ban: public-private infrastructure development facility (ppidf)...type of business power generation...

Annual Environmental and Social Compliance Audit Report – Regent Energy and Power Limited Project Number: 40517-013 Annual Report April 2015

BAN: Public-Private Infrastructure Development

Facility (PPIDF)

Prepared by the Infrastructure Development Company Limited (IDCOL) for the People’s Republic of Bangladesh and the Asian Development Bank

CURRENCY EQUIVALENTS (as of 30 June 2015)

Currency unit – taka (Tk)

Tk1.00 = $0.013 $1.00 = Tk77.775

NOTES

(i) The fiscal year (FY) of the Government of Bangladesh ends on 30 June. FY before a calendar year denotes the year in which the fiscal year ends, e.g., FY2015 ends on June 2015.

(ii) In this report, "$" refers to US dollars. This environmental and social compliance audit report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Loan No. 2454-BAN-OCR

Public-Private Infrastructure Development Facility

ANNUAL ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT REPORT

108 MW Power Project at Palash, Narsingdhi, Bangladesh

Regent Energy and Power Limited

April, 2015

Prepared by

INFRASTRUCTURE DEVELOPMENT COMPANY LIMITED

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TABLE OF CONTENTS

Executive Summary…..………………………….…………………………………..……………..6

1. Introduction………..………….………………….……...………………………………………..8

1.1 Project proponent.…….…..……………….…….…….……………...…………….…………………8

1.2 Area and location of the project…………..…….…………...………………….…….………..…….8

1.3 Brief description of the project……………..…………….………………………….…….…..…..…9

1.4 Objectives of environmental and social compliance audit……..…….………….……………….10

1.5 Methodology ….………………………..……………………………………….………...………….11

1.6 Reporting period………………………..……………..………………………….…………………..11

1.7 Changes in project scope……………..……………………………………….………..…………..11

1.8 Environmental monitoring ……………..………………………………….…….…………………..11

2. Regulatory Requirements………………………………………………………………………………..12

2.1 ECR, 1997 of Bangladesh Government………………………………………………………..… 12

2.3 SPS, 2009 of Asian Development Bank……………...……………….…..……………….………12

2.4 ESSF of IDCOL………………………………………………………………….……………………12

3. Status of Project Implementation….....………………..…………...................................................13

3.1 Implementation of electro-mechanical and civil components….…….……….…………….……13

4. Implementation of Environmental Safeguards………………………….……………………………14

4.1 Compliance with ECR, 1997…………………………..…………..…………………….…….……14

4.2 Compliance with EMP……………………………………………………………………….……….14

4.3 Compliance with ADB requirement……………….…………………………………….………..…25

5. Implementation of Social Safeguards…………………………………………………..…………..…27

5.1 Impact on resettlement and livelihood ….…………………………………………………….……27

5.2 Institutional arrangement for social safeguards ………………………………………….……….28

5.3 Grievance redress mechanism………………… ………………………………………….……….28

5.4 Impact on indigenous people………………….. ………………………………………….……….28

5.5 Child labour…………………………………..………………………………...………….….………29

5.4 Public consultation and disclosure of information …………...……………...……………………29

6. Corrective Action Plan ……….………...……….……………………...…….………………………….31

7. Conclusion…………………………………….………………………………….………………….…..…32

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Annexure

Annex-1: Environmental Clearance Certificate………...………………………….……..………………...33

Annex-2: Location of the project site……...……………………….…………….…….…….………………35

Annex-3: Project risk rating checklist of ESSF, IDCOL……….………….………….………………….…36

Annex-4: PPE arrangement……………...…….…………….…….………….………….………………..…37

Annex-5: Fire-fighting arrangement.…………………………..….………….…….…….………………..…38

Annex-6: Fire fighting training through in-house expert………….…………….…….………….…………39

Annex-7: Fire drill by Bangladesh fire Service and Civil Defence……….….…….………………………40

Annex-8: Application of signage.…….…………..…………………………….….………….….…. ………41

Annex-9: Current status of project (external view)…….……………………………………..….…………42

Annex-10: Current status of project (internal view)…….……………………………………...….………..43

Annex-11: House- keeping ………………………………………………………………….…………….…44

Annex-12: Arrangement of drainage facility.…………………………………….………………………….45

Annex-13: Land schedule….………………………………………………………….………..….…….……46

Annex-14: Crop valuation report ….………………………………………………………………….………47

Annex-15: Compensation distribution evidence for share cropper………………………….……………48

Annex-16: Compensation distribution evidence in case of transmission line…..………….……………49

Annex-17: List of landowners as were compensated during transmission line…………….……………51

Annex-18: List of female respondents during consultation………………………………….……….……52

Annex-19: List of male respondents during consultation……………………………..……..……….……53

Annex-20: Consultation with male and female respondents………….………….………….……….……54

Annex-21: Consultation with male and female respondents ………..….…………………………...……55

Annex-22: Grievance redress mechanism…………………………….….…………………………...……55

4

List of Abbreviations

ADB Asian Development Bank

DOE Department of Environment

ECR Environment Conservation Rules

REPL Regent Energy and Power Limited

EHS Environment and Health Safety

EMP Environmental Management Plan

ERP Emergency Response Plan

FGD Focus Group Discussion

IDCOL Infrastructure Development Company Limited

IEE Initial Environmental Examination

PPE Personal Protective Equipment

SPS Safeguards Policy Statement

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List of Tables

Table 1.1: Key project information……………………...………….………….…….….…..………………...8

Table 1.2: Distance of project site from major infrastructures.………..……..……..…..….………………9

Table 1.3: List of major equipment……...……………………….……………..….……..….……….………9

Table 1.4: Engine specifications..…….………………….………….……………….….………………...…10

Table 1.5: Generator specifications.…………….………….………….……………….……………..…..…10

Table 3.1: Project progress………….………………….………….…………………….…….….…….……13

Table 4.1: Compliance with ECR, 1997.…….…………..….… ……………………….………………...…14

Table 4.2: Response of REPL on major project activities (construction phase)….……...….……….…15

Table 4.3: Major environmental and social issues and implementation of corrective action plan….…17

Table 4.4: Monitoring parameters and frequency (trial run)…………………….………….….……….…17

Table 4.5: Response of REPL on major project activities (operation phase)…………….………...……20

Table 4.6: Monitoring parameters and frequency (operation phase)……..….……….………………….22

Table 4.7: Ambient air quality at project site on 13 July 2014………………….…..…………………..…23

Table 4.8: Ambient noise level at project site on 13 July 2014……………….………………………..…24

Table 4.9: Ground water quality at project site on 13 July 2014……….………..……………………….24

Table 4.10: Compliance with important EHS aspects during construction and operation…………….25

Table 5.1: Impact on settlement and livelihood…………………………………………………………….27

Table 6.1: Gap between environmental and social compliance and corrective actions…….…………29

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EXECUTIVE SUMMARY

Background

Regent Energy and Power Limited (REPL) has been awarded through a competitive bidding

process to develop and operate an independent power plant project with capacity of 108 MW

at Garpara Village, Palash Upazila, Narsingdhi District. For financial assistance REPL has

approached Infrastructure Development Company Limited (IDCOL), along with other

lenders. Considering the importance of the project to meet the national power demand,

IDCOL has provided a term loan facility of USD 30 million in favour of the project. IDCOL

has sourced the required financing from the fund allocated as ordinary capital resources

(OCR) for large infrastructure projects under Public-Private Infrastructure Development

Facility (PPIDF) of Asian Development Bank (ADB).

According to the Environmental Conservation Rules (ECR), 1997 of Bangladesh

Government, industrial projects have been categorized into four classes—Green, Orange A, Orange B and Red. Considering the magnitude of environmental impacts, power plant

project has been classified as Red Category. Hence, REPL project has fallen into the Red

category. Given the environmental impacts of the REPL project are mostly site specific, ADB

has categorized the project as B as per ADB guidelines. Due to the absence of any

indigenous habitat in the project area, the project has been categorised as C from

indigenous peoples (IP) perspective. But as there were impact on livelihood of seven share

croppers, temporary inconvenience of adjacent locality during installation of gas

transmission line and erection of transmission line, the project has been categorised as B

from involuntary resettlement (IR) perspective. In addition, IDCOL has adopted an

Environmental and Social Safeguards Framework (ESSF). According to this ESSF, the

proposed project of REPL seems to be fallen under the category of High Risk project

requiring detail environmental impact assessment.

Adroit Environment Consultants Limited (AECL) being engaged by REPL as Environmental

Consultant, has conducted the detail environmental impact assessment and prepared the

Initial Environmental Examination (IEE) Report based on the guidelines of Department of

Environment (DOE), Government of Bangladesh (GOB) and Asian Development Bank’s (ADB’s) Safeguard Policy Statement (SPS), 2009. In addition, as there is investment of International Finance Corporation (IFC), REPL has to comply with the respective IFC EHS

guidelines (general and sector specific).

To assess the actual implementation of environmental management plan and social

safeguards, respective IDCOL official visited the project site during construction and

operation phases. According to the IEE, there is requirement of IDCOL to submit annual

Environmental and Social Compliance Audit Report of this project to ADB. Accordingly, this

audit report has been prepared by IDCOL.

Audit overview and findings

The respective IDCOL official has visited the project during the audit period (April 2014 to

April 2015). He has also reviewed the available relevant documents and clearances. In

addition, there was consultation with representatives of adjacent neighborhood. The audit

period encompasses two phases viz. construction (upto June 2014) and operation (from July

2014). During construction phase, REPL had been found to be satisfactorily responsive in

7

regard of environmental and social safeguards. In operation phase, their commitment to

comply with environmental and social safeguards have been found as appreciable.

However, they need to emphasize on the following issues:

Monitoring of surface water quality and adopt required mitigation measures based on the monitoring data (if required);

Revise the existing EHS Guidelines;

Revise the existing Emergency Response Plan;

Adopt required measure to limit the noise level within the acceptable standards;

Conduct stakeholder consultation according to the Stakeholder Engagement Plan and ensure proper documentation about the response of respondents.

8

1.0 INTRODUCTION

1.1 PROJECT PROPONENT

The project involves development and operation of a 108 MW gas based power plant at

Garpara, Palash, Narsingdhi by Regent Energy and Power Limited (REPL). REPL is an

special purpose vehicle of well-known entrepreneur named Habib Group. The generated

electricity from the project will be sold to Bangladesh Power Development Board (BPDB)

under a 15-year Power Purchase Agreement. The following Table 1.1 shows key project

information:

Table 1.1: Key project information

Project Company Regent Energy and Power Limited

Date of Incorporation 12 December 2011

Registration Number CH-9197/11

Registered Address 1182 Jubilee Road, Chittagong

Trade License Number & Issuer No: 112342; Chittagong City Corporation

TIN Number 341-200-7333/CO-6

Type of Business Power Generation

Capacity 108 MW

Fuel Type Gas

Project Location Ghorashal, Polash, Narsingdi

Land Area 4.9 acres

Project Tenure 15 Years

Project Type Independent Power Producer

LOI Issuance Date 23 November 2011

Project Agreements

Power Purchase Agreement (PPA)

Implementation Agreement (IA)

Gas Supply Agreement (GSA)

GenSet Supplier GE Jenbacher GmbH & Co. OG, Austria

1.2 AREA AND LOCATION OF THE PROJECT

It is already said that the proposed project site of REPL 108 MW Project is located at a

village named Garpara of Palash Upazila, Narsingdhi District. It is a purchased land from

private land owners. The area is about 5 acres. The geographical location of the site is

23058’18” N and 90038’27” E. The project site is about 0.5 km away from Ghorashal 1,160 MW power plant. The Ghorashal-Palash Bypass Road is adjacent to the project site. The

Shitalakhya River is at the western side of the site with a distance of about 1.5 km.

Ghorashal Fertilizer Industry and Pran Group of Industries have been found to be about 2

km away from the site. There is vacant high land lying on the northern side. Some scattered

homesteads are found on the western side of the project site. There are trees on the

southern side including few tin-shed houses. The estate of Bangladesh Railway is on the

9

eastern side of the site. The schematic location of the project in respect of local context and

satellite image of the project area has been presented in respect of 500 m radius air shed

are presented in Annex-2.

Table 1.2: Distance of project site from major infrastructures

Major Infrastructure Areal distance from site (km)

Ghorashal power plant 1.75

Ghorashal 132KV sub-Station 1.75

Ghorashal Fertilizer Industry 3.75

Janata Jute Mill 3.0

Pran Factory 4.0

Upazila parishad office 1.0

Gas source 1.75

Bus stand 1.25

Shitalakkhya river 4.25

Source: Google Earth

1.3 BRIEF DESCRIPTION OF THE PROJECT

The technology involves for power generation of REPL108 MW project is mainly based on

reciprocating engines. The primary fuel is natural gas. There are 34 (thirty four) reciprocating

engines with a cumulative capacity of 108 MW, which are coupled with alternator to generate

electricity. The following Table 1.3 shows list of major equipment as have been used in this

power plant.

Table 1.3: List of major equipment

The GE JMS 620 F101 GS-N.L is a four-stroke gas engine, in which the cylinders are in

V60o configuration. The following Table 1.4 shows technical specifications of the engines.

Major Equipment Manufacturer Country of Origin Unit

Engine (JMS 620 F101) GE Jenbacher Austria 34

Generator (DIG 142) Cummins (AVK) Germany 34

Main Transformer (11/230 kV,75 MVA) Siemens India 2

Aux. Transformer (11/0.415 kV,2.5 MVA)

Charoenchai Thailand 2

230 kV SF6 Circuit Breaker Siemens Germany 3

11 kV vacuum Circuit breaker Siemens India 38

10

Table 1.4: Engine specifications

Particulars JMS 620 F101 GS-N.L

Number of cylinders 20

Engine speed 1,500 rpm

Cylinder bore 190 mm

Piston stroke 220 mm

Mean Piston Speed 11 m/s

Moment of inertia 69.21 kgm2

Exhaust gas temperature at full load 390oC

Combustion air volume 14,111 Nm3/h

Length X width X Height 5.542x1.90x2.54m3

Weight 12,000kg

The generators are designed to operate together with JMS 620 F101 GS-N.L engines. The

following Table 1.5 shows technical specifications of the generators.

Table 1.5: Generator specifications

1.4 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL COMPLIANCE AUDIT

The audit has been conducted with the aim to assess the project’s compliance with-

(i) Environment Conservation Rules (ECR)1997 of GOB;

(ii) Environmental and social safeguards according to the Environmental and Social

Safeguards Framework (ESSF) of IDCOL;

(iii) Environmental and social safeguards according the Safeguards Policy Statement

(SPS), 2009 and other relevant standards and guidelines of the ADB;

(iv) Proposed mitigation measures and monitoring procedures according to the

environmental management plan (EMP), resettlement action plan (RAP) as are

applicable.

Particulars DIG 142 h/4 e

Manufacturer AVK

Rating at p.f.=1.0 3.354 MW Rating at p.f.=0.8 3.338 MW Rated current at p.f.=0.8 219 A Nominal Voltage 11 kV Frequency 50Hz Speed 1,500 rpm Permissible over speed 2,250 rpm Power Factor lagging 0.8-1.0 Efficiency at p.f.=0.8 97.3% Maximum ambient temperature 40oC

Mass 12,700 kg

11

1.5 METHODOLOGY

The audit includes the following steps:

(i) visits the project site and consult with stakeholders especially local people;

(ii) review the environmental and social safeguards documents including environmental impact assessment report, EMP and Resettlement Action Plan, Stakeholder Engagement Plan (as are relevant) ;

(iii) assess actual implementation of the guidelines/action plan of the safeguard related

documents.

1.6 REPORTING PERIOD

The reporting period of this Environmental and Social Compliance Audit Report is

April 2014 to April 2015. During this reporting period upto June 2014 was

Construction phase and from July 2014 has been considered as Operation phase.

1.7 CHANGES IN PROJECT SCOPE

There is no change in the technology and operational process as have been declared

by the respective government and accepted by REPL. So, it can be said that the

Environmental Management Plan of ADB approved Initial Environmental Examination

(IEE) is fully applicable during the reporting period as well.

1.8 ENVIRONMENTAL MONITORING

The parameter, frequency and methodology of environmental monitoring are in

accordance with EMP of ADB approved IEE, as has been detailed in chapter 4 of this

audit report.

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2.0 REGULATORY REQUIREMENTS

2.1 ENVIRONMENT CONSERVATION RULES, 1997 OF BANGLADESH

The project has to comply with the Environment Conservation Rules (ECR), 1997. According

to the categorization of ECR, 1997, the project has been categorised as Red1 meaning that

it has significant adverse environmental impacts, which are to be mitigated with proper

mitigation measures.

2.2 ENVIRONMENTAL AND SOCIAL COMPLIANCE RELATED STANDARDS AND

GUIDELINES OF ASIAN DEVELOPMENT BANK

The project has to be complied with Safeguards Policy Statement (SPS), 2009 of ADB in

regard of environmental and social (E&S) compliances. Considering the adversity of

environmental impacts, it has been categorized as B from environmental safeguard point of

view. Accordingly an IEE has been prepared, which is already approved by the ADB. As no

record of any indigenous habitat has been found at Garpara, Palash the project has been

categorised as C in respect of Indigenous People (IP). But in consideration of affecting the

livelihood of seven share croppers, temporary inconvenience of shop keepers along the road

side and landowners along the transmission line, the project has been categorised as B

from IR perspective.

2.3 ENVIRONMENTAL AND SOCIAL SAFEGUARDS FRAMEWORK OF IDCOL

IDCOL has adopted an Environmental and Social Safeguards Framework (ESSF) in 2011,

which is to be complied with all infrastructure projects as are to be funded IDCOL. According

to the environmental categorization of ESSF, the project has been categorised as High

Risk2 project requiring significant compliance safeguards including comprehensive

environmental impact assessment and regular monitoring. In consideration of social

categorization, the project has been categorised as Moderate Risk in consideration of social

safeguards due to the partial change of livelihood of seven share croppers and temporary

inconvenience of some local people while installing gas distribution and power transmission

line.

1 Schedule-1 of ECR (project no. 6 of Red category), 1997

2 The project risk screening checklist of ESSF, IDCOL is provided in Annex-3

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3.0 STATUS OF PROJECT IMPLEMENTATION

3.1 STATUS OF IMPLEMENTATION OF VARIOUS ELECTRO-MECHANICAL

COMPONENTS

The status of progress of implementation of major electro-mechanical and civil components upto 20 April 2015 are mentioned in Table 3.1, where it is observed that the project work has been fully accomplished as the project has started commercial operation from July 2014.

Table 3.1: Progress of implementation of electro-mechanical and civil components

Type of

component

Component Percentage of

accomplishment

Ele

ctr

o-m

ech

an

ical

co

mp

on

en

t

Generator 100

Exhaust gas system 100

Ventilation system 100

Intake air system 100

Gas train of gen-Set 100

Lube oil system 100

Cooling water system 100

Electrical works 100

11KV/230 KV sub-station 100

11/0.4 KV auxiliary transformer 100

Gen-set control panel/MCC panel/VCB panel (switch gear) 100

Testing & Commissioning 100

230 KV HT cable terminations and Transmission Towers 100

Gas Pipeline 100

TBS and RMS 100

Fire Fighting System 100

Civ

il c

om

po

nen

t

Power house and warehouse 90

Internal and external drainage 100

Road surface 100

Administrative Building 100

Septic tank and soak pit 100

Water reservoir of fire hydrant 100

The photographs of current status of various project components are provided as Annex-9

and 10.

14

4.0 IMPLEMENTATION OF ENVIRONMENTAL SAFEGUARDS

4.1 COMPLIANCE WITH ENVIRONMENT CONSERVATION RULES, 1997

REPL has to comply with the requirement of ECR, 1997 of the DOE. In the following Table

4.1, the compliance status of REPL, in regard of major milestones of ECR, 1997 is depicted.

The Environmental Clearance Certificate is provided in Annex-1.

Table 4.1: Compliance with the requirement of ECR, 1997

Basic Requirement Compliance Status

Approve IEE Fully complied

Approve EIA Fully complied

Award Site Clearance Certificate Fully complied

Award EIA approval Fully complied

Award Environmental Clearance Certificate Fully complied

4.2 COMPLIANCE WITH ENVIRONMENTAL MANAGEMENT PLAN

4.2.1 COMPLIANCE WITH EMP DURING CONSTRUCTION PHASE

a. Institutional arrangement

REPL had formed an Environment and Health Safety (EHS) Team comprising three full-time

personnel, to look after the environmental, social and occupational health safety aspects

during construction phase. The EHS Team was led by Mr. Md. Abdul Ghani. He is a retired

officer of Bangladesh Navy having expertise on EHS aspect. He was assisted by two

engineers. The overall EHS implementation at project site was monitored Mr. Ismail Sarker,

Plant Manager. He is a graduate Electrical Engineer having about 15 years experience in

power sector.

At the corporate level, the EHS compliance was monitored by Mr. Emrul Chowdhury. He is

an experienced Electrical Engineer. He has sound orientation on environment and health

safety aspects. To comply with the required EHS compliance in a systematic manner, REPL

had adopted an EHS Manual.

b. Compliance status

In the IEE, a number of activities having potential adverse environment impacts and

occupational health safety aspects in relevant to construction phase have been identified. In

the following Table 4.2, suitable mitigation measures to address these impacts according to

the EMP and responses by REPL have been discussed.

Table 4.2: Response of REPL on major activities and potential impacts (construction phase)

Project activity Potential Impacts Proposed mitigation measures as per EMP Actual Implementation Status of

compliance

Influx of workers

Generation of

sewage and solid

waste

Construction of sanitary latrines and septic tank system

Erecting “no litter” sign, provision of waste bins/cans, where appropriate

Proper disposal of solid waste

Sanitary latrines were provided

To ensure proper solid waste disposal, various types of waste bins were found to be practiced.

Partially complied

Possible spread of

disease from

workers

Clean bill of health a condition for employment

Regular medical monitoring of workers

Efforts have been observed to maintain health safety in working condition.

Partially complied

Transportation of

equipment,

materials `and

personnel; storage

of materials

Deterioration of air

quality from

increased vehicular

movement, affecting

people in the

surrounding areas

Keeping vehicles under good condition, with regular checking of vehicle condition to ensure compliance with

national standards and EHS guidelines (as applicable)

The available vehicles were found mostly of satisfactory condition, based on visual observation.

Partially complied

Wind-blown dust

from material (e.g.

fine aggregate)

storage areas

Watering the access road

Sprinkling and covering stock piles

Covering top of trucks carrying materials to the site and carrying construction debris away from the site

Access road was found to be watered

Stock piled had been found to be covered.

Partially complied

Site clearance Topographic change

by cutting existing

trees, shrubs, herbs,

and filling land

Adopt such type design as is required minimum cutting of trees, shrubs, herbs, and low-land filling

Use waste shrubs, herbs as organic fertilizers

Adopt required measures to prevent waste shrubs, herbs as fuel to cook or for any localized burning

purpose.

Basic design of the project has been found as land efficient i.e. ensuring optimum use of land.

As the project site was a low lying land having irregular terrain, there was neither significant shrubs nor trees.

Partially complied

Noise from

construction

equipment

operations and

Noise could exceed

the allowable limit

and result in hearing

loss

Use of noise suppressors and mufflers in heavy equipment

Avoiding, as much as possible, construction equipment

Workers were found to be equipped with PPE.

Most of the noise intensive work had been reported to be accomplished

Partially complied

16

Project activity Potential Impacts Proposed mitigation measures as per EMP Actual Implementation Status of

compliance

maintenance producing excessive noise

Avoiding prolonged exposure to noise by workers

Creating a buffer zone by introducing green belt around the project site

Follow construction scheduling to avoid evening and nighttime disruption

during day time.

Dust during

construction and

exhaust gases from

construction

machinery and

vehicles (particulate

matter, NOx, SO2)

Increased SPM,

NOx, SOx levels at

construction sites,

and surrounding

areas

Avoiding equipment usage such as stone crushers at site, which produces significant amount of particulate

matter

Immediate use of construction spoils as filling materials

Immediate disposal/sale of excavated materials

Continuous watering of bare areas

Ready-made stone chips were used

The evidence of using construction spoils as filling materials was

observed

Watering was observed in bare areas

Partially complied

Fires, explosion and

other occupational

health safety related

issues

Risk of human

health and property

damage

Use of personal protective equipment during construction and maintenance.

Prepare and implement safety and emergency manual.

Regular inspection of lines for faults prone to accidents.

Provision of fire protection equipment.

Provision of Lightening arrestors

Fire extinguishers were found in the site.

Evidence of regular inspection of lines for faults prone to accidents, had been observed.

Partially complied

REPL had been found responsive about satisfactorily complying with EMP requirement.

While visit in January 2014, IDCOL official had identified some areas requiring corrective

actions. REPL’s response in regard of this proposed corrective actions are documented in Table 4.3.

Table 4.3: Major environmental and social issues and action plan

Issue Required corrective action Status of implementation

of corrective action

House keeping The standard of house-keeping at project site needs to be

improved to minimize the risk of accidents and associated

pollution.

Fully complied (Annex-11)

Availability of

PPE

There is scope to increase the number and quality of PPE, in

respect of actual demand.


Workers

accommodation

The health safety condition of the workers’ accommodation facility requires improvement.

Partially complied

Sanitary facility The sanitary facility seems to be inadequate. Partially complied

Drainage and

water logging

There is evidence of water logging and the drainage has not

been completed.


C. Environmental monitoring

I. Technical approach of environmental monitoring

According to the IEE, no environmental monitoring has been required in the EMP during

construction phase except during trial run. Because usually trial run phase is considered as

the final milestone of construction phase. According to the EMP, the monitoring requirement

during trail run is as follows (Table 4.4).

Table 4.4: Monitoring parameters and frequency of monitoring during trial run

Key parameters to be monitored: (1) Ambient Air Quality

location frequency parameter

At Project site, residential/institutional/commercial

areas within 500m outside from plant boundary

(4 locations)

Once during trial run SOx, NOx and CO

Key parameters to be monitored: (2) Noise


At four corners of Project boundary,

residential/institutional /commercial areas within 100m

and 300m outside from plant boundary

Hourly basis for 24

hours during trial run

Limits in dBA

18

II. Result of environmental monitoring

There was no air and noise quality monitoring during trial run.

III. Disclosure of environmental monitoring

As disclosure of environmental monitoring, REPL is required to keep monitoring result

available at project site. But as neither air nor noise quality was monitored during trial run, no

result has been made available for disclosure purpose.

IV. Monitoring adjustment measure

As there was no monitoring, the requirement of monitoring adjustment was not determined.

19

4.2.2 COMPLIANCE WITH EMP DURING OPERATION PHASE

a. Institutional arrangement

To ensure satisfactory EHS compliance, REPL has already appointed Mr. Abdullah Al

Mahmud. Mr. Mahmud is experienced with technical and EHS issue in relevant to power

plant because he served in Meghnaghat 450 MW power plant for a considerable period of

time. He is assisted by Mr. Abdul Ghani and a group of engineers.

At the corporate level, the EHS aspect is monitored by Mr. Emrul Chowdhury.

b. Compliance status

In the IEE, a number of activities having potential adverse environment impacts and

occupational health safety aspects during operation phase have been identified. In the

following Table 4.5, suitable mitigation measures to address these impacts according to the

EMP and actual responses by REPL has been discussed.

Table 4.5: Response of REPL on project activities and mitigation measures during operation phase

Project Activity Potential Impacts Proposed mitigation measures in EMP Actual implementation Compliance

status

Power generation

Emission from the power plant Using 20 meter tall stack

Installation of stack emission monitoring equipment for major pollutants

Planting of indigenous trees around the Project site

20 meter tall stacks have been installed

Fully complied

Generation of noise from

generators and associated

sub-stations , which could

exceed 70 dB(A) at site

boundary

Locate facility 70–100 m from nearest receptor;

Use walls, fencing, and/or greenbelt to provide partial noise barrier

Provision of silencers or generators an turbines (if need arises)

Use of ear-muffs and ear-plugs by plant personnel working in the generator and turbine facilities of the plant

Walls are being installed as noise barrier.

Ear plugs were being used as noise barrier.

Partially complied

NOx generation from the engine, which can negatively affect health

Use low-NOx burners and water injection to control NOx;

Should maintain burning temperature less than 900 OC

REPL has installed low-NOx burners and water injection to control NOx.

The burning temperature is less than 900 OC.

Fully complied

Suspended particulate matter

(SPM) and PM2.5, PM10

generation from the engine,

which can adversely affect

health

Use fabric bag filter to reduce particulate matter before discharging the emission.

Good combustion control, required stack height should also be maintained properly

Fabric bag filter has been introduced.

Good combustion and required stack height have been ensured.

Partially complied

21

Project Activity Potential Impacts Proposed mitigation measures in EMP Actual implementation Compliance

status

Electro-magnetic wave or

electrical interference, which

may result in occupational

health risk.

All equipment should be grounded earthing with mesh system.

Power plant to sub-station should be connected by HT cable.

Power plant & substation site is away from the settlement.

No house is located in the immediate vicinity of the site.

Relevant equipment have been grounded.

Power plant to sub-station has been connected by HT cable.

Power plant & substation site are away from the settlement.

No house is located in the immediate vicinity of the site.

Fully complied

Heath safety during

operation

Risk of human health and

property damage

All necessary safety equipment should be ready at the plant.

Regular training on safety needs to provide.

PPE were found to be adequately practiced.

Fully complied

Fires, explosion and

other accidents

Risk of human health and

property damage

Use of personal protective equipment during operation and maintenance.

Prepare and implement safety and emergency manual.

Regular inspection of lines for faults prone to accidents.

Provision of fire protection equipment.

Provision of Lightening arrestors

There are fire extinguishers

Automated firefighting system has been installed. (Annex-5).

Regular fire drill has been accomplished (Annex-6 and 7).

Fully complied

Domestic wastewater

and sewage

BOD, fecal coliform

contamination in groundwater

and surface water

Need to provide septic tank with soak pit for treatment of sewage.

Septic tank with soak pit for treatment of sewage.

Fully complied

Wastes oil from Plant

(scrap metal, waste,

lube oils, spill oil etc)

Potential soil and groundwater

contamination

Secure on-site storage, waste sell to the DOE authorized vendor for discharge in a safe place.

Used lube oil is being sold to DOE designated vendor.

Fully complied

c. Environmental monitoring

I. Technical approach of environmental monitoring

In the EMP of the IEE, environmental monitoring has been required during operation phase.

The air, water and noise quality monitoring schedule are depicted in Table 4.6.

Table 4.6: Monitoring parameters and frequency of monitoring during operation phase

Key parameters to be monitored: (1) Ambient Air Quality


At Project site, residential /institutional

/commercial areas within 500m outside from

plant boundary.

Quarterly (routine) analysis SPM, SOx, NOx

Key parameters to be monitored: (2a) Surface Water


Project site at Garpara Bi-annual basis in each year (pre-

monsoon and post-monsoon)

pH, Temperature, DO,

BOD, COD, TDS, Oil

and grease

Key parameters to be monitored: (2b) Ground Water


Project site at Garpara Bi-annual basis in every year (pre-

monsoon and post-monsoon)

pH, Temperature, DO,

BOD, COD, TDS, Oil

and grease

Key parameters to be monitored: (3) Noise


At four corners of Project boundary,

residential/institutional /commercial areas

within 100m and 300m outside from plant

Quarterly (routine) analysis (four

times in each year)

Limits in dBA

Table 4.7: Ambient air quality at project site dated on 13 July 2014

Location PM2.5

(µg/m3)

PM10

(µg/m3)

SPM

(µg/m3)

SOx

(µg/m3)

NOx

(µg/m3)

At project site 57 117 198 34 39

Standard of DOE 65 150 150 365 150

24

Table 4.8: Ambient noise level at project site dated on 13 July 20143

Location Noise level in dBA

Day (6.00 am to 9.00 pm) Night (9.00 pm to 6.00 am)

At project site 68.11 58.72

Standard of DOE 60 50

Table 4.9: Ground water quality at project site dated on 13 July 2014

Parameter Monitoring result DOE Standard

pH 6-9 6-9

Temperature 250C 20-300C

DO 5.2 6 mg/l

BOD 0 0.2 mg/l

COD 0.6 4 mg/l

TDS 175 1000 mg/l

Oil and grease 0 0.01 mg/l

II. Result of environmental monitoring

During operation phase, the ambient air quality has been found to comply with the

acceptable limit of DOE standard. But the noise level has been measured higher than the

acceptable limit. In this regard, REPL has informed that they have adopted critical silencer,

styrofoam and buffer wall. In addition, they have planted trees along the boundary of project

site. But REPL is in the process to explore further measures to fully comply with the noise

limit. The ground water quality has been found to be within the limit of DOE. But REPL has

to monitor the surface water quality to ensure that the project is not responsible to adversely

affect the ambient surface water.

III. Disclosure of environmental monitoring

As disclosure of environmental monitoring, REPL has kept the copy monitoring result

available at project site.

IV. Monitoring adjustment measure

The air and ground water quality monitoring result has been found to be within the limit. To

comply with the noise limit REPL has expressed commitment to adopt the required

mitigation measures.

3 The monitoring data has been provided by REPL

25

4.3 COMPLIANCE WITH SAFEGUARDS POLICY STATEMENT, 2009 OF ADB

It is already said that the REPL project has to comply with the requirement of SPS, 2009 of

ADB. Accordingly, the compliance of this project in regard of major EHS related requirement

are mentioned in Table 4.10, where the gray colored portion represents the construction

phase and colorless portion represents the operation phase.

Table 4.10: Compliance with important EHS aspects during construction and operation phase

ADB

Requirements

Issue and Description of

Observation

Status of

compliance

Recommendation

Environment

Assessment

requirements for

various financing

modalities

The IEE of the project comprehensively

describes the potential environmental,

social and occupational impacts in

compliance with SPS 2009 of ADB, and

IFC EHS guidelines (General and

Power plant).

To ensure the implementation of EMP

during construction phase (upto June

2014) REPL had been found to adopt

specific EHS Implementation

Guidelines, where induction training

and other relevant issues required to be

more structured.

Partially

complied

Revise the EHS Implementation

Guidelines with focus on

induction training and other

relevant issues need to be more

structured.

During operation phase (from July

2014), REPL has adopted an EHS

Implementation Guidelines, which could

be enhanced by incorporating the IFC

EHS Guidelines (general and project

specific) in a more structured manner.

Partially

complied

REPL has to make the required

improvement in EHS Guidelines

in light of IFC EHS Guidelines

(general and project specific).

Occupational and

Community

Health and safety

During construction phase the

occupational and community health

safety measures had been found to be

in line. Regular consultation with

community representative had ensure

the effective community participation.

Partially

complied

No action was required.

During operation phase, REPL has

ensured the satisfactory application of

PPE.

Fully

complied

No action is required

There is satisfactory evidence of fire

drill.

Fully

complied


Biodiversity

conservation and

sustainable

natural resource

management

The scale and complexity of

construction activities were too limited

to adversely affect local biodiversity and

to appear as detrimental in respect

natural resource management.

Fully

complied


26

ADB

Requirements

Issue and Description of

Observation

Status of

compliance

Recommendation

The activities in relevant to operation

phase seems to be inadequate to

adversely affect the biodiversity and

natural resource management in the

project area to a greater extent. But due

to the long term operation of the

project, there could be limited/minimal

impact to the local biodiversity.

Fully

complied REPL has to ensure proper

implementation of EMP.

Pollution

prevention and

abatement

Based on the visual observation, the

pollution prevention and abatement

process has been found as mostly

satisfactory during the construction

phase.

Partially

complied No action was required.

REPL has conducted air and ground

water quality monitoring during

operation phase. But they also need to

monitor the surface water quality

according to the EMP.

Partially

complied

Monitor the surface water

quality.

During operation phase, the noise level

has been found to be higher than the

acceptable limit. So, there is necessity

of noise monitoring to have the actual

data and respond accordingly.

Late

complied Adopt required mitigation

measure.

There is scope to improve the present

spillage management process.

Partially

complied

REPL needs to emphasize on

spill management process.

Physical Cultural

resources

Garpara is a rural area having

dominating agricultural trend. In

addition, it is significantly deprived with

adequate educational and cultural

facility. So, there is no significant

physical cultural resources in close

proximity to this project. So, to affect

the physical cultural resources during

construction phase seemed to be

irrelevant.

Fully

complied


Due to the unavailability of physical

cultural resources within the range of

close distance, the issue of adversely

affecting the physical cultural property

seems not to be relevant with the

project.

Fully

complied


27

5.0 IMPLEMENTATION OF SOCIAL SAFEGUARDS

5.1 IMPACT ON RESETTLEMENT OF THE PROJECT AFFECTED PEOPLE AND LIVELIHOOD

As the project site is a purchased land of REPL from private land-owners through willing seller-willing buyer arrangement, there is no issue resettlement. There was no physical displacement or loss of structure of any project affected people due to the land purchase. The land schedule is available as Annex-13. As there were seven share croppers cultivating about 4 acres of land of total 5 acres area of project site, their economic displacement has been considered as a temporary impact of the project. So, the project has been categorized as B from Involuntary Resettlement (IR) perspective. The potential impacts of the project on settlement and livelihood of project area and adopted compensation measures are described in the following Table 5.1.

Table 5.1: Impact on settlement and livelihood

Project

activity

Type of impact Compensation measures

Construction of

power plant

There were 7 share croppers,

who used to cultivate in an area

of about 4 acres. Due to the

project intervention, they had

faced some temporary loss of

livelihood.

The members of the PVAT4 assessed the amount of cultivable land under the jurisdiction of each PAP. Thereafter, there was consultation with Mr. Md. Ishaque, Upazila Agriculture Officer, Palash, Narsingdhi about the amount compensated amount in terms of the value of the crops (Annex-14). As the sharecroppers used to cultivate on a 50% sharing of produced crops, they were given total Tk.1, 20, 000 (Annex-15) as compensation for one season’s standing crop.

Installation of

gas

transmission

line

1.5 km gas transmission line has followed the right of way of existing government’s road. So, there was no issue of land acquisition. However, there are homesteads and shops adjacent to the road, prone to temporary inconvenience.

Most of the shopkeepers and representatives of households along the gas transmission line were willingly engaged in gas transmission related works especially earth cutting and filling and they were given higher wages than the usual labour.

Erection of

transmission

line

While erection of transmission

line, there is minimal scope to

affect the adjacent landuse and

settlement due to the vertical

distance between transmission

line and ground surface (about

100 feet). But as best practice

REPL has emphasized the issue

with due attention.

In case of erection of transmission line, REPL has compensated the affected people with a rate of Tk. 30,000 to 50,000 for per decimal of land based on the type of land, due to indirectly affected. The list of compensated people has been provided in Annex-17.

4 PVAT means Property Valuation Advisory Team

28

5.2 INSTITUTIONAL ARRANGEMENT ON SOCIAL SAFEGUARD

There were two-tier arrangements to deal the stakeholder including resettlement and other

social aspects. During construction phase, Mr. Ismail Sarkar served as Plant Manager, who

was responsible to ensure the social safeguards at plant level. But during operation phase,

Mr. Abdullah Al Mahmud, Plant Manager, REPL is in the responsibility to ensure social

safeguards.

From corporate level, Mr. Emrul Chowdhury is responsible to provide required cooperation to

ensure social safeguards during operation phase as like as construction phase.

5.3 GRIEVANCE REDRESS MECHANISM

To redress the grievances in a satisfactory manner, REPL has introduced Grievance Log

Book (Annex-22). The Grievance Log Book is accessible for any internal or external

stakeholder, who wants to place grievances in writing. But in case of confidentiality, there is

an arrangement of Grievance Box, where anyone can place complain in a secret manner.

But REPL has to think about a designated cell phone number and e-mail ID to facilitate

effective grievance redress. To resolve significant grievances, REPL is expected to form a

Grievance Redress Committee (GRC), with the structure as has been detailed in Box-5.1.

Box-5.1: Formation of GRC

Representatives of local government : Md. Ishaque, Upazila Agriculture Officer

Representative of REPL : Abdullah al Mahmud, General Manager

Representative of Affected people : Md. Gofur Miah, share cropper

Representative of IDCOL : Raihan Uddin Ahmed, Environmental Specialist

But prior to approaching the GRC, REPL has to make sure that all efforts have been duly

made at the project level to reach informal resolution of grievances in consultation with

affected party (AP).

5.4 IMPACT ON INDIGENOUS PEOPLE

Based on the primary observation during site visit and secondary sources including BBS5

Census 2011, no habitat of any indigenous community has been reported at Garpara. So,

the project has been categorized as C for Indigenous Peoples (IP) safeguards concluding

that there is no issue about adversely affecting IP neither in construction phase nor in

operation phase.

REPL has conveyed that they are gender and caste neutral. So, any qualified person coming

from the indigenous community will be equally treated during the recruitment process, and

will be given the same benefits as like as other personnel.

5 BBS stands for Bangladesh Bureau of Statistics

29

5.5 CHILD LABOUR

The Bangladesh Labour Act 2006 (Act XLII of 2006) also defines the “child” and the “adolescent” on the basis of age. As per section 2(8) of the Act, a person who has attained the age of 14 but below the age of 18 is considered to be an „adolescent‟ and as per section 2(63), a person not attaining the age of 14 is defined as a “child‟.

According to The National Child Labour Elimination Policy 2010, following rights are to be

complied with, in regard of addressing child labour Issue

Employing children according to the age determined by the Acts and not to employ children below 14 years as a regular employee;

Ensuring the children at domestic work not to perform any hazardous work and providing them with proper food and accommodation, education, recreation since they work full time; and

Refraining child workers from physical, mental, sexual persecution and abuse.

REPL has been found to be careful about the child labour issue. So, neither in construction

phase nor in operation phase, no child has been found to be engaged in the project

activities.

30

5.6 PUBLIC CONSULTATION AND DISCLOSURE OF INFORMATION

I. Public Consultation

As part of environmental and social compliance, the respective official of IDCOL consulted

with local respondents for a number of periods including a consultation on 16 November

2014. In this consultation 24 male respondents were consulted ranging age from 35-60

years. The list of male respondent has been provided in Annex-19.

The social structure of Palash, Narsingdhi is conservative. So, it is inconvenient to discuss

with female respondents. However, with the co-operation of local people, three women were

consulted. They said that they have not feel any inconvenience due to any activities of

Project or Project related personnel. Like the male respondent, they have shown concern

about noise especially the noise of operation phase. The list of female respondents has

been provided in Annex-18. In addition, the photographs of consultation has been provided

as Annex-20. Besides this formal consultation, there were a number of informal consultation

with limited respondents such as consultation on 20 April 2015 (Annex-21).

II. Major findings

The major findings of public consultation are as follows:

local people do not have specific concern about project-personnel or project activity.

due to the Project their socio-economic status has improved. They are earning more by selling goods and renting-out residential accommodation to the project people.

they have requested to minimize the impact of noise

a significant number of local people have already been engaged in the project. But as the rate of unemployment is high at Garpara, they have requested to engage more local people.

III. Response from REPL

In response, the REPL official has ensured that they are considering the noise issue with

due importance.

IV. Disclosure

REPL has to adopt structured approach to disclose the grievance redress aspects, results of

environmental monitoring and any other issue (as seems relevant during operation phase).

31

6.0 CORRECTIVE ACTION PLAN

6.1 CORRECTIVE ACTION PLAN IN REGARD OF ENVIRONMENTAL AND SOCIAL

SAFEGUARDS

Based on the discussion in earlier chapters, it assumes that the REPL had been found to be

satisfactorily environmental and social (E&S) safeguards compliant during construction

phase. But they are required to focus on some specific issue to make the project

satisfactorily E&S compliant during operation phase as well. In this regard, the specific E&S

issues with potential corrective measures are depicted in the following Table 6.1.

Table 6.1: Gap between E&S compliances and proposed corrective action plan

Aspect Issues Reason of inadequacy Corrective measure Required committed time period

Environmental

EHS

Guidelines

There is scope to improve the

existing EHS Guidelines.

Revise the existing EHS Guideline to clearly describe the process of EMP implementation during operation phase according to the standard of IFC.

30 July 2015

Emergency

Response Plan

(ERP)

There is scope to improve the

existing ERP.

Revise the existing ERP to make it more objective oriented.

30 July 2015

Noise

The local people raised the

issue of higher noise level

Erection of boundary wall and adopt required mechanical measures to limit noise level.

30 August 2015:

find the solution

31 December 2015

complete the

implementation

Surface water

monitoring

There is potential risk of

surface water population from

a project where lube oil and

other chemical substances

are used with a considerable

amount.

To monitor the surface water quality and adopt required measures based on the monitoring result.

30 July 2015

Social Grievance

Redress

Mechanism

(GRM)

Due to the close proximity to neighborhood, the project requires intensive monitoring of social safeguards including GRM.

To conduct regular consultation with stakeholders according to the Stakeholder Engagement Plan.

30 July 2015

32

7.0 CONCLUSION

Based on the findings of environmental and social compliance audit, it can be concluded that

REPL had been found adequately responsive in regard of complying with environmental and

social safeguards during construction phase. In case of complying with the environmental

and social safeguards during operation phase, REPL has been found to be committed. So, it

is expected that they will ensure the proper implementation of corrective action plan (Table

6.1).

33

Annex 1: Environmental Clearance Certificate issued by the DOE

35

Annex 2: Location of the project site

Figure: Schematic location of the project in respect of local context

Figure: Satellite image of the proposed Project (500 m radius)

36

Annex 3: Project risk screening checklist of ESSF, IDCOL

Sl.

no

Env. and scl. risks rating criteria Response Remarks

Yes No

01

For new projects, does the project have any pending compliance such as

Location and Environmental Clearance based on its category (Red,

Orange-A, Orange-B and Green), from the DOE?

02

Is the project located in the immediate vicinity (likely to adverse impact) of

environmentally critical areas (national wetlands, wildlife habitats, important

bird areas, and protected areas)

03 Does the project construction and/or operation lead to environmental

impacts that are diverse, irreversible and/or unprecedented in nature?

04 Does the project require involuntary resettlement that results in loss of land

or livelihoods or physically displaces more than 200 persons?

05

Is the project site on or in immediate vicinity of socially vulnerable or

Indigenous People IP) owned or occupied land and has the potential to

cause an adverse impact on their culture and identity?

06 Is the project vulnerable to climate change related impacts?

07 Does the Borrower have a documented Policy on E&S Performance?

08

Does the Borrower have dedicated human resources to address E&S

performance?

09

Has the Borrower established and implemented Environmental, Health &

Safety Management Systems and Social Accountability Systems for the

Project SPV or in the parent company?

37

Annex 4: PPE arrangement for officer, worker and temporary worker

Photograph: First aid box arrangement Photograph: PPE arrangement (officer)

Photograph: PPE arrangement (worker)

Photograph: PPE arrangement ( temporary worker)

38

Annex 5: Fire-fighting arrangement

Photograph: Internal fire-fighting arrangement

Photograph: External fire-fighting arrangement Photograph: Three pumps for fire fighting

39

Annex 6: Fire-fighting training through in-house expert

Photographs: In house training on fire-fighting

40

Annex 7: Fire-drill by the Bangladesh Fire Service and Civil Defence

Photographs: Formal fire drill by Fire Service and Civil Defence

41

Annex 8: Application of signage

Photograph: Application of mask Photograph: Application of helmet

Photograph: Awareness on fire Photograph: Awareness on requirement of safety

42

Annex 9: Current status of project (external view)

Photograph: An external view of the Plant

Photograph: A view of RMS

Photograph: Transformer

43

Annex 10: Current status of project (internal view)

Photograph: Internal view of the Plant (control monitor)

Photographs: Internal view of the Plant (genset and control panel)

44

Annex 11: Housekeeping

Photographs: Status of internal housekeeping

Photographs: Status of external housekeeping

Photographs: Different types of waste bins

45

Annex 12: Arrangement of drainage facility

Photograph: A view of internal drainage

Photographs: A view of external drainage of which cover of one side is under construction

46

Annex 13: Land schedule

Amount of land in decimal

Dag no. Owner Father’s of owner SA RS

30.00 2204 370 Mohsin mia

Late. Mokbul Hossain

15.00 1807 377,378 Fozlul Haque Late Aziz Mollah 91.50 2202 373 Rokeya Begum

Khalilur Rahman

22.00 2205 369 Anwara Begum Khalilur Rahman 291.00 1805,2203 371,

373 Rokeya Begum

Late. Kafil Uddin

49.50 1803,2865 943, 944 Abul Hasem Late Sobje Ali

47

Annex 14: Crop Valuation Report for compensating share croppers

48

Annex 15: Compensation distribution evidence for share cropper

49

Annex 16: Compensation distribution evidence in case of transmission line

51

Annex 17: List of landowners as were compensated due to transmission line

Sl. No. Name Compensated

amount in BDT

01 Md. Mostofa Mia 3,25,000

02 Md. Fazlul Haque 90,000

03 Zaynal Abedin 1,25,000

04 Radha Kanta Dey 4,35,000

05 Rokeya Begum 4,00,000

06 Nasrin Sultana 2,70,000

07 Md. Razzak Mia 1,75,000

08 Md. Shawkat Hossain 4,75,000

09 Mosammat Ranu Begum 1,00,000

10 Abdur Razzak 3,45,000

11 Mosammat Lovely Begum 5,00,000

12 Abdul Sattar 1,75,000

13 Md. Aminul Haque 2,00,000

14 Anzumanara Begum 50,000

15 Abdus Sattar 1,00,000

16 Abdus Sattar 1,25,000

17 ShamimaYeasmin 3,50,000

18 Sharmin Begum 3,00,000

19 Md. Shamim Khondakar 5,00,000

20 Tahmina Akther 2,75,000

21 Md. Saiful Islam 75,000

22 Md. Moniruzzaman 1,05,000

23 Nirod Chandra Dey 2,47,000

24 Imran Ahmed 3,00,000

25 Md. Rafiqul Islam 11,65,000

52

Annex 18: List of female respondents during consultation

Name Husband Age Cell phone

Mosammat Farida Begum

Razu Mia 50 01733631495

Bahar zan Abdur Rahman 45 01720542584

Morium Begum Azhar Mia 45 -

Beauty Begum Jalal Uddin 42 01760605919

Mashuda Shahzaddi 38 -

Sumitra Dey Monoronjon Das 40 01726273481

Khaleda Begum Late. Ruhul Amin 50 -

53

Annex 19: List of male respondents during consultation

Name Father Age Cell phone

Mr. Md. Sharifullah Late. Abdul Motaleb 50 01816470599

Mr. Chaitnya barman Mr. Prafulla Chandra barman 45 01850263699 Mr. Nurul Islam Late Abdul Aziz 50 01913263558

Mr. Rinku Mr. Pran Krishna 35 01928961051

Mr. Abul Kalam Bhuiyan Hazi Abdul Bhuiyan 58 01716488299

Mr. Md Mostofa Late Mofiz Uddin Mia 53 - Mr. Akram Bhiyan Late Abdur Rahim 40 01745130363

Md. Zaman Mia Md. Abdur Rahman 35 01746251268

Mr. Md. Kamal Hossain Late. Abdus Salam 43 01924530761

Mr. Abu Hanif Late. Md. Kafil Uddin 40 01768743867

Mr. Lokman ahmed Late. Mokor Uddin 45 01731059695

Mr. sharif Hossain Late Siddiqur Rahman 42 01782137563

Mr. Md. Hiron Sarker Late Abdul Barek Sarker 55 01918301074

Jahangir alam Samir Uddin 45 01777938337

Shafiqul Alam Mr. Mannan Sarker 01727321339

Badal das Binod Chandra Das 40 019819152696

Md. Mostafa Late. Abdul Majid 70 01753708014

Md. Babul khandakar Late. Ramiz Uddin 42 01725166692

Md. Rahmatullah Late. Abdul Motaleb Mia 45 01731075094

Md. Tajul Islam Late. Abdul Haque 30 01922802493

Bayzid Belayet Fakir 30 01767678626

Monoronjon Das Late. Debendra Das 50 01726273481

Mowlana Ohiduzzaman Late. Nurul Islam 45 01916561973

Hazi Abdul Mannan Late. Riaz Uddin 50 01833287562

54

Annex 20: Consultation with male and female respondents

Photographs: Consultation with male respondents

Photographs: Consultation with female respondents

55

Annex 21: Consultation with male and female respondents (random approach)

Photographs: Consultation with male and female respondents

Annex 22: Grievance Redress Mechanism

Photographs: Arrangement of Grievance Log Book and Grievance Box

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