIGURES
Figure I.1: Subproject location map ........................................................................................................ 5
Figure II.1: Environmental approval framework ...................................................................................... 9
Figure III.1: Location map of the integrated waste management facility in camp 4 .............................. 17
Figure III.2: Location of IWMF in camp 4 ext. showing surrounding features ....................................... 18
Figure III.3: Location map of the solid waste management facility in camp 23 .................................... 19
Figure III.4: Faecal collection and transportation system in the camp .................................................. 20
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Figure III.5: Existing status of solid waste management ....................................................................... 20

Figure III.6: Mass balance showing solid waste and faecal sludge management process .................. 21
Figure III.7: Layout Plan of the integrated waste treatment facility for camp 4 ext. .............................. 22
Figure III.8: Cross section of the landfill ................................................................................................ 23
Figure III.9: Typical section of the leachate collection pond showing impermeable lining with patent
stone brick flat soling ............................................................................................................................ 23
Figure III.10: Process flow of a typical compost plant ........................................................................... 24
Figure III.11: Plan view of drying bed and effluent tank ........................................................................ 25
Figure III.12: Schematic of faecal sludge flow at proposed FSTP in camp 4 ext. ................................ 26
Figure III.13: Proposed solid waste management system for camp 23 ................................................ 27
Figure III.14: Plan for composting bin and RCC base .......................................................................... 27
Figure III.15: Plan for composting maturing and recyclable storage shed ............................................ 28
Figure IV.1: Elevation and general soil map of Bangladesh ................................................................. 30
Figure IV.2: Monthly average maximum, minimum and mean temperature ......................................... 30
Figure IV.3: Average monthly rainfall .................................................................................................... 31
Figure IV.4: Monthly evaporation values ............................................................................................... 31
Figure IV.5: Monthly average wind speed ............................................................................................. 32
Figure IV.6: Wind rose diagram of the subproject area ........................................................................ 32
Figure IV.7: Hazard calendar for subproject area ................................................................................. 33
Figure IV.8 Earthquake zone around the subproject ............................................................................ 34
Figure IV.9: Watercourse runs through the subproject area ................................................................. 35
Figure IV.10: Floods risk map for camp 23 ........................................................................................... 35
Figure IV.11: Stream network in the Kutupalong area .......................................................................... 36
Figure IV.12: Monkhali river along Camp 23 in Shamlapur .................................................................. 36
Figure IV.13: Groundwater sources in the subproject area .................................................................. 37
Figure IV.14: Percentage of contaminated source and household-level samples................................ 37
Figure IV.15: Floral species around camp 4 ext. .................................................................................. 39
Figure IV.16: Floral species in camp 23 ................................................................................................ 39
Figure IV.17: Faunal species around the subproject area .................................................................... 40
Figure IV.18: Fish species around the subproject area ........................................................................ 40
Figure IV.19: Elephant watchtower in the camp ................................................................................... 41
Figure IV.20: Human-elephant conflict map around camp area ........................................................... 41
Figure IV.21: Protected areas of Bangladesh ....................................................................................... 42
Figure IV.22: Refugee camp sites by population .................................................................................. 43
Figure IV.23: Main sources of income of the HHs in the subproject area ............................................ 43
Figure IV.24: Land cover maps for the subproject area ........................................................................ 45
Figure IV.25: Land use at camp 23 in Shamlapur ................................................................................ 45
Figure VIII.1: Grievance redress process ........................................................................................... 104
Figure IX.1: Public consultation held at camp 4 in Kutupalong, Ukhia ............................................... 106
Figure IX.2: Public consultation held at Camp 23 in Shamplapur, Teknaf ......................................... 106
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ABBREVIATIONS
ADB Asian Development Bank
BREB Bangladesh Rural Electrification Board
BMD Bangladesh Meteorological Department
BoQ Bill of Quantities
CEMP Contractor’s Environmental Management Plan
DOE Department of Environment
DEWATS Decentralized Wastewater Treatment System
DPHE Department of Public Health Engineering
DSC Design and Supervision Consultancy
EA Executing Agency
EAP Emergency Assistance Project
EARF Environmental Assessment And Review Framework
ECA Environmental Conservation Act
ECC Environmental Clearance Certificate
ECR Environmental Conservation Rules
EIA Environmental Impact Assessment
EMP Environmental Management Plan
FD Forest Department
FGD Focus Group Discussion
FSTP Faecal Sludge Treatment Plant
GoB Government of Bangladesh
GRM Grievance Redress Mechanism
IA Implementing Agency
IEE Initial Environmental Examination
IUCN International Union for Conservation of Nature
ISCG Inter Sector Coordination Group
IWMF Integrated Waste Management Facility
H&S Health And Safety
LGED Local Government Engineering Department
MLGRD&C Ministry of Local Government, Rural Development and Cooperatives
MOEFCC Ministry of Environment, Forest and Climate Change
NGO Non-governmental Organization
NOC No Objection Certificate
O&M Operation & Maintenance
PIU Project Implementing Unit
REA Rapid Environmental Assessment
RHD Roads and Highways
RRRC The Refugee Relief And Repatriation Commission
SCC Site Clearance Certificate
SPS Safeguards Policy Statement
ToR Terms of Reference
UN United Nations
UNDP United Nations Development Programme
UNHCR United Nations High Commissioner for Refugees
WB World Bank
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EXECUTIVE SUMMARY
1 The Emergency Assistance Project is proposed by the Government of Bangladesh from a grant
from Asian Development Bank to provide high-priority basic infrastructure and essential services to help
address the humanitarian crisis caused by the arrival of the displaced persons from Myanmar. The Project
is aligned to accelerate the social recovery of affected persons in Teknaf and Ukhia sub-districts. The
project will improve the living conditions and the resilience of displaced persons. Moreover, it will directly
benefit the lives of people in camps while co-benefitting host communities in some instances. Under this
subproject Integrated Waste Management Facility (IWMF) component is designed to safe disposal of both
solid and faecal wastes by using decentralized wastewater treatment system which will improve the health
of displaced persons and the environment.
2 In accordance with ADB Safeguard Policy Statement (SPS), 2009, an initial screening was
conducted using ADB’s Rapid Environmental Assessment (REA) checklist for waste management (Annex
1). Result of the screening and assessment reveal that the subproject is unlikely to cause significant
adverse environmental impact. Thus, the subproject is categorized as category B for environment as per
ADB SPS, 2009. In addition, the assessment was also carried out within the policy, legal, and
administrative frameworks relevant to waste management projects in Bangladesh.
3 The subproject scope includes construction and operation of integrated waste management facility
having total solid waste management capacity of 3 tons per day (including recyclable waste) and dried
fecal sludge of 1.75 tons per day. The facility is designed for beneficiary of 25,000 population or 78% of
the population live in camp 4 ext. On the other hand, intervention in camp 23 for SWM is designed for
beneficiary of 9900 population or 100% of the population having total solid waste management capacity of
1.1 tons per day.
4 The proposed subproject is envisaged to be constructed at camp 4 in Ukhia and camp 23 in

Shamlapur, Teknaf which is situated south of Cox’s Bazar and borders with the Rakhine state in Myanmar.
The subproject area is on the Pleistocene formations and have a Dupi Tila formation and soils of the Dupi
Tila formations were formed on unconsolidated and compact rocks, moderately well to excessively drained
and probably the oldest of the area. The climate of the subproject area is tropical and characterized by a
change of four, pre-monsoon (March to May); monsoon (June to September); post-monsoon (October to
November); and the dry season (December to February).
5 Kutupalong-Balukhali mega camp including camp 4 is located outside of the flood zone but the
camp is vulnerable to extreme weather events such as cyclones and have to withstand major precipitation
and strong winds. The steep slopes may become unstable in the monsoon seasons and cause landslides,
shelter damage and other destruction. It has limited sources of surface water where the main water sources
such as the Naf River and other big channels are at some distance and are saline and brackish especially
in the lower part of the rivers. Himchari national park is located about 15 km away from the camp area.
6 However, camp 23 is located on flatter land along the Monkhali river beside the coast, making it
prone to riverine flooding in monsoon in addition to tidal surge during low atmospheric pressure. Teknaf
Wildlife Sanctuary is located on the east of Shamlapur and encompasses an area of 11,615 hectares.
7 Various alternatives were examined prior to arriving at a decision making regarding establishment
of proposed subproject. The proposed site has therefore been chosen for setting up of the IWMF because
of its accessibility, proximity to camp areas and the location in less populated area. The technology to be
adopted for the proposed facility was decided on the basis of quality, quantity and characteristics of waste
to be processed, land availability (limited in the area), the most feasible technology option recommended
for the IWMF is composting for processing of bio-degradable organic waste.
8 Total twenty-eight parameters are likely to be affected by the project implementation. Adverse
environmental impacts during construction are temporary, less than significant, and can be easily mitigated.
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The proposed IWMF will be established in Rohingya camp, therefore no land acquisition issue may arise.
However, for government land, a NOC must be taken from Cox’s Bazar DC office and/or RRRC.
9 Potential impacts were identified in relation to design, construction and operation of the integrated
waste management system. During construction phase, impacts mainly arise from excavation, waste
management, dust, noise and health and safety risk to workers and community. These are common
temporary impacts of construction, and there are well developed methods for their mitigation. Mitigation
measures have been developed to reduce all potential negative impacts to acceptable levels.
10 In the operational phase, the facilities will operate with routine maintenance, which should not
affect the environment. Facilities will need to be repaired from time to time, but environmental impacts will
be much less than those of the construction period as the work will be infrequent, affecting small areas
only. During operation phase, the potential adverse environmental impacts are mainly related to the health
and safety risk to workers, water pollution, odour and abnormal or malfunctioning of the IWMF which can
be minimized by the mitigating measures.
11 An environmental management plan (EMP) is developed to effectively manage any environmental

issues arising from the subproject implementation. The EMP includes: (i) mitigating measures to be
implemented, (ii) required monitoring associated with the mitigating measures, and (iii) implementation
arrangement. The institutional set-up and arrangement identifies the requirements, responsible
stakeholders and responsibilities during pre-construction, construction, and operation phases. The EMP
applicable for each phase is presented in detail in tabular form with specific information on: (i) required
measures for each environmental impact that requires mitigation, (ii) locations where the measures apply,
(iii) associated cost, and (iv) responsibility for implementing the measures and monitoring.
12 Mitigation measures have been developed to reduce all negative impacts to acceptable levels.
Mitigation will be assured by a program of environmental monitoring to be conducted during construction.
The environmental monitoring program will ensure that all measures are implemented, and will determine
whether the environment is protected as intended. It will include observations on- and off-site, document
checks, and interviews with workers and beneficiaries. Any requirements for corrective action will be
reported to the ADB. The PMU and supervision consultant will be responsible for monitoring. The PMU will
submit semi-annual monitoring reports to ADB. ADB will post the environmental monitoring reports on its
website.
13 The stakeholders were involved in developing the IEE through public consultation, after which
views expressed were incorporated into the IEE. The IEE will be made available at public locations in the
construction site and will be disclosed to a wider audience via the ADB websites. The consultation process
will be continued and expanded during project implementation to ensure that stakeholders are fully
engaged in the subproject and have the opportunity to participate in its development and implementation.
A grievance redress mechanism is described within the IEE to ensure any public grievances are addressed
quickly.
14 The subproject will have overall positive impacts with some negative effects. Most of these
negative impacts are mainly construction related and can be mitigated by the successful implementation
of the EMP. Therefore, the EMP shall be made binding on all contractors operating on the site, and will be
included in the contractual clauses. Moreover, DPHE have fully endorsed the EMP and committed to
implement all the mitigation measures and also ensure that the work is carried out in an environmentally
acceptable manner and the monitoring and reporting are completed in a compliant and timely fashion,
acceptable to ADB.
15 As per Government of Bangladesh ECA, 1995 and ECR, 1997, the sub-project is categorized as
“red”; thus LCC and ECC must be obtained from DoE. On the other hand, based on this IEE, the
determination of environment category as “B” in accordance with ADB’s SPS 2009 is confirmed and does
not require further environmental impact assessment.

16 Therefore, it can be concluded that if the subproject is developed following the suggestions given
in the EMP of this IEE, it is our contention that there will be no negative impacts to deter the development
of the subproject.

I. INTRODUCTION
A. Background
1. Bangladesh has received more than 700,000 displaced persons from Myanmar (displaced
persons) since August 2017. These displaced persons, which mostly reached Bangladesh by crossing the
nearby border on foot, joined about 400,000 other displaced persons who had arrived in waves from
Rahkine State earlier. The vast majority of displaced persons who have arrived in Bangladesh are living in
32 camps in Cox’s bazar District, with more than 600,000 living in the Kutupalong–Balukhali mega camp.
The large influx of displaced persons has caused a huge strain on the local people, infrastructure, and
economy. The 2:1 ratio of displaced persons to the local population poses significant challenges to the
food supply, shelter, health, sanitation, water, and other essential services. Although UN agencies and
other donors are providing humanitarian relief such as food, water, medical aid, and temporary shelter, the
existing services are stretched, and large gaps remain.
2. The Government of Bangladesh requested the Asian Development Bank (ADB) on 7 May 2018 for
grant support to provide high-priority basic infrastructure and essential services to help address the
humanitarian crisis caused by the arrival of the displaced persons. The project meets the requirements for
emergency assistance financing.
3. The proposed Emergency Assistance Project will support the Government of Bangladesh in
addressing the immediate and urgent needs of the displaced persons in Cox’s bazar District, as identified
by the United Nations (UN) in its Joint Response Plan (JRP). The project will mainly support the
improvement of water supply and sanitation, disaster risk management, sustainable energy supply, and
access roads.
B. Need for the Project

4. The Emergency Assistance Project is proposed by the Government of Bangladesh from a grant
from Asian Development Bank to provide high-priority basic infrastructure and essential services to help
address the humanitarian crisis caused by the arrival of the displaced persons from Myanmar. The Project
is aligned to accelerate the social recovery of affected persons in Teknaf and Ukhia sub-districts. The
project will improve the living conditions and the resilience of displaced persons. Moreover, it will directly
benefit the lives of people in camps while co-benefitting host communities in some instances. Under this
project integrated waste management component is designed to safe disposal of both solid and faecal
waste by using decentralized wastewater treatment system which will improve the health of displaced
persons and the environment.
C. Impact and Outcome

5. The project is aligned with the following impact: social recovery of displaced persons in Teknaf and
Ukhia camps accelerated. The project will have the following outcome: living conditions and the resilience
of displaced persons improved. The project will directly benefit the lives of people in camps while indirectly
co-benefitting host communities in some instances. ADB is cognizant of sensitivities and potential conflicts
among and within affected communities. These will be addressed through a gender- and socially-inclusive
approach, among others.
D. Outputs
6. The project has the following four outputs:
7. Output 1: Water supply and sanitation improved. This consists of providing the camp areas
with (i) mobile water carriers for the distribution of treated water; (ii) community bathing facilities for women;
(iii) mini piped water supply systems with a production tube well, distribution pipe network, and standpipe
water distribution points; (iv) an integrated waste management facility with collection system; and (v) small
surface water treatment plants.

8. Output 2: Disaster risk management strengthened. This includes constructing in and around
the camp areas (i) multipurpose cyclone shelters with emergency access roads, (ii) food distribution
centers, (iii) hill slope protection and/or toe walls to resist landslides, and (iv) storm water drainage
networks. The project will also provide lightning arresters and support the preparation of gender-sensitive
disaster risk management plans with community-based disaster risk reduction approach.
9. Output 3: Energy sources provided. This includes providing the camp areas with (i) retained
heat cookers; (ii) stand-alone solar powered street lights with solar photovoltaic panels, battery boxes, and
mini grid-connected street lights; and (iii) access to electricity by augmenting substations, distribution lines,
and transformers.
10. Output 4: Access roads improved. This consists of rehabilitating (i) rural roads to connect to
food storage and distribution centers, field hospitals, primary health care centers, and primary education
centers; (ii) emergency access roads to the camp areas; and (iii) existing access roads to and within the
camps and drainage systems. The project also supports resurfacing the road from Cox’s Bazar to Teknaf,
which is the main supply line.
E. Subproject
11. Construction and operation of integrated waste management and resource recovery facility with
collection system at camp 4 at the outskirts of Kutupalong-Balukhali Mega Camp, Ukhia including solid
waste management and resource recovery facility with collection system at camp 23 in Shamlapur, Teknaf.
The camps are situated south of Cox’s Bazar and borders with the Rakhine state in Myanmar. The locations
of the selected camps are shown in the Figure I.1 presented below.
Figure I.1: Subproject location map

F. Objectives and Scope of the Report

12. The project is categorized as category ‘B’ in accordance with ADB’s Safeguard Policy Statement
(SPS), 2009 warranting an initial environmental examination (IEE). The IEE has been prepared based on
the Environmental Assessment and Review Framework (EARF) endorsed by Bangladesh Government.
The IEE also follows the guidelines of the Department of Environment (DoE) as required by the
Environmental Conservation Rule (ECR) 1997 (amended 2002) and in accordance with the Safeguard
Policy Statement 2009 (SPS 2009) of ADB and will be disclosed in the websites of the ADB and the
implementing agencies. This document shall serve as the base of environmental assessment of the
proposed sub-project to be implemented by the executing agency and guideline for environmental
management activities on-site.
13. The IEE study has four basic objectives; (i) identify the environmental issues that should be taken
into account due to project interventions (ii) determine the magnitude of potential environmental concerns
and to ensure that environmental considerations are given adequate weight at planning/design stage (iii)
identify need for further environmental studies or Environmental Impact Assessment (EIA) and (iv) suggest
enhancement measures, if any.
14. The Scope of works will include:
 Describe the project and its components.

 Determination of the environmental baseline conditions of the project considering the existing and
proposed interventions.
 Assessment of the environmental impacts of the proposed interventions.
 Preparation of an EMP integrating the adaptation and mitigation measures, scaling-up measures
and an environmental monitoring plan.
 Specify the monitoring and reporting requirements. Moreover, IEE is to ensure, in line with EARF,
that the subproject, in the entirety of its project cycle, will not deteriorate or interfere with the
environmental sensitivity of the project area, but rather improve environmental quality.
G. IEE Methodology
15. This IEE report has been prepared on the basis of EARF, field investigations and stakeholder
consultations to meet the requirements for environmental assessment process and documentation as per
ADB’s Safeguard Policy Statement (SPS), 2009. IEE commenced with the review of legal requirements for
the project. In next step, technical details were collected compiled by a discussion with the implementing
agency to reconfirm the technical details.
16. Scoping of issues to be addressed in the IEE was conducted early in the assessment process (i.e.
Field visit) to collect the appropriate baseline information so that collected and the IEE report/study can
focused on the relevant issues needed.
H. Structure of the Report

17. The report has been structured in compliance with ADB SPS 2009.
Executive Summary
Chapter 1 - Introduction: Presents a brief overview of the assignment along with its background, objectives,
scope of work and methodology etc.
Chapter 2 - Legislative, Regulatory and Policy Consideration: Outlines the Policy and Legislation on
environmental issues.
Chapter 3 - Project Description: Describes the proposed interventions including background, project
category, need for the project, location, size and magnitude of operation.

Chapter 4 - Description of the Environment: Presents a description of the environmental baseline condition
(socioeconomic, physical and biological) of the project area.
Chapter 5 - Analysis of Alternative: Analyzes the environmental situation “With and Without project”.
Chapter 6 - Anticipated Potential Project Impacts: Deals with environmental parameters are identified,
predicted the impact and formulate the mitigation measures need to be taken for reducing impact.
Chapter 7 - Environmental Management Plan and Environmental Monitoring Plan: Mainly deals with the
environmental management plan. However, Deals with the indicator to be monitored during construction
and operation as well as frequency of monitoring. Moreover, outlines the environmental monitoring
program, institutional responsibilities including the cost of implementing the EMP.
Chapter 8 - Grievance Redress Mechanism describes the process of addressing complaints.
Chapter 9 - Public Consultation and Information Disclosure: Discusses the issues raised during the
consultations, proposed actions to address them, and the information needed to disclose to the public.
Chapter 10 - Conclusion and Recommendations: It presents the findings, conclusion and

recommendations of the IEE study.

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK
A. Introduction
18. The Government of Bangladesh (GoB) has developed a complete legal framework, including laws,
regulations, decrees, and standards addressing environmental safeguards for promoting ecologically
sustainable development through the conservation and ecologically sustainable use of natural resources.
It is not limited to the Environmental conservation law. Rather, other laws, regulations and policies have
also acknowledged related environmental responsibilities. Of the existing legal framework, those most
relevant to this subproject are summarized in this chapter.
B. Environmental Legislation Framework
1. Overview of the Project Approval Process

19. Key legislation governing the environmental approvals process for the proposed Project is the
Bangladesh Environmental Conservation Act, 1995 (BECA, 1995) and the Environmental Conservation
Rules (ECR, 1997).
20. According to Rule 7 of the ECR, proposed developments within Bangladesh are classified as one
of four categories, as follows:
 Green;
 Orange A;
 Orange B; and
 Red
21. These categories define proposed developments according to their potential environmental
impact. Section 12 of the ECA states that ‘No industrial unit or project shall be established or undertaken
without obtaining an Environmental Clearance Certificate from the Director General, in the manner
prescribed by the Rules’.
2. Environmental Approval Framework

22. Key milestones in the approvals process are outlined in Figure II.1. These comprise:
 Project Authorization Letter: Formal authorization of the Project by the Department of Public
Health and Engineering is required in order for the environmental approvals process to formally
commence.
 No Objection Certificate (NOC): A NOC must be received from the Deputy Commissioner in the
sub-project area before the SCC application can be made.
 Site Clearance Certificate (SCC): An SCC will be issued by DoE upon approval of the IEE study
(note that the IEE submission is to include the Project Authorization Letter, NOC and SCC
application form). The SCC will include a ToR for the IEE/EIA study, and typically provides
authorization for site establishment works to commence.
 Environmental Clearance Certificate (ECC): The ECC will be issued by DoE upon approval of
the IEE/EIA study (including associated EMP). The ECC allows project construction to commence,
and contains specific approvals requirements for matters such as pollution control and
environmental monitoring.

Figure II.1: Environmental approval framework

23. Table II.1 provides an overview of key Bangladesh legislative approvals requirements which are
relevant to the Project, and the permissions required under this legislation in order to undertake the
subproject works.

Table II.1: Required Permissions for Project under Bangladesh Legislation

Permission
Legislation Purpose Permission Given By
Required
Environment
DoE will issue an SCC to allow for a
Conservation Act (1995)
detailed EIA as per Section 12 (ECA), Director General of the
Environment SCC and ECC Rule- 7 and Form -3 of the ECR. Bangladesh DoE
Conservation Rules
(1997)
Acquisition and
Requisition of To acquire and compensate for any Ministry of Land and
Application required
Immovable Property Act Project land Deputy Commissioner
(1982)
24. Rule 7 of ECR indicates the procedure and requirements for the issuance of an ECC. The
corresponding requirements per category are described below:
 Green category projects:

i. completed application for ECC, and the appropriate fee (shown in Schedule 13);
ii. general information about the project;
iii. exact description of the raw materials to be used, and the product to be manufactured (where
relevant); and
iv. No-objection certificate from the local authority.
 Orange-A category projects:

25. Same requirements as green category projects, plus the following:
i. process flow diagram;
ii. layout plan (showing location of effluent treatment plant or ETP);
iii. effluent discharge arrangement; and
iv. outlines of the plan for relocation and rehabilitation (if applicable).
 Orange-B category projects:
i. completed Application for ECC, and the appropriate fee;
ii. report on the feasibility of the project;
iii. report on the IEE for the project, plus process flow diagram, and in the case of an industrial
project, layout plan (showing ETP) and ETP design;
iv. report on the environmental management plan (EMP);
v. no objection certificate from the local authority;
vi. emergency plan relating to adverse environmental impact and plan for mitigation of the effect
of pollution; and
vii. outline of the relocation and rehabilitation plan (where applicable).
 Red category projects:
26. Same requirements as Orange Category B, except that Item 3 (IEE) is amended to read as follows:
i. report on the IEE for the project, and terms of reference for the EIA; or EIA report prepared
based on ToR previously approved by DOE;
ii. in the case of an industrial project, layout plan showing location of ETP, process flow
diagram, design, and time schedule of the ETP.
C. National Policies, Laws, Regulations

27. The Government of Bangladesh (GoB) has developed a complete legal framework, including laws,
regulations, decrees, and standards addressing environmental and social safeguards for promoting
ecologically sustainable development through the conservation and ecologically sustainable use of natural
resources. It is not limited to the Environmental conservation law. Rather, other laws, regulations and
Initial Environmental Examination 10 | P a g e

policies have also acknowledged related environmental responsibilities. Of the existing legal framework,
those most relevant to this subproject are summarized in the Table II.2.
Table II.2: Summary of Environmental Legislations Applicable to the Proposed Project
Environmental Responsible
No. Objective Relevance to the Project
Legislation / Act Institution
1 National Ensure that development Restriction on operations Ministry of
Environmental components do not pollute the which cannot be initiated in Environment and
Policy, 1992 environment or degrade ecological critical areas Forests, and
resources. It sets out the basic Climate Change
framework for environmental Regulation on vehicles
action together with a set of broad emitting smoke which is
sectoral action guidelines. harmful to the environment
Follow standards on quality

of air, water, noise and soil
Sets limits for discharging

and emitting waste
2 National An action plan to identify key Sectoral agencies to Ministry of
Environmental environmental issues affecting coordinate with MoEFCC in Environment and
Management Bangladesh, identifies actions for preparing environmental Forests, and
Action Plan reducing the rate of guidelines. Climate Change
(NEMAP), 1995 environmental degradation and
improve quality of life.
3 Environment Establishment of Environment Option to affected persons Ministry of
Court Act, 2000 Court for trial of an offence or for for grievances related to Environment and
and subsequent compensation under environment safeguards. Forests, and
amendments in environmental law, such as Climate Change
2003 environment pollution.
4 The Forest Act An act to control trespassing, Requires clearances for any Department of
(1927) and Forest illegal resource extraction and project within forest areas Forests
(Amendment) Act provide a framework for the and clearances for any
(2000) forestry revenue collection felling, extraction, and
system; transport of forest produce.
5 National Forest To conserve existing forests and Incorporate tree planting in Department of
Policy (1994) bring about 20% of the country’s the subproject Forests
land area under the Forestation
Programme and increase Clearance for any felling,
reserved forests by 10% per year extraction, and transport of
until 2015 forest produce
6 The Bangladesh To conserve and protect wildlife Consultation and necessary Department of
Wildlife in Bangladesh including permits required if the Forests
(Conservation & designation of protected areas. project will pass through the
Security) Act, Protection of wildlife is provided wildlife sanctuaries and
2012 with lists of species with four other protected areas.
schedules: first, second, third and
fourth schedule. The fourth
schedule species have the
highest level of protection.
7 National Safe Ensures access to safe water and Pourashavas and water Ministry of Local
Drinking Water sanitation services at an sanitation authorities will Government, Rural
Supply and affordable cost take actions to prevent Development, and
Sanitation Policy wastage of water. They will Cooperatives
of 1998 take necessary steps to
increase public awareness
to prevent misuse of water
Pourashavas shall be
responsible for solid waste
collection, disposal and their
management
8 National Water Ensures Bangladesh water Secure clearance certificate Ministry of Water
Act 2013 sources are free from any type of on water resource Resources
pollution. Pollution from water in development subprojects
urban outfalls and reservoirs, e.g.
lakes, canals, ponds and ditches

may result in amenity losses,
fisheries depletion, health
problems and fish and aquatic
species contamination.
9 Wetland Advocates protection against In case of diversion of water Ministry of Water
Protection Act degradation and resuscitation of from Naf river, detailed Resources
2000 natural water-bodies such as assessment will be done
lakes, ponds, beels1, khals,
tanks, etc. affected by man-made
interventions or other causes.
Prevents the filling of publicly-
owned water bodies and
depressions in urban areas for
preservation of the natural
aquifers and environment.
Prevents unplanned construction
on riverbanks and indiscriminate
clearance of vegetation on newly
accreted land.
10 Bangladesh Labor It is a comprehensive law Compliance to provisions on Ministry of Labor
Law, 2006 covering labour issues such as: employment standards, and Employment
conditions of service and occupational health and
employment, youth employment, safety, welfare and social
benefits including maternal protection, labor relations
benefits, compensation for and social dialogue, and
injuries, trade unions and enforcement.
industrial relations, disputes,
participation of workers in Prohibition of employment
company’s profits, regulation of of children and adolescents.
safety of dock workers, penalty
procedures, administration and
inspection.
This Act pertains to the
occupational rights and safety of
factory workers and the provision
of a comfortable environment for
working. It also includes rules on
registration of labourers,
misconduct rules, income and
benefits, health and fire safety,
factory plan
11 Bangladesh Labor Includes rules on registration of Contractors to implement Department of
Rules, 2015 laborers, misconduct rules, occupational health and Labor
income and benefits, health and safety measures
fire safety, factory plan
Contractor will be liable for
compensation for work-
related injuries
12 The Pourashava Provides guidance for subproject Coordinate with Pourashava Local Authorities
Act 2009 / integrated community and committees on disaster
Ordinance issued workers health and hygiene at the management measures,
for the construction and operation and water and sanitation and
amendment of maintenance stages of the waste management
local government project
(municipality)
ordinance, 2009
and 2010; The
Pourashava
Ordinance, 1977;
Municipal
1 A beel is a billabong or a lake-like wetland with static water (as opposed to moving water in rivers and canals -
typically called khaals), in the Ganges - Brahmaputra flood plains of the Eastern Indian states of West Bengal, and
Assam and in the country of Bangladesh.

Administration
Ordinance, 1960
13 Bangladesh Enhances the capacity of Integrate adaptation Ministry of
Climate Change government ministries, civil measures for buildings in Environment,
Strategy and society and private sector to meet consideration of extreme Forests and
Action Plan of the challenges of climate change climatic events Climate Change
2009
14 Building Regulates technical details of Follow specifications to Ministry of Housing
Construction building construction and to ensure structural integrity of and Public Works
(Amendment) Act maintain standards of building buildings
and Building construction
Construction
Rules,
Bangladesh
National Building
Code
15 Electricity Act, Requires compensation for any Secure permission to supply Ministry of Power,
1910 and damage, detriment or energy and lay down or Energy and Mineral
Electricity Rules inconvenience caused by the place electricity supply lines Resources
1937 project; Requires precautionary for the conveyance and
measures in laying down transmission of electricity
electricity supply lines near or from respective authorities
where any metallic substance or prior to any works
line crosses to avoid
electrocution Give full compensation for
any damage, detriment or
inconvenience caused by
him or by anyone employed
by him
Take precautions in laying

down electricity supply lines
near or where any metallic
substance or line crosses in
order to avoid electrocution
16 The National Ensures environmentally sound Public and private sector Ministry of Power,
Energy Policy sustainable energy development participation in the Energy and Mineral
(1996 and programs causing minimum development and Resources
Updated 2004) damage to the environment, to management of the energy
encourage public and private subprojects.
sector participation in the
development and management Provides guidelines for
of the energy sector and to bring renewable energy
the entire country under subprojects
electrification.
17 National Disaster Establishes a framework for Setting-up emergency Ministry of Disaster
Management Act managing disasters in a response procedures and Relief
of 2012 comprehensive way.
D. Relevant Occupational Health and Safety Laws and Rules

28. During construction, the subproject will conform to the occupational and health related rules as
outlined in the Table II.3 below.
Table II.3: occupational and health related rules
Title of Laws and Rules Descriptions

Social Security under the Act, According to the Act social impact assessment includes the processes of analyzing,
1923 and an amendment in 1980 monitoring and managing the intended and unintended social consequences, both
positive and negative of planned interventions (policies, programs, plans, projects)
and any social change processes invoked by those interventions.

Title of Laws and Rules Descriptions

Bangladesh Labor Law of 2006 - Compliance to the provisions on employment standards, occupational safety and
health, welfare and social protection, labor relations and social dialogue, and
enforcement
- Prohibition of employment of children and adolescent
The Employer's Liability Act, 1938 The Act declares that the doctrine of common employment and of assumed risk shall
not be raised as a defense in suits for damages in respect of employment injuries.
Under the Maternity Benefit Act, 1939, the Maternity Benefit Act, 1950, the Mines
Maternity Benefit Act, 1941, and finally the rules framed thereunder, female
employees are entitled to various benefits for maternity, but in practice they enjoy
leave of 6 weeks before and 6 weeks after delivery.
Public Health (Emergency The ordinance calls for special provisions with regard to public health. Whereas an
Provisions) Ordinance, 1994 emergency has arisen, it is necessary to make special provision for preventing the
spread of human disease, safeguarding public health and providing them adequate
medical service and other services essential to the health of respective community
and workers in particular during the construction related work.
The Employees State Insurance It has to be noted that health, injury and sickness benefit should be paid to people,
Act, 1948 particularly respective workers at work place under the Act.
Bangladesh Factory Act, 1979 The Act requires every workplace including small or large scale construction where
women are employed to have an arrangement of childcare services. Based on this
Act and Labor Laws - medical facilities, first aid and accident and emergency
arrangements are to be provided by the authority to the workers at workplaces.
Water Supply and Sewerage The Act specify WASA’s responsibility to develop and manage water supply and
Authority Act, 1996 sewerage systems for the public health and environmental conservation.
E. Conventions, Treaties and Protocols

29. Bangladesh has consented to be bound by the terms of some 21 of the 44 principal international
conventions, treaties and protocols relating to the environment (Islam, 1996). Those with partial and indirect
relevance to industrial projects are the Paris convention of 1972 concerning the protection of the World
cultural and natural Heritage, Convention concerning safety in the use of chemicals at work, Geneva 1990,
Biodiversity convention, Rio-de-Janeiro, 1992, Convention concerning occupational health services,
Geneva 1985 etc.
Table II.4: International Environmental Conventions relevant to the project activities
Ratified/
Conventions Signed Accessed (AC)/ Relevance
Accepted (AT)
1 International Plant Protection 01.09.1978 Ensures that component work or
Convention (Rome, 1951) & Plant 04.12.1974 (AC) construction materials do not introduce
Protection Agreement for SE Asia plant pests
and Pacific (1999 Revision)
2 Convention on Wetlands of 20.04.1992 Protection of significant wetland and
International Importance, 1971 (ratified) prevention of draining or filling during
(Ramsar Convention) construction
3 Convention Concerning the 03.11.1983 Prevention of damage or destruction of
Protection of World Cultural and (ratified) culturally and/or historically significant
Natural Heritage (Paris, 1972) sites, monuments, etc.
4 Convention on Biological 05.06.1992 03.05.1994 Protection of biodiversity during
Diversity, 1992 (Rio de Janeiro) construction and operation.
5 Convention on Persistent Organic 23.05.2001 In process Restriction of use of pesticides and
Pollutants, 2001 herbicides
6 United Nations Framework 11.12.1997 22.10.2001 Reduce greenhouse gas concentrations
Convention on Climate Change, 13.11.2003 in the atmosphere to a level that would
1997 (amended) prevent dangerous anthropogenic
interference with the climate system
F. Environmental Categorization and Standards
1. Environmental Category: Bangladesh

30. For the purpose of issuance of Environmental Clearance Certificate, the industrial units and
projects shall, in consideration of their site and impact on the environment, be classified into the following

four categories: (a) Green; (b) Orange – A; (c) Orange – B; and (d) Red. The Industries and projects
included in the various categories are specified in sub-rule (1) have been described in Schedule – 1. The
ECR indicates that all industrial units or projects must obtain a Location Clearance Certificate (LCC) and
Environmental Clearance Certificate (ECC) from the Department of Environment (DoE). No industrial unit
or project shall be established or undertaken without obtaining environmental clearance from DoE in the
manner prescribed by the rules.
31. The environmental category of the sub-project is listed in Schedule – 1 of ECR. As per Schedule
1 of ECR, integrated waste management subproject is likely to be classified as Red Category (Table II.5).
Thus, LCC and ECC should be obtained by DPHE from DoE prior to commencement of the subproject.
Table II.5: Categorization of Subproject Components
Equivalent in Schedule I of DoE
Subproject Component
ECR Classification
Construction and  Solid waste management and resource  Land-filling by industrial,
operation of recovery facility with collection system. household and commercial
Red
integrated waste  Faecal sludge management system. wastes; and
management  Sewage treatment plant.
2. ADB Safeguard Policy (ADB Safeguards Policy Statement, 2009)

32. ADB The Safeguards Policy Statement (SPS 2009) of ADB provides guidance on the environment
category of projects based on the degree of anticipated environmental impacts. ADB environmental
safeguards objectives are: (i) to ensure the environmental soundness and sustainability of projects and (ii)
to support the integration of environmental considerations into the project decision-making process. ADB
environmental safeguards are triggered if a project is likely to have potential environmental risks and
impacts. The initial process of categorization involves filling out a sectoral Rapid Environmental
Assessment (REA) checklist. A project is classified as one of the four environmental categories (A, B, C,
or FI) based on the most environmentally sensitive component. Categories are as follows:
 Category A: Project that is likely to have significant adverse environmental impacts which are
irreversible, diverse, or unprecedented. These impacts may affect an area larger than the sites or
facilities subject to physical works. An environmental impact assessment (EIA), including an
environmental management plan (EMP), is required.
 Category B: Project with potential adverse environmental impacts that are less adverse than those
of category A projects. These impacts are site-specific, few if any of them are irreversible, and in
most cases mitigation measures can be designed more readily than for category A projects. An
initial environmental examination (IEE), including an EMP, is required.
 Category C: Project that is likely to have minimal or no adverse environmental impacts. An EIA or
IEE is not required, although environmental implications need to be reviewed.
 Category FI: Project is classified as category FI if it involves the investment of ADB funds to, or
through, a financial intermediary.
33. The project has been categorized as B for environment under the ADB’s Safeguards Policy
Statement 2009 (SPS).
34. Environmental management plan. An EMP, which addresses the potential impacts and risks
identified by the environmental assessment, shall be prepared. The level of detail and complexity of the
EMP and the priority of the identified measures and actions will be commensurate with the project’s impact
and risks.
35. Public disclosure. ADB will post the safeguard documents on its website as well as disclose
relevant information in accessible manner in local communities:
 for environmental category A projects, draft EIA report at least 120 days before Board
consideration;

 final or updated EIA and/or IEE upon receipt; and

 environmental monitoring reports submitted by the PMU during project implementation upon
receipt.
36. Pollution Prevention and Control Technologies. During the design, construction, and operation
of the project the PMU and PIUs will apply pollution prevention and control technologies and practices
consistent with international good practice, as reflected in internationally recognized standards such as the
World Bank Group’s Environment, Health and Safety Guidelines. These standards contain performance
levels and measures that are normally acceptable and applicable to projects. When Government of
Bangladesh regulations differ from these levels and measures, the PMU and PIUs will achieve whichever
is more stringent. If less stringent levels or measures are appropriate in view of specific project
circumstances, the PMU and PIUs will provide full and detailed justification for any proposed alternatives
that are consistent with the requirements presented in ADB SPS.
G. Institutional Capacity
37. The Refugee Relief and Repatriation Commission (RRRC) is proposed to act as the coordinator
on behalf the government to execute all interventions. RRRC and ADB will conduct regular coordination
meetings involving all Implementing Agencies (IAs), relevant stakeholders including deputy commissioner
(DC), Cox’s Bazar, other development partners and agencies. ADB plans to establish extended mission
office in Cox’s Bazar for close coordination, facilitation of sub-projects development and implementation.
A steering committee comprising higher officials from relevant ministries coordinated by ERD will be formed
to provide necessary guidance to expedite the sub-project development and implementation. The steering
committee will have a safeguards focal person.
38. The Local Government Engineering Department (LGED), the Department of Public Health
Engineering (DPHE), the Roads and Highways Department (RHD), and the Bangladesh Rural
Electrification Board (BREB) will be the executing agencies and implementing agencies. responsible for
project oversight and coordination. There will be a safeguards focal person in the EA/IA. The EA/IA will be
assisted by PMCs. The EAs/IAs will form project implementation units (PIU). The PIUs will identify a focal
person for environmental safeguards. The focal person will be assisted in the conduct of the environmental
assessment, the development and implementation of EMPs, and compliance monitoring by project
consultants. All the implementing agencies are currently implementing ADB projects under this institutional
arrangement (further defined in Section VI). ADB also conducts safeguards training for project executing
and implementing agencies. Thus, the government has sufficient capacity in implementing ADB
requirements and strengthening of capacity, other than through the course of the consultant’s work with
local counterparts, is not required. ADB will continue to conduct capacity building programs during
implementation.

III. DESCRIPTION OF THE PROJECT
A. Need for the Subproject

40. Given the scale and speed of the refugee influx, the need for clean and safe sanitation facilities
has been a constant challenge. Sanitation facilities in the Rohingya camps were mostly created as stop-
gap measures, which would have been enough for temporary residents. Over time waste management
has become a serious concern with high levels of diarrhoea, respiratory infections and skin diseases like
scabies. These are all linked to poor sanitation which is the cause of a large number of deaths and
hospitalizations at one of the world’s mostly dense refugee camps in Bangladesh.
41. In 2018 there were more than 200,000 cases of acute diarrhoea reported in the Cox’s Bazar
camps, according to the WHO and the Ministry of Health and Family Welfare. Under this subproject
Integrated Waste Management Facility (IWMF) component is designed to safe disposal of both solid and
faecal wastes by using decentralized wastewater treatment system which will improve the health of
displaced persons and the environment.
B. Subproject Scope
42. The subproject scope includes construction and operation of integrated waste management facility
having total solid waste management capacity of 3 tons per day (including recyclable waste) and dried
fecal sludge of 1.75 tons per day. The facility is designed for beneficiary of 25,000 population or 78% of
the population live in camp 4. On the other hand, intervention in camp 23 for SWM is designed for
beneficiary of 9900 population or 100% of the population having total solid waste management capacity of
1.1 tons per day.
C. The Study Area

43. The proposed subproject is envisaged to be constructed at camp 4 in Ukhia and camp 23 in
Shamlapur, Teknaf which is situated south of Cox’s Bazar and borders with the Rakhine state in Myanmar.
Cox’s Bazar - Teknaf highway is located to the North of the camp 4 and runs south east. However, camp
23 is bordered by river Monkhali on the north and marine drive on the west. Teknaf Game Reserve is west
of Kutupalong and east of Shamlapur which encompasses an area of 11,615 hectares. The location of the
subproject component is shown in the Figure III.1 and Figure III.2 presented below.
Figure III.1: Location map of the integrated waste management facility in camp 4

Figure III.2: Location of IWMF in camp 4 ext. showing surrounding features

Figure III.3: Location map of the solid waste management facility in camp 23
D. Current State of Waste Management in the Camp

44. Faecal Management. As per UNHCR (2018), “Assessment of waste water quality in Cox’s Bazar
Camps”, generated faecal sludge and characteristics are: Black water generation: 2.5l/c/d; Total solids:
~1-2%; average TS is 1.5%; COD typically: 500 mg/l; BOD typically: 195-210 mg/l.
45. Current systems of sanitation especially faecal sludge management in the camps are not
environmentally sound. At present the FSM treatment system can cover around 200,000 populations. The
largest treatment plant is of 40 cubic meter per day capacity established by UNHCR/Oxfam without any
mechanism for disposal of sludge from the treatment plant. Key features of sanitation system are described
below:
 Access to pits is challenging as there are only a few roads through the camps, much of the
equipment and pit emptying has to be carried by hand using drums on bamboo poles;
 The content of pits is at least 80% water though some estimate it as high as 99% water;
 Space in the camps in limited due to the number of people and topography;
 Currently there are struggles to meet minimum coverage levels (1 toilet for 20 people) and there
is little space to build more latrines.
46. There are a range of FSM technologies being used in the camps:
 Toilet/interface/containment: Twin pits (direct and off set), septic tanks (with drainage field),
direct pits, Emptying and transport: mostly with buckets with manual system, centrifugal water
pump, generator with waste water pump, 'Oxfam' motorized diaphragm sludge pump. Manual
transportation (mostly), sludge transfer tank (5 and 10 m3) in few camps and two vacuum tugs
having capacity of 4000 liters capacity.
 Treatment and reuse/disposal: Planted dewatering beds/vertical flow constructed wetlands
(3m3/day), biogas plants (<1m3/day); Decentralized chemical treatment - lagoon lime treatment
with dewatering bed (3 m3/day), in barrel treatment with gravel bed dewatering (3m3/day), In barrel
treatment with geotextile and gravel bed dewatering (3m3/day); Centralized biological treatment -
Covered lagoons into settling beds and ponds (40m3/day) with no options for treatment of the
sludge from the lagoons; Onsite treatment - Lime stabilization in barrels and subsequent discharge
into shallow tanks.

Figure III.4: Faecal collection and transportation system in the camp

47. Solid Waste Management. There are 33 Rohingya Camps in Cox’s Bazar where 65% of the
camps have some sort of solid waste management initiative, mainly communal waste collection and open
disposal practices. Proper segregation of waste is not practiced within the camps.
48. ADB Consultant Team estimates that, currently, 137 tons of solid waste are generated per day in
the camps (Ukhia - 80 tons per day, Teknaf- 20 tons per day, and in host communities 37 tons per day), or
50,000 tons per year. It is found that 53% of the generated waste is biodegradable or organic in nature,
15% is comprised of recyclables (plastics, paper, and glass), 28% is inert material (soil and sand), and 4%
are rejects.
49. Currently, waste collection and transportation is manual and mainly done by community volunteers
carrying the waste bins from the communal collection points to the open disposal sites. This creates odor
pollution as well as ground and surface water pollution. Open dumping is the most common form of waste
disposal practice in all of the camps, and this produces undesirable effects on public health and the
environment.
50. In general, there is little effort to recycle or recover wastes generated in the camps. However, there
is some effort to collect plastic bottles from the waste stream. The current approach of solid waste
management is based on an end of the pipe solution.
Figure III.5: Existing status of solid waste management
E. Description of the Proposed Integrated Waste Management System

51. ADB is planning its intervention based on Decentralized SWM System with Integrated 3R
Approach based on a closed loop circular approach in camp 4 ext. The reason for this approach is to
minimize the disposal of waste on land using crude dumping method and instead promote recycling and
resource recovery based on the 3R Approach, i.e. reduce, reuse and recycle waste. This approach will

promote source separation of waste at the household level with incentives of cash for trash. Special bins
for source separation of waste shall be provided such as composting bins/barrels, bins for storing the inert
materials, and bins for storing the recyclables. Three types of bins shall be provided to groups of 5-8
households. The source separation program shall be linked with an awareness raising program involving
the NGOs working in the camps with solid waste and sanitation issues.
52. In camp 4 ext., faecal sludge treatment plant comprising of drying beds, trickling filter and polishing
pond has been proposed. Intervention in camp 4 for SWM is designed for beneficiary of 25,000 population
or 78% of the population having total solid waste management capacity of 3 tons per day (including
recyclable waste) and dried faecal sludge of 1.75 tons per day.
Figure III.6: Mass balance showing solid waste and faecal sludge management process
1. Facilities of the Proposed Integrated Landfill with Resource Recovery Facility

53. Land Requirement. The land requirement of 5400m2 has been earmarked for setting up of
proposed project facilities such as FSTP, landfill cell, compost plant, leachate water settlement pond, green
belt, trickling filter, compost drying bed, waste water tank/pond, septic tank and Internal road (H.B.B. road).
The greenbelt development and landscaping activities will be carried out in 40.4% area of the project site.
The overall area breakup for various project components within the proposed project is presented in Table
III.1.
Table III.1: Land requirement for the integrated waste treatment facility
Camp 4
Sl. No. Particulars
(Area in m2)
1 FSTP 254.66
2 Landfill Cell 977.45
3 Compost Plant 505.68
4 Leachate Water Settlement Pond 519.67
5 Green Belt 2186.66
6 Trickling Filter 21.56
7 Compost Drying Bed 48.09
8 Waste Water Tank/Pond 13.6
9 Septic Tank 11.02
10 H.B.B Road (Internal Road) 861.61
Total 5400.00

Figure III.7: Layout Plan of the integrated waste treatment facility for camp 4 ext.
54. Controlled Landfill Cell. The landfill cell will accept only domestic waste from the camps. It will
not accept any clinical or hazardous waste. The landfill site has embankments on three sides and wall on
one side. Design height of the landfill site is 4m from the existing ground level.
55. Stability of the landfill cells is considered with 1:2.5 ratio slope of the cell to avoid excessive
settlement or slippages. The hydraulic uplift pressure on the lining system (due to groundwater) has been
considered during the detailed structural design stage. Daily earth covering/capping system has been
introduced to ensure stability against sliding.
56. Landfill cells are designed considering the proper utilization of the decomposed old waste in the
cell. Considering the volume of each cell, daily incoming waste, and density of waste, the cell will take a
minimum of 7-8 years to be filled up.

Figure III.8: Cross section of the landfill

57. Leachate Management. To reduce leachate generation, control measures have been considered
that will enable minimizing the quantities of precipitation, surface water, and groundwater entering the
landfilled waste. These measures include soil cover and an impermeable material placed at the base.
58. Contaminated water called leachate has been taken into consideration by the inclusion of a proper
drainage system for collection. Leachate collection system has been introduced to ensure that leachate
accumulation at the base of the landfill is kept to a minimum. The leachate system will consist of a leachate
collection pipe network to convey the leachate to a storage and treatment facility, and in-facility treatment
of leachate prior to reuse in the composting cells and spray in the landfills.
Figure III.9: Typical section of the leachate collection pond showing impermeable lining with
patent stone brick flat soling
59. Compost Plant. A compost plant with capacity of 3 tons/day has been proposed at the initial stage.
The earmarked land for the compost plant can accommodate total 7-8 tons/day in future. So, the compost
plant will divert significant portion of the incoming waste for land filling. The facility can utilize significant
portion of organic waste in a cost effective way. This compost plant is designed mainly focuses on `organic
waste’ (fresh organic waste coming mainly from kitchens, restaurants, vegetable markets). Three major
activities are carried out in compost plant which are `collection’ of segregated waste from the source,
`processing’ of waste using aerobic compost technology, `marketing’ of resources produced from waste.
60. In natural environments, the slow decomposition of organic matter by different microorganisms
and invertebrates produces a black-brown earthy material called humus – a valuable component of good
soils. Composting runs along the same lines, but is accelerated by optimised and controlled process
parameters like input material, temperature, moisture, and pH. This distinguishes composting from natural
decomposition. The quality of the input materials and certain biological and physical parameters has a
major influence on the quality of the compost and on the occurrence of operational problems with the
composting facility. A properly constructed compost pile can be compared to an interactive biological and
ecological system. It contains various microorganism’s dependent on the nutritional and environmental

condition of the pile. It is important for composters to understand the physical, chemical and biological
processes involved in the decomposition of biodegradable organic material.
Figure III.10: Process flow of a typical compost plant

61. The solid material is the biodegradable waste, the moisture inside and outside of the waste is the
liquid part and the air in the gaps between the solid particles the gaseous phase. All three constituents play
a key role in the composting process, as the main activity of microorganisms can be observed at the
interfaces of these three phases. Microorganisms can only make use of dissolved nutrients found in the
liquid phase. However, they require oxygen for their metabolism, which they draw from the air in the gaps.
62. Operational and Restoration Requirements. Infrastructural requirements during landfill
operation and restoration have been considered. Landfill cells shall be developed on a phased basis. Site
infrastructure includes the provision of: guard room, site accommodation, weighbridge, waste inspection
area, wheel wash, site services, and security fencing.
63. Internal Road. Considering existing subsoil condition of the proposed site, 300m long and 4.8m
width internal HBB roads are designed to withstand heavy duty vehicles all-round the year, especially
during monsoon season for uninterrupted operation.
64. Visual Appearance and Landscape. Consideration was given to the visual appearance of the
landform during operation, at termination of landfilling, and its impact on the surrounding landforms.
65. Protection for Environmental Nuisances. Special consideration will be taken to minimize and
control nuisances arising from the construction, operation, closure and aftercare phases of the landfill.
Nuisances that may arise from landfilling include: noise, odors, dust, litter, birds, vermin, and fires.

66. An impermeable liner is suggested for the protection of soil, groundwater and surface water. The
liner system will consist of a natural or artificially established clay/mineral layer combined with a geo-
synthetic liner that must meet prescribed permeability and thickness requirements.
67. The accumulation and migration of landfill gas will be controlled. The most effective manner of
managing landfill gas is to collect, treat and utilize it. Considering the cost implications, we have proposed
venting it out.
2. Faecal Sludge Treatment Process in Camp 4 Extension

68. Based on the characteristics of faecal sludge, literature reviews and other significant parameters
of the O& M capacity within the camps, following concept of faecal sludge treatment is proposed:
69. The treatment concept proposed for faecal sludge treatment in camp 4 ext. has been developed
considering mainly-
 Minimum operation and maintenance requirements

 Hygienisation and safe operation
 Maximum treatment efficiency
70. The treatment concept is proposed to treat maximum of 10500 liters (10cu.m) of faecal sludge
every day. The faecal sludge received at the treatment facility using vacuum trucks to be provided by the
project would be treated in various stages using different treatment modules.
71. In the proposed concept, the incoming faecal sludge, flows through a screen chamber and enters
the un-planted drying beds. Here solid liquid separation takes place as the solids get retained on the filter
bed and the liquid percolates through the filter bed and is collected in a settling chamber and anaerobic
filter where it undergoes sedimentation and digestion. The partially treated effluent is further treated in
trickling filter and pond for aerobic treatment before it can be reused for irrigation.
Figure III.11: Plan view of drying bed and effluent tank

72. Unplanted drying bed is also provided to ensure regular availability of sludge for co-composting
with municipal wet organic waste. Unplanted drying beds are mainly filtration units and this module mainly
contributes in removal of moisture content through filtration as well as evaporation. Very minimum amount

of sludge digestion also takes place in the initial period. In the unplanted drying beds, the sludge drying
cycle is approximately 15 to 20 days for removal from the beds depending on the climate conditions,
whereas in the planted drying beds the sludge is removed after 3 years (minimum) from the date of
commissioning of the beds. The roof also may enhance the drying period of sludge due to greenhouse
effect.
73. As the proposed treatment facility is integrated with the solid waste management facility, there is
a provision given for composting wet organic waste collected from the camp. The dried sludge collected
from these beds also can be co-composted to make compost that can be used in agricultural fields.
Figure III.12: Schematic of faecal sludge flow at proposed FSTP in camp 4 ext.
3. Proposed Solid Waste Management Facility in Camp 23

74. It is proposed to establish on-site barrel composting methods at the household level linked with
decentralized composting facility and material recovery facility in Camp 23 (Figure III.13). For household
level composting for a group of 5-8 households, a specially designed barrel composting unit has been
suggested. This requires a very small area and this type of barrel composting unit has very little odor.
Operation and maintenance are very simple and easy.
75. Intervention in camp 23 for SWM is designed for beneficiary of 9900 population or 100% of the
population having total waste management capacity of 1.1 tons per day. It is estimated that around 1.5
tons per day (TPD) of solid waste (SW) is being generated within the camp in Shamlapur. Current practice
of solid waste disposal is open dumping in small pits or in open space. Inadequate collection and
uncontrolled disposal of solid waste cause a serious health hazard to inhabitants and environment of the
camp area. To manage the solid waste, barrel composting will be utilized for treatment of waste collected
from four blocks of the camp. Main objective of this system is to transform organic wastes into compost.

Figure III.13: Proposed solid waste management system for camp 23

76. Barrel Composting: Barrel system can work efficiently for solid waste management in low income
disadvantage people residential areas. It is better to use plastic barrel for this purpose. It is a usual practice
to use 260 Kg capacity plastic barrel for organic solid waste disposal. One composting barrel can be used
by 4-6 families.
Figure III.14: Plan for composting bin and RCC base

77. Barrel for organic household waste should contain sufficient number of bores at the bottom and
the wall. Bores should be of ½ to ¾” diameter so that aerobic bacteria can degrade organic wastes to
compost through microbial activities. Barrel lid should be a bit larger than the opening of the barrel so that
rainwater cannot enter the barrel.
78. Barrel should be placed over a concrete platform. This ring should be of such a size that there is
not much gap left in between the barrel and ring. Sufficient space should also be left in one or both sides
at the bottom of the ring to facilitate proper air circulation.
79. Rainwater should not be allowed to accumulate at the foot of the barrel. Therefore, barrels should
be placed at sufficient elevation. It is better to leave a height of at least 6” between the ground level and
the bottom of the barrel.
80. First wastes should be segregated as organic and inorganic. Organic wastes should be put into
the compost barrel. Inorganic wastes should be kept primarily in a specific box or at a specific place in the
house. After about three months, organic wastes in the compost barrel will be transformed into compost.
Some water may be sprayed over the wastes in the compost barrel, if it is very dry. Usually, there is no
need to apply extra water during the rainy season.

Figure III.15: Plan for composting maturing and recyclable storage shed
F. Implementation Schedule
81. Substantial time is required spanning the continuum of subproject design & estimate, contract
award and contract execution. Efforts needs to be made to meticulously follow the schedule should a timely
implementation of work is aimed at.
82. Normally the construction work season in Bangladesh runs from October through May (eight
months). Construction works are sometimes impeded for the following reasons.
 Early floods in April/May,
 Late floods in September/October,
 Natural calamities (cyclone/tornado, excessive floods) occur in April/May and October/November.
 Normally, the best construction period is only for 6 months a year (October to March). The
construction period is sometimes squeezed to 4 months due to natural calamities.
83. However, sometimes, based on time constraint or exigency, construction work may even need to
be carried out in the monsoon. Besides, whenever possible, simultaneousness of activities can be
ascertained and cashed in on and consequently, quantum of work can be maximized through efficient
planning and adoption of best available practice.
84. Summing up, over a 24-month period, major works are advisable to take place in the first quarter
of 2020.

IV. DESCRIPTION OF THE ENVIRONMENT
A. Physical Environment
1. Topography and Geomorphology

85. Bangladesh is on a relatively young and low-lying area with three main geomorphologic regions:
plains, terraces, and hills. It is geo-morphologically young because of the sedimentary deposition that has
formed much of the land. The plains compose 80% of the country and are highly susceptible to flooding.
Bangladesh’s deltaic coastline is wide near sea-level, with numerous rivers carving through the
sedimentary silt to reach the ocean. There are regions of tertiary hills in both the north-east and south-east
(Imamul Huq and Md. Shoaib J.U, 2013).
86. Both Kutupalong and Shamlapur area inhabited by refugees are situated on a combination of
plains and small hills, extending into the Chittagong Hill tracts bordering Myanmar. Elevation in the focus
area are shown in Figure IV.1. Heavy rain on the Chittagong Hill tracts has resulted in numerous landslides.
District administration has restricted tree-cutting to limit erosion in the hope of limiting further landslides
and related fatalities (Mahmud, 2017).
2. Geology
87. The south eastern part of Bangladesh is part of the geo-synclinal basin (Khan, 1991). In the Cox’s
Bazar District, the geo-synclinal basin is characterized by thick layers of clastic sedimentary rocks, mostly
sandstone and shale of Tertiary age. The entire basin occupies areas of greater Dhaka, Faridpur, Noakhali,
Sylhet, Comilla and Chittagong and the Bay of Bengal. The huge thickness of sediments in the basin
(maximum of about 20 km near the basin center) is a result of tectonic mobility or instability of the areas
causing rapid subsidence and sedimentation in a relatively short span of geologic time and the vast amount
of sediment transported from the Himalaya ridge by the Brahmaputra and Ganges rivers.
88. The geo-synclinal basin is subdivided into two parts, i.e. fold belt in the east and a fore deep to the
west. Around Cox’s Bazar, the fold belt is characterized by folding of the sedimentary layers into a series
of anticlines (upward folds) and synclines (downward fold). The anticlines form the hills and the synclines
form valleys. The intensity of the folding is greater towards the east, causing higher topographic elevation
in the eastern Chittagong hill tracts. The Tertiary sediments of the Surma group, known as the Boka bill
and Bhuban formation, form an important stratigraphic layer in the region. It is composed of monotonous
alternating sandstone, shale, siltstone and some conglomerate. Boka bill and Bhuban are difficult to
distinguish, but where Boka bill is considered shallow marine sediments, recent field studies suggest that
the basal parts of the Upper Bhuban formation are formed in a deep marine turbidite environment. Outcrops
of the Boka Bil and Bhuban formation are present around the study area.
89. The Boka Bill/Bhuban layer is overlain with sandstone sediments from the Tipam group in areas
further north. Around Kutupalong, this layer is present in synclinal folds and acts as an aquifer for drinking
water supply.
3. Soil
90. The soil in the Chittagong region is composed of coarse material and is less mature than the rest
of the coastal areas. Similar to the rest of the coastal region of Bangladesh, the area also contains various
silts, sands, and some clay (Fisheries and Aquaculture Department, 1985). The soils of the Dupi Tila
formations were formed on unconsolidated and compact rocks, moderately well to excessively drained and
probably the oldest of the area.

Figure IV.1: Elevation and general soil map of Bangladesh
4. Climate and Meteorology

91. The climate of the subproject area is tropical and characterized by a change of four, monsoon-
related seasons: pre-monsoon (March to May); monsoon (June to September); post-monsoon (October to
November); and the dry season (December to February). Meteorological data of Cox's Bazar station is
considered for the subproject area as it is located in the close proximity to Cox’s Bazar station.
92. Temperature - The temperature of the country is related to the period of rainfall. In general, cool
seasons coincide with the period of lowest rainfall. The monthly average maximum and minimum
temperature at the Cox’s Bazar station are 29.1oC and 19.9oC respectively. Figure IV.2 show average
mean, maximum and minimum temperature for the last five years (2008 to 2012) at Cox’s Bazar
Meteorological station.
35
30
25
Temperature (oC)
20
Mean Temp (oc)
15 Max Temp (oc)
Min Temp (oc)
10
Figure IV.2: Monthly average maximum, minimum and mean temperature

93. Rainfall - Rainfall varies considerably from year to year and month to month. The highest rainfall
recorded between 2008 and 2012 was in 2012 with peak in June of 1226 mm at Cox’s Bazar Station. The
average rainfall Cox’s Bazar station between 2008 and 2012 was 281.97 mm/month over that five-year
period. However, no rainfall was recorded during the month of November, December and January. Figure
IV.3 shows the average monthly rainfall over the five-year period along the project corridor, with most of
the rainfall between May and August.
1000
900
800
700
Rainfall (mm)
600
500
400
300
200
100
0
Figure IV.3: Average monthly rainfall
94. Evapotranspiration- With maximum daily temperatures of 30 degrees centigrade in April,

evaporation rates are high. The dry season is also the coolest and therefore the evaporation rates in these
months are slightly lower (FAO, 2018). A total potential evaporation of 500 mm during the dry season
should be considered.
Figure IV.4: Monthly evaporation values

95. Relative Humidity - Humidity levels are consistently very high during the monsoon season, and
drop significantly for a relatively short period at the end of the dry season. The 5-yearly average maximum
relative humidity at Cox’s Bazar station was 87% respectively and the average humidity recorded was
77.99%.
96. Wind Speed and Wind Direction - Monthly wind data of Cox’s Bazar station shows that wind
speed is at a maximum in the early part of the monsoon, but drop substantially by the beginning of the dry
season. The monthly average wind speed for Cox’s Bazar station over the last five years (2008-12) are
shown in Figure IV.5, and this pattern is assumed to reflect the conditions of the subproject area.

Wind Speed ( km/h)

4
0
Jan Feb. Mar. Apr. May June July Aug. Sep. Oct. Nov. Dec.
Figure IV.5: Monthly average wind speed
97. Historical wind data (wind speed, wind direction) were collected from Cox’s Bazar station which
suggested that wind blows from south east for 6% of the year, around 9% of the year wind blows from
north-west and south west accordingly, 15% of the year wind blows from north with wind speed between
3-6 km/h (2%) and 6-9 km/h (10%) and 9-12 km/h (3%). About 17% of the year, wind blows from north-
east with wind speed between 3-6 km/h (4%) and 6-9 km/h (13%). Other 44% of the year, wind blows from
south with wind speed between 6-9 km/h (30%), 9-12 km/hr (12%) and 12-15 km/h (2%), wind is highly
variable (Figure IV.6).
Figure IV.6: Wind rose diagram of the subproject area
5. Natural Disasters
98. Bangladesh is vulnerable to floods, flash floods, salinity, storm surges, landslides and earthquakes.
Flooding, mainly in the period from May to October, occurs almost annually and affects most of the country
with the exception of Barind Tract and hilly areas. The western part of the country, including Barind Tract,
is a drought prone area which faces severe problems due to a scarcity of water, particularly during the dry
season. The southern coastal part of Bangladesh is prone to storm surges and soil salinity while the hilly

areas of Bangladesh (Chittagong Hill Tracts, Cox’s Bazar and Teknaf) are vulnerable to landslides (UNDP,
2012).
Figure IV.7: Hazard calendar for subproject area

99. The subproject area has a history of occurrence of earthquakes, flash floods and tidal surges
(Figure IV.6). Since Shamlapur camp is located along the coast, the camps are vulnerable to extreme
weather events such as cyclones and have to withstand major precipitation and strong winds. In general,
neither the structures in the Rohingya camp nor those in the community settlements are able to withstand
cyclones or floods; nearly 70% of shelters in settlements were damaged by Cyclone Mora in May 2017
(ISCG, 2017).
6. Seismicity
100. The subproject area is located in a seismic zone II, referred to as the medium risk zone for
earthquake in the country (Figure IV.8). Seismic events in Bangladesh are relatively infrequent, but
historically, have been severe, such as the earthquakes of 1930, 1950 and 2004. To address any potential
impacts due to seismic activities, provisions of the Bangladesh National Building Code (BNBC) 1993 and
2006 shall be strictly followed.

Figure IV.8 Earthquake zone around the subproject
7. Flooding, Water Logging and Drainage Pattern
101. Cox’s Bazar records heavy rains every year and is one of the most flood prone areas of
Bangladesh. Flash floods (rapid flooding from heavy rains) are the most common type of floods in hilly
southeastern areas of Bangladesh (Shaw et al. 2013). Ramu, Cox’s Bazar Sadar, and Chakaria upazila
generally record the highest number of people affected by floods across Cox’s Bazar district during the
monsoon.
102. Eastern side of Ukhia Upzila comprising high land and gradually down towards the western side.
Several natural streams act as the natural drainage system of the region. The mainland surrounding
Kutupalong is generally high from the level of tide. However, there exist erosion and instability problems in
the hilly and elevated areas.
103. The surface hydrology in camp 4 extension area is regulated by rainfall and runoff from adjacent
uplands and the relief pattern of the plains. The area is interspersed by valleys and gullies and crossed by
several streams which at the eastern side flow to the Naf river. A small stream runs nearby the selected
site for the IWMF has been observed to be seasonal, drying up in the dry season where seasonal
waterlogging has been observed (Figure IV.9).

Figure IV.9: Watercourse runs through the subproject area

104. Shamlapur located on flatter land along the Monkhali river beside the coast, making it prone to
riverine flooding in monsoon in addition to tidal surge during low atmospheric pressure (Figure IV.10). In
May 2018, Hatkhulapara and Purbo Asarbonia in Shamlapur were deemed at risk from flooding/water-
logging which were protected instantly by back filling. Hence highest flood level should be considered in
the design for the SWM.
Figure IV.10: Floods risk map for camp 23
8. Hydrology and Water Resources

105. Surface Water- There are 405 rivers in Bangladesh and 57 of them are transboundary (2030
WRG, 2015). The Ganges, the Brahmaptura, and the Meghna are the three major rivers in the country that
contribute to alluvium deposits. The Kutupalong camp is in the southern part of the Chittagong region
where small rivers flow through the makeshift settlement and expansion regions (Figure IV.11). Main water

sources such as the Naf River and other big channels are at some distance and are saline and brackish
especially in the lower part of the rivers. Fresh water sources are basically pond water and a few small
streams originating from the hills. These ponds and streams are not capable of meeting the water needs
of the population of the makeshift camps, but can be used for domestic purposes if kept clean from sewage
pollution.
106. A study carried out by UNDP Bangladesh and UN Women Bangladesh 2018 on the physical
properties of the water with the assistance of the DoE Cox’s Bazar office. Under the study samples were
taken from up-stream and down-stream of Gondhom Chara, Balukhali Chara, Talipara Chara, Hakimpur
Khal, Palong Khali Khal, Tangkhali Khal and from a number of ponds. Tests were conducted for pH,
dissolved oxygen (DO), total dissolved solids (TDS), electro conductivity (EC) and temperature. Test
findings reveal that some of the streams are becoming devoid of oxygen downstream from the camps. In
some samples, EC was also observed to be high. Uncontrolled open defecation practices along the banks
of the ponds and streams and the sedimentation deposits in the streams are most likely the reasons for
the deteriorating water quality of the available surface water (UNDP Bangladesh and UN WOMEN
Bangladesh, 2018).
Figure IV.11: Stream network in the Kutupalong area

107. Shamlapur camp is located along the coastline in the southern part of the Chittagong region where
a coastal river flows through the settlement and it is the main surface water source which is saline and
brackish. However, drainage system of the camp is directly connected to the river; thus it receives
significant amount of wastes including black water from the camp. Moreover, uncontrolled open defecation
practices along the banks of the river and the sedimentation deposits are most likely the reasons for the
deteriorating water quality of the surface water (Figure IV.12).
Figure IV.12: Monkhali river along Camp 23 in Shamlapur

108. Groundwater- In Bangladesh, surface water and groundwater are used for human resources. The
availability and restoration of both water systems vary depending on the season (2030 WRG, 2015). There
are shallow and deep aquifers on which 97% of the Bangladeshi population depend (NERC, 2001). Smith
et al. (2000) mention that inorganic arsenic occurs naturally in Bangladesh’s groundwater and poses many
threats to the health of humans (Smith, 2000).
109. Camp 4 in Kutupalong depends on the groundwater and uses tube wells to access the resource
(Sikder, 2010). A study by Grant, 2013 found that 38 sampled wells in the Kutupalong area had a pH from
3.9 – 7.73. Water that has a pH less than 5 raises concern for those areas that contain toxic heavy metals
(Grant, 2013). The safety standard for arsenic-contaminated water by WHO is 10μg/L, although the
Government of Bangladesh has a regulation of 50μg/L. Flanagan et al. (2012) found that 45%-62% of
arsenic-related deaths are from drinking water within the 10μg/L and 50μg/L concentration guidelines.
110. Shamlapur also depends on the groundwater and uses tube wells to access the resource. Most of
the shallow tube wells are about 18-30 feet deep in Shamlapur area which are susceptible to contamination
(Figure IV.13). However, the shallow water-level might not be an issue in the Shamlapur as the tube-wells
installed are mostly deep tube-wells, although there might be salinity in the deep-level water of Shamlapur
as it is situated in the coastline.
Figure IV.13: Groundwater sources in the subproject area

111. Six rounds of water quality surveillance were completed from August 2017 to June 20182. Previous
rounds of water quality monitoring have shown high levels of E. Coli contamination of water particularly at
the household level. An increase in contamination proportions was seen in the latest round (June 2018)
during the monsoon season (Figure IV.14).
Figure IV.14: Percentage of contaminated source and household-level samples
2 Health Sector Bulletin #6, Rohingya Crisis in Cox’s Bazar, Bangladesh, September 2018

9. Air Quality and Dust

112. Baseline data on air quality is not available. However, the air quality in the camp has slightly
deteriorated along the Marine drive and LGED roadside areas because of increased traffic. Brick kilns in
Ukhia and Teknaf may also be contributing to the problem. In accordance to the inhabitants, they suffer
from the dust generated from the loose soil when strong winds blow; serious dust pollution during stormy
winds is an issue. From a health point of view, this should not be a great concern as the size of the dust
particles does not allow them to penetrate into the respiratory tract.
113. Indoor air pollution in the camps from cooking is a serious concern especially for women and
children, and has been identified as having a severe impact. All cooking is carried out inside the poorly
ventilated shelters (the only opening in an 8/8 sq. ft. space is a door at the front) and the firewood which is
used as fuel produces large quantities of smoke that stays in the air long after the fire has been
extinguished. Burning firewood releases particulate matters, CO, CO2, and Sulphur oxide which are
extremely dangerous.
10. Noise Level

114. Noise level data is not available for the camp. The major causes for noise in the subproject area
are increased traffic on the Cox’s Bazar-Teknaf highway, Marine drive and LGED road (motor cycles, pick-
up, mini-trucks, CNG rickshaw and auto-rickshaws). The impact of noise generation on the settlements is
not significant as most of the households are at some distance from the road. However, some internal
roads have been constructed to facilitate the connectivity between the camps in Kutupalong, but traffic on
these roads is still very light. Noise is generated at the set times when relief materials are distributed, but
measures introduced by the Bangladesh Army in charge of the distribution of relief materials have kept
noise levels within reasonable limits.
B. Biological Environment
115. South and Southeast Asian countries are recognized by International Union for Conservation of
Nature (IUCN) to be regions of high species diversity. A large number of native plants, including 3,000-
4,000 species of woody flora, have been recorded from Bangladesh. The country lies at the meeting point
(Eco-tonal region) of several floristic provinces, including the Manipur-Khasia, Bengal and North Burma
provinces within the Indo-Malayan realm (IUCN , 2002 ).
1. Diversity of Floral and Faunal Species

116. Flora Species- The forestland in the Ukhia and Teknaf Upazila is covered by tropical evergreen
and semi-evergreen forests dominated by Garjan (Dipterocarpus spp.) occurring in deep valleys and
shaded slopes. Human activities have denuded most parts of the hills which have been re-occupied by
sun-grass, herbs and shrubs. There is a small section of mangrove forest on the coast near Kutupalong
which encompasses a diverse ecosystem, including medicinal plants (BCAS, 2008).
117. The plant species found in Camp 4 are: Akashmoni (Acacia auriculiformis), raintree (Albizia
saman), mango (Mangifera indica), jackfruit (Artocarpus heterophyllus), boroi (Ziziphus mauritiana),
mahogany (Swietenia mahogany), guava (Psidium guajava), banana (Musa sp.), segun (Tectona grandis)
Bokul (Mimusops elengi) and Bamboo (Disambiguation). Sessile joy weed (Alternanthera sessilis), thorny
amaranth (Amaranthus spinosus), bermuda grass (Cynodon dactylon), smartweed (Polygonum sp),
creeping oxalis (Oxalis corniculata), etc., are the common weed species (Figure IV.15 and Annex 4).
Among crop-field vegetation, aman is grown during summer rains and boro (winter rice) cultivated by
irrigation in winter.

Figure IV.15: Floral species around camp 4 ext.

118. Shamlapur camp is located within 2km of Teknaf Wildlife Sanctuary which is rich in flora and
contains several different ecosystems including hill forest, mangrove formation and sand-dune (Uddin et
al. 2013). Feeroz (2013) recorded a total of 538 plant species under 102 families and 370 genera from
TWS.
119. The plant species are recorded in camp 23: Coconut (Cocos nucifera), Betel nut (Areca catechu),
Akashmoni (Acacia auriculiformis), raintree (Albizia saman), mango (Mangifera indica), jackfruit
(Artocarpus heterophyllus), boroi (Ziziphus mauritiana), mahogany (Swietenia mahogany), guava (Psidium
guajava), banana (Musa sp.), segun (Tectona grandis) Bokul (Mimusops elengi) and Bamboo
(Disambiguation). Sessile joy weed (Alternanthera sessilis), thorny amaranth (Amaranthus spinosus),
bermuda grass (Cynodon dactylon), smartweed (Polygonum sp), creeping oxalis (Oxalis corniculata), etc.
are the common weed species (Figure IV.16).
Figure IV.16: Floral species in camp 23

120. Faunal Species- The Refugee camps have a significant impact on wildlife by shrinking habitats
and disruptions in breeding grounds are affecting nocturnal, crepuscular and diurnal wildlife. More than
67% of the mammal wildlife are terrestrial, and of this number, around 63.8% rely on forests as a habitat.
Arboreal species are also under severe threat due to the ever-decreasing natural forest area.
121. Apart from the degradation of forest land along the Refugee camps, it still houses rich biodiversity
including megafauna like the Asian elephant (Elephas maximus) and many different bird species. It has
been confirmed that more than 50% of the country’s wildlife species are living in the forests of Ukhia,
Teknaf, Inani and Himchari under Cox’s Bazar South Forest Division.
122. Common bird species noted in the subproject area were Asian crow, myna, cuckoo, kingfisher,
pigeon and dove satare, drongo, weaver bird choroi, babui, and dahuk (Figure IV.17 and Annex 3). The
mammals include fox, monkey, mongoose, Bengal monitor, various rodents etc. There are also several
species of frog, lizard and snake.

Figure IV.17: Faunal species around the subproject area
2. Fisheries
123. A survey of the Fisheries fauna of the Naaf river estuary in the 1990s recorded 123 fish species,
20 species of shrimp and prawns, 3 species of crabs and 2 species of lobster (Islam, 1993). The dominant
group was represented by a few small sized fishes. Given the close proximity to the sea and the presence
of backwaters, the people in the region are habituated in pisciculture and prawn culture.
Figure IV.18: Fish species around the subproject area

124. Major fishes are listed in the subproject area are bele, bata, telapia, rui, catla, catfish (boal, pangas,
silon, ayeir, and bacha) and snake head (shol, gazar, and taki), freshwater shrimp and several other tropical
whitefish species (Figure IV.18). In contrast, the saltwater species found in the camp are Loittya (Harpadon
nehereus), Ranga choukha (Lutjanus johni), Lal poa (Johnius argentatus), Olua (Coilia dussumieri), Rup
chanda (Stromateus chinensis), Tuna (Euthynnus affinis) and Ilish (Tenualosa ilisha).
3. Asian Elephants
125. The globally endangered Asian Elephant (Elephas maximus) is ‘critically endangered’ in
Bangladesh. Host and Rohingya communities are encroaching on its habitat in the Cox’s Bazar Forest
Division, and both resident and migratory elephants are facing a continuous shrinkage of their habitat and
food supply. There are likely less than 300 animals remaining in the country with about 200 residents (i.e.,
not crossing international borders) and 100-150 having a transboundary range with India and Myanmar,
and about 40,000 animals in the world, with the greatest populations found in Myanmar and India.

126. There is evidence of presence of elephants in

the camp area. This human-elephant conflict has seen
13 refugees killed in elephant attacks since August last
year, according to the International Union for
Conservation of Nature (IUCN). Figure IV.20 presents
a map of recent human-elephant conflicts prepared by
the IUCN.
127. The IUCN has conducted a study on such
conflict and suggested a few mitigation measures to
reduce such conflicts. The IUCN and UNHCR have
formed 30 elephant response teams of 10-12 people in
the camps. They are also setting up 92 elephant
Figure IV.19: Elephant watchtower in the camp
watchtowers, more response teams and training
(Figure IV.19).
Figure IV.20: Human-elephant conflict map around camp area
4. Protected Areas
128. Protected areas (PAs) are “especially dedicated to the protection and maintenance of biological
diversity and associated cultural resources, which are managed through legal or other effective means"
(IUCN, 1994); "designated or regulated and managed to achieve specific conservation objectives"
(Mulongoy & Chape, 2004). Three types of protected areas were defined under the Bangladesh Wildlife
Preservation Act, 1973; i.e. National Park, Wildlife Sanctuary and Game Reserve. Figure IV.21 shows the
protected areas of Bangladesh.
129. Originally designated as Teknaf game reserve in 1983, in December 2009 the Government of
Bangladesh enhanced its status to a Wildlife Sanctuary protecting 11,615 hectares. It is located in Teknaf

Upazila of Cox’s Bazar District, and comprises a range of steep hills aligned north-south and bordered by
the Bay of Bengal to the west and a narrow strip of lowlands and settlements along the Naf river to the
south and east, and Inani reserve forest to the north.
130. The sanctuary is comprised of 10 forest beats under three forest ranges of Cox’s Bazar (south)
Forest Division. It is a hilly mixed-evergreen sub-tropical forest with secondary plantations and covers an
area of 11,615ha with a length of 32km (north-south) and width of 5km at the north end and 3km at the
south end. The area consists of intervals of steep hills and valleys. The moist sub-tropical maritime climate
of the sanctuary has three seasons: spring (March to April), monsoon (May to October) and winter
(November to February; Bari & Dutta 2004). The sanctuary is rich in flora and contains several different
ecosystems including hill forest, mangrove formation and sand-dune (Uddin et al. 2013).
Figure IV.21: Protected areas of Bangladesh
C. Socio-economic Environment
1. Population
131. As of 9 November 2018, the Inter-Sector Coordination Group (ISCG) reported that 620,0001 and
12300 Rohingya refugees have taken shelter in Kutupalong and Shamlapur respectively. According to
ISCG’s rapid needs assessment, 58 per cent of new arrivals are children and 60 per cent are women
including a high number of pregnant (3 percent) and lactating women (7 percent). With the new influx, the
current total number of Rohingya who have fled from Myanmar into Bangladesh, coupled with the affected
population in the communities, has reached a staggering 1.2 million (Figure IV.22). There are 720,000
children among the new arrivals, existing Rohingya populations and vulnerable host communities.

Figure IV.22: Refugee camp sites by population
2. Occupation
132. The key activities carried out by the camp inhabitants in Kutupalong are (i) daily labor; (ii)
dependent on the financial help of GOs/NGOs; (iii) working as a volunteer and a small portion is involved
in the small business such as small tea/ betel leaf shop and small eateries. In Shamlapur, the camp
dwellers are (i) catching fish in the sea and river; (ii) small business such as small tea/ betel leaf shop and
small eateries; (iii) daily labor; and a small portion is dependent on the financial help of GOs/NGOs (Figure
IV.23). In contrast, women often take care of household duties, such as cooking and cleaning, but can also
generate income by weaving net and selling clothing (Akhter, 2017). Some NGOs have employed local
women in cooking and cleaning tasks within the camp.
Figure IV.23: Main sources of income of the HHs in the subproject area

3. Income and Expenditure

133. A guidance recommended by the RRRC is the approach for humanitarian stakeholders working in
Rohingya refugee camps and settlements (Table IV.1). This guidance provides a uniform, harmonized
approach to definitions of refugee volunteer engagement. There are two main ways in which refugees are
engaged in labor the current context: Cash for Work programming, and engaging refugee volunteer labor
to achieve set operational objectives (including unskilled, semi-skilled and skilled volunteers).
Table IV.1: Rohingya volunteer incentive rates recommended by RRRC
Category Criteria and Competencies Current Rate
Cash-for-Work Principles of Cash for Work Programming, including: 350 BDT/day
• Beneficiary selection criteria (usually vulnerability) (Revised April 2018, yet to be
• Days of work predetermined (16 days consecutively, or endorsed by the HCTT. This
32 days scattered over a quarter) amount represents 75% of the
• Predetermined daily flat rate Minimum Expenditure Basket)
Unskilled Unskilled labor engaged to meet operational needs: 50 BDT per hour
Volunteer • Porters
• Physical/construction laborers
• Truck loading/unloading
• Gatekeepers
• General labor e.g. cleaners
Semi-skilled Semi-skilled labor engaged to meet operational needs. Hourly rate (infrequent
Volunteer Requires basic literacy and basic training prior to engagement)
performing the role. BDT 503 – BDT 75 per hour
• Community mobilizers Monthly rate (longer term
• Outreach workers (including community health workers, engagement)
hygiene promoters) BDT 7,2004 – BDT 12,600 per
• Site management assistants month (assumption of 7 hours per
• Enumerators/data collectors (generalists) day, 24 days a month)
134. The rates will also be applied to the contractors taken on by DPHE as well. The guidance should
be incorporated by agencies into contracts at the time they are drawn up.
4. Land Use
135. In most parts of Ukhia, especially in the areas of Kutupalong, land use has completely changed
within a short period of time. Some of the hills have been completely denuded and deforested and the area
is now filled with shelters. Other hills will likely face a similar fate. There are over a million Rohingya who
have so far been sheltered within a few square kilometers of the influx area combining old and new
makeshift camps. However, narrow strip of agricultural land is located in camp 4 area (Figure IV.24).
3
It is noted that the starting incentive for semi-skilled is equivalent to that for unskilled. Unskilled labour is often of a
hard, physical and sometimes dangerous nature, which requires fair remuneration, and therefore, this is not deemed
to be a flaw in the incentive structure. The upper parameter included in the semi-skilled incentive allow for agencies to
pay according to their own determination of complexity and responsibilities.
4 It is noted that the lower end of the band for monthly incentives is lower than the hourly incentive, if multiplied across
the same time worked. This acknowledges the additional benefits of predictability of income in a longer-term
engagement.

Figure IV.24: Land cover maps for the subproject area

136. On the other hand, camp 23 area is mixed of residential zone with homestead forestry and
commercial infrastructures at Shamlapur bazar. Since the study area is located along the coastline thus
the primary land use in this area are salt farming, shrimp cultivation and cultivation of betel nuts and betel
leaf (pan). Fishing is also done using both small to large size boats, as well as without boats on the shore
and in the Monkhali River. The site along the SWM-1 is used for salt production and shrimp cultivation. In
contrast, narrow strip of agricultural land is located adjacent to the SWM site-2 where food crops cultivated
include rice, potato, vegetables etc.
Figure IV.25: Land use at camp 23 in Shamlapur
5. Education
137. UNHCR has been supporting primary and junior secondary education for refugee children born
Kutupalong camp since the early 1990s. As of September 2018, 36,834 children (31%) out of 120,000
children and youth targeted by UNHCR's programs were provided access to learning. In order to increase
the coverage of refugee education, UNHCR and partners has put in place the following: (1) 316 learning
spaces including 5 adolescent clubs set up, (2) 682 teachers (including 329 from host communities)
recruited, trained and deployed, (3) 812 School Management Committee Members mobilized and engaged

to enhance community involvement, (4) 35 Early Childhood Development (ECD) centers set up and 79
facilitators recruited for mobile ECD in 316 locations.
6. Healthcare Facility
138. The health sector maintained the up to date dataset of all health facilities within the camps and the
surrounding areas, including facilities implemented by NGOs and Government. Currently, there are 278
functional facilities known to the health sector, with a further 37 planned or under construction. Based on
the data available, overall coverage meets the minimum requirements. There are an estimated 170 basic
health units (1: 7647 people in need); 33 primary health center facilities (1:39394 people in need) and 10
secondary care facilities (1: 130 000 people in need). Approximately 910 hospital beds are available to the
people in need, of which 290 are in Government run facilities. However, there is an estimated 2 basic
health units (1: 6000 people in need) are available in the camp 23.
7. Sanitation
139. Over 48,000 emergency pit latrines were installed to quickly meet the needs of the affected
population in the camp, out of which an estimated 17% are non-functional. A minimum depth of five feet
for latrine pits has not been met, and they are still often built in close proximity to one another. The number
of latrines located within 10 meters of a water source was over 30% in December. In addition, latrines are
built too close to shelters, on steep slopes, and close to rivers, which are not usable by women, children,
elderly people, or people with disabilities. On the other hand, final disposal and treatment of faecal sludge
is become a major issue due to scarcity of land in the congested camps.
8. Energy
140. Up to now, the dwindling forests around Kutupalong have provided the only source of fuel to cook
with for Rohingya refugees. Currently there is a shortage of natural firewood sources due to the increase
in camp population. It is estimated that 900,000 Rohingya refugees in the Cox’s Bazar area have needed
700 metric tons of wood every day for cooking alone. In the past, there have been initiatives to create
alternate energy sources for the camps, but these have been limited to certain areas and are not sufficient
for the current numbers. A solar based mini grid system is in place, providing indoor lighting and street
lights in different areas. Other alternative fuels which have been used are biogas, compressed rice husk,
and kerosene for lamps (UNHCR, 2017). Moreover, currently more than 200,000 refugee households and
some Bangladeshi host families were provided liquefied petroleum gas (LPG).
9. Physical and Cultural Heritage

141. Within the influence area of the subproject no historical sites were identified. Religious center (such
as Mosques, temples), educational institutions and local bazar bring cultural values to the community
people.

V. ANALYSIS OF ALTERNATIVES
142. The section below presents the rationale for selection of the project site and the proposed waste
treatment technology. Various alternatives were examined prior to arriving at a decision making regarding
establishment of proposed subproject. The following scenarios have been considered:
 Project versus No Project scenario;
 Site evaluation;
 Alternative technology analysis
A. No Project Scenario
143. A ‘no project’ scenario would lead to magnification of the problems related to waste handling and
management, soil quality, water quality, odor & air quality and drainage congestion related issues. It will
also lead to development of unhygienic conditions in the area due to unplanned accumulation of waste and
shall become breeding grounds for mosquitoes. Therefore, it will pose threat to environment and health of
the locals. Hence, this alternative is undesirable as the development will be unplanned and will lack the
basic infrastructure facilities leading to pollution and contamination.
B. Site Evaluation
144. The proposed site has been identified for construction and operation of integrated waste
management and resource recovery facility has been planned to minimize environmental and social
impacts in the present and future.
1. Site Selection Criteria

145. A total of 4 categories of attributes have been chosen for evaluation of the site. The details of the
parameters and the rationale for selection of the site have been provided in Table V.1. The selected
attributes are as follows:
I. Site accessibility;
II. Distance from nearby receptors;
III. Environmental sensitivity; and
IV. Socio-economics;
Table V.1: Rationale for site selection
Justification for
SL. Attribute Parameter Rationale for Site Selection
proposed Site selection
The site should be accessible for The present location is
transportation of waste from the accessible from nearby camps.
1 Road source of generation till the Moreover, 300m long HBB road
selected disposal site. is proposed to construct for
better connectivity to the IWMF.
Accessibility The distance of the selected site The IWMF site is situated within
should not be more than 5km from 100m from the boundary of camp
Distance from main road. Also, the access roads 4 extension and the proposed
2 the collection should not be passing from densely access road will be built along
area populated residential areas. the boundary of the camp
shanties from where wastes to
be collected.
The present usage pattern of the Presently the site is not in use
site should be evaluated in order to and the nearby area is being
Use of site by
3 determine whether the site is in use developed to build the shelter
nearby residents
at present for agriculture/ houses for the Rohingya people.
Distance from
settlements.
nearby receptors
The existing land cover depicts the There is less economic
Land use/ economic importance of the site. importance of the land as it is not
4
zoning The site shall be more suitable for used for agriculture and
setting up of the IWMF if there is residential purpose.

Justification for
SL. Attribute Parameter Rationale for Site Selection
proposed Site selection
less economic importance of the
site.
The acceptance of the people in the The acceptance of RRRC is
Public nearby residential areas plays a obtained for selection of the site.
5
acceptability very important role in setting of the
project.
Environmental Environmentally The selected site should not fall into The proposed site does not fall in
6
sensitivity critical area environmentally critical area. ECA.
There should not be any chronic There is no prevalent chronic
7 Health health diseases in the adjoining disease in the area.
areas due to prevailing air quality.
The technology selection in IWMF An odor control system
Socioeconomics should be such that there shall not comprising of ventilation ducts,
be any odor issues in 2 km radius. exhaust fans will be installed to
8 Odor
collect and treat odor generated
from waste reception pit, sorting
area, composting plant.
146. The proposed site has therefore been chosen for setting up of the IWMF because of its
accessibility, proximity to camp areas and the location in less populated area.
C. Technology Alternatives
147. Various technologies were considered as options for the treatment/ disposal of SWM. These
included:
I. Biomethanation;
II. Incineration;
III. Composting; and
IV. Vermicomposting
1. Option 1: Biomethanation
148. It is a process of biochemical conversion or anaerobic digestion wherein solid wastes (food wastes
free of plastics and ash) with a large proportion of organic matter is subjected to anaerobic decomposition
thereby producing a gaseous mixture of Methane and Carbon dioxide (CH4 & CO2 ) known as biogas
under favorable conditions. This process is quite stable and gives a good performance at detention time of
25 days.
2. Option 2: Incineration
149. Incineration is the process wherein the waste is burned at high temperature. This involves the
combustion of processed waste to generate heat which is supplied to a boiler coupled with a steam turbine
for electricity generation. The thermal conversion efficiency varies from 80-90% and electricity conversion
efficiency is around 14%. Carbon dioxide, water vapor, ash and noncombustible materials will be the end
products. However, it is suitable for wastes with high calorific value, low moisture content and is associated
with risks such as air pollution.
3. Option 3: Composting
150. Aerobic composting is the process of degradation of biodegradable waste matter into simple
organic compound by certain micro-organisms in the presence of air. It requires adequate supply of air,
moisture (50% to 60% optimum), temperature (50 to 60oC for 5 to 7 days), C/N ratio (between 20–40).
Aerobic conversion process is preferable as compared to anaerobic conversion process since it is fast,
exothermic and free from odor. Aerobic process also helps to eliminate pathogenic organisms, weed seeds,
larva etc. as a result of high temperature developed during the process. The turning of waste is done after
approximately 5-7 days to ensure adequate oxygen.

4. Option 4: Vermicomposting
151. Vermicomposting involves the stabilization of organic solid waste through earthworm consumption
which converts the material into worm castings. It is the result of combined activity of microorganisms and
earthworms. The worm species that are commonly considered are Pheretima sp., Eisenia sp. & Perionyx
excavatus sp. These worms are known to survive in the moisture range of 20-80% and the temperature
range of 20-40oC. The worms do not survive in pure organic substrates containing more that 40%
fermentable organic substances. Hence fresh waste is commonly mixed with partially or fully stabilized
waste before it is subjected to vermicomposting. The worms are also known to be adversely affected by
high concentrations of heavy metals.
152. A comparative matrix has been developed to assess the above mentioned waste processing
techniques as given in Table V.2.
Table V.2: Evaluation of alternate options
Treatment Suitable for

Description of technology Advantages Disadvantages
Option waste type
Anaerobic Biomethanation involves Organic bio-  Generated bio gas  The capital cost for
digestion/ segregation of the organic degradable recovered can be used setting up of plant is
Bio-methanation fraction of wastes which is waste for generating power. comparatively higher
fed to a closed container  The digested residue than composting
(biogas digester) where, can be used as a high- techniques.
under anaerobic conditions, grade soil conditioner.  Not suitable for wastes
the organic wastes undergo  Less retention time than containing less
bio-degradation producing aerobic composting. biodegradable matter.
methane rich biogas and  Free from odor, vector,  Waste should be free
effluent/sludge. The biogas rodent and fly menace, from inorganic as well as
production ranges from 50- visible pollution and inert material.
150 m3/ton of wastes, social resistance.  Requires waste
depending upon the  Less land requirement segregation for
composition of waste. than composting improving digestion
techniques. efficiency.
Incineration In Incineration the waste is  Most suitable for high  Least suitable for
burned in presence of air Calorific Value waste, aqueous/ high moisture
(oxygen) at a temperature of pathological wastes, content/ low Calorific
about 800oC and above, and etc. Value and chlorinated
converts the waste into heat  Units with continuous waste.
that can be used to generate feed and high through-  Excessive moisture and
electricity, gases and put can be set up. inert content affects net
particulates of combustion,  Thermal energy energy recovery;
and a smaller amount of solid recovery for direct auxiliary fuel support
residue (ash). heating or power may be required to
generation. sustain combustion
 Relatively noiseless and  Concern for toxic metals
odorless. that may concentrate in
 Low land area ash, emission of
requirement particulates, SOx, NOx,
chlorinated compounds,
ranging from HCl to
Dioxins.
Composting Composting is the Organic bio-  Proven technology;  Process is very slow;
decomposition of organic degradable  Can be done at small  Unsuitable for waste
matter by a mixed microbial waste scale; containing low organic
population in the moist, warm  Production of high material;
and aerobic environment. grade compost which  Land requirement is high
These microorganisms can be used as a soil in comparison to other
convert organic wastes into conditioner as end thermo-chemical and bio
compost or humus, which product; chemical treatment
has significant value to  No hazardous methods.
agriculture farming. emissions produced;
 No major risks involved.

Treatment Suitable for

Description of technology Advantages Disadvantages
Option waste type
Vermicomposting Vermicomposting is a bio- Organic bio-  Can be done at small  Process is very slow,
oxidation and stabilization degradable scale; takes 180- 200 days for
process of organic matter waste  No power requirement; harvesting.
that involves earthworms.  High-grade conditioner  Land requirement is high
The residual material can be is end product. in comparison to
used as soil conditioner. thermos-chemical and
bio-chemical treatment
methods.
 High maintenance.
 Highly sensitive to
temperature.
153. The technology to be adopted for the proposed facility was decided on the basis of quality, quantity
and characteristics of waste to be processed, land availability, proximity to camp areas, the most feasible
technology option recommended for the IWMF is composting for processing of bio-degradable organic
waste.

VI. ANTICIPATED ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

154. This section identifies the overall impacts of subproject activities on the physical, biological and
socio-economic environment of the subproject area. It also narrates the measures that will mitigate the
subproject’s adverse environmental effects.
A. Project Boundaries
155. The area of influence of the subproject covers the whole neighborhood and the road network which
will be linked to the subproject area in the course of transferring equipment, debris and construction
materials during different phases of the subproject. All the locations may be considered to be within
subproject boundaries as it may influence its impacts to these locations.
156. IWM Facility Area. The proposed subproject for construction of IWM facility will require 5400m2
which will receive the most intense physical impacts of the construction works as it is targeted to receive
permanent works. The proposed site for IWM facilities is located about 100m from the residential houses.
However, the nearest shanties may be treated as “receptors” of some of the impacts such as noise or
unpleasant smell during construction period and obnoxious odour during operation. Undoubtedly these will
equally have a significant impact if proposed mitigation measures are not implemented.
157. Wider Project Area. This is the area that will coincide with the road network that will be used by
subproject trucks during delivery of building materials and later transportation of sludge and solid waste
during the operation phase. This will be dictated by the number of heavy trucks needed at once to haul
construction materials. Therefore, the subproject impacts either positive or negative are likely to extend
beyond the boundaries of the project area following the road network to sources of materials and back to
the proposed site. Of course the IWM facility will be used to treat sludge and solid wastes from different
camp area of which is significance to environmental management especially livelihood improvement
among camp residents.
B. Impact Assessment
1. Methodology
158. The significance of potential impacts was assessed using the risk assessment methodology that
considers impact magnitude and sensitivity of receptors, described below.
159. Impact Magnitude- The potential impacts of the subproject have been categorized as major,
moderate, minor and negligible based on consideration of the parameters such as: i) duration of the impact;
ii) spatial extent of the impact; iii) reversibility; iv) likelihood; and v) legal standards and established
professional criteria. These magnitude categories are defined in Table VI:1.
Table VI.1: Parameters for Determining Magnitude
Parameter Major Medium/Moderate Minor Negligible
Duration of potential Long term (more than Medium Term Limited to Temporary with no
impact 35 years) Lifespan of the construction period detectable
project (5 to 15 potential impact
years)
Spatial extent of the Widespread far beyond Beyond immediate Within project Specific location
potential impact project boundaries Project boundary within project
components, site component or site
boundaries or local boundaries with
area no detectable
potential impact
Reversibility of Potential impact is Baseline requires a Baseline returns Baseline remains
potential impacts effectively permanent, year or so with naturally or with constant
requiring considerable some interventions limited intervention
intervention to return to to return to baseline within a few months
baseline

Parameter Major Medium/Moderate Minor Negligible

Legal standards and Breaches national Complies with limits Meets minimum Not applicable
established standards and or given in national national standard
professional criteria international standards but limits or international
guidelines/obligations breaches guidelines
international lender
guidelines in one or
more parameters
Likelihood of Occurs under typical Occurs under worst Occurs under Unlikely to occur
potential impacts operating or case (negative abnormal,
occurring construction conditions impact) or best case exceptional or
(Certain) (positive impact) emergency
operating conditions
conditions (Likely) (occasional)
160. Sensitivity of Receptor- The sensitivity of a receptor has been determined based on review of
the population (including proximity/numbers/vulnerability) and presence of features on the site or the
surrounding area. Each detailed assessment has defined sensitivity in relation to the topic. Criteria for
determining receptor sensitivity of the subproject’s potential impacts are outlined in Table VI: 2.
Table VI.2: Criteria for Determining Sensitivity
Sensitivity Determination Definition
Very Severe Vulnerable receptor with little or no capacity to absorb proposed changes
Vulnerable receptor with little or no capacity to absorb proposed changes or limited

Severe
opportunities for mitigation.
Vulnerable receptor with some capacity to absorb proposed changes or moderate
Mild
opportunities for mitigation
Vulnerable receptor with good capacity to absorb proposed changes or/and good
Low
opportunities for mitigation
161. Assigning Significance- Following the determination of impact magnitude and sensitivity of the
receiving environment or potential receptors, the significance of each potential impact has been established
using the impact significance matrix shown below in Table VI: 3.
Table VI.3: Significance of Impact Criteria
Sensitivity of Receptors
Magnitude of
Potential Impact
Very Severe Severe Mild Low
Major Critical High Moderate Negligible

Medium High High Moderate Negligible
Minor Moderate Moderate Low Negligible
Negligible Negligible Negligible Negligible Negligible
2. Summary of Impacts
162. The subproject’s potential impacts on the key environmental parameters have been assessed and
their significance determined using the methodology described above. A summary of the potential impacts
of the subproject on the key environmental parameters and significance of these impacts are presented in
Table VI: 4.

Construction and operation of 2 integrated waste management and resource recovery facility with collection system at camp 4 in Ukhia and camp 23 in Teknaf (EAP/DPHE/W9A)
Table VI.4: Summary of the potential impacts of the subproject

Duration of Reversible Significance Prior Significance
Potential Impacts Spatial Extent Likelihood Magnitude Sensitivity
Impact or not to Mitigation after Mitigation
Environmental Impacts During Pre-Construction Phase
Location impacts of IWMF Long term Local Yes Certain Medium Mild Moderate Negligible
Collection system of faecal Long term Local Yes Certain Medium Mild Moderate Negligible
sludge
Transportation of the sludge Long term Local Yes Certain Medium Mild Moderate Negligible
Natural calamities Long term Local Yes Certain Medium Mild Moderate Negligible
Sources of materials Short term Local Yes Certain Medium Mild Moderate Negligible
Testing of environmental Short term Local Yes Certain Medium Mild Moderate Negligible
quality (air, noise, water)
Permits, clearances, NOC Short term Local Yes Certain Medium Mild Moderate Negligible
etc.
EMP implementation training Short term Local Yes Certain Medium Mild Moderate Negligible
Environmental Impacts During Construction Phase
Physical and cultural heritage Short term Local Yes Occasional Minor Low Negligible Negligible
Excavations Short term Local Yes Certain Medium Mild Moderate Negligible
Waste management Short term Local Yes Certain Medium Mild Moderate Negligible
Water quality Short term Local Yes Certain Medium Mild Moderate Negligible
Air quality Short term Local Yes Certain Medium Mild Moderate Negligible
Noise level Short term Local Yes Certain Medium Mild Moderate Negligible
Biodiversity Short term Local Yes Likely Minor Mild Moderate Negligible
Socio-economic status Short term Local Yes Certain Medium Mild Moderate Negligible
Provision of worker facilities Short term Local Yes Certain Medium Mild Moderate Negligible
Workers health and safety Long Term Local Yes Certain Major Severe High Negligible

Duration of Reversible Significance Prior Significance

Potential Impacts Spatial Extent Likelihood Magnitude Sensitivity
Impact or not to Mitigation after Mitigation
Community health and safety Short term Local Yes Certain Medium Mild Moderate Negligible
Site Reinstatement Long term Local Yes Certain Medium Mild Moderate Negligible
Environmental Impacts During O&M Phase

Health and safety risk of
Long Term Local Yes Certain Major Severe High Negligible
workers at IWMF
Efficient working of IWMF Long term Local Yes Certain Medium Mild Moderate Negligible
Water quality Long Term Local Yes Certain Major Severe High Negligible
Biodiversity Long term Local Yes Certain Medium Mild Moderate Negligible
Air emission and odor Long term Local Yes Certain Medium Mild Moderate Negligible
Reuse and disposal of
Long term Local Yes Certain Medium Mild Moderate Negligible
compost
Traffic management Long term Local Yes Certain Medium Mild Moderate Negligible
Socio-economic aspect Long term Local Yes Certain Medium Mild Moderate Negligible

3. Positive Impacts Expected from the Proposed Subproject

 Improved quality of health from proper management of solid waste and faecal matter that would
otherwise be dumped haphazardly and drain into water bodies where others may become in
contact with.
 Improved water quality in streams and subsequent groundwater.
 Employment and trading opportunities will be direct benefits to the neighboring communities.
 The government will equally benefit from statutory contributions made by the contractor for his
employees. Sales from construction materials will have value added tax that goes to the
government.
 It is also anticipated that properly treated sludge can be re-used as fertilizer to increase agricultural
productivity. The use of compost can also minimize the use of chemical fertilizers, which are
potential pollutants. Similarly, the properly treated supernatant overflow from sludge treatment
process can be used for land irrigation. This will also depend with the willingness of the community
on using compost as fertilizer, thus the community should be sensitized on the advantage of using
this compost as fertilizer to avoid nuisance of using it.
4. Screening Out Areas of No Significant Impact

163. From the preliminary design and results of the rapid environmental assessment, it is clear that
implementation of integrated waste (solid waste and faecal sludge) management subproject will not have
major negative impacts because activities will be localized/site-specific and short in duration. Moreover,
subproject construction will be conducted within a relatively small area. Because of these, some aspects
of the environment that are not expected to be significantly affected by the construction process have been
screened out and will not be mentioned further in assessing the impacts of the construction process (Table
VI.5).
Table VI.5: Fields in which the subproject is not expected to have significant impacts
Field Rationale
Topography, geology and
Required amount of materials will not cause alteration of topography and landforms.
landforms
Aerobic composting process will be used in the integrated waste management
facility (IWMF) thus no greenhouse gases specially methane will be generated.
Climatic condition
Short-term production of dust is the only effect on atmosphere. However, impact is
short-term, site-specific and within a relatively small area.
Land use There are no major changes in any areas to be affected by the subproject.
Tourism Tourists mostly drive by the villages located as these are located on the highway.
5. Anticipated Impacts and Mitigation Measures during Pre-Construction Phase

164. Planning principles and design considerations will be incorporated in the site planning process
whenever possible. The potential adverse impacts that are associated with planning and design can be
mitigated to acceptable levels with the following mitigation measures (Table VI.6).
Table VI.6: Anticipated Impacts and Mitigation Measures – Pre-Construction Phase
Field Impacts Mitigation Measures
Location impacts of Nearby community may be IWMF sites should be selected in such a way that nearby
IWMF affected due to increased community may have no or minimum impact such as dust,
pollution during construction noise and access limit at construction phase and odor
and operation. generation during operation phase due to proposed works.
55 | P a g e

Collection system of  Manual emptying will affect  Provision of vacuum trucks with pump and hose are
faecal sludge public health. considered in the design for motorized collection system.
 Collection may impede in  Long hose pipe is considered to cover the pits located in
the inaccessible hilly area. the inaccessible hilly area.
 Spillage may occur during  Disinfectant has been considered to use for the spillage if
sludge collection could happen during sludge collection.
affect public health and  Solid content is lesser than liquid identified in the faecal
environmental problems. sludge generated in the camp. A long spade or jetted with
 Cannot pump thick, dried a water hose should be used for compacted layers of the
sludge at the bottom of the sludge.
pits.
Transportation  Spillage occur during  Chemical disinfectant has been considered to be use on
system of the sludge transportation could affect the spillage if occur during transportation.
public health and  Vacuum trucks should be checked daily basis before
environmental problems. operation.
 Traffic accident may  The speed limit of the trucks will be restricted to 20 km/hr;
increase due to frequent  A well-defined schedule and route will be followed by the
movement of vacuum sludge carrying trucks;
trucks in camp.  A proper traffic management plan should be implemented
 Traffic congestion may to mitigate adverse impacts;
happen due to random
parking of the trucks.
Natural calamities In camp 4 ext., IWMF  Highest flood level has been considered in the design.
location is adjacent to a  Planning of IWMF at a suitable elevation above the current
narrow water channel which high tide level (utilizing accurate topographic survey).
can cause flash flooding
during monsoon. However,
drying and maturing shed in
camp 23 is located close to
the river (approx. 250m)
which is connected to the sea
therefore, there is a threat of
inundation due to river
flooding and tidal surge.
Sources of materials Extraction of materials can  Prioritize sites which already permitted by the authority.
disrupt natural land contours  If other sites are necessary, it is contractor’s responsibility
and vegetation resulting in to verify the suitability of all material sources and to obtain
accelerated erosion, the approval of PMU and consultants.
disturbance in natural  If additional quarries will be required after construction is
drainage patterns, ponding started, construction contractor to obtain a written
and water logging, and water approval from PMU.
pollution.
Testing of To generate the baseline Undertake baseline quality tests of air, noise, water in the
environmental quality data to protect the subproject site to serve as benchmark for subsequent
(Air, noise, surface & environment of the monitoring.
groundwater quality) subproject area.
Permits, clearances, Failure to obtain necessary  Obtain NOC from DC, Cox’s Bazar for the government
no objection permits and NOCs, etc. can land and take the permit from RRRC for the camp access
certificate (NOC) etc. result to design revisions prior to start of civil works.
and/or stoppage of works.  Obtain NOC from Cox’s Bazar DC office for the khas land
required for the SWM in Shamlapur.
 Acknowledge in writing and provide report on compliance
all obtained permits, clearance, NOCs, etc.
 Include in detailed design drawings and documents all
conditions and provisions if necessary.
56 | P a g e

EMP implementation Irreversible impact to the Project manager and all key workers of contractors will be
training environment, workers, and required to undergo EMP implementation including spoils
community. management, Standard operating procedures (SOP) for
construction works; health and safety (H&S), core labor
laws, applicable environmental laws, etc.
6. Anticipated Impacts and Mitigation Measures during Construction Phase

165. The impacts during construction shall include generic construction related impacts associated with
construction activities. In the case of this subproject (i) most of the individual elements are relatively small
and involve straightforward construction, so impacts will be mainly localized and not greatly significant; (ii)
most of the predicted impacts are associated with the construction process, and are produced because
that process is invasive, involving excavation and earth movements. These are not expected to be
significant, and can be addressed through adoption of good engineering and construction practices and
construction methods. The potential adverse impacts that are associated with construction activities can
be mitigated to acceptable levels with the following mitigation measures (Table VI.7).
57 | P a g e
Construction and operation of integrated waste management and resource recovery facility with collection system at camp 4, Ukhia and solid waste management facility at Shamlapur, Teknaf
(EAP/DPHE/W9A)
Table VI.7: Anticipated Impacts and Mitigation Measures – Construction Phase

Physical and Cultural Construction works will be on existing Rohingya Stop work immediately to allow further investigation; Prevent workers or any other persons from
Heritage camp, thus risk for chance finds is low. removing and damaging of archaeological remains.
Excavations Potential erosion, dust generation, accident/  The excavated earth shall always be dumped on the designated areas to be reused as needed.
dropping small children on open trench. The  In the event that excavations are to be kept open overnight, lights, high visibility warning signs,
impacts are negative but short-term, site-specific and barricades shall be provided.
within a relatively small area and reversible by
mitigation measures.
Access road  Impact of dust from transportation on  Damp down exposed soil and any sand stockpiled on site by spraying with water during dry
construction work surrounding residents; weather;
 Temporary increase in noise level;  Use tarpaulins to cover soils, sand and other loose material when transported by trucks.
 Tree felling;  Monitor noise levels. Maintain maximum sound levels not exceeding 80 decibels (dBA) when
 Potential top soil erosion; measured at a distance of 10 m or more from the vehicle/s.
 Construction works will impede the access of  Highest efforts will be necessary to avoid tree cutting. If unavoidable at least two trees will be
residents and businesses in limited cases. planted for every tree cut.
 Topsoil storage areas must be protected during the dry season, wind erosion—by covering.
 Formulate traffic direction, diversion and temporary access plans, setting up sufficient traffic
direction signs.
 Warning lights should be set up along the construction road sections, guiding the access of
vehicles.
Waste management  Oil, grease etc. from construction machinery;  Prepare and implement waste management plan approved by PMU.
 Hazardous and solid waste from waste  Wastes must be placed in the designated bins which must be regularly emptied. These shall
construction material and food; remain within demarcated areas and shall be designed to prevent wastes from being blown out
 Kitchen and sewage wastes from labour camp by wind.
will cause growth of flies and water born germs.  Recycling is to be encouraged by providing separate receptacles for different types of wastes and
The impacts are negative but short-term, site- making sure that staff is aware of their uses.
specific within a relatively small area and  All waste must be removed from the site and transported to a disposal site.
reversible by mitigation measures.
Water quality Trenching and excavation, run-off from stockpiled  Prepare and implement a waste management plan.
(surface and materials, and chemical contamination from fuels  Every effort shall be made to ensure that any chemicals or hazardous substances do not
groundwater) and lubricants may result to silt-laden runoff during contaminate the soil or water on-site.
rainfall which may cause siltation and reduction in  Care must be taken to ensure that runoff from vehicle or plant washing does not enter the
the quality of adjacent bodies of water. The surface/ground water.
impacts are negative but short-term, site-specific  Site staff shall not be permitted to use any stream, other open water body, or natural water source
within a relatively small area and reversible by adjacent to or within the designated site for the for disposing wastes.
mitigation measures.  All concrete mixing must take place on a designated, impermeable surface.

(EAP/DPHE/W9A)

 All substances required for vehicle maintenance and repair must be stored in sealed containers
until they can be disposed of removed from the site.
 Hazardous substance/ materials is to be transported in sealed containers or bags.
 Monitor water quality according to the environmental management plan.
Soil disturbance The construction activities may cause soil  Precautions to be taken at any time of year when rainstorms are likely, actions to be taken when
degradation problems in the areas of IWMF etc. a rainstorm is imminent or forecast, and actions to be taken during or after rainstorms shall be
developed by the Contractor.
 Slope protection measures through turfing;
 The earthwork sites where exposed land surface is vulnerable to runoff shall be consolidated
and/or covered.
 The material stockpile sites shall be far away from surface water bodies and areas prone to
surface run-off. Loose materials shall be bagged and covered.
 Channels, earth bunds, netting, tarpaulin and or sand bag barriers shall be used on site to manage
surface water runoff and minimize erosion.
 The overall slope of the works areas and construction yards shall be kept to a minimum to reduce
the erosive potential of surface water flows.
Air Quality Air pollution due to construction activities. The Water spraying for dust control; construction materials with potential for significant dust generation
impacts are negative but short-term, impacts shall be covered; no smoke belchers equipment; and limiting speed of construction vehicles in
within a relatively small area and reversible by access roads and work sites to maximum of 20 kph.
Noise Level Construction activities will be on settlements.  Consultation with affected people; not to operate noisy equipment during night time (22:00 –
Temporary increase in noise level may be caused 06:00);
by excavation equipment, and the transportation of  Sound suppression for equipment;
equipment, materials and people. The impact is  Ear protection for workers.
short-term and within a relatively small area and  Conduct noise quality monitoring as per EMP.
reversible by mitigation measures.
Biodiversity  Haphazard site clearing, parking and movement  CSC will monitor and supervise the activities of the contractors engaged during construction phase
of construction vehicles and equipment, of the project
stockpiling, and illegal unnecessary loss of  Plantation will be done at the ratio of 1 (cut): 2(new planting) for each tree felling.
vegetation beyond subproject footprints.  No trees, shrubs, or groundcover will be removed or vegetation stripped without the prior
 There are no protected areas in or around the permission of the environmental specialist;
IWMF in camp 4 ext., and no known areas of  While clearing vegetation it must be ensured that no wildlife injure and/or die.
ecological interest.  Harming and/or killing of any types of wildlife by the workers of the project must be prohibited.
 Teknaf Wildlife Sanctuary is located about 2km  Minimum levels of noise during construction activities will be maintained as well as illumination and
away from camp 23 in Shamlapur, thus illegal night operations will be restricted.
hunting may occur and pose the threat to wild 
animals.
 The flora and fauna in adjacent area may be
exposed to high levels of fugitive dust generated
during construction.

(EAP/DPHE/W9A)

Socio-economic  The drying & maturing shed in camp 23 will be  For the private property in camp 23, DPHE will negotiate with the landowners to purchase/lease
status located in the private land thus, there is a the required land and in case of khas land, a NOC has been furnished from Cox’s Bazar DC office.
requirement for land acquisition/requisition.  Employ at least 50% of labor force from communities in the vicinity of the site. This will have the
 Manpower may be employed from local
added benefit of avoiding social problems that sometimes occur when workers are imported, and
community as per guideline of RRRC during the
construction and operation stage. Thus potential avoiding environmental and social problems from workers housed in poorly serviced camp
impact is positive and long-term. accommodation.
 Secure construction materials from local market.
Provision of Worker  Inconvenience to the communities due to  Provide suitable housing, adequate supplies of potable water, and toilet and bathing facilities within
Facilities presence of workers; the housing area. Onsite facilities for preparing food need to be provided, or food service
 Solid waste and sanitary discharges from worker contracted;
camps.
 Provide means for disposing of wastewater from toilets, baths and food preparation areas either
through a septic tank and soak away, or holding tank with removal by vacuum truck.
 Solid waste should be collected at waste bins and disposed of properly offsite.
Worker Health and Occupational hazards which can arise during  Comply with requirements of Government of Bangladesh Labor Law and all applicable laws and
Safety work. Potential impacts are negative and long- standards on workers H&S.
term but reversible by mitigation measures.  Ensure that all site personnel have a basic level of environmental awareness training. If necessary,
the environmental safeguard specialist will help further capacity building.
 Produce and implement a site health and safety (H&S) plan which include measures as: (i)
excluding the public from worksites; (ii) ensuring all workers are provided with and required to use
personal protective equipment (reflectorized vests, footwear, gloves, goggles and masks) at all
times; (iii) providing (H&S) training for all site personnel; (iv) documenting procedures to be
followed for all site activities; and (v) maintaining accident reports and records.
 Arrange for readily available first aid unit including an adequate supply of sterilized dressing
materials and appliances.
 Provide Insurance coverage for workers;
 Provide H&S orientation training to all new workers to ensure that they are apprised of the basic
site rules of work at the site, personal protective protection, and preventing injuring to fellow
workers;
 Ensure the visibility of workers through their use of high visibility vests when working in or walking
through heavy equipment operating areas;
 Ensure moving equipment is outfitted with audible back-up alarms;
 Disallow worker exposure to noise level greater than 85 dBA for a duration of more than 8 hours
per day without hearing protection. The use of hearing protection shall be enforced actively.
Community health Construction works will impede the access of  Adequate lighting, temporary fence, reflectorized barriers and signage at active work sites;
and safety some residents in limited cases. The impacts are  Contractor’s activities and movement of staff will be restricted to designated construction areas.
negative but short-term, site-specific within a  Contractor’s preparedness in emergency response;
relatively small area and reversible by mitigation  PAPs need to be made aware of the existence of the complaints book and the methods of
measures. communication available to them. The contractor must address queries and complaints by: (i)
documenting details of such communications; (ii) submitting these for inclusion in complaints

(EAP/DPHE/W9A)

register; (iii) bringing issues to the environment management specialist’s attention immediately;
and (iv) taking remedial action as per environment management specialist’s instruction.
 Adequate dissemination of the GRM and Contractor’s observance/implementation of the GRM.
Site reinstatement Damage due to debris, spoils, excess construction  Remove all spoils wreckage, rubbish, or temporary structures which are no longer required;
materials  The area that previously housed the construction worker shed is to be checked for spills of
substances such as oil, paint, etc. and these shall be cleaned up.
 The contractor must arrange the cancellation of all temporary services.
 Request PMU to report in writing that worksites and camp have been vacated and restored to pre-
project conditions before acceptance of work.

7. Anticipated Impacts and mitigation Measures during Operation Phase

166. Construction contractor shall be responsible for Operation and Maintenance of the IWMF for 2
years, under the control of DPHE. The system has a design life of 20 years, during which shall not require
major repairs or refurbishments and should operate with little maintenance beyond routine actions required
to keep the system in working order. The stability and integrity of the system will be monitored periodically
to detect any problems and allow remedial action if required. Any repairs will be small scale involving
manual, temporary, and short-term works involving regular checking and recording of performance for
signs of deterioration, servicing and replacement of parts.
167. There are certain environmental risks from the operation of the IWMF, most notably is handling of
waste, disposal of effluent and compost which can damage human health and contaminate both soil and
groundwater. It will be imperative therefore that the operating agency establishes a procedure to routinely
check the operation and integrity of the IWMF, and to implement rapid and effective repairs where
necessary. However, there is also an occupation health risk to workers engaged in IWMF maintenance
activities. During cleaning/clearing of IWMF system utmost precautions should be taken for the safety of
workers conducting such works. The potential impacts that are associated with O&M activities can be
mitigated to acceptable levels with the following mitigation measures (Table VI.8).
Table VI.8: Anticipated Impacts and Mitigation Measures – O&M Phase
Health and safety Risk of health of workers  Provide all the personal protective equipment like gum
risk of workers working in IWMF operation boots, nose mask, gloves etc. for the protection of
and maintenance, workers workers.
may suffer infectious diseases  The workplace will be equipped with fire detectors, alarm
due to faecal matters. systems and fire-fighting equipment. The equipment will
be periodically inspected and maintained in good working
condition.
 Providing adequate personnel facilities, including
washing areas and areas to change clothes before and
after work.
 Medical check-up will be conducted on regular basis and
the health conditions will be monitored.
 First aid facilities required to attend immediately for
meeting emergency situations will be made available at
the facility.
 Maintaining good housekeeping in waste processing and
storage areas.
Efficient working of Inefficient working of IWMF  Procedure for each step of operation shall be
IWMF may cause poor quality of documented and all workers/operators shall be trained on
treatment and resulting under the proper operation of each component of the IWMF,
treatment of waste water and including the proper desludging procedure for septic
sludge may cause tanks.
environment, health and  Although impact is likely to be minimal due to new and
safety risk to workers and well-designed efficient system, it must be ensured that
environment. the facility is operating properly at all times.
Water quality Run-off from IWMF which may  Take all precautions to prevent entering of run-off into
cause reduction in the quality streams, watercourses or irrigation system.
of adjacent water body and  Quality of leachate shall be regularly monitored to ensure
groundwater. The impacts are that leachate quality complies with the prescribed effluent
negative but short-term and in standards (chemical and biological).
small area and reversible by  Quality of water shall be regularly monitored to ensure
mitigation measures. that water quality complies with the DOE standards.
Biodiversity  Ensure the survival rate of  Monitor survival of replanted trees (also compensatory
planted trees. planting) and replant, as necessary.
 Release of ill‐treated black  Prevent workers or any other person from removing and
water onto water courses damaging any flora (plant/ vegetation) and fauna
may cause eutrophication (animal).
and harm aquatic species.  Quality of discharge shall be regularly monitored to
ensure that effluent quality complies with the prescribed
effluent standards (chemical and biological).


Air emission and Odor generation for the FSTP  Frequently monitor performance of the FSTP to ensure
odour may cause health risk to the that clogging is remedied as soon as possible;
worker and community.  Keep the immediate surrounding of the FSTP tidy.
Reuse and Environmental hazard and  Compost shall be used as soil conditioner to enhance soil
disposal of compost health risk to workers and fertility in nearby farms.
other people.  If reuse is not feasible safe disposal should be ensured
for treated effluent and sludge.
 Quality of compost shall be regularly monitored to ensure
that compost quality complies with the standards.
 Vacuum trucks will be  A well-defined schedule and route will be followed by the
Traffic management
plying to the facility from the waste carrying trucks;
camps. This may lead to  Proper signage will put up near the proposed facility
increase in traffic accident. giving route directions;
 Random parking of  Vehicles will be parked inside the facility premises in the
vehicles and unplanned designated slots;
loading /unloading areas  Entry and exit routes from the premises will be clearly
can lead to traffic marked;
congestion.  Adequate lighting and reflective boards will be put up for
night time safety;
 A proper traffic management plan will be implemented to
mitigate adverse impacts;
 All routes will be planned to cause minimal disturbance to
local community;
 The vehicles will be allowed to move in the site only
through dedicated entry and exit points within the site;
 Dedicated parking area will be provided in the facility for
parking of vehicles;
 The speed limit of vehicles will be restricted to 20 km/hr;
 Visual impacts.  Good waste handling practices will be implemented which
Socio-economic
 Impacts on community will greatly reduce foul smell and reduce impact from
aspect
health. odors;
 Employment.  Vehicles moving through community roads will be
covered and the operations will be restricted to day time;
 Maximum efforts will be made to provide job opportunities
to local residents during construction and operation
phase.
 Awareness campaigns should be organized emphasizing
the need of sorting at source, waste collection and
participatory role of residents in waste management in an
area.
C. Potential Cumulative Impacts

168. Cumulative Impact Assessment is the analysis of all effects on an area from one or more activities
as they accumulate over time and space (IPENZ, 2009). Cumulative impacts are those that may result
from a combination of past, existing, and imminent human activities.
169. Cumulative impacts can include multiple causes, multiple effects, effects of activities in more than
one locale, and recurring events. For any activity, there is the potential for negligible individual impacts to
create larger cumulative impacts, both positive and negative.
170. A conventional project and site-specific approach to environmental assessment has its limitations
when it comes to assessing potential cumulative effects on environmental resources. This is because the
impact of a particular project on an environmental resource may be considered insignificant when assessed
in isolation, but may be significant when evaluated in the context of the combined effect of all past, present,
and reasonably foreseeable future activities that may have or have had an impact on the resources in
question (ADB, 2009). In determining the potential cumulative impacts, a holistic approach is taken that
looks at potential changes over time, over unrelated or widespread areas, and also considers other nearby
developments that are related and unrelated to the Project.
171. Cumulative impacts are defined in the Equator Principles and the International Finance
Corporation’s Procedure for Environmental and Social Review of Projects (IFC, 1998), as those impacts

that could arise as a result of “projects or potential developments that are realistically defined at the time
the environmental assessment is undertaken if those projects and developments could impact on the
project area.”
172. The objective of the current cumulative impact assessment is to evaluate the combined effects of
proposed developments along the proposed Integrated Waste Management Facility. The project adverse
impacts have been broadly classified as impacts on surrounding environment (air quality, noise level, water
quality and soil quality), impacts on biodiversity and impacts on socio economic environment etc.
1. Current and Future Development Projects

173. Twelve UN agencies, some 127 international and national nongovernment agencies, several faith-
based organizations and government agencies, and other donors provide support in the Rohingya camps.
These agencies have carried out many interventions to provide high-priority basic infrastructure and
essential services to the displaced persons from Myanmar. In connection to this, the following projects are
identified to implement along the proposed integrated waste management facility area.
 Human Waste Treatment Facility in Refugee Settlement in Cox’s Bazar by UNHCR and Oxfam.
 Design, Supply, Install, Test, Commission, Operation and Maintenance of Faecal Sludge and
Segregated Solid Waste Treatment Plant in Camp 4 Extension.
 Construction and operation of mini piped water supply system in Kutupalong Balukhali Mega camp.
 Construction of Semi-Permanent Food Distribution Centers and loading /unloading yard in Ukhia.
 Construction of 3 nos. school cum cyclone shelter for affected people, 3 story LGED Prototype, in
Ukhia.
 Development of Faliapara Primary School Road Ch. 0-1035m and Development of Ukhia Marine
Drive Road N.I Chowdhury Road Ch. 00-2505m in Ukhia, Cox’s Bazar.
 Construction of Non-Motorized Road by HBB at Kutupalong Balukhali Mega camp in Ukhia, Cox’s
Bazar.
 Construction of Storm Water Drainage Network on Primary canal-01 (Modhuchara) Outleting to
Naf river, in Ukhia, Cox's Bazar.
 Construction of Hill Slope Protection by Landscaping inside the Kutupalong Balukhali Mega Camp
Ukhia.
 Construction of 50 KM of 11 KV and below lines with necessary transformers from proposed two
substations to Palongkhali area, Ukhia.
 Supply and installation of 50 nos. solar mini-grid for household electricity supply within the camp
(150 households per cluster: to cater 7,500 HH) at Kutupalong-Balukhali mega camp.
174. Prior to commencing construction of the interventions, the agencies undertake different studies
including environmental assessment for the projects. However, the following reports are considered to
identify the cumulative impacts for the proposed integrated waste management project.
175. Design, Supply, Install, Test, Commission, Operation and Maintenance of Faecal Sludge
and Segregated Solid Waste Treatment Plant– Initial Environmental Examination, 2019: Basic scope
of the plant and services under this assignment covers designing, planning, engineering, procurement
(fabricating/supplying), constructing/erecting, testing, commissioning, and five years of Operation and
Maintenance of Faecal Sludge and Segregated Solid Waste treatment plant in the displaced persons’
Camps of Cox’s Bazar. Plant will be designed by advanced innovative technologies to reuse dewatered
faecal sludge, some organic solid waste, and single use multi-layer segregated plastic. The project was
classified as B category of ADB SPS 2009 which to be established in the same premises of the proposed
integrated waste management project. Major impacts from the different process of the proposed technology
are exhaust air quality from boiler, release of heat from the boiler to environment, distilled water quality as

byproduct, ash quality for disposal and filtrate and filter material disposal from sludge stream. Mitigations
are proposed to be integrated in design so that negative impacts are reversed or minimal. During
construction phase, impacts mainly arise from excavation, waste management, dust, noise and health and
safety risk to workers and community. These are common temporary impacts of construction, and there
are well-developed methods for their mitigation. Mitigation measures have been developed to reduce all
potential negative impacts to acceptable levels.
176. Construction and operation of mini piped water supply system– Initial Environmental
Examination, December 2018: Under this component, 40 mini-piped water supply schemes based on
groundwater were designed to construct to supply water at camp areas which comprises (1) construction
of production well (2) installation of solar pump solution for production well (3) construction of pump houses
(4) construction of reservoirs (10000 liter HDPE), (5) construction of HDPE Pipe networks (100mm and 75
mm pipeline) using trench and (6) construction of community tap stand. Five contract packages were
designed under procurement plan as per ADB’s procurement guideline to implement this component. Total
twelve environmental parameters are likely to be affected by the project implementation. Adverse
environmental impacts during construction are temporary, less than significant, and can be easily mitigated.
There will be no massive construction activities that can damage the environment. No cutting of trees will
be done in the subproject area. Water supply pipe-laying is a low impact construction activity since trench
excavation is shallow with narrow width. Excavated soil is backfilled to the trench after pipe-laying.
Required structures are relatively small in size. Typical construction issues are manageable with the
implementation of preventive measures to address: land slide hazard, groundwater quality, dust, noise,
biodiversity, worker and public safety. However, the socioeconomic environment is considered to be
affected positively as the project activities will create job opportunity for the local people and safe water
supply system to mitigate the water scarcity in the camps.
177. Development of Faliapara Primary School Road Ch. 0-1035m and Development of Ukhia
Marine Drive Road N.I Chowdhury Road Ch. 00-2505m in Ukhia, Cox’s Bazar– Initial Environmental
Examination, June 2019: Proposed length of this road is 3040m. The proposed road already exists, but
needs improvement (i.e. widening, repairing, additional drainage system). The improved road will be
mixture of RCC and BC with steel made culverts and roadside drains. The IEE report fulfils the
requirements of DOE and ADB SPS 2009. The IEE identifies potential environmental and social impacts
and issues associated with undertaking the proposed project. It provides an outline of the potential positive
and negative impacts as a result of the Project and proposes suitable mitigation and management
measures.
178. Construction of Non-Motorized Road by HBB in Ukhia, Cox’s Bazar– Initial Environmental
Examination, September 2019: The proposed project will improve the internal roads within Rohingya
Camps. The proposed road already exists, but needs improvement (i.e. widening, repairing, additional
drainage system). The improved road will be HBB in nature with roadside drains. A number of roads will
be constructed which well spread over the camp area. The project is classified as category B in accordance
with the Safeguard Policy Statement (SPS) of the Asian Development Bank (ADB), accordingly an Initial
Environmental Examination (IEE) has been prepared for the project. Environmental issues as well as social
impacts were identified during pre-construction, construction stage and operational stage.
179. Construction of Storm Water Drainage Network on Primary canal-01 (Modhuchara)
Outleting to Naf river, in Ukhia, Cox's Bazar– Initial Environmental Examination, 2019: The original
natural canal is more than 8km long of which 5800m has been proposed for excavation and upgradation.
The canal is originated from the Camp – 4 Extension inside the Balukhali Mega Camp and drains into Naf
river. The canal has several branches and sub-branches including both tributaries and distributaries. The
canal is featured with densely population on both banks and runs through Camp no 18 Extension (originally
survey was possible from this point) and 12 and 10. The canal bed features frequent undulation which
causes localized heavy waterlogging during the rains. The earthen sections of this canal has been
damaged in last couple of years, especially during monsoon season. The whole chainage (5800m) has
been proposed to maintain 0.14% sloping by excavation and filling for smooth flow of upstream water.

Along the canal 10962sqm area of slope has been proposed for cast-in-situ for bank protection. Staircases
and grass plantation to prevent erosion has been considered.
180. Construction of Hill Slope Protection by Landscaping inside the Kutupalong Balukhali Mega
Camp Ukhia under Emergency Assistance Project – Initial Environmental Examination, 2019: The
proposed project aims to address the vulnerable hilly areas of the Kutupalong-Balukhali mega camp and
proposes construction measures for effective and environmental friendly hill protection. The project is
classified as category B in accordance with the Safeguard Policy Statement (SPS) of the Asian
Development Bank (ADB), accordingly an Initial Environmental Examination (IEE) has been prepared for
the project.
181. Construction of 50 KM of 11 KV and below lines with necessary transformers from proposed
two substations to Palongkhali area, Ukhia– Initial Environmental Examination, November 2018:
UNHCR and Oxfam have together put into service a human waste treatment facility in refugee settlement
in Cox’s Bazar. The facility can process the waste of 150,000 people - 40 cubic meters a day. The sludge
is transported by waste vehicles that empty out waste from multiple locations in the refugee sites into two
massive, tightly covered lagoons where the processing begins. The facility maintains minimal operational
and maintenance costs, with the initial investment of developing the site and installing the equipment falling
just under $400,000.
182. Human Waste Treatment Facility in Refugee Settlement in Cox’s Bazar by UNHCR and
Oxfam: UNHCR and Oxfam have together put into service a human waste treatment facility in refugee
settlement in Cox’s Bazar. The facility can process the waste of 150,000 people - 40 cubic meters a day.
The sludge is transported by waste vehicles that empty out waste from multiple locations in the refugee
sites into two massive, tightly covered lagoons where the processing begins. The facility maintains minimal
operational and maintenance costs, with the initial investment of developing the site and installing the
equipment falling just under $400,000.
183. Report on Environmental Impact of Rohingya Influx. The Environmental Assessment Study
was initiated by the Ministry of Environment and Forest (MoEF) of Bangladesh and by UNDP and UN
Women to assess the environmental impacts of the Rohingya influx into Bangladesh and propose a series
of actions to address the high environmental risks related to the influx. Eleven environmental impacts were
identified that have been or could potentially be exacerbated by the Rohingya influx. Six of these were
physical environmental impacts on: ground water; surface water; acoustic levels; indoor air quality; solid
waste management; and soils and terrain; and the remaining five were impacts on ecosystems: natural
forests; protected areas and critical habitats; vegetation; wildlife; and marine and freshwater ecosystems.
Key risks were pinpointed and assessed based on the rating of their impact. The following risks associated
with the physical environmental impacts were assessed as high: ground water depletion; ground water
contamination; poor indoor air quality; poor management of sewer sludge; removal of soils and terrain; and
changes in terrain. Impacts on ecosystems with high associated risks were: deforestation and forest
degradation; encroachment onto and resource extraction from protected areas; changes in land cover;
rapid biomass reduction; loss of species; loss of wildlife habitat and shrinkage of wildlife corridor; and
mortality risks for wildlife.
2. Identification of Cumulative Impacts

184. Each of these identified project has the potential to cumulatively impact on the environment. The
environmental and social aspects which the project functions have the capacity to interact or accumulate
with project potential impacts are summarized in Table VI.9.

Table VI.9: Potential to contribute to cumulative impacts

Mini Construction Construction
Faecal Construction
Piped Construction of Non- Construction of 11 KV &
Camp Sludge Storm
Aspects Water of Access Motorized of Hill Slope below line
Activities Treatment Drainage
Supply Road Internal Protection with
Facility Network
System Road Transformers
Water
✓ ✓ ✓ ✓ ✓ ✓ ✓
quality
Air quality ✓ ✓ ✓ ✓ ✓
Noise level ✓ ✓ ✓ ✓ ✓ ✓ ✓
Soil quality ✓ ✓ ✓ ✓ ✓ ✓
Biodiversity ✓ ✓ ✓ ✓ ✓ ✓
Land use ✓ ✓ ✓ ✓
Traffic ✓ ✓ ✓ ✓ ✓ ✓ ✓
Social/
Livelihood ✓ ✓ ✓ ✓ ✓ ✓ ✓ ✓
pattern
185. Deterioration in surface water quality. Setting up the Rohingya camps involves vegetation and
soil removal, and hill cutting is caused soil erosion and changes in local hydrology. Deterioration of surface
water quality due to silt runoff and biological contamination of surface and ground water by sanitary waste
from latrines. On the other hand, run-off from IWMF which may cause reduction in the quality of adjacent
water body. Contamination of surface water quality will have potential significant negative impact on
biological functions of surface water as well as fish/aquatic life resources therein.
186. To prevent surface water pollution from IWMF, all precautions are proposed to prevent entering of
run-off into streams, watercourses or irrigation system. Moreover, quality of leachate shall be regularly
monitored to ensure that leachate quality complies with the prescribed effluent standards (chemical and
biological).
187. Deterioration in groundwater quality. Thousands of latrines without proper soak pits have been
installed along the contour lines of the hills close to the shelters and very close to water points, causing
ground water contamination. In addition, deterioration in groundwater quality is likely to occur due to the
dumping of untreated wastes. Leachate of wastes that contains hazardous elements will percolate soils
reaching groundwater contaminating the natural resources.
188. There will be provisions for leachate collection system and it will be treated in a Leachate
Treatment Plant and recycled for utilization in Vehicle washing, greenbelt development and floor washing.
Ground water quality will be monitored periodically as per monitoring plan.
189. Air quality and odour nuisance. The impacts on air quality may occur due to dispersion of dust
and particulate matter from the compost plant, movement of vehicles, operation of machinery etc. Apart
from this, exhaust from the Omni plant may contain dust, CO2, NOx, SOx, CO, HCl, particulate matter,
lead and its compounds, cadmium and its compound and mercury and its compounds and dioxin which
may degrade air quality in manifolds. However, odour nuisance associated with the proposed waste
management facility may occur during presorting of waste, containment of odorous material in waste
reception pit, pre-sorting area, composting plant and leachate collection area. The main gaseous product
of composting and mulching (i.e. carbon dioxide and other organics) characterized by an earthy or woody
odour will be generated in composting plant under aerobic conditions.
190. This development would be contributing pollutants to the air, which may accumulate with emissions
from the proposed Project. Atmospheric pollutants do not accumulate in a predictable, additive manner
and as such it is difficult to quantitatively assess any potential air quality cumulative impacts. However,
green belt will be provided along the internal roads and site boundary of the proposed IWMF which will
limit the spread of dust and odour. Moisture content between 40% and 60% will be considered to provide
a good air/moisture balance to support aerobic processes. Moreover, in the design of the Omni plant it
must ensure the complete exhaust treatment consists with Dust collector, Scrubber, Denitrification system,
Acid vapor removal, Sulfur removal, Dioxin removal, Particulate arrestor to control the air quality.

191. Noise level. Increased traffic on the Cox’s Bazar-Teknaf road is the main source of noise as the
camps are along this road. Movement of waste carrying vehicles transporting waste to the existing Oxfam
faecal sludge treatment facility in adjoining project area is another source of noise. However, potential
increase in noise level is expected due to operation of various equipment, movement of trucks for waste
loading and unloading which has the potential to affect the health of the people in the vicinity.
192. Deterioration in soil quality. Improper waste dumping will contaminate soil. Liquid wastes
generated from leachate pit may be accumulated contaminating surface water, groundwater and soil. The
effect may be widespread due to flooding effect.
193. Impact on biodiversity. Operation of machineries may disturb local birds and small mammals in
the adjoining areas. Exhaust from the Omni plant may contain dust, CO2, NOx, SOx, CO, HCl, particulate
matter, lead and its compounds, cadmium and its compound and mercury and its compounds and dioxin
which would have some negative impacts on the surrounding ecology. Impact on avifaunal species due to
increased noise.
194. Change in land use. Change in land use is from conversion of existing lands, mostly bushy hilly
lands into urban infrastructures such as shelter houses, internal roads, access road etc. Moreover,
development works would induce further developments which also have the impact on land use again. For
example, construction of a waste treatment facility will result in change in land use, i.e., agricultural lands
into waste treatment plant; and again there will be further change in land use from associated
developments (say shelter facilities for the workers) due to this treatment facility.
195. Heavy traffic movement. Traffic movement will be increased to transport construction materials
and equipment. Moreover, waste carrying trucks will be plying to the facility from the camps. This may lead
to increase in traffic volume. Random parking of vehicles and unplanned loading / unloading areas can
lead to traffic congestion in the camp area.
196. Employment. The establishment of the facility is likely to increase employment/ business
opportunities along the road-side and periphery of the facility, such as small eateries, tea stalls, pan and
cigarette shops, etc. However, the more enterprising lot would establish such vending stalls, to cater to the
needs of the workers, truckers and others who are dependent on the facility.
197. Benefits of using compost. The finished product from the project, “Organic Manure” shall be
black in color, fine powdery texture. It shall be used as a market commodity due to the following
advantages:
 Increase productivity of soil especially where chemical fertilizers are used discretely since several
decades
 Improves soil texture and structure of both clay and sandy soils
 Increases organic matter (humus) in the soil
 Rectifies the micro nutrient deficiency in the soil
 Increases the water holding capacity of the soil
 Acts as soil conditioner
 Reduces the susceptibility to wind and water erosion
 Increases crop yield
 Increases the uptake of macro and micronutrients by the crops
 Saves the cost of in-organic fertilizers more than 10%
 Maintains soil health
 Balances the pH value of the soil

VII. ENVIRONMENTAL MANAGEMENT PLAN

198. Environmental management is a sustainable way of planning, arranging, supervising, organizing,
and developing the environment so that the preservation of natural resources can be maintained and
impact can be prevented or mitigated. An EMP, also referred to as an impact management plan, is usually
prepared as part of EIA or IEE reporting. It translates recommended mitigation and monitoring measures
into specific actions that will be carried out by the project proponent. Depending upon particular
requirements, the plan may be included in, or appended to, the EIA report or may be a separate document.
The EMP will need to be adjusted to the terms and conditions specified in during project approval stage. It
will then form the basis for impact management during project construction and operation.
199. On the basis of identification of the environmental impacts and recommended mitigation measures
linked with the construction activities of integrated waste management, an EMP has been prepared which
will be followed at the pre-construction, construction and operation stages. A mitigation measure will be
considered as successful when it complies with the Environmental Quality Standards (EQS), policies, legal
requirements set by ADB SPS, 2009 and DoE environmental guidelines and other relevant GoB legal
requirements. In absence of DoE’s own EQS, other relevant international or other recognized
organization’s quality standard will be applied.
A. Objective of the EMP
200. The main objectives of the EMP for the construction and operation of integrated waste
management system are:
i. Identification of the environmental impacts and recommended mitigation and enhancement
measures;
ii. Define the responsibilities of the project proponents in accordance with the three project phases
(design, construction and operation);
iii. Facilitate the implementation of the mitigation measures by providing the technical details of each
project impact;
iv. Define a monitoring mechanism and identify monitoring parameters to ensure that all proposed
mitigation measures are completely and effectively implemented;
v. Identify training requirements at various levels and provide a plan for the implementation of training
sessions;
vi. Providing a cost estimate for all proposed EMP actions.
B. Environmental Monitoring Plan
201. The environmental monitoring is important for assessing the baseline environmental quality and
during the construction and operation of the project. The monitoring plays vital role to assess the
deterioration of environmental quality and extent of implementation of the mitigation measure. It plays a
judgmental role about the efficacy of the implementation.
202. The main objectives of the pre-construction, construction and operation phase monitoring plans
will be to:
I. Monitor the actual impact of the works on physical, biological and socioeconomic receptors within
the subproject site;
II. Recommend mitigation measures for any unexpected impact or where the impact level exceeds;
III. Ensure compliance with legal and community obligations including safety on construction sites;
IV. Monitor the rehabilitation and the restoration of construction campsites as described in the EMP;
V. Evaluate the effectiveness of the mitigation measures proposed in the EMP and recommend
improvements, if and when, necessary
203. The compliance monitoring will be conducted in accordance with the environmental mitigation
measures and monitoring plan provided with this report (Table VII.1 and Table VII.2). Aspects to be
monitored are as follows:
204. Pre-construction phase: Compliance monitoring during the pre-construction comprises:

 Checking that the project’s design incorporates appropriate measures to avoid or minimize
negative impacts.
 Incorporation of appropriate protective clauses in the contract documents that will be obliged by
contractors.
205. Construction phase: To ensure environmental safety the following parameters should be
observed to ensure the efficiency of mitigation measures:
 Contractor’s compliance to the environmental issues in their day-to-day activities.
 Air quality will be monitored once by direct measurement of sensitive air pollution parameters like
particulate matters (PM10, PM2.5), SPM and SO2.
 Noise will be monitored during regular construction procedures. Hearing protection means will be
provided to personnel when noise cannot be avoided or controlled.
 Chemical and microbiological tests will be carried out on surface and groundwater samples to
determine the requirement.
 Collection, transportation and disposal of solid waste of construction site and camp will be
monitored.
 Inexperience coupled with unawareness of mechanical and electrical equipment to be used during
the construction phase can cause injuries to the workers.
 Health and safety training program will be developed for the awareness of workers for handling of
emergency situations.
 Provision of first aid facilities and use of personal protection devices like helmets, ear plugs and
safety boots will be ensured. Entry of persons not wearing the protection devices within the
construction site will not be allowed.
206. Operation phase: The contractor for 1st two-years of O&M will compile and maintain the
environmental data and records gathered during the construction phase for reference during the operation
phase. The contractor will coordinate with DPHE, for monitoring with respect to water quality, leachate
quality and compost quality etc.
 The contractor in collaboration with the concerned department will organize monitoring of surface,
groundwater quality and necessary measures will be taken to keep them within the limits set by
government.
 The contractor in collaboration with the concerned department will organize monitoring of leachate
and compost quality and necessary measures will be taken to keep them within the limits set by
government.
 The contractor will monitor any activity of the nearby residents (such as disposal of waste etc.),
which affects the environment, will be brought to the knowledge of the competent authority for
necessary action.
C. Components to be Monitored
207. Monitoring has two components:

I. Compliance monitoring, which checks whether prescribed actions have been carried out, usually
by visual observation and by the use of checklists.
II. Effects monitoring which records the beneficial and adverse consequences of activities on the
biophysical and social environment. This is often by repeat measurements of a set of objectively
verifiable indicators.
208. Monitoring for this project will concentrate on compliance monitoring to ensure that measures are
being implemented on time and according to sound environmental principles.
D. Contractor’s Environmental Management Plan
209. During construction, contractor will be guided by its detailed CEMP. This shall be based on the
subproject’s EMP with details on staff, resources, implementation schedules, and monitoring procedures.
The agreed CEMP will be the basis for monitoring by PMU and supervision consultant. Inclusion in

construction contract documents the provisions requiring the contractor to submit a CEMP is important
since the contractor will be legally required to allocate a budget for mitigation measures implementation.
The CEMP will allow PMU construction supervision engineer to focus on what are specific items expected
from the contractor regarding environmental safeguards on a day-to-day basis. With the CEMP, PMU can
easily verify the associated environmental requirements each time the contractor will request approval for
work schedules.

Table VII.1: Environmental Management and Monitoring Plan – Pre Construction, Construction and O&M Phase
Cost and Responsibility

Project Activity/ Monitoring Frequency of
Impacts Mitigation Measures Source of
Field Indicator Monitoring Implementation Supervision
Funds
1. Pre-Construction Phase
1.1 Location Nearby community may IWMF sites should be selected in such a way Final design Prior to award No Consultant PMU
impacts of be affected due to that nearby community may have no or drawings of contract additional
IWMF increased pollution minimum impact such as dust, noise and cost required
during construction and access limit at construction phase and air
operation. emission and odour during operation phase due
to proposed works.
 Manual emptying will  Provision of vacuum trucks with pump and Final design Prior to award No Consultant PMU
1.2 Collection
affect public health. hose are considered in the design for drawings of contract additional
system of faecal
 Collection may impede motorized collection system. cost required
sludge
in the inaccessible hilly  Long hose pipe is considered to cover the pits
area. located in the inaccessible hilly area.
 Spillage may occur  Chemical disinfectant has been considered to
during sludge use for the spillage if happen during sludge
collection could affect collection.
public health and  Solid content is lesser than liquid identified in
environmental the faecal sludge generated in the camp. A
problems. long spade or jetted with a water hose should
 Cannot pump thick, be used for compacted layers of the sludge.
dried sludge at the
bottom of the pits.
 Spillage occur during  Chemical disinfectant has been considered to Final design Prior to award No additional Consultant PMU
1.3 Transportation
system of the transportation could be use on the spillage if occur during drawings of contract cost required
sludge affect public health and transportation.
environmental  Vacuum trucks should be checked daily basis
problems. before operation.
 Traffic accident may  The speed limit of the trucks will be restricted
increase due to to 20 km/hr;
frequent movement of  A well-defined schedule and route will be
vacuum trucks in followed by the sludge carrying trucks;
camp.  A proper traffic management plan should be
implemented to mitigate adverse impacts;


Funds
 Traffic congestion may
happen due to random
parking of the trucks.
1.4 Natural IWMF location is  Highest flood level has been considered in Final design Prior to award No additional Consultant PMU
calamities adjacent to a narrow the design. drawings of contract cost required
water channel, thus,  Planning of IWMF at a suitable elevation
there is a threat of above high flood level (utilizing accurate
inundation during topographic survey).
monsoon.
1.5 Sources of Extraction of materials  Prioritize sites which already permitted by  List of approved During No additional Contractor PMU,
materials can disrupt natural land the authority. quarry sites and implementatio cost required Consultant
contours and vegetation  If other sites are necessary, it is contractor’s sources of n phase, as
resulting in accelerated responsibility to verify the suitability of all materials; necessary
erosion, disturbance in material sources and to obtain the approval  Bid document to with
natural drainage of PMU and consultants. include discussion
patterns, ponding and  If additional quarries will be required after requirement for with PMU,
water logging, and water construction is started, construction verification of Consultant
pollution. contractor to obtain a written approval from suitability of
PMU. sources and
permit for
additional
quarry sites if
necessary.
1.6 Testing of To generate the Undertake baseline quality tests of air, noise,  Air quality- Before start of Included in Contractor PMU,
environmental baseline data to protect water in the subproject site to serve as PM10, PM2.5, construction civil works through a Consultant
quality (Air, noise, the environment of the benchmark for subsequent monitoring. COx, NOx, SOx. contract nationally
surface & subproject area.  Noise level in recognized
groundwater Leq (dB).
quality) laboratory
 Surface water
quality Test
Report (pH, EC,
TSS, DO, BOD,
COD, Total N,
Total P, TC,
FC).


Funds
 Groundwater
quality Test
Report (pH,
TDS, Chloride,
As, Fe, Mn, S,
TC, FC)
1.7 Permits, Failure to obtain  Obtain NOC from DC, Cox’s Bazar for the Incorporated in Prior to award No additional Consultant PMU
clearances, no necessary permits and government land and take the permit from final design and of contract cost required
objection NOCs, etc. can result to RRRC for the camp access prior to start of communicated to
certificate (NOC) design revisions and/or civil works. contractors.
 Acknowledge in writing and provide report on
etc. stoppage of works.
compliance all obtained permits, clearance,
NOCs, etc.
 Include in detailed design drawings and
documents all conditions and provisions if
necessary.
1.8 Updating of Expecting minor  Update IEE and EMP during implementation Final IEE and EMP Upon No additional
Contractor, PMU
IEE and CEMP impacts, during if required. reviewed, completion of cost required
Consultant
construction period only  Ensure updated EMP is provided to approved and layout plan by
and mitigation measures contractor disclosed contractor
are addressed.  Relevant information disclosed.
1.9 EMP Irreversible impact to the Project manager and all key workers of (i) Proof of Before start of Cost of EMP Consultant PMU
implementation environment, workers, contractors will be required to undergo EMP completion construction Implementati
training and community implementation including spoils management, (Safeguards on
Standard operating procedures (SOP) for Compliance Orientation
construction works; health and safety (H&S), Orientation) Training to
core labor laws, applicable environmental laws, (ii) Posting of EMP contractor is
etc. at worksites responsibility
of PMU and
Consultant.
2. During Construction Phase
2.1 Physical and Construction works will  Stop work immediately to allow further Records of chance Visual Included in Contractor Consultant,
Cultural Heritage be on existing Rohingya investigation; finds inspection by civil works PMU
camp, thus risk for  Prevent workers or any other persons from PMU and contract
chance finds is low. removing and damaging of archaeological supervision
remains. consultants


Funds
on monthly
basis
2.2 Excavations Potential erosion, dust  The excavated earth shall always be Contractor’s safety Inspection by Included in Contractor Consultant,
generation, accident/ dumped on the designated areas to be and security PMU and civil works PMU
dropping small children reused as needed. program; Location supervision contract
on open trench. The  In the event that excavations are to be kept of stockpiles; consultants
impacts are negative but open overnight, lights, high visibility warning Number of on monthly
short-term, site-specific signs, and barricades shall be provided. complaints from basis;
within a relatively small stakeholders;
area and reversible by
2.3 Access road  Impact of dust from  Damp down exposed soil and any sand Number of Once in a Included in Contractor Consultant,
construction work transportation on stockpiled on site by spraying with water complaints from week during Civil works PMU
surrounding during dry weather; stakeholders construction; contract
residents;  Use tarpaulins to cover soils, sand and other regarding access; Air and noise
 Temporary increase loose material when transported by trucks. Record of watering level
in noise level;  Monitor noise levels. Maintain maximum schedule; monitoring;
 Tree felling; sound levels not exceeding 80 decibels Air and noise once during
 Potential top soil (dBA) when measured at a distance of 10 m monitoring report; construction;
erosion; or more from the vehicle/s. Visual
 Construction works  Highest efforts will be necessary to avoid inspection by
will impede the tree cutting. If unavoidable at least two trees PMU and
access of residents will be planted for every tree cut. supervision
and businesses in  Topsoil storage areas must be protected consultants
limited cases. during the dry season, wind erosion—by on monthly
covering. basis.
 Formulate traffic direction, diversion and
temporary access plans, setting up sufficient
traffic direction signs.
 Warning lights should be set up along the
construction road sections, guiding the
access of vehicles.
2.4 Waste Oil, grease etc. from  Prepare and implement waste management Complaints from As work Included in Contractor Consultant,
management construction machinery; plan approved by PMU. community; progresses civil works PMU
Hazardous and solid  Wastes must be placed in the designated Regular inspection contract
waste from waste bins which must be regularly emptied. These of waste
shall remain within demarcated areas and


Funds
construction material shall be designed to prevent wastes from management
and food; being blown out by wind. activity;
Kitchen and sewage  Recycling is to be encouraged by providing Waste disposal
wastes from labour separate receptacles for different types of record.
camp will cause growth wastes and making sure that staff is aware
of flies and water born of their uses.
germs. The impacts are  All waste must be removed from the site and
negative but short-term, transported to a disposal site.
site-specific within a
relatively small area and
reversible by mitigation
measures.
2.5 Water quality Trenching and  Prepare and implement a waste (i) Areas for Water quality Included in Contractor Consultant,
(surface and excavation, run-off from management plan. stockpiles, storage test once in Civil works through a PMU
groundwater) stockpiled materials,  Every effort shall be made to ensure that any of fuels and construction contract nationally
and chemical chemicals or hazardous substances do not lubricants and period recognized
contamination from fuels contaminate the soil or water on-site. waste materials; laboratory
and lubricants may  Care must be taken to ensure that runoff (ii) Records of
result to silt-laden runoff from vehicle or plant washing does not enter water quality
during rainfall which the surface/ground water. inspection; Water
may cause siltation and  Site staff shall not be permitted to use any Quality Test
reduction in the quality stream, river, other open water body, or (National Drinking
of adjacent bodies of natural water source adjacent to or within the Water Quality
water. The impacts are designated site for the for disposing wastes. Standard
negative but short-term,  All concrete mixing must take place on a Parameters);
site-specific within a designated, impermeable surface.
relatively small area and  All substances required for vehicle For surface water
reversible by mitigation maintenance and repair must be stored in quality
measures. sealed containers until they can be disposed parameters: pH,
of from the site. EC, TSS, DO,
 Hazardous substance/ materials is to be BOD, COD, Total
transported in sealed containers or bags. N, Total P, TC, FC.
 Monitor water quality according to the
For groundwater
environmental management plan.
quality


Funds
parameters: pH,
TDS, Chloride, As,
Fe, Mn, S, TC, FC.
(iii) No visible
degradation to
nearby drainages,
khals or water
bodies due to
construction
activities
2.6 Soil The construction  Precautions to be taken at any time of year Complaints from As work Included in Contractor Consultant,
disturbance activities may cause soil when rainstorms are likely, actions to be community; progresses civil works PMU
degradation problems in taken when a rainstorm is imminent or Vegetation cover; contract
the areas of IWMF etc. forecast, and actions to be taken during or No visible
after rainstorms shall be developed by the degradation to
Contractor. nearby drainages,
 Slope protection measures through turfing; khals or water
 The earthwork sites where exposed land bodies due to soil
surface is vulnerable to runoff shall be erosion.
consolidated and/or covered.
 The material stockpile sites shall be far away
from surface water bodies and areas prone
to surface run-off. Loose materials shall be
bagged and covered.
 Channels, earth bunds, netting, tarpaulin
and or sand bag barriers shall be used on
site to manage surface water runoff and
minimize erosion.
 The overall slope of the works areas and
construction yards shall be kept to a
minimum to reduce the erosive potential of
surface water flows.
2.7 Air Quality Air pollution due to  Water spraying for dust control; Location of Air quality test Included in Contractor Consultant,
construction activities.  Construction materials with potential for stockpiles; once in civil works through a PMU
The impacts are significant dust generation shall be covered; construction contract nationally
negative but short-term,  No smoke belchers equipment; and period.


Funds
impacts within a  Limiting speed of construction vehicles in Number of recognized
relatively small area and access roads and work sites to maximum of complaints from laboratory
reversible by mitigation 30 kph. stakeholders;
measures. Records of air
quality inspection;
Air quality test
report (PM10
PM2.5, SPM and
SO2)
2.8 Noise Level Construction activities  Consultation with affected people; not to Number of Inspection by Included in Contractor Consultant,
will be on settlements. operate noisy equipment during night time complaints from PMU and civil works through a PMU
Temporary increase in (22:00 – 06:00); stakeholders; Use supervision contract nationally
noise level may be  Sound suppression for equipment; of silencers in consultants recognized
caused by excavation  Ear protection for workers. noise-producing on monthly laboratory
equipment, and the  Conduct noise quality monitoring as per equipment and basis;
transportation of EMP. sound barriers;
equipment, materials Noise Quality,
and people. The impact Equivalent Sound
is short-term and within Pressure Level
a relatively small area
and reversible by
2.9 Biodiversity Haphazard site clearing,  Plantation will be done at the ratio of 1 (cut): PMU to report in Visual Included in Contractor Consultant,
protection parking and movement 2(new planting) for each tree felling. writing the number inspection by civil works PMU
of construction vehicles  No trees, shrubs, or groundcover will be of trees cut and PMU and contract
and equipment, removed or vegetation stripped without the planted twice; supervision
stockpiling, and Illegal prior permission of the environmental Number of consultants
unnecessary loss of specialist; complaints from on monthly
vegetation beyond  While clearing vegetation it must be ensured stakeholders on basis
subproject footprints. that no wildlife injure and/or die. disturbance of
There are no protected  Harming and/or killing of any types of wildlife vegetation,
areas in or around by the workers of the project must be poaching, fishing,
subproject sites, and no prohibited. etc.
known areas of
ecological interest.


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2.10 Socio- Manpower may be  Employ at least 50% of labor force from (i) Employment (i) Visu Included in Contractor Consultant,
economic status employed from local communities in the vicinity of the site. This will records; al inspection civil works PMU
community as per have the added benefit of avoiding social (ii) Records of by PMU and contract
guideline of RRRC problems that sometimes occur when compliance to supervision
during the construction workers are imported, and avoiding Bangladesh Labor consultants
and operation stage. environmental and social problems from Law and other on monthly
Thus potential impact is workers housed in poorly serviced camp applicable basis
positive and long-term. accommodation. standards.
 Secure construction materials from local
market.
2.11 Provision of Inconvenience to the  Provide suitable housing, adequate supplies Site-specific H&S Visual Included in Contractor Consultant,
Worker Facilities communities due to of potable water, and toilet and bathing Plan; inspection by civil works PMU
presence of workers; facilities within the housing area. Onsite Records of supply PMU and contract
facilities for preparing food need to be of uncontaminated supervision
Solid waste and sanitary provided, or food service contracted; water; consultants
discharges from worker  Provide means for disposing of wastewater Record of H&S on monthly
camps. from toilets, baths and food preparation areas orientation basis
either through a septic tank and soakaway, or trainings;
holding tank with removal by vacuum truck. Condition of
 Solid waste should be collected at waste bins sanitation facilities
and disposed of properly offsite. for workers
2.12 Worker Occupational hazards (i) Government of Bangladesh Labor Law and (I) Site-specific Visual Included in Contractor Consultant,
Health and Safety which can arise during all applicable laws and standards on workers H&S Plan inspection by civil works PMU
work. Potential impacts H&S. (ii) Equipped first- PMU and contract
are negative and long- (ii) Ensure that all site personnel have a basic aid stations (iii) supervision
term but reversible by level of environmental awareness training. If Insurance consultants
mitigation measures. necessary, the environmental safeguard coverage for on monthly
specialist will help further capacity building. workers (iv) basis
(iii) Produce and implement a site health and Number of
safety (H&S) plan which include measures as: accidents (v)
(i) excluding the public from worksites; (ii) Records of supply
ensuring all workers are provided with and of uncontaminated
required to use personal protective equipment water
(reflectorized vests, footwear, gloves, goggles
and masks) at all times; (iii) providing (H&S)


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training for all site personnel; (iv) documenting (vi) Condition of
procedures to be followed for all site activities; eating areas of
and (v) maintaining accident reports and workers
records. (vii) Record of
(iv) Arrange for readily available first aid unit H&S orientation
including an adequate supply of sterilized trainings
dressing materials and appliances. (viii) Use of
(v) Provide Insurance coverage for workers; personal
(vi) Provide H&S orientation training to all new protective
workers to ensure that they are apprised of the equipment
basic site rules of work at the site, personal (ix) % of moving
protective protection, and preventing injuring to equipment
fellow workers; outfitted with
(vii) Ensure the visibility of workers through their audible back-up
use of high visibility vests when working in or alarms
walking through heavy equipment operating (x) Permanent
areas; sign boards for
(viii) Ensure moving equipment is outfitted with hazardous areas
audible back-up alarms; (xi) Signages for
(ix) Disallow worker exposure to noise level storage and
greater than 85 dBA for a duration of more than disposal areas
8 hours per day without hearing protection. The (xii) Condition of
use of hearing protection shall be enforced sanitation facilities
actively. for workers
2.13 Community Construction works will  Adequate lighting, temporary fence, (i) Number of Visual Included in Contractor Consultant,
health and safety impede the access of reflectorized barriers and signage at active permanent inspection by civil works PMU
some residents in work sites; signage, PMU and contract
limited cases. The  Contractor’s activities and movement of staff barricades and supervision
impacts are negative but will be restricted to designated construction flagmen on consultants
short-term, site-specific areas. worksite; on monthly
within a relatively small  Contractor’s preparedness in emergency (ii) Number of basis
area and reversible by response; complaints from
mitigation measures.  PAPs need to be made aware of the stakeholders.
existence of the complaints book and the (iii) Agreement
methods of communication available to between
them. The contractor must address queries landowner and
contractors in case


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and complaints by: (i) documenting details of of using private
such communications; (ii) submitting these lands as work
for inclusion in complaints register; (iii) camps, storage
bringing issues to the environment areas, etc.
management specialist’s attention
immediately; and (iv) taking remedial action
as per environment management specialist’s
instruction.
 Adequate dissemination of the GRM and
Contractor’s observance/implementation of
the GRM.
2.14 Submission Unsatisfactory  Appointment of contractor’s supervisor to Availability and Monthly Included in Contractor Consultant,
of EMP compliance to EMP ensure EMP implementation; competency of monitoring civil works PMU
Implementation  Timely submission of monitoring reports appointed report to be contract
Report including pictures supervisor by submitted by
contractor; contractor to
Monthly report by consultant
contractor and and
consultant. consultant to
PMU;
PMU to
submit semi-
annual
monitoring
report to ADB.
2.15 Site Damage due to debris,  Remove all spoils wreckage, rubbish, or PMU report in Prior to turn- Included in Contractor Consultant,
reinstatement spoils, excess temporary structures which are no longer writing that (i) over of civil works PMU
construction materials required; worksite is completed contract
 The area that previously housed the restored to original works
construction worker shed is to be checked for conditions; (ii)
spills of substances such as oil, paint, etc. worker shed has
and these shall be cleaned up. been vacated and
 The contractor must arrange the cancellation restored to pre-
of all temporary services. project conditions;
 Request PMU to report in writing that (iii) all construction
worksites and camp have been vacated and related structures


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restored to pre-project conditions before not relevant to
acceptance of work. O&M are
removed; and (iv)
worksite clean-up
is satisfactory.
3. Operation and Maintenance (O&M) Phase
3.1 Health and Risk of health of workers  Provide all the personal protective  Regular Regular Included in
Contractor DPHE
safety risk of working in IWMF equipment like gum boots, nose mask, inspection and monitoring O&M cost
workers operation and gloves etc. for the protection of workers. testing of all weekly at
maintenance, workers  The workplace will be equipped with fire safety features IWMF.
may suffer infectious detectors, alarm systems and fire-fighting and hazard
diseases due to faecal equipment. The equipment will be control
matters. periodically inspected and maintained in measures and
good working condition. personal
 Providing adequate personnel facilities, protective
including washing areas and areas to features;
change clothes before and after work.  Ensure proper
 Medical check-up will be conducted on training of newly
regular basis and the health conditions will deployed
be monitored. worker.
 First aid facilities required to attend  Record of
immediately for meeting emergency regular health
situations will be made available at the check-up for the
facility. epidemic
 Maintaining good housekeeping in waste disease and
processing and storage areas. illness of related
workers.
3.2 Efficient Inefficient working of  Procedure for each step of operation shall be  Check the Regular Included in
Contractor DPHE
working of IWMF IWMF may cause poor documented and all workers/operators shall IWMF regularly. monitoring O&M cost
quality of treatment and be trained on the proper operation of each  Record of daily at IWMF.
resulting under component of the IWMF, including the proper regular
treatment of waste water desludging procedure for septic tanks. inspection at
and sludge and may  Although impact is likely to be minimal due to IWMF.
cause environment, new and well-designed efficient system, it  Proper training
health and safety risk to to the operator.


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workers and must be ensured that the facility is operating
environment. properly at all times.
3.3 Water quality Run-off from IWMF  Take all precautions to prevent entering of  No visible  Regular Included in
Contractor DPHE
which may cause run-off into streams, watercourses or degradation to visual O&M cost through a
reduction in the quality irrigation system. nearby water inspection nationally
of adjacent water body  Quality of leachate shall be regularly bodies. for drains recognized
and groundwater. The monitored to ensure that leachate quality  Complaints and water laboratory
impacts are negative but complies with the prescribed effluent from bodies
short-term and in small standards (chemical and biological). communities. within 30m
area and reversible by  Quality of water shall be regularly monitored  Effluent quality: circumfere
mitigation measures. to ensure that water quality complies with the pH, nce of the
DOE standards. Temperature, facilities.
TSS, DO, BOD,  For effluent
COD, Nitrate, and
Phosphate, TC, leachate:
FC. Twice/yr in
 Treated 1st year and
Leachate: pH, once/ yr
SS, TDS, BOD, over 2
COD, As, C/N, years.
Cl.  For SW
 For surface and GW:
water quality Twice/yr in
parameters: pH, 1st year and
EC, TSS, DO, once/ yr
BOD, COD, over 2
Total N, Total P, years.
TC, FC.
 For
groundwater
quality
parameters: pH,
TDS, Chloride,
As, Fe, Mn, S,
TC, FC.


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3.4 Biodiversity  Ensure the survival  Monitor survival of replanted trees (also  Survival rate of Vegetation Included in
Contractor DPHE
rate of planted trees. compensatory planting) and replant, as vegetation. monitoring to O&M cost
 Release of ill‐treated necessary.  No visible be
black water onto water  Prevent workers or any other person from degradation to implemented
courses may cause removing and damaging any flora (plant/ nearby water until trees is 2
eutrophication and vegetation) and fauna (animal). bodies. m high.
harm aquatic species.  Quality of discharge shall be regularly
monitored to ensure that effluent quality
complies with the prescribed effluent
standards (chemical and biological).
3.5 Air emission Odour generation for the  Frequently monitor performance of the  Complaints Daily Included in
Contractor DPHE
and odour IWMF may cause health IWMF to ensure that clogging is remedied as from inspection at O&M cost through a
risk to the worker and soon as possible; communities. IWMF. nationally
community.  Keep the immediate surrounding of the recognized
IWMF tidy. laboratory
3.6 Reuse and Environmental hazard  Compost shall be used as soil conditioner to  Health condition Twice/yr in 1st Included in
Contractor DPHE
disposal of and health risk to enhance soil fertility in nearby farms. of farmers of year and O&M cost through a
compost workers and other  If reuse is not feasible safe disposal should that agricultural once/ yr over nationally
people. be ensured for treated effluent and sludge. land. 2 years. recognized
 Quality of compost shall be regularly  Regular visual laboratory
monitored to ensure that compost quality inspection at
complies with the standards. disposal site;
 Compost quality
to meet
standards for
pH, As, Cd, Cr,
Cu, Pb, Hg, Ni,
Zn, C/N ratio.
 Monitoring the
documentation
of the test
result.
3.7 Traffic  Vacuum trucks  A well-defined schedule and route will be  Check the Regular Included in
Contractor DPHE
management carrying trucks will be followed by the waste carrying trucks; vehicle pool. monitoring O&M cost


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plying to the facility  Proper signage will put up near the proposed  Record of weekly at
from the camps. This facility giving route directions; regular vehicle pool.
may lead to increase  Vehicles will be parked inside the facility inspection.
in traffic accident. premises in the designated slots;  Proper training
 Random parking of  Entry and exit routes from the premises will to the driver.
vehicles and be clearly marked;  Record of
unplanned loading /  Adequate lighting and reflective boards will accidents/incid
unloading areas can be put up for night time safety; ents.
lead to traffic  A proper traffic management plan will be
congestion. implemented to mitigate adverse impacts;
 All routes will be planned to cause minimal
disturbance to local community;
 The vehicles will be allowed to move in the
site only through dedicated entry and exit
points within the site;
 Dedicated parking area will be provided in
the facility for parking of vehicles;
 The speed limit of vehicles will be restricted
to 20 km/hr;
3.8 Socio-  Visual impacts.  Good waste handling practices will be  Regular Weekly Included in
Contractor DPHE
economic aspect  Impacts on implemented which will greatly reduce foul inspection at monitoring. O&M cost
community health. smell and reduce impact from odours; IWMF site.
 Employment.  Vehicles moving through community roads  Proper training
will be covered and the operations will be to the driver.
restricted to day time;  Record of
 Maximum efforts will be made to provide job awareness
opportunities to local residents during campaign.
construction and operation phase.
 Awareness campaigns should be organized
emphasizing the need of sorting at source,
waste collection and participatory role of
residents in waste management in an area.

Table VII.2: Environmental Management and Monitoring Plan- Pre Construction, Construction and O&M Phase for Camp 23 in Shamlapur
Project Activity/ Frequency of
Impacts Mitigation Measures Monitoring Indicator Source of
Field Monitoring Implementation Supervision
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1. Pre-Construction Phase
1.1 Permits, Failure to obtain  Obtain NOC from Cox’s Bazar DC Incorporated in final Prior to award No additional
clearances, no necessary permits and design and of contract cost required Consultant PMU
office for the khas land and take the
objection NOCs, etc. can result to permit from RRRC for the camp communicated to
certificate (NOCs) design revisions and/or access prior to start of civil works. contractors.
etc. stoppage of works.  Acknowledge in writing and provide
report on compliance all obtained
permits, clearance, NOCs, etc.
 Include in detailed design drawings
and documents all conditions and
provisions if necessary.
1.2 Sources of Extraction of materials  Prioritize sites which already  List of approved During No additional
materials can disrupt natural land implementatio cost required Contractor Consultant
permitted by the authority. quarry sites and
contours and vegetation n phase, as and PMU
 If other sites are necessary, it is sources of materials;
resulting in accelerated contractor’s responsibility to verify  Bid document to necessary with
erosion, disturbance in the suitability of all material sources include requirement discussion with
natural drainage and to obtain the approval of PMU for verification of PMU,
patterns, ponding and and consultants. suitability of sources Consultant
water logging, and water  If additional quarries will be required and permit for
pollution. after construction is started, additional quarry
construction contractor to obtain a sites if necessary.
written approval from PMU.
1.3 Natural The dry and maturity  Highest flood level has been Final design drawings Prior to No additional
calamities (Flood, shed will be located award of cost required Consultant PMU
considered in the design.
Tidal surges) close to the river  Planning of solid water management contract
(approx. 60m) which is facility at a suitable elevation above
connected to the sea the current high tide level (utilizing
therefore, there is a accurate topographic survey).
threat of inundation due
to river flooding and tidal
surge.
1.4 Testing of To generate the Undertake baseline quality tests of air,  Air quality- PM10, Before start of Included in civil
environmental baseline data to protect noise, water in the subproject site to construction works contract Contractor Consultant
PM2.5, Cox, NOx,
quality (Air, noise, the environment of the serve as benchmark for subsequent through a and PMU
SOx.
surface & subproject area. monitoring. nationally
 Noise level in Leq
groundwater recognized
(dB).
quality) laboratory
 Surface water quality
Test Report (pH, EC,


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TSS, DO, BOD, COD,
Total N, Total P, TC,
FC).
 Groundwater quality
Test Report (pH,
TDS, Chloride, As,
Fe, Mn, S, TC, FC)
1.5 Updating of Expecting minor  Update IEE and EMP during Final IEE and EMP Upon No additional
IEE and EMP impacts, during reviewed, approved and completio cost required Contractor Consultant
implementation if required
construction period only disclosed n of layout and PMU
 Ensure updated EMP is provided to
and mitigation measures contractor plan by
are addressed.  Relevant information disclosed contractor
1.6 EMP Irreversible impact to the  Project manager and all key workers (i) Proof of completion Before start of Cost of EMP
implementation environment, workers, (Safeguards construction Implementation Consultant PMU
of contractors will be required to
training and community undergo EMP implementation Compliance Orientation
including spoils management, Orientation) Training to
Standard operating procedures (ii) Posting of EMP at contractor is
(SOP) for construction works; health worksites responsibility of
and safety (H&S), core labor laws, PMU and
applicable environmental laws, etc. Consultant.
2. During Construction Phase
2.1 Physical and Construction works will Stop work immediately to allow further Records of chance finds Visual Included in civil
Cultural Heritage be on existing Rohingya investigation; Prevent workers or any inspection by works contract Contractor Consultant
camp, thus risk for other persons from removing and PMU and and PMU
chance finds is low. damaging of archaeological remains. supervision
consultants on
monthly basis
2.2 Excavations Potential erosion, dust  The excavated earth shall always be Contractor’s safety and Inspection by Included in civil
generation, accident/ security program; PMU and works contract Contractor Consultant
dumped on the designated areas to
dropping small children Location of stockpiles; supervision and PMU
be reused as needed.
on open trench. The  In the event that excavations are to Number of complaints consultants on
impacts are negative but be kept open overnight, lights, high from stakeholders; monthly basis;
short-term, site-specific visibility warning signs, and
within a relatively small barricades shall be provided.
area and reversible by
2.3 Waste Oil, grease etc. from  Prepare and implement waste Complaints from As work Included in civil
management construction machinery; community; progresses works contract Contractor Consultant
management plan approved by
Hazardous and solid and PMU
PMU.
waste from waste


Funds
construction material  Wastes must be placed in the Regular inspection of
and food; designated bins which must be waste management
Kitchen and sewage regularly emptied. These shall activity;
wastes from labour remain within demarcated areas and Waste disposal record.
camp will cause growth shall be designed to prevent wastes
of flies and water born from being blown out by wind.
germs. The impacts are  Recycling is to be encouraged by
negative but short-term, providing separate receptacles for
site-specific within a different types of wastes and making
relatively small area and sure that staff is aware of their uses.
reversible by mitigation  All waste must be removed from the
measures. site and transported to a disposal
site.
2.4 Water quality Mobilization of settled  Prepare and implement a waste (ii) Areas for Water quality Included in
(surface and silt materials, run-off stockpiles, storage of test once in Civil works Contractor Consultant
management plan.
groundwater) from stockpiled fuels and lubricants and construction contract through a and PMU
 Every effort shall be made to ensure
materials, and Chemical waste materials; period nationally
that any chemicals or hazardous
contamination from fuels (ii) Records of water recognized
substances do not contaminate the
and lubricants during quality inspection; laboratory
soil or water on-site.
construction works can  Avoid stockpiling of earth fill Water Quality Test
contaminate nearby especially during the monsoon (National Drinking
surface water quality. season unless covered by tarpaulins Water Quality Standard
The impacts are or plastic sheets; Parameters);
negative but short-term,  Site staff shall not be permitted to use (iii) No visible
site-specific within a the river and other open water body degradation to nearby
relatively small area and for disposing wastes. drainages, khals or
reversible by mitigation  All concrete mixing must take place water bodies due to
measures. on a designated, impermeable construction activities.
surface. (iv) For surface water
 Place storage areas for fuels and quality parameters: pH,
lubricants away from any drainage EC, TSS, DO, BOD,
leading to water bodies COD, Total N, Total P,
 All substances required for vehicle TC, FC.
maintenance and repair must be (v) For groundwater
stored in sealed containers until they quality parameters: pH,
can be disposed of removed from the TDS, Chloride, As, Fe,
site. Mn, S, TC, FC.
 Hazardous substance/ materials is to
be transported in sealed containers
or bags.


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 Monitor water quality according to
the environmental management
plan.
2.5 Soil The construction  Precautions to be taken at any time Complaints from As work Included in civil
disturbance activities may cause soil community; progresses works contract Contractor Consultant
of year when rainstorms are likely,
degradation problems in Vegetation cover; and PMU
actions to be taken when a rainstorm
the areas of IWMF etc. is imminent or forecast, and actions No visible degradation
to be taken during or after rainstorms to nearby drainages,
shall be developed by the Contractor. khals or water bodies
 Slope protection measures through due to soil erosion.
turfing;
 The earthwork sites where exposed
land surface is vulnerable to runoff
shall be consolidated and/or
covered.
 The material stockpile sites shall be
far away from surface water bodies
and areas prone to surface run-off.
Loose materials shall be bagged and
covered.
 Channels, earth bunds, netting,
tarpaulin and or sand bag barriers
shall be used on site to manage
surface water runoff and minimize
erosion.
 The overall slope of the works areas
and construction yards shall be kept
to a minimum to reduce the erosive
potential of surface water flows.
2.6 Air Quality Dust and emissions Water spraying for dust control; Location of stockpiles; Air Quality: Included in civil
from construction construction materials with potential for Number of complaints PM10 PM2.5, works contract Contractor Consultant
activity may degrade the significant dust generation shall be from stakeholders; SPM and SO2 through a and PMU
air quality. The impacts covered; no smoke belchers Records of air quality test once in nationally
are negative but short- equipment; and limiting speed of inspection; Air quality construction recognized
term, impacts within a construction vehicles in access roads test report. period. laboratory
relatively small area and and work sites to maximum of 20 kph.
measures.


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2.7 Noise Level Construction activities  Consultation with affected people; Number of complaints Inspection by Included in civil
will be on settlements. from stakeholders; Use PMU and works contract Contractor Consultant
not to operate noisy equipment
Temporary increase in of silencers in noise- supervision through a and PMU
during night time (22:00 – 06:00);
noise level may be producing equipment consultants on nationally
 Sound suppression for equipment;
caused by excavation and sound barriers; monthly basis; recognized
 Ear protection for workers. laboratory
equipment, and the  Conduct noise quality monitoring as Noise Quality,
transportation of per EMP. Equivalent Sound
equipment, materials Pressure Level
and people. The impact
is short-term and within
and reversible by
2.8 Biodiversity Teknaf Wildlife  Plantation will be done at the ratio of Number of complaints Visual Included in civil
Sanctuary is located from stakeholders on inspection by works contract Contractor Consultant
1 (cut): 2(new planting) for each tree
about 2km away from disturbance of PMU and and PMU
felling.
the subproject sites,  No trees, shrubs, or groundcover will vegetation, poaching, supervision
thus illegal hunting may be removed or vegetation stripped fishing etc. consultants on
occur and pose the without the prior permission of the monthly basis
threat to wild animals. environmental specialist;
 Harming and/or killing of any types of
wildlife by the workers of the
subproject must be prohibited.
2.9 Socio- The drying & maturing  DPHE will negotiate with the (i) Record of rental (ii) Visua Included in civil
economic status shed will be located in agreement. l inspection by works contract Contractor Consultant
landowner to purchase/lease the
the private land thus, (ii) Employment PMU and and PMU
required land for the facility.
there is a requirement  Employ at least 50% of labor force records; supervision
for land from communities in the vicinity of the (iii) Records of consultants on
acquisition/requisition. site. This will have the added benefit compliance to monthly basis
Manpower may be of avoiding social problems that Bangladesh Labor Law
employed from local sometimes occur when workers are and other applicable
community as per imported, and avoiding environmental standards.
guideline of RRRC and social problems from workers
during the construction housed in poorly serviced camp
and operation stage. accommodation.
 Secure construction materials from
local market.
2.10 Provision of Inconvenience to the Provide suitable housing, adequate Site-specific H&S Plan; Visual Included in civil
Worker Facilities communities due to supplies of potable water, and toilet and Records of supply of inspection by works contract Contractor Consultant
presence of workers; bathing facilities within the housing uncontaminated water; PMU and and PMU
area. Onsite facilities for preparing food supervision


Funds
Solid waste and sanitary need to be provided, or food service Record of H&S consultants on
discharges from worker contracted; orientation trainings; monthly basis
camps. Provide means for disposing of Condition of sanitation
wastewater from toilets, baths and food facilities for workers
preparation areas either through a
septic tank and soakaway, or holding
tank with removal by vacuum truck.
Solid waste should be collected at
waste bins and disposed of properly
offsite.
2.11 Worker Occupational hazards (I) Comply with requirements of (I) Site-specific H&S Visual Included in civil
Health and Safety which can arise during Government of Bangladesh Labor Law Plan inspection by works contract Contractor Consultant
work. Potential impacts and all applicable laws and standards (ii) Equipped first-aid PMU and and PMU
are negative and long- on workers H&S. stations (iii) Insurance supervision
term but reversible by (ii) Ensure that all site personnel have a coverage for workers consultants on
mitigation measures. basic level of environmental awareness (iv) Number of accidents monthly basis
training. If necessary, the (v) Records of supply of
environmental safeguard specialist will uncontaminated water
help further capacity building. (vi) Condition of eating
(iii) Produce and implement a site areas of workers
specific health and safety (H&S) plan (vii) Record of H&S
which include measures as: (i) orientation trainings
excluding the public from worksites; (ii) (viii) Use of personal
ensuring all workers are provided with protective equipment
and required to use personal protective (ix) % of moving
equipment (reflectorized vests, equipment outfitted with
footwear, gloves, goggles and masks) audible back-up alarms
at all times; (iii) providing (H&S) training (x) Permanent sign
for all site personnel; (iv) documenting boards for hazardous
procedures to be followed for all site areas
activities; and (v) maintaining accident (xi) Signages for
reports and records. storage and disposal
(iv) Arrange for readily available first aid areas
unit including an adequate supply of (xii) Condition of
sterilized dressing materials and sanitation facilities for
appliances. workers
(v) Provide Insurance coverage for
workers;
(vi) Provide H&S orientation training to
all new workers to ensure that they are
apprised of the basic site rules of work


Funds
at the site, personal protective
protection, and preventing injuring to
fellow workers;
(vii) Ensure the visibility of workers
through their use of high visibility vests
when working in or walking through
heavy equipment operating areas;
(viii) Ensure moving equipment is
outfitted with audible back-up alarms;
(ix) Disallow worker exposure to noise
level greater than 85 dBA for a duration
of more than 8 hours per day without
hearing protection. The use of hearing
protection shall be enforced actively.
2.12 Community Construction works will  Adequate lighting, temporary fence, (i) Number of Visual Included in civil
health and safety impede the access of permanent signage, inspection by works contract Contractor Consultant
reflectorized barriers and signage at
some residents in barricades and flagmen PMU and and PMU
active work sites;
limited cases. The  Contractor’s activities and movement on worksite; supervision
impacts are negative but of staff will be restricted to (ii) Number of consultants on
short-term, site-specific designated construction areas. complaints from monthly basis
within a relatively small  Contractor’s preparedness in stakeholders.
area and reversible by emergency response; (iii) Agreement between
mitigation measures.  PAPs need to be made aware of the landowner and
existence of the complaints book and contractors in case of
the methods of communication using private lands as
available to them. The contractor work camps, storage
must address queries and areas, etc.
complaints by: (i) documenting
details of such communications; (ii)
submitting these for inclusion in
complaints register; (iii) bringing
issues to the environment
management specialist’s attention
immediately; and (iv) taking remedial
action as per environment
management specialist’s instruction.
 Adequate dissemination of the GRM
and Contractor’s
observance/implementation of the
GRM.


Funds
2.13 Submission Unsatisfactory  Appointment of contractor’s Availability and Monthly Included in civil
of EMP compliance to EMP competency of monitoring works contract Contractor Consultant
supervisor to ensure EMP
implementation appointed supervisor by report to be and PMU
implementation;
report  Timely submission of monitoring contractor; submitted by
reports including pictures Monthly report by contractor to
contractor and consultant and
consultant. consultant to
PMU;
PMU to submit
semi-annual
monitoring
report to ADB.
2.14 Site Damage due to debris,  Remove all spoils wreckage, rubbish, PMU report in writing Prior to turn- Included in civil
reinstatement spoils, excess that (i) worksite is over of works contract Contractor Consultant
or temporary structures which are no
construction materials restored to original completed and PMU
longer required;
 The area that previously housed the conditions; (ii) worker works
construction worker shed is to be shed has been vacated
checked for spills of substances such and restored to pre-
as oil, paint, etc. and these shall be project conditions; (iii)
cleaned up. all construction related
 The contractor must arrange the structures not relevant
cancellation of all temporary to O&M are removed;
services. and (iv) worksite clean-
 Request PMU to report in writing that up is satisfactory.
worksites and camp have been
vacated and restored to pre-project
conditions before acceptance of
work.
3. Operation and Maintenance (O&M) Phase
3.1 Health and Risk of health of workers  Provide all the personal protective  Regular inspection Weekly Included in
safety risk of during operation and monitoring. O&M cost Contractor DPHE
equipment like gum boots, nose and testing of all
workers maintenance, workers mask, gloves etc. for the protection of safety features and
may suffer infectious workers. hazard control
diseases.  The workplace will be equipped with measures and
fire detectors, alarm systems and personal protective
fire-fighting equipment. The features;
equipment will be periodically  Ensure proper
inspected and maintained in good training of newly
working condition. deployed worker.


Funds
 Providing adequate personnel  Record of regular
facilities, including washing areas health check-up for
and areas to change clothes before the epidemic disease
and after work. and illness of related
 Medical check-up will be conducted workers.
on regular basis and the health
conditions will be monitored;
 First aid facilities required to attend
immediately for meeting emergency
situations will be made available at
the facility.
 Maintaining good housekeeping in
waste processing and storage areas.
3.2 Water quality Run-off from stockpiled  Take all precautions to prevent  No visible  Regular Included in
(surface & wastes and end- O&M cost Contractor DPHE
entering of run-off into streams, degradation to visual
groundwater) products of composting through a
watercourses, or irrigation system. nearby water bodies. inspection
which may cause nationally
Install temporary silt traps or  Complaints from for drains
reduction in the quality recognized
sedimentation basins along the communities. and water
of adjacent water bodies laboratory
channels leading to the water bodies.  For effluent quality: bodies
and groundwater.  Remove all wastes, by-, and end- pH, Temperature, within 30 m
The impacts are products immediately. TSS, DO, BOD, circumferen
negative but short-term,  Quality of discharge shall be COD, Nitrate, ce of the
site-specific within a regularly monitored to ensure that Phosphate, TC, FC. facilities.
relatively small area and effluent quality complies with the  For surface water  Twice/yr in
reversible by mitigation prescribed effluent standards quality parameters: 1st year and
measures. (chemical and biological). pH, EC, TSS, DO, Once/yr in
BOD, COD, Total N, 2nd year.
Total P, TC, FC.
 For groundwater
quality parameters:
pH, TDS, Chloride,
As, Fe, Mn, S, TC,
FC.
3.3 Air emission Odor generation from  Use bin covers and/or tarpaulins  Complaints from  Daily Included in
and odour the barrels as well as O&M cost Contractor DPHE
during transport of wastes, by-, and communities inspection
maturing shed may end products (compost).
cause health risk to the  Keep the immediate surrounding of
worker and community. the compost shed tidy.
The impacts are
negative but short-term,


Funds
site-specific within a
relatively small area and
measures.
3.4 Acoustic Increase in noise level Plan activities in consultation with  Complaints from  During O&M Included in
environment due to presence of community so that activities with the O&M cost Contractor DPHE
communities phase
workers and movement greatest potential to generate noise are
of vehicles. The impacts conducted during periods of the day
are negative but short- which will result in least disturbance.
term, site-specific within
and reversible by
3.5 Reuse and/or Environmental hazard  Compost shall be used as soil  Health condition of Prior to Included in
disposal of and health risk to packaging O&M cost Contractor DPHE
conditioner to enhance soil fertility in farmers of the
compost workers and other nearby farms. agricultural land. of compost
people.  If reuse is not feasible safe disposal  Regular visual visual
should be ensured. inspection at disposal inspection
 Monitor compost quality. site; to ensure
 Compost quality to that glass,
meet standards for plastic and
pH, As, Cd, Cr, Cu, other
Pb, Hg, Ni, Zn, C/N physical
ratio. inert and
fragments
are absent
in compost
and it has no
offensive
smell.
Twice/yr in
1st year and
Once/yr in
2nd year.
3.6 Traffic  Waste carrying trucks  A well-defined schedule and route  Check the vehicle Regular Included in
management monitoring O&M cost Contractor DPHE
will be plying to the will be followed by the waste carrying pool.
facility from the trucks;  Record of regular weekly at
camps. This may lead  Proper signage will put up near the inspection. vehicle pool.
to increase in traffic proposed facility giving route  Proper training to the
volume. directions; driver.


Funds
 Random parking of  Vehicles will be parked inside the  Record of
vehicles and facility premises in the designated accidents/incidents.
unplanned loading / slots;
unloading areas can  Entry and exit routes from the
lead to traffic premises will be clearly marked;
congestion.  Adequate lighting and reflective
boards will be put up for night time
safety;
 A proper traffic management plan will
be implemented to mitigate adverse
impacts;
 All routes will be planned to cause
minimal disturbance to local
community;
 The vehicles will be allowed to move
in the site only through dedicated
entry and exit points within the site;
 Dedicated parking area will be
provided in the facility for parking of
vehicles;
 The speed limit of vehicles will be
restricted to 20 km/hr;
3.7 Socio-  Visual impacts.  Good waste handling practices will  Complaints from Weekly Included in
economic aspect monitoring. O&M cost Contractor DPHE
 Impacts on be implemented which will greatly sensitive receptors
community health. reduce foul smell and reduce impact  Regular inspection at
 Employment. from odours; IWMF site.
 Vehicles moving through community  Record of awareness
roads will be covered and the campaign.
operations will be restricted to day
time;
 Maximum efforts will be made to
provide job opportunities to local
residents during construction and
operation phase.
 Awareness campaigns should be
organized emphasizing the need of
sorting at source, waste collection
and participatory role of residents in
waste management in an area.

E. Institutional Arrangement and Responsibilities
1. Oversight Body
210. The RRRC is proposed to act as the coordinator on behalf the government to execute all
interventions. RRRC and ADB will conduct regular coordination meetings involving all executing and
implementing agencies, relevant stakeholders including deputy commissioner of Cox’s bazar, other
development partners and agencies. ADB established an extended mission office in Cox’s bazar for close
coordination, facilitation of sub-projects development and implementation.
211. A steering committee comprising higher officials from relevant ministries coordinated by ERD will
be formed to provide necessary guidance to expedite the sub-project development and implementation.
2. Executing and Implementing Agencies

212. The Department of Public Health Engineering (DPHE), under the Local Government Division
(LGD) of the Ministry of Local Government, Rural Development and Cooperatives (MLGRD&C), having
extensive experience in managing urban and water supply projects financed by ADB, will be the both
executing and implementing agency of Emergency Assistance Project. Ministry of Finance, Economic
Relations Division has signed the grant agreement with ADB for funding of the implementation of project.
Ministry of Disaster Management and Relief will facilitate establishing a project coordination committee and
provide guidance and supervision of project activities.
3. Project Management Unit and Project Implementation Unit

213. A PMU will be established at Dhaka for the overall management of the project. The PMU will be
headed by Project Director (PD) supported by officials. A Project Implementation Unit (PIU) will be
established at Cox’s Bazar under DPHE. A team of Individual Consultant leaded by Project Management
Specialist/TL and a consulting firm leaded by Team Leader/Sr Water Supply and Sanitation Engineer will
be recruited to support PMU and PIU in implementing the project activities at Cox’s Bazar, Ukhiya and
Teknaf.
4. Design and Supervision Consultants (DSC)

The DSCs together with the PIU, will assist in developing and updating IEEs through the conduct of the
DMS in a participatory and transparent way and consistent with the ADB’s environment principles and the
environmental assessment and review framework. Once approved by the PMU and reviewed and
concurred by ADB, the DSC will provide technical advice in the implementation of the approved IEE and
EMP. The DSC will likewise provide capacity-building orientation and skills training, as needed, to
concerned personnel of the PMU and PIU.
20. Together with the EA/IA and PIU, the DSC will supervise civil works activities to ensure that the
contractors adhere with the terms of their contract relative to avoiding and/or minimizing environmental
impacts, in addition to ensuring that contractors provide the necessary compensation and/or assistance to
the affected households prior to and/or during construction activities. The DSC will assist the PIU in regular
monitoring of EMP implementation.
5. Civil Works Contracts and Contractors

214. EMPs are to be included in bidding and contract documents and verified by the PMU. The
contractor will be required to designate an environmental supervisor to (i) coordinate with Consultant on
updating the IEE/EMP if necessary, and (ii) ensure implementation of EMP during civil works. Contractors
are to carry out all environmental mitigation and monitoring measures outlined in their contract.

F. Capacity Building
215. A training program on environmental assessment, implementation and reporting will be developed
to build the capability of PMU. This will be conducted by the Consultants. The PMU, consultants and
contractors of on-going contracts will attend a one-day ADB SPS induction workshop provided by ADB
safeguard specialist at BRM. Salient features of ADB SPS, policy triggers, safeguard requirements on
environment, resettlement and indigenous peoples, and construction best practices.
216. PMU will organize an induction course for the training of contractors, preparing them on:(i) EMP
implementation, including environmental monitoring requirements related to mitigation measures; and (ii)
taking immediate actions to remedy unexpected adverse impacts or ineffective mitigation measures found
during the course of implementation. The contractor will be required to conduct environmental awareness
and orientation of workers prior to deployment to work sites. The suggested outline of the training program
is presented in Table VII.3.
Table VII.3: Indicative Capacity Building and Training Program on EMP
Description Contents Schedule Participants

Program 1 Module 1 – Orientation ADB 1 day DPHE officials involved in
Orientation Safeguards Policy Statement the project implementation
workshop Bangladeshi Environmental
Laws and Regulations
Module 2 – Environmental PMU

Assessment Process ADB
environmental process,
identification of impacts and
mitigation measures, formulation
of an environmental
management plan (EMP),
implementation, and monitoring
requirements
Review of environmental
assessment report to comply
with ADB requirements
Incorporation of EMP into the
project design and contracts
Program 2 Environmental issues during 1 day PMU
Orientation construction contractors
program/ Implementation of EMP
workshop for Monitoring of EMP
contractors implementation
and supervisory
staff Reporting requirements
Program 3 Experiences on EMP 1 day on a regular period PMU
Experiences and implementation to be determined by Consultant
best – issues and challenges PMU and Consultant Contractors
practices sharing Best practices followed Local community
representative
G. Environmental Costs
217. The contractor’s cost for site establishment, preliminary activities, construction, defect liability
activities, and environmental mitigation measures related to EMP implementation before construction and
construction are to be incorporated into the contractual agreements and engineer’s costs, which will be
binding on him for implementation. The survey will be conducted by the contractor.
218. The operation phase mitigation measures are again of good operating practices, which will be the
responsibility of the implementing agency (DPHE). 1st two-years O&M will be done by contractor and rest

period will be done by local personnel involve in O&M and/or camp in charge (such as UNHCR/IMO or
other organization responsible for O&M) or any other mechanism identified by ADB.
219. The activities identified in the EMP mainly include site inspections and informal discussions with
workers and local community, and this will be the responsibility of PMU with the assistance of Consultant,
costs of which are part of project management. Table VII.4 presents the estimated cost to implement the
EMP.
Table VII.4: Cost Estimates to Implement the EMP
Total Costs
SL. Particulars Phase Unit Rate (BDT) Cost (BDT)
number covered by
A. Capacity building
Program 1
Orientation
Workshop
Program 2
Three
Orientation
modules,
program/workshop Pre-
1 1 Covered under consultancy
for contractors and construction
day per
supervisory staff
module
Program 3
Experiences and
best practices
sharing
Training for
Two
contractor’s staff and
modules,
labour on Health, During Civil Works
2 1 2 25,000.0 50,000.0
safety and construction Contract
day per
environment and
module
construction practice
Sub Total (A. Capacity building) 50,000.0
B. Mitigation measures
Compensatory
plantation measures
(payment is Civil works
1. Construction Per tree 200 200.0 40,000.0
to be made only contract
when trees are fully
grown)
Civil works
contract
Site safety and should be
2. Construction Per site 2 20,000.0 40,000.0
security included
under site
preparation
Dust suppression
measures at work
Civil works
3. sites twice per day Construction Per site 2 30,000.0 60,000.0
contract
over construction
period
Worker health and
safety (safety gears
and first aid facility at
work site, water Civil works
4. Construction Per site 2 80,000.0 160,000.0
quality at labour contract
camp, solid waste
management at
labour camp etc.)
Sub Total (B. Mitigation measures) 300,000.0
C. Monitoring parameter for establishing baseline during pre-construction
Ambient air quality
Per
monitoring at work Before Civil works
1 contract 2 25,000 50,000.0
site and nearby construction contractor
package
sensitive receptor;

Total Costs
number covered by
(PM10, PM2.5,
SOx, NOx, COx)
Noise level (LAeq in
dB during day and Per
Before Civil works
2 night period at work contract 4 2,000 8,000.0
construction contractor
site and nearby package
sensitive receptor)
Surface water
quality monitoring at
Per
nearby water body; Before Civil works
3 contract 2 25,000 50,000.0
(pH, EC, TSS, DO, construction contractor
package
BOD, COD, Total N,
Total P, TC, FC)
Groundwater quality
monitoring at nearby Per
Before Civil works
4 Tube-well; (pH, contract 2 25,000 50,000.0
construction contractor
TDS, Chloride, As, package
Fe, Mn, S, TC, FC)
Sub Total (C. Monitoring parameter during pre-construction) 158,000.0
D. Monitoring parameter during construction
Ambient air quality
monitoring at work
Per
site and nearby Civil works
1. Construction contract 2 25,000 50,000.0
sensitive receptor; Contract
package
(PM10, PM2.5,
SOx, NOx, COx)
Noise level (LAeq in
dB during day and Per
Civil work
2. night period at work Construction contract 4 2,000 8,000.0
contractor
site and nearby package
sensitive receptor)
Surface water
quality monitoring at
Per
nearby water body; Civil work
3. Construction contract 2 25,000 50,000.0
(pH, EC, TSS, DO, Contractor
package
BOD, COD, Total N,
Total P, TC, FC)
Groundwater quality
monitoring at nearby Per
Civil work
4. Tube-well; (pH, Construction contract 2 25,000 50,000.0
Contractor
TDS, Chloride, As, package
Fe, Mn, S, TC, FC)
Sub Total (D. Monitoring parameter during construction) 158,000.0
E. Monitoring parameter during operation
Civil work
Contractor
Effluent quality Operation; for 1st two
monitoring (pH, Twice/yr in 1st years; DPHE
Temperature, TSS, year and Camp 4 as per ADB
1. 3 25,000 75,000.0
DO, BOD, COD, Once/yr in 2nd Ext. identified
Nitrate, Phosphate, year mechanism
TC, FC) (2x1+1=3) for operation
for rest
period
Civil work
Contractor
Treated leachate Operation;
for 1st two
quality monitoring Twice/yr in 1st
years; DPHE
(pH, Temperature, year and Camp 4
2. 3 25,000 75,000.0 as per ADB
TSS, DO, BOD, Once/yr in 2nd Ext.
identified
COD, Nitrate, year
mechanism
Phosphate, TC, FC) (2x1+1=3)
for operation
for rest

Total Costs
number covered by
period
Civil work
Contractor
Operation; for 1st two
Surface water
Twice/yr in 1st Two sites years; DPHE
quality monitoring
year and (camp 4 as per ADB
3. (pH, EC, TSS, DO, 6 25,000 150,000.0
Once/yr in 2nd ext. and identified
BOD, COD, Total N,
year camp 23) mechanism
Total P, TC, FC)
(2x1+1=3) for operation
for rest
period
Civil work
Contractor
Groundwater quality Twice/yr in 1st Two sites years; DPHE
monitoring (pH, year and (camp 4 as per ADB
4. 6 25,000 150,000.0
TDS, Chloride, As, Once/yr in 2nd ext. and identified
Fe, Mn, S, TC, FC) year camp 23) mechanism
for rest
period
Civil work
Contractor
Compost quality Twice/yr in 1st Two sites years; DPHE
monitoring (pH, As, year and (camp 4 as per ADB
5. 6 30,000 180,000.0
Cd, Cr, Cu, Pb, Hg, Once/yr in 2nd ext. and identified
Ni, Zn, C/N ratio) year camp 23) mechanism
for rest
period
Sub Total (E. Monitoring parameter during operation) 630,000.0
Grand Total for EMP Monitoring (A+B+C+D+E) 1296,000.0
220. The EMP implementation cost stands at BDT 12,96,000.0
H. Monitoring and Reporting

221. PMU will monitor and measure the progress of EMP implementation. The monitoring activities will
correspond with the project’s risks and impacts, and will be identified in the IEEs for the projects. In addition
to recording information on the work and deviation of work components from original scope PMU, and
Consultant will undertake site inspections and document review to verify compliance with the EMP and
progress toward the final outcome.
222. Contractor will submit report to Consultant and Consultant will submit monthly monitoring and
implementation reports to PMU, who will take follow-up actions, if necessary. PMU will submit semi-annual
monitoring reports to ADB. Subproject budgets will reflect the costs of monitoring and reporting
requirements.
223. ADB will review project performance against the MLGRDC’s commitments as agreed in the legal
documents. The extent of ADB's monitoring and supervision activities will be commensurate with the
project’s risks and impacts. Monitoring and supervising of social and environmental safeguards will be
integrated into the project performance management system. ADB will monitor projects on an ongoing
basis until a project completion report is issued. ADB will carry out the following monitoring actions to
supervise project implementation:
(i) conduct periodic site visits for projects with adverse environmental or social impacts;
(ii) conduct supervision missions with detailed review by ADB’s safeguard specialists/officers or
consultants for projects with significant adverse social or environmental impacts;

(iii) review the periodic monitoring reports submitted by EAs to ensure that adverse impacts and
risks are mitigated, as planned and as agreed with ADB;
(iv) work with EAs to rectify to the extent possible any failures to comply with their safeguard
commitments, as covenanted in the legal agreements, and exercise remedies to re-establish
compliance as appropriate; and
(v) prepare a project completion report that assesses whether the objective and desired
outcomes of the safeguard plans have been achieved, taking into account the baseline
conditions and the results of monitoring.

VIII. GRIEVENCE REDRESS MACHANISM

224. The objective the grievance redress mechanism (GRM) is to resolve complaints as quickly as
possible and at the local level through a process of conciliation; and, if that is not possible, to provide clear
and transparent procedures for appeal. A well-defined grievance redress and resolution mechanism will
be established to resolve grievances and complaints in a timely and satisfactory manner. All affected
persons will be made fully aware of their rights, and the detailed grievance redress procedures will be
publicized through an effective public information campaign. The grievance redress process includes three
levels:
A. First Level of GRM

225. The first level and most accessible and immediate contact for the fastest resolve of grievances are
the contractors, with assistance from DSC on site. Prior to construction of any works, the PIU will ensure
local community meetings are held to notify residents and businesses of any temporary disturbances, and
to inform them of the Project and the GRM. If any complaints arise, the contractors, with assistance from
DSC can immediately resolve the complaint on site. The contractor’s and DSC’s office phone number will
be posted in public areas within the subproject areas and construction sites. Any person with a grievance
related to the project works can contact the project to file a complaint. The contractor may seek the
assistance of the DSC safeguards specialists (the environmental specialist or social safeguards specialist)
to resolve the issue. The DSC safeguards (environment and resettlement) focal person will immediately
address and resolve the issue with the contractor within 1-2 days, if the complaint remains unresolved at
the field level. The DIU safeguards focal person will fully document the following information: (i) name of
the person; (ii) date complaint was received; (iii) nature of complaint; (iv) location, and (v) how the complaint
was resolved.
B. Second Level of GRM

226. Should the grievance remain unresolved; the contractor with assistance from DSC will forward the
complaint to the PIU safeguards focal person. The person filing the grievance will be notified by DSC
safeguards focal person that the grievance was forwarded to the PIU safeguards focal person. The PIU
will address the grievance. Grievances will be resolved through continuous interactions with affected
persons, and the PIU will answer queries and resolve grievances regarding various issues including
environmental or social impacts. Corrective measures will be undertaken at the field level by the PIU
safeguards focal person within 7 days. He/she will fully document the following information: (i) name of the
person; (ii) date complaint was received; (iii) nature of complaint; (iv) location and (v) how the complaint
was resolved.
C. Third Level of GRM

227. Should the grievance remain unresolved, the PIU’s project director will activate the third level of
the GRM by referring the issue (with written documentation) to a Grievance Redress Committee (GRC),
which will, based on review of the grievances, address them in consultation with the PIU, contractor, DSC,
and affected persons. The GRC will consist of Refugee Relief and Repatriation Commission (RRRC), as
chairperson, EA/IA representative, camp-in-charge, and other relevant stakeholders. A meeting will be
called with the GRC, if necessary, where the affected person can present his/her concern and issues. The
process will promote conflict resolution through mediation. The GRC will meet as necessary when there
are grievances to be addressed. The GRC will suggest corrective measures at the field level and assign
clear responsibilities for implementing its decision within 15 days. The functions of the GRC are as follows:
(i) to provide support to affected persons on problems arising from environmental or social disruption, asset
acquisition (where required), and eligibility for entitlements, compensation, and assistance; (ii) to record
grievances of affected persons, categorize and prioritize them, and provide solutions within 15 days; and
(iii) to report to the aggrieved parties’ developments regarding their grievances and decisions of the GRC.
The EA/IA safeguards focal person will be responsible for processing and placing all papers before the

GRC, recording decisions, issuing minutes of the meetings, and taking follow-up action to see that formal
orders are issued, and the decisions carried out.
228. Safeguard monitoring reports will include the following aspects pertaining to progress on
grievances: (i) number of cases registered with the GRC, level of jurisdiction (first, second, and third levels),
number of hearings held, decisions made, and the status of pending cases; and (ii) lists of cases in process
and already decided upon may be prepared with details such as affected person, date of notice, date of
application, date of hearing, decisions, remarks, actions taken to resolve issues, and status of grievance
(i.e. open, closed, pending).
229. All costs involved in resolving the complaints (meetings, consultations, communication and
reporting / information dissemination) will be borne by the EA/IA.
230. Where an affected person is not satisfied with the outcomes of the 3 levels of the Project GRM,
the affected person should make good faith efforts to resolve issues working with the South Asia Regional
Department through ADB’s Bangladesh Resident Mission. As a last resort, the affected person can access
ADB’s Accountability Mechanism (ADB’s Office of Special Project Facility or Office of Compliance Review).
ADB’s Accountability Mechanism, including information on how to file a complaint, will also be explained
to affected households.
231. The grievance redress mechanism and procedure are depicted in Figure VIII.1.
Grievance
1-2 day
1st Level FIELD LEVEL: days Grievance
Grievance Contractor, with Redressed
assistance from DSC
Not redressed
7 day
2nd Level Grievance

PIU Redressed
Grievance
Not redressed
15 day
SRD BRM Grievance Redress Grievance
Committee Redressed
Not redressed
Accountability
Mechanism Higher Authority/Court
of Law
GRC, recording decisions, issuing minutes of the meetings, and taking follow-up action to see that formal
Figure VIII.1: Grievance redress process
orders are issued, and the decisions carried out.

IX. INFORMATION DISCLOSURE, CONSULTATION AND PARTICIPATION
A. Stakeholder Consultation
233. Meaningful stakeholder consultation and participation is part of the subproject preparation and
implementation strategy. Consultation, participation and will ensure information is provided and feedback
is obtained and considered on the implementation of subprojects. Affected persons will be consulted at
various stages of subproject preparation to ensure: (i) incorporation of views/concerns of affected persons,
particularly the vulnerable, on environmental impacts and mitigation measures; (ii) identification of any help
required by affected persons during rehabilitation; and (iv) avoidance of potential conflicts for smooth
project implementation.
234. It will also provide adequate opportunities for consultation/participation of all stakeholders and
inclusion of the vulnerable in subproject process. Relevant information on any major changes to the Project
or subproject scope will be shared with beneficiaries, affected persons, vulnerable groups, and other
stakeholders.
1. Stakeholder Consultation Strategy for Emergency Assistance Project

235. At minimum, stakeholders will be consulted regarding the scope of an impact assessment before
work is commenced and they will be informed of the likely impacts of the subproject and proposed
mitigation once the draft IEE and EMP documents are prepared. The safeguards documents will record
views of stakeholders and indicate how these have been taken into account in subproject development.
Consultations will be held with a special focus on vulnerable groups.
B. Key Target Stakeholders

236. The key stakeholders to be consulted during subproject preparation, EMP implementation and
subproject implementation include:
 Beneficiaries;
 Elected representatives, community leaders, religious leaders and representatives of community
based organizations;
 Local non-government organizations (NGOs);
 Local government and relevant government agency representatives, including local authorities
responsible for land acquisition, protection and conservation of forests and environment,
archaeological sites, religious sites, and other relevant government departments;
 Residents, shopkeepers, business persons, and farmers who live and work alongside transport
and education/district infrastructure which will be rehabilitated;
 Executing agency, implementing agency, PIU, staff and consultants; and
 ADB and Government.
C. Consultation and Disclosure to Date

237. Two public consultation was held during field visit on 26 February and 8 May 2019 at camp 23 and
camp 4 where 18 and 21 attendees were participated respectively (Figure IX.1 and Figure IX.2). The
attendees list is attached in Annex 1. Some informal discussion was held with the local people during site
visit. Main topics of discussions were:
 Awareness and extent of the subproject components

 Benefits of the subproject for the betterment of camp dwellers
 Labour availability in the subproject area
 Local disturbances due to subproject construction work
 Water logging and drainage problem
 Air and noise pollution due to subproject construction work
 Movement of construction vehicle within the camp

Figure IX.1: Public consultation held at camp 4 in Kutupalong, Ukhia
Figure IX.2: Public consultation held at Camp 23 in Shamplapur, Teknaf
D. Findings of the Public Consultation

238. Camp dwellers are very much interested on the subproject and they will help the authorities in all
aspects. However, mitigation measures will be required at construction sites to minimize the impact on
environment. The major outcomes from the public consultation were related to dust, noise, drainage
congestion during construction and the possible air emission & odor and noise problems during operation
phase. Moreover, people were interested to know the possibility of employment in the construction activity.
Summary of the consultation outcomes is presented in Table IX.1.
Table IX.1: Summary of consultation outcomes
Sl. Issues Response
Does the local person support the proposed All participants pledged to give their full support for the said
01
subproject? subproject for everybody's welfare.
Any critical issue or concern by the local
02 No issues or concerns.
people regarding the subproject?
No land acquisition is required for the IWMF in camp 4 as it
will be established in the camp area, if require, DPHE will
Will the subproject require any land negotiate with the land owner to purchase/lease the land.
03
acquisition for implementation? However, for camp 23, narrow strip taking will be required for
drying and maturing shed which will purchase/lease from the
land owner.
Will the subproject construction activity Necessary provisions will be provided to avoid the drainage
04
adversely affect drainage management? congestion during the construction.
Sprinkling of water at frequent intervals will avoid and curtail
Will the subproject construction activity the dust emission. Good constructional practices and proper
05
adversely affect the air and noise level? work schedule shall avoid noise disturbances to the
neighborhood.
Will the subproject adversely affect the air Aerobic process has been selected to decompose the
06
quality during operation? biodegradable waste, therefore, no foul smell will be emitted

Sl. Issues Response

from the facility. Moreover, monitoring the performance of the
IWMF will be frequently to ensure that clogging is remedied as
soon as possible and keep tidy of the immediate surroundings
of the facility.
During labour recruitment, should the camp
This largely depends on the types of job and will be assessed
07 dwellers including women be given priority
on a case-to-case basis by the contractor according to needs.
during construction?
E. Future Stakeholder Consultation

239. The contractor will consult with the targeted stakeholders prior to the implementation of work,
during implementation and prior to operation and maintenance. Contractor will also consult with the camp
authority and working WASH partner. The consultation is very important to finalize the site of all
components. The contractor will coordinate with WASH working group through DPHE. Under the guidance
of WASH working group, different NGOs are working for the task of community consultation and motivation.
The WASH working group will define the concern NGOs and the contractor will finance the NGO from the
contract provision for carrying out the project specific task, in consultation with DPHE.
F. Information Disclosure
240. Information is disclosed through public consultation and making available relevant documents in
public locations. The following documents will be submitted to ADB for disclosure on its website:
 IEE (including subproject EMP);
 Updated IEE (including EMP) and corrective action plan prepared during project implementation,
if any; and
 Environmental monitoring reports.
241. The EAs/IAs will send a written endorsement to ADB for disclosing these documents on the ADB
website. The PIUs will provide relevant safeguards information in a timely manner, in an accessible place
and in a form and language understandable to affected people and other stakeholders. For illiterate people,
other suitable communication methods will be used. Disclosure will follow ADB’s Public Communication
Policy, 2011.

X. CONCLUSION AND RECOMMENDATION

243. The process described in this document has assessed the environmental impacts of all elements
of construction and operation of integrated waste management facility (IWMF) at camp 4 and camp 23. All
potential impacts were identified in relation to design, construction and operation phases.
244. The environmental assessment process has highlighted the environmental issues and concerns
of the proposed subproject. It has not identified any significant negative environmental impacts that cannot
be mitigated. Most of the individual elements of the subproject are relatively small and involve
straightforward construction and operation, so impacts will be mainly localized and not greatly significant.
Most of the predicted impacts are associated with the construction process, and are produced because
that process is invasive, involving excavation and earth movement. However, the routine nature of the
impacts means that most can be easily mitigated. Mitigation measures have been developed to reduce all
negative impacts to acceptable levels. Mitigation will be assured by a program of environmental monitoring
to ensure that all measures are implemented, and will determine whether the environment is protected as
intended. It will include observations on- and off-site, document checks, and interviews with workers and
beneficiaries. Any requirements for corrective action will be reported to the ADB.
245. The subproject will benefit the camp dwellers as well as host community by contributing to the
long-term improvement of public health and community livability in the camp. The potential adverse
environmental impacts are mainly related to the abnormal or malfunctioning of the IWMF during its
operation, which can be minimized by the mitigating measures.
246. The stakeholders are involved in developing the IEE through discussions on-site and public
consultation, after which views expressed are incorporated into the IEE. The IEE will be made available at
public locations in the camp and will be disclosed to a wider audience via the ADB websites. The
consultation process will be continued and expanded during project implementation to ensure that
stakeholders are fully engaged in the project and have the opportunity to participate in its development and
implementation. A grievance redress mechanism is described within the IEE to ensure any public
grievances are addressed quickly.
247. A copy of the EMP shall be kept on-site during the construction period at all times. The EMP shall
be made binding on the contractor operating on the site, and will be included in the contractual clauses.
Non-compliance with, or any deviation from, the conditions set out in this document shall constitute a failure
in compliance.
248. DPHE (Executive Agency) have fully endorsed the EMP and is committed to implement all the
mitigation measures. DPHE will also ensure that the work is carried out in an environmentally acceptable
manner and the monitoring and reporting are completed in a compliant and timely fashion, acceptable to
ADB. If the subproject is developed following the suggestions given in the EMP of this IEE, it is our
contention that there will be no negative impacts to deter the development of the subproject.
249. As per Government of Bangladesh ECA, 1995 and ECR, 1997, the sub-project is categorized as
“red”; and LCC and ECC must be obtained from DoE. On the other hand, based on this IEE, the
determination of environment category as “B” in accordance with ADB’s SPS 2009 is confirmed and does
not require further environmental impact assessment.

XI. REFERENCES
2030 WRG. (2015). Consolidation and analysis of information on water resources management
in Bangladesh. Dhaka: 2030 WRG.
Akhter, S. &. (2017). Gender-based Violence among Documented Rohingya Refugees in

Bangladesh. Indian Journal of Gender Studies.
DoE. (1997). Environmental Conservation Rules. Department of Environment, Ministry of

Environment and Forestry, GoB.
FAO. (2018). Retrieved from http://www.fao.org/docrep/field/003/AC352E/AC352E03.htm#ch22
Fisheries and Aquaculture Department. (1985). Chapter II: Hydrology. In Report on tidal area
study. . FAO.
Grant, K. (2013). Effect on nitrogen on lead release in an iron and manganese rich aquifer in
Kutupalong refugee camp, Bangladesh. (Master’s Thesis). Bangladesh.
Imamul Huq and Md. Shoaib J.U. (2013). Geology and Geomorphology. Springer.
ISCG. (2017). Situation Report: Cyclone Mora. Cox's Bazar: Inter Sector Coordination Group.
Islam, M. S. (1993). Fisheries fauna of the Naf river estuary . Bangladesh journal of fish,
Mymensingh, Bangladesh.
IUCN . (2002 ). Bio-ecological Zones of Bangladesh . Dhaka : IUCN-The World Conservation

Union .
IUCN. (1994). Guidelines for Protected Area Management Categories. . Cambridge, UK.: World
Conservation Union.
Khan, F. (1991). Geology of Bangladesh . Dhaka: University Press Limited.
Mahmud, T. (2017). Rohingya influx: 15-year-old forestation project destroyed in 57 days. Dhaka:
Dhaka Tribune.
Mulongoy, K., & Chape, S. (. (2004). Protected Areas and Biodiversity: An Overview of Key
Issues. Cambridge, UK.: CBD Secretariat, Montreal and UNEP-WCMC.
NERC. (2001). Groundwater quality: Bangladesh. . British Geological Survey.
Roy, M. A. (2012). Paleoenvironment of deposition of the Dupi Tila Formation, Lalmai Hills,
Comilla, Bangladesh. Journal Geological Society of India , 80: 409-419.
Sikder, A. (2010). Access to water and sanitation in refugee settings: Success and setbacks in
Bangladesh. . In Proc. of International Conference on Environmental Aspects of
Bangladesh (ICEAB10), (pp. pp. 149-151). Japan.
Smith, A. L. (2000). Contamination of drinking-water by arsenic in Bangladesh: a public health

emergency. Bulletin of the World Health Organization, 78(9): 1093-1103.
UNDP. (2012). Comprehensive Disaster Management . Dhaka: UNDP.
UNDP Bangladesh and UN WOMEN Bangladesh. (2018). Report on Environmental Impact of

Rohingya Influx. Dhaka: UNDP Bangladesh.

ANNEX 1: RAPID ENVIRONMENTAL ASSESSMENT (REA) CHECKLIST (SOLID

WASTE MANAGEMENT)
Instructions:
(i) The project team completes this checklist to support the environmental classification of a project. It is to be
attached to the environmental categorization form and submitted to the Environment and Safeguards Division
(SDES) for endorsement by the Director, SDES and for approval by the Chief Compliance Officer.
(ii) This checklist focuses on environmental issues and concerns. To ensure that social dimensions are
adequately considered, refer also to ADB's (a) checklists on involuntary resettlement and on tribes, minor
races, ethnic sects and communities;5 (b) poverty reduction handbook; (c) staff guide to consultation and
participation; and (d) gender checklists.
(iii) Answer the questions assuming the “without mitigation” case. The purpose is to identify potential impacts.
Use the “remarks” section to discuss any anticipated mitigation measures.
Country/Project Title: G0582-BAN: Emergency Assistance Project
Sector Division:
Urban Infrastructure
Subproject Name – Construction and operation of 2 integrated waste management and resource recovery facility
with collection system at camp 4 in Ukhia and camp 23 in Teknaf (EAP/DPHE/W9A)
Screening Questions Yes No Remarks
A. PROJECT SITING
IS THE PROJECT AREA…
The population distribution shows that the project area
 DENSELY POPULATED? ✓
is densely populated as high as 125000 per sq.km.
 HEAVY WITH DEVELOPMENT
ACTIVITIES? ✓
 ADJACENT TO OR WITHIN ANY

ENVIRONMENTALLY SENSITIVE
AREAS?
 CULTURAL HERITAGE SITE There is no sensitive cultural site in the subproject area.
✓
Teknaf Wildlife Sanctuary is located approx. 5km from
 PROTECTED AREA
✓ the camp but project activities are not large enough to
have impact on bio-diversity of sanctuary.
 WETLAND
✓
 MANGROVE
✓
 ESTUARINE
✓
 BUFFER ZONE OF
PROTECTED AREA ✓
 SPECIAL AREA FOR

✓
PROTECTING BIODIVERSITY
 BAY ✓
B. POTENTIAL ENVIRONMENTAL
IMPACTS WILL THE PROJECT
CAUSE…
5 Groups or population identified as Indigenous Peoples within the context of ADB’s Safeguard Policy Statement
will be referred to in this document as tribes, minor races, ethnic sects and communities (following the request of
the Government of Bangladesh).


 impacts associated with transport of Covered refuse collection vehicles have been
wastes to the disposal site or ✓ proposed. Vehicles will be maintained periodically to
treatment facility? prevent spillage of leachate on the route.
 impairment of historical/cultural
monuments/areas and loss/damage ✓ No
to these sites?
 degradation of aesthetic and Design includes green belt to form a physical

✓
property value loss? separation and visual screen to the development.
Design includes aerobic composting with proper

aeration to control the odor problem. Health risk due to
 nuisance to neighboring areas due breeding of flies in waste is proposed to be controlled
to foul odor and influx of insects, ✓ by appropriate fly control measures. The compost plant
rodents, etc.? shall be covered with net to prevent the entry of birds
and animals that may spread the waste in the nearby
areas.
 dislocation or involuntary
✓ Not applicable.
resettlement of people?
 disproportionate impacts on the Flies, insects and rats will be controlled by the
poor, women and children, mitigation measures and no rag pickers/scavengers are
✓ allowed in the dumpsite.
indigenous peoples or other
vulnerable groups?
 risks and vulnerabilities related Anticipated during construction activities. However,
occupational health and safety due impacts are temporary and short in duration. The EMP
to physical, chemical, biological, ✓ includes measures to mitigate the impacts.
and radiological hazards during
project construction and operation?
 public health hazards from odor, Aerobic process helps to eliminate pathogenic
smoke from fire, and diseases organisms, weed seeds, larva etc. Moreover, EMP
✓ includes measures to mitigate the impacts during O&M
transmitted by flies, insects, birds
and rats? phase.
 deterioration of water quality as a Design includes leachate collection and treatment
result of contamination of receiving facility with adequate capacity. Monitoring of treated
✓ leachate quality shall be conducted as specified in the
waters by leachate from land
disposal system? environmental monitoring plan.
 contamination of ground and/or Same as above. Further, monitoring of ground water
surface water by leachate from land quality has been proposed in the EMP. Appropriate
✓
disposal system? mitigation measures shall be taken if any contamination
is detected.
 land use conflicts? ✓ Not applicable.
 pollution of surface and ground Design includes leachate collection and treatment
water from leachate coming from system and air venting system.
sanitary landfill sites or methane gas
produced from decomposition of
✓
solid wastes in the absence of air,
which could enter the aquifer or
escape through soil fissures at
places far from the landfill site?
 inadequate buffer zone around Greenbelt around facilities is included in the design.
✓
landfill site to alleviate nuisances?
 road blocking and/or increased Existing road will be improved and contractors will be
traffic during construction of ✓ required to implement traffic management plan and
facilities? coordinate with RRRC.
 noise and dust from construction The impacts are negative but short-term, site-specific
activities? within a relatively small area and reversible through
✓ mitigation measures. Air quality and noise level
monitoring shall be conducted as specified in the
environmental monitoring plan.
Due to excavation, run-off from stockpiled materials,
 temporary silt runoff due to
✓ and chemical contamination from fuels and lubricants.
construction?
The impacts are negative but short-term, site-specific


within a relatively small area and reversible through
mitigation measures included in the EMP.
 hazards to public health due to Adequate institutional arrangements have been
inadequate management of landfill proposed in the IEE report. Enough financial provisions
site caused by inadequate for environmental management have been included in
✓ the operation and maintenance cost of the subproject.
institutional and financial
capabilities for the management of
the landfill operation?
 emission of potentially toxic volatile Air quality monitoring shall be conducted as specified in
✓ the environmental monitoring plan.
organics from land disposal site?
Design includes leachate collection and treatment
system and venting system. Monitoring program has
 surface and ground water pollution
been proposed for regular surface and ground water
from leachate and methane gas ✓
quality monitoring. Moreover, expected GHG
migration?
generation is insignificant due to aerobic composting
process.
Plantation program is included in EMP where deep-
 loss of deep-rooted vegetation (e.g.
✓ rooted vegetation will be planted at the ratio of 1 (cut):
tress) from landfill site?
2 (new planting).
 explosion of toxic response from Not anticipated. Expected GHG generation is
accumulated landfill gas in ✓ insignificant due to aerobic composting process.
buildings?
 contamination of air quality from Not applicable.
✓
incineration?
Personal protective equipment will be provided to
 health and safety hazards to
workers. Regular training will also be conducted to
workers from toxic gases and ✓
ensure that workers are aware of construction hazards
hazardous materials in the site?
and risks of chemicals during O&M.
The contractor will appoint the local labour force as far
 social conflicts if workers from other as possible; in case if it is unavoidable, labour camps
✓
regions or countries are hired? and facilities will be provided appropriately. No conflicts
envisaged.
 community safety risks due to both Operational area will be clearly demarcated and access
accidental and natural hazards, will be controlled. Only worker and project concerned
especially where the structural members will be allowed to visit the operational sites.
elements or components (e.g.,
landfill or incinerator) of the project
are accessible to members of the ✓
affected community or where their
failure could result in injury to the
community throughout project
construction, operation and
decommissioning?

A Checklist for Preliminary Climate Risk Screening
Screening Questions Score Remarks

Location and Is siting and/or routing of the project (or its components) 1 Little chance to be
Design of likely to be affected by climate conditions including affected by the flash
project extreme weather-related events such as floods, flood and landslide as
droughts, storms, landslides? the facility will be built
along the hill slope
where a water canal
exits, however, proper
protection will be taken.
Would the project design (e.g. the clearance for 0
bridges) need to consider any hydro-meteorological
parameters (e.g., sea-level, peak river flow, reliable
water level, peak wind speed etc.)?
Materials and Would weather, current and likely future climate 0
Maintenance conditions (e.g. prevailing humidity level, temperature
contrast between hot summer days and cold winter
days, exposure to wind and humidity hydro-
meteorological parameters likely affect the selection of
project inputs over the life of project outputs (e.g.
construction material)?
Would weather, current and likely future climate 0
conditions, and related extreme events likely affect the
maintenance (scheduling and cost) of project output(s)?
Performance Would weather/climate conditions, and related extreme 0
of project events likely affect the performance (e.g. annual power
outputs production) of project output(s) (e.g. hydro-power
generation facilities) throughout their design life time?
Options for answers and corresponding score are provided below:
Response Score
Not Likely 0
Likely 1
Very Likely 2
Responses when added that provide a score of 0 will be considered low risk project. If adding all responses will
result to a score of 1-4 and that no score of 2 was given to any single response, the project will be assigned a
medium risk category. A total score of 5 or more (which include providing a score of 1 in all responses) or a 2 in
any single response, will be categorized as high risk project.
Result of Initial Screening (Low, Medium, High): Medium

ANNEX 2: LIST OF ATTENDEES OF THE PUBLIC CONSULTATION


ANNEX 3: LIST OF WILDLIFE (MAMMALS, BIRDS, REPTILES AND AMPHIBIANS)

RECORDED IN THE SUBPROJECT AREA
MAMMALS:
SL Scientific Name English Name Family

01 Bandicota bengalensis Lesser Bandicoot Rat Muridae
02 Mus musculus Eastern House Mouse Muridae
03 Rattus rattus House Rat Muridae
04 Vandeleuria oleracea Asiatic Long-tailed Climbing Mouse Muridae
05 Paradoxurus hermaphroditus Common Palm Civet Viverridae
06 Viverra zibetha Large Indian Civet Viverridae
07 Felis chaus Jungle Cat Felidae
08 Herpestes auropunctatus Small Indian Mongoose Herpestidae
09 Canis aureus Golden Jackal Canidae
10 Suncus murinus Asian House Shrew Soricidae
11 Cynopterus sphinx Greater Short-nosed Fruit Bat Pteropodidae
12 Pteropus giganteus Indian Flying Fox Pteropodidae
13 Megaderma lyra Greater False Vampire Bat Megadermatidae
14 Pipistrellus tenuis Least Pipistrelle Vespertilionidae
15 Scotophilus heathi Greater Asiatic Yellow Bat Vespertilionidae
16 Scotophilus kuhlii Lesser Asiatic Yellow Bat Vespertilionidae
BIRDS:
SL
Scientific Name English Name Family
01 Columba livia Rock Pigeon Columbidae

02 Spilopelia suratensis Western Spotted Dove Columbidae
03 Streptopelia decaocto Eurasian Collared-dove Columbidae
04 Streptopelia tranquebarica Red Turtle-dove Columbidae
05 Treron phoenicopterus Yellow-footed Green pigeon Columbidae
06 Caprimulgus macrurus Large-tailed Nightjar Caprimulgidae
07 Cypsiurus balasiensis Asian Palm-swift Apodidae
08 Cacomantis merulinus Plaintive Cuckoo Cuculidae
09 Clamator jacobinus Jacobin Cuckoo Cuculidae
10 Cuculus micropterus Indian Cuckoo Cuculidae
11 Eudynamys scolopaceus Western Koel Cuculidae
12 Hierococcyx varius Common Hawk-cuckoo Cuculidae
13 Ardeola grayii Indian Pond-heron Ardeidae
14 Bubulcus ibis Cattle Egret Ardeidae
15 Egretta garzetta Little Egret Ardeidae
16 Tyto alba Common Barn-owl Tytonidae
17 Merops orientalis Asian Green Bee-eater Meropidae
18 Dendrocopos macei Fulvous-breasted Woodpecker Picidae
19 Dicrurus leucophaeus Ashy Drongo Dicruridae
20 Dicrurus macrocercus Black Drongo Dicruridae
21 Corvus macrorhynchos Large-billed Crow Corvidae
22 Corvus splendens House Crow Corvidae

SL
23 Acrocephalus dumetorum Blyth's Reed-warbler Acrocephalidae

24 Hirundo rustica Barn Swallow Hirundinidae
25 Pycnonotus cafer Red-vented Bulbul Pycnonotidae
26 Pycnonotus jocosus Red-whiskered Bulbul Pycnonotidae
27 Acridotheres fuscus Jungle Myna Sturnidae
28 Acridotheres tristis Common Myna Sturnidae
29 Copsychus saularis Oriental Magpie-robin Muscicapidae
30 Motacilla alba White Wagtail Motacillidae
REPTILES:
SL
01 Calotes emma Forest Crested Lizard Agamidae

02 Calotes versicolor Common Garden Lizard Agamidae
03 Gekko gecko Tokay Gecko Gekkonidae
04 Hemidactylus frenatus Common House Gecko Gekkonidae
05 Eutropis carinata Keeled Grass Skink Scincidae
06 Eutropis macularia Bronze Grass Skink Scincidae
07 Sphenomorphus maculatus Spotted Litter Skink Scincidae
08 Varanus bengalensis Bengal Monitor Varanidae
09 Amphotyphlops braminus Common Blind Snake Typhlopidae
10 Lycodon aulicus Common Wolf Snake Colubridae
11 Xenochrophis piscator Checkered Keelback Colubridae
12 Naja naja Spectacled Cobra Elapidae
13 Duttaphrynusmelanostictus Common Toad Bufonidae
14 Microhyla berdmorei Berdmore’s Microhylid Frog Microhylidae
15 Euphlyctis cyanophlyctis Common Skipper Frog Dicroglossidae
16 Hoplobatrachus tigerinus Indian Bull Frog Dicroglossidae
17 Polypedates leucomystax Common Tree Frog Rhacophoridae

ANNEX 4: LIST OF HIGHER PLANTS (MAMMALS, BIRDS, REPTILES AND

AMPHIBIANS) RECORDED IN THE SUBPROJECT AREA
01 Pteris vittata Fern Pteridaceae

02 Microlepia speluncae Lacy Fern Dennstaedtiaceae
03 Thunbergia grandiflora Black Clock Vine Acanthaceae
04 Achyranthes aspera Prickly Chaff-flower Amaranthaceae
05 Alternanthera philoxeroides Alligator Weed Amaranthaceae
06 Amaranthus spinosus Spiny Amaranth Amaranthaceae
07 Centella asiatica Indian Pennywort Apiaceae
08 Calotropis gigantea Crown Flower Asclepiadaceae
09 Ageratum conyzoides Billy Goat Weed Asteraceae
10 Chromolaena odorata Triffid Weed Asteraceae
11 Crassocephalum crepidioides Redflower Rag leaf Asteraceae
12 Eclipta alba False Daisy Asteraceae
13 Sphaeranthus indicus East Indian Globe-thistle Asteraceae
14 Tridax procumbens Coat Button Asteraceae
15 Vernonia cinerea Little Ironweed Asteraceae
16 Bombax ceiba Red Silk Cotton Tree Bombacaceae
17 Heliotropium indicum Indian Heliotrop Boraginaceae
18 Senna occidentalis Coffee Senna Caesalpiniaceae
19 Tamarindus indica Tamarind Caesalpiniaceae
20 Carica papaya Papaya Caricaceae
21 Terminalia catappa Indian Almond Combretaceae
22 Ipomoea aquatica Swamp Cabbage Convolvulaceae
23 Coccinia grandis Ivy Gourd Cucurbitaceae
24 Thladiantha cordifolia Golden Creeper Cucurbitaceae
25 Dipterocarpus turbinatus Garjan-oil Tree Dipterocarpaceae
26 Croton bonplandianus Bonplant’s Croton Euphorbiaceae
27 Euphorbia hirta Snake Weed Euphorbiaceae
28 Phyllanthus reticulatus Reticulated Leaf-flaver Euphorbiaceae
29 Desmodium triflorum - Fabaceae
30 Leucas aspera - Lamiaceae
31 Abutilon Indicum Indian Mallow Malvaceae
32 Hibiscus rosa-sinensis China Rose Malvaceae
33 Malvastrum coromandelianum Coromandel Malva Malvaceae
34 Acacia auriculiformes Ear-pod Wattle Mimosaceae
35 Albizia lebbeck Siris Tree Mimosaceae
36 Mimosa pudica Sensitive Plant Mimosaceae
37 Artocarpus heterophyllus Jackfruit Moraceae
38 Ficus benghalensis Banyan Tree Moraceae
39 Psidium guajava Guava Myrtaceae
40 Syzygium cumini Black Berry Myrtaceae
41 Oxalis corniculata Indian Sorrel Oxalidaceae
42 Piper betle Betel Piperaceae
43 Persicaria lapathifolia Green Smartweed Polygonaceae

44 Citrus aurantifolia Common Lime Rutaceae

45 Citrus maxima Pummelo Rutaceae
46 Laportea interrupta - Urticaceae
47 Phyla nodiflora Cape-weed Verbenaceae
48 Areca catechu Betel-nut Palm Araceae
49 Cocos nucifera Coconut Palm Araceae
50 Commelina benghalensis Blue Commelina Commelinaceae
51 Cyperus compressus Poorland Flat-sedge Cyperaceae
52 Cyperus difformis Small Flower Umbrella Plant Cyperaceae
53 Lemna perpusilla Minute Duckweed Lemnaceae
54 Bambusa balcooa Bhalku Bamboo Poaceae
55 Bambusa tulda Tulda Bamboo Poaceae
56 Chrysopogon aciculatus Love Grass Poaceae
57 Cynodon dactylon Bahama Grass Poaceae

ANNEX 5: IUCN GUIDELINE FOR PLANTATION IN THE CAMP

This guideline has been prepared by the International Union of Nature Conservation (IUCN) in
collaboration with UNHCR. IUCN carried out a study in August 2018 in Camp 4 of Kutupalong Extension
Camp to identify suitable places for plantation, to select suitable species for plantation, and to outline
management options for this plantation. Although the plantation guideline is intended for Camp 04, the
generalized plantation process can be applied to other camp areas.
The following sections of this study draws the generalized plantation recommendation from the IUCN
study. The original study should be cited as:
UNHCR & IUCN. 2018. Plantation and Management Plan for Camp 4, Cox’s Bazar. UNHCR, IUCN
(International Union for Conservation of Nature), Dhaka, Bangladesh.
The report is available at: https://www.iucn.org/sites/dev/files/content/documents/plantation_and_management_plan_for_camp_4_iucn-

unhcr.pdf (Accessed:November 26, 2018).
A. Site preparation
Since the best time to plant is in August, the site should be well-prepared immediately for the
plantations.
 The fallow forest sites with bushes of coppice shoots and weeds/grasses, shall be lightly
slush, but the coppice shoots of native tree species, for example Puti jam, Kharullah,
Suregada, Chatian, and Dumur should be left alone.
 Predetermine the planting position with appropriate spacing and stacking with bamboo
sticks.
 On hills/hillocks, make stacking across the slopes for minimizing soil erosion.
 After stacking, make planting pit/hole of 30 cm x 30 cm x 30 cm dimension. Care should be
taken to make pits in steep slopes for avoiding soil erosion and land slide. Augur may be
use in those areas for making the pits.
 Put handful of decomposed cow dung and 20 g of TSP in each pit, mix well with top soil
before planting the seedlings.
 For soil conservation and stabilization, only line planting of Vetiver/ Phuljaru/ Arahar should
be done for minimal soil disturbance.
B. Planting Techniques
B 1 Spacing
 Long-, medium- and short-rotation forest trees: 2 m x 2 m

 Shed trees: 4 m x 4 m or depending on suitable lands around homesteads
 Plants for soil stabilization with Vetiver, Phuljaru, Arahar: 40 cm x 40 cm
 Bamboo offset/seedlings/cuttings along creeks/chhara: 5 m x 5 m in alternate position
B 2 Plantation of seedlings
 Distribute the seedlings according to the design of the plantations (short-, medium and
long-rotation).
 Short-rotation, fast-growing species shall be planted in mix on the hill-tops.
 Slow-growing, long-rotation species shall be planted at the hill bottom and mid slope.
 Cut polybag with a sharp knife and remove it carefully so that the ball of earth does not
break.
 Place the seedling with the ball of earth in the pit/ hole. Take proper care so that roots do
not curl or bend in the holes.

 Make sure that root-collar region of the seedling is just below the soil surface. Tighten the
soil by tramping with feet/hand around the seedlings, so that there does not remain any air-
space inside the planting hole.
 In the low-lying areas, ensure that no water can stand at the root-collar zone. This may be
achieved by slightly raising the soil surface in the seedling region.
C. Post-plantation management and maintenance
C1 Weeding
Weeding schedule is given below:
 3 weeding in 1st year (August, October & April-May of next year).

 2 weeding in 2nd year (July-August and May-June).
 1 weeding in 3rd year (May-June depending on rainfall & severity of weed growth).
Note: Weeding pattern shall be circular (50 cm around the seedling/sapling) or line (50 cm all along).
Complete weeding is not recommended for halting the soil erosion.
C2 Vacancy filling
 If any vacancy occurs, have to fill it up at the end of the plantation programme (if rain exists).
 Priority shall be given for the same species for vacancy filling.
C3 Fertilizations
 If the soil of the plantation area is fertile, generally fertilization is not essential.
 Since the camp plantation site is degraded, it needs adequate fertilizer application: Urea
30 g, TSP 20 g with a basal doze of 20 kg/ha of MP.
 Thoroughly mix full doze of TSP and half of urea with the soil of planting hole/pit.
 Apply the rest half of urea after 30-40 days of planting the seedlings (if drought starts, be
careful about the application of urea.
C4 Watering/ Irrigation
 If watering/ irrigation is possible, seedlings must be benefited and growth will be enhanced.
C5 Mulching
Mulching is useful to conserve soil moisture for the seedlings during the dry period and release nutrients
after gradual decomposition.
 Mulching helps to conserve 20−25% soil moisture, thus helps the seedling further growth
during dry period.
 Kitchen waste (biodegradable) and leaf-litter/grass may be used for mulching in the camp
site.
 About 2” thick mulching may be given from 1-2” distance from the seedling.
D. Records, Monitoring, and Evaluation
 Make a register/plantation Journal for each site, indicating the details of plantation activities.
 Make a detailed map of the plantation indicating the ordinates, plantation type and species
with topography of the site.
 Keep record of all activities, e.g. nursery raising, purchase of seedlings (species, prices
and average height), field preparation and out-planting etc.
 Record the silvi-cultural treatments, e.g. weeding, cleaning, vacancy filling, mulching,
irrigation and any damages, if happened, etc.
 Take photographs of the activities (before, during and after planting activities).
 Record the survival, height growth and diameter of the seedlings plated at each site.

ADB - Camp 4

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Initial Environmental Examination

Project No. 52174-001

Emergency Assistance Project

Construction and operation of 2 integrated waste management and resource recovery

G0582-BAN: Emergency Assistance Project

Construction and operation of 2 integrated waste management

EXECUTIVE SUMMARY ........................................................................................................................ 1

Initial Environmental Examination i|Page

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B. Key Target Stakeholders......................................................................................................... 105

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Figure III.5: Existing status of solid waste management ....................................................................... 20

Initial Environmental Examination iv | P a g e

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4 The proposed subproject is envisaged to be constructed at camp 4 in Ukhia and camp 23 in

Initial Environmental Examination 1|P a g e

11 An environmental management plan (EMP) is developed to effectively manage any environmental

Initial Environmental Examination 2|P a g e

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B. Need for the Project

C. Impact and Outcome

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Figure I.1: Subproject location map

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F. Objectives and Scope of the Report

 Describe the project and its components.

H. Structure of the Report

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Chapter 8 - Grievance Redress Mechanism describes the process of addressing complaints.

Chapter 10 - Conclusion and Recommendations: It presents the findings, conclusion and

Initial Environmental Examination 7|P a g e

II. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

B. Environmental Legislation Framework

1. Overview of the Project Approval Process

2. Environmental Approval Framework

Initial Environmental Examination 8|P a g e

Figure II.1: Environmental approval framework

Initial Environmental Examination 9|P a g e

Table II.1: Required Permissions for Project under Bangladesh Legislation

 Green category projects:

 Orange-A category projects:

C. National Policies, Laws, Regulations

Initial Environmental Examination 10 | P a g e

Follow standards on quality

Sets limits for discharging

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Take precautions in laying

D. Relevant Occupational Health and Safety Laws and Rules

Title of Laws and Rules Descriptions

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Title of Laws and Rules Descriptions

E. Conventions, Treaties and Protocols

F. Environmental Categorization and Standards

1. Environmental Category: Bangladesh

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2. ADB Safeguard Policy (ADB Safeguards Policy Statement, 2009)

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 final or updated EIA and/or IEE upon receipt; and

Initial Environmental Examination 16 | P a g e

III. DESCRIPTION OF THE PROJECT

A. Need for the Subproject