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E-236 VOL. 3 GOVERNMENT OF THE PEOPLE'S REPUBLIC OF BANGLADESH MINISTRY OF COMMUNICATIONS ROADS AND ROAD TRANSPORT DIVISION ROADS AND HIGHWAYS DEPARTMENT FEEDER ROADS TYPE A (RRMP III) DRAFT ENVIRONMENTAL MANAGEMENT PLAN MARCH - 1998 L.G. MOUCHEL AND PARTNERS LTD., U.K. in association with BECA WORLEY INTERNATIONAL, NEW ZEALAND TRANSROUTE INTERNATIONAL, FRANCE ENGINEERING SCIENCE LTD., BANGLADESH Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized

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Page 1: E-236 VOL. 3 - World Bankdocuments.worldbank.org/curated/en/104661468743401121/pdf/multi-page.pdf · e-236 vol. 3 government of the people's republic of bangladesh ministry of communications

E-236 VOL. 3GOVERNMENT OF THE PEOPLE'S REPUBLIC OF BANGLADESH

MINISTRY OF COMMUNICATIONSROADS AND ROAD TRANSPORT DIVISIONROADS AND HIGHWAYS DEPARTMENT

FEEDER ROADS TYPE A (RRMP III)

DRAFT ENVIRONMENTAL MANAGEMENT PLAN

MARCH - 1998

L.G. MOUCHEL AND PARTNERS LTD., U.K.

in association with

BECA WORLEY INTERNATIONAL, NEW ZEALANDTRANSROUTE INTERNATIONAL, FRANCEENGINEERING SCIENCE LTD., BANGLADESH

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Page 2: E-236 VOL. 3 - World Bankdocuments.worldbank.org/curated/en/104661468743401121/pdf/multi-page.pdf · e-236 vol. 3 government of the people's republic of bangladesh ministry of communications
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Feeder Roads Type A Proiect Ens ironmenial Nianagement Plan

TABLE OF CONTENTS - ENVIRONMENTAL MANAGEMENT PLAN

Page

Executive Summary i

1. INTRODUCTION 1

1.1 Background I1.2 Summary of the Project I1.3 Summary of the Project Environmental Setting 41.4 Approach to Environmental Management and Monitoring 5

2. OVERVIEW OF IMPACTS AND MITIGATION MEASURES 6

2.1 Scoping 62.2 Potentially Significant Impacts and Mitigation Measures 10

2.2.1 Pre-construction Phase 102.2.2 Construction Phase 112.2.3 Operational Phase 132.2.4 Residual Impacts . 13

3. MAJOR MITIGATION PROGRAMMES 15

3.1 Introduction 153.2 Tree Planting 16

3.2.1 General Considerations 163.2.2 Approach to the Programme - 17

3.3 Rehabilitation of Borrow Pits 21

3.3.1 General Considerations 213.3.2 Reinstatement for Agriculture 233.3.3 Rehabilitation as Fish Ponds 25

4. ORGANISATIONAL ASPECTS 28

4.1 Management Framework and Overview of Responsibilities 284.2 Specific Environmental Management Activities and Responsibilities 30

4.2.1 Pre-construction Phase 304.2.2 Construction Phase 314.2.3 Operational Phase - 32

4.2.4 Summary of Management Measures and Responsibilities 32

4.3 Institutional Strengthening 34

5. IMPLEMENTATION SCHEDULE 35

5.1 Project Implementation Schedule 355.2 Environmental Management Implementation Schedule 35

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Feeder Roads Type A Project Environmental Management Plan

6. ENVIRONMENTAL MONITORING AND REPORTING 37

6.1 General Considerations 376.2 Pre-construction Monitoring 376.3 Construction Monitoring 386.4 Operational Phase Monitoring 396.5 Independent Review Monitoring 40

7. MITIGATION AND MONITORING COSTS 41

7.1 General Considerations 417.2 Borrow Pit Programme Management 417.3 Support to NGO Managers 427.4 Costs of Independent Environmental Review 43

Appendix I ReferencesAppendix 2 RHD Tree Planting Guidelines

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Abbreviations used in the text

CCDB Christian Commission for Development in BangladeshCSMC Construction Supervision and Monitoring ConsultantDC District GommissionerEA Environmental AssessfnentEIA Environmental Impact AssessmentEMP Environmental Management Plan

EP Entitled PersonER Engineer's RepresentativeFRA Feeder road Type A-FRB Feeder road Type BIBRD Intemational Bank for Reconstruction and Development

LCS Labour Contracting SocietyLGED Local Government Engineering DepartmentNGO Non-Governmental OrganisationOD Operational DirectivePAH Project-Affected-HouseholdPAP Project-Affected PersonPCWD Project Civil Works DirectorPIO Project Implementation OfficeRAP Resettlement Action PlanRE Resident EngineerRHD Roads and Highways DepartmentRRMIMP2 Rural Roads & Markets Improvement and Maintenance Project IIRRMP3 Third Road Rehabilitation and Maintenance ProjectSEP Site Environmental PlanTA Technical Assistance

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Feeder Roads TF pe A Project Ens tronrnerial Nlanagemeni Plan

Executive Summary

This Environmental Management Plan (EMP) forms part of the environmental documentation for theFeeder Roads Type A (FRA) component of the Third Road Rehabilitation and Maintenance Project(RRMP3) in Bangladesh and has been prepared in accordance with IBRD guidelines.

Social and socio-economic impacts, mitigation and management measures associated with theofficial land acquisition process are not considered in detail, as these matters will be dealt with in theconsolidated RRMP3 Resettlement Action Plan (RAP) which is currently under preparation.However, in the interests of completeness, these matters are briefly referred to where appropriate.

The ProjectThe FRA project will comprise rehabilitation and maintenance works to approximately 500 km ofroad sections which are all located in districts lying to the west of the Brahmaputra - Jamuna -Meghna river. The principal components of the works will include (as necessary on each section):

* widening of embankments to achieve the required minimum crest width of 7.4m to accommodatea 3.2m carriageway with 1.5m sealed shoulders and 0.6m earth shoulders on either sideflattening of side slopes to 1:2 v:h to achieve stability, and provision of erosion protection

* raising of embankment crest levels to allow all-weather use in floods up to a I in 10 year event* limited construction of new embankments, in situations where there is a need for minor

realignment to improve sight distances or to reduce the radius of curvature on sharp bends in theinterests of road safety and suitability for higher vehicle speeds, or where there is effectively noexisting embankment, or where existing embankments are threatened by river erosion

* pavement improvements* rehabilitation and/or replacement of existing culverts and bridges* construction of new culverts and bridges

On all sections within the project, embankment and pavement improvements will form the bulk ofthe works.

The civil works will be carried out under a number of construction contracts, let under nationalcompetitive bidding procedures acceptable to RHD and the Bank. Within each year of the three-yearconstruction programme, several contracts will be executed concurrently. Construction is expectedto be relatively labour-intensive, with approximately 25% of the total construction cost of the worksbeing labour-related.

Project Environmental SettingAll the sections of road included in the overall project lie iii flat areas of the western parts ofBangladesh, either within the floodplains or the delta lands of the Brahmaputra-Ganges-Jamuna-Meghna river system. Land use is dominated by smallholder subsistence farming centred on theproduction of rice, although a wide range of other crops are also grown.

There are no areas of high ecological value, such as natural forest, mangroves or undisturbedwetlands, along or in the immediate vicinity of any of the project roads, all of which pass throughlands which have been heavily modified by man in connection with agricultural development.

Impacts and Mitigation MeasuresThere is a general similarity in the environmental settings of all road sections within the overallproject and, although there will be some variation between sections in terms of the nature and scaleof the improvement works, these too are broadly comparable. As a result, there are no majordifferences between sections in terms of potential environmental impact.

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Feeder Roads Type A Proiect Ens ironmental MNanagement Plan

All impacts are such that they can be controlled to an acceptably low level through the adoption ofsuitable mitigation measures. Residual impact is expected to be low in all cases, providing that thespecified mitigation measures are fully adopted.

The potential impacts on which the environmental rnanagement is focused, and the mitigation/enhancement measures which will be adopted are outlined below.

Pre-construction phaseDuring the pre-construction phase, significant adverse potential impacts could arise from the need foracquisition of land and property in order to accommodate the proposed works; a major part of whichwill comprise embankment widening. Effects on family wealth and incomes have the greatestpotential significance. Lesser impacts will include inducement of uncertainties amongst the localpopulation, regarding various aspects of the land acquisition process, which disturb family life andcan promote social unrest, and problems associated with stimulation of new construction solely withthe aim of fraudulently obtaining compensation.

Considerable effort has been expended by the Phase I design consultants to minimise the area of landwhich needs to be acquired in connection with the works, since this is the most effective mitigationmeasure. It is expected that this approach will continue to be adopted in relation to Phase 2 design.Nevertheless, approximately 210ha of land will need to be acquired for the overall project, of whichabout three quarters is expected to be agricultural land and the remainder homestead land. In total,some 21,300 households are expected to be directly affected by the land acquisition process; anaverage of 42 households/km.

Although the number of PAHs is very high, it should be recognised that, for the majority, the extentof impact is expected to be marginal, since only a small proportion of an individual's landholding islikely to be affected by land acquisition. Analogy with very similar FRB projects suggests that abouttwo-thirds of affected households will lose less than 5'%o of their holding, 87% less than 10%, andonly 1.5% more than 20%.

In the case of homestead land, it seems unlikely that acquisition of a narrow strip will result in theneed for demolition of houses and/or relocation, since nmost are set back from existing road marginsby at least 5-6m, and in many cases, by far greater distances. The high level of agriculturallandholding fragmentation is expected to result in land acquisition having only marginal effects onall but the smallest landholders, sharecroppers, agricultural labourers, and the relatively few peoplewho rent agricultural land.

Payment of compensation for acquired land and other assets is expected to reduce the financialeffects on PAHs to an acceptably low level, provided ithat the compensation paid truly reflects thefinancial losses- incurred. Support to PAHs, in various iForms including income-restorationprogrammes, will be provided under the RRMP3 RAP programme, which will include elementsrelating to families, individuals and groups who are both directly and indirectly affected by the landacquisition process.

The probiem of community uncertainties regarding land acquisition will be dealt with by the NGOappointed by RHD to oversee and assist with RAP implementation, who will be responsible forpromoting (in conjunction with the local authorities, and as an integral part of. implementation of theRAP) an information dissemination programme to those likely to be affected, primarily on acommunity basis, but witf individual assistance to those families who require it.

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The NGO will also be responsible for preparing a dated photographic or video record of the land tobe acquired, immediately before commencement of the land acquisition process, whose existencewill be publicised, and which will be used as a means of minimising and refuting fraudulentcompensation claims relating to the recent erection of structures.

Construction phase

Employment opportunitiesBeneficial impact will arise from employment opportunities for local people with contractors. Inorder to enhance this aspect, the construction contracts will include clauses to require the contractorsto maximise local hire of labour; to carry out at least 25% of the works (as measured by contractvalue) by hand labour; to take positive steps to recruit women, the poor and destitute and the landlessas labour; and to ensure that at least 30% of the unskilled labour force employed at any one time isfemale.

Loss of roadside treesLoss of roadside trees resulting from the need for clearance to accommodate embankment raising andwidening works (mainly in connection with the latter) and pavement improvements is a majoradverse potential impact affecting all sections. Apart from their aesthetic value, the trees provide animportant source of fuel and/or income for the poorest sections of the community, and in particularfor poor women.

Various engineering options to reduce the need for felling were investigated, but none were found tobe feasible. The extent of loss cannot be quantified at present, but it is clear that on nearly all lengthsof road which traverse open agricultural land, most, if not all, the existing trees on embankments willhave to be felled. In most cases, the trees are relatively young, having been planted in the last 6-10years, and the number of mature trees affected will be relatively low. In locations where large banyanitrees are located close to existing road margins, embankment works have been designed so as toavoid the need for felling, since these trees have high cultural significance.

Mitigation will take the form of a major tree-planting programme which will result in a net gain inthe numbers of roadside trees, and will provide benefits in terms of employment for the mostdisadvantaged sections of local communities.

Tree planting will be carried out in broad conformity with the RHD Arboricultural Unit guidelines.Approximately 2000 trees/km will be planted on average. Where embankments are low, two rowswill be planted on each side, with three rows on higher embankments. Provision will be made forprotecting young trees against depredation by livestock, particularly by goats. Bamboo, or a similartype of fencing is preferred to establishment of hedges compTrising compact, fast-growing busheswith a low growth habit, since protection is needed immediately after planting, and hedges will notprovide immediate protection.

Groups of the poor, destitute and landless (with particular emphasis on participation by women), willbe organised by an experienced NGO, to raise and plant the trees and subsequently to maintain them.The groups then share the benefits of the planting scheme as trees are harvested. Preliminaryassessment suggests that approximately 40 groups will need to be established in connection withimplementation of each year's planting programme to be executed over a period of 3 years. Short-term (about 12 months) paid work will benefit approximately 400 families per year. Additional andlonger-term benefits may arise if some of the scheme participants can be encouraged to use skillslearned in project tree-raising to set up their own home-based small-scale businesses.

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Feeder Roads Ty pe A Project En% ironmental Nlanagement I'lan

Land productivity loss associated with borrow pitsLong-term loss of productivity of land developed for borrow pits also constitutes a major adversepotential impact. Large quantities of borrow material will be required in connection wvithembankment works on all sections within the project. Preliminary estimates suggest that, on average,I 0,000m 3/km will be required. If the usual shallow side-borrow practices of local contractors were tobe permitted, this could adversely affect the productivity of approximately 500ha of agricultural landin total, through the removal of fertile topsoil coupled with worsening of drainage conditionsresulting from a lowering of ground level.

Government will not acquire the land needed for borrow pits, and agreement will have to be reachedbetween contractors and private landowners regarding lease fees. There is a high probability thatpayments under lease agreements would fail to provide adequate compensation for productivity loss.

Primary mitigation has involved minimisation of borrow requirements through careful engineeringdesign, and in particular, through restricting new embankment construction, raising and widening tolengths where it is absolutely necessary on sound engineering grounds.

Secondary mitigation focuses on three elements:

* introduction of clauses into the construction contracts which forbid extensive shallow borrowpractices (except in exceptional circumstances), require pits to be spaced at not less than 1.5kmintervals, and make provision for safeguarding the financial interest of landowners, mainlythrough requiring lease agreements to cover the nature and extent of post-use reinstatement works

- provision of advice to landowners concerning the likely eiFfects of borrow pit (and associatedaccess track) development on their land, and the options regarding post-use reinstatement, so thatappropriate lease agreement terms can be negotiated with contractors

- implementation of a major technical assistance programme to landowners, with the primeobjective of offsetting income losses resulting from reduced agricultural productivity, through theadoption of new or amended agricultural practices on affected land, increasing productivity on anowner's unaffected land, or the development of managed fish ponds

In the last two respects, it is proposed that the assistance should be planned, coordinated and partiallyprovided through an experienced national NGO, supported by local NGOs, particularly in relation tothe fish pond element. Landowners who do not wish to develop and operate fish ponds on their ownwill be encouraged to lease the borrow pits for pond development by local groups comprising thepoor and landless, with technical and management suppcort from a local NGO.

Erosion of embankmentsAll embankment materials are inherently easily erodible, either by rainfall runoff or wave actionduring flood episodes. In the long term, both embankment and pavement integrity becomethreatened, with consequent adverse effects on trafficability of the road and a reduction in the social,socio-economic and economic benefits arising from project implementation.

Embankment erosion will be reduced to acceptably low levels by the incorporation of clauses in thespecifications for the establishment of full vegetation cover on completion of the earthworks and, inthe case of wave erosion, the incorporation of suitable bank protection measures in the projectdesigns. Provided that routine inspections are carried out to identify any embankment sections whereerosion is taking place, and effective and timely remedial actions are implemented, embankment andpavement integrity will be preserved in the long term.

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Feeder Roads Type A Project En\ ironmental Nlanaeement Plan

Other construction impactsA number of impacts, which are associated with general construction activities are anticipated. Mostare short-term, reversible impacts. They include the following:

* Friction between imported work-ers and the local population* Increased pressure on local services; particularly medical facilities* Water pollution from sanitary and other wastes and spillages* Competition for water resources with other users* Fuelwood/forest depletion through use in contractors' camp facilities, tar boilers, brick kilns etc* Reduction of land use options for worksites and base camp areas if not properly cleared on

completion of the works* Overloading of road pavement and structures on mobilisation/demobilisation of heavy plant, and

by general haulage traffic* Increased traffic congestion and road safety problems associated with construction traffic* Interference with phone and electricity lines* Interruption to navigation caused by in-river construction works* Air pollution from hot-mix plants

All the above will be mitigated and reduced to acceptable levels through the inclusion of appropriateclauses in the construction contracts and enforcement during the construction period.

Operational phaseThe potentially significant impacts during the operational phase are:

* Major improvements in local trade and communications, and a reduction in transport costs, to thebenefit of all communities on both the improved sections of road and connecting roads.

- Impedance to boat traffic on navigable waterways resulting from inadequate clearance at new orreplacement bridges.

Continued long-term enjoyment of the benefits arising from the improved roads will only be possibleif effective routine and periodic maintenance is carried out. Otherwise, the condition of the roads andassociated structures will gradually deteriorate to the pre-project state. The matter of roadmaintenance is to be addressed under another component of the RRMP3 project, and therefore is notconsidered further in this Environmental Management Plan.

The design of all bridges has taken into account the need for adequate soffit and lateral clearanceunder flood conditions, according to the requirements for each class of navig-able waterway.Consequently, no impact is anticipated in this respect.

Organisational aspects

The RRMP3 project will be managed and implemented by RHD and its various sections and zonaloffices under the Chief Engineer. High level management and coordination functions for individualcomponents of the overall RRMP3 project will be provided through a Project Implementation Office(PIO) in Dhaka, headed by the Project Civil Works Director (PCWD).

The PCWD in his role as the 'Engineer', as defined in the construction contracts, will have primaryresponsibility for management and coordination of all matters relating to construction supervisionand monitoring, including environmental manag,ement. He will be advised and assisted in hismanagement functions by a joint venture of foreign and local consultants (the constructionsupervision and monitoring consultants - CSMC), who will be responsible for day-to-day supervisionand monitoring.

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Feeder Roads Ty pe A Project Enx ironmental Mianagement Plan

The CSMC Team Leader will be designated as 'Engineer's Representative'. and will be the primarylinkage between RHD and the consultants at project (Dhaka) level. He and his support staff will beresponsible for construction supervision and monitoring at site level, and wvill have environmentalmanagement responsibilities in this respect.

The CSMC team will include a part-time expatriate Environmental Specialist, whose responsibilitieswill include provision of advice and assistance to the consultants' Team Leader and his engineeringstaff on environmental matters, including those specifically involved in the implementation ofenvironmental management functions.

In his more general role as overall manager and coordinator of the rRA project; the PCWD will alsohave other high level responsibilities and functions, which wvill cover aspects of environmentalmanagement as well as implementation of the RAP. Since the NGOs responsible for planning andmanagement of the tree planting and borrow pit restoration programmes will be appointed by, andwill report directly to RHD, the PCWD will also have primary responsibility for these aspects ofenvironmental management, although the NGOs themnselves will be responsible for day-to-daymanagement of their mitigation programmes.

Implementation schedule

An environmental management implementation schedule has been prepared which is fullycoordinated and integrated with the preliminary project implementation schedule. This indicates allkey dates by which specified actions should take place by specified bodies, if efficientimplementation of the EMP is to be achieved.

Environmental monitoring

Monitoring during the pre-construction phase of the project will be concerned with checking that theproject designs and specifications incorporate appropriate measures to minimise negative impactsand to enhance beneficial impacts, and that appropriate environmental protection clauses have beenincluded in the contract documents to allow control of actions by the contractors which arepotentially damaging to the environment. This will be the responsibility of the CSMC Team Leader,supported by his Environmental Engineer.

