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					                                 E2946 v1




    Environmental Management Framework
                      For
  Bangladesh Rural Water Supply and Sanitation
              Project (BRWSSP)




     Department of Public Health Engineering
The Local Government Division (LGD), MOLGRDC
  Government of Peoples Republic of Bangladesh




                October, 2011



                                                 2
Table of Contents
Acronyms and Abbreviations
.........................................................................
................. 5
EXECUTIVE SUMMARY
.........................................................................
.............................. 7
1.
Introduction.............................................................
.................................................. 12
   1.1 Project
Background...............................................................
.................................. 12
   1.2 Purpose of the Environmental Management Framework (EMF)
........................... 12
   1.3 Structure of EMF
.........................................................................
........................... 13
2. Project
Description..............................................................
...................................... 13
   2.1 Objectives of the
Project..................................................................
....................... 13
   2.2 Components of the
Project..................................................................
.................... 14
   2.3 Anticipated Subproject
Types....................................................................
............. 14
   2.4 Project Target Areas
.........................................................................
...................... 15
      2.4.1 Physiography and Land-use
Pattern.................................................................
15
      2.4.2 Hydrology
.........................................................................
............................... 16
      2.4.3 Ground
Water....................................................................
............................... 17
      2.4.4 Ecology
.........................................................................
................................... 19
      2.4.5 Environmentally and Ecologically Sensitive
Areas......................................... 20
   2.5 Main Environmental Concerns in project
areas...................................................... 21
   2.6 Arsenic Contamination of drinking water in Project areas
..................................... 21
3. Environmental Policies, Laws and
Rules..................................................................
22
   3.1 Bangladesh Legal Framework
.........................................................................
....... 22
   3.2 Environmental Guidelines for Projects in Bangladesh
........................................... 22
   3.3 Environmental Category for
BRWSSP...................................................................
26
   3.4 International Obligations
.........................................................................
............... 26
   3.6 Bank's Environmental Safeguards
.........................................................................
28
      3.6.1 Environmental Assessment and OP 4.01
......................................................... 29
      3.6.2 Projects on International Waterways and OP 7.50
.......................................... 30
      3.6.3 Environmental Management in Sub-
projects................................................... 30
      3.6.4 Environmental
Screening................................................................
................. 30
      3.6.5 Classification for EA and Procedures
.............................................................. 31
4. Requirements on Environmental Clearance in
Bangladesh......................................... 31
   4.1 General Procedure for
EA.......................................................................
............... 31
   4.2 Application for Environmental Clearance – Green
Category................................. 32
   4.3 Application for Environmental Clearance –Amber B & A
Category..................... 32
   4.4 Application for Environmental Clearance – Red Category
.................................... 33
   4.5 Validity Periods for Environmental Clearance
Certificates.................................... 34
5. Subproject Preparation, Approval and
Monitoring................................................... 34
   5.1 Subproject Document Preparation
..................................................................... 34
   5.2 Appraisal and Approval
.........................................................................
............ 35
   5.3 Annual
Reports..................................................................
................................. 38
   5.4 Annual Reviews
.........................................................................
........................ 38
6. Environmental Management
Plan.....................................................................
........ 39
3
   6.1 Subproject Planning
.........................................................................
....................... 40
   6.2 Water quality analysis and quality Assurance in analysis
...................................... 41
7. Consultation &
Disclosure...............................................................
............................. 42
   7.1 Community / Stakeholder Consultations
................................................................ 42
   7.2 Disclosure
.........................................................................
...................................... 43
8. Project Coordination and Implementation
.................................................................... 43
   8.1 Organizational Structure
.........................................................................
................ 43
   8.2 Responsibility Allocation Framework
.................................................................... 43
   8.3 Grievance Redress
.........................................................................
......................... 44
9. Capacity Building and
Training.................................................................
................... 44
   9.1 Institutional Capacity Assessment
..................................................................... 44
   9.2 Capacity
Building.................................................................
.............................. 45
   9.4 Resources for EM and Capacity Building
.............................................................. 48
10. Conclusions and Recommendations
.........................................................................
.. 49
Annex I: Environmental Management
Forms...................................................................
50
Annex-II: Arsenic Rich Sludge Disposal from Fe/Mn/As Removal Plants
..................... 55
Annex-III: Bangladesh Drinking Water Quality
Standards.............................................. 58
Annex-IV: Stakeholders’ Consultation and
Disclosure............................................... 60



Tables:
Table 1: Type of Subprojects that may be financed by the project
Table 2: Environmental Issues and Relevant Laws and Regulations in
Bangladesh
Table 3: ECR Environmental Categories for projects and industries
Table 4: Subproject Environmental Categories in BRWSSP and WB guidelines
Table 5: Environmental Assessment and Management Framework
Table 6: Criteria for Requiring a Field Appraisal
Table 7: Type of subprojects and their environmental category
Table 8: Capacity Building Criteria for managing C and B Category
Subprojects
Table 9: Outline of different Training Needs




4
Acronyms and Abbreviations

BBS         Bangladesh Bureau of Statistics
BOD         Bio-Chemical Oxygen Demand
BP          Best Practice
BRWSSP      Bangladesh Rural Water Supply & Sanitation Project
BWSPP       Bangladesh Water Supply Program Project
BRWSSP      Bangladesh Rural Water Supply And Sanitation Project
CBO         Community Based Organization
COD         Chemical Oxygen Demand
CWASA       Chittagong Water Supply and Sewerage Authority
DPHE        Department of Public Health Engineering
DG          Director General, DOE
DOE/DoE     Department of Environment
DTL         D-Water Tech Ltd.
DW          Drinking Water
EA          Environmental Assessment/ Appraisal
ECA         Environmental Conservation Act of 1995
ECC         Environmental Clearance Certificate
ECR         Environmental Conservation Rules of 1997
EHS         Environmental Health and Safety
EIA         Environmental Impact Assessment
EMF         Environmental Management Framework
EMS         Environmental Management System
EMP         Environmental Management Plan
ES          Environmental Screening
ER          Environmental Review
GOB         Government of the People’s Republic of Bangladesh
GP          Good Practices
GRC         Grievance Redress Committee
ISDS        Integrated Safeguard Datasheet
ISO         International Organization of Standardization
IEE         Initial Environmental Examination
LEA         Limited Environmental Assessment
MICS        Multiple Indicator Cluster Survey

                                                                   5
MLD       Million Litres Per Day
MOEF      Ministry of Environment and Forestry
MOLGRDC   Ministry of Local Govt. Rural Development & Cooperatives
NEMAP     National Environmental Management Action Plan
NOC       No objection Certificate
NGO       Non Government Organization
NTU       Nephelometric Turbidity Unit
NWP       National Water Policy
OHT       Over Head Tank
OP        Operational Policy
PMU       Project Management Unit
QAQC      Quality Assurance and Quality Control
RPWS      Rural Piped Water Supply
RPWSS     Rural Piped Water Supply Schemes
SCC       Site Clearance Certificate
UNICEF    United Nations International Children’s Emergency Fund
UP        Union Parishad
WB        World Bank
WSS       Water and Sanitation Sector




                                                                     6
EXECUTIVE SUMMARY
Project Background


The national rural water supply coverage in Bangladesh was estimated as
97.4% in 2009
which has been reduced to an estimated 86% after adjusting for arsenic
contamination
(MICS 2009). GOB with support from World Bank has decided to take up this
Rural
Water Supply and Sanitation Project (BRWSSP) to increase sustainable
access to safe
water supply and piloting on improved sanitation in the rural areas of
Bangladesh in
limited scale. DPHE has been chosen as the implementing agency for this
project as it has
successfully implemented earlier the Bangladesh Water Supply Program
Project
(BWSPP) on pilot Rural Piped Water Supply Schemes using Public-Private
Partnership
model and Community Managed Non-Piped Water Supply Systems with World
Bank
financing.

Project Description

The overall objective of the proposed project would be to increase the
sustainable access
to safe water supply and to explore improved sanitation in the rural
areas of Bangladesh,
focused on supporting the Government to mitigate the Arsenic & other
water quality and
quantity problems including pathogen contamination of drinking water
sources. This
objective is to be achieved by scaling up and promoting the rural piped
water supply
systems with local public-private partnerships in financing and
operation; scaling up the
provision of safe water (point) sources managed by community user groups
and carrying
out sanitation and hygiene promotion programs in line with the Bangladesh
“Total
Sanitation Campaign�? to promote household hygiene and safe sanitary
practices in
targeted villages.

Under these interventions, BRWSSP has proposed to fund 125 Rural Piped
Water Supply
Schemes, 20,000 Non-piped Rural Water Supply Schemes and Rural Sanitation
in 20
Union Parishads (UPs). The first two of these components would ensure
sustainable
access or safe drinking water primarily in water quality & quantity
problem areas through
the tested service delivery models including Public Private Partnership
with private
sponsors as well as community managed point source options. The other
component will
support the government to carry out sanitation and hygiene promotion
programs in
targeted UPs which will include Technical Assistance for Social
Marketing, Social
Mobilization and Business Capacity Building. More specifically, this will
include
building awareness of rural households to demand hygienic sanitation
services where
supplies will be made available in affordable prices. There is also
another component to
the project which will support towards developing regulatory and
oversight framework



7
for the service provision models as well as a knowledge base on water
quality monitoring
through technical assistance.

Purpose of the EMF

The project components proposed have environmental safeguard issues and
this EMF
documents provides a framework to address these issues. The projects
components are to
be designed and implemented by integrating the national policies,
guidelines, codes of
practice and procedures proposed in this EMF. The objectives are to
ensure that the
activities undertaken in the project:
         Enhance positive environmental outcomes;
         Prevent negative environmental impacts;
         Identify and mitigate with appropriate measures, the adverse
impacts that might
         arise;
         Obtain Environmental Clearance form DOE; and
         Ensure compliance with the World Bank’s environmental safeguards
policies.

Structure of EMF

The EMF document is structured in a sequential manner to assist the
reader to understand
the background of the preparation of the document, its purpose,
objectives and its
implementation during design, implementation and operational stages of
the project.

Relevant Country Environmental Laws and Regulation

The present Policies, Acts, Rules & Regulations with respect to the
Environmental issues
in the country are under the custodianship of the Ministry of Environment
and Forest
(MOEF)/Department of Environment (DoE). However, there are also some
sectoral laws
dealing with different environmental issues in Bangladesh which were
enacted at
different periods but are largely obsolete now. The activities under the
project are
covered by the Policies, Acts, Rules & Regulations under ECA 95 and ECR
97.

World Bank's Environmental Safeguards

The main purposes of the Bank’s safeguard policies are to (i) avoid harm
to the
environment and affected people and provide affected people an
opportunity to
participate in the development process; (ii) improve project design and
performance; and
(iii) protect the reputation of the Bank. The current set of safeguard
policies cover a broad
range of topics from environmental assessment to natural habitats,
forests, resettlement,
and Indigenous Peoples and others. The policies are the reflection of
international
conventions and internationally accepted principles of good practice in
project
preparation and implementation. Similar principles, supporting the
aspirations for



8
sustainable development, are generally reflected in policies in
Bangladesh like most
developing countries; however, implementation is often weak and variable.
Out of
Bank’s safeguards policies only OP 4.01 related to environment is
triggered in the
Project. Considering the environmental impacts according to WB policy,
the project has
been classified in the B category. The legal policy OP 7.50 (i.e.,
Projects on International
Waterways) is not triggered in this project.
The zones of impact of the tubewells involved in the sub-projects are
expected to be less than 50
meters on the groundwater aquifers. So, in order to avoid any adverse
impact on possible
water use in neighboring countries, no tubewell will be located within
500 meters of the
international boundary.
Requirements on Environmental Clearance for projects in Bangladesh

In Bangladesh, the EA procedure has three tiers which are; (i) Screening;
(ii) Initial
Environmental Examination (lEE); and (iii) Detailed EIA. The rural piped
water supply
subprojects in BRWSSP can be classified in the Orange-B category (ECA97,
Schedule-1,
item-28: Water Purification Plant), and need to obtain the clearance from
the DOE in two
stages i.e., (i) Initial Stage in which a Site Clearance Certificate
(SCC) is obtained and (ii)
an advanced Stage in which an Environmental Clearance Certificate (ECC)
is obtained.
Although, it is not clearly specified in the rules, DOE does provide
clearance to EMF for
projects with multiple sub-projects with small environmental footprints.
The PMU will
seek DOE clearance for the EMF, so that clearance for individual
subprojects are not
required..

Environmental Management Plan

In the context of a project, environmental management is concerned with
the
implementation of the measures necessary to minimize or offset adverse
impacts and to
enhance beneficial impacts. The EMP ensures that the mitigation and
benefit
enhancement measures identified in the EMF/LEA are fully implemented and
a clear line
of responsibilities for the purpose are assigned. It is expected that for
most of the sub-
projects, groundwater from arsenic free aquifer will be used. However, in
cases where
unavoidable, treatment plant to remove Arsenic and other harmful or
aesthetic
contaminants will be established. At the sub-project level, quality of
water will be
ensured through testing during feasibility studies and implementation
(testing will include
all relevant parameters notified in the GOB standards for drinking water
that are expected
to be exceeded). Although, the aim would be to avoid problematic sources,
by exploring
and tapping safe sources (by location), adequate arsenic removal
plants/technologies and
conventional water treatment will be used, wherever required. Adequate
assessment will
be undertaken to understand the aquifer thickness, hydraulic gradient and
its recharge
capacity prior to the installation of deep tube wells. Safe drilling
techniques will be
employed following the standard protocol being used by the DPHE. In cases
where
Arsenic laden sludge will be produced, adequate measures will be ensured
for its proper
disposal using approved protocols.



9
Community / Stakeholder Consultations

Community/stakeholder discussions are basic requirements in the OP4.01
for project
preparation and implementation. As the basic principles require, inputs
and feedbacks
received from stakeholder consultations are the major determinants in the
selection,
location and design of the project and its implementation. Accordingly, a
public
consultation on the EMF was done with the participation of the
stakeholders.

Disclosure

The PMU will disclose this EMF document on the DPHE website. The PMU will
ensure
that copies of the document are available at the project sites, DPHE
local offices and
DPHE Head Office in Dhaka, so that the document is accessible to the
general public.
The executive summary of the EMF in Bangla will also be made available
alongside.
The PMU will inform the public through a notification in two local
newspapers (i.e. one
Bangla and one English) about the stakeholders’ consultation on the EMF
and the EMF
accessibility.

Grievance Redress

The Project Management will establish a procedure to answer to project-
related queries
on environmental issues and address complaints and grievances about any
irregularities
in application of the guidelines adopted for assessment and mitigation of
environmental
safeguards impacts. The complaints related to project activities that may
create
inconveniences during construction should be addressed based on
consensus, the
procedure will help to resolve issues/conflicts amicably and quickly
without resorting to
expensive, time-consuming legal actions. For the purpose, a Grievance
Redress
Committee (GRC) will be formed by the PMU.

Capacity Building

For establishing a sound Environmental Management System (EMS), the PMU
will
ensure EMS as a valuable tool that provides a structure for strategic
goal setting,
improved decision making and efficient resource allocation across
management priorities,
balancing the management of operations throughout the value chain. The
implementation
of an EMS which minimizes negative and advance positive impacts on the
environment
is an achievable goal through implementation an environmental policy. The
components
of the EMS on capacity building will consist of human resource
development as well as
investment in environment infrastructures including resources for health
and safety
measures.

Monitoring, Reporting and Audit



10
The purpose of monitoring measures that will be undertaken are to ensure
that the
environmental concerns are addressed, environmental assets are protected
and quality is
enhanced through mitigation measures and these are monitored and reported
in an
efficient and effective manner. Yearly report on the project’s
environmental performance
should be submitted to the appropriate authorities and shared with the WB
for review of
the effectiveness of environmental management.


Conclusions and Recommendations

The proposed sub-projects under the BRWSSP will have mostly positive
impacts on the
beneficiaries and their environment. However environmental impacts (if
any) can be
managed if the procedures given in this EMF are followed, so that there
are no harmful
impacts on the local community. The EMF is a document which provides
guidelines as to
how the environmental safeguard issues can be addressed for the project.
The project
staff and other relevant persons should be trained so that they can fully
implement the
actions needed under the EMF. Provision for adequate funding has been
made in the
project’s operational budget for the purpose.




11
1.     Introduction

1.1 Project Background

The national rural water supply coverage in Bangladesh was estimated as
97.4%
according to the Multiple Indicator Cluster Survey (MICS) conducted by
Bangladesh
Bureau of Statistics and UNICEF (BBS/UNICEF, 2009). However, safe water
coverage
has been adjusted as 86% considering arsenic contamination according to
MICS.
Institutionally, the Department of Public Health Engineering (DPHE) under
Ministry of
Local Government, Rural Development and Cooperatives (MOLGRDC) is
responsible
for planning, designing and implementing water supply and sanitation
services in rural
and urban areas except city corporation areas of Dhaka, Chittagong and
Khulna. DPHE
has implemented different types of water supply systems in the country.
These include
both point source options and local piped water supply options. Recently
DPHE has
successfully implemented a number of pilot Rural Piped Water Supply
Schemes using
Public-Private Partnership model and Community Managed Non-Piped Water
Supply
Systems under the World Bank financed Bangladesh Water Supply Program
Project
(BWSPP). Based on the lessons learnt from BWSPP, World Bank and DPHE
(i.e., on
being designated by GOB) have decided to take up this follow on project,
the Rural
Water Supply and Sanitation Project (BRWSSP). The objective of the
project is to
increase sustainable access to safe water supply and piloting on improved
sanitation in
the rural areas of Bangladesh in limited extent, focused on supporting
the Government in
mitigating the deteriorating water quality arising from arsenic,
pathogens, salinity and
other causes.


1.2 Purpose of the Environmental Management Framework (EMF)

BRWSSP will entail implantation of water supply and sanitation sub-
projects all over the
country. The details of the subprojects are not known at the present time
and these will be
identified during project implementation. The sub-projects in the project
will be be
designed and implemented by integrating the general policies, guidelines,
codes of
practice and procedures proposed in this EMF.
All proposed requests for funding the sub-projects will be subject to
environmental
screening exercise in order to prevent execution of projects with
significant negative
environmental impacts; decrease potential negative impacts through
adaptations in
design, location or execution; prevent or mitigate negative cumulative
impacts; enhance
the positive impacts of subprojects; and prevent additional stress on
environmentally
sensitive areas. World Bank Operational Policy on Environmental
Assessment (OP 4.01)
is triggered for this project. In order to avoid potentially adverse
environmental impacts,


12
this policy will be used for assessing potential environmental problems
and taking
mitigation measures.

More specifically the objectives of this EMF are:
  • To establish clear procedures and methodologies for the environmental
review,
      approval and implementation of subprojects to be financed under the
Project;
  • To specify appropriate roles and responsibilities, and outline the
necessary
      reporting procedures, for managing and monitoring environmental
concerns
      related to subprojects;
  • To determine the training, capacity building and technical assistance
needed to
      successfully implement the provisions of the EMF;
  • To establish the areas for project funding requirements to implement
the EMF
      requirements; and
  • To provide practical resources for implementing the EMF.

The implementation of EMF will help to ensure that activities under the
proposed project
   will:
   • Protect human health;
   • Enhance positive environmental outcomes; and
   • Prevent negative environmental impacts as a result of either
individual subproject
       or their cumulative effects.


1.3 Structure of EMF

The EMF document is structured in a sequential manner to assist the
reader to understand
the background of the preparation of the document, purpose, objectives
and its
implementation during design, implementation and monitoring stages of any
sub-project
under the project. The chapters are appropriately labeled so as to
provide information on
the coverage.




2.     Project Description

2.1 Objectives of the Project

The overall objective of the proposed project would be to increase the
sustainable access
to safe water supply and improved sanitation in the rural areas of
Bangladesh, focused on
supporting the Government to mitigate the arsenic & other water quality
and quantity


13
problems including pathogen contamination of drinking water sources. This
objective is
to be achieved by:

   •       Scaling up and promoting the rural piped water supply systems
with local
           public-private partnerships in financing and operation;
   •       Scaling up the provision of safe water (point) sources managed
by community
           user groups;
   •       Carrying out sanitation and hygiene promotion programs in
targeted villages
           in line with the Bangladesh “Total Sanitation Campaign�? to
promote
           household hygiene and safe sanitary practices, and the
provision of sanitation
           facility in target villages;
   •       Supporting the development of a natural disaster WSS response
mechanism
           (Institutional setups, response arrangements, funding
mechanisms, etc) for
           expeditious intervention in the event of natural disasters;
and
   •       Supporting the development of adequate regulations and
monitoring of
           groundwater, characterization of aquifer, and relevant
environmental studies.

2.2 Components of the Project

BRWSSP has proposed four major investment components: (1) Rural Piped
Water
Supply Schemes; (2) Non-piped Rural Water Supply Schemes; (3) Rural
Sanitation and
(4) Regulatory and Oversight Framework for Service Provision, including
Water
Monitoring. First two of these components would ensure sustainable access
to safe
drinking water primarily in the water quality & service coverage problem
areas through
the tested service delivery models including Public Private Partnership
with private
sponsors as well as community managed water supply options. One component
will
support the government to carry out sanitation and hygiene promotion
programs in
targeted villages in line with the Bangladesh ‘Sanitation Campaign’ while
another
component will support towards developing regulatory and oversight
framework for the
service provision models as well as a knowledge base on water quality
monitoring
through technical assistance.
2.3 Anticipated Subproject Types

A list of subprojects that may be financed by the project is given in
Table 1. This list
provides general information to the local communities/ private agencies
on the generic
type of subprojects that may be implemented under the project. Such
subprojects should
be judged on merit and will be financed if they have manageable
environmental
dimensions within the framework.




14
           Table 1:        Type of Subprojects that may be financed by
the project

 Rural Piped Water Supply Schemes (RPWSS)
     1. Implementation of 125 rural piped water supply schemes.
 •    Major Components in each RPWS :
         • Test Tube Wells ( 2 units)
         • Production Wells ( 2 units)
         • Pump House cum Office Room
         • Treatment Plant (if required)
         • Water Reservoir (OHT)
         • Distribution Network
         • House Connection
         • Electro- Mechanical Works (Pumps, Motors etc)
     2. Non-piped Rural Water Supply Schemes
      -   14,000 Point Water Sources (Contributory fund from users)
      -   6,000 Point Water sources ( Emergency meet up- no contributory
fund)
     3. Rural Sanitation
       - Sanitation in 20 UPs in the rural piped water supply schemes
areas
      4. Regulatory and Oversight Framework and Water Monitoring
2.4 Project Target Areas

As the project is expected to cover all parts of the country where water
quality (including
Arsenic contamination) is an issue in phases, it is necessary to keep in
mind the general
variation in the environmental conditions expected in different parts of
the country. A
brief description of the important environmental resources and
environmental issues are
given in this section.

2.4.1 Physiography and Land-use Pattern

Bangladesh is located between 20O34´ and 26O38´ N, and 88O01´ and 92O41´
E. The area
of the country is 147,570 square km with a coast line of about 700 km in
length. The land
is flat to the extent of about 80% intersected by numerous rivers and
their distributaries.
The land area has a general slope of 1O-2O (5-10cm/km) from north to
south. The soils in
the flat areas mostly (~80%) consist of recent alluvium. The rest 20% of
the area consists
of uplands (~8%) and hill areas (~12%). The uplands consist of Barind
Tract in the north
western part, Madhupur Tract in the central part and the Lalmai Hills in
the east. The
upland soils are derived from old Pleistocene sediments and are typically
reddish or
brownish in color. The hill areas consist of Chittagong Hill Tracts, hill
ranges of
northeastern Sylhet and hills along the narrow strip of Sylhet and
Mymensingh Districts.
The hill soils are derived from tertiary rocks, unconsolidated tertiary
and Pleistocene



15
sediments. Most of the land is used for agriculture. Land use is
generally classified into
five categories as agricultural, forest, cultivable, waste or current
fallow and as ‘not
available for cultivation’. The category of ‘not available for
cultivation’ consists of
mainly of urban, rural settlements and industrial land. Different regions
in the country are
different in respect of Physiography and Land-use pattern. Such
differences would be
recognized in subproject planning.

2.4.2 Hydrology

Bangladesh is the largest delta in the world formed by the Ganges, the
Brahmaputra, and
the Meghna river systems. This delta is characterized by flat terrain
interlaced with the
intricate system of rivers and tidal channels, which carry an enormous
quantity of
sediment-laden water downstream. The three major rivers have a huge
catchment area of
1,554,000 sq km, spreading, over five countries, namely, Bhutan, Nepal,
China, India,
and Bangladesh. There are about 700 rivers, canals, and streams in
Bangladesh, with a
total length of approximately 22,155 km, which occupy a riverine area of
about 9,384 sq
km.

The main river system occupying the delta is formed by the Ganges and the
Brahmaputra,
which are known as the Padma and the Jamuna, respectively once they enter
Bangladesh.
The Jamuna joins the Padma near Aricha, and flows up to Chandpur where it
joins the
Meghna and the combined flow is called the Meghna. It comprises a large
estuary, known
as the Meghna estuary, at the northeastern apex of the Bay of Bengal. The
Ganges,
primarily a meandering stream, is about 2,600 km long, and flows parallel
to the
Himalayan range. It is fed mainly by rivers rising in the southern slopes
of the Himalayas
and enters Bangladesh at the western extremity of Rajshahi region. The
Brahmaputra
arises in Tibet, and flows in an easterly direction north of the
Himalayan range before
turning south through the mountains, it then flows west down the Assam
valley for a
distance of about 700 km, and enters Bangladesh as a wide-braided river,
in the Rangpur
area. The meandering Meghna river drains the Sylhet Basin and parts of
the adjacent
Shillong Plateau, and Tripura Hills.

The rivers flowing   from the hills situated in the southeast of
Bangladesh, namely   Feni,
Karnaphuli, Sangu,   Matamuhuri and Knaaf flow into the Bay of Bengal. The
most
important river in   this region is the Karnaphuli, which is also the
longest at 274 km.

A vast amount of water (1,106 km3)1 flows through Bangladesh mostly
during June-
October. The rivers of Bangladesh also carry huge amounts of sediment, an
estimated 24

1
     http://www.fao.org/nr/water/aquastat/countries/bangladesh/index.stm



16
billion tons/year. These sediments are subjected to coastal dynamic
processes generated
mainly by river flow, tide, and wind actions. The ultimate result are
additional new land
in some places due to accretion, forming islands called chars, and loss
of land in some
other places due to erosion. Bangladesh is also richly endowed with
numerous perennial
and seasonal water-bodies known locally as haors, beels, baors, khals,
pukurs and
dighies. Rivers, canals, beels, lakes, and haors are open wetlands while
baors, dighis,
ponds, and ditches constitute closed ones. The haors are depressions
located between two
or more rivers, and function as small internal drainage basins. The
lowest points of the
haors and beels are lake-like deep depressions retaining water
permanently or for a
greater part of the year. The beels are usually connected to the adjacent
rivers by one or
more drainage channels, locally termed as khals. Baors are oxbow lakes
from the old
meandering bends of rivers that have been cut off from the main stream.
Pukurs and
dighies refer to ponds of various sizes. To these may be added the vast
estuarine systems
and mangrove swamps of the south and southeast regions, as well as
innumerable man-
made water bodies of various sizes. Hydrology of a given area is
extremely important for
any subproject which may have impact up on water bodies. Impact on water
flow by any
subproject would be carefully considered in subproject planning. The
quality of water is
also an important factor in subproject planning.

2.4.3 Ground Water

Below the zone of aeration extending from surface to only a few meters
below the
ground, the soil in Bangladesh is saturated with water. Saturation means
that all pore
spaces in the soil are filled with water and this zone is defined by a
groundwater table.
However, in substantial part of the country the water table goes beyond
the limit of
suction pump (27 ft) particularly in dry season when the irrigation pumps
operate in full
swing. Bangladesh soils consist of unconsolidated sediments and the pore
spaces are
simply the openings between the grains. Lithologic drill logs show layers
of gravel, sands
of different grades, silt and clay down to great depths in succession.
Hydrogeologists classify soil layers as to their ability to yield water
to wells or springs.
A layer which is permeable enough to supply water to wells or springs is
referred to as an
"Aquifer", while an “Aquiclude�? is impermeable and an “Aquitard�? tends
to be very
poorly permeable. The aquifers are sand or gravel layers that may be a
few centimeters to
many meters’ thick. Like other similar areas in the world, the sand
intervals which
constitute the aquifers are probably lens-shaped with varying degree of
lateral and
vertical interconnectedness. This interconnectedness usually decreases
with depth. The
extent of the aquifers may vary from a few km2 to many thousands of km2.
So, a large
aquifer may easily contain a trillion liters or even more water. Even a
small aquifer would
probably contain a couple of billion liters.



17
An aquifer is referred to as confined when it is bounded by aquicludes or
aquitards that
impede flow into it. The primary source of recharge to the aquifers is
assumed to be
historic runoff from the rainfalls. Groundwater is in principle renewable
but in certain
cases the period needed for replenishment (100s to 1000s of years) is
very long in
relation to the normal time-frame of human activity. For this reason, it
is valid in such
cases to talk of the utilization of non-renewable groundwater or the
‘mining of aquifer
reserves’. Water in the confined aquifers can be literally thousands of
years old. This is
the reason for concern about the aquifer systems and their specific
susceptibilities to
negative impacts under abstraction stress. For water balance studies
three and four
aquifer models have been shown to be adequate. However, in reality in
many regions of
Bangladesh more aquifers can be found stacked on top of one another where
from water
can be extracted. The hydrogeology of Bangladesh area has been studied
for more than
fifty years and the details are available elsewhere (Kinniburgh and
Smedley, 2001).

Groundwater is a vital natural resource for the reliable and economic
provision of potable
water supply in both the urban and rural environment. It thus plays a
fundamental role in
human well-being. Until the emergence of the Arsenic problem, groundwater
was hailed
for providing the access to clean drinking water in Bangladesh. It is
necessary to exercise
caution in the large scale exploitation of confined deep aquifers, as
these may be depleted
giving rise serious problems in the future. As Arsenic contamination is
quite extensive for
aquifers in some areas, it is essential to test shallow tubewells for
drinking water to
ensure that Arsenic level in the water is below the national standard. In
general deeper
aquifers have lesser probability of arsenic contamination. However, the
depths having
arsenic free aquifers vary depending on the area. So, it is necessary to
check the Arsenic
content in the aquifer before a production well is established. In case
of BRWSSP arsenic
contaminated aquifer will be avoided as far as possible. In case source
water without
Arsenic is unavailable in a given area, the water will be treated for
Arsenic removal to
comply with the Bangladesh drinking water standard. The details on
Arsenic related
issues are given in Annex-II.

Two types of tubewells namely hand tubewells and mechanized tubewells
will be used in
the project as water sources. In the case of hand tubewells, water
withdrawn is typically a
few thousand liters per day and such extraction can be considered as
insignificant
perturbation unlikely to have any impact on the aquifer. In the case of
mechanized
tubewells for piped water supply, the water production is unlikely to
exceed 500,000
liters per day. Even such production is small compared to aquifer
capacity to impact the
water quality of aquifers. However, there are concerns that in case of
deep aquifers there
may be drawdown of Arsenic contaminated water from shallow aquifers. To
alleviate
such concerns, DPHE has developed sealing procedure to isolate shallow
and deep



18
aquifers for production wells. It may be noted that such drawdown is
highly unlikely as
deeper aquifers have higher pressure and pumping rate is rather small to
have impact on
this pressure.

2.4.4 Ecology

The terrestrial and aquatic ecosystems in the country support a large
number of diverse
biological populations, both plant and animal. The most important
terrestrial ecosystem
in Bangladesh is that of the forests. Large varieties of species exist in
the forest areas and
depend on various biotic and abiotic components of the forest for their
survival. The total
land under forest in Bangladesh is about 2.56 million ha, which includes
officially
classified and unclassified state lands, and forestlands accounted for by
village forests
and tea or rubber gardens. Although a significant part of the existing
forest area is
designated as State Forest, most of this land is actually barren of tree
vegetation. In terms
of per capita forestland, Bangladesh ranks amongst the lowest in the
world. The forests of
Bangladesh have been disappearing at an accelerating rate.

The Sundarban forest areas support a very rich and diverse fauna and
flora. These are:
mammals (49), reptiles (87), birds (355), amphibians (14), fishes (237),
crustaceans (38),
mollusks (34), insects (240) and over 220 species of plants. It is an
important staging and
wintering area for migratory shore birds, gulls, and terns. The
Sundarbans are the habitat
of the Bengal Tiger probably the most notable of Bangladesh's fauna
species. However,
many small members of the cat family are found throughout the forest
areas.

Wetlands are invaluable components of the environment and bio-diversity
in Bangladesh.
Bangladesh possesses considerable wetland areas, among which the
principal ones are
rivers and streams, freshwater lakes and marshes, including haors, baors,
and beels, water
storage reservoirs, fish ponds, flooded cultivated fields, and estuarine
systems with
extensive mangrove swamps. The coastal and inland wetlands encompass the
vast
floodplains and delta system of the Ganges, Meghna and Brahmaputra
rivers. The total
area of the wetlands in the country has been variously estimated at seven
to eight million
hectares, or about 50 per cent of the total land surface. The wetlands in
Bangladesh are
increasingly being recognized as habitat and refuge for a large variety
of wildlife, and a
safe nesting site for avifauna. The marsh vegetation associated with
wetlands also forms
important breeding areas for a wide variety of waterfowl, and roosting
places for a large
number of resident and migratory birds.

The nutrient products of wetlands in Bangladesh are carried by rivers and
floodwater, and
benefit the systems downstream. The grazing systems in these regions
support cattle that
recycle nutrients, enrich soil, and are used as draft animals. The plant
diversity provides
refuge for predators of pests, e.g., snakes, frogs, and certain fish
species, and this helps


19
agriculture in general. Bangladesh does not possess adequate
infrastructure for sewage
treatment and the wetlands function as natural system for the treatment
of pollutants. The
wetlands of Bangladesh are being drastically affected by the impacts of
the increasing
human population. The wetlands are being lost to flood control, drainage
and irrigation
development. Severe erosion in the catchment areas is causing increased
siltation, and
having major impacts on the key wetland areas. The exploitation of the
haor wetland
ecosystem began due to ever-expanding agrarian settlements, and they are
being
reclaimed as agricultural land for production of rice. The beels are
being drained, and
embankments built to save crops from flash floods. These changes in land
use patterns
have occurred in tandem with a decline in fish and migratory birds. Swamp
forests that
were once extensively distributed are now on the verge of extermination.
As the projects
area covers all of the country, some sub-projects/schemes are likely to
be located in the
forest and wetland areas. As subprojects are small, likely impacts of
these on the ecology
are expected to be small. However, impact minimization on ecology would
be a
cornerstone in subproject design. In case environmental assessment shows
any significant
environmental impacts in any proposed scheme, such schemes will not be
funded under
the project.

2.4.5 Environmentally and Ecologically Sensitive Areas

Environmentally sensitive areas are defined as being areas that are of
significant value in
their natural state, or areas that are of socio-cultural significance or
sensitivity. Cultural
or historical sites and densely populated urban centers are examples of
the latter category.
Ecologically Sensitive Areas can be defined as areas that may contain
unique features,
maintain key natural processes, support endangered, endemic or threatened
plants or
animals and their habitats, or provide important breeding areas for
wildlife. Some
Ecologically Sensitive Areas are natural, while others may have been
significantly altered
by certain human activities. In terms of management, some Ecologically
Sensitive Areas
will prosper when left undisturbed while others will require intensive
management to
restore or maintain their natural values.

The ECA 1995 refer to Environmentally Sensitive Areas as Ecologically
Critical Areas.
According to this legislation, environmental protection is deemed
particularly relevant in
Ecologically Critical Areas, which are defined as areas where degradation
of the
environment has reached or threatens to reach a critical state. In the
sensitive areas,
environmental and ecological impacts tend to be more severe than
elsewhere, and
therefore, extra precautions must be taken to avoid significant
environmental impacts. In
many cases, this will mean extra investments in mitigation measures,
while in some cases
these areas will simply have to be avoided, resulting, for example, in
the abandonment of
a subproject or the re-alignment of a section of road.



20
2.5 Main Environmental Concerns in project areas

The key environmental concern in the present project is the Arsenic
contamination in the
groundwater which will be taken up in the next section. The other
environmental
concerns for rural and small urban and peri-urban areas in Bangladesh
include:
         •         Flooding
         •         Drainage
         •         River bank erosion
         •         Surface water quality
         •         Seasonal fluctuations in ground water table
         •         Groundwater quality
         •         Saline intrusion (coastal areas)
         •         Wetland deterioration
         •         Land degradation
         •         Ambient Air Pollution
         •         Indoor Air Pollution
         •         Forestry management
         •         Biodiversity conservation
         •         Fish and fisheries resource management

2.6 Arsenic Contamination of drinking water in Project areas

As this is an issue of important public health concern, it is discussed
separately here. In
case, where existing tubewell are mostly arsenic contaminated, arsenic
mitigation option
such as deep tubewell, ring well, pond sand filter will be explored
first. In this case,
arsenic treatment will not be required. However, as a last assort, if
removal of arsenic is
required, the water will be treated for Arsenic removal to comply with
the Bangladesh
drinking water standards. Removal of Arsenic from contaminated
groundwater to the
level less than the current Bangladesh standard of 0.05 mg/L can be
achieved using
proven methods and technologies. A whole plethora of treatment options
are available
such as conventional treatment (coagulation, co-precipitation with Fe/Mn,
and softening),
sorption processes (activated alumina, ion exchange, iron-oxide-coated
sands) and
membrane processes (nano-filtration, reverse osmosis, ultra-filtration,
micro-filtration).
Pre-oxidation of arsenite to arsenate has been found to be helpful in
most of the
processes.
The conventional Fe/Mn removal plants also remove As and this method is
most likely to
be used as there is a considerable body of local experience on this type
of plants in
Bangladesh, this process also removes Arsenic is most likely to be used
here and it is
highly cost effective. In the process of removal of iron and manganese,
arsenic is also
removed as it binds to Fe. If the naturally occurring amount of iron and
manganese is not


21
enough to get the desired arsenic removal, more iron may be added but
this will be
probably unnecessary in Bangladesh as ground water in Arsenic
contaminated areas also
have high iron content. Pre-oxidation using aeration is the common method
convert
arsenite to the more perceptible arsenate form but other methods such as
potassium
permanganate or hydrogen peroxide may also be used. Sludge from As
removal process
can also be an issue but can be handled safely if appropriate procedure
is used. The
details on Arsenic related issues are given in Annex-II.




3.     Environmental Policies, Laws and Rules

This section describes relevant national environmental management
requirements and as
well as the World Bank safeguards policies applicable to the Project and
its subprojects.
In each case, national and local institutions that will be involved in
reviewing and
approving subprojects identified, along with their respective roles and
responsibilities.
Responsibilities may include issuing approvals for undertaking a
subproject and ensuring
compliance to obligatory requirements under laws and regulations.

As stated earlier, the World Bank EA category assigned to the Project is
B A brief
description of the relevant World Bank safeguard policy is provided to
explain how their
requirements will be complied with or used.

3.1 Bangladesh Legal Framework

The requirements for compliance with environmental regulations are laid
down by the
policy, legal and regulatory framework in the country. A large number of
laws related to
environmental issues, some dating back to 19th century exist in
Bangladesh. The most
important of these are the Environment Conservation Act, 1995 (ECA95) and
the
Environment Conservation Rules (under the ECA, 1995), 1997(ECR97). Many
of the
other laws are cross-sectoral and are only partially related to
environmental issues. Most
of the old legislations have become largely obsolete also with the
promulgation of
ECA95 and ECR97.           The relevant laws and regulations related to
important
environmental issues in Bangladesh are shown in table 2.

3.2 Environmental Guidelines for Projects in Bangladesh

As pointed out earlier the most important of the laws/rules in table 2,
are the ECA95 and
the ECR97. The ECA95 is primarily an instrument for the Department of
Environment



22
(DOE) and for controlling industrial pollution. The Act also includes
‘Polluter Pay
Principle’ in general terms in that as it states "if any particular
activity is causing damage
to the eco-system, the responsible party will have to apply corrective
measures". The
ECR97 was promulgated under ECA 95 to operationalize the enforcement of
the Act.
The modifications to ECR can be brought about by executive orders
requiring no new
legislation. Thus, the rules can be modified from time to time when sound
technical
reasons exist without going through the long drawn legislative process.




23
      Table 2: Environmental Issues and Relevant Laws and Regulations in
Bangladesh

Issues            Laws/Regulations                  Enforcing
Regulated/Enforced Items
                                                    Agency
Water pollution   • ECA, 1995                       MOEF/DOE
Promulgation of standards for water
                  • ECR 1997                               ,,        quality
                  • Environmental Court      Act,          ,,
Promulgation of discharge limits
                    2000                                    ,,
Prosecution of offenders
                  • The Local Government               UPs           Control
of Environmental sanitation
                    Ordinance, 1983                                  in rural
areas
Air pollution     • ECA, 1995                       MOEF/DOE
Promulgation of standards for air
                  • ECR 1997 (amended 2005)            ,,            quality
                  • Environmental Court Act,           ,,
Promulgation of emission standards
                    2000                                ,,           for
Motor vehicles and industries
                  • Brick Burning Control Act,         ,,
Prosecution of offenders
                    1989 (Amended 1992)
                                                    BRTA/Police
Prosecution of offending vehicles
                  • Motor Vehicle Act, 1983
Noise pollution   • ECA, 1995                       MOEF/DOE
Promulgation of standards for noise
                  • ECR 1997                               ,,        levels

Toxic or          • ECA, 1995                       MOEF/DOE
Promulgation of      standards       and
hazardous waste   • ECR 1997                           ,,
management rules.
pollution         • Nuclear Safety and Radiation
Solid waste         Protection Ordinance, 2000      BAEC
Promulgation of standards and rules
pollution                                                            for
management of radioactive

materials.

Marine            • ECA, 1995                       MOEF/DOE
Promulgation of standards for water
pollution         • ECR 1997                                         quality
                  • Environmental Court Act,                    ,,
Promulgation of discharge limits
                    2000
Prosecution of offenders
Pollution of      • The     Protection   and          MOLF
Promulgation of regulatory measures
fisheries           Conservation of Fish Act,
                    1950

Pesticides and    • The Agricultural Pesticides       DA          Approval
of permissible pesticides
fertilizers         Ordinance, 1971

Forest            • ECA, 1995                      MOEF/DOE
Declaration of Ecologically Critical
conservation      • ECR 1997                          ,,          Areas
                  • The Forest Act 1927                           Reserve
Forest, protected Forest,
                                                   MOEF/DOF       Village
Forest

Wildlife          • ECA, 1995                      MOEF/DOE
Declaration of Ecologically Critical
conservation      • ECR 1997                                      Areas
and national      • The Wild Life (Preservation)             ,,
parks               (Amendment) Act, 1974




24
Depending on the extent of impact on the environment, industries and
projects are
classified in four different categories under the ECR 1997. The four
categories are:
Green, Orange A, Orange B and Red. The procedures for obtaining
‘Environmental
Clearance (EC)’ for different categories of projects are also provided in
the ECR. Green
category industries are to be granted EC within 15 days. The Green
Category Schedule
does not list specific projects. For other categories, schedules
containing lists of
industries and projects are provided in the ECR. For Orange A & B and Red
category of
industries and projects, an application for EC must include a
‘Feasibility Report (FR)’
and an ‘Initial Environmental Examination (IEE)’ report. A Process Flow
Diagram and a
Layout Plan are also needed for industries. IEE report must include a
‘Terms of
Reference’ for the Environmental Impact Assessment (EIA) for Red Category
industries
and projects. An EIA report is mandatory for final approval and issuing
of an
‘Environmental Clearance’ for Red Category industries and projects. The
ECR, 1997 lists
the contents required for both IEE and EIA reports. Table 3 lists project
types included in
the ECR and categories. Although, it is not clearly specified in the
rules, DOE does
provide clearance to EMF for projects with multiple sub-projects having
small
environmental footprints.
           Table 3: ECR Environmental Categories for projects and
industries*

Category        Sub-projects/           Clearance    WB project Comments
                Industries              Requirements Category
Green           • No Projects           None         C          • Only
local authority clearance needed
                    Listed in the                               • Many
BRWSSP subprojects (point
                    ECR (Only
sources and household sanitation
                    Industries)
units) will in this category and should
                                                                       not
require any environmental

clearance from DOE.
Orange A        • Small-scale           IEE,           B
Although small scale piped water
                  industries            Feasibility
supply is not listed under this
                                         Report
category, Considering the impacts, the

BRWSSP subprojects are likely to fall
                                                             in
this category.
Orange B        • Medium                 IEE,          B
BRWSSP subprojects can be classified
                    Scale                Feasibility         in
this category also as water
                    industries           Report
purification plants fall under this

category (i.e., Sl. 28 of the list).
    Red         • Water                  IEE,          A/B   This
is a category for large scale water
                  Treatment              Feasibility
treatment plant and BRWSSP
                  Plant                  Report, EIA
subprojects are not expected in this

category
* Full list available in schedule-1 of ECR97.




25
3.3 Environmental Category for BRWSSP

In keeping the historical precedence in the country, the BRWSSP
subprojects are to be
classified into 3 categories as shown in table 4.

• ‘C’ those whose expected impacts are small in scale, do not require
special study
  other than ER, and can be addressed through standardized environmental
techniques
  or technical methods. ER in these cases should be performed using a
screening list.
  The point sources are likely to fall in this category.

• ‘B’ those whose impacts are larger and more complex, requiring
preparation of a
  Limited Environmental Assessment (LEA) and incorporation of recommended
  mitigation measures into subproject design. The piped water supply
schemes are likely
  fall in this category.

• ‘A’ those whose potential impacts involve significant environmental
risk, and these
  will not receive funding under the BRWSSP.
   Table 4: Subproject Environmental Categories in BRWSSP and WB
guidelines
      Category Attributes                   GOB      World Bank
EA Process
                                          category    category
Subprojects likely to have some minor      Green         C
Environmental Review (ER) by
impacts on the environment but for
proponent and clearance by
which sufficient standard mitigation                              PMU.
measures have been identified
Subprojects that have some moderately     Orange         B        ER by
the proponent, Limited
significant environmental impacts, for
Environmental Assessment
which mitigation measures can be          A&B,                    (LEA)
by qualified individuals
readily identified                         Red                    and
clearance by PMU once
                                                                  EMF is
cleared by DOE.
Subprojects that potentially have           Red          A
Subprojects in this category will
significant impacts on the environment;                           NOT be
eligible for BRWSSP
(mitigation measures may be identified,                           funding
but there remains a risk of significant
impacts)
3.4 International Obligations

Bangladesh is party to a number of international environmental
conventions, treaties and
protocols. These have to be taken into account in the implementation of
BRWSSP
subprojects where applicable. In the implementation stage of the project,
NGOs and
Citizens Groups may invoke these agreements if they have concerns on
infringements.
These agreements are summarized for in the following:

   • International Plant Protection Convention, Rome, 1951 (Ratified
1978)



26
   • International Convention for the Prevention of Pollution of the Sea
by Oil, London,
     1954 (Ratified 1981)
   • Convention on Wetlands of International Importance, especially as
Waterfowl
     Habitat, Ramsar, 1971 (Ramsar Convention) (Ratified 1992)
   • Convention Concerning the Protection of the World Cultural and
Natural Heritage,
     Paris, 1972 (World Heritage Convention) (Ratified 1983)
   • Convention on International Trade in Endangered Species of Wild
Fauna and Flora,
     Washington, 1973 (CITES Convention) (Ratified 1982)
   • Agreement on the network of Aquaculture Centers in Asia and Pacific
(NACA),
     1988
   • Montreal Protocol on Substances that Deplete the Ozone Layer,
Montreal, 1987
     (Ratified 1990), (London Amendment, 1990) (Ratified 1994)
   • Convention on Biological Diversity, Rio de Janeiro, 1992 (Ratified
1994).
   • International Convention to Combat Desertification, 1994.
   • Basel Convention on the Control of Transboundary Movements of
Hazardous
     Wastes and their Disposal, Basel, 1989 (Ratified 1993)
   • United Nations Framework Convention on Climate Change, New York,
1992
     (Ratified, 1994)

3.5 Bank's Environmental guidelines

The World Bank has mandatory EA guidelines in the form of OP/BP/GPs. The
World
Bank has several policies governing environmental assessment (EA) of
projects.
OP/BP/GP 4.01, issued in January 1999, is the central document that
defines the Bank's
environmental assessment requirements. This directive outlines Bank
policy and procedures
for the environmental assessment of Bank lending operations.
Environmental consequences
should be recognized early in the project cycle and taken into account in
project selection,
sitting, planning, and design by preventing, minimizing, mitigating or
compensating for
adverse environmental impacts and enhancing positive impacts. EA includes
the process
of mitigating and managing environmental impacts throughout project
implementation.
The Environmental Assessment Sourcebook (1993) and its updates (1996,
1997) provide
technical guidance on these issues.

In addition to OP/BP/GP 4.01, there are other directives that cover a
number of specific
environmental issues which may be optionally used in this project. These
are OP 4.04
(Conservation of Natural Habitats), OP 4.09 (Pest Management),OP
4.36(Forestry
Management) and OP 7.50 (Projects on International Waterways). As the
project area
covers the whole of country, there is likelihood that these policies may
be applicable to a
scheme. Such a scheme will not be implemented in the BRWSSP.




27
A screening process for all World Bank projects classifies them into one
of three
environmental assessment categories. Projects in Category "A" potentially
cause
significant and irremediable environmental impacts. Category "B" projects
cause lesser
impacts, which are often essentially remediable or can be mitigated.
Category "C"
projects can be expected to have little or no environmental impact.
Category A projects
require a full, detailed Environmental Impact Assessment, which needs to
be approved
before the Bank can give its support. Category B projects require the
implementation of
an Limited Environmental Assessment (LEA, which requires far less details
than an EIA.
Category C projects do not require an LEA or EIA.

The BRWSSP has been classified as Category "B" because as a whole, as it
may result in
only small-scale, and remediable impacts. In practice, most
subprojects/schemes (i.e.,
point sources) are likely to be belonging to Category C. In some cases
(i.e., RPWSS)
subprojects will fall under Category B, and subprojects that fall under
Category A will
not be eligible for funding under BRWSSP. The equivalence of Bank
guideline
categories and those of BRWSSP are shown in table 4.

The present EMF deals with project specific application of Bank polices
outlined above.
The draft EMF has now been disclosed in country and is now available on
the DPHE
website (www.dphe.gov.bd) along with translation of the executive summary
in Bangla.
It will be disclosed in the Bank’s Info Shop as per World Bank’s
Disclosure Policy prior
to appraisal.

3.6 Bank's Environmental Safeguards

The main purposes of the Bank’s safeguard policies are to (i) avoid harm
to the
environment and affected people and provide affected people an
opportunity to
participate in the development process; (ii) improve project design and
performance; and
(iii) protect the reputation of the Bank. The current set of safeguard
policies cover a broad
range of topics from environmental assessment to natural habitats,
forests, resettlement,
and Indigenous Peoples and others. The policies are the reflection of
international
conventions and internationally accepted principles of good practice in
project
preparation and implementation. Similar principles, supporting the
aspirations for
sustainable development, are generally reflected in policies in most
client countries;
however, implementation is often weak and variable.

From the preliminary review of project activities, it has been determined
that the
Environmental Assessment (OP/BP 4.01) Policy will be triggered by the
proposed project
due to its focus on construction and extension of water supply and
household sanitation
systems. This Environmental Management Framework (EMF) has been prepared
to
identify and assess the potential impacts under different components of
the proposed


28
project. Each sub-project/scheme in the components has to be screened
individually for
potential environmental impacts through ER initially, and will be
subjected to appropriate
Limited Environmental Assessment (LEA). As appropriate detailed design of
the project
components for carrying out component specific LEAs will be available
during project
implementation only, the system to support the process of environmental
review and
clearance is defined through this Environmental Management Framework
(EMF). As OP
4.01 is triggered and the possibility of triggering OP 7.50 was
considered in the project,
these are discussed in some details in following sections.

3.6.1 Environmental Assessment and OP 4.01

The World 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. 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,
sitting, 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.

The investments pertaining to improving water and sanitation are likely
to cause minor
and reversible environmental impacts, which can be managed through
appropriate
mitigation measures. Considering the nature and magnitude of potential
environmental
impacts from relatively limited scale and magnitude of reconstruction
works, the project
is classified as category ‘B’ on an overall basis. As the exact nature
and location of these
investments are not yet fully known at the time of project preparation,
this EMF is
presented as the safeguard document, adherence to which will mitigate the
environmental
risks. This includes environmental procedures and requirements. This EMF
includes
procedures for ensuring compliance to legislations on environmental
requirements to be
adhered to during the construction and also in the monitoring & reporting
arrangements.


At project level, the impact of the project on groundwater resources can
be assessed by
the number of tubewells currently operated in the country which consists
of about 1.33 million2
mechanized tubewells and 8.61million hand tubewells. Only about 250
mechanized tubewells
and 20,000 hand tubewells will be involved in BRWSSP, which is miniscule
compared to current
activities in the groundwater sector in this country. The amount of water
involved in the
project is only a very small addition to the current rate of abstraction
to have any




29
significant impact. However, if it is considered that the project is
replacing contaminated
water supplies with piped and clean water, there should be no impact at
all.


3.6.2 Projects on International Waterways and OP 7.50




The project is groundwater based and does not involve or has any impact
on International or any
other Waterways. Current activities in the groundwater sector both in
Bangladesh and India are
thousands of times larger and these activities have not impacted
waterways in any significant
way over the period of several decades. The zones of impact of the
tubewells involved in the
sub-projects are expected to be less that 50 meters on the groundwater
aquifers. So, in order to
avoid any adverse impact on possible water use in neighboring countries,
no tubewells will be
located within 500 meters of the international boundary. Thus, it is
assessed that this policy
should not be triggered in the project.


3.6.3 Environmental Management in Sub-projects

Once the project goes into implementation, the DPHE and its partners that
will
implement the subprojects on the ground, will be required to prepare and
implement the
activities according to the stipulations adopted in this EMF. The PIC is
likely to be
supported by services of environment specialists to screen the individual
subprojects and,
if required, prepare and implement the impact mitigation plans.
Responsibility for
conducting an EA that meets the requirements of the DOE and World Bank
will rest with
the PMU in DPHE. The Bank team will review EA related documents
periodically.

3.6.4 Environmental Screening

Screening is necessary to decide whether or not a particular investment
should be
undertaken from an environmental perspective and classify the sub-project
according to
regulatory requirements both national and Bank guidelines. The extent of
environmental
work that might be required prior to the commencement of the sub-projects
will depend
on the outcome of the screening process described below.

The PIC is responsible for the screening of each sub-project under the
project. PIC will
carry out the screening by completing the Environmental and Social
Screening Form
developed (by consultant under PMU) for the purpose. Completion of this
screening
form will facilitate the identification of potential environmental and
social impacts,
determination of their significance, assignment of the appropriate
environmental


2
     http://www.fao.org/nr/water/aquastat/countries/bangladesh/index.stm


30
category, proposal of appropriate environmental mitigation measures, or
recommend the
execution of a Limited Environmental Assessment (LEA), if necessary.
3.6.5 Classification for EA and Procedures

Once the environmental screening is done, the subprojects can be
categorized according
to both Bangladesh and WB requirements. There are prescribed procedures
for
processing different category projects in the Bangladesh law and rules as
given in table 4.
In addition to that, WB requirements over and above the prescribed
procedure in the
Bangladesh law will also need to be followed. In Bangladesh, the
Department of the
Environment (DOE) is the authority responsible for providing
environmental clearances.
The effectiveness of this process is still constrained due to a lack of
transparency and
consultation, as well as the rather limited resources of the DOE.
However, in the current
project, the subprojects are expected to have only limited environmental
footprint as such
the PMU will approach the DOE for the approval of this EMF rather than
IEE/EIA for
individual subprojects. It may be noted that there are instances in which
DOE has
provided umbrella clearance to EMF type documents.


4. Requirements on Environmental Clearance in Bangladesh

4.1 General Procedure for EA

In Bangladesh the EA procedure has three tiers which are:

               Screening;
               Initial Environmental Examination (lEE); and
               Detailed EIA

Screening as explained earlier decides whether the EIA process should be
applied to a
development project and if it is required, it’s type i.e. IEE &/or EIA or
limited EIA.

All industries and projects listed in “Red�? category are required to
carry out IEE and
subsequent EIA. In order to fulfill the requirement of DoE, it is
required to conduct EIA,
which should include the following:

               Identification of impacts of the project activities, both
during construction
                 and operational stages, on the various environmental
components and
               recognizes those which are critical to the changes.
               Prediction of the environmental impacts using qualitative
and if possible,
               quantitative methods.
               Recommendation of EMP to reduce adverse environmental
impacts and


31
                  enhance positive contributions of the project.
                  Presentation of the results of environmental impact
identification,
                  prediction and assessment, with suggested mitigation
measures.
                  To set the basis for continuous monitoring of key project
activities and
                  environmental conditions.

The legal requirements for EA under different categories are described in
detail in the
ECR97 Schedule-1. Procedure and guidelines for different categories of
the projects are
briefly given here for ready reference. For any projects, the sponsor or
PMU needs to
obtain the clearance from the DOE in two stages explained earlier:
      a. Initial Stage:   Site Clearance Certificate (SCC)
      b. Advanced Stage: Environmental Clearance Certificate (ECC)
The requirement for SCC is the IEE report and EIA or limited EIA are
needed for the
ECC. Upon receiving site clearance, the proponent can undertake land
development and
infrastructure development programs, and can install machinery for Orange
category
projects. However, the industrial units or projects can’t get gas
connection to go for trial
production.

4.2 Application for Environmental Clearance – Green Category

Applications for the environmental clearance for industries and other
projects listed under
category ‘Green’ need the following documents:

       I.        General information pertaining to the industry or project;
       II.       Description of the product along with that of the raw
material; and
       III.      No objection certification (NOC) from the local authority.

4.3 Application for Environmental Clearance –Amber B & A Category

Applications for the environmental clearance for industries and other
projects listed under
categories ‘Amber B & A’ need the following documents:

       I.       General information pertaining to the industry or
project;
       II.      Description of the product along with that of the raw
materials;
       III.     The process flow diagram;
       IV.      The layout plan (indicating the site for effluent
treatment plant);
       V.       Waste disposal system;
       VI.      Outlines of relocation, rehabilitation plan (where
applicable);
       VII.     Other relevant information (where applicable);
       VIII.    Feasibility Study Report of the industry or project
(applicable only for



32
             proposed industries or projects);
       IX.   Initial Environmental Examination (IEE) Report with the
process flow
             diagram, layout plan (indicating the site for effluent
treatment plant),
             design of the effluent treatment plant (applicable only for
proposed
             industries or projects);
       X.    Environment Management Plan with process-flow diagram,
layout plan
             (indicating the location of effluent treatment plant),
design and efficiency
             of the effluent treatment plant (applicable only for
existing industries or
             projects);
       XI.   No-objection certificate (NOC) from the local authority;
       XII. Contingency plan in respect of adverse environmental impacts
together
             with plan to reduce pollution load;
       XIII. Outlines of relocation, rehabilitation plan (where
applicable); and
       XIV. Other relevant information.

4.4 Application for Environmental Clearance – Red Category

Applications for the environmental clearance for industries and other
projects listed under
category ‘Red’ need the following documents:

       I.      Feasibility Study Report of the industry or Project
(applicable only for
               proposed industries or projects);
       II.     Initial Environmental Examination (IEE) Report together
with the terms of
               reference of Environmental Impact Assessment (EIA). and
the process-
               flow diagram of the industry or project, or, the
Environmental Impact
               Assessment (EIA) Report prepared on the basis of terms of
reference
               approved earlier by the Department of Environment, layout
plan
               (indicating the site for effluent treatment plant), design
and time-schedule
               to construct the effluent treatment plant, process-flow
diagram (applicable
               only for proposed industries or projects);

       III.    Environment Management Plan (EMP) together with process-
flow
               diagram, layout plan (indicating location of effluent
treatment plant),
               design and efficiency of the effluent treatment plant
(applicable only for
               existing industries or projects);
       IV.     No-objection-certificate (NOC) from the local authority;

       V.      Contingency plan in respect of adverse environmental
impacts together
               with plan to reduce pollution load;
       VI.     Outlines of relocation, rehabilitation plan (where
applicable); and



33
       VII. Other relevant information.
4.5 Validity Periods for Environmental Clearance Certificates


         Categories of Project       Validity              Renewal Period
         Green                       1 year
                                                           30 days before
expiry
         Orange A & B                1 year
                                                           of the validity
period
         Red                               3    year




5.       Subproject Preparation, Approval and Monitoring

In this section, the process for addressing the environmental concerns
through the
institutional arrangements and procedures used by the Project for
managing the
identification, preparation, approval and implementation of subprojects
are discussed.
The generic steps discussed below (Sections 5.1 through 5.5) are similar
for all
subprojects. It is crucial that the procedures are clearly linked to the
project-defined
subproject cycle so they can be readily included in, or referenced from,
the Project
Implementation Guidelines.

5.1      Subproject Document Preparation

Taking into consideration the learning from different earlier projects in
the Bangladesh,
BRWSSP has been designed to address environmental concerns during
subproject
preparation and these are described here in some detail.

In general, it is expected that DPHE team will work with agencies in
relation to
subprojects/schemes (i.e., sponsors, NGOs/CBOs etc) in preparing ER/LEA
documents
to avoid or minimize adverse environmental impacts. An ER checklist
(i.e., Form 1 in
Annex I) together with information on typical project impacts and
mitigation measures
will be used to carry out this work. The aim of the checklist is to
assist in identifying
potential impacts based on field investigations. The standard approach
for community
participation methods in the project will be used to address the
environmental concerns
also. The ER checklist identifies the potential impacts of the
subprojects; describes the
measures that can be built into a subproject to address these impacts.
The completed ER
checklist must be preserved along with other project documentation or any
additional
reports that may be required (e.g. LEA (Form 2 in Annex I) for category-B
subprojects).



34
The checklist contains a certification by the subproject preparation team
that all measures
required to avoid or minimize adverse environmental impacts are included
in the
subproject design. In some situations for the most effective use of
resources, it may be
appropriate to prepare any needed additional reports (e.g. LEA) after a
subproject
proposal has been approved in principle. In these situations, a
subproject cannot be
finally approved and funded until such reports are received and approved.

It is advisable to use skilled personnel for special reports (e.g. LEA)
preparation.
Although, these require extra resources to prepare, these studies and
reports may be
worth the extra effort for an otherwise excellent subproject. In these
cases, the subproject
committee should discuss the issues involved with the local authority to
confirm the need
to carry out the work.

To satisfy the requirements of the Bank’s safeguards policies, it should
be emphasized
that in some subproject situations mitigation measures will be need to be
specified more
precisely than others, either in the application or as an annex to it. It
is expected that,
with project training, the DPHE teams will be able to assist subproject
sponsors in
adequately addressing these situations, when preparing their
applications.

5.2    Appraisal and Approval

This section focuses on the procedures that will be used when reviewing
and then
approving subproject applications. These procedures need to be consistent
with
applicable national approval procedures. They also need to be integrated
into the planned
project process of approving subprojects. The roles and responsibilities
of various
authorities at different levels, as appropriate and subproject sponsor
are illustrated in
table 5.
The procedures first specify how the review authority determines whether
a subproject
proposal, along with the completed ER checklist and any appropriate
required reports
already prepared, can be cleared for approval. The first step is an
appraisal to determine
if all the relevant information has been provided, and if these are
adequate.
From an environmental point of view, the review authority needs to
determine if it is
satisfied that the subproject sponsor has thoroughly considered all
potential adverse
effects of the subproject, and included measures in the subproject plan
to adequately
address them.
If the appraisal indicates that the proposed subproject may have
environmental concerns
that are not adequately addressed in the proposal, or if the application
does not meet
certain criteria, the review authority (PMU) may requires a field
appraisal before the
application can be considered further. The criteria for a field appraisal
report are given in
table 6.


35
36
           Table 5: ENVIRONMENTAL ASSESSMENT AND MANAGEMENT FRAMEWORK

  Milestones        Objectives                        Process
Responsibility Decision/Product

1. Subproject Screening
   Environment Scope                   •   Review of the subproject proposal
•      Proponent   •      Assign
   al Scoping     subprojects              by trained resource persons from
and PMU            Environmental
                  from                     DPHE to assign an Environmental
Category to
                  environmental            Category to it.
subproject
                  perspective

Environmental        Screen            •   Review of the subproject proposal
• Completed
 Screening           subprojects           using trained resource persons
• Proponent            ER form for
                     from                  from to fill the ER Form for
and PMU                subproject
                     environmental         Category ‘C’.
proposal
                     perspective       •   Review of the subproject proposal
                                           using trained resource persons to
•      Proponent
                                           fill the ER Form and produce a
and PMU          •        LEA Report
                                           LEA report for Category ‘B’.
for subproject

proposal

2. Subproject Appraisal
   Detailed      Appraise         • Review ER for category C subprojects
•     PMU          • Confirmation
   Environment environmental        by DPHE.
of
   al Appraisal components of
Environmental
                 subproject       • Review LEA by DPHE for category B
category.
                                    subprojects
•     PMU           • Sub-project
                                  Conduct site visits to Crosscheck:
Appraisal
                                  - type of Environmental issues;
Report with
                                  - magnitude of Environmental issue;
decision to:
                                  - adequacy of Environmental
                                    management measures provided;
-     accept project
                       - cost of implementing Environmental
as submitted
                        management measures;
-     accept
                       Suggest:
project with
                       - modifications to be incorporated in
modifications
                        environmental l components of the
-     reject project
                         subproject;
                       - appropriate changes in other
                         components of subproject;
                         Finalize environmental components
                         as part of project appraisal report.




37
                      Table 6: Criteria for Requiring a Field Appraisal

 Criteria                                             Field Appraisal
 1. A subproject may affect a protected area or a     A field appraisal
determines if the subproject will
 natural habitat                                      adequately avoid
adverse effects on the protected
                                                      area or natural
habitat.
 2. A subproject may have an impact on                A field appraisal
determines the scale and level of
 ecologically sensitive ecosystems (e.g. wetland or   impact. The
application may need to be revised to
 marshes)                                             describe how the
subproject will avoid or minimize
                                                      adverse impacts to
ecologically sensitive areas.
                                                      This may require a
distinct LEA.
 4. A subproject may involve, or result in:           A field appraisal
determines the scale and level of
                                                      potential impact.
The application may need to be
 •    Production of waste (e.g., Arsenic laden        revised to avoid or
minimize potential adverse
      sludge);                                        effects, and may
include a LEA.




Based on the appraisal and, if needed, the field appraisal, the review
authority may
approve a subproject with recommended conditions and implementation
supervision
(e.g., Arsenic laden sludge disposal).

5.3       Annual Reports

PMU will be required to report annually on their subproject activities
during the
preceding year. These annual reports should capture the experience with
implementation
of the EMF procedures.
The purpose of these reports is to provide:
    • A record of the subproject transactions;
    • A record of experience and issues running from year-to-year
throughout the
        subproject that can be used for identifying difficulties and
improving
        performance; and
    • Practical information for undertaking an annual review.

5.4       Annual Reviews
The scope of work and procedures for carrying out annual reviews of the
implementation
of the EMF in the subprojects are specified here. The purpose of the
reviews is two-
fold:

      •   to assess compliance with EMF procedures, learn lessons, and
improve future
          EMF performance; and
      •   to assess the occurrence of, and potential for, cumulative
impacts due to project-
          funded and other development activities.



38
It is expected that these reviews will be carried out by the Bank’s task
team or an
authorized third party not involved in the subproject implementation. If
third-party annual
reviews are involved, these reviews will be the principal sources of
information to project
management for improving performance, and to the World Bank supervision
missions.
Thus, they should be undertaken after the annual report has been prepared
and should be
available for Bank supervision of the Project.



6.     Environmental Management Plan

This section describes how subprojects will respond to the needs for
environmental
management (OP4.01), including pest management(OP4.09) and the
conservation of
protected areas, natural habitats(OP4.04), forests (OP4.36) and physical
and cultural
resources (OP 4.11). The types of subprojects which will be implemented
in the project
are shown in table 7.

           Table 7: Type of subprojects and their environmental category.

Sub-project Types in Rural         Environmental   Environmental
Comments
Piped Water Supply Schemes         Category        Category(GOB)
(RPWS)                             (Project/WB)
1. Rural Piped Water Supply              B            Orange-B        If
DOE clearance
Schemes (RPWS)                                        (Item-28)       for
EMF is
Major Components in each:
obtained, clearance
                                                                      for
individual sub-
•      Test Tube Well ( 2 nos.)
projects may not be
•      Production Well ( 2 nos.)
needed.
•      Pump House/Office Room
•      Treatment Plant (if
           required)
•      Water Reservoir (OHT)
•      Distribution Network
•      House Connection
•      Electro- Mechanical
           Works (Pumps,
           Motors etc)
2. Non-piped Rural Water Supply   C   Green   DOE
clearance not
Schemes
required
Point Water Sources (Hand
Tubewells)
3. Rural Sanitation               C   Green   DOE
clearance not
Individual household Sanitary
required
Toilets



39
The primary goal of this project is the supply of clean water for
drinking. So, it is
imperative that water quality should be analyzed in a quality assured
manner, so that
water quality meets the regulatory Bangladesh Standards for water
quality. Because of
its importance water quality analysis is is discussed separately under
section 6.2.
6.1 Subproject Planning

The subproject planning should strive for plans and designs that avoid
creating adverse
environmental impacts that have to be explicitly managed. “Environment�?
is broadly
defined to include the natural environment (air, water and land), and
human health and
safety. At the time of the implementation of any sub-project, the
potential environmental
impacts must be clearly identified and if needed an Environmental
Management Plan
(EMP) formulated, implemented and the plan’s performance monitored during
and after
execution of project activities. The impacts should be avoided or
neutralized where
possible or mitigated in conformity with Bangladesh’s and the World
Bank’s
prescriptions for sound environmental management.

For C category subprojects only ER is required. A screening format (Form
1) for ER/IEE
is given in annex I. The subproject design should ensure that
environmental concerns are
taken care of and this is verified in the approval process and no action
in addition to
project implementation should be necessary. Only in the category B
subprojects where
explicit limited environment assessment (LEA) is required, an
environmental
management plan (EMP) is to be included. A format (i.e., Form 2) for LEA
is given in
annex I .

It should be emphasized that a LEA should fit the needs of a subproject
and be easy to
use. There is no standard format or length. For many small-scale
subprojects, it may be
no more than a few paragraphs or perhaps just a table. On subprojects
with more
significant environmental concerns (e.g. waste management), a more
substantive LEA
may be warranted to highlight its importance.

The basic elements of an LEA are:
   •   A description of the possible adverse effects that the LEA is
intended to deal with;
   •   A description of planned mitigation measures, and how and when
they will be
       implemented;
   •   A program for monitoring the environmental effects of the
subproject -- both
       positive and negative;
   •   A description of who will be responsible for implementing the LEA
measures;
       and
   ���     A cost estimate and source of funds.



40
Community participation is essential in preparing a LEA since local
knowledge is
important in identifying, designing and planning the implementation of
practical
mitigation measures. It is especially important where the success of the
LEA measures
depends on community support and action, both in implementing mitigation
measures
and in monitoring their effectiveness.

In order to make the project effective, environmental management must be
fully
integrated with the overall project management effort, which itself
should aim at
providing a high level of quality control, leading to a project which has
been properly
designed and constructed and functions efficiently throughout its life.
At sub-project
completion a report should be prepared on the implementation of the EMP.

6.2 Water quality analysis and quality Assurance in analysis

Ground water carries with it many substances which may be classified as
biological,
chemical (both inorganic and organic), physical, and radiological
impurities. These
substances may give water a bad taste, color, odor, or cloudy appearance
(turbidity), and
cause hardness, corrosiveness, staining, or frothing. Some of these
substances are harmful
to human health or transmit diseases. In a drinking water supply system,
the harmful
substances are removed or rendered harmless. One means of establishing
and assuring the
purity and safety of drinking water is to set a standard for various
contaminants. A
standard is a definite rule, principle, or measurement which is
established by
governmental authority considering the local condition, such as, social,
economical and
food habit.. The standards are sometimes established on an interim basis
until better
information becomes available. This is also the reason why the standards
differ from
country to country3. The Drinking Water standards can be considered as
minimum
standards to be met by all public water systems. The Bangladesh drinking
water quality
standards is given in annex-III.
In all the subprojects, it will be a mandatory requirement that
Bangladesh drinking
quality standards are met. To this end, it will be necessary to test
water quality
parameters during construction of the tubewells and the piped water
systems. In the
construction stages, it is expected that tests will be mainly carried out
for the critical
parameters based on technical judgment as it neither necessary nor cost
effective to
monitor all the water quality parameters specified in the standards. Many
of the
parameters are usually measured using portable equipment/kits. However,
for final
certification of a subproject for water quality, samples taken should be
analyzed at a
laboratory with adequate QAQC system in place. This is because in the
case of earlier kit
based analysis of Arsenic, there were reported cases of misclassification
of Arsenic safe

3
 Bangladesh standard for Arsenic in drinking water is 50 ppb compared to
US EPA standard and WHO
guideline of 10ppb. It may be noted that cost-benefit analysis is also
involved in setting standards.


41
tubewells4 and this should not happen again in the present project. For
laboratory
analysis, proper protocols have to be followed from sampling to analysis
and
certification. For example, when taking samples, there are quite specific
time limits on
how long the sample can be left before analysis. If the sample is
collected in a bottle and
transported back to a laboratory or office, then the sample should be
stored at below 4oC
and analyzed within 4-6 hours.

For piped water supplies, the numbers of samples to be taken is usually
based on the
population that is served by piped water system. This may need to be
calculated based on
water usage study data especially because of the intermittent nature of
supplies under the
project. Loss of pipe pressure during non-supply period, contamination
can happen with
minor leaks in the pipes. All activities associated with QAQC aspects are
aimed at one
target: the production of reliable data with a minimum of errors.

It is expected that all water quality analysis work will be contracted to
DPHE laboratory
system. However, in case DPHE laboratories are unable to provide
analytical services in
a timely manner, the analytical work may be outsourced to other
laboratories with an
adequate QAQC system in place.


7. Consultation & Disclosure

7.1 Community / Stakeholder Consultations

Community/stakeholder discussions are basic requirements in the EMF
preparation and
implementation. As the basic principles require, inputs and feedbacks
received from
stakeholder consultations are the major determinants in the selection,
location and design
of projects and their implementation. A Stakeholder Consultations
workshop was held on
October 10, 2011 in which total of 45 invited participants from the
concerned
Agencies/Organization participated. The documentation on the discussions
in respect of
participation, deliberations and the decisions reached along with
disclosure notification (
published December 21/22, 2011) are given in Annex-IV. The stakeholders
gave strong
support for the implementation of the project considering its beneficial
impacts and were
convinced that environment impacts of the project can be managed, so that
no harmful
effect will be caused to the environment or to the people.




     4
    M. Khaliquzzaman, (URL:
http://www.phys4.harvard.edu/~wilson/arsenic/countries/bangladesh/
   NAMIC%2037%20upzillas.doc)




42
7.2 Disclosure

The DPHE has disclosed this EMF summary in Bangla to the public in
Bangladesh, and
authorized the World Bank to disclose it at its Country Office
Information Center and in
its Infoshop. The DPHE has supplied copies of the documents at the DPHE
head office
and other offices, public libraries, and other places accessible to the
general public.
DPHE has also informed the public through a notification on December 22,
2011, in two
newspapers (Bangla and English) about the EMF disclosure and where it
could be
accessed for review.


8. Project Coordination and Implementation

The roles and responsibilities for all participants (e.g., PMU, NGOs,
CBOs, Sponsors) in
preparing, reviewing, approving and implementing subprojects are given in
some detail
in this section. This includes institutional arrangements for managing
the subproject
cycle.

8.1 Organizational Structure

In order to ensure that the policy obligations and associated procedures
in the
Environmental Framework (EMF) are operationalized, the BRWSSP
organizational
support structure for subproject planning, review and implementation is
to be
appropriately organized. BRWSSP management will arrange for qualified
teams to
support preparation and oversee the implementation of the Environmental
component of
the subprojects. The team members should be adequately briefed and
trained with
resource support from the BRWSSP.


8.2 Responsibility Allocation Framework

BRWSSP management will ensure sensitivity to environmental aspects of
various
subprojects among its teams, so that they can provide competent support
to the
sponsors/CBOs. This will be done by providing training to the relevant
PMU staff.
Attempts should be made to involve local inhabitants wherever possible to
ensure local
agreement with appropriateness to ensure effective subproject
preparation,
implementation, operation and maintenance. Additionally, BRWSSP may
maintain a
list of consultants from among individuals or organizations who have the
full range of
expertise to address environmental concerns related to anticipated
subprojects. They
can be used to address project specific environmental issues as and when
necessary for
the following:



43
       •   Advising BRWSSP on environmental issues;
       •   Selective review of ER, LEA and other documents from the
proponents for
           quality assessment; and
       •   Selective monitoring and evaluation of subprojects.
    The service of the consultants may also be utilized to undertake the
annual sample
environmental audit of all BRWSSP financed subprojects.

8.3 Grievance Redress

The PMU should set up a procedure to address complaints and grievances on
environmental issues. This can be part of an integrated complaints and
grievances redress
mechanism in the PMU. The complaints and grievances redress procedure
will not pre-
empt the aggrieved person’s right to seek redress in the courts of law.
All complaints
will first be negotiated at the local levels i.e., with the Community
Groups/Community
Based Organizations (CBOs). If this fails, the complaints can be referred
to local
authority with the minutes of the hearing that has taken place earlier. A
decision agreed
with the aggrieved person at any level of hearing will be binding on the
subproject
sponsor. The DPHE will keep the records of all complaints and grievances
including
ones that may remain unresolved.


9. Capacity Building and Training

The environmental sustainability of the BRWSSP that involve funding of
multiple small-
scale piped water supply subprojects, is highly and unavoidably dependent
on the
capacity of the DPHE staff and sponsors to carry out the associated
design, planning,
approval and implementation work. Thus, to ensure that capacity, it is
important that that
BRWSSP allocates sufficient resources to training and capacity building
especially in the
early years. These efforts will not only benefit the BRWSSP, but will
also build local
capacity to undertake other development initiatives funded locally or by
other donors.

9.1    Institutional Capacity Assessment

An assessment of the existing institutional capacity to implement the EMF
is presented in
this section. It focuses on the adequacy of the institutions identified
in Section- 5 to carry
out their EMF responsibilities. It assesses, at a minimum, the adequacy
of:
    • the institutional structure, and its authorities at all relevant
levels, to address
        environmental management issues;
    • the number and qualifications of staff to carry out their EMF
responsibilities;



44
      •   resources to support staff in their work; and
      •   knowledge and experience relevant to carrying out environmental
analyses and
          designing mitigation measures for small-scale infrastructure.

Having implemented Bank financed BAMWSP and BWSPP projects, the senior
officials
of the DPHE are well aware of the environmental management issues.
However, once the
project is completed, most of the lower level staff with experience is
usually unavailable
for the subsequent projects. It is thus unlikely that much of the
capacity built in the
earlier projects will be available for the BRWSPP also. Some of the
private project
sponsors especially the newcomers may lack environmental orientation.
Thus, as a part of
the institutional capacity building for the project as a whole, the field
level PMU/DPHE
Teams and member of sponsoring agencies have to be trained in different
aspects of the
project, including interpretation and implementation of environmental
impact
management guidelines.

9.2       Capacity Building

BRWSSP will envisage capacity building at all levels i.e., field level
BRWSSP/DPHE
staff and project sponsor personnel to ensure that the EMF is effectively
operationalized.
The BRWSSP personnel will be exposed to formal training in the management
of
environmental issues. The training program for various role players will
include an
orientation program on the EMF, Environmental Assessment Processes,
Participatory
Methodologies and Project Management.

BRWSSP will help to improve the effectiveness of local proponents in the
management
of environmental and social impacts during planning, implementation and
operation of
proposed investments. Proposed criteria for capacity building for C and B
category
subprojects are shown in table 8, which will be used as modules in
capacity building at
all levels.

Capacity building will enhance the subprojects’ EMF management capacity
by allowing
real application of the critical practices such as the following:
             •   Basic practices: screening impacts, scoping assessments,
planning
               mitigation options, public consultation to assess
feasibility and acceptability
               options.

             •   Environment: site selection and route alignment to
minimize
                 environmental impacts and social disruption; restoration
of drainage
                 patterns, land use etc; including mitigation measures in
contracts;
               management of impacts during construction; monitoring of
effectiveness of
               measures.



45
          •     Monitoring and grievance redress: Transparency and
public
                 administration in planning, reporting and supervision
responsibilities and
                 formats during implementation, documenting land
transactions, complaint
                 response record keeping and procedures.

 Table 8: Capacity Building Criteria for managing C and B Category
Subprojects

         Issue                   Concern
Eligibility Criteria

1.                          •   Realistic                • Proponents
effectively decide questions of what mitigation
         Environmen             environmental              is needed to
manage risks, who is eligible for what and
tally sound                     standards for              determining
how much is enough to achieve the standards,
subprojects,                    planning and               for
environmental protection.
                                implementation.
complying with
agreed EMF policy
                            •   Effective monitoring     • Accuracy and
credibility of baseline data and reasonable
                                of actual mitigation       certainty of
detecting and correcting any errors or
                                results.                   problems
during planning and implementation. To be able
                                                           to meet
standards, the proponents must have sensitive
                                                           monitoring
systems & specific indicators for the adequacy
                                                           of the
mitigation delivered and actual results.


                            •   Clear incentives and     • Proponents
have clear statements of task assignments,
                                accountability for all     reasonable
corrective consequences for mistakes or failures
                                partners.                  and
unambiguous responsibility and sources of financing
                                                           to correct
problems, and functioning grievance redress
                                                           systems.

                            •   Common awareness         • Communication
to ensure common awareness of
                                and understanding of       standards,
monitoring and accountability by those affected,
                                the above.                 contractors,
NGOs, independent consultants, proponents,
                                                           government
agencies and donors.


2.    Participatory         •   Sub project             • Resolution of
the proponents in support of the sub –
      planning and              prioritization is          project after
public meeting.
      implementation            based on adequate
      and inclusion of          consultation.
      the poor in project
      benefits.             •   Effective               • Formal
endorsement by the community through public
                                accountability to          hearings and
documented periodic reporting of proponents
                                citizens.                  performance to
citizens;




9.3       Training needs and plans


The training programs will be coordinated and anchored within the BRWSSP
management at national level. Local and National Institutions and
individuals
experienced in environmental aspects of subprojects may be employed to
develop and
conduct courses on various modules.


46
The section describes the training needs and plan for the various
participants involved in
implementing the EMF based, in part, on the institutional assessment
described above.
The training on EMF may be integrated with social framework and other
related training
program for cost effectiveness. The objectives of the training under the
EMF are to:

   •   support representatives and leaders of community groups and
associations to
       prioritize their needs, and to identify, prepare, implement and
manage the
       environmental aspects of their subprojects;
   •   ensure that field level staff have the capacity to assist in
preparing subproject
       proposals, and to appraise, approve and supervise the
implementation of
       subprojects; and
   •   strengthen the capacity of the local sponsors/NGOs and other
stakeholders which
       may be involved in the public participation in preparing and
implementation of
       subprojects.

Different groups involved in BRWSSP implementation have different
training needs in
terms of raised awareness, sensitization to the issues, and detailed
technical training:

   •   Awareness-raising for participants who need to appreciate the
significance or
       relevance of environmental issues;
   •   Sensitization to the issues for participants who need to be
familiar enough with
       the issues that they can make informed and specific requests for
technical support;
       and
   •   Detailed technical training for participants who will need to
analyze potentially
       adverse environmental impacts, to prescribe mitigation approaches
and measures,
       and to prepare and supervise the implementation of management
plans. This
       training will address such matters as community participation
methods;
       environmental analysis; using the ER checklist, reporting; and
subproject
       supervision and monitoring.

The different training needs that are generally associated with the
projects are given in
table 9. Based on these needs, a training plan has to be worked out for
the life time of the
project. The needs for     various participants (e.g. government
officials, community
leaders, extension teams) have to be different of necessity. While some
would require
training on general awareness building and more specific training would
be needed for
others. The table shows the initial training needs as well as the needs
for further or
“refresher�? training. It should include mechanisms for periodically
bringing trainees
together to examine the need for and design of additional training.




47
                   Table 9:         Outline of different Training Needs

Group             Participants      Venue          Resource      Duration
Frequency
                                                   persons
BRWSSP/DPHE       Staff involved DPHE              Experts/      1- day
Year 1 of the
staff             in project                       Consultants   workshop
Project
                  implementation                                  ½-day
After Year 1 as
                                                                  refresher
needed
                                                                  workshop
Sponsor staff     Staff involved Any suitable       Experts/      1- day
Year1 of the
                  in project       venue           Consultants   workshop
Project
                  implementation                                 ½-day
After Year 1 as
                                                                  refresher
needed
                                                                 workshop
Stakeholders      NGO workers,      Any suitable   DPHE staff    1-day
As needed
                 Concerned           venue                        workshop
per   throughout the
                 individuals                                     community
project




The detailed agenda and specification of resource needs (venue, trainers,
materials, etc.)
for each type of training activity should be worked out before the
training activities are
undertaken.

9.4 Resources for EM and Capacity Building

The capacity building and training should be considered as an implicit
component of
BRWSSP management and adequate resources from this component should be
allocated
to ensure effective implementation of the EMF. The resources are needed
to implement
the following items.
    •     Institutional development activities
    •     The training program for PMU/DPHE and sponsors’ staff to
implement their
          EMP responsibilities
    •     Preparation of subproject LEAs etc. (The costs of implementing
these plans are
          included in the subproject budgets.)
    •     Consultants remuneration
    •     Laboratory fees for collection/testing of water and any other
samples
    •     Annual reviews and audits




48
10. Conclusions and Recommendations

This EMF is a document to provide guidelines as to how the environmental
safeguard
issues can be addressed for the BRWSSP. As discussed in the earlier
sections, the
proposed sub-projects under the project will have rather small scale
environmental
impacts that can be managed if the procedures given in this EMF are
followed. The
project staff and other relevant persons should be trained so that they
can fully implement
the actions needed under the EMP. Provision for adequate funding must be
made in the
project’s operational budget for the purpose.




References

1. MICS (2009), Multiple Indicator Cluster Survey (MICS) conducted by
Bangladesh
Bureau of Statistics and UNICEF (BBS/UNICEF, 2009).

2. Bangladesh Environment Conservation Act, 1995.

3. Bangladesh Environment Conservation Rules, 1997.

4. World Bank (1999), Operational Policy OP 4.01 on Environmental
Assessment.

5. D. G. Kinniburgh and P. N. Smedley, Arsenic contamination of
groundwater in Bangladesh, BGS
Technical Report WC/00/19, Vol. 1-4 (2001); UNDP., Groundwater Survey:
The Hydrogeological
Conditions of Bangladesh, UNDP Technical Report DP/UN/BGD-74-009/1(1982)




49
 Annex I: Environmental Management Forms

           Form 1: Environmental/Social Screening Checklist for Sub-
Projects

 Part A: GENERAL INFORMATION

Sl    Item                                                   Description
1.    Sub-Project                    Community Piped Water supply
2.    Project Location               Full description
3.    Project description            Installation community piped water
supply scheme for xx
                                     households consisting of xx house
connections, xx stand
                                     posts
4.    Population type in the
                                     [     ] All mainstream or non-
indigenous/tribal peoples
      project area                   [     ] All indigenous/tribal peoples
                                     [     ] Majority mainstream or non-
indigenous/tribal peoples
                                     [     ] Majority indigenous/tribal
peoples

5.    Brief description of the       Tube well and pump installation,
Water tank construction,
      physical works
                                     Pipeline laying, Water treatment
plant (surface/Iron/arsenic)
6.    Sub-project                                                      B
      Environmental Category
7.    Expected                                                     Positive
      Environmental outcome
      of the sub-project


Part B: ENVIRONMENTAL SCREENING


 SCREENING QUESTIONS                                    YES/NO        REMARKS
 (i) PROJECT SETTING: IS THE PROJECT
 AREA…
 1. Densely populated?
 2. Heavy with development activities?
 3. Adjacent to or within any environmentally
 sensitive areas?
 4. Cultural heritage site
 5. Protected area
 6. Wetland
 7. Mangrove
 8. Buffer zone of protected area
50
SCREENING QUESTIONS                               YES/NO   REMARKS
9. Special area for protecting biodiversity

(ii). POTENTIAL ENVIRONMENTAL
IMPACTS (Construction Phase)

1. Noise and dust from construction activities?    Yes     The impacts
are likely to be tolerable
                                                           enough, so
that public complaints are
                                                           not
expected.
2. Temporary silt runoff due to construction?      Yes     Drill mud
and water run off may
                                                           happen
during tubewell construction
                                                           but these
are expected to be
                                                           manageable.
3. Road blocking and temporary flooding due to     Yes     Some
temporary problems may arise
land excavation during rainy season?                       during pipe
laying and measures will
                                                           be taken to
minimize these.
4. Solid Waste and construction debris             Yes     Some debris
will be generated in the

construction of water tank and pump
                                                           house.
These will be responsively
                                                           managed.
5. Health and safety related to construction       Yes     Standard
safety procedures in
activities
construction industry will be
                                                           followed
6. Potential risk that water quality being non-            Water
quality will be tested and if
compliant with drinking water quality standards            essential
water treatment plant will
and aesthetically unsuited for drinking.                   be
established to ensure that water
                                                           quality is
compliant with Bangladesh
                                                           drinking
water standard.
(iii). POTENTIAL ENVIRONMENTAL
IMPACTS (Operation Phase)
1. Hazards to public health due to drill mud       Yes     Initially
water may be contaminated due
contamination                                              to residual
drilling mud which may
                                                           contain
materials like cow-dung. It will
                                                           be ensured
that the water is free from
                                                           such
contamination before public use.
2. Potential hazards to public health due to         Yes   The base of
the tubewells will be
microbial contamination of tubewell water                  cemented to
avoid microbial

contamination of tubewells water
                                                           due to
seepage.
3. Potential hazards to public health due to         Yes   Water
quality will be tested and if
Arsenic contamination.                                     necessary a
treatment plant will be
                                                           set up.
4. Potential hazard from sludge from water           Yes   Sludge will
be disposed off in
treatment plant especially Arsenic contaminated            technically
and environmentally safe
sludge.                                                    processes
using approved protocol.
5. Water resource problems (e.g. depletion/           No   Water
quantity extracted will be
degradation of available water supply,                     small
compared to aquifer capacity.
deterioration of surface and ground water quality,         So, no
problems are anticipated in
and pollution of receiving waters?)                        the
foreseeable future.



51
SCREENING QUESTIONS                                   YES/NO        REMARKS
 6.Degradation of land and ecosystems (e.g. loss of      No
wetlands and wild lands etc)
7. Overuse of ground water, leading to land                No     Only a
small quantity of water is
subsidence, lowered ground water table, and                       involved
in the project, so such
salinity.                                                         impacts
are highly unlikely.


Part C: SOCIAL SCREENING

SCREENING QUESTIONS                                   YES/NO        REMARKS

1.       Need for land acquisition                         No       Land to
be provided by the
                                                                    sponsor
2. If ‘Yes’, the required lands presently
   belong to:
      (a) Government/Public (Lands that are    Not
     khas and/or belong to the government ) applicable
      (b) Private landowners                                Not
                                                         applicable
3. Dislocation or involuntary resettlement of               No      Site
selection will ensure this
people
4. Social conflicts between construction                   No       Sponsor
will take measures to
workers from other areas and local workers?                         avoid
such issues
5, Degradation of cultural property, and loss of           No       Site
selection will ensure this
cultural heritage and tourism revenues?




Prepared by (Name): …………………………………………………


Signature: ………………………………………......                                     Date:
…………………………




52
Form 2: Limited Environmental Assessment (LEA) Format for Category ‘B’
Subprojects
                      (This form should be completed by a qualified
specialist)


      1. General Description of the Sub-project


      Subproject Name and Location: …………….……………….…………....
      ………..……………….

      Name of Upazila: ……..………………….. Name of District:
…………..................….
      Names of Persons Participating in the report preparation with job
title : ……………

      …………………………..…………………………………………………………..………
      …………………………………………………………………………………………….
      Sub-project Objectives:
      …………………………………………………………………………..…………………
      …………………………………………………………………………………..…………
      ………………………………………………………………………………………….

      Sub-project Components:
      ……………………………………………………………………….……………………
      ………………………………………………………………………………………………
      ……………………………………………………………………………………


      2. Baseline Description of the Affected Environment

         •   Description of the Physical/Chemical Environment (Soil,
Water Air etc):




         •    Description of the Biological Environment (Habitat, Flora,
Fauna etc):




         •   Description of the Socio-economic Environment (Public
health, historical sites,
             infrastructure etc):




53
3. Specification of Expected Negative Environmental Impacts

Impact on the Physical/Chemical Environment (Soil, Water Air etc):




Impact on the Biological Environment (Habitat, Flora, Fauna etc):




Impact on the Socio-economic Environment (Public health, historical
sites, infrastructure
      etc):




4.     Mitigation Measures

     Cost effective mitigation measures should be identified and measures
for their
     integration into the project design including implementation and
monitoring should
     be recommended.




Report Prepared by (Name & Designation):
……………………………........................

Signature: ………………………………………...... Date: …………………..……….

Telephone Number:………………………………………..



Report Approved by (Name & Designation):
……………………………........................

Signature: ………………………………………...... Date: …………………..……….

Telephone Number:………………………………………..




54
Annex-II: Arsenic Rich Sludge Disposal from Fe/Mn/As Removal
Plants

1. Introduction

Removal of Arsenic from contaminated groundwater to the level less than
the current
Bangladesh standard of 0.05 mg/L can be achieved using proven methods and
technologies. There is a considerable body of local experience on
groundwater Fe/Mn
removal plants under the BAMWSP and also in other projects in Bangladesh.
Prefabricated packaged plants for Fe/Mn removal are now commercially
available. This
process is most likely to be used in projects under BRWSSP. In the
process of removal of
iron and manganese, arsenic is also removed as it binds to Fe. If the
naturally occurring
amount of iron and manganese is not enough to get the desired arsenic
removal, more
iron salt may be added. Pre-oxidation using aeration is employed to
convert arsenide to
the more precipitable arsenate form. However, other methods such as
potassium
permanganate or hydrogen peroxide addition can also be used if required.
Waste generation by Arsenic removal treatment plants is an important
issue of public
concern often with high emotional overtones in Bangladesh. This issue,
therefore, needs
careful considerations. The activities required in this connection may
include preparation
of sludge management plans, sludge thickening, dewatering, drying,
stabilization,
sanitary landfill, land application, identification of disposal sites,
demobilization in stable
matrices and environmental risk assessment. It should be realized that
sludge from
groundwater treatment is different from waste water treatment sludge
being mostly
inorganic in nature. The problems are both scale and technology
dependent.


2. Process Performance

In general, the Fe/Mn removal processes have been found to be
significantly more
effective in removal of As(V) than in removal of As(III). As (III) can be
converted
through pre-oxidation to As(V). In the currently available packaged
plants, pre-oxidation
is achieved by simple aeration.
The Iron-Manganese Removal System is based on flocculation of oxidized
iron and
manganese and subsequent co-precipitation of Arsenic including both
arsenate and
arsenide. In a typical iron-manganese filtration system aerated feed
water is passed
through a greensand (or simple sand) media bed for removal of oxidized
iