Employment Generation Program for the Poorest (EGPP)

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EENNVVIIRROONNMMEENNTTAALL MMAANNAAGGEEMMEENNTT FFRRAAMMEEWWOORRKK ((EEMMFF))

June 2010

Ministry of Food and Disaster Management (MoFDM) Government of the People’s Republic of Bangladesh

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TABLE OF CONTENTS TABLE OF CONTENTS .............................................................................................................. 2

LIST OF ABBREVIATIONS ...................................................................................................... 4

EXECUTIVE SUMMARY ........................................................................................................... 5

1.0 PROJECT BACKGROUND AND INTRODUCTION ................................................... 7

1.1 Background ...................................................................................................................... 7

1.2 About EMF ....................................................................................................................... 7

2.0 OBJECTIVES OF THE EMF ........................................................................................... 8

3.0 PROJECT DESCRIPTION ............................................................................................... 9

3.1 Project Development Objective ........................................................................................ 9

3.2 Project Components.......................................................................................................... 9

3.3 Project Areas .................................................................................................................. 14

3.4 Key Project Interventions as Emergency Employment Generation ............................... 14

4. 0 RELEVANT GOVERNMENT POLICIES, ACTS, RULES & STRATEGIES ......... 15

4.1 General Description .......................................................................................................... 15

4.2 Some Relevant Policies and Legislations ....................................................................... 15

4.2.1 Environment Conservation Act 1995 (ECA 1995) ................................................. 15

4.2.2 Environmental Conservation Rules 1997 ............................................................... 16

4.2.3 National Water Policy, 1999 ................................................................................... 17

4.2.4 National Safe Drinking Water Supply and Sanitation Policy 1998 ........................ 17

4.2.5 National Agricultural Policy, 1999 ......................................................................... 18

4.2.6 National Fisheries Policy, 1996 .............................................................................. 18

4.2.7 National Livestock Development Policy, 2007 ...................................................... 18

4.2.8 Others: Standing Orders on Disaster, 1999 ............................................................. 19

4.3 Implication of Policies and Legislations with the EGPP Activities ............................... 19

5.0 WORLD BANK’S ENVIRONMENTAL SAFEGUARDS POLICY ........................... 20

5.1 World Bank’s environmental and social/resettlement guidelines .................................. 20

5.2 World Bank Environmental Screening under OP 4.01 .................................................. 21

6.0 GENERAL PRINCIPLES FOR EMF IN EGPP ACTIVITIES .................................. 22

7.0 POTENTIAL ENVIRONMENTAL ISSUES IN EGPP ................................................. 23

7.1 Introduction ...................................................................................................................... 23

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7.2 Typical Environmental Impacts ....................................................................................... 23

7.3 Environmental Categorization .................................................................................... 25

8.0 ENVIRONMENTAL MANAGEMENT IN EGPP ....................................................... 26

8.1 Environmental Screening ................................................................................................. 26

8.2 Environmental Mitigation ................................................................................................ 26

8.3 Environmental Review and Approval.............................................................................. 26

8.4 Environmental Monitoring .............................................................................................. 27

9.0 INSTITUTIONAL ARRANGEMENT AND CAPACITY BUILDING ........................ 29

9.1 Environmental Screening ................................................................................................. 29

9.2 Capacity Building ............................................................................................................ 29

9.3 Grievance Redness System .............................................................................................. 30

ANNEX A: 100 Days EGP: Division Wise Project Data ......................................................... 31

ANNEX B: List of Negative Subproject Attributes ................................................................. 33

ANNEX C: Environmental Screening Format ......................................................................... 34

ANNEX D: Typical Environmental Management Plan .......................................................... 37

ANNEX E: Typical Environmental Mitigation Measures for Earthen Road and Embankment ..................................................................................................................... 38

ANNEX F: Sub-Project Specific Environmental Management Plan ..................................... 39

ANNEX G: Committee Structure .............................................................................................. 48

ANNEX H: Scope of Work of Environment Specialist under Independent Assessment/Third Party Monitoring .............................................................................. 50

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LIST OF ABBREVIATIONS

BDT - Bangladesh Taka (Currency) BP - Bank Procedures DC - Deputy Commissioner DOE - Department of Environment DPD - Deputy Project Director EA - Environmental Assessment ECA - Environmental Conservation Act ECC - Environmental Clearance Certificate ECR - Environmental Conservation Rules EGPP - Employment Generation program for the Poorest EIA - Environmental Impact Assessment EMF - Environment Management Framework FY - Fiscal Year GOB - Government of Bangladesh GRO - Grievance Redress Officer ICT - Information and Communication Technology IDA - International Development Agency IEE - Initial Environmental Examination MOFDM - Ministry of Food and Disaster Management MPC - Main Program Component NEMAP - National Environmental Management Action Plan NSDWSSP - National Safe Drinking Water Supply and Sanitation Policy OP - Operational Policies OPD - Office of the Project Director OSC - Operational Support Component PDO - Project Development Objective PIC - Project Implementation Committee PIO - Project Implementation Officer UNO - Upazila (Sub-district) Nirbahi (Executive) Officer UP - Union Parishad WB - World Bank

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EXECUTIVE SUMMARY The Employment Generation Program for the Poorest (EGPP) is the continuation of the government effort to address the poorest segment of people through creating seasonal employment. The Government of Bangladesh (GOB) launched in 2008 its largest public works program called the 100 Day Employment Program in response to the international food and fuel crisis. The program was intended to cushion the poor against the rise in food prices. The program was designed to run during the lean season in rural areas only. The GOB has requested the World Bank involvement as much for the financing it brings as the technical expertise it can garner to generate far-reaching reforms in the design and implementation of one of the country’s largest safety net programs. The Ministry of Food and Disaster Management (MOFDM) is implementing the program in partnership with local governments. The program to be supported by the World Bank is expected to reduce vulnerability to shocks for eligible Program participants by providing short-term employment on community projects while strengthening Program implementation capacity. MOFDM has prepared this Environmental Management Framework (EMF) to support the implementing partners of the programs to deal with potential environmental issues that may arise during implementation of the small scale subprojects. The purpose of the Environmental Management Framework (EMF) is to ensure that neither the emergency employment/livelihoods of the poor nor the environment are compromised through the project activities. It is to explore the possibilities of making the efforts to improve community driven emergency employment generation opportunities as well as conservation of the environment complimentary so that there are sustained benefits from the development activities initiated. The specific objectives of EMF are: to outline a framework for environmental screening procedures and methodologies for the subprojects to be financed under the project in accordance to the GOB and World Bank Safeguard policies/rules; and to specify appropriate roles and responsibilities to carryout environmental screening, monitoring and reporting related to subprojects. To avoid potentially adverse environmental impacts and enhance environmental outcomes of the activities implemented under individual subprojects, the World Bank Operational Policy on Environmental Assessment (OP 4.01) is triggered for this project. The project has been identified as Category ‘B’ since the sub-project specific environmental impacts cannot be precisely identified upfront before sites are selected and also these sub-project may have environmental impacts if not properly designed, executed and mitigation measures not implemented. IDA support is envisaged as investment lending to the Government of Bangladesh’s existing safety net program of the same name. Implemented by the Ministry of Food and Disaster Management, disbursements to the program will be made against a set of results which aim at improving accountability and transparency. The project development objective is to provide short-term employment on community projects to enable households to better cope with vulnerability, while strengthening Program implementation. The program is expected to create 200 million person days of employment over three years.. The project will support mainly the earthworks as emergency employment generation activities. These activities will help the agriculture productivity, better rural communication, protection during natural disaster etc. The subprojects include: i) canal excavating/re-excavating, ii) earth dam construction/re-construction, iii) rural road construction/re-construction, iii) drain construction/re-construction to address water logging, iv) land filling of community institutions like schools, graveyard, prayer ground etc., v) earthen shelter for animals to project against cyclone, vi) excavation of public ponds/fish firms, vii) organic fertilizer production for agriculture application, viii) further development (height increase) of market/helipad, and ix) water reservoirs construction for rainwater conservation/drinking water. The analysis of the 100 days program in 2008 revealed that earthen embankment and road rebuilding was the most common (80.64%) employment generation activities. The average subproject size was BDT 79,158 (around USD 1140). The MOFDM will follow a set of principles in implementing the Emergency Employment Generation Project to ensure environmental sustainability of the project. The major general principles are: i) the

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Project Director or his/her assigned official at the Office of the Project Director (OPD) will be overall responsible for environmental compliance in EGPP; ii) all the subprojects to be funded under the EGPP will be subject to an environmental screening in order to prevent execution of projects with significant negative environmental impacts; iii) the project will support mainly the earthen works which will not have any significant environmental impacts; iv) the Project will not support any activities which may have significant environmental impacts; and v) prior to selection of specific subprojects, the Union Parishad Project Implementation Committee (UP-PIC) will undertake community consultation regarding their objectives, scopes as well as environmental safeguard implications. Although most of the project impacts would be localized due to the relatively small scale activities, there are some issues of concern that cut across the range of proposed interventions. The common environmental impacts form the projects are loss of top soils, change in land use pattern, drainage congestion/water logging, erosion or siltation of embankment or road, losses of trees and vegetation, dust, noise and water pollution, impact on fish and aquatic habitat and occupational health & safety etc. The subprojects to be supported under EGPP includes different sector as per the project categorization of ECR’97. However, considering the average size (USD 1140) and nature of the project, no specific categorization in the line of ECR is proposed in the project. Again, although EGPP is identified as Category ‘B’ project as per OP/BP 4.01, the individual subprojects will be considered a Category ‘C’ project. As mentioned earlier, all the project will be subject to environmental screening and only the subprojects having no significant environmental impacts will be funded through EGPP. The responsibility of screening the subproject rests on the Union Parishad Project Implementation Committee (UP-PIC) during the selection of projects in consultation with community and ward members. The Upazilla Field Facilitator (hired on a contractual basis by the Project) will review the environmental screening, suggest mitigation measures (if required) and ensure no activities with significant negative impact will be implemented. A simple Environmental Management Plan (EMP) may be required in some of the cases. The Upazilla Project Implementation Committee (UPIC) will be responsible for providing necessary technical input to the UP-PIC and overall supervision and monitoring of the subprojects. As part of the monitoring of the sub-project implementation, the Project Implementation Officer (PIO) of each Upazila will monitor the environmental compliance issue. The PIO at Upazila level and the Deputy Director at Office of the Project Director (OPD) will maintain a database for sub-project specific environmental screening, and mitigation measures. The project M&E system will capture that information as well. In addition, the project’s independent assessment/third party evaluation (reputed local think-tank) will include a brief environmental audit to assess and evaluate the quality of environmental compliance of the subprojects.

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1.0 PROJECT BACKGROUND AND INTRODUCTION

1.1 Background

1. The Employment Generation Program for the Poorest (EGPP) is the continuation of the government effort to address the poorest segment of people through creating seasonal employment. The Government of Bangladesh (GOB) launched in 2008 its largest public works program called the 100 Day Employment Program in response to the international food and fuel crisis. The program was intended to cushion the poor against the rise in food prices. The program was designed to run during the lean season in rural areas only. The FY09 budget provided for 100 days of work for up to 2 million people with an initial allocation of approximately US $300 million. Close on the heels of the 100 Day Employment Program, the GoB launched the Employment Generation Program for the Poorest (EGPP). The EGPP is intended to run during two lean season cycles – for 60 days from September to November and for 40 days from March to April. In FY10, the GOB allocated approximately BDT 8 billion to the program. In the first cycle (September to November 2009), the program had spent over 90% of the BDT 1.775 billion allocated for the cycle and had created 16,555,325 person days of employment. The GOB has requested the World Bank involvement as much for the financing it brings as the technical expertise it can garner to generate far-reaching reforms in the design and implementation of one of the country’s largest safety net programs.

2. The Ministry of Food and Disaster Management (MOFDM) is implementing the program in partnership with local governments. The program to be supported by the World Bank is expected to reduce vulnerability to shocks for eligible Program participants by providing short-term employment on community projects while strengthening Program implementation capacity. MOFDM has prepared this Environmental Management Framework (EMF) to support the implementing partners of the programs to deal with potential environmental issues that may arise during implementation of the small scale subprojects.

1.2 About EMF

3. Projects and programs financed with IDA resources need to comply with the World Bank Operational Policies. Therefore, the project components eligible for funding under EGPP will be required to satisfy the World Bank's safeguard policies, in addition to conformity with environmental legislation of the Government of Bangladesh (GOB). The subprojects to be funded under the project will be identified at the field level during implementation phase. It is not possible to identify the subprojects specific environmental issues upfront during project design and appraisal stage. The EMF provides general policies, guidelines, and procedures to be integrated into the implementation of all sub-projects implemented by MoFDM under EGPP program. In preparing the document, relevant environment safeguard practices and compliance from theoretical and empirical sources such as GOB and WB were reviewed. The activity included field visits, different level consultations, qualitative and quantitative assessment towards understanding implementation processes of environmental safeguard compliance, capacity assessment of implementing agency and its field level staff from environmental safeguard perspective etc.

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2.0 OBJECTIVES OF THE EMF 4. The purpose of the Environmental Management Framework (EMF) is to ensure that neither the emergency employment/livelihoods of the poor nor the environment are compromised through the project activities. It is to explore the possibilities of making the efforts to improve community driven emergency employment generation opportunities as well as conservation of the environment complimentary so that there are sustained benefits from the development activities initiated. The Environmental Management Framework will contribute the goal of the poverty reduction by:

• enhance environmental outcomes of the activities implemented under individual subprojects;

• preventing and/or mitigating any negative environmental impact that may emerge from the sub-projects;

• ensuring the long-term sustainability of benefits from sub-projects by securing the natural resource base on which they are dependent; and

• facilitating pro-active sub-projects that can be expected to lead to increased efficiency and improved management in the use of natural resources resulting in improvements in local environmental quality and human well-being.

5. More specifically the objectives of the EMF are:

• To outline a framework for environmental screening procedures and methodologies for the subprojects to be financed under the project in accordance to the GOB and World Bank Safeguard policies/rules; and

• To specify appropriate roles and responsibilities to carryout environmental screening, monitoring and reporting related to subprojects.

This will also cover institutional/organizational needs of the implementing agency in executing the recommendations to mitigate any possible environmental negative impacts.

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3.0 PROJECT DESCRIPTION

6. The Employment Generation program for the Poorest (EGPP) provides short-term employment to manual workers during the lean season over two cycles that add up to 100 days in a year. The first cycle runs from September to November providing 60 days of employment and the second cycle runs from March to April providing 40 days of employment. Wages are set below the prevailing market wage for unskilled workers and this contributes to self-selection of the poorest households into the program. Bank support will be to the GOB’s existing program, where IDA will reimburse no more than 70 percent of wage costs. 7. The Project is envisaged as a results-based investment lending support to the Government of Bangladesh’s existing safety net program of the same name. Implemented by the Ministry of Food and Disaster Management, disbursements to the program will be made against a set of results which aim at improving accountability and transparency. 3.1 Project Development Objective 8. The project development objective is to provide short-term employment on community projects to enable households to better cope with vulnerability, while strengthening Program implementation.

9. The PDO will be pursued by 1) ensuring that the program benefits go to the poorest areas and households 2) improving governance through better transparency and accountability and 3) improving capacity for monitoring and evaluation. 3.2 Project Components 10. Two Components are proposed for the project – a Main Program Component (MPC) would support expansion of and reforms to the existing program. The Operational Support Component (OSC) would provide direct support to the MOFDM for implementation support and capacity strengthening based on the needs. I. Main Program Component:

The Main Program Component (MPC) has three Focus Areas.

Focus Area 1: Rigorous Targeting Prior to the implementation of the EGPP and its precursor program there were clear mismatches between the spatial distribution of poverty and program coverage. Data from HIES 2005 showed that the three poorest divisions (Khulna, Rajshahi and Barisal) had lower coverage of safety nets programs than two of the better off divisions (Dhaka and Sylhet). An independent assessment of the precursor to the EGPP found that while 67 percent of the overall program benefits went to the poor, just above 37 percent of the resources reached the extreme poor (FAO-BRAC 2008). Reaching the poorest is the cornerstone of the EGPP. This includes both the poorest areas and the poorest households. There is a three-fold targeting methodology in the program:

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• Geographical or area based targeting based on the poverty map, where the bulk of the resources go to the poorest upazilas.

• Household targeting: o Filter 1: The first filter that will ensure the participation of the poorest is the

setting of wages. The current wage of Tk. 120 per day is below the prevailing market wage in most areas, ensuring that only the poorest enrol for the program. The program will ensure that wages are set below the prevailing market wage so that the program is not attractive to the non-poor households.

o Filter 2: The second filter is a proxy for household poverty – individuals from those households where the head is a manual laborer and the household has less than ½ acre of land will be eligible;

In the poorest areas, it is likely that there may be a larger turnout of potential beneficiaries than there is budget allocation or capacity to implement. Guidelines to deal with such over-subscription will emphasize the importance of equity, participatory and transparent selection of beneficiaries and publicizing the results of the selection. On the other hand, in richer areas or areas where alternative employment is available, there may be lower turnout. These trends will also inform the allocations in successive phases.

• Gender targeting where 33 percent of the beneficiaries are intended to be women during the course of the project period.

Focus Area 2: Improved governance through clearer rules and enhanced transparency Focus Area 2 proposes a set of results that enhance clarity of rules and transparency of implementation. Clarity and accessibility of rules and procedures: Program rules are currently quite generic and many field level functionaries are unaware of many changes that were made to the rules and procedures. Rules seldom percolate down the chain to the Union Parishad and hardly ever reach the PIC. The project therefore proposes a set of results (see Annex 3) that require changes to the program document and for the revised rules and procedures to be publicly available all the way down the chain.

Information and public disclosure: Currently, communities have limited knowledge of the structure and functioning of the program. Evidence from across the world and from the Sirajganj pilot project in Bangladesh indicates that community level notice boards, displaying regularly updated, reliable and correct information, enhance community confidence and participation. Community notice boards will be mandated under the project. PICs and Union Committees would also be required to make selection criteria and beneficiary lists publicly available. Adherence to this provision would be monitored through independent third party validations and process assessments conducted under Focus Area 3 of the project.

Provision of non-wage costs: Typically, public works programs in Bangladesh do not have a provision for non-wage costs and the EGPP is no exception. Providing for costs associated with

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the purchase of materials, hardware or skilled labor is central to the quality of infrastructure and governance of the program. Lack of such provision could have several negative impacts. First, it restricts the type of projects to mud-based or “earth” works. Second, if communities are expected to contribute non-wage costs, it affects poorer communities disproportionately. Finally, lack of provision for non-wage costs can create incentives for irregularities, especially when combined with strict monitoring (pressure to deliver the program). In such cases, more “enterprising” PICs may divert wage costs to material costs through the use of ‘ghost workers’. During the project period, guidelines will be issued to earmark up to 20 percent of the cost of each EGPP subproject to purchase materials and skilled labor. This is in keeping with global practice. For most infrastructure projects at least 10 percent of the cost would be mandated for materials and other non-wage costs. Disbursement projections have assumed an average of 20 percent for non-wage costs. While IDA will reimburse only wage costs, the inclusion of non-wage costs in the GOB’s program will be an important innovation, which will be linked to disbursement.

Better system for payment of wages: Another major innovation to be introduced to the program through IDA support concerns the way wages are paid. Currently EGPP workers are paid by the PIC in cash transactions on a weekly basis. This violates the important principle that resource management and payment processing should be kept separate. The lack of separation accounts partially for the aforementioned irregularities. Furthermore, the recordkeeping systems are dated, processing is done manually, and monitoring is weak. This leaves considerable exposure to misappropriation, payment mismanagement, and abuse in individual payment cases (delays, bribes, collusion, etc.). If administration and payments were separated, if parties other than the PIC made payments directly to the workers, and if all such transactions were adequately automated, it would significantly reduce fiduciary risk and empower the poorest. New robust payment systems therefore need to be introduced and innovations in cash delivery piloted where necessary. In fact, several programs in Bangladesh already pay cash benefits through formal financial channels. Annex 4 details the options that were considered in the reform of payment systems. Given the constraints under which the poorest citizens are served, IDA support to the EGPP envisages that direct payments to workers using formal channels will be introduced and this result will be linked to disbursement. It is proposed that during an initial phase, following all the required preparations, a minimum of 80 percent of those participating unions that have banks located within them will receive payments through banking channels, which will grow to 85 percent in the second year. By the final year of IDA support to the program, it is expected that 95 percent of those UPs which have banks located within them will be paying out wages through banks or other formal financial channels. Importantly, the project will support development of comprehensive manual covering operations of the bank payments program. Delivery of such a manual will be an important indicator for disbursement of IDA funds for payment of wages. Furthermore, where access to the formal financial mechanisms remains significant challenge (e.g., remote rural areas), and with a view to further the progress of expansion of coverage of the new payment systems, IDA will support a pilot to adapt some innovative payment solutions to the operational needs of the program. The pilots will cover a minimum of three upazilas and will be subject to a rigorous evaluation to fine-tune the proposed solutions, bring awareness about good practices, and promote standards in benefit delivery.

Enhanced capacity at the field level for better supervision: IDA support to EGPP is fundamentally about strengthening systems of monitoring and implementation. The

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Government’s current capacity is very limited and this creates a potential for malpractice. IDA support to the EGPP therefore provides for field level supervisors in the poorest 334 upazilas. Moreover, upazila level PIOs and the new field level supervisors will be provided with transport in the form of a motorcycle in each of the poorest 334 upazilas. The financing for staff and transportation costs of these supervisors will be done under the Operational Support Component of the project. In addition, while this is not a disbursement indicator, there is a provision for training field supervisors and PIOs. Finally, it is anticipated that the new payment systems will considerably improve the quality of record-keeping, and thus comprehensively strengthen program monitoring at the field level. For example, by allowing for better directed audits.

Grievance redress: The project will also support the development of an enhanced grievance redress system. The first point where complaints will be accepted is proposed to be the upazila. This is the level of the project closest to the community that is not directly involved in beneficiary selection or wage payments, two common sources of grievances. However, complaints can be accepted at any of the three levels - Upazila, district or the Ministry. At the upazila level, the Upazila Nirbahi Officer (UNO) will be the Grievance Redress Officer (GRO). At the district level, the Deputy Commissioner (DC) will serve as the GRO. The Deputy Project Director (DPD) in the office of the Project Director will act as the GRO at the central level. A feedback loop that includes informing the complainant about the action taken on their complaints, and feeding this information into the implementation of the program, will be a key aspect of the grievance redress system. Focus Area 3: Better Capacity for Monitoring and Evaluation The program would support the development of a set of standardized summary indicators and monitoring reports and would provide financing for critical staffing at the central and local levels and investments to introduce a digitized MIS. The details on the proposed investments in this area are provided below. Streamlined data collection and flow: IDA will support the redesign of existing monitoring forms and reports to facilitate monitoring of inputs, outputs, intermediate outcomes and compliance with program guidelines. Data on a set of streamlined indicators will be collected at the sub-project level. In order to ensure that the data collected is available for real-time decision-making, a number of institutional and technical enhancements will be made under focus area three of the program. The program will provide for MIS (in the form of hardware, software, and data entry clerks) at the upazila or district level, as well as connectivity that will allow information to be transferred electronically from the local level directly to the center. The monitoring cell in the Project Director’s Office will receive additional support and training. Resources that will allow greater supervision at the sub-project level will also be provided. Providing contract staff and access to transport for PIOs and Tag Officers will further strengthen Monitoring of program implementation at the upazila level (as discussed in Focus Area 2 above). External Validation: Independent validation of the program implementation would be conducted in a random sample of approximately three percent of union parishads each program phase by a firm contracted by the World Bank and financed by trust funds. The independent third party validations would examine whether program implementation guidelines are followed and whether program benefits reach the intended beneficiaries.

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Impact evaluation: The World Bank would partner with a reputable local survey firm to undertake baseline and follow-up surveys of program participants and non-participants in a representative sample of upazilas. This will be funded by the Trust Fund on Environmentally and Socially Sustainable Development, which has been approved. The survey data will be used to examine program targeting and the determinants of program participation, including whether women or individuals from households in the lowest income quintiles are (i) more likely to receive job cards; and (ii) more likely to work under the program. The individual, household, and community characteristics (e.g., literacy, other wage-earning opportunities, shocks suffered, and distance from the nearest worksite) that influence both the ability to access job cards under the program and the days worked by beneficiaries in the EGPP will also be examined. Program impacts to be examined at the household level include: net household incomes (measured relative to the household’s prior year income or relative to otherwise similar non-participant households); responses to lean season vulnerability, including the use of coping strategies such as borrowing, migration, or reductions in the number and quality of meals eaten per day; changes in household assets, especially in relation to possible distress sales, and impacts of the program on human capital through children’s school enrolment and household health spending. The survey data will be merged with administrative data detailing the extent and types of workfare activities in the upazilas where households were surveyed. Program targeting performance, new payment system efficiency, and the net income gains to participating households will be identified. Qualitative assessments: To complement the quantitative work, beneficiary and non-beneficiary assessments will be conducted. This work would examine how well the program is working, including perceptions of targeting, of leakages/corruption, the quality of works produced under the EGPP, the value of the community sub-projects (both to participants and to non-participants), and impacts of the program on internal and external migration as well as on social empowerment.

II. Operational Support Component (OSC)

Overall objective: Provide operational support to the Disaster Management and Relief Division, Ministry of Food and Disaster Management in delivering EGPP with enhanced efficiency in terms of better targeting, better benefit delivery mechanism, greater transparency and improved monitoring.

Specific objectives:

i) Strengthen reporting and monitoring of the EGPP operations ii) Provide training to staff engaged in the EGPP to enhance their capacity for targeting

beneficiaries and delivering benefits Expected outputs:

• Services of financial management and procurement personnel availed.

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• Services of Field Supervisors are availed. • Digitalized reporting, monitoring and supervision system is established. • Transport facility for the Field Supervisors provided. • Systematic targeting methodology is established. • Training is provided for beneficiary targeting and enrolment process. • The Ministry’s overall capacity to deliver quality social protection projects is improved.

3.3 Project Areas

27. In terms of coverage, EGPP will be implemented nation-wide targeting the poorest upazilas (sub-districts) of Bangladesh. Currently, the following allocation system is in place: i) 40% of the budget to upazilas with extreme poverty rates of 35% and higher; ii) 40% of the budget to upazilas with extreme poverty rates of 21-34%, and iii) 20% of the budget to upazilas with extreme poverty rates of 20% and below. The exact locations of the sub-project will be identified by the Union Parishad Project Implementation Committee (UP-PIC) during the selection of projects in consultation with community and ward members during EGPP implementation.

3.4 Key Project Interventions as Emergency Employment Generation

28. The project will support mainly the earthworks as emergency employment generation activities. These activities will help the agriculture productivity, better rural communication, protection during natural disaster etc. The subprojects include: i) canal excavating/re-excavating, ii) earth dam construction/re-construction, iii) rural road construction/re-construction, iii) drain construction/re-construction to address water logging, iv) land filling of community institutions like schools, graveyard, prayer ground etc., v) earthen shelter for animals to project against cyclone, vi) excavation of public ponds/fish firms, vii) organic fertilizer production for agriculture application, viii) further development (height increase) of market/helipad, and ix) water reservoirs construction for rainwater conservation/drinking water. 29. The analysis of the 100 days program in 2008 is presented in Annex-A. It revealed that earthen embankment and road rebuilding was the most common (80.64%) employment generation activities. The average subproject size was BDT 79,158 (around USD 1140).

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4. 0 RELEVANT GOVERNMENT POLICIES, ACTS, RULES & STRATEGIES

4.1 General Description

30. A wide range of laws and regulations related to environmental issues are in place in Bangladesh. Many of these are cross-sectoral and only partially related to environmental issues. The most important of these are the Environment Conservation Act, 1995 (ECA, 1995), and the Environment Conservation Rules (ECR, 1997). The ECA 1995 is primarily an instrument for establishing the Department of Environment (DOE), and for controlling industrial and project related pollution. The Act also defines in general terms that if any particular activity is causing damage to the eco-system, the person responsible will have to apply corrective measures. Until the appearance of ECR, 1997, enforcement of the Act was not possible, as many of the clauses refer to specifications spelled out in the Rules. ECA and ECR were further amended to address the growing environmental challenges. 31. In addition to the Environmental Conservation Act and Rules, there are numbers of other policies, plans and strategies which deal with the water sector, agricultural development, coastal area, disaster management and climate change. These are National Water Policy, 1999; Forest Act 1927 (modified up to 30th April 2000); National Forest Policy, 1994; National Conservation Strategy; National Environmental Management Action Plan (NEMAP); Costal Zone Policy, 2005; Costal Development Strategy, 2006; National Agricultural Policy, 1999; National Fisheries Policy, 1996; National Livestock Development Policy, 2007; Standing Orders on Disaster, 1999; Climate Change Strategy and Action Plan, 2009; National Plan for Disaster Management, 2008-2015. Some of these policies and legislations are described in this chapter for reference.

4.2 Some Relevant Policies and Legislations

4.2.1 Environment Conservation Act 1995 (ECA 1995) 32. The national environmental legislation known as Environmental Conservation Act, 1995 (ECA'95) is currently the main legislative document relating to environmental protection in Bangladesh, which replaced the earlier environment pollution control ordinance of 1992 and has been promulgated in Environmental Conservation Rules, 1997 (ECR'97). The main objectives of ECA’95 are: i) conservation of the natural environment and improvement of environmental standards; and ii) control and mitigation of environmental pollution.

33. The main strategies of the act can be summarized as:

Declaration of ecologically critical areas, and restriction on the operation and process,

which can be continued or cannot be initiated in the ecologically critical areas. Regulation in respect of vehicles emitting smoke harmful for the environment. Environmental clearance. Remedial measures for injury to ecosystem Regulation of the projects and other development activities - discharge permit. Promulgation of standards for quality of air, water, noise and soil for different areas for

different purposes. Promulgation of standard limit for discharging and emitting waste.

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Formulation and declaration of environmental guidelines. 34. The Act is being implemented by Department of Environment (DOE). DOE is under the Ministry of Environment and Forest and is headed by a Director General (DG). The DG has complete control over the DOE. The power of DG, as given in the Act, may be outlined as follows: - The DG has the power to close down the activities considered harmful to human life or the

environment. The operator does have the right to appeal and procedures are in place for this. However, if the incident is considered an emergency, there is no opportunity for appeal.

- The DG has the power to declare an area affected by pollution as an ecologically critical area. The type of work or process which can take place in such an area is governed by DOE.

- Before going for any new development project, the project proponent must have to take Environmental Clearance from DOE. The procedures to take such clearance are in place.

- Failure to comply with any part of ECA'95 may result in punishment by a maximum of 10 years imprisonment or a maximum fine of BDT. 1000,000 or both.

4.2.2 Environmental Conservation Rules 1997 35. A set of the relevant rules to implement the ECA’ 95 has been promulgated (August, 1997). The rules mainly consist of:

categorizations of the industries and projects, procedure to take environmental clearance, ambient standards in relation to water pollution, air pollution and noise, as well as

permitted discharge/emission levels of water and air pollutants and noise by projects. 36. The Rules incorporate "inclusion lists" of projects requiring varying degrees of environmental investigation. The Government is also empowered to specify which of the operations or processes shall be carried out or shall not be initiated in the ecologically critical area. Under this mandate, MOEF has declared Sunderban, Cox's Bazar-Tekhnaf Sea Shore, Saint Martin Island, Sonadia Island, Hakaluki Haor, Yanguar Haor, Marzat Baor and Gulshan-Baridhara Lake as ecologically critical areas and prohibited certain activities in those areas. 37. ECR'97 (Rule 7) classifies industrial units and projects into four categories depending on environmental impact and location for the purpose of issuance of Environmental Clearance Certificate (ECC). These categories are: Green Orange A Orange B, and Red 38. Green List projects are considered relatively pollution-free. Orange List projects fall into two categories. Orange A projects are required to submit general information, a feasibility report, a process flow diagram and schematic diagrams of waste treatment facilities along with their application for obtaining DOE environmental clearance. Orange B projects are required to submit an Initial Environmental Examination (IEE) report, along with their application and the information and papers specified for Orange B projects. Red List projects are those which may cause ‘significant adverse’ environmental impacts and are, therefore, required to submit an EIA

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report. It should be noted that they may obtain an initial site clearance on the basis of an IEE report, and subsequently submit an EIA report for obtaining environmental clearance along with other necessary papers, like the feasibility study report, no objection from local authority. 39. As per ECR ’97 all existing and new industries and projects in Orange B and Red category require an Environmental Management Plan (EMP) (after IEE or EIA) to be prepared and submitted along with necessary other papers while applying for environmental clearance. 40. Environmental standards in operation in Bangladesh also promulgated under the Environment Conservation Rules 1997. There are standards prescribed for varying water sources, ambient air, noise, odor, industrial effluent and emission discharges, vehicular emission etc. 4.2.3 National Water Policy, 1999 41. The National Water Policy promulgated in 1999 with the intension of guiding both public and private actions in the future for ensuring optimal development and management of water that benefit both individuals and the society at large. The policy aims to ensure progress towards fulfilling national goals of economic developments, poverty alleviation, food security, public health and safety, decent standard of living for the people and protection of natural environment. According to the policy, all agencies and departments entrusted with water resource management responsibilities (regulation, planning, construction, operation, and maintenance) will have to enhance environmental amenities and ensure that environmental resources are protected and restored in executing their tasks. Environmental needs and objectives will be treated equally with the resources management needs. The policy has several clauses related to the protection and conservation of the natural environment for ensuring sustainable development. 4.2.4 National Safe Drinking Water Supply and Sanitation Policy 1998 42. National Safe Drinking Water Supply and Sanitation Policy (NSDWSSP, 1998) was drafted in 1998, and sets out the basic framework for the improvement of public health quality and to ensure improved environment, together with a set of broad sectoral action guidelines. The draft policy offered various objectives to achieve the goal and these are:

To manage water supply and sanitation related basic needs for all. To bring the positive change of peoples attitude, regarding water and sanitation. To reduce the outbreak of water borne diseases. To increase the efficiency of the Local Government and associated community for

handling more effectively the problems related to water supply and sanitation. To improve sustainable water supply and sanitation system. To ascertain proper conservation, management and use of surface water and to control

water pollution due to the scarcity of underground water. To take necessary steps to use and conserve rain water.

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4.2.5 National Agricultural Policy, 1999 43. The overall objective of the National Agriculture Policy is to make the nation self-sufficient in food through increasing production of all crops including cereals and ensure a dependable food security system for all. One of the specific objectives of National Agricultural Policy is to take necessary steps to ensure environmental protection as well as 'environment -friendly sustainable agriculture' through increased use of organic manure and strengthening of the integrated pest management program. The policy also suggests creating awareness so that the chemical fertilizers and pesticides used for increased crop production do not turn out to be responsible for environmental pollution. Water logging and salinity are identified as one of the serious problem in some parts of the country including the coastal areas for agricultural activities and environmental damage. The policy recommends for crop diversification and salt tolerant crop varieties. Irrigation from surface water will get priority and appropriate infrastructure will be built for capturing surface water from khals, beels and small rivers considering the water bodies as fish production systems.

4.2.6 National Fisheries Policy, 1996 44. The National Fisheries Policy, 1996 recognizes that fish production has declined due to environmental imbalances, adverse environmental impact and improper implementation of fish culture and management programs. The policy suggests following actions: To conserve fish habitats from damage, appropriate care should be taken during the

implementation of all development activities such as flood control, irrigation and drainage projects, agriculture, industries, road and development projects.

Shrimp and fish culture will not be expanded to the areas which damage mangrove forest in the coastal region

Biodiversity will be maintained in all natural water bodies and in marine environment. Chemicals harmful to the environment will not be used in fish and shrimp farms

Breeding ground of fish and fresh water giant prawn will be conserved Environment friendly shrimp culture technology will be used Control measures will be taken against activities that have a negative impact on fisheries,

resources and vice-versa Laws will be formulated to ban the disposal of any untreated industrial effluents into the

water bodies. 4.2.7 National Livestock Development Policy, 2007 45. The National Livestock Development Policy has been prepared to address the key challenges and opportunity for a comprehensive sustainable development of the Livestock sub-sector through creating an enabling policy framework. The policy recognizes that there are no guidelines for environmental protection and bio-security when establishing poultry farms. The use of antibiotics in feeds is thought to be common and a cause of public health concern. The policy recommends for developing and enforcing specific guidelines for establishing environment-friendly commercial poultry farms.

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4.2.8 Others: Standing Orders on Disaster, 1999 46. The 'Standing Orders on Disaster' is designed to enhance capacity at all tiers of government administrative and social structures for coping with and recovering from disasters. The document contains guidelines for construction, management, maintenance and use of cyclone shelter. Accordingly to the guideline, geographical information system (GIS) technology will be applied at the planning stage to select the location of cyclone shelter considering habitation, communication facilities, distance from the nearest cyclone centre etc. The advice of the concerned District Committee is to be obtained before final decision. The cyclone shelters should have easier communication facilities so that in times of distress delay does not occur to go there. For this reason, the road communication from the cyclone shelters should not only link up with city or main road but also with neighboring village areas. Provision of emergency water, food, sanitation and shelter space for livestock during period should also be kept in view for future construction of shelters.

4.3 Implication of Policies and Legislations with the EGPP Activities

47. The relevant policy and legislation documents underscored the importance of environmental consideration in the project planning and implementation to promote sustainable development. These provide the general guidelines to integrate environmental issues with different sector projects and programs. The ECR’97 (with amendments later on) is the main legislation in Bangladesh. ECR’97 defined different sectors (industries and projects) as ‘Green’, ‘Orange-A’, ‘Orange-B’ and ‘Red’ categories, without considering the extent and types of interventions. For example, construction/reconstruction/expansion of flood control embankment, polders, dikes etc. are classified as the ‘Red’ category project. However, it does not explicitly mention about the environmental category for earthen embankments/polders, small-scale repairing or rehabilitation projects having minor environmental impacts. Again, environmental clearance is mandatory for projects (3 years for Green category and 1 year for other categories). Considering the numbers (37,000) of small scale subprojects, the EGPP requires a flexible approach on environmental categorization and clearance.

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5.0 WORLD BANK’S ENVIRONMENTAL SAFEGUARDS POLICY

5.1 World Bank’s environmental and social/resettlement guidelines

48. The Bank requires environmental assessment (EA) of projects proposed for Bank financing to help ensure that they are environmentally sound and sustainable, and thus to improve decision making. The World Bank's environmental assessment policy and recommended processing are described in Operational Policy (OP)/Bank Procedure (BP) 4.01: Environmental Assessment. This policy is considered to be the umbrella policy for the Bank's environmental "safeguard policies" which among others include: Natural Habitats (OP 4.04), Forests (OP 4.36), Pest Management (OP 4.09), Physical Cultural Resources (OP 4.11)), and Safety of Dams (OP 4.37). Operational Policies (OP) is the statement of policy objectives and operational principles including the roles and obligations of the Borrower and the Bank, where as Bank Procedures (BP) are the mandatory procedures to be followed by the Borrower and the Bank. OP/BP 4.01 issued in January 1999, is the central document that defines the Bank’s environmental assessment requirements. Following are the WB’s environmental policy guidelines:

OP 4.01 Environmental Assessment OP 4.04 Conservation of Natural Habitats OP 4.09 Pest Management OP 4.36 Forestry OP 4.37 Safety of Dams

49. The most relevant policy of WB in EGPP activities is OP 4.01 Environmental Assessment. Environmental Assessment is used in the World Bank to identify, avoid, and mitigate the potential negative environmental impacts associated with Bank lending operations. In World Bank operations, the purpose of Environmental Assessment is to improve decision making, to ensure that project options under consideration are sound and sustainable, and that potentially affected people have been properly consulted. 50. The Bank requires environmental assessment (EA) of projects proposed for Bank support to ensure that they are environmentally sound and sustainable, and thus to improve decision making. EA is a process whose breadth, depth, and type of analysis depend on the nature, scale, and potential environmental impact of the proposed project. EA evaluates a project's potential environmental risks and impacts in its area of influence; examines project alternatives; identifies ways of improving project selection, siting, planning, design, and implementation by preventing, minimizing, mitigating, or compensating for adverse environmental impacts and enhancing positive impacts; and includes the process of mitigating and managing adverse environmental impacts throughout project implementation. EA takes into account the natural environment (air, water and land); human health and safety; social aspects (involuntary resettlement, indigenous peoples and physical cultural resources); and transboundary and global environmental aspects. The borrower is responsible for carrying out the EA and the Bank advises the borrower on the Bank’s EA requirements.

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5.2 World Bank Environmental Screening under OP 4.01

51. All World Bank projects are classified into three environmental assessment categories as shown in the following Table 1. Table 1: World Bank Environmental Screening Category Category ‘A’ Category ‘B’ Category ‘C’ Description The project is

likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented. These impacts may affect an area broader than the sites or facilities subject to physical works

The project has potential adverse environmental impacts on human populations or environmentally important areas—including wetlands, forests, grasslands, and other natural habitats—are less adverse than those of Category ‘A’ projects. These impacts are site-specific; few if any of them are irreversible; and in most cases mitigation measures can be designed more readily than for Category ‘A’ projects.

The project is likely to have minimal or no adverse environmental impacts

EA Requirements

For a Category ‘A’ project, the project sponsor is responsible for preparing a report, normally an EIA

EA is narrower than that of Category ‘A’ EA. Like Category ‘A’ EA, it examines the project's potential negative and positive environmental impacts and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance.

Beyond screening, no further EA action is required for a Category ‘C’ project

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6.0 GENERAL PRINCIPLES FOR EMF IN EGPP ACTIVITIES 52. As stated earlier, at the preparation stage of EGPP, the specific subprojects are not identified. Consequently, specific information on types of subprojects, site/location of the sub-projects, land requirements, local communities, geo-physical land features and nature is not available. Therefore, exact details and intensity of environmental impacts and their effective mitigation cannot be determined during project preparation. This EMF is thus prepared to establish the mechanism to determine and assess future potential environmental impacts of subprojects that are to be identified and cleared based on a community demand driven process, and to set out mitigation, monitoring and institutional measures to be taken during implementation and operation of the sub-projects to eliminate adverse environmental impacts, offset them, or to reduce them to acceptable limit. This section therefore, describes the general principles of Environmental management in EGPP. 53. The MOFDM will follow a set of principles in implementing the Emergency Employment Generation Project to ensure environmental sustainability of the project. In the view of EMF objectives and assessment of the nature, the planning and implementation of the project activities will be based on the following principles, most of which are incorporated in the project design and implementation arrangements. A set of negative list of sub-projects/activities that will not be financed under the project is presented in Annex-B. General principles

• The Project Director or his/her assigned official at the Office of the Project Director (OPD) will be overall responsible for environmental compliance in EGPP.

• All the subprojects to be funded under the EGPP will be subject to an environmental screening in order to prevent execution of projects with significant negative environmental impacts.

• The project will support mainly the earthen works which will not have any significant environmental impacts.

• The Project will not support any activities which may have significant environmental impacts.

• Prior to selection of specific subprojects, the Union Parishad Project Implementation Committee (UP-PIC) will undertake community consultation regarding their objectives, scopes as well as environmental safeguard implications.

• The OPD will ensure that the related government rules (laws, ordinance, acts, etc.) and World Bank Operational Policies and guidelines related to environment are being followed in subprojects selection and implementation. The EMF would serve as the basis for ensuring the compliance.

• The Project Implementation Officer (PIO) of every upazila will be responsible for obtaining and ensuring clearance required from local government agencies as necessary.

• No projects activities will be carried out in disputed lands or lands restricted for development or Environmentally Sensitive areas.

• Climate resilient and flood proofing considerations will be integrated in designing relevant subprojects.

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7.0 POTENTIAL ENVIRONMENTAL ISSUES IN EGPP

7.1 Introduction

54. This section deals with the main potential environmental concerns likely to arise from the various subprojects interventions proposed under the EGPP. Though the project is designed to support the employment generation of the poorest people through small scale interventions, its implementation must be designed to be environmentally sensitive so as to avoid any undesirable consequences of the given interventions. 55. Although most of the project impacts would be localized due to the relatively small scale activities, there are some issues of concern that cut across the range of proposed interventions. Field studies and lessons from similar programs show that issues such as community involvement, community ownership and selection of appropriate sites are some of the key concerns that influence project success and sustainability. Some of the typical environmental impacts from the proposed subprojects especially earthen embankment and road construction/rehabilitation and site development are described in the next section.

7.2 Typical Environmental Impacts

7.2.1 Loss of Top Soil of Agricultural Land

56. The most of the project activities are related to the earthen works. This requires huge of soil materials. The practice of soil collection from the top soil layer of agricultural land deprives the land from fertile ingredients, which reduce the agricultural production. Such impact can be avoided by collection of soil from barren land or stockpile top soil and replace it later on. Soil can also be collected from existing borrow pits/ponds nearby, which will help increased fish production from those areas. 7.2.2 Change in Land Use and Loss of Agricultural Land

57. Construction of new alignment may change the topography of the project area. Agricultural land may gradually be converted to non-agricultural uses. Improving the rural embankments or roads by widening/or increasing height will cause embankment/road-side agricultural land loss. While it is not possible to avoid the agricultural lands, the mitigation measure is to provide steep slopes for the embankment/road by applying improved soil stabilization means to minimize the land loss. Among others grass turfing or vetiver grass plantation could be effective means in minimizing erosion. 7.2.3 Drainage Congestion/Water Logging

58. The construction of rural road and earthen dam/embankment may interfere with cross drainage and can cause flooding or drainage congestion in adjacent areas during period of high rainfall. This may affect commercial activities in the market and cause potential risk to community health, crop damage and in extreme cases long-term loss of agricultural lands. These things should be properly addressed and taken in consideration during design phase of the project.

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7.2.4 Erosion and Siltation 59. In general, the constriction of waterways by embankment and roads increases velocity of flow to cause erosion during floods and subsequent siltation in the downstream. Improper drainage may cause erosion of embankment and road surface and side slope during rainy season exerting adverse impact on adjacent lands. These things should be properly addressed and taken in consideration during design phase of the project. 7.2.5 Losses of Trees and Vegetation 60. Roads and embankment construction and widening or other development works may require removal of trees and other vegetation growing along the roads and earlier embankment. While some trees may need to be removed because they are in the path of widening activities or because they pose safety hazards, there are many which could be saved through the cutting back of branches. The road and embankment-sides may be used for plantation of similar species, which will compensate the losses trees and vegetation. 7.2.6 Dust and Noise Pollution 61. Dust pollution occurs due to handling of soils during construction and mainly from lack of watering of earth surface. Such pollution is also a function of weather condition - in dry season nuisance is more; during rainy season, dust nuisance subsides. Dust is of more consequences during pre-construction / construction stages. Noise pollution is normally due to some construction related works. 7.2.7 Water Pollution 62. Although the project interventions do not expect any major waste generation, improper disposal of solid and liquid wastes from the people working in the sites may pollute the nearby water bodies. In addition, if the rainwater reservoir is constructed for drinking purpose, proper care including disinfection is required to ensure the water quality. 7.2.8 Fish and Aquatic Habitat 63. Embankment or road construction may encroach on wetlands, which can alter the ecology or wetlands/swamplands and cause destruction of aquatic habitat. The construction of embankments has important consequences on flood plain ecology. Embankments prevent longitudinal and lateral migration of fishes in the flood plain and obstruct movement of fishes onto natural feeding and breeding grounds in flood plains. 7.2.9 Occupational Health and Safety 64. Since the project activities does not include any large construction and risky activities, it is expected that no major occupational health & safety issues. However, attention should be provided on communicable diseases among workers and illness due to water pollution. First Aid facilities recommended to address any minor accidents during project works.

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7.3 Environmental Categorization

65. The subprojects to be supported under EGPP includes different sector as per the project categorization of ECR’97. However, considering the average size (USD 1140) and nature of the project, no specific categorization in the line of ECR is proposed in the project. Again, although EGPP is identified as Category ‘B’ project as per OP/BP 4.01, the individual subprojects will be considered a Category ‘C’ project. As mentioned earlier, all the project will be subject to environmental screening and only the subprojects having no significant environmental impacts will be funded through EGPP.

8.0 ENVIRONMENTAL MANAGEMENT IN EGPP

8.1 Environmental Screening

66. In General, the environmental screening process identifies what level of environmental assessment is required for the subprojects. It is one of the crucial stages of project decision making. The screening process also provides information to decision-making authorities about the nature of the sub-project before its implementation. Broadly speaking, the purpose of the environmental screening is to get relevant concerns addressed early on before further design of a project and to ensure that actions to mitigate environmental impacts or enhance environmental opportunities are budgeted for. The environmental screening is about taking stock in time and to avoid losing later opportunities. The participation and consultation with local communities are important indentifying the potential impacts of the project interventions. In case of EGPP, screening will be used for taking decision about the inclusion or exclusion of the subprojects to be funded under the project. The proposed screening criteria have been selected from the experience of other project and typical environmental impacts of the proposed project interventions. 67. The screening responsibility of the subproject rests on the Union Parishad Project Implementation Committee (UP-PIC) during the selection of projects in consultation with community and ward members. A sample screening format is attached in Annex-C. The Bangla form will be used for the screening purposes at field level. Using the screening form, proposed sub-projects will be screened by respective UP-PIC, to identify any potential adverse impacts/effects from the sub-project activities. If the screening identifies significant environmental impacts like possibility of drainage congestion in the adjacent areas due to the new embankment, the subprojects will not be recommended for financing under EGPP. 8.2 Environmental Mitigation

68. Once impacts are identified, the necessary mitigation measure would then be recommended and the sub-project would be designed to implement these mitigation measures. The Upazila Field Supervisor (hired on a contractual basis by the Project) will review the environmental screening and suggest appropriate mitigation measures. If required, Upazila Field Supervisor will prepare a simple environmental management plan for the subproject. A sample environmental management plan format is attached in Annex-D and a typical environmental mitigation measures have been suggested in Annex-E. Annex-F also provides some sub-project specific Environmental Management Plans. 69. The Upazila Field Supervisor will estimate the cost for the environmental mitigation of the subprojects. For example, if the subproject requires plantation to compensate the tress lost due to construction/expansion of roads/embankment, the cost of plantation of similar species must be considered in subproject design.

8.3 Environmental Review and Approval

70. The completed screening forms along with mitigation plan (if required) must accompany the subprojects that are sent to the Upazila Committee (UC) for review, finalization and

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approval. If the screening form has any ‘Yes’ entries, or eventually unjustified ‘No’ entries, the project proposal/application would need to adequately explain and demonstrate form its design that the issue has been managed to avoid unacceptable adverse effects/impacts. On behalf of the UC, the Project Implementation Officer (PIO) will review the environmental screening and environmental management plan. If the proposal/application satisfactorily addresses the issues it will be recommended for approval to the UC. The UC will compile and submit the proposals including environmental screening and mitigation measures to the Deputy Commissioner (DC) for formal approval. The structure of the UP-PIC and UC are attached in Annex-G.

8.4 Environmental Monitoring

71. The supervision and monitoring of the subprojects implementation in EGPP will be carried out at different levels. The primary responsibility of the supervision of implementation including environmental mitigation measures is assigned to the UP-PIC. They will ensure the proper implementation of environmental management plan (if required) and maintain all necessary records in this regard. The UC will be responsible for the subproject monitoring. On behalf of the UC, the Project Implementation Officer (PIO) of each Upazila along with the Upazila Field Supervisor will monitor the environmental compliance issue. The PIO at Upazila level and the Deputy Director at Office of the Project Director (OPD) will maintain a database for sub-project specific environmental screening, and environmental management plan. 72. The purpose of the environmental monitoring is to ensure that envisaged purpose of the project are achieved and result in desired benefits to the target population without adversely affecting environmental resources. The monitoring activities of EGPP will include the compliance of the environmental management plan implementation. In general, the PIO will monitor the following indicators during field visit as ‘spot check’ and the related mitigation measures: i) top soil losses; ii) losses of agricultural lands; iii) drainage congestion/water logging; iv) erosion and siltation; v) losses of tress and vegetation; vi) dust and noise pollution; vii) sources of water pollution; viii) occupation health and safety practices etc. The project M&E system will capture the field monitoring information through its MIS.

73. It may be noted that the project would assist the implementing Ministry in refining their monitoring strategy for the EGPP and would provide support to develop the monitoring capacity at the Upazila level. The project would support the development of monitoring reports and would provide financing for critical staffing at the central and local levels and investments in ICT. The existing monitoring forms and reports would be redesigned to facilitate monitoring on inputs, outputs, intermediate outcomes and compliance with program guidelines. It has been decided that the environmental issues will be integrated with the new M&E system.

74. In addition, the Project will support an independent assessment for EGPP, which would aim to provide information on program implementation including environmental safeguard, the effectiveness of targeting and the impact of the program on household net incomes and coping strategies in response to the socks. This monitoring will take place on a ‘spot check’ basis as it would be impossible to monitor all the subprojects to be financed under the project. The spot checks consist of controlling the establishment of mitigation measures. The World Bank will hire a local think tank to conduct this independent assessment or third party monitoring. The input required for the environment will be part of the overall Term of Reference (ToR) the

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independent assessment/third party monitoring consultant. The scope of environmental independent monitoring and the required qualifications of environmental specialist are attached in Annex H.

75. A summary of the key steps of the environmental management is shown in the Figure -1.

Figure -1: Key Steps of Environmental Management in EGPP

Identification of Subprojects

Environmental Screening of Subprojects

Prepare simple EMP

Not eligible for funding under EGPP

Significant adverse environmental impacts

No significant adverse environmental impacts

Implementation of EMP

Supervision & Monitoring of EMP

Independent Assessment of Environmental Compliance

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9.0 INSTITUTIONAL ARRANGEMENT AND CAPACITY BUILDING

9.1 Environmental Screening

76. The previous chapter explains the environment management in EGPP and also the stakeholders involved in the process. The key stakeholders are: i) Union Parishad-Project Implementation Committee (UP-PIC); ii) Community; iii) Upazila Field Supervisor; iv) Project Implementation Officer (PIO); v) Upazila Committee (UC); vi) Deputy Director of the Office of the Project Director; and vii) A think tank as independent assessment or third party monitoring. Table-2 summarizes the responsibilities of different stakeholder in environmental management of the EGPP. Table -2: Responsibilities of Different Stakeholders

Responsible Entity/Person Responsibility Upazilla Project Implementation Committee

Environmental Screening Supervision of EMP Implementation

Community Participation and contribution to • Subproject identification • Environmental screening • Preparation and implementation

support to EMP Project Implementation Officer Review of subproject proposal

Monitoring of database Maintaining database at Upazila

Upazila Committee Review, finalization and approval of Sub-projects Overall monitoring

Deputy Director of Office of Project Director Maintaining database at national level. Think Tank Independent Assessment and/or third party

monitoring

9.2 Capacity Building

77. The implementing agency is mainly responsible to address disaster and emergency situation. Environmental concern has not been integrated with the operation. In addition, the other stakeholders involved in the project have limited or no experience on environmental management. The project has integrated environmental briefing in the general training programs to the staffs and stakeholders involved in project implementation.

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9.3 Grievance Redness System

78. Environmental issues will be integrated with the project Grievance Redress System, which will be set up at national, district and upazila levels. At the Upazila level, the Upazila Nirbahi Officer (UNO) will be the Grievance Redress Officer (GRO), while at the district level the Deputy Commissioner (DC) will be the GRO. The Deputy Project Director (DPD) in the office of the Project Director will act as the GRO at the central level. At each level, there will be a Grievance Redress Register, where complaints are entered petitioners given a receipt. All grievances should ideally be disposed within 15 days, failing which the petitioner can appeal before the appellate authority. Monitoring and reporting on possible complaints on environment issues from community and affected people in the villages will be one of the responsibilities of the Upazilla level GRO. The DC of respective district will be the appellate authority for the upazila level complaints, while the DPD of the project will be the appellate authority for the district level complaints. The National Steering Committee (NSC) headed by the Secretary, DMRD will act as the final appellate authority for grievance redress. The Office of the Project Director will be responsible for developing appropriate formats for complaints and redress as well as disseminating information about the Grievance redress system. Complainants can however send letters of complaint to any level and these will be acted upon by the level where they are received.

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ANNEX A: 100 Days EGP: Division Wise Project Data (First Phase: September 15 - November 30, 2008 / Extended Phase: up to December 15, 2008)

Sl. Division Total Budget (BDT.)

Total Projects Approved

Fertilizer Composition

Post-Disaster Home Repair

Earth-Filling to Heighten Homes

Embankment & Road Rebuilding

Water-Logging Prevention

Kitchen Garden & Plantation Work

Clogged Canal & Pond Clearing

Waste Cleaning

Earth-Filling (Public Property)

Others

1 Barisal 859,812,000 11,359 1,883 0 65 7,538 136 41 609 101 871 115 2 Chittagong 1,947,634,000 31,831 4,405 22 0 20,472 433 147 2,412 756 2,486 698 3 Dhaka 3,279,598,000 35,158 3,261 1 16 26,246 271 135 472 916 3,789 51 4 Khulna 1,327,256,000 15,149 1,216 278 3 10,601 245 6 580 208 1,825 187 5 Rajshahi 3,960,124,000 44,217 3,487 4 310 29,553 821 137 619 295 8,635 356 6 Sylhet 710,828,000 10,514 276 7 1 8,479 458 27 214 346 656 50

TOTALS: 12,085,252,000 148,228 14,528 312 395 102,889 2,364 493 4,906 2,622 18,262 1,457

Sl. Division Total Budget (BDT.)

Total Projects Approved

Fertilizer Composition

Post-Disaster Home Repair

Earth-Filling to Heighten Homes

Embankment & Road Rebuilding

Water-Logging Prevention

Kitchen Garden & Plantation Work

Clogged Canal & Pond Clearing

Waste Cleaning

Earth-Filling (Public Property)

Others

1 Barisal 859,812,000 11,359 16.58% 0.00% 0.57% 66.36% 1.20% 0.36% 5.36% 0.89% 7.67% 1.01% 2 Chittagong 1,947,634,000 31,831 13.84% 0.07% 0.00% 64.31% 1.36% 0.46% 7.58% 2.38% 7.81% 2.19% 3 Dhaka 3,279,598,000 35,158 9.28% 0.00% 0.05% 74.65% 0.77% 0.38% 1.34% 2.61% 10.78% 0.15% 4 Khulna 1,327,256,000 15,149 8.03% 1.84% 0.02% 69.98% 1.62% 0.04% 3.83% 1.37% 12.05% 1.23% 5 Rajshahi 3,960,124,000 44,217 7.89% 0.01% 0.70% 66.84% 1.86% 0.31% 1.40% 0.67% 19.53% 0.81% 6 Sylhet 710,828,000 10,514 2.63% 0.07% 0.01% 80.64% 4.36% 0.26% 2.04% 3.29% 6.24% 0.48%

TOTALS: 12,085,252,000 148,228

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Sl. Division Total Budget (BDT.)

Total Projects Approved

Average Project Cost (BDT.)

Project Distribution

1 Barisal 859,812,000 11,359 75,694 7.66% 2 Chittagong 1,947,634,000 31,831 61,187 21.47% 3 Dhaka 3,279,598,000 35,158 93,282 23.72% 4 Khulna 1,327,256,000 15,149 87,613 10.22% 5 Rajshahi 3,960,124,000 44,217 89,561 29.83% 6 Sylhet 710,828,000 10,514 67,608 7.09%

TOTALS: 12,085,252,000 148,228 - 100.00% AVERAGES: 2,014,208,667 24,705 79,158 -

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ANNEX B: List of Negative Subproject Attributes

The Project will not support any activities which may have significant environmental impacts since the project has no provision for the environmental assessment of the subprojects. No projects activities will be carried out in disputed lands or lands restricted for development or Environmentally Sensitive areas. Specific subprojects with any of the attributes listed below will be ineligible for support under the proposed emergency reconstruction operations. • New Building Construction

Building and any facility with cement concrete (CC) and reinforced cement concrete (RCC) works

• Roads Construction, reconstruction and extension of regional, national road and highway Construction/reconstruction of road involving major concrete/cement concrete/reinforced

cement concrete/ concrete block

• Organic Fertilizer Production for Agriculture Application Requiring pesticides that fall in WHO classes IA, IB, or II.

• Dams/Embankment Construction/reconstruction of dam/embankment involving major concrete/ cement

concrete/reinforced cement concrete /concrete blocks. • Drain/canal/pond Construction/reconstruction of drain, canal/pond excavation with major loss of

agriculture land. Use of concrete cement/ reinforced concrete cement.

• Land filling Sub-projects that will impact major destruction of top soil of agricultural land. Land filling by industrial, household and commercial wastes

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ANNEX C: Environmental Screening Format

District: ………………………………………. Upazilla: ……………………………………………. Union: ………………………………………... Village: …………………………………………….. Type of Subproject: ………………………………………………………. Major Activities under the Subproject: …………………………………… Screening Questions Yes No Scale of Impact Remarks

High Medium Low A. Subproject Siting Is the sub-project area adjacent to or within any of the following environmentally sensitive areas?

Protected Area □ □ □ □ □ Wetland □ □ □ □ □ B. Potential Environmental Impacts Will the sub-project cause………

loss of top soil? □ □ □ □ □ loss of agricultural land? □ □ □ □ □ negative effects on rare (vulnerable), threatened or

endangered species of flora or fauna or their habitat? □ □ □ □ □

negative effects on designated wetlands? □ □ □ □ □ negative effects on locally important or valued

ecosystems or vegetations? □ □ □ □ □

destruction of trees and vegetation? □ □ □ □ □

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Screening Questions Yes No Scale of Impact Remarks High Medium Low

impact on fish migration and navigation? □ □ □ □ □ obstruction of natural connection between river and

wetlands inside project area? □ □ □ □ □

water logging in polder areas? □ □ □ □ □ insufficient drainage leading to salinity intrusion? □ □ □ □ □ negative effects on surface water quality, quantities or

flow? □ □ □ □ □

negative effects on groundwater quality, quantity or movement?

□ □ □ □ □

increased soil erosion and /or sedimentation? □ □ □ □ □ negative impact on soil stability and compactness? □ □ □ □ □ increased noise due to day-to-day construction

activities? □ □ □ □ □

increased wind-blown dust from material (e.g. fine aggregate) storage areas?

□ □ □ □ □

C. Other Potential Impacts Will the subproject cause………

potential social conflict between occupational groups – farmers vs.fisheries?

□ □ □ □ □

degradation or disturbance of historical or culturally important sites (mosque, graveyards, monuments etc.)?

□ □ □ □ □

conflicts in water supply rights and related social conflicts?

□ □ □ □ □

health risks to labors involved in activities? □ □ □ □ □ Note: Please add any other screening questions relevant to the demonstration. Also provide additional comments and/or positive impacts in ‘remarks’ column. Recommendations:

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Filled and signed by UP-PIC representative: Name: _______________________________ Title: _______________________________ Date: _______________________________ Reviewed and signed by Upazila Field Supervisor: Name: _______________________________ Title: _______________________________ Date: _______________________________

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ANNEX D: Typical Environmental Management Plan

Activity/Issue Potential Environmental Impacts

Proposed Mitigation Measures

Responsible Partiers

Estimated Cost

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ANNEX E: Typical Environmental Mitigation Measures for Earthen Road and Embankment

Impact Impact Description Mitigation Measures

Loss of top soil Fertility of the soil will be reduced from farm land by excavation of top soil for fill materials

* Top soil from farm land should not used as fill materials for earthworks * Use of bottom part of soil for soil filling * Keeping the top soil beside and restore the top soil after construction to

the agricultural land Change in land use and loss of agricultural land

Change in land use pattern and topography of the project

* Avoid agricultural land for subproject activities * If avoidance is not possible, use steep slopes and stabilize by using

improved soils, grass turfing or vetiver grass Drainage congestion/water logging

Improper roads and embankment can create localized drainage problem/water logging

* Consider the drainage system of the whole area in subproject design * Maintain cross-drainage at all times during construction

Erosion and siltation Destabilization of road embankment and slope may occur

* Destabilization is mostly related to embankment if not properly compacted

* Dense and well rooted growth of permanent grass and trees should be planted at embankment and road sides for protection the slopes.

Losses of tress and vegetation

Cutting or trimming of trees, losses of vegetation

* Consider alternation options to reduce the loss of tress and vegetation * Plant same species of trees and vegetation

Dust and noise pollution Dust generation during construction phase. Spillage of the material will be occurred from physical works Noise generation from physical interventions

* Spray of water during dry season and in windy conditions * Immediate compaction after construction of base course * Cover the stockpiles of fine materials in construction yard * Plan the work schedule of noise creating activities in consultation of local

community Water Pollution: Surface/ Ground water pollution

Improper disposal of solid and liquid waste generate from construction sites will pollute the water quality

* Prohibit direct disposal of solid and liquid wastage into nearby water body.

* Spoil Management Plan should be implemented by the contractor Fish and aquatic habitat Change in ecology or wetlands can affect the

fish and aquatic habitat

* Avoid any activities which can alter local ecology * Not allow any work in water bodies during fish migration

Occupational health and safety

Chances of any accidents, spread of communication diseases

* Provision of first aid facility * Arrangement of safe drinking water for the labors working in the

subprojects

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ANNEX F: Sub-Project Specific Environmental Management Plan Canal Excavation/Re-excavation

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Earthworks (Excavation, Vegetation Clearance)

• Increase in fugitive dust levels and felling of trees

• In residential areas, if works are conducted in the dry season, wet the exposed areas and stockpiles of earth materials, particularly fines, to minimize windborne particles and increase in levels of fugitive dust.

• Compensate for trees removed by planting new trees.

• Communities must be given at least two weeks prior notice of intended excavation period.

• Communities must be given prior notice of intended road closures and designated detours.

• For worker health and safety, all workers should be supplied with dust masks.

• Cover canal sides with stones (riprap), or use vegetation cover.

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Earthen Dam Construction/Re-construction

Project Activity Potential Environmental Impact

Proposed Mitigation (incl. Legislation and Regulation)

Excavation and fill

• Blocked access & disruptions • Landslides & slips, erosion

and sedimentation

• Give early notice to residents, use signs and flagmen, use diversion or open access periodically.

• Keep angle of slopes within limits of soil type.

• Use appropriate slope stabilization measures.

• Balance cut and fills to limit steepness of slopes.

• Cover slopes and re-vegetate early, including shoulders.

Use of construction material

• Spillage of the material (mud, sand, etc.)

• Improper disposal of construction material

• Cover the stockpiles of fine materials in construction yard to avoid spillage

• Proper disposal of construction material

Construction work

• Dust generation during construction phase.

• Loss of Top soil from farm land by excavation of top soil for fill materials

• Water logging problems may occur

• Removal of trees

• Regular water should be sprayed during construction of embankment and over newly constructed dry embankment.

• Construction should be avoided during rainy season

• Immediate compaction after embankment and cleaning after construction of base course

• Top soil from farm land should not be used as fill materials for earthworks

• Use of bottom part of soil for soil filling keeping the top soil beside and restore the top soil after construction to the agricultural land

• Maintain cross-drainage at all times during construction

• Removal of trees should be minimal and compensate for trees removed by planting new trees.

Occupational Health and safety

• Accident at the construction sites.

• Conflict may arise between local &migrant workers

• First Aid Box should be provided to workers/project personal.

• Engage local workers instead of migrant workers and to be provided.

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Rural Road Construction/Re-construction

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Survey and Fixing Alignment

• Tree cutting

• Alignment should be fixed such a way that minimum number of tree cutting occurs

Land Acquisition • Loss of agricultural land, forest, wetlands

• Alignment should be fixed such a way that minimum loss of agricultural land, forest, wetlands

• Alternative Alignment can be considered

Use of construction material

• Spillage of the material (mud, sand, etc.)

• Improper disposal of construction material

• Cover the stockpiles of fine materials in construction yard to avoid spillage

• Proper disposal of construction material

Construction work

• Loss of Top soil from farm land by excavation of top soil for fill materials

• Water logging problems may

occur • Removal of trees

• Top soil from farm land should not be used as fill materials for earthworks

• Use of bottom part of soil for soil filling keeping the top soil beside and restore the top soil after construction to the agricultural land

• Maintain cross-drainage at all times during construction

• Removal of trees should be minimal and compensate for trees removed by planting new trees.

Occupational Health and safety

• Accident at the construction sites.

• Conflict may arise between local &migrant workers

• First Aid Box should be provided to workers/project personal.

• Engage local workers instead of migrant workers and to be provided

Use of road • Dust during dry season mud • Erosion of slope • Inconvenience in movement

during rain • Water logging • Impact on fish migration due

to lack of cross drainage

• Use of water to control dust • Tree plantation • Considering natural drainage pattern,

proper planning and design should be done to avoid water logging

• Cross drainage should be appropriate in number and location

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Drain Excavation/Re-excavation

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Earthworks (Excavation, Vegetation Clearance)

• Increase in fugitive dust levels and felling of trees.

• Contamination or siltation

from dredged/excavated material

• Flooding from inadequate or • blocked drains • Erosion of drain and siltation

• In residential areas, if works are conducted in the dry season, wet the exposed areas and stockpiles of earth materials, particularly fines, to minimize windborne particles and increase in levels of fugitive dust.

• Compensate for trees removed by planting new trees.

• Communities must be given at least two weeks prior notice of intended excavation period.

• Communities must be given prior notice of intended road closures and designated detours.

• For worker health and safety, all workers should be supplied with dust masks.

• Use good design; do not block drains, clear blocked drains.

• Cover drain sides with stones (riprap), or use vegetation cover.

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Land filling

(Community Institutions like school, graveyard, prayer ground, height increase of market/helipad)

Project Activity Potential Environmental Impact

Proposed Mitigation (incl. Legislation and Regulation)

Earthworks (Filling, Vegetation Clearance)

• Increase in fugitive dust levels and felling of trees

• In residential areas, if works are conducted in the dry season, wet the exposed areas and stockpiles of earth materials, particularly fines, to minimize windborne particles and increase in levels of fugitive dust.

• Compensate for trees removed by planting new trees.

• Communities must be given at least two weeks prior notice of intended excavation period.

• Communities must be given prior notice of intended road closures and designated detours.

• For worker health and safety, all workers should be supplied with dust masks.

Use of construction material

• Spillage of the material

• Cover the stockpiles of fine materials in construction yard

• Ensure proper disposal of construction material

Construction work

• Loss of Top soil from farm land by excavation of top soil for fill materials

• Water logging problems may occur

• Top soil from farm land should not used as fill materials for earthworks

• Use of bottom part of soil for soil filling keeping the top soil beside and restore the top soil after construction to the agricultural land

• Maintain cross-drainage at all times during construction

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Earthen Shelter for Animals

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Land Acquisition

• Loss of agricultural land, forest, wetlands

• Location should be fixed such a way that minimum loss of agricultural land, forest, wetlands

• Alternative location can be considered Earthworks

• Increase in fugitive dust levels and feeling of trees

• In residential areas, if works are conducted in the dry season, wet the exposed areas and stockpiles of earth materials, particularly fines, to minimize windborne particles and increase in levels of fugitive dust.

• Compensate for trees removed by planting new trees.

• Communities must be given at least two weeks prior notice of intended construction period.

• Communities must be given prior notice of intended road closures and designated detours.

• For worker health and safety, all workers should be supplied with dust masks.

Usage of the shelter

• Animal wastes generation • Odor nuisance

• Sell uncontaminated wastes to farmers as fertilizer

• Avoid dumping solid waste • Do not let sludge stagnate in or around

community

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Excavation of Public Ponds/Fish Firms

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Survey and Fixing Alignment

• Tree cutting

• Pond location should be selected which will cause minimum trees to be cut

Land Acquisition

• Loss of agricultural land, forest, wetlands

• Pond location should be fixed such a way that minimum loss of agricultural land and wetlands

• Alternative location can be considered Construction work

• Dust generation during • Removal of trees • Use of dechlorinator

• Regular water should be sprayed during earthworks.

• Excavation should be avoided during rainy season

• Removal of trees should be minimal • Restrict the water from drinking

Use of construction material

Improper disposal of excavated material

• Proper disposal of excavated material

Occupational Health and safety

• Accident at the construction sites.

• First Aid Box should be provided to workers/project personal.

• Engage local workers instead of migrant workers and to be provided

Usage of pond • Erosion of slope • Eutrophication

• Tree plantation along the pond side • Plantation grass on the slope • Proper maintenance to take out extra

hyacinth

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Organic Fertilizer Production

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Production of Organic Fertilizer

• Odor • Surface water pollution and

Eutrophication • Pest problem

• Improperly-processed organic fertilizers may contain pathogens from plant or animal matter that are harmful to humans or plants. Fertilizer should be prepared according to the manual.

• Avoid excessive use of nitrogen nutrient.

• Ensure proper disposal of the wastes Uses of Organic fertilizer

• Possible pollution of surface water or groundwater.

• Contamination of

surrounding area.

• Dispose of collected waste materials at approved landfill or disposal site.

• Only use approved standard processes and equipment, and maintain it in good working order.

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Water Reservoir Construction

Project Activity Potential Environmental

Impact Proposed Mitigation (incl. Legislation and Regulation)

Earthwork • Increase in fugitive dust levels;

• Hindrance of pedestrian

movement;

• Waste/debris, and creation of stagnant pools.

• Excavation must be made (if possible) during the dry season, to avoid erosion and siltation of drainage canals or other water bodies in the area; • Use silt screens and sediment traps to

prevent sediment from reaching trenches and watercourses. • Provide adequate drainage interception

and diversion around trenches and work site. • 4. Ensure prompt refilling of reservoir

and proper management and use/disposal of soil cover and wastes.

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ANNEX G: Committee Structure

Union Parishad-Project Implementation Committee At the Union Parishad (UP) level, the Union Committee will be responsible for the selection of all projects and beneficiaries in consultation with the community and the ward members, preparation and regular updating of the beneficiary muster roll, conducting environmental and social assessment of projects. The Union Committee will be responsible for the periodic supervision of projects, timely payment to the beneficiaries, liaison with the UC and OPD, maintenance of all necessary records including site registers, registration/ job cards, receipts & payment, etc. with the help of the Project Implementation Committees (PICs). The Union Committee will also coordinate with the PICs for ensuring timely reporting including data collection and preparation of activity / progress reports.

The Union Committee will be chaired by the UP Chairman and the UP Secretary will act as its Member Secretary. Other members of the Union Committee will include all members of the UP, Sub-assistant Agricultural Officer (Block Supervisor), One representative from LGED, Field Assistant, BRDB, one eminent person from each ward of the union (Selected by the Upazila Nirbahi Officer), one teacher and one women representative from the union (Selected by the Upazila Nirbahi Officer). Where necessary, a representative from the Water Development Board and any one as appropriate for the committee may be co-opted in the committee.

A Union Committee will be formed in each UP in a community meeting in the presence of UP Chairman, UP members and with community participation from all wards organized by UP. In choosing Union Committee members, the following principles will be respected:

(a) The members of the Union Committee should be residents of the Ward (or village) that benefits most directly from the proposed investment. Every effort should be made to ensure that the representatives (at least two in every Committee) of beneficiary communities are included in the Union Committees – as this maximizes local ownership and increases accountability;

(b) At least two members of the Union Committee shall be women.

Every Union Committee may form Project Implementation Committees (PICs) consisting of 5-7 members for each project. Each PIC will be responsible for day to day implementation of the projects in close collaboration with the Union Committee. They will also be responsible for timely payment to the beneficiaries, liaison with the Union Committee, maintenance of all necessary records including site registers, registration/ job cards, receipts & payment, etc. The day to day reporting including data collection and preparation of activity / progress reports of the concerned project will also be carried out by the PIC. The Project Implementation Committee (PIC) will be formed in a community meeting in the presence of UP Chairman, UP members and with community participation from all wards organized by UP. The members of the PIC should be residents of the Ward (or village) that benefits most directly from the proposed project. A concerned ward member or women ward member will be selected as the Chairperson of PIC during this meeting. Other members of the PIC will be nominated by the community at ward level open meeting organized by the ward

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members. One school teacher and an eminent person from the locality shall be the committee members in addition to the local ward members. One member nominated by the committee will act as the Member-Secretary. The following principles will be respected in the process of selection and functioning:

a) A person will not hold the position of the Chair in more than one PIC; b) At least 30% of the members of PIC will be women.

Upazilla Committee At the Upazila level, the Upazila Committee (UC) will be responsible for the finalization and approval of projects and list of beneficiaries submitted by the Union Committee, supervision & monitoring of projects, liaising with the Office of the Project Director (OPD) and Union Committee, supporting PIO and Union Committee with necessary technical inputs, timely transfer of funds to Union Committee as well as preparing and forwarding Upazila level progress reports to OPD.

The UC will compile and submit (via the UNO) its Upazila Plan to the Deputy Commissioner (DC) for formal approval. The Upzila Plan will contain union-wise details of planned projects and beneficiaries for each phase of the project. In the event that no comments are received from the DC within one month, the UC will assume that its annual plan/budget has been formally approved.

The UC will be chaired by the respective Upazila Nirbahi Officer (UNO) and the Project Implementation Officer (PIO) will act as its Member Secretary. The respective Member of Parliament (MP) will act as the Chief Advisor, while the Upazila Chairman will act as the Advisor. Other members will include Upazila Vice Chairmen, Upazila Health and Family Planning Officer, Upazila Engineer LGED, Upazila Women Affairs Officer, Upazila Education Officer, Upazila Agricultural Officer, Upazila Cooperative Officer, Upazila Livestock Officer, Upazila Fisheries Officer, Social Welfare Officer, Ansar and VDP officer, Upazila BRDB Officer, all Union Parisad Chairmen of the respective Upazila, eminent persons of the Upazila (Selected by the Deputy Commissioner), and one teacher and a representative from the volunteer organizations (Selected by the Deputy Commissioner). The UC will have powers to co-opt more members from the upazila, if necessary.

The Project Implementation Officer (PIO) of every Upazila will be the focal point for the implementation of the project at the Upazila level and he will be assisted by a Field Supervisor hired on a contractual basis by the Project. The Field Supervisor will be responsible for: (i) Facilitating the overall implementation process of the program; (ii) Supporting upazila and union-level public administration in efficiently executing the program; (iii) Coordinating regularly with the head of local administration and relevant government officials; (iv) Participating in local-level meetings where program maters are discussed; (v) Conducting and facilitating the targeting and enrolment processes in the assigned location; (vi) Monitoring and supervising public workfare schemes; (vii) Preparing and submitting all assigned reports from the local-level on a regular basis; and (vii) Assisting the Program Implementation Officer (PIO) with other tasks as requested.

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ANNEX H: Scope of Work of Environment Specialist under Independent Assessment/Third Party Monitoring

Scope of Work Develop a systematic approach to identify the representative sample size considering the

types of subprojects; Review the adequacy of the environmental screening, environmental management plan and

implementation of the environmental mitigation activities; Assess the institutional mechanism for integration, management and monitoring of

environmental issues in subproject planning, implementation and operation & maintenance (O&M);

Examine the knowledge and awareness of the field level staffs on management of environmental issues;

Recommend specific suggestions to improve the environmental management of the subproject design, implementation and O&M in next year; and

In order to carry out the above tasks, the consultant will review the list of the subprojects, identify category subprojects, conduct FGD and interviews of the beneficiaries, other local community people, NGOs and field level staffs.

Qualification of Environmental Specialist • At least Masters Degree in environmental studies/ management/science /engineering • About 10 years of experience in environmental assessment • Experience in community-driven development approach • Ability to lead, organize and co-ordinate • Good verbal and written communication skills in both English and Bangla • Demonstrated interpersonal skills, and proven ability to work in a different multicultural

context