Environmental monitoring during the construction phase will cornprise four groups of activities:

. review of the contractors' Site Environmental Plans, method statements and temporary worksdesigns to ensure that environmental protection measures specified in the contract documentshave been given due consideration and, when implemented, will provide an acceptable level ofimpact control

. systematic observation on a day-to-day basis of alll site activities and the contractors' offsitefacilities such as base camps and borrow areas, as a check that the contract requirements relatingto environmental matters are in fact being complied with, and that no unforeseen impacts areoccurring

• certification of site clearance, on completion of the works* monitoring related to the implementation of the tree-planting and borrow pit restoration

programmes

The first three activities will be fully integrated with other construction supervision and monitoringactivities carried out by CSMC. Primary responsibility for ensuring that an adequate level ofmonitoring is carried out in relation to these will lie with the Engineer and the Engineer's

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Representative, as part of their duties connected with controlling site activities. Actual monitoringwill be carried out by site staff from CSMC, under the direction of the Resident Engineersresponsible for each site. Technical support in terms of environmental expertise will be providedCSMC Environmental Engineer during his periodic visits to the sites.

Environmental inspection checklists for site use will be developed by the CSMC EnvironmentalEngineer in collaboration with the ER and REs, prior to the commencement of construction, so as tofacilitate systematic monitoring and recording. The Environmental Engineer will be responsible forproviding basic training in the management and monitoring of environmental aspects to REs and sitestaff, to be carried out prior to the commencement of construction, and on a refresher basis duringconstruction as required.

All environmental monitoring records will be reviewed initially, as they are received at the CSMCsite offices by the REs concerned, who will decide on the appropriate course of action to be taken incases where unsatisfactory reports are received. In the case of relatively minor matters, advice to thecontractor on the need for remedial action may suffice, but in all serious cases, the ER will beinformed without delay, who will either recommend to the Engineer an appropriate course of action,or will issue instructions to contractors to take remedial action, if his delegated powers allow him todo this.

Since the management and monitoring systems will all be effectively under the control of the projectproponent, it is recommended that an independent environmental review should be carried outapproximately 7 months into the first year's construction programme, so as to provide a fullyindependent assessment of the environmental performance of the adopted impact control measuresand procedures.

Environmental management and monitoring costs

Many of the costs associated with implementation of the Environmental Management Plan havealready been, or will shortly be, included in the project budget, as an integral part of specific costitems.

The costs of the borrow pit reinstatement programme (excluding managing/coordinating NGO costs)will be met from private sources (lease payments and/or micro-credit arrangements) and, as such,should not be included in the project budget.

Incremental costs associated with implementing the EMP, which are not provided for under otheritems in the project budget are:

* NGO costs related to the provision of planning and implementation management/coordinationservices for the borrow pit reinstatement programmes (US$ 637,200)

* costs of provision of technical support to the planning/coordinating NGOs for both the treeplanting and borrow pit programmes (US$ 310,500)

* costs of implementing an independent environmental review (US$ 20,400)

In view of the importance of the tree planting and borrow pit programmes to minimisation of two ofthe three key adverse impacts of the project, and therefore to overall environmental performance,together with the desirability of having a completely independent environmental review during theconstruction phase, it is proposed that the costs of the above items should be met wholly by the Bank.

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Feeder Roads Ty pe A Project Environmental Manaeement Plan

SECTION 1

INTRODUCTION

1.1 Background

This Environmental Management Plan (EMP) forms part of the environmental documentation for theFeeder Roads Type A (FRA) component of the Third Road Rehabilitation and Maintenance Project(RRMP3) in Bangladesh. It has been prepared in accordance with IBRD guidelines and follows onfrom:

* a sectoral EIA (SEIA), which was developed in the early stages of project preparation, whenprioritisation studies were still underway, and the choice of road sections which would ultimatelybe included in the project had not been made (Mouchel 1997)

* an environmental review (ER) of the road sections selected for inclusion in the overall FRAcomponent, which was carried out in order to establish whether or not project implementationwould give rise to unacceptable adverse environmental impacts on any of the sections (Mouchel1998)

In this EMP, social and socio-economic impacts, mitigation and management measures associatedwith the official land acquisition process are not considered in detail, as these matters are dealt within the consolidated RRMP3 Resettlement Action Plan (RAP). However, in the interests ofcompleteness, these matters are briefly referred to where appropriate.

In general, impacts and associated mitigation measures are also not described in detail: these mattershaving been dealt with at some length in the SEIA.

1.2 Summary of the Project

The FRA project will comprise rehabilitation and maintenance works to approximately 500 km ofroad sections (Table 1.2), which are all located in districts lying to the west of the Brahmaputra -Jamuna - Meghna river (Figures 1 .2a & b, at the end of this section).

Land acquisition will be carried out under the standard procedures provided for by Bangladesh law,and in a manner which is acceptable to the Bank. An NGO will be appointed to oversee and monitorthe land acquisition and compensation process, under arrangements which will be set out in the RAP.The NGO will also be responsible for implementing certain'aspects of the RAP which, in broadterms, are related to the provision of support to the various categories of Project AffectedHouseholds/Persons (PAHs/PAPs). All land acquisition and payment of compensation (with theexception of disputed compensation) will be completed prior to the commencement of works on eachsection.

It is anticipated that approximately 210ha of privately-owned land will have to be acquired toaccommodate the project permanent works, and that some 21,300 families (PAHs) will lose part oftheir landholding (Table 1.2).

The principal components of the works will include (as necessary on each section):

* widening of embankments to achieve the required minimum crest width of 7.4m to accommodatea 3.2m carriageway with l.5m sealed shoulders and 0.6m earth shoulders on either sideflattening of side slopes to 1:2 v:h to achieve stability, and provision of erosion protection

* raising of embankment crest levels to allow all-weather use in floods up to a 1 in 1O year event

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Feeder Roads Ty pe A Project Environmental Nlanagement Plan

* limited construction of new embankments, in situations where there is a need for minorrealignment to improve sight distances or to reduce the radius of curvature on sharp bends in theinterests of road safety and suitability for higher vehicle speeds, or where there is effectively noexisting embankment, or where existing embankments are threatened by river erosion

* pavement improvements* rehabilitation and/or replacement of existing culverts and bridges* construction of new culverts and bridges

On all sections within the project, embankment and pavement improvements will form the bulk ofthe works.

The embankment works will require large quantities of fill material, which will be obtained bycontractors from new borrow pits, developed in convenient locations relatively close to the existingembankments. No excavation from existing side-borrow pits wi:ll be permitted for reasons relating toembankment stability. The contractors will be responsible for making their own arrangements withprivate landowners for temporary use of their land as borrow areas. Government will not acquire theland needed for borrow pit development.

Pavement sub-base and base layers will be of crushed brick mixed with sand. Wherever possible,existing pavement layers, some of which include HBB surfacing, will be reworked. The runningcourse will be bituminous surfacing incorporating crushed river gravel. The sealed shoulders, whichwill be used largely by rickshaws, will have a single spray and chip plus slurry seal surface.

Major bridge construction is likely to be of very limited extent: for example, only one major newbridge will be constructed within the Phase I programme (on road 371, where a bridge ofapproximately 100m length is needed to link two presently-unconnected road sections). However, anumber of new or replacement bridges of lengths in the range 20-65m will also be constructed.

The civil works will be carried out under a number of consitruction contracts, let under nationalcompetitive bidding procedures acceptable to RHD and the7 Bank. Within each year of the three-yearconstruction programme, several contracts will be executed concurrently. Construction is expectedto be relatively labour-intensive, with approximately 25% of the total construction cost of the worksbeing labour-related.

Tree planting will fall outside the main civil works contracts, and will be carried out by local people,organised into groups and managed one or more suitably qualified and experienced NGOs, based onthe usual RHD Arboricultural Unit procedures.

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Feeder Roads Type A Plroject Environmental Managcment plan

Table 1.2 Sections includetd in Feeder Roads Type A project

Project Constr. Road Location Length LAR LARI LAR2 LAR PAIls3'

phase year section (km) total agric. home. (ha/km) Comments

No. (ha)I 1 511 Kotalipara-Kandi 9.76 3.86 2.89 0.97 0.39 410

1 117 Gournadi-Agailjhara-Kotalipara-Gopalganj 45.95 13.21 9.91 3.30 0.29 1930 Approx. I Ikm is on Water Dcv. Board land

I 371 Shahapur-Sholgati-Chuknagar 12.56 5.14 3.85 1.29 0.41 527 Major raisingover I km

1 433/435 Dapdabia-Nalchiti-Mollerhat 22.84 6.27 4.70 1.57 0.27 959 1.Ikm realignment to avoid rivcr crosion

1 415 Bhandaria-Sripur (with link to Kanua) 5.79 4.28 3.21 1.07 0.74 243 Major raising and/or realignment

1 508 Dhawa-lkri 14.75 5.87 4.40 1.47 0.40 619

1 439 Daulatkhan-liakimuddin 13.77 4.99 3.74 1.25 0.36 578

1 68 Bhaga-Lalpur-lshardi 26.72 5.76 4.32 1.44 0.22 1122

1&2 76A&B Sirajganj-Kajipur-Dhunal-Sherpur 55.61 3.94 2.95 0.99 0.07 2336 LA needed along 16km, remainder on (iovt land

2 418 Bhandaria-Paikhali-Kathalia 12.02 1.50 1.12 0.38 0.12 505 No raising: embankmenit relatively low

2 517 Kheaghat-Bankerhat-Veduria 19.41 7.20 5.40 1.80 0.37 815

2 509 Charkali-Telikhali 11.19 4.48 3.36 1.12 0.40 470

2 2 112 Kushtia-Poradaha-Alamdanga-Chuadanga 43.2 7.7 5.8 1.9 0.18 1814 Approx 16km on Govt land

2 72 Tabunia-Atgharia-Chatmoharpur-Baghabari 60.3 46.6 35.0 11.6 0.77 2533

3 516 Patgati-Tungipara-Gopalganj 17.2 7.6 5.7 1.9 0.44 722

3 420 Barisal-Lakutia-Babuganj 13.4 7.2 5.4 1.8 0.54 5633 510 Rahagaganj-Sadullahpur-Bhuterbari 12.0 6.0 4.5 1.5 0.50 504

3 77 Rangpur-Pirgacha-Sunderganj-Gaibandhat 67.9 36.6 27.5 9.1 0.54 2852

3 322 Pabna-Pakshi - 23.2 16.2 12.1 4.1 0.70 974

3 73 Madhahpur-Sathira-Bera 19.1 17.2 12.9 4.3 0.90 802 Major widening ofliighinembankmcnt

Totals 506.67 211.60 158.75 52.85 0.43 21278

Notes:I Assumes 75% of total LAR is in agricultural land2 Assumes 25 % of total LAR is in homestead land3 Assumes 42 direct PAHs/km

P age 3

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Feeder Roads TN pe A Project Env ironmental Management Plan

1.3 Summary of the Project Environmental Setting

All the sections of road included in the overall project lie in flat areas of the western parts ofBangladesh, either within the floodplains or the delta lands of the Brahmaputra-Ganges-Jamuna-Meghna river system.

Land use along the project roads is dominated by agriculture, and mostly by small-scale subsistenceagriculture based on one or more crops of rice, although sugarcane, maize and wheat are locallyimportant. Dry season cash crops such as potatoes are important in many areas, but particularly onroad 77 in the Rangpur area. Oilseeds (mainly mustard) are an important winter crop in most areas.Grazing of cattle and sheep is of more importance in the southern part of the project area than in thenorthern parts, but is always a subsidiary activity to food crop production, and mainly makes use ofseasonally fallow land.

Agricultural landholdings are relatively small, with most probably being between 0.5ha and 1.0ha,and are highly fragmented. Most holdings are owner operated, but sharecropping is widely practisedin most areas. Rental of agricultural land is relatively rare.

Homestead land holdings are much smaller than agricultural holdings, and most are less than about400m2 . Homesteads are generally concentrated in more or less continuous, but well-separated,settlement areas, found along all of the project sections. However, small and relatively isolatedgroups of homesteads are common in many areas. The smaller settlements are usually of ribbon type,with a single row of houses and gardens on either side of the road, sometimes including a smallbazaar area.

Small or large towns are found at the beginning and end of most, but not all roads, and also atintermediate points on many. These usually have a central bazaar area, which is relatively narrowand highly congested.

Many of the watercourses which run alongside, or are crossed by the project road sections are usedfor navigation purposes for all or part of the year; primarily by small- and medium-sized countryboats. Boat transport of goods is more prevalent in the southeni parts of the project area, where thereare many more permanently navigable waterways than in the northern parts. In the wet season, boattransport becomes important in all areas, and seasonally dry waterways become navigable by smallboats.

There are no areas of high ecological value, such as natural forest, mangroves or undisturbedwetlands, along or in the immediate vicinity of any of the project roads, all of which pass throughlands which have been heavily modified by man, in connectionr with agricultural development. Onlyone road (371) passes through an area of beels. Dakatia beel, which is crossed by the eastern part ofthe road, has very largely been developed for agriculture, and remaining open water areas are smalland discontinuous. A much larger area of open water still exists in Baratbhaina beel, which is crossedby the western part of the road, but in neither case is any natural wetland vegetation evident.

The land adjacent to all project roads is subject to flooding with variations in frequency, inundationperiod and depth, from road to road. On most roads, flood levels are below pavement base level, andonly minor raising will be required (usually of the order of 0.5m over lengths of a few hundredmetres).

It should be noted that erfibankment integrity of parts of road 76a is potentially under threat, as aresult of the poor condition of the Jamuna flood embankment in that area, which lies close to the east,and should provide protection against inundation.

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Feeder Roads Type A Prolect En% ironmental Manazement Plan

The flooding situation in relation to roads 72 and 73 is complex, since the alignment of both isroughly perpendicular to the so-called 'Green River', and in addition, backflooding also occurs.These matters need to be given careful consideration when the detailed designs of embankments,cross drainage structures and bridgres are being prepared during Phase 2 of the project.

Most of the sections included in the project are existing roads which currently provide through transitlinks for motorised traffic. Current traffic levels on these are generally relatively low, being of theorder of 100- 150 vehicles per day, of which a high proportion are non-motorised rickshaws.

1.4 Approach to Environmental Management and Monitoring,

The approach to EMP development has been based on recognition of the primary objective ofenvironmental management, which is efficient implementation of the measures necessary to avoid,minimise or offset adverse impacts and to promote beneficial impacts, so that the overallenvironmental performnance of the project is enhanced. In this respect, emphasis has been placed onfull integration of environmental management activities with other aspects of the overall projectmanagement effort, which themselves are directed towards the objective of achieving a properlydesigned and constructed project which meets its intended purpose and functions efficientlythroughout its life.

Environmental monitoring is an essential tool in environmental management, since it provides thebasic information for rational management decisions, and needs to be fully integrated withmanagement efforts.

Taking the above broad principles into account, the EMP has been formulated to address thefollowing matters:

* impacts which need to be controlled and the control measures which need to be adopted* appropriate management actions needed to implement the control measures and the bodies to be

responsible for their implementation* monitoring necessary for environmental management purposes, procedures to be adopted for

execution, and reporting so that monitoring results are fed back to those responsible for takenexecutive management actions and decisions

* the overall organisational structure necessary for efficient environmental management, and thecoordination linkages which need to be established between the various entities involved

* the programme for implementation of management and monitoring, fully coordinated with otheraspects of the project implementation schedule

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Fecder Roads T%pe A Pro ject Environmental Nlanagement Plan

SECTION 2

OVERVIEW OF IMPACTS AND MITIGATION MEASURES

2.1 Scoping

A comprehensive matrix checklist (Table 2.1 at the end of this section) presents an overview of thepotential impacts likely to be associated with the pre-construction, construction, and operationalphases of the FRA project. It also includes an assessment of significance, assuming that nomitigation or management measures are adopted to enhance beneficial impacts, or to mitigate,compensate for, or offset adverse impacts. In the interests of clarity of presentation, it should benoted that checkboxes have only been completed for those impacts which are considered to bepotentially significant; those relating to non-significant impacts have been left blank.

There is a general similarity in the environmental settings of all road sections within the overallproject and, although there will be some variation between sections in terms of the nature and scaleof the improvement works, these too are broadly comparable. As a result, there are no majordifferences between sections in terms of potential environmental impact.

Many of the potentially adverse impacts commonly associated with road projects will either notoccur, or are likely to be of low magnitude and negligible significance. Impacts falling in thesecategories are:

Direct impacts* Major landslides, slumps, slips and other mass movements in road cuts: the project roads do not

traverse hilly terrain and there will be no cuts; the landscape on all roads is flat and stable.* Erosion of land adjacent to the road arising from concentrated runoff from road drains: lateral drains

will not be installed and there will be no concentration of pavement run-off.e Alteration of groundwater regimes where road cuts intercept aquifers: the project roads do not

traverse hilly terrain and no cuts will be constructed.* Destruction or damage to terrestrial wildlife, habitats, biological resources or ecosystems that should

be preserved: no sensitive ecological areas are traversed by project roads, or will be affected by theproject works or operation of the improved roads.

* Alteration of hydrological regimes of wetlands by embankment construction, with harmful effects onthese ecosystems: no ecologically significant wetlands traversed by the roads; short lengths of newembankment will be constructed only where realignment is absolutely necessary, and all will haveadequate cross-drainage openings.

. Interruption of migratory routes for fish, other wildlife and livestock: project-improved cross-drainage works will, if anything, result in marginal improvements for the passage of fish throughembankments; no migratory routes for animals occur within the project area.

* Increased vehicle collisions with wild animals: not relevant as large wild animals are extinct in theareas traversed by the project roads.

* Transmission of communicable diseases from workers to local populations and vice versa: mostworkers will be local; STD's from prostitution around camps are a special case.

* Creation of temporary breeding habitats for mosquito and other insect vectors of disease, e.g.,stagnant pools of water: large numbers of such pools exist already; increase in numbers arising fromborrow pit development will be insignificant.

* Creation of transmission corridors for diseases, pests and weeds: the roads already exist, and no newtransmission corridors will be opened up.

* Displacement of public buildings and facilities by land acquisition: new alignments have beenselected to avoid affecting mosques, temples, schools, government buildings etc.

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Feeder Roads T% pe A P'rojecc Env ironmental Nlanagcmcnt Plan

* Loss of cultural heritage: very few cultural heritage sites, mainly in the forn of old temples, occurnear to the project roads, although there are numerous eidgah, graveyards, mosques and associatedproperties; new alignments have been selected to avoid encroachiment and none will be affected.

* Increase in noise and air pollution from vehicles; road improvernents are unlikely to result in project-generated traffic sufficient to cause significant incremental impacts.

* Community severance effects resulting from higher traffic levels and vehicle speeds: improvementsunlikely to give rise to motorised traffic levels or increased speeds sufficient to cause significantimpact.

Indirect impacts

* Stimulation of unplanned or illegal timber cutting: the project roads do not traverse or provideincreased access to areas with significant timber resources.

* Stimulation of unplanned or illegal land clearing: all land is already utilised or clearly owned andmanaged; displacement from agricultural land will be very limited and compensation payments atmarket value will allow purchase of replacement land which has already been developed; newalignments have been selected to avoid causing displacement from housing, and there will be nomass displacement of population to undeveloped areas.

* Long-term or semi-permanent destruction of soils in cleared areas not suited for agriculture: notrelevant for reasons given above.

• Unplanned development and illegal invasion of homelands of indigenous peoples by squatters andpoachers causing serious social and economic disruption: not relevant as no such homelands exist onor near to the project roads..

- Destruction of or damage to terrestrial wildlife habitats, biological resources or ecosystems thatshould be preserved, by induced development: project roads will not create any new access to anyareas of ecological significance.

• Stimulation of land speculation: project roads are all located in rural areas and the improvementswhich will be carried out are not such as will stimulate major new development such as housing orindustrial estates.

• Impacts associated with quarr-v development: unlikely that any new quarries, will be developed tosupply materials in connection with the works; marginal incremental impact at existing workings.

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ds Type A Project Etrxironncctat NI:irropcrl,c t Ilan

Table 2.1 Impact Checklist (Sheet 1)

Potenholty affeded envsronmental oomponentstvalues Potential impad dharacterisalion Evaluation

Air Water Land Flora & aua Human use Ouslity of lif Type Effect Curaion Change Area] eulent Baseline Significance lenetchange without ettigatlon

A 01 1

land s p _ __rl1 1 Not rnonaty a pmrhlem o mrural road projects in Bangladeshnsowconbucton loo _ i I r- b roccurt some ent al +on

bvagdesrne" o nsWW oa I h t - i 1 I SuLrveytito ottume tra ui"ng: no n

irptacametntfrom t homestead ld [ | I x ] I X X X KA Individual tosses mainly smatt teess hos plhty d mliton

,s ylac er tsn I IXltoidividua t losses m a nle y sm all. relaiu el t PA H x wit suf f w i Ter Ind.rect eff ecssptacenrrtfrontareast - Numbersof PAHsneeding elocationtonesssites likely t.obeu ery lowrvatoprnerson nesugeble sites - -1 _I .…as aboue

I__ f__li s _tornmerc_ t- p emises I I No II Isuc land & premises tob ho acquiedr transient effacts o squatersIofpubticobtdutn dfadtles - I I L I 1 | I I No public baildingstaocllities affected bry land acquisitionWnEdu tw etnomhredemrl1 i No iijtwal her|tage affected by land acquisition

epojrnt'gireviopalio_rre II 't ___ | i- | |-t- L ] -t- 2<. < ___ I JI I -1s :

_ _1MUN" for IDCNI po>axnd. x -+ + X I X KB Major employmnt opportNnities during construchion per-iod*en trrprtad workteAandloWMlpopnttlor I ! ,_---- - -kajorty ~olorho,c will !hoied locally; ineurlahle o.n-signilcrr-t impactsatmr on loca services (hoOphattla scbools etc) 1 i 4ii - - IC IC-G Constwolion accidento likely to put pressure on local rned,cal tacd,irtin

Strata esettary and ottsar waateslsptaagea Ix] X I x - - - - L.J.......1 .~~~~~~ ~ 1 K X IC X GA Potenbaelprb hlp mataem lworasltws.scamps,psplantntarTinJetc________________ _ P-W 4Az i H J J] n x < I +- i ___ ______=_-x---=-=-

or w ater r eoras wr exisrig us ta I Ix I I 1 II I I X G Ptenal lem i dn where water resourcs ar firn,_ed

=X+ WXXCS----8t 3~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~- sreore aeWe

dtikt by trapp . ktting etc K=Nosignikicantwldlite neara soy prject roads fish resources need protectn__use _p _____fird s __e da __nce lmi-exua1 1 1 XC-I - XI GA -Potential locatised prublem mainly In camp areas & major struicture sites

aojptt of Ontbyaaleeanctadquemona andneta - - -1 t i i tI I i~I - Unlikety tohbe a significant problem in rural areas

of heavyirptanrfdschtnaey + I 4I I I,j_____I___tromad steucttte and pavemafri l. ! . .e. .iM2 _ GAPtnilpolmo n sections where heaoy plant in to be deployed

tbatficcongastton&roadaafatptsezarde 1. j) I It I I I ~~~~ I xxi xl lxi I XI GAr I Litoc major plonte needed:aminoredcon estionnproblemsro onensoon svtrserr-

ive or rare hbabta j ! I j[ J __ Io sensitlue hab,tat cearance needed; no ImpactadjacMtOeatittlfoingrmad ft 1. .x. J I- tX I tI It It I KA Major treeclearance iklon all sectionsas duat reuisanc am bornaitetkee deinsolftlonr No major demolition necessary, no signifi cant impact

nuisance ____ __MM…- - --w .s----Clow- - - GA Onlyminor siteclearance involved; no significant Impact.

ve "rvlcn ~~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~~~~~~~~~X l x IC t Xt ItG Phone and electricity lines located along or cross many sections

rrfilopeeatn of qianfstaa lI [1______ No new quarries. marginal incremenlal_impact at existing quames

o ewtdt S Ions of habita I

rhsenweo eaefrorsaggregate weabtsh 1k________________Iof tardscpe bsataollftp

coinatr { xi xV ~ x It IC - KA Ngttoccur on all secln.tfota rall to ho affected wifllb ho rgh__

________________________ - I - ~~~~~~~~~~~ - -1 1 -~~~ ___ AtborrOsePria writ ho hr Oat lands witSAR no rpitoaOUbephiffatrvdserosionnn prisk

mmas rlotkWaetp ttazaa on abrarsdortret1I Annai ost andnsg renter- will bet hoincr-eased qg-n-illcAntlyn

anIta larsatacape qarebly 1 - - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ l Lanoacape qoarity hr potershot korrose amos near to rLoado 5 lore nar fonoad- row

K1Bw key beneficial KA= key advferse GA= general adverse Pope fi

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[yr rronmentttl Nlarnirnmnrirr Kin~fTable 2.1 Impact CheckliSt (Sheet 2)

Potentially Circled ealryonmental comporenltslvalues Potentiai impact characledsalion Evaluation

Air Water Lenid Flora it founa Human use Ouality of life Type Effect cturatly e ru etn aseline signilicance levelclrange wilhoUt mritigation

lvlethis andassoclsted potential Impacts I j Commewts

enfropiieslton ofspelltdisposalareas HI PAdipsla m

iel -b -csa;nsrnrPactdisplacemsent from pmductive land 3 -

HItve Irehltaldidtulutetce to wildlife 3 * - - i L - - - J I ILnIoferosloeiVsdrmenl tteposlinr -

Altdust nulssnoe 1 ii- - --

__-- __________ l lii---lngttom speciletpt V- }4

lIe peantertr & stoactros x IX 111 i I j L x ~- V GA Posrlonatelincrvtigrad oerorrycurafttconge"ttn & mad safety he~naalo 11 i3 ItrF1~ - GA Localined problems us most sectios. partrcularly in barar arya-If noise and air polluhoa - I--_ _ue - lvvre haula ge traffic iostfricient tor Signiricant naIn emeal rotructI dua nuisance ott unsurtaed haul routes 1 livor local prvblnm In locations whee ha.l roules are unsurfaced£ riaeconstrutiollnMl of tsndscape InstbIlty ~K T 3- 3Ladcafpeun~aqlsectiosfaan tbe ronipactsteo deosIion eoteoltlt elopes ~x I x 3 3I {x r~A All erbankbment maerials readily erodible; no cuts to he -cu.ottroCnrt

ft as obeleucllon to Is tgaia13j Worb, mot unlikely to have significant effects on fish migraliownts, seutfems canting constyaclion N] -I- o culloas to be constructed~ no impact

0.111, ic195it05 4 f { i -. I -~~~~~~~~~~~~~~~~~~~ 1 MitroteOectsponnbde on Padn 01 OSly one secIrvo (117)~m e 5ibe n Frtsofonl on sdio (I17Nmitnlantadscape euallt

t.1i ivo, chaungesfoemhankrmevnts no significart chasng in landscatpets OPhbldgeso/.shermoarst#rufnctursed~ --- - ~4 i ~ -Of "ft OCWsmwm "ftoay Iun-ive or X - xl xI GAL rtentivalproblem at alltreplacementlslrctre siteshsfbe11Nptlco sedment Ieaedl saet aua s H-_I_ _ _71 L 2

1 7 L ior jr-ivr or amost odles9 no0 srynificant impactsooctefed witty stabslitrsllotn offernles by bridges I I - -- j I 3~~~~~~~~~~~I j I { j-3~~ 3 l~~'~ Hew Lodges constrocwtedidesundertuheedrunercthe illje notwreplacerela e renno Iteolgatluts tsp ttt-aIn~~~~~~~~s~otll5 ~ ~~ - 3 - - j ~ ~ ~ II - - X X3 K II PolesytTl problemn alarolem tea.fewdes depependinng on s con atm-cI-nrto genertion (mmn plle-iloivrng - L rr--- ----- -- 31trdplsnral sdn lnniat Impact lihelyovasfeoctien-- .rFI 7 4 i IIIr onltutmlx plants

pii--- t J~-~7}7 I ~ i - A oaie rb emiplnts sited oera settlementsfutnenood Rophase kitrbleitc gs"

A Pote,ollal problem on all sections as fuelwuod resources scarcerOise levels front lncfeas truftlI - - Traffic levels unlikely lo be highenuughr for Significant incremental impactIte poeaonlt tens tWmt Incresed bafIl - Traffic levels un-lrhet to be hrgh enough for Significant incernemoli -mpinar"trlc-generaled dual1 7 1 i-. Only shotrolength of curre.tlyr traffic-able pmoject sectionIs hre -unyrlced'noetayce effects dul 55 Witctessed botrfc

IIb,h-t _-9___ inte rl~P-- --io Mm A fguns Mmugh nolsel&cw$$/So"r4- z HO ner roads will be created; no impacteloptntent inprevountslyoesocesslhle treat I

tC

noegstio on connecting rod L evel of project-generated traffic unlnbely to caune signdicanr- erecdovesiaiddismunily lsoattOltton tagh ft dietfcresison N --- o diversion of traffic witl reoult~ no impact

________________ - o -~~~~~

I _ -fxx

I n Ie. polttea local cnetnrutlcsttdntrax

ceessthresetslutudtlo as coesnonan.s No -1-- -- - j 3 traitiovinal cmmmunrties on any sections roilhin the project, no impAct'plopiese oppeetanlle on fted masltretn5nce,L___4 _ -- xt X 1 I B--- La,,q.ternnemployment prospects f.rsmall numbers ofpvIadlrGvusrsfrtsunlane ibIot dueopset _pil.i- ---- - - -b -r mpovmdtevnibtktostmuat sgmicnIne rbbn e__etnndesISty heoseds r I ll

-- - - - - -- ~~~~~~~-TSigndicatirrinceaeselIn mtnrtrsed bjalti speedsiuvlumtne unlikely

K<Bm hey beti11ficitsl KAin key adVerse GAo general edVerse

-. s 1 I 'r5

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Feeder Roads Type A Project Environmental Mfanacement Plan

2.2 Potentially Significant Impacts and Mitigation Measures

In the interests of brevity, impacts and mitigation measures are described in summary form only inthe sections which follow. Details are given in the SEIA report (Mouchel 1997).

2.2.1 Pre-construction Phase

Impacts

There is only one anticipated key potential impact during the pre-construction phase:

Displacement from agricultural and homestead land, with adverse effects on social life and familyincomes which are derived wholly or in part from affected land and other assets. Approximately21 Oha of land will need to be acquired of which about three quarters is expected to be agriculturalland and the remainder homestead land. In total, some 21,300 households are expected to bedirectly affected by the land acquisition process (Table 1.2).

Impacts which are likely to be of considerably less importance are:

* Inducement of uncertainties amongst the local population, regarding such matters as whether ornot land and other assets will be subject to compulsory purchase by govemment, the extent towhich they will be affected, the form and adequacy of compensation arrangements, and the dateby which affected land and property will have to be vacated, all of which disturb family life andcan promote social unrest: the consequences of the latter being directed largely towards theofficials involved in the acquisition process and contributing to making the process more difficultand time-consuming.

* Stimulation of new construction solely with the aim of fraudulently obtaining compensation,which commonly has the effect of reducing compensation payments to those with genuineentitlement, either on this project or indirectly on others, as a result of constraints on the availablebudget.

Mitigation measures

Considerable effort has been expended by the Phase I design consultants to minimise the area of landwhich needs to be acquired in connection with the works. It is expected that this approach willcontinue to be adopted in relation to Phase 2 design. In this respect, design measures include:

* a policy that no raising of embankments should take place within built-up areas and bazaar areasin particular, and that no pucca buildings should be affected by land acquisition: widening ofembankments will only be undertaken in built-up areas where this is absolutely essential on thegrounds of preserving embankment stability

* restriction of realignment involving land acquisition to open rural areas, where only agriculturalland will be affected, and then only to locations where such realignment is considered absolutelynecessary for safety or other reasons

* where new embankment construction is necessary, as far as possible in the circumstances, thealignment will follow existing tracks

Although the number of PAHs is very high, it should be recognised that, for the majority, the extentof impact is expected to be marginal, since only a small proportion of an individual's landholding islikely to be affected by land acquisition. Analogy with very similar FRB projects suggests that about

Page I 0

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Feeder Roads Type A Project Environmental Management Plan

tvo-thirds of affected households will lose less than 5% of their holding, 87% less than 10%, andonly 1.5% more than 20%.

In the case of homestead land, it seems unlikely that acquisitiorn of a narrow strip will result in theneed for demolition of houses and/or relocation, since most are set back from existing road marginsby at least 5-6m, and in many cases, by far greater distances. However, a number of other domesticstructures such as animal housing, crop storage facilities etc, will be affected. Most such domesticstructures are in any case of simple kutcha construction, and could easily be dismantled and rebuilton unaffected parts of the homestead.

The high level of agricultural landholding fragmentation is expected to result in land acquisitionhaving only marginal effects on all but the smallest landholders, sharecroppers and the relatively fewpeople who rent agricultural land. The incomes of most agricultural labourers are also unlikely to beaffected significantly, partly as a result of fragmentationi of the holdings on which they work, andpartly because labour is normally drawn as needed fronm a large floating pool of workers, and fewlabourers have permanent relationships with specific parcels of land. In addition, many agriculturallabourers derive a large part of their income from work outside aggriculture.

Payment of compensation for acquired land and other assets 1is expected to reduce the financialeffects on PAHs to an acceptably low level, provided that the compensation paid truly reflects thefinancial losses incurred, whether these relate to wealth (in the form of asset loss) or income, orsubsistence. Support to PAHs, in various forms, will be provided under the RRMP3 RAPprogramme, which will include elements relating to families, individuals and groups who are bothdirectly and indirectly affected by the land acquisition process. The plan, which is currently underpreparation, will make specific provision for identifying and supporting vulnerable groups, includingwomen, the poor, the destitute and the landless. Provision will also be made in relation to relocationof squatters, although the present indications are that there are relatively few squatters on most of theproject roads.

The problem of community uncertainties regarding land acquisition will be dealt with by the NGOappointed by RHD to oversee and assist with RAP implementation, who will be responsible forpromoting (in conjunction with the local authorities, and as an integral part of implementation of theRAP) an information dissemination programme to those likely to be affected, primarily on acommunity basis, but with individual assistance to those families who require it. Provided that theprogramme is properly formulated and that due efforts are made to obtain and disseminate accurateand relevant information, residual impact should be low and non-significant.

The NGO will also be responsible for preparing a dated photogramphic or video record of the existingproperty on land to be acquired, immediately before commencement of the land acquisition process.This will be used to refute any fraudulent compensation claims. Provided that the existence of thevisual record is publicised by both the NGO and local authorities, and it is made clear that fraudulentclaims will not be entertained by the authorities, and may be considered as grounds for iegal action, itis expected that the incidence of such claims will be low.

2.2.2 Construction Phase

Impacts

A wide range of potential impacts is likely to be associated with tdhe construction phase, most but notall of which are adverse and direct, and are applicable to all sections. Key potential impacts whichhave been identified are:

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. Employment opportunities for the local population: this is likely to be a substantial benefit, asapproximately 25% of the works will involve unskilled labour, and there will be considerableopportunities for the poorest segments of rural society to participate, including the landless andwomen.

* Loss of roadside trees: this is a major adverse potential impact because large numbers of trees willhave to be cleared from embankments, in order to accommodate raising and widening works, onall sections within the overall project. Apart from their aesthetic value, the trees provide a sourceof fuel for the poorest sections of the community, and in particular for poor women.

* Loss of productivity of land developed for borrow pits: large quantities of borrow material will berequired in connection with raising and widening of embankmnents on all, sections within theproject, although there are expected to be wide variations between sections. In total, theproductivity of many hectares of agricultural land is likely to be affected, through the removal offertile topsoil coupled with worsening of drainage conditions resulting from a lowering of groundlevel. In addition, soil compaction along temporary access tracks by trucks is likely to result inadverse effects on post-use productivity.

* Erosion of embankment material: all materials likely to be used in embankment construction andremodelling are inherently highly susceptible to erosion, either by rainfall, pavement runoff, or bywave action during flood episodes. Such erosion, if left unchecked gives rise to shoulder andpavement degradation, and ultimately threatens the integrity of the embankment itself, withadverse effects in terms of a general reduction in the economic benefits which arise from roadimprovement.

In addition to the key potential impacts, it is very likely that a number of less important impacts willoccur during construction. These are essentially general construction impacts, and may occur to someextent on all sections under construction. Most are likely to be localised, reversible, short-tennimpacts, and will probably be of relatively low or moderate magnitude. They include:

- Friction between imported workers and the local population• Increased pressure on local services, particularly medical facilities- Water pollution from sanitary and other wastes and spillages- Competition for water resources with other users* Fuelwood depletion through use in contractors' camp facilities, tar boilers, brick kilns etc* Reduction in land-use options for worksites and base camp areas if not properly cleared on

completion of the works* Overloading of road pavement and structures on mobilisation/demobilisation of heavy plant, and

by general haulage traffic* Increased traffic congestion and road safety problems associa'ted with construction traffic* Interference with phone and electricity lines* Interruption to navigation caused by in-river construction works* Air pollution from hot-mix plants

Mitigation measures

Enhancement of empioyment opportunities during construction will be achieved through theconstruction contracts requiring contractors to maximise local hire of labour; to carry out at least25% of the works (as measured by contract value) by hand labour; to take positive steps to recruitwomen, the poor and destitute and the landless as labour; and to ensure that at least 30% of theunskilled labour force employed at any one time is female.

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Loss of roadside trees will be mitigated by a major tree planting programme, which will result inmore trees being planted than are removed in connection with construction. The essential features arethat mixed species planting of around 2000 trees/km and subsequent maintenance, will be carried outby groups comprising the most disadvantaged elements of local communities, organised by anexperienced NGO, and that those responsible for planting and maintenance will share the benefitswith RHD. This matter is dealt with in detail in Section 3.2.

It is also proposed that one or more NGOs should be responsible for developing and managing theimplementation of a mitigation programme in relation to agricultural productivity losses connectedwith borrow pit development by contractors. The programme, which is described in detail in Section3.3, will cover two aspects:

* advice regarding the possible long-termn consequences of agreeing to allow land to be used forborrow pit development, so that a suitable level of compensation payment can be negQtiated withcontractors

. advice regarding the options which are available in relation to borrow pit reinstatement for aproductive purpose once extraction has ceased, which could involve redevelopment for agriculture(with or without modification to crops, cropping patterns or seed varieties to suit the changedconditions), or as relatively small-scale fish ponds (to be operated by the landowner, or underlease arrangements involving locally-formed groups, with particular emphasis on the organisationof groups comprising the most disadvantaged members of local communities).

Embankment erosion will be reduced to acceptably low levels by the incorporation of clauses in thespecifications for the establishment of full vegetation cover on completion of the earthworks and, inthe case of wave erosion, the incorporation of suitable bank protection measures in the projectdesigns. Provided that routine inspections are carried out to identify any embankment sections whereerosion is taking place, and effective and timely remedial actions are implemented, embankmentintegrity will be preserved in the long term.

The general construction impacts will be mitigated through the enforcement of environmentalprotection clauses which will be included in the construction contracts. The main provisions in thisrespect are summarised in Table 4.2.4 of Section 4. Provided that construction supervision staff dulyenforce all the clauses, impacts should be reduced to acceptably lIDw levels.

2.2.3 Operational Phase

Impacts

The potentially significant impacts during the operational phase are:

* Major improvements in local trade and communications, and a reduction in transport costs, to thebenefit of all communities on both the improved sections of road and connecting roads.

* Impedance to boat traffic on navigable waterways resulting from inadequate clearance at new orreplacement bridges. - -

Mitigation measures

Continued long-term enjoyment of the benefits arising from the iimproved roads will only be possibleif effective routine and periodic maintenance is carried out. Other-wise, the condition of the roads andassociated structures will gradually deteriorate to the pre-project state. The matter of road

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maintenance is to be addressed under another component of the RRMP3 project, and therefore willnot be considered in this Environmental Management Plan.

The design of all bridges has taken into account the need for adequate soffit clearance under floodconditions, according to the requirements for each class of navigable watervvay. Consequently, noimpact is anticipated in this respect.

2.2.4 Residual Impacts

In all cases, the potentially significant adverse impacts associated with project implementation can allbe minimised offset or compensated satisfactorily, through adoption of the specified mitigationmeasures. Provided that the measures are actually implemented and, where necessary, are enforced,residual impact should be at acceptably low levels.

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SECTION 3

MAJOR MITIGATION PROGRAMMES

3.1 Introduction

Apart from implementation of the RAP in connection with mitigating the effects of land acquisition,two major mitigation programmes are proposed. They relate to replacement tree-planting and post-use reinstatement of borrow pits, and are focused on offsetting two of the most significant long-termadverse effects of project implementation: loss of roadside trees and a reduction in the productivity ofland which is used for borrow pit development. Both programmes are of considerable importance inrelation to improving overall environmental performance of the project, and it is vital that theyshould be implemented efficiently.

At the time of preparation of this EMP, individual contract details regarding works within the firstyear's programme were still to be finalised, and only limited engineering information was availablefor other roads within the project. In the case of tree removal, the numbers concerned and thelocations involved will not be known until a complete inventory has been carried out by RHDArboricultural Unit, following completion of the detailed designs. Borrow quantities will not befinalised until detailed designs have been completed. Borrow pit locations will be selected by thecontractors (subject to the approval of the Engineer), and will not be known until construction worksare about to commence on each section.

In consequence, the programmes themselves can only be developed to the conceptual stage atpresent. However, an integral feature of both programmes is the incorporation of a further planningelement to evaluate the required scope and extent, as well as to firm up on implementation details.

Both programmes will address livelihood restoration for project affected persons. However, becauseof the marginal impact which land acquisition is expected to have on most affected families, neitherprogramme is exclusively focused on this issue, although both programmes will cater for those whoare directly, or indirectly affected by land acquisition and who need income restoration support.

In the case of the tree planting programme, the focus will be on those groups, mainly comprisingvery poor women, who depend on existing roadside plantations for leaves and small branches used astheir domestic fuel, or who sell a proportion to derive income. The extensive tree felling which isneeded in connection with implementation of the works will deprive such groups of the resourcewhich they currently exploit. The programme will also be open to others representing the mostdisadvantaged elements of rural society, such as poor or destitute males and females, together withthe landless or functionally landless who have limited opportunities for income generation.

The borrow pit reinstatement programme will also not be specifically aimed at income restoration forthose affected by agricultural or homestead land acquisition, since it is unlikely that many PAPs willneed this type of support. It is however clearly focused on minimisation of the adverse effects ofborrow extraction on agricultural land, which constitutes an important impact, both in terms ofincome reduction and devaluation of a non-renewable natural resource. Participants in theprogramme will not only include those whose land is affected (even though they will have receivedcash compensation from contractors), but also, as in the case of the tree planting programme, thepoorest sections of society.

Income restoration matters are also addressed in the RRMP3 RAP, but this is primarily addressed atprovision of support to those affected by the official land acquisition process, whereas the

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programmes outlined above are primarily addressed at groups who will be affected by projectimplementation, but not through gzovernment acquisition of private land.

The question of whether the NGO responsible for assisting RHD in implementation of the RAP,should also be responsible for managing the tree planting and borrow pit reinstatement programmes,has been given careful consideration. Two factors were given particular attention:

* RAP implementation will very largely take place cluring the pre-construction phase for each roadsection, while the main work related to the tree planting and borrow pit programmes will takeplace towards the end, or immediately after cornpletion of the construction works on eachsection: ie. some 15 to 24 months later, when the RAP teams on each section have moved away toother sections

* there are grave doubts that the RAP implementation NGC) has the staff resources, technical andorganisational skills, local contacts and credibility, to undertake geographically dispersedprogrammes, which in the case of borrow pit development for fish production will involveprovision of continued support to those involved over a relatively long period

Consequently, the programmes have been planned on the basis that they will be implemented througheither local NGOs, or national NGOs with considerable experience in the relevant technical fields,and who already have a well-established local presence in the areas concerned, rather than on thebasis of implementation through the RAP NGO.

3.2 Tree Planting

3.2.1 General Considerations

The study and design consultants have investigated ways in which the need for tree felling onembankments could be minimised, including the possibility of widening embankments on one side,so that felling is needed only on one side. However, there are sound engineering reasons why this isnot practicable, mainly connected with the need to maintain approach geometry to the many existingculverts and bridges, which otherwise would have to be replaced. Realignment of approaches toavoid felling would unnecessarily incur additional construction costs but, and more importantly fromthe environmental viewpoint, would also result in slightly higher levels of socio-economic and otherimpacts associated with the need for additional land acquisition impacts, and even greater impact inrelation to the need for further borrow extraction.

In many cases where raising of embankments is currently being carried out under other projects, treefelling is being avoided through the placement of fill around existing trees. In such cases, mechanicalcompaction of placed fill is not being undertaken. This approach is considered unacceptable for thepresent project, since proper compaction is necessary to promote long-term embankment stability andpavement integrity.

Although the final crest width at pavement surface level will be a minimum of 7.4m, the minimumcrest width at pavement base level will be 9.4m. This latter width is the minimum width needed forconstruction of the improved pavement, since in most cases, pavement works will involve excavationof existing layers to a depth of lm, reconstitution and compaction of the base layers, and lateralextension of the base layers to accommodate the rickshaw lanes.

The maximum distance (at pavement level) between trees which have been planted on either side ofthe project roads is approximately 8.5m, although in most locations it is less than 6.5 to 7m. Thus,

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even if no flattening of embankment slopes is necessary, extensive tree removal would have to becarried out prior to the commencement of construction works. Where embankment sideslopeflattening and mechanical compaction of placed fill is to take place, the numbers of trees to beremoved will be further increased, beyond what is necessary in connection with pavementimprovement alone.

The net result will be that the majority of existing trees on embankments will need to be felled onmost the roads within the project. In most cases, the trees are relatively young, having been planted inthe last 6-10 years, and the number of mature trees which need to be felled will be relatively low. Inlocations where large banyan trees are located close to existing road margins, embankment works arebeing designed so as to avoid the need for felling, since these trees have high cultural significance.

Most tree clearance will take place in areas where the roads traverse open agricultural lands, sincethese are where most roadside trees have been planted. However, even though no embankmentraising will be carried out in built-up areas, there will still be a need for some clearance in connectionwith pavement improvement, and in some areas for embankment slope flattening, although this willbe on a much smaller scale than in rural areas, and will mainly affect privately-owned trees onhomestead land, for which compensation will be paid under the land acquisition programme.

3.2.2 Approach to the Programme

The prime objectives of the programme are:

• replacement of trees which necessarily have to be felled in connection with execution of theworksn provision of benefits to the poorest segments of society in terms of employment during planting,use of thinnings and prunings during the rotation period, and share of revenue on felling

- improvement in the visual quality of the roads• provision of shade for the many non-motorised users of the roads

In addition, planting of trees will make some contribution to discouraging squatter occupation ofembankments, and thus will reduce social problems associated with the need for displacement infuture years when further widening is necessary to increase road capacity.

Tree planting will be carried out through the RHD Arboricultural Unit, in broad conformity with theirexisting guidelines (Appendix 2).

Approximately 2000 trees/km will be planted on average. Where embankments are low, two rowswill be planted on each side, with three rows on higher embankments. In the rows nearest to thepavement margins, spacing will be at 6m centres. In other rows, spacing will be at 2m centres. Noplanting will be undertaken on the inside of bends, in order to avoid obscuririg sight lines. Provisionwill need to be made for protecting young trees against depredation by livestock, particularly bygoats. Bamboo or a similar type of fencing is preferred to establishment of hedges comprisingcompact, fast-growing bushes with a low growth habit, since protection is needed immediately afterplanting, and hedges will not provide immediate protection.

Groups of the poor, destitute and landless(with particular emphasis on participation by women), willbe organised by an experienced NGO, to raise and plant the trees and subsequently to maintain them.The groups then share the benefits of the planting scheme as trees are harvested.

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Preliminary assessment suggests that approximately 40 groups will need to be established inconnection with implementation of each year's planting programme to be executed over a period of 3years, on the basis that:

* a 3km section will be allocated to each group (this is a reasonable distance for travel to plantingsites for women, who wil! need to be fairly close to their-homes so-that work does not undulyinterfere with domestic commitments)

* 75% of the total length of roads within the project will require replanting, giving 125 km to beplanted each year over a 3 year period

* actual planting to take place over a two month period each year (June-July), before the onset ofthe flood season

* approximately 10 persons in each group, of whom about half would be directly involved with theplanting, and the other half involved in nursery activities, planting hole preparation etc.

In the interests of efficient management it is recommended that a single large and experienced NGOshould be appointed by RHD to oversee and manage the planting programme, although there is somemerit in the altemative of appointing two NGOs, one with responsibility for planting on roads northof the Padma river and one with responsibility for roads to the south. Whichever approach is adopted,it is essential that the NGO or NGOs concerned should have proven capability to organise andmanage extensive programmes. A prime criterion in selection should be that the NGO has existingextensive relevant operations in, and offices covering, all areas in, which the project roads are located.

Appointments need to be made well before (at least 12 rnonths and preferably 15-18 months) beforeactual planting is scheduled to commence, since an adequate lead time will be necessary in order to:

* identify, establish and brief groups* arrange benefit sharing agreements between RHD and the groups* ascertain group preferences regarding tree species to be planted- develop detailed implementation plans and planting schemes, taking into account group

preferences and the overall objectives of the schemes* establish sapling nurseries

Group establishmentOn each section of road, a number of groups will have to be established, each with responsibility forthe fixed length within their local area, so as to minimise problems associated with memberstravelling to sites in connection with planting and subsequent maintenance, the need for women inparticular to be near their homes etc. The length assigned to an individual group may involve one ormore separate locations, since in many instances planting will be discontinuous. However, it isimportant that each group should comprise members from A single Union Parishad and shouldoperate only in its own Union, so as to avoid difficulties between communities from differentjurisdictions. Since a relatively large number of groups is likely to be involved, the selection processfor the organising NGOs should take into account the need for demonstrable expertise and experiencein group management and coordination, as well as an existing presence in the areas concerned.

Potential group members should be identified by the organising NGO, through discussions with theChairmen of the Unions concerned, and should comprise the poor, the destitute, the landless andothers who are socially or financially disadvantaged, with preference being given to women who fallinto one of these categories. Other things being equal, first priority should be given to thosedisadvantaged persons who have been directly or indirectly affected by the project land acquisitionprocess or by felling of ekisting trees on embankments, and this will require consultation with theNGO responsible for RAP implementation.

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Once potential group members have been identified, it will be necessary to select those who willactually become members of active groups, since it is vital that numbers in each group should belimited, so that a reasonable return on their labour can be achieved. If a group is too large, there isalways a danger that an individual's share of benefits will be so small as to make participationunviable in terms of making a significant improvement in living conditions possible, and lack ofcommitment may result.

On the other hand, groups which are too small may be incapable of carrying out planting at asufficient rate to achieve completion in the relatively narrow planting window between the onset ofthe monsoon rains and the start of the flood season. In addition, the objective of improving livingstandards for the optimum number of families may not be met. In some cases, a compromise may benecessary between the numbers of people wanting to participate in the programme and optimumnumbers related to significant improvement in living standards for those who participate..

As part of the detailed planning process, the NGO responsible should determine the number ofgroups needed on each section of road, together with the optimum number of members in each,taking all relevant factors into account. Current RHD practice is for groups to comprise around 10members/km of road, but this should only be taken as indicative of the optimum number, which maywell vary within and between sections. Through consultation with the Parishad Chairmen, criteria forthe selection of group members should be developed, with high priority being given to thoseindividuals in greatest need of support.

Planting and benefit-sharing agreementsAgreement will have to be reached between the organising NGO and RHD concerning details of theplanting programmes on each road section, responsibilities of the various parties concerned andprecisely how benefit sharing of plantation production will operate. The current guideline form ofagreement developed and used by the Arboricultural Unit gives a maximum of 50% of the benefits tosocial forestry participants, which is lower than the 55% proposed for the forthcoming ADB ForestrySector Project for roadside planting.

The responsible NGO should assist RHD in developing a modified form of agreement, broadlysimilar to that proposed for the ADB Forestry Sector project. Local beneficiaries should receive100% of the benefits arising from any thinnings 6 years after planting, and of the trimmings arisingover the planned 30 year rotation cycle, in return for caring for the trees and doing simple routinemaintenance to the embankments. When the trees are felled after 30 years, the agreements shouldmake provision for felling revenues to be distributed between RHD, the local authorities, and localbeneficiaries and a tree replanting fund, with at least 55% going to local planting groups. Theagreements should also make provision for payment of a proportion of plantation establishment costs(probably around 15%) to the responsible NGO as a service charge, to meet administrative,management and other costs associated with setting up beneficiary groups and supervising nurseryestablishment, planting etc. The agreements should also involve Union Parishads as beneficiaries,since a share in the felling revenue will promote long-term interest in and security of the trees. RHDshould be responsible for providing the NGO with the funds necessary for procurement of seeds,fertiliser and other materials, including simple hand tools needed for plantation establishment, andfor payments to group members for their labour.

In this latter respect, it should be noted that the groups, being made up of the poor etc, are in need ofimmediate rewards in the form of cash for their efforts. If the programme is based solely on benefitsharing in return for labour, there is likely to be little enthusiasm for a scheme which effectivelydelays receipt of rewards for 6 years, at which time proceeds from the first thinnings would beavailable for distribution. Cash payments for labour should therefore be part of the programme.

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Selection of speciesSingle species planting dominates most of the existing roadside planting schemes which have beenestablished in recent years, with Sisso (Dalbergia sissoo), rain tree or Fulkorai (Samanea saman) andseveral species of acacia being most common. These are all basically timber or fuelwood species,although they also used for other purposes including animal fodder. For this project it is proposedthat mixed species planting should be adopted, in line with the recommendations made for Dhaka-Sylhet road project, with the mix being selected to include those which:

e are relatively fast growing and will rapidly produce good shacle

e are adapted to coppicing, so that benefits can be realised on a regular basis

• are relatively slow growing, but produce good timber in the long term• provide fodder for domestic livestock

Inclusion of fruit trees in the planting mix has been considered, but cannot be recommended. Manyfruit species such as mango and jackfruit are capable of producing good crops well after the age 30years, which is the RHD standard rotation. It is probable that considerable unrest would occur if aproductive tree were to be felled for its timber. In addition there are adverse road safety implicationsif ripe fruit falls on the pavement and makes it slippery, and potential problems associated with theftof either saplings or ripe fruit.

The responsible NGO should discuss with local beneficiary groups their preferences regarding themost appropriate planting mix, and take this into account, together with RHD Arboricultural Unitviews and the above factors, when developing individual planting schemes.

Plant nurseriesPlant nurseries will need to be established at an early date in order to grow seedlings on until theyreach the required height for planting out (I to l.Sm). While existing RHD nurseries could supplysaplings, these could be located far from the project roads, thus increasing transportation costs andintroducing difficulties in maintaining regular supplies to planting sites during the short plantingseason. Furthermore, existing nurseries have their own programme commitments to meet, and maynot have the spare capacity to produce the sapling numbers required to a tight time schedule.

The responsible NGO should determine the most appropriate nursery strategy for each section ofroad, taking into account such factors as the length of the sectjion, and the numbers of trees to beplanted at various locations. While there are advantages in making each planting group responsiblefor its own nursery, in terms of skills development reaching. a larger number of people, ease oftransport of planting material to work sites, promoting a sense of group responsibility etc., largenumbers of small nurseries may prove to be difficult to manage efficiently, and the altemative offewer but larger nurseries may have to be adopted.

Whatever strategy is adopted, the nurseries should be set up so as to produce approximately 50%more planting material than is required by the planting plans. This will make allowance for partialplanting failures, but more importantly, sale of the-excess by those participating in nursery operationswill provide additional income support at marginal cost. Some of those who develop tree raisingskills through involvement in nursery production on this project may find that they can subsequentlyoperate a viable small-scale business based on the homestead, thus extending the long-term benefitsof the programme.

The nurseries will need to be located near to or on the project roads, to facilitate transport of plantingmaterial to worksites at the beginning of the wet season. They should have sufficient area and

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production capacity to meet the requirements of the individual planting schemes that thev have beenset up to supply. Simple shade sheds may be necessary for raising certain species, and in all cases anassured supply of water will be necessary, which may involve provision of a shallow tubewellequipped with a pump. Security, in the form of a nightwatchman may be needed in some locations. Inselecting locations for nurseries, consideration should be given to the utilisation of khas land wherethis is available, as a means of reducing costs. Discussions with the local authorities will benecessary in this respect.

Organisational supportThe level of technical skill necessary to establish successful tree plantations is not particularly high.However a high level of planning and organisational skill is required if a major planting programmecovering some 500km of roads spread over a wide area is to be implemented efficiently.

In view of the importance of the planting programme in mitigating one of the major adverseenvironmental impacts of the project, and the fact that no provision has been made in the TOR for theconstruction supervision consultant or elsewhere for specialist inputs connected with the programme,it is thierefore proposed thzat:

* the Bank should finance a small TA sub-project to provide support to the NGO or NGOsresponsible for organising and overseeing the planting progranmme, with particular reference tothe provision of expertise and training in planning and other organisational aspects

* the TA should comprise provision of the services of an experienced Social Forestry Specialist foran overall period of 5 months, split into 3 inputs, being 3 months in connection with the firstyear 's programme and I month for each of the second and third year programmes

3.3 Rehabilitation of Borrow Pits

3.3.1 General Considerations

It is clear that large quantities of borrow will be required on all road sections in connection withembankment remodelling. Borrow quantities for sections within Phase I of the project, range fromapproximately 16,900m3/km for Section 511, which is on a very narrow and relatively highembankment, to 6,800m3/km for Section 433/435, which is on a relatively wide and lowembankment. The average is around I 0,000m3/km. Borrow will be obtained from pits developed bythe contractors, under private arrangements which they will negotiate with individual landowners.Government will not acquire land needed in connection with borrow pit development.

Contractors working on road rehabilitation projects in Bangladesh commonly remove material to arelatively shallow depth (approximately Im in many cases) from fields on both sides adjacent to theroad. This results in a reduction in agricultural productivity related to removal of the topsoil, whichcontains the bulk of the organic matter and plant nutrients in the soil profile, and forms the rootingmedium for annual crops. In addition, the resultant lowering of ground level means that drainageconditions become worse in the root zone in locations where the water table is at a relatively shallowdepth (which situation applies to most, if not all, sections of road included in the project during themain cropping season). The net result is that large areas of productive land become significantly lessproductive.

There is little which can be done in terms of adjustments to designs to reduce the quantities of borrowrequired if the design standards needed to achieve long-term embankment stability and flood

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protection are to be met, although the decision that no embankment works will be carried out in built-up areas has reduced borrow quantities to some extent.

The aggregate area of land which is expected to be affected by borrow pit development and theconsequent reduction in productivity is high. On the assumption that the maximum economic hauldistance is 2 kmn, individual pits would-need to be of 20000m3 capacity which, if they are excavatedto about 2.5m depth, would have an area of 0.8ha. The overall programme would require of the orderof 250 pits, covering a total area of 200ha, which is very close to the overall permanent landacquisition requirement of approximately 21 Oha.

Most landowners, and especially small landowners, already operate at or very close to subsistencelevel, and even marginal reductions in productivity are likely to be significant in terms of reducingfamily food production, or income in cases where a surplus is available for sale or trade. Paymentsmade under lease agreements for use of land for borrow pits are most unlikely to reflect the long-term consequences of productivity reduction, and consequent losses will therefore be largelyuncompensated, unless measures are adopted to minimise these aclverse effects.

In addition, there are likely to be problems associated with soil compaction on temporary haul routeswhich connect borrow pits with the roads, again in terms of a reduction in productivity. Most farmnersuse simple country ploughs for land preparation, which are capable of working the soil only to ashallow depth, and it seems likely that this would not be sufficient to break up compacted layerscaused by the passage of heavily-laden trucks. Even where mechanical rotovators are used, theseonly work the soil to a depth comparable with that which can be achieved with a country plough.Although the effects of such compaction in terms of productivity reduction are unlikely to be assevere as those associated with borrow extraction, they will nevertheless be significant unlesssuitable measures such as shallow subsoil ripping are adopted to restore the land after borrowextraction ceases.

It is proposed that a suitably qualified and experienced national NGO should be appointed by RHD toadvise and assist landowners on matters related to borrow pit lease arrangements and to plan, overseeand manage post-use reinstatement support. Local NGOs should also be appointed on each section ofroad to assist in implementation of the reinstatement process on a day-to-day basis, where these arein a position to provide the necessary technical expertise.

Given the importance of minimising the effects of borTow extraction in relation to the overallenvironmental performance of the project, and the likelihood that RHD may find it difficult to obtainlocal financing for the programme, since it represents a departure from the convention; it is proposedthlat:

v The Bank shouldfinance, as a supporting TA project, the costs associated with involvement of themanaging NGO, together with the costs of providing specific specialist technical support (asindicated in the sections which follow), and part of the costs of local NVGO involvement, especiallythose relating to training.

Only limited control can be achieved under the construction contracts in relation to the actions ofcontractors in relation to borrow pit development, since private arrangements with third parties areinvolved. However, clauses will be included in the construction contracts as follows, as a means ofreducing the possibility of exploitation of unsophisticated landowners by unscrupulous contractors,minimising the area of land affected, and to facilitate post-use reinstatement:

* contractors must make all reasonable efforts, to the satisfaction of the Engineer, to minimise thearea of land which will be affected by borrow operations. Ihe common practice of extensive

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Feeder Roads Type A Project Environmental Management Plan

shallow excavation will not be considered acceptable by the Engineer. Unless it can bedemonstrated to the satisfaction of the Engineer that there are exceptional circumstances, borrowpits on each section of road shall not be, on average, be spaced at intervals of less than 1.5km.

* contractors shall erect and maintain near the margin of each borrow pit, a pernanent referencebenchmark, of pattern, materials and dimensions acceptable to the Engineer, so as to facilitatedetermination of the volume of borrow excavated. In the event of the benchmark being damagedor removed, the reference level shall be deemed by the Engineer to be that of the highest groundlevel in the undisturbed plots which immediately surround the pit.

* topsoil to a depth of 0.3m shall be removed prior to excavation of borrow, and shall be stockpiledat one or more of the pit margins, and shall not be used in any way in connection withconstruction of the permanent or temporary works.

* no continuous length of borrow pit may cross Thana or Union boundaries, so as to avoid potentialownership or rights of use disputes between persons from different villages, in the event thatgroup usage of the site takes place after reinstatement. The maximum length of a single pit shallnot exceed 100m.

* the contractors are required to produce a certificate for each proposed borrow area and borrowaccess track, for approval by the Engineer, and before any site preparation or borrow extractionbegins, containing the following information:

* A site plan showing the location, area, current land use, names of landowners and theboundaries of individual holdings, together with photographs which adequately illustratethe present state of the site and its immediate surroundings under non-flooded conditions.

* Confirmation, in the form of signatures or witnessed marks,- from each landowner thatsatisfactory agreement has been reached with the contractor regarding payment for use ofthe land for borrow extraction, the period of the agreement including the expected dateon which borrow extraction is to commence, and the date by which all reinstatementworks will have been completed.

C A statement setting out clearly a plan and specification for the works the contractor willundertake in relation to post-use reinstatement, accompanied by signatures or witnessedmarks from each landowner that they agree to the proposed reinstatement works.

* A statement from the appointed NGO that the landowners concerned were fully briefedby them, prior to conclusion of financial arrangements with the contractor, regarding theoptions for post-use reinstatement, the recommended option for the site, and theimplications regarding future productivity, countersigned or marked by each landowner.

Copies of approved certificates shall be given to the contractor and each of the landownersconcerned.

The above provisions, unless they fail to be enforced properly, should reduce some of the potentiallyadverse effects of borrow pit development on landowners. However, additional measures will berequired to offset productivity losses. Over a 3-year construction programme, reinstatement measureswould need to cover about 80 new sites each year. The options for reinstatement are described in thesections which follow.

3.3.2 Reinstatement for Agriculture

Some landowners may choose to have their land reinstated for agriculture, but if pits are deeper thanabout 1-2m, it is unlikely that this would be the most satisfactory option. Where agriculturalreinstatement is preferred, the lease agreements with the contractors should require that oncompletion of borrow extraction, stockpiled topsoil should be spread evenly over the whole site andlevelled. However, problems related to deterioration in drainage conditions will still remain.

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The feasible options for reinstatement will depend on site conditions, and in particular on the localwater table regime and groundwater quality, and will need to be determined on a case-by-case basis.They will also depend on the preferences of the landowner, parnicularly in relation to the extent towhich he is prepared to make changes to his cropping system. In most cases, it seems likely thatsome degree of experimentation will be necessary over several seasons to find the-optimum solution.

Options which need to be considered include the introduction of alternative crops, modifications totiming of planting, and changes in seed varieties to suit the changed conditions. Improvements to theroads will result in improved access to markets for agricultural produce, and it is possible thatfarmers would consider switching production on affected land from rice to higher value crops such asvegetables, which would have the improved market access, lovier transport costs and reduced in-transit losses in quality, which are necessary to achieve the higher returns needed to make morelabour- and input-intensive cultivation viable.

A further option would be for a farmer to accept reduced production from a reinstated borrow pit, andto concentrate on making up the deficit through improving income from production on other,unaffected parts of his holding, either through yield increase of crops within his existing croppingpattern, or by partial switching to crops which have higher producer margins. This may be the onlyfeasible agriculture-based option in locations where groundwater ilevels are high for most of the year.

Crop yields in general are relatively low compared with those achieved in other parts of the worldwith broadly similar climate and soils, and reflect the low usage of inputs such as improved seedvarieties and fertiliser. A farmer who has accepted payment for use of his land for borrow extractionshould be in a position to make the necessary investment in higher inputs to achieve improved yields.

Whatever options are selected by the landowners concerned, technical support will be necessary interms of agricultural extension services. The Thana agricultural extension services are unlikely, ontheir own, to be able to provide an adequate level of support, as they already suffer budgetary andexpertise problems in connection with their existing programmes. It is therefore proposed that theprogramme should be coordinated, managed and at least partially implemented by the same NGOappointed to assist landowners in connection with the borrow pit lease agreements, with additionalinputs from the Thana agricultural extension services and such local NGOs as have the requisitetechnical skills.

Preliminary studies should be carried out by the managing NGO, prior to contractor mobilisation,with the objective of reviewing the options for site reinstatement, or the alternative of increasingproductivity on unaffected land, so that appropriate recommendations can be made to landownersbefore leases with contractors are signed.

The work carried out by the managing NGO in relation to assistance to landowners with leaseagreements will -allow definition of the probable numbers who will require support in connectionwith reinstatement for agricultural purposes or improvement of productivity on the unaffected part ofthe holding, and will form the basis for establishing a definitive scope of work, programme etc. forpost-use assistance. At this stage, the contribution to support activities that can be made by therelevant Thana authorities and by local NGOs should also be established. Training schemes for thosewho will be involved in programme implementation also need to be formulated and executed prior tothe completion of borrow activities on each section of the works.

From a technical viewpoint, the success of the programme vwill be improved if an innovativeapproach is adopted to identifying options for improving income from either reinstated sites or otherland. The managing NGO will probably need support to come up with truly innovative but practicalapproaches. It is therefore proposed that:

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* The Bank shouldfinance (within the overall TA support programme indicated above) provision oftechnical support to the managing NGO, with particular reference to assisting in theidentifcation and evaluation of options for borrow pit reinstatement and improvement ofproduction on unaffected land.

a The TA should comprise provision of the services of an Agricultural Extension Specialist withexperience of rice production and the introduction of other crops to paddy-based productionsystems. An input totalling 5 months will be required, with 3 months in connection with the firstyear 's programme and I month in each of the succeeding two years.

3.3.3 Reinstatement as Fish Ponds

Fish production in reinstated borrow pits is the most obvious potentially productive use for what inmany cases will be a large hole, which seasonally or permanently contains water. In many parts ofthe country, farmners have already developed fish ponds in rice lands, and not just in low-productivitylands. Clearly fish production must provide a return which is at least comparable with that which canbe achieved from rice production, in spite of the higher labour requirement.

As an alternative to development of managed ponds, which will involve labour and capital inputs,some farmers may prefer to rely on natural recruitment of fish during flooding for pond stocking, andeither harvest the ponds themselves, or lease out this activity to others. This is not to berecommended on the grounds of sustainability, since ponds used in this way will be cleared of fishcompletely once they start to dry out, and there will be no natural return of fish to the rivers asfloodwaters recede. Such usage will therefore contribute to the continued depletion of fish stocks.However, it has to be accepted that almost certainly some landowners will prefer this option.

The Third EU-financed Integrated Food Assisted Development Project (IFADEP3) includes a pilotproject (currently underway) for fish farming in borrow pits which are being developed in connectionwith improvements to 4 FRBs in Magurah and one in Rajshahi (Anon. 1996). Under this scheme, ithas been agreed with LGED that contractors will not be allowed to employ the usual practice ofextensive shallow borrowing, and that only a single, relatively large pit will be allowed on each road.Extraction of borrow will be carried out in such a way that the shape of the pit on completionconforms with the specification for a fish pond, at least to the depth of extraction. Final shaping ofthe pit, including any additional deepening, will be carried out by local groups, organised andsupported by NGOs, who will ultimately establish and run the fish pond. The pits are leased from thelandowner concerned for a period of at least 7 years from cessation of borrow extraction, withpayment taking the form of 10% of the production. When the lease period comes to an end, the pitwill be handed back to the owner as an operating fish production unit.

Although it is too early for conclusions to be drawn regarding long-term viability, there is no doubtthat the overall concept is sound from environmental, financial and social viewpoints. It is proposedthat this concept should form the basis for fish pond development within the FRA project.

The EMP for the Nalka-Bonpara component of RRMP3 (DHV 1996) also contained proposals forfish production in borrow pits which were broadly comparable with the IFADEP3 pattern, but it isunderstood that this proposal was rejected by RHD. However, recent discussions with the RHD FRAProject Director have resulted in agreement that the option of fish production in borrow pits shouldbe offered to landowners whose land is used for borrow extraction in connection with the FRAproject.

Landowners with an interest in managed fish ponds may decide to develop them themselves as agroup, since the area of each pit will most probably extend over land owned by a number of people.

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Alternatively, owners may prefer to lease pits for development by local groups organised by NGOs,but with themselves being members of a group. Part of the initial planning process to be carried outby the managing NGO, operating in conjunction with local NGOs, would be to find out from thelandowners concemed which option they prefer. Recommendations regarding the most appropriateformn-of pond development would also be made at this stage.

The proposals made by the contractors in relation to reinstatement of borrow pits, which have to beapproved by the Engineer before extraction can commence, would make provision for generalshaping of the pit to the proposed extraction depth, so that it conforms with the basic requirementsfor fish pond development. Further pond development would be carried out by the groups concerned.

Ponds should be no longer than 100m, with a maximurn width of 25m. If borrow pits exceed thiswidth, final shaping will need to include the construction of internal bunds.The precise shape ofindividual ponds will depend on local conditions. In most areas, it seems likely that silty sandmaterial will predominate, for which side slopes of 1:2 v:h would be appropriate. A Im wide bermneeds to be constructed on each side of the pit to facilitate fishing operations. Provision also needs tobe made for a small level area on which the person responsible for pond security can erect a house,since stealing of fish is a major problem in most areas. Formation of flood protection bunds (wherethese are necessary) would be carried out by the groups during the post-extraction phase, usingmaterial extracted from the bottom of the pit in connection with providing the optimum depth for fishproduction, since it seems likely that additional deepening will be required in many cases.

Formation of participant groups will be organised by local NGOs in much the same way as proposedfor the tree planting programme, and will take place towards the end of the borrow extractionactivities on each section of road, and all necessary plans and arrangements will be finalised. Groupnumbers need to be limited to between 6 and 10 per hectare of pond, so that each gains sufficientincome to maintain interest.

The decision on what form of production should be established at each site will depend partly ongroup preferences, but will also have to take into account matters such as local water quality,flooding heights etc, and proximity to markets. The options will be identified by the local NGO andput forward to the groups for their decision. The basic options are:

* operate the pond as a hatchery/fingerling production enterprise or as an adult fish production unit* what types of fish to produce: some species are slower growing than others; some such as carp

need fresh water and some, such as Tilapia and prawns will tolerate brackish water* operation as a seasonal pond with restocking very year, or as a perennial pond with continuous

production of species which will reproduce in the pond

In the case of groups comprising only landowners who have received lease fees from contractors, intheory there wouid be no need for access to credit facilities for pond stocking, fertiliser etc. However,it is likely that any fees paid would be spent well before pond establishment takes place, and accessto credit will be needed. In the case of groups comprising the poor and landless, credit access willdefinitely be needed, and will be arranged through the local NGO. Depending on the type ofproduction selected, credit of around Tk2O,000 will be needed to meet initial establishment costs.Similar amounts will probably need to be made available on a revolving annual basis to financeoperations over the first two or three years.

Both landowner and landowner/poor and landless groups will need training and technical support bythe local NGO in aspects such pond and water quality managernent, since successful pond fisherydevelopment requires a fairly high level of expertise. Training may also be needed in relation torunning a business, marketing and the use of credit. NGO members acting as trainers may themselves

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Feeder Roads Type A Project Environmental Management Plan

need training, which would be developed through cooperative arrangements with the Thana fisheriesofficers as well as through the managing NGO.

The managing and local NGOs will probably need technical support in planning and executing theprogramme. It is proposed 1hat this should:

* be financed by the Bank as part of the overall TA support programme* take the form of provision of the services of an Inland Fisheries Specialist with experience in

fisheries extension, to advise and assist the NGOs involved in the borrow pit programme onplanning, programming and technical aspects

The local NGOs would take a service fee from the groups they assist, as a percentage of group netincome (probably around 15%). If micro-credit access is provided by the supporting NGO rather thanthrough other organisations, it would also benefit from interest payments on the loan, which currentlystand at around 15% per annum.

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Feeder Roads Type A Project Enx ironmental Management Plan

SECTION 4

ORGANISATIONAL ASPECTS

4.1 Management Framework and Overview of Responsibilities

The FRA project is one of several components of the RRMP3 project. During implementation,environmental management functions will be carried out by several government and non-governmentbodies, which will be coordinated and linked through the overall project management framework.

The management structure for the FRA component is outlined in Figure 4.1. In the interests of clarityof presentation, this shows only the principal components which will be involved in environmentalmanagement, and excludes a large number of elements whose functions are not directly relevant, butwhich form part of the overall management structure.

The RRMP3 project will be managed and implemented by RHD and its various sections and zonaloffices under the Chief Engineer. High level management and coordination functions for individualcomponents of the overall RRMP3 project will be provided through a Project Implementation Office(PIO) in Dhaka, headed by the Project Civil Works Director (PCWD). The PCWD will be supportedby staff specifically assigned to the PIO, and will also be able to draw on the expertise of other unitswithin RHD headquarters as needed. A small Advisory Unit, which will include anEnvironmental/Resettlement Specialist is also to be established, to provide specialist advice andassistance to the PCWD. For the FRA component, the PCWD will be supported at zonal level byProject Directors (PDs) located in the Rajshahi, Rangpur, Khulna and Barisal zonal offices.

The PCWD in his role as the 'Engineer', as defined in the construction contracts, will have primaryresponsibility for management and coordination of all matters relating to construction supervisionand monitoring, including environmental management. He will be advised and assisted in hismanagement functions by a joint venture of foreign and local consultants (the constructionsupervision and monitoring consultants - CSMC), who will be responsible for day-to-day supervisionand monitoring.

The CSMC Team Leader will be designated as 'Engineer's Representative', and will be the primarylinkage between RHD and the consultants at project (Dhaka) level. His support staff will includeResident Engineers, based in the various contractors' site offices, who will be responsible forconstruction supervision and monitoring at site level. These latter will have a liaison/coordinationrole in the linkage between the consultants and RHD at zonal level. Environmental managementresponsibilities will be attached to all these positions.

The CSMC team will include a part-time expatriate Environmental Specialist, whose-responsibilitieswill include provision of advice and assistance to the consultants' Team Leader and his engineeringstaff on environmental matters, including those specifically involved in the implementation ofenvironmental management functions. The Environmental Specialist will also have a keyliaison/coordination role which will link the consultants and the PAP implementation NGO, and willalso link the consultants with the NGOs responsible for planning and managing the tree-planting andborrow pit restoration programmes.

In his more general role as overall manager and coordinator of the FRA project, the PCWD will alsohave other high level responsibilities and functions, which will cover aspects of environmentalmanagement as well as implementation of the RAP. Since the NGOs responsible for planning andmanagement of the tree planting and borrow pit restoration programmes will be appointed by, andwill report directly to RHD, the PCWD will also have primary responsibility for these aspects ofenvironmental management.

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Feeder Roads Type A Project Environimiental Management Plan

Chief EngneerRHO

Highway Engineering 1iProjec CtI WorksjEnvironmenViResettlement D ( lrector E - - - - -

Financial Management (The Englneer)

RHD Arboriculturel

Team Leader (ER)Constr.Supervision

& Monitoring

Consultants

Team Leader Chiet Resettlement roe tmni - - Team Leader TeeantnRAP Implementation I A Officer ofece Staff Borrow Pit Programme TPro Planmtei

NGO (FRA) i I . NGO P.Ga

Engin eerng Environmental |I ~~~~~~~~~~~~~~ ~~~~~~~~~~~~~Tea Engineer

[ ~ ~ ~ ~ ~~~~~~~~~CretDirectr (s)Resident Engineers BorowPit Programnme Tree PlantingFicid Teems Lend HO~~~~~~~~~Vi Zonat ie Sl~p~iin- - -- IProject Manaers Programme

RAP Implementa ion Landcqusilion hui Ran I I Staff ilocalN & Maoncag pNG

A A ~~~~~~~~~~~~~~~~~~~~~~~~~-A

Figure 4.1 Organisational Structure for Feeder Roads Type A Project

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Feeder Roads Ty pe A Project Environmental Mianagement Plan

4.2 Specific Environmental Management Activities and Responsibilities

4.2.1 Pre-construction Phase

Environmental management during the pre-construction phase is largely concerned with ensuringthat environmental matters have been adequately recognised and addressed in project plans, designsand contract documents.

Prior to contractor mobilisation and the commencement of construction, environmental managementcovers four principal groups of activities, some of which have already been completed, but aresubject to review. Matters relating to land acquisition and preparation and implementation of theRAP have been excluded, since they fall very largely outside the scope of mainstream environmentalmanagement activities, although they obviously are related. The end February 1998 status of pre-construction phase activities was as follows:

* Environmental review of all project roads (scoping), and detailed EIA as necessary for roadsincluded in the first phase of construction (250km). This activity was completed with submissionof the Environmental Review report by the Phase I study and design consultants (SDC) inFebruary 1998, which concluded that the nature and scope of the works to be carried out on allroad sections within the project would not give rise to unacceptable levels of environmentalimpact, provided that appropriate, specified mitigation measures are adopted and fully enforced. Itwas also concluded that detailed EIA was unnecessary for any of the project road sections. Theseconclusions are however subject to review as indicated below.

* Preparation of a detailed Environmental Management & Monitoring Plan (EMP). This activitywill be completed on submission of this report, which constitutes the project EMP, and has beenprepared by the SDC. The EMP is however subject to review as indicated below.

* Preparation of detailed designs which give due consideration to minimisation of adverse impactsand benefit enhancement. This activity will have been completed by SDC by the end of March1998 (subject to review), for approximately 250km of road sections which will be rehabilitated inthe first, and part of the second year's construction programmes. Designs for the remaining250km will be prepared by the CSMC.

* Preparation of tender and construction contract documentation which contains appropriate clausesto allow control of impacts arising from construction activities. The current status is as indicatedabove for detailed designs.

* Review of Phase I environmental reports, designs and contract documents, to confirm thatappropriate conclusions have been drawn from the environmental studies which have been carriedout, and that suitable measures have been incorporated in the EMP, designs and documentation toreduce adverse environmental impacts to an acceptable level. This activity will be carried out bythe CSMC, as one of the priority tasks following mobilisation.

Primary executive responsibility for ensuring that environmental matters relating to the overallproject have been adequately recognised and addressed and, in particular, that suitable measures forimpact control have been incorporated in the designs and contract documents for the Phase I roadsections, lies with the SDC Team Leader, although day-to-day responsibility for these aspects lieswith the members of his environmental and design/contract documentation teams. The Team Leaderof the CSMC and his team members will have similar responsibilities in relation to designs andcontract documents prepared for the Phase 2 sections.

Although review of environmental documentation and the environmental components of Phase Idesigns and contract documents, by the CSMC, is an environmental monitoring exercise, this is useof monitoring as a management tool, and the review process is therefore an integral part of theenvironmental management process. Primary responsibility for this aspect will lie with the TeamLeader of the CSMC, although the process will largely be carried out by the EnvironmentalSpecialist, working in conjunction with the engineering team members.

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4.2.2 Construction Phase

Most of the project environmental management activities will be carried out during the constructionphase, since this is the phase when most impacts could be expected to arise. Management will verylargely be concerned with controlling impacts arising through the actions of contractors, throughenforcement of the construction contract clauses related to protection of the environment as a wholeand the components within it. In this respect, it is important to recognise that successful mitigation ofconstruction impacts can only be achieved if the environmental protection measures, as set out in theconstruction contracts, are properly enforced.

Overall primary responsibility for construction supervision and contract management, and thereforefor environmental management during construction, will lie with the Engineer as defined in theconstruction contracts ie. the PCWD. However, certain powers relating to day-to-day supervision willbe delegated by the PCWD to the Engineer's Representative (ER) ie. the Team Leader of the CSMC.The ER will have responsibility for ensuring that all site environmental management and monitoringaspects are dealt with promptly and properly by his staff, including the Resident Engineers and othersite staff. The site supervision staff will be responsible for environmental management andmonitoring at the lowest organisational level, but their role in the management chain is crucial ifeffective impact control is to be achieved.

The CSMC Environmental Specialist will be responsible for identifying the necessary procedures foreffective environmental management and monitoring, and will make recommendations to the ER fortheir incorporation in the overall construction supervision and monitoring framework. This will covermatters such as the development of checklists of key points which should be monitored on a routinebasis during construction and reporting mechanisms for ensuring that appropriate action is taken,should monitoring reveal that this is necessary.

Particular attention will be paid to establishing procedures whereby emergency action can be takenby site staff in the event of the contractor acting in a manner which will cause immediate andsignificant environmental damage, for example through the felling of trees which are protected underthe contract, interference with utility services, or contamination of groundwater or surface waterthrough inappropriate handling of contaminating substances.

The Environmental Engineer will also be responsible for providing basic training in the managementand monitoring of environmental aspects to REs and site staff, to be carried out prior to thecommencement of construction, and on a refresher basis during construction as required.

The initial training course will include matters such as:

* an introduction to the concepts of environmental management and monitoring, the aims andobjectives, and the relationship with other construction supervision and monitoring activities

* a review of impacts which will be managed during construction, and the mechanisms which willbe adopted in impact control, with particular reference to key impacts

* the role of monitoring as an environmental management tool and the procedures which will beadopted, including the way in which site checklists are to be used in routine monitoring

* procedures to be adopted in the event of emergency action needing to be taken to preventenvironmental damage occurring, or to minimise the effects if damage has already occurred

The content of refresher 'courses will be determined largely on the basis of the periodic reviewfindings of the Environmental Engineer, as referred to below. In general terms, these would focus

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clearly on specific aspects of site level management and monitoring which have been found to beunsatisfactory, for whatever reason.

During his periodic visits to the sites, the Environmental Engineer will carry out an evaluation of theeffectiveness of. environmental management and monitoring, and will make recommendations to theER for modifications to procedures, the need for adoption of additional control measures, and on anynecessary actions to be taken regarding remedial measures etc, on the basis of his review findings.

The Environmental Engineer will also have a role to play in relation to liaison with the NGOsresponsible for RAP implementation and the tree planting and borrow pit restoration programmes.However, in view of the fact that his overall input will be relatively short (approximately 6 months intotal), and his periodic visits during construction will necessarily have to be short and infrequent(probably twice a year for about 3 weeks), responsibilities in this respect will have to be shared withthe ER at Dhaka level, and the REs at site level. Consequently his liaison function will be moreconcerned with the broad integration of NGO programmes with other project implementation aspects,than with day-to-day site-specific matters.

4.2.3 Operational Phase

The only key adverse potential impact which is anticipated during the operational phase is theimpedance to boats arising from bridge soffit levels having been set too low. This is a design matter,and environmental management in this respect has already been covered in section 4.2.1.

Continued enjoyment of the benefits arising from implementation of the FRA improvement projectwill only be achieved if effective routine and periodic pavement and embankment maintenance iscarried out in a timely manner. Environmental management and monitoring in this respect will be theresponsibility of RHD maintenance units, with implementation being carried out through the zonaland district offices.

Maintenance of the roadside trees which will be planted under the project will be the responsibility oflocal groups organised by the RHD Arboricultural Unit, through the zonal offices. In general, it is notexpected that much maintenance will be required once the trees are established, apart from thinningat 6 years, and routine pruning at intervals as necessary.

Environmental management relating to fish ponds and other measures related to borrow pitreinstatement will be a matter for the private individuals and groups concerned. In the case of fishponds operated by groups, long term support over the lease period will be provided through the localNGOs concerned with initial establishment. In the case of reinstatement measures for agriculture, itis expected that no long-term management measures will be needed.

4.2.4 Summary of Management Measures and Responsibilities

Table 4.2.4 summarises the potential impacts which are to be controlled, the mitigation measureswhich are to be adopted, the environmental management actions which are to be implemented, andindicates which organisations and individuals within those organisations will be responsible forensuring that the management actions are efficiently implemented.

Where mitigation of impacts involves the incorporation of suitable clauses in the constructioncontracts (and subsequent enforcement during construction), the provisions to be made in this respecthave been outlined in Table 4.2.4 in the interests of simplicity and brevity of presentation. Fulldetails are provided in the relevant parts of Section 5 of the SEIA (Mouchel 1998).

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Table 4.2.2 Summary of Environmental Management Measures

Potential Impctti Benefit enihancementlmitigationl measures Management actions Executive responnsiblitiesPre-construct)on phSaaeLocal poplatin sufers uncerlaete oces ProWsitin of hit and thea/ knafntmttcn regarding She protect& Sits ipicatlons Esttobishemeal t ofacedurrs and organlsatonat arrangemntns f arn effective intamatiun HGO responsible tar RAP preparu/srnAmplemantatlon. RHDO/ank to ctreckland & ether tas acqulst adlsing tron wrvy in tlrrat of land & peprly eqthsn disanrinatloe progranan to affected uDmnmhnties. to b inluded in the RAP. thal su able pronvilon has been madleRlearn acvtntes, Ved subequantp by

petalrlpeelto.wrigIcommen oem end n aealtnsprocedut tmtpterntafron ciuse praramme to be undertaken Immediately prior to commencement ortihe land NGO esponsible tor RAP Prepsaoimplerenion working Inapldslboi proces, and subseqLtensty as naeessary, oaweing all affected communilies coordination whh the land acquisition teams and local autlrit/es In theareas concemed. CRO wlthin PiO, responsible tor FRA project landbacoqusiion manetm, to ensure effective lnformaJoen dissenination to atits Sdan .5.1 f SPAt wtha require s.Ftntatn hedrdphip asodated waits iradeqtte Miiniluto of land c quishion Protectdesignsto rnimaiahe need far land acuisleon tothe meaimteasihe ectent ooCiCrMCor.pnston to land, pboperp S ose af

blU resa, enpomPkt etcPaymeet d KlA and fair corspenaton to Et affcted parbast Identifcaion of land a property aqusitron etc requirements SDC /CSMC to prepare mouza plans showing land which wilt be ffected

RAP owsnpensaton mabtx to make prosison far cormpenoation or other assislance to Ihose directtv or NGO responsible far RAP preparationarmplementation. RHD/Bank to; indirectty effected by land acqoulilion ensure that adequate provisons have been made to saleguard PAPsAuatrarles to ensure proper assessment and theely payment of oompensation, pror to CRO wmthen PIOiDC/Min. o Land. The Bank to ensure that a tuitablecommencement of any constbcton acivties one secon ot road affecked by tand aucqiition coenant i inator/ed in the credit agreenti conceinring cnomnancemedi ot

constroction pri ori completion of compensation payments at any sectionof road.

Ful imptementation of the provisions made In the RAP for overseeing and monitorng RAP execudon NGO responsible tor RAP preparation/Amplementetlon. CRO withab PIO toand the pronn d asoislonrso to PAPe who need I be responsible for ovenertngt satisactory execedlon ot the RAP____ ____ ____ ____ ____ ____ ____ tee Sacas 5.4.1 od SPlAtDelays to proect liplementron end tho benefit Preparaion Of a crompleat record Of exssting buidings immediately pr to Preparation of a dated video recording, taken hm a moving vehicle, which shows both mad margins CSMClag assoctated with it udukent cmtpeatete on eormcenemnt o the land taluhlfion process and SO nearby stuctruesctairn

Advice to local comrunities ot the existence o the n/dOa. thai any construcioDn slarted after the date NGO responsible ton RAP preparatlnnimpiementaoon In coordinalion withof tie recording may not be oovered by the conrpensaton process, and that fraudulent wmpensatlion the land actuisition teams and local authorities(see Sectlrm 5.5.2 of SELA) dalams will be appropriate/ aa with by the autorilisConstnuction phaseGenae adverse Impacts edtconstuction ete Conautr to behavehr n environmentatly responsible manner Descripton a the works in Indicate that the Bank and RHD view environmental masers to be ot SDC/CSMC

onsiderable Importance and that the contract will be administered accordingoy

Brieftng o appointed contractors on mblxsation. regarding sensitive environmental matter and The Engineerrelanrcement of advice reganding contract adainistratlon: contracts to be administered according/a

Increased eaplboymnt opportunetes far the lo %cal ituction conteds n require mrximum uoe at tal labour, contractors in orctusir ot appropriale dauses In constdction oniracts. SDCpoputaton lk potine steps in recuN wmnen, the desitute and landles. wth adininmm d 30% ot tht woorktrce i be tamale and at teest 25% od wosis Ito Montoring of compliance during constracfon and appropriate administration a the contracs The Engneer/ER/ftRE S aia staffbe csared out by labour

trtee SectIon 5t3.1 a SdElAt'Lons of inedelda t eeocled st reining and Mialeisatln f the qeed ta fetling of exiisng trees Appropriate designs to be prepared which rinimise ihe need tor tree tiling. Options tar reducing tree SDC/CSMCwidentng d arrbentxtnkrla t.Inas tu ba Investigaled, during design. Alignment in be advusted to avoid felling t large or signiticant

tetes wherever ahis is easible

Cont'ruction coentractl tn make provbsian tor penalty tr the conrrracors tncluslon ot appropriate clause In conhtruction contracts Monitoring of compliance durng constrcon SDC/CSMC. Moriting and entorcement by the EngineedEr/ REs sireurrncessarty fetling er damaging tna. and approprate administration ot contracts stafAN large trees. or those oa religious or cultural signifeance lying on the embankments or within ICm om CSMCthe to, whtich are not to be tailed or damaged l be identiffed en sile plans. Trees not to be tailed ordamaged l be cleartY marked.

tmnpternbtlon d replard Smee plabntg programme Detailed reptenting programme in be prepared and Implemented ouside the cdil works coniracts, RHD Arboricullural Uni in coordination with the appointed NGO, who willunder the management of an expenenced NGO appointed by RHD. with appropriate technical Identity and organise loi groups for Implementation(tee Secdan 3.2 d this EMtPt assistanceLons o prductIe land tar bomw ptb and Minrlsatia ofd bm reuiremenf Options tor borrow miniriSatiom obeinoesgted duringdellaeddesign. SDC/CSMCadeerse tart affect Slaod withepltation d tahnt landownerts by contracors Equitable tgntemesb tr bartow pi developmtent l be reacled by contscrs Exprienced NGO, acceptable to the Bank and RHD, to be appointed to advise and assist landowners RHD IPCVWD )to appoint NGOand lahoers. Lease aograrsentosto tPocptr what post-use aboran tn relation barrow grereeents and post-us. tncom erestoration opoons.weorhs arm ID be carried or1A by fth cortaclors

Conb 5 to biubmRit pattt for borrow expiotaton and siae mestrtion for Incusion of appropriate rlause In consructioncoated; monKoring a complince durng consnidion SDC/CSMC.eppraval beore commrindring any woreKs and to imptarnest suaIh pproved nd appropriate edrninstrhion of oDntractsplans.

Coahucdore to be atdwtad Stat plane Involving the usatu pactise of tenstrle Decriptorm aSthe works taincude n appropriate statement SDCICSMC. M otng and entforement by the Engineer/ERREs a sitesteaws dida boorwing Adtwnt t approved unless there are excepbtin staffdrcurstncee.

terplemapttllon of support prongtmes to affectd landorers In Income Drtaled progranmies iOVneng post-use resbrrdotn tor *grtculture/ Improvement ct pnoductivity on NHO appolnled by NGO in connection wh pre-extraction dvice torestoatem tasinghorn rdtducio In pruducrave apacity bte lmwl unaftteced pats ot hodirss ortsh pond devexprnt lobe prepared and implemenled ater extradtion landowners to prepare detailed pians and to mayage execution throughhas ceased. local NGOs (with addliotnal technical assistance In planning endErt-on dnkmenb tattZt b detitrea Secdbn3.3 SdthiEMP) i_ l Implementation)

d the a mnl almuarsnd pavemen tlopes, and watering d laid ItuO as necessary untN ground cover tauly aWropriate admInstratiOn ot contcts staffattae sttY Ated xine of erath read established.

'Wve eroson proteceun meseumte to be crnsbtedd at tnsentta tiles uting Senltive sati to be Identiied; oPtiOns tor pwrteello, nessores to be lnvestgated, and suatable SDC/CSMCnatural ietat where possRdbe. meeTISUs l be icorporated in proiect design, spcttcatniaas etc

("ate Section 544 o4 SEIA)

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Table 4.2.2 Summary of Environmental Management Measures

Potential Impacts Benefit enhancement/mitigation measures Management actions Executive responsibilitiesDagsoe to rimos running iogonglsde or wro Retocatl on any potenfaty ffected ser prior to omarrnenement of any Potenbally affected aervnes to be idenbied at eariiest opportunity. SOC/CSMC.gtr rod during consbtucon. Weeadg to rnsburcon wersa.inteeubOf11UptI, Servie providers to be rrotied ot need ror nreorabon and equired prolimorming to avoid consructlon RHO (PCvvD)

delays

.Implementotion of reloabon woreK to be comptlted by service providers before ny of main Service providercorrnstucto works pmceed, t acordance vAth previously agreed pogramme

Contrctrs to be responsible fbr Identfying and sateguarding serc Indtusion of appropriate cause In consbton oDntracs; monitoring ot compliance during constctlon SDC/CSMC. Monitoring ad enforcement by the Engineer/EiUREs 6 siteadjacent to the works, end tor comrpenisatng Service providers for any and epproprate adminisration of onbacts stafecidentat damage to suc h services.

__see SectIon 5.5 3 of SEIA_Crtres woitd ptesence bromiag Cotactors to provide mmt sitb equipped and Mtaed site mergiency ntdusion of appropiate cmonitoringofcompliance ring nshuction SDC/CSMC Monitoring and enforcement by the Engineer/RiRs & siepr_sm orn attldy trabred tkocl medicat mtedical tOibeM and apprpnsate adornistatoiro of nbwtc staff

(See Secibon 5.5.4 of SEIA)tnroplete bpost-use Cesreio and retstemstnt Contractor to prepare sile restoration plans for apprval, and to Impiemnt Indusion of appropnate clauses o consn kction contracts; montorng of complance during SOCDCSMC. Monitoring and enforcement by the Eng1neerwitRREs & nsleof ba caM ad other temporary work site. Sach plans flly por to derobti1sation AN tenporary works sies to be onsbtructionandappmpriatesdministratonofconracts stafftat tosa of tend productivity or additional nrobed by the conbtctor, prior to usecoos or b w to reabe land A sites to be photographed to provide a record or pre-use stale CSMC

l0012 to Irrdude onminated lump sume for reinstatement of emporary Siles. SDC/CSMC________ _______ ________ ______ itee Section 5.5.5 of SEtA)__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _PdiS Aof d tend gronde r Wnd surfce wrter Conrcs to prepare for approvol detailed sie envirsmental plans for the Indunion o approprate clauses o cnstruction contras; monitoring of ompliance durng SDCCSMC. Monitodng and enorcement by the EngineerdERPRES & siteritn ibow saIry and other w e and base caps arnd other Work es.t. whcr reake adequate prvison for Use constuctiaonedappropdSteadministatonofcontracts stffSpisages disposal of dA wastes, and prevention of spillagn, leakage of pollngmawteras 54c.

Contreci to be reqtulrd b pa y costs essocatad ltlh dcea,ning uP sny an sbove SDC/CSMC. Monitoong and enrorcement by the Engineer/ERlRES & sitepoAution aused by ther sctvties and to pay biA cOmpensation to those staffaffected.______ ______ ______ ______ ______ (55 Section 5.6.6 of SEIA)

Contractor s watr abstracion reult t Contracbr to moke suitable arrangenents for oes Supply and, to provide asn Indusonin o apprmpnate caules in oDnstruction contracts; monitoring of compliance durng SDCUCSMC. Monitoring and enorcement by the EngineerrRES & siteoMrpeton ibr grcarce water rnesutce with tKcal dtemRav wpply to any users affeced. by ontacto abstraction. construcion and appnopdiae administration of contracts staffusrs laee Section .5.57 oi SEiA)Consruction barsic susing pavemnt and Contractorsnd *unboontao, to use appropriate vehicles. and to comply Inclusion ot appropriate cdauses in constrution contracts; monioring o0 compirance dunng SDC/CSMC Monitor,ng and enforcement by the EngineerEiR/RfEs & s,testoictua daa dee to oveirteding. kresse t wih legal g vehide and side toad imi. onstouction and appropriate adminisntratin ot contracts stuffconr_gae . rnd tnrused roed sefrty heonts

Contractnrs to repair damege at owm expense as above S aboveContwators to minimise med sshb bazards and toconvenience to oter mad as above as aboveases by takingrt all appropriate measures.(se Section .5.8 of SEIA)

rddgeirtnortotefe,tog wih nragation Contrctors to programme end eeckute alt in-waterway operations on rcdusion oA approprnate dauses in construction contracts; monitong compliance during SDCICSMC. Monitonng and enforcement by the Engiireer/iREsR & ste"able waterways so as not to Impede navigation. construdion and appropdate administration of contracts staffl(se Section 5.50 of SELA)Road sy hasrds asociated wih temporary Contrators to faks all reasonable measures to minimise Interference with Indusion of appmprate claues Is construction contacts; monitoring of compliance dudng SDC/CSMC Monloring and enforcemel by the EngineerEfiREs sntetraffc d i5s trefflo iow and to provide sate transit of dilersrons cansurtn end appropdare administration of contracts stia

( saee Sedlon 5.510 of SEiA) _ _ _ __CSMCCreaton d fuel*ood hortage for the loal MintiSeon O the need for new bdrick tor use In Wsemnent mterials The spedfications to make provion fr use of HB and other pavement materials i the lower SDUCSMCpo noIs"l 5eugh Sie Vse hI ktlt sw o pavement foyers to the manmurn eert n possie.cks tC emIbdot. aNd ctacto ue Oftoetesod br woo4n at at bane camps, and AS bdrJc dIAeed to st to be fmo duly Ocenred ldins acoompanied by a Indusion of appropriate dauses to constmscson contracts; monining of compliance durng SDC/CSMC. Monitoring and enforcement by the EngineeriERfREs 6 iteidrldaindiatott tc r ft resoure. eslid certificate showAng Stt OS Wit crnced baa nso used iemood in their construction and approPriat administratio contracts staff

Po on. ~~~~~~~~~~as above an aboveContractors to une coal, kbroness. gas or other son-fuseiwood material brhasting blhumen and for domentic ptrposs at base oamps

( ee Secion 5.511 o SEIA)Alr po mtii fre hCt-55 plaete Opwbon end maintenance to be to 00cordance with manuctunWrs Inclusion of appropnat auses t constucton contacts; monitoding of copliance dunng SDC/CSMC. Monitng and enforcement by the Engneenr/EPREs C sitepdslstio oDnstrsucon and appropnile administration of conacts staff

Sitto drm5wndnd wo botsm vlg5s as above as abovsp_e,t Ssecton 5,512 of SEIA)Operatdon iphs

"trr to bosle on nraigable wd rwL at Oss15rw to nb von tbr adesate tbrt and veaicA ideamrne Clernces to he -coding to the appropdate standards fbr the class of alerwey conemed. as SDC/CSMCewhttuirt sbuckee advised by the responsidble uthoties. Nto replacment bidges to have lower sofft levels than theeoistIn level.totprsertet to trade oppalt s focal tImproved reds tobe propery tlntated Adequate budgetand other resorn tobealloated b routne and periodic maintuane, which h1 RHD zonal maintennce unitsatt lrsodc and assoeated ter5ft. dag be carnied out to an agreed prngrasnae. Routine minor embonknw maintenance t he anted olbythm m tod t nfr tnFt (noe Sacion 5.3.3 d SEA) local groups of ftt poor and deslitle.

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Feeder Roads Type A Project Environmental lmanagemenm Plan

4.3 Institutional Strengthening

The Environment and Resettlement Unit of RHD, located at headiquarters in Dhaka, which at presentcomes under the Chief Engineer, Planning and Development, is currently staffed by oneSuperintending Engineer, assisted by one clerk. It is understood t:hat this unit does not currently haveany significant involvement in environmental matters, mainly as a result of inadequate staffinglevels, but also as a result of lack of environmental expertise. It presently functions as anadministrative unit, rather than as a technical unit, and is largelv concerned with matters relating toland compensation.

Under the Interim reorganisation arrangements, implemnentation of which will be a condition ofnegotiations with the Bank, a Technical Services Wing will be created within which will be a Roadsand Environment Division comprising three units: Road Design., Road Safety and Environment andResettlement. However, the organisational changes will n,ot result in any increase in staffing levels orenvironmental expertise compared with the present situation. Although longer-term macro-reorganisation of RHD is to be implemented, which may result in improved staffing and functionalitywith respect to environmental matters, this will probably not be accomplished in time for significantinvolvement of the unit in FRA project. In any case, it would seem that the proposed environmentalfunctions of the unit would be focused on EIA and environmental studies, rather than on the broaderaspects of environmental management (Report - of the RHD/IDC Sub-Committee on InterimReorganisation, August 1997).

Taking the above into account, it is considered inappropriate that additional strengthening of theEnvironmental and Resettlement Unit should be recommended for implementation under this EMP.Furthermore, the nature and extent of impacts associated with implementation of the FRA project,and the environmental management requirements, are such that they can be dealt with adequatelythrough the organisational arrangements set out in Sections 4.2.1 and 4.2.2, with additional technicalsupport relating to the tree planting and borrow pit programmes as set out in Section 3.

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Feeder Roads Type A Project Environmental Management Plan

SECTION 5

IMPLEMENTATION SCHEDULE

5.1 Project Implementation Schedule

The preliminary project implementation schedule (Figure 5.1) is based on the information which wasavailable in early March 1998.

On the basis of the schedule, contractor mobilisation on the first year's packages will commence on IDecember 1998, with construction commencing about I month later. This implies that landacquisition, for at least some of the roads within the first year's packages, will have been completedby 1 January 1999 at the latest. It seems unlikely that this will be possible, since land acquisition inBangladesh is a lengthy process, and for most road projects takes a minimum of 10-13 months.

Contract periods for individual roads within the first year's packages will vary from 15 to 24 months,with most being 18 months. It is anticipated that contract periods for roads within succeeding year'spackages will be for similar periods. Consequently, there will be a considerable degree of overlapbetween packages for different years, with a number of contracts from two or more year's packagesbeing implemented concurrently over most of the construction period of 3 years.

5.2 Environmental Management Implementation Schedule

Table 5.2 sets out the latest dates by which specified actions needed to implement the EMP must betaken. These are based on and coordinated with the project implementation schedule which, asindicated in Section 5.1, is preliminary. All dates shown in Table 5.2 are therefore provisional, andwill require review once a the project schedule has been finalised.

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Feeder Roads Type A Project Environmcntal Management I'lan

Table 5.1 Preliminary Project Implementation Schedule

1998 1999 2000 2001J F M A M J J A S OINID J F M A M J J A SIOINID J MAMJJ ASON J F|M|AIM| JI J A|SO ND1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 18 17 18 19 20 21 22 23 24 25 28 27 28 29 30 1CV 32 3'3131 .58 37 38 39 40 41 42 43 44 45 48 47 49

Completion of Phase 1 designs and contract documents

Appointment or constructon supervisiontmonitoring consultants

Review of Phase 1 designs and contract documents

Prequallftcaton of contractors for 1st year works packages

Preparettonlapprovat of tender shorttists for tat year works packages

Tender period for Iet year works packages

Tender evatuation/approvatslaward ot contracts for Ist year works packages

Construction of 1 st year works packages

Preparsaton of designs and contract documents for remaining works

Prequalificationl tendering/award of contracts for 2nd year packages

Construcion of 2nd year packages

Prequaificationl tenderinglaward of contracts fpr 3rd year packages

Construcion of 3rd year packages _ _ 1- _

SCHEDULExbs Pagc 35 A

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!- L, j . _ , , _

Feeder Roads Type A Project

Environmental Management Plan

Table 5.2 EMP Action Schedule

Action Responsible body Target date CommentsPre-construction

Finalisation and approval of RAP Appointed NGO to finalise; RHD/Bank to approve mkd-March 1998 Must be complete before credit negotiations commenceImplementation of RAP Appointed NGO In cortaboration with RHD/OCs and 1 April 1998 All necessary surveys to be completed on each section before land acquisition processlocal authorities

starts;implementation of assistance on each section to start when the land acquiSition______________________________________________________________________

__________________________ procprocessmommenceChecking of SEIA, Environmental Review and EMP documents CSMC Env. Eng mid-June 1998 Must be completed In time for any necessary additional impact control measures to be_______________________________________________________________________________

IncorporatednoDrpor t In In ede nsg anda tendererdocumentsChecking of environmental aspects of designs and tender documents to ensure inclusion of alt CSMC Env. Eng/Englneering Team mid-July 1998 Must be completed before tender documents are issued for each contractapproptate protection measuresPreparation of environmental checklists and planning of site inspection and reporting procedures CSMC Env. Eng/Team Leader early November 1998 Must be completed before site staff inttial training commencesInitial training of sde staff in the use of environmental checklists, inspection and reporting CSMC Env. Eng mid-November 1998 Must be carried out before contractor mobilisatlon commencesprocedumes

I__

_ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _Decision on trnanscing arrangements for NGO to advise and assist with borrow pit programme, and BanklRHD/PCDW mid-March 1998 Decision needs tobe made befmre credit negotiations with the Bank are concludedfor technical assistance In planning and programming for tree planting and borrow pit programmesPrequaliticalion of NGOs in connection with the borrow pit reinstatement programme RHD/PCDW to execute; Bank to approve shortlist end March 1998 1month for preparation/issue of prequalification documents; 1 month for NGQs to prepareprequalifications; 1 month for preparation/approval of shoritlistPreparation of TOR for NGO involvement in borrow pit programme CSMC/RHD/PCDW; Bank to approve TOR I July 1998 TOR draft must be completed at least 2 weeks before RFPs are issued to allow lime for

any necessary revision before final Bu.nk approvalIssue of RFPs to shortlisted NGOs and evaluation of proposals RHD/PCDW to Issue RFPs and evaluate Proposals 1 AuguA least month neessary for proposa p i bspriovBank to approve selected NGO _ for RHD to evatuate proposals . 0.5 months for Bank approvalAppointmenteofNGOto advise and assist with borrow pit programme RHD/PCDW. following Bank approval of selected mid-Odober 1998 Appointment must be made at least 1.5 months before the first contractor mobilines. toNGO

allow time for NGO mobilisalion and consideration of reinstatemernt options and_____ ____ ____ _____ ____ ____ ____ strategiesRecruiment & mobilisation of expatriate Fisheries and Agric. Extension Specialists to assist Bank 1 November 1998 Specialists and managing NGO must start planning and other preparatlon work at least 1appointed NGO

_ _ month prior to contractor mobitisationCommencement of first phase of borrow pit advice and assistance programmo Appointed NGO 1 December 1998 Teams must be on site at time of contractor mobilisationConstrucUon phaseCommencement of site monitoring

CSMC/EJRCREssite staff; periodic review visits by 1 December 1998 Inspections to commence during contractor base camp establishmentEnvCEnnRefresher training of site staff in environmental inspection procedures CSMC Env. Eng As and when needed through Timing to be determined on the basis of CSMC Env. Eng. periodic review findingsSite dearance inspection and certification CSMC/ERIREs (+ Env. Eng when avatable during end February 200 for ist contract to be To be carried out on each site following completion of construction worksperiodic visits) compltedPrequalification of NGOs in connection with the tree planting programme RHD/PCWD/Arboricultural Unit mid-June 1998 1month for preparationfissue of prequalification documents; I month for NGOs to prepare_____________________________________________________________________________________

prequatificetionsequalifica io month m forh preparation/approvalvaloffshh rtllssPreparatino of TOR for NGO involvement in tree planting programme RHD/PCWDlArboricultural Uni- i olaboratioOwith mi-October1998 TOR draft must be completed at least 2 weeks before RFPs are Issued to allow ime for

.____________________________________________________________________________ CSMC Cnv Env.

anE necessarv revision before final Bank approvalIssueofRFPstoshortiistedNGOOnpreparation of proposalsievaluation and approval RHDIPCDWto issue RFPs and evaluate proposals; 1 November1998 At least 1 month necessary for proposal preparation by shortlisted NGOs, and I monthBank to approve selected NGO for RHD to evaluate proposals/Bank approvalAppointment of NGO to advise and assist in tree planting programme programme RHD/PCDW, following Bank approval of selected 1 January 1999 At least 1 month to be allowed for NGO mobilisation before planting programme is toNGO

______________commnenceCommencement oftree planting programme planning and execution Appointed NGO 1 Febiary 1999 vNGO must mobilise and commence planning activities at least 13 months before actual_______________________________________________________________________________

planting Is scheduledng to chedul com mencemonnc thenftretr oft thet completeded roadd secttoo aRecruitsent & mobilisation of expatriate Social Forestry Specialist to assist appointed NGO 8ank to recruit and arrange mobilisation, 1 Febmay 1999 Recruitment and arrangements for mobilisation to be coordinated with the abovecoordinated with aboveEstablishment of first iursery --- cAppointed NGO 1 March 1999 Must be established at least 12 months before planting commences on the first of the

______________________________________________________________________

completed road c m pleted aro d ectctionRecruitment of Environmental Specialist for Independent Review Bank mid-November 1999 Should be completed in time for review to be carried out approximalefy 12 months aftercommencemrent of the first contract

Implementation of Independent Environmental Review Appointed specalist I December 1999 Should be completed in time for resuis to be taken Into account when reviewingmonitoring and management approach for 2nd years works packages before_________________________________ ______________ __ construction on these stan1s

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Feeder Roads Type A Project Environmental Management Plan

SECTION 6

ENVIRONMENTAL MONITORING AND REPORTING

6.1 General Considerations

Environmental monitoring is an essential tool in relation to environmental management as it providesthe basis for rational management decisions regarding impact control. The monitoring programme forFRA project will be undertaken to meet the following objectives:

* to check on whether mitigation and benefit enhancement measures have actually been adopted,and are proving effective in practice

* to provide a means whereby any impacts which were subject to uncertainty at the time ofpreparation of the EIA, or which were unforeseen, can be identified, and to provide a basis forformulating appropriate additional impact control measures

* to provide information on the actual nature and extent of key impacts and the effectiveness ofmitigation and benefit enhancement measures which, through a feedback mechanism, can improvethe planning and execution of future, similar projects

There are two basic forms of monitoring:

* Compliance monitoring, which checks whether prescribed actions have been carried out, usuallyby means of inspection or enquiries

i Effects monitoring, which records the consequences of activities on one or more environmentalcomponents, and usually involves physical measurement of selected parameters or the executionof surveys, to establish the nature and extent of induced changes

Compliance monitoring is usually given more emphasis in the case of road projects than is effectsmonitoring. This is because most impact controls take the form of measures incorporated in projectdesigns and contract documents, and the extent to which these are complied with, plays a major partin determining the overall environmental performance of the project.

6.2 Pre-construction Monitoring

Monitoring during the pre-construction phase of the project will be concerned with three aspects:

* checking that the project designs and specifications incorporate appropriate measures to minimisenegative impacts and to enhance beneficial impacts

* checking that the appropriate environmental protection clauses have been included in the contractdocuments to allow control of actions by the contractors which are potentially damaging to theenvironment

* checking that the land and property acquisition process, including payment of compensation, isbeing carried out in accordance with official procedures and the RAP

The first two activities will be carried out as part of the preparation of designs and contractdocuments for the two phases of the project. For Phase I sections, initial checking will be theresponsibility of the Phase I SDC Team Leader, assisted by his Environmental Team. A furthercheck will be carried out by the CSMC for Phase 1&2 implementation, whose TOR include checkingPhase I designs and contract documentation. The CSMC Team Leader and his EnvironmentalEngineer will be responsible for checking the environmental elements of both the Phase I and Phase2 designs and documentation.

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Feeder Roads Type A Project Enxironmental Management Plan

In the case of Phase I sections, the CSMC will prepare a design and contract documentation reviewreport (which will probably form part of the inception report) which draws attention to anydeficiencies, and indicates what remedial action is being taken.

Monitoring of matters relating to land and property acquisition will be carried out by theNGO/Consultant team appointed by RHD in connection with preparation and supervision ofimplementation of the RAP, and is not considered further here. Details of this aspect of monitoringand associated reporting will be included in the overall project RAP.

6.3 Construction Monitoring

Environmental monitoring during the construction phase will comprise four groups of activities:

* review of the contractors' Site Environmental Plans, method statements and temporary worksdesigns to ensure that environmental protection measures specified in the contract documentshave been given due consideration and, when implemented, will provide an acceptable level ofimpact control

• systematic observation on a day-to-day basis of all site activities and the contractors' offsitefacilities such as base camps and borrow areas, as a check that the contract requirements relatingto environmental matters are in fact being complied with, and that no unforeseen impacts areoccurring

* certification of site clearance, on completion of the works- monitoring related to the implementation of the tree-planting and borrow pit restoration

programmes

The first three activities will be fully integrated with other construction supervision and monitoringactivities carried out by CSMC. Primary responsibility.for ensuring that an adequate level ofmonitoring is carried out in relation to these will lie with the Engineer and the Engineer'sRepresentative, as part of their duties connected with cOntrolling site activities. Actual monitoringwill be carried out by site staff from CSMC, under the direction of the Resident Engineersresponsible for each site. Technical support in terms of environmental expertise will be providedCSMC Environmental Engineer during his periodic visits to the sites.

The majority of monitoring will comprise visual observations, carried out at the same time as theengineering monitoring activities. Site inspections will take place at varying times on different daysof the week. Initially, all parts of the sites (and offsite facilities'such as base camps and borrow pits)will need to be visited on a twice-weekly basis, with the emp]hasis on early identification of anyenvironmental problems and the initiation of suitable remedial aLction. Where reniedial actions havebeen required on the part of the contractors, further checks will need to be made to ensure that theseare actually being implemented to the agreed schedule and in the required form. As experience of theprincipal problem areas is gained, attention will be concentrated on locations and activities which areknown to be the most troublesome, with a lower frequency of inspections at problem-free locations.Nevertheless, each part of the site needs to be formally inspected at least once every two weeks.

In addition to visual observation, it is particularly important that monitoring should also includelimited questioning of people who live on and adjacent to the project roads, since they may be awareof matters which should be given consideration, but which may riot be readily apparent or recognisedduring intermittent inspection visits.

Environmental inspection checklists for site use will be developed by the CSMC EnvironmentalEngineer in collaboration with the ER and REs, prior to the commencement of construction, so as to

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Feeder Roads Type A Project Environmental Management Plan

facilitate systematic monitoring and recording. These may require modification in the light of siteexperience, and it is recommended that a review of their adequacy and ease of use should be carriedout approximately 2 months after the commencement of works on the first section to be constructed.Further reviews should be carried out whenever a new activity, eg. pavement construction,commences.

All environmental monitoring records will be reviewed initially, as they are received at the CSMCsite offices by the REs concerned, who will decide on the appropriate course of action to be taken incases where unsatisfactory reports are received. In the case of relatively minor matters, advice to thecontractor on the need for remedial action may suffice, but in all serious cases, the ER will beinformed without delay, who will either recommend to the Engineer an appropriate course of action,or will issue instructions to contractors to take remedial action, if his delegated powers ailow him todo this.

Monthly site reports prepared by the REs will contain a brief section summarising the results ofenvironmental inspections, remedial measures which have been initiated, and whether or not theresultant action by the contractor is acceptable. The ER's monthly project report should contain asection dealing with environmental matters, which specifically comments on the effectiveness of themitigation measures and management methods applied to control impacts. The reports should alsoidentify any particular problems which are being experienced, and recommend solutions.

Following each of his periodic inspection visits to the sites, the supervision consultant'sEnvironmental Engineer should prepare a brief overview report for the ER, covering each sectionunder construction individually, which summarises the position regarding control of theenvironmental impacts associated with construction. The report should clearly identify any aspectswhich are unsatisfactory, together with the reasons for poor environmental performance.Recommendations should be made for suitable remedial action to be taken, including wherenecessary, any changes in environmental management and monitoring methods, and in the mitigationmeasures which have been adopted.

The tree-planting and borrow pit restoration programmes will fall outside the scope of theconstruction contracts. Day-to-day monitoring will be an integral part of the responsibilities of theNGOs involved with management of these programmes. However, overall responsibility for bothmanagement and monitoring will lie with the PCWD, who may delegate responsibility for theseaspects to the Environmental/Resettlement Specialist within his advisory team.

Monthly reports prepared by the NGOs concerned should set out clearly the progress which has beenmade on each of the road sections for which they are responsible, identifying any problems which arebeing experienced, and making recommendations for any appiopriate remedial action. The CSMCEnvironmental Engineer will also review and repQrt on progress on these aspects during his periodicsite visits.

6.4 Operational Phase Monitoring

Operational phase environmental monitoring will essentially be concerned with reviewing theeffectiveness of routine maintenance of trees and embankments, carried out by LCSs, and the needfor periodic and special maintenance works. It is anticipated that these aspects will be carried out byRHD as the organisation responsible for maintenance.

Since traffic levels on the improved roads are most unlikely to reach a point where air pollution ornoise arising from vehicle operation, or water pollution from pavement run-off are likely to becomesignificant, no monitoring is proposed in these respects.

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Feeder Roads Type A Project Environmental Mlanagement Plan

6.5 Independent Review Monitoring

The monitoring system indicated above will be effectively controlled, directly or indirectly, by RHDas the project proponent. It is not therefore independent.

It is therefore recommended that:

* The Bank should initiate and finance an independent environmental review mission, to examrineand report on all aspects of environmental management and monitoring. The mission's primeobjective should be to establish whether or not the environm7ental managenment and monitoringsystems, procedures etc. as set out in this EvP are actually being implemented, with particularreference to matters relating to impact control during the construction phase.

The most appropriate timing for the mission would be approximately 12 months after the start ofconstruction on the sections within the first year works programme, thus allowing time for anynecessary changes to be made in management or monitorinig in relation to the second yearprogramme. At this point, a substantial part of the works on each of the sections should have beencompleted, and most, if not all, impacts that could occur will probably have been experienced to agreater or lesser extent. However, implementation of the tree planting and borrow pit restorationprogrammes will probably not have commenced since construction works will be continuing on mostsections.

Delay of the mission until these other programmes have commenced, would mean that the secondyear works programme would have started, and it woulcd be moire difficult to introduce any changesin approach, procedures etc.

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Feeder Roads Type A Project Environmental Management Plan

SECTION 7

MITIGATION AND MONITORING COSTS

7.1 General Considerations

Many of the costs associated with implementation of the Environmental Management Plan havealready been, or will shortly be, included in the project budget, as an integral part of specific costitems. For example:

* the incorporation of mitigation measures in designs and contract documents is covered in the costitem for consultancy services for the Phase I and Phase 2 programmes

* the costs of environmental monitoring during construction by CSMC are covered in the item forconstruction supervision and monitoring consultancy services

* construction cost estimates incorporated in the overall project budget will reflect the marginalcosts which will be incurred by contractors in complying with the environmental clausesintroduced into the contract documents

* the costs of actual tree raising and planting, as well as the service fees to the managing NGOs whoorganise planting groups, are included in the overall item for tree planting in the project costestimates

The costs of the borrow pit reinstatement programme (excluding managing/coordinating NGO costs)will be met from private sources (lease payments and/or micro-credit arrangements) and, as such,should not be included in the project budget.

Incremental costs associated with implementing the EMP, which are not provided for under otheritems in the project budget are:

* NGO costs related to the provision of planning and implementation management/coordinationservices for the borrow pit reinstatement programmes

* costs of provision of technical support to the planning/coordinating NGOs for both the treeplanting and borrow pit programmes

* costs of implementing an independent environmental review

In view of the importance of the tree planting and borrow pit programmes to minimisation of two ofthe three key adverse impacts of the project, and therefore to overall environmental performance,together with the desirability of having a completely independent environmental review during theconstruction phase, it is proposed that the costs of the above items should be met wholly by the Bank.

The sections which follow provide budget cost estimates.

7.2 Borrow Pit Programme Management

The cost estimates (in US$ at an exchange rate of US$1=Tk45) in Table 7.2 are based on thefollowing assumptions:

* that the programme will commence as soon as the first contractor commences mobilisation, andwill extend over a period of 48 months; this allows 12 months, following completion of the lastconstruction works within the three year construction period, for the borrow pit programmes to beimplemented at those sites where extraction ceases at the end of construction year 3

* that there will be no cost inflation in US$ terms within the programme period

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Feeder Roads Ty pe A Project Env ironmental Management Plan

* that the managing NGO has local offices which can be used as bases by the field teams, and ahead office where the Team Leader/Coordinator will be based: the allowance made for generaloffice costs assumes that only marginal incremental costs at existing offices are incurred by thefield teams

* that, given the geographic spread of the programme, the field teams will operate from 2 offices,one located north of the Padma river and the other to the south

* the two field teams will each comprise a Project Manager/Sociologist, Fisheries Specialist andAgricultural Extension Specialist: in the event that there is relatively little interest in reinstatementfor agriculture, the Agricultural Extension Specialists would be replaced by second FisheriesSpecialists

Table 7.2 Borrow Pit P'rogramrime Costs

Item Quantity Unit Rate Amount(US$) (USS)

Project Team Leader/Coordinator (part time) 24mm 2200/mth 52800Project Managers/Sociologists (2) 96mm 1780/mth 170880Agric. Extn. Specialists (2) 96mm I110/mth 106560Fisheries Specialists (2) 96mm 11 10/mth 106560Vehicle rent/operation (2) 96mths 1500/mth 144000Out of station allowances 96mths 200/mth 19200Training/workshops 40 250 10000Office operation 96mths 200/mth 19200Computer/printer purchase/maintenance (2 sets) LS LS 8000

Total 637200

7.3 Support to NGO Managers

The provision of managerial and technical training support to the NGOs who will be involved withmanaging the tree planting and borrow pit programmes is consi,dered to be vital, if the programmesare to be executed efficiently and to schedule. Both programmes cover a wide geographical area, andproper planning and coordination are necessary for success. The larger Bangladesh NGOs generallyhave adequate technical skills and experience to implement large programmes, but are relativelyweak in planning, particularly for schemes which must be implemented over a relatively short period,and need careful coordination with other aspects of project implementation. The proposed TAsupport would be focused on strengthening capabilities in these respects, but would also include atechnical support element.

The support programme would run over a period of three years, with the main inputs being in theearly stages of the first year of construction: it being assumed that adequate transfer of knowledgehas taken place over the preceding three years, for the fourth year programmes to be planned andexecuted without external guidance and assistance.

The cost estimates in Table 7.3 are based on the following assumptions:

* that the Bank will recruit individual, freelance experts, rather ithan drawing on staff members fromconsulting firms

• that the specialists will be mobilised from overseas* that there is no cost inflation in US$ terms over the support programme period

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Feeder Roads T\ pe A Project Environmental MNanagement Plan

Table 7.3 Costs of Support to NGO Managers

Item Quantity Unit Amountrate (US$)

(US$)Social Forestry Specialist 5mm 12000 60000Fisheries Specialist 5mm 12000 60000Agric. Extn. Specialist 5mm 12000 60000Airfares 9 3000 27000Per diems 450 180 81000Vehicle hire/operation 15mths 1500 22500

Total 310500

7.4 Costs of Independent Environmental Review

The estimated costs of an independent environmental review are based on the following assumptions:

* that the Bank will recruit an individual, freelance specialist, rather than drawing on Bank staff, ora staff member from a consulting firm

* that the specialist will be mobilised from Europe* that there is no cost inflation in US$ terms over the support programme period* that the Bank office in Dhaka will provide all local transport

Table 7.4 Costs of Independent Environmental Review

Item Quantity Unit Amountrate (US$)

(US$)Environmental Specialist 1mm 12000 12000Airfare 1 3000 3000Per diems 30 180 5400

Total 20400

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APPENDIX 1

References

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Anon. 1996 Technical proposal for the simultaneous development of rural roads andfisheries through the development of borrow pits created duing roadconstruction in a form suitable for aquaculture. IFADEP ProjectALA192/05/02 Bangladesh. October 1996

DHV 1996 Nalka - Hatikamrul - Bonpara New Road; Detailed Environmental Study;Part 5 Environmental Management and Monitoring Plan. DHV ConsultantsBV, in association with Consulting Engineering Services (India) PVT Ltd,Development Design Consultants, Desh Upodesh Ltd. December 1996

Mouchel 1997 Feasibility Study and Detailed Design of Feeder Roads Type A (RRMP3).Interim Report. Volume 2 Environmental Aspects. LG&Mouchel and PartnersLtd, in association with Beca Worley International, Transroute International,Engineering Science Ltd. May 1997

Mouchel 1998 Feeder Roads Type A Project. Environmental Review. LG Mouchel andPartners Ltd, in association with Beca Worley Intemational, TransrouteInternational, Engineering Science Ltd. February 1998

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APPENDIX 2

RHD Tree Planting Guidelines

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Roads and Highways DepartmentGovernment of BangladeshArboriculture Circle

C!IIDETINE

LEASE AGREEMENTS

FOR

ROAD SIDE AFFORESTATION AND MAINTENANCE

THROUGH PEOPLE'S PARTICIPATION

UNDER THE ASSISTANCE OF THE RHD

18-07-94 - Arboriculture CircleRHD, Dhaka.

(English Translation by DHV-Consultanis, Nov. '97)

Roadside Plantation Guide, Arboriculture Circle RHDFile: MMA\EIA\RHDGuide.Doc page

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PREFACE

It is a world wide concern to keep balance with environmental conditions while promoting developmcnt.Tree plantation and maintenance can help in keeping sustainable socio-economic and environmentalbenefits. The importance of trees is multifold: They influence weather and rainfall, and each single treeenhances fresh air quality. The global environment is affected seriously because of careless use ofnatural resources. The human being responsible for the survival on earth has widely exploitcd andmismanaged these natural resources. There are many reasons whv many species have-disappeared. Thecontributing factors are natural disasters, increasing population, industrial revolution, diminishingcultivable land, increased desertification and so on. Besides the green house effect has increased theaverage global temperature which have further adverse global impacts in the next few years accordingto many specialists.

Ten percent of the total world forestry has already been destroyed and further twenty five percent areunder threat. Industrial and urban development destroys seven million hectares of land in every minute;at the same pace 44 hectares of fertile land is currently changing into desert and 22 hectares of forestland is destroyed. Particularly tropical countries, vital for global oxvgen production, are loosingforestry at a rate of one percent every year.

As for Bangladesh, its total area is 143,980 sq.km and the population is 120 million (resulting in adensity of 900 persons per sq.km. Forests covers only nine percent instead of twenty five percent incomparable environmental settings. Since there is great deficit in forest coverage, the government isplanning for forestry improvement in engaging rural people in different activities of tree plantation.

There is no unused land in a highly populated country like Bangladesh. Neither it is easy to meet therequirements of forestry, but using the limited resources substantial improvement and developmenttowards forestry can be achieved. Therefore, the Government is undertaking afforestation efforts in theland adjacent to roads, highways, railways and all kinds of embankments, as well as in public andprivate office yards.

GoB is encouraging public participation by offering share of forestry benefits. Therefore, roadsideafforestation is becoming a main motivation issue nation wide.

Considering the above circumstances, Secretary, Ministry of Communication and Chief Engineer. RHDdecided to plant trees by RHD's Arboriculture Division on at least 200 km of roads even' vear. whileanother 2 km of roadside plantation will be undertaken by the Sub-Divisional Engineer. As a result ofthis decision each year the RHD will plant trees for 450 km of roads which will contain 0.9 millionplants on both sides of the roads. The planted trees shall be well cared and maintained. Trees destroyedwithin the planted areas shall be replaced first in the next year. For tree plantation purpose every yearthe cost will be provided under 168-road, bridge, and maintenance account and for the new road 2%provision shall be made in the Project Concept Paper (PCP).

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Criteria of Planting Trees on Both Sides of Roads

1. Trees are to be planted as such manner that no obstruction is created to the drivers.

2. At least 10.00 m distance from culverts or bridge approaches shall be left free from any trees.Road bends are equally to be kept free of trees.

3. Trees shall be planted in sufficient distance from the road shoulder so that in need vehicles canbe parked on the road side without disturbing smooth traffic movement.

4. Trees like Mahogany, Sissoo, Arjune, Jarul, Jackfruit, Koroi, Neem and Akashmoni are amongsuitable species to be planted along road side. Shrubs are to be discouraged for plantation onside slopes and at the verge as they are likely to get out of control and become harmful to theroads. Mulberry, Banana and Papaya cultivation are also not recommended for cultivation onslopes.

5. Every year by the 30th July tree plantation shall be completed. Growth and resistance againstanimal grazing of newly planted trees will be enhanced if they are cultivated before the end ofJuly. Generally, plants of 2 years of age are more stronger than younger ones. Whatevermethod of plantation is adopted, if the plantation is entrusted and maintained bv local people ingranting them due shares there will be less possibility of destruction and failure. Thereforepeople shall be directly engaged in such plantation scheme.

Project success apparently will depend on the agreement and engagement of local people formaintenance of all these trees after the first or the first two years. In this way local people will learn toappreciate "their" trees and their responsibility for these forestry resources will be strengthened. Incases where there is no road side villages and/or people do not show any interest in tree maintenance,such plantation agreements are not applicable.

* -* *

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Cost Estimate for 1 km Roadside Plantation:

In FY 1994-95, for 1 (one) kmnof tree plantation and maintenance of species mentioned abovein both sides of the roadin 2 rows at 1.82 m planting distance, the following cost estimate is made:

Cost of young plants, including transportation and handling:

2000 nos d Tk. 10.45 each Tk. 20,900 00

2. Labour cost for making planting holes of size .45 x .45 x .45 m(or as per instruction of the executing officer)

2000 no @ Tk. 1.57 each = Tk. 3,140.00

3. Cost of Fertiliser including cowdung

a. Cow dung (0.5 ft3 @ Tk 1.83 per ft) Tk. 0.90

b. Urea(144gr aTk5.59 perkg) Tk. 0.63

c. TSP (I14 gr @Th7.59 perkg) Tk. 0.86

d. MP (114 gr @Tk 6.00 per kg) Tk. 0.68

TOTAL for 2000 no of trees , Tk. 3.08 Tk. 6,160.00

4. Placing of trees in holeand cost of Bamboo pole (1.5 m long, 2 cm diameter) support2000 @ Tk. 3.14 = Tk. 6.280.00

5. Maintenance costs for one year maintenanceI krn x I man x 12 month x 1536.15 Tklmonth = Tk. 18A433.00

TOTAL COST FOR 1 km (both Side)ROADSIDE PLANTATION, INCL. MAINTENANCE = Tk. 54,913.50

Provision has been made for plantation of 2000 trees for 1 (one) kcm of road.

However, the number of plants will depend according to the availability of adequate space on the roadsides.

The cost indicated above include VAT, taxes and profit of contractors.

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Guideline for:

Agreement between local selected beneficiaries and RHDfor roadside plantation and maintenance'scheme

The Government of Bangladesh intends to increase tree resources at a lesser cost on road side by engagementof local people.

Correspondingly,

today . . year _ monthon behalf of the RHD (considered to be 1st Party)

undertakes the following agreement with

the Chairman

of Union council (as a second Party)of VillagePost Office _ Police StationDistrict __,

representing the following persons:

a. Name a. Fathers Name,

b. b.

c. c.

It is agreed to protect trees on both side of road after being maintained by the Government of Bangladesh inmutual responsibility on the following terms and conditions:

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Terms and Conditions

1. The First Party will divide the roadside in various modules and shall develop horticulture schemes withthe finance of 1st Party. The scheme shall be maintained by the 1st Party for the first year or, ifdecided so, for the first two years.

2. The 2nd Party will be selected by the 1st Party. For the tree maintenance the 2nd Party will beengaged. 2nd Party shall be composed primarily frorn landless people categories.

3. If any terms of the agreement is breached by the 2nd Party, the First Party will have right to cancel theagreement.

4. 2nd Party will have right to plant other edible and useful plants like chilli, eggplant, sweet potatoes,cotton, nepiar, para grass, corns etc. In between the existing trees, no cultivation of plants is allowedwhich may create erosion. It is also forbidden to establish there any type of shelter.

5. In embankment slope, timber producing trees such as Sissoo, Mahogany, Arjune, Jarul, Koroi andNeem shall be planted at 1.80 m distance in the first row and at 1.50 m C/C distance in the secondrow. Timber producing trees such as Akashmoni and Rain Tree will remain the property of the 1stParty. Fire wood can be cut after 5/6 years and can be taken by the 2nd Party. The concept is that theleasees will eventually benefit 40% of the total plantation. All trees shall be protected from cow andother animal grazing.

In roads where only one row is allowed the spacing shall be Cc) 5 feet C/C and trees like Koroi, Sissoo,Mahogany and Akashmuni shall be given priority. The 2nd Party can cut down and collect everyalternate tree after 5 to 6 years for use as firewood. Permanent trees @ 10 feet C/C shall be theproperty of the 1st Party. Banana, papaya and bamboo is not allowed for cultivation.

6. The 1st Party will assist 2nd Party by all means in maintenance. In case of threat from 3rd Party 2ndand 1st Party jointly ask for help from the relevant authority. Developed horticultures cannot be leasedto any other organisation.

7. In case there is need for road widening resulting in the removal of trees within 5 to 6 years after thesigning of agreement the 2nd Party will be entitled for compensatiopn at 50% for the removed trees.After the remaoval of trees the site shall be filled, levelled and compacted to the required standard.

8. Within 1Om of the bridge approach no trees are allowed to plant.

9. All parties, with due consultation, can agree for changing any terms of the contract.

(Signatures)

Representative of RHD (Class-I Officer)

Witness _

Union Parishad Chairman

Witness

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Guideline for:

Lease Agreement between Beneficiaries and RHDfor Additional Roadside Plantation and Maintenance Scheme

Agreement is made on date for increase of tree resources along roadsides, at lesserexpenditure

between RHD, represented by (1 st Party),

and (groupslorganisationl7ndividuals) (2nd Party)

represented by Chairman/Secretary on behalf of

2.3.

On basis of 50:50 share of benefit between GoB and (groups/organisationlindividuals) concerning roadsideplantation lease schemes the following terms and conditions are to be adopted:

Terms and Conditions

1. RHD is the only owner of khas land along roads.

2. Tree plantation can be made on the condition that land alongside the road concerned is available.

3. The 1st Party will divide the roadside in various sections and shall lease them out for horticultureschemes to the 2nd Party. The trees (Mahogany, Sissoo, Koroi, Jackfruit, Jarul, Akashmoni, Arjune,Mohanem) shall be planted by the 2nd Party.

4. In embankment slope, timber producing trees such as Sissoo, Mahogany, Arjune, Jarul, Koroi, Neemand firewood producing trees like Akashmoni and Rain Tree shall be planted at 6" distance in the firstrow and at 5" C/C distance in the second row. Fire wood can be cut after 6 years and can be taKen bythe 2nd Party, subject to prior approval of the 1st Party. The concept is that the leasees will have ashare benefit of 50% of the total plantation.

5. 2nd Party will have right to plant other edible and useful plants like chilli, eggplant, sweet potatoes,cotton, nepiar, para grass, corns etc. In between the existing trees, no cultivation of plants is allowedwhich may create erosion. It is also forbidden to establish there any type of shelter.

6. Banana, papaya and bamboo is not allowed for cultivation along roadsides.

7. If any term:ns of the agreement is breached by the 2nd Party, the 1st Party will have right to cancel theagreement at no cost incurring to the 1st Party.

8. If there is need for road widening to remove trees within 6 years after plantation the 2nd Party will beentitled for 70% of the removed tree.

9. In areas of bridge approaches and at road bends no trees are allowed to plant along roadside.

10. On embankments and on plain land the 2nd Party will be allowed to cultivate agricultural crops. Ifrequired by the 1st Party, however, to retrieve soil material for roadlembankment maintenance, the2nd Party will not be compensated.If feasible, the 1st Party will allow beneficiaries to perform fish culture in borrow pits. In such cases, theshare basis for production will be 50:50.

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11. Utmost attention shall be paid by the 2nd Party to avoid any damage to the road embankment

No cultivation of crops along roadside is allowable in areas without prior tree plantation.

12. This agreement is not transferable to other beneficiaries/partiies unless approved by the 1 st Party.

13. The 1st Party will assist 2nd Party by all means in rnaintenance. In case of threat from 3rd Party 2ndand 1st Party jointly ask for help from the relevant aLuthority.

14. Lease will be allowed to collect earth fill materials frDm RHD borrow pit for repair of the embankmentbut not for other individual interests. Every year all holes in the embankment shall be filled up by thelease.

15. The life span of firewood producing plants is 6 years, for timbier and fruit bearing trees is 30 years. The2nd Party will receive share of fruit production at 50%.Tuth (Mulberry) cultivation is not permitted.

16. Trees planted earlier shall be the RHD's property. Road side already satisfactory planted shall be leftaside and shall not be included in the scheme.Road sections located in Social Forestry Schemes shall be exempted from this agreement.

CONCLUSION.

For the purpose of tree plantation in road side there exist a inter-ministerial committeechaired by the Ministry of Forestry. In every District exists a Tree PlantationConmmittee under the Chairmanship of the District Conmnissioner. If RHD.Govenmments Departments and NGOs take positive stapes in tree plantation, withinnext few years the proposed scheme will be successful.

The Arboriculture Division should, with assistance from other Executive Engineers ofRHD, play a key role in implementing the proposed plantation schemes. The StandingOrder of Higher Authority should be followed which specifies the cutting down ofmatured and dead trees. Each removed tree should be replaced by 5 newly planted treesand shall be well maintained.

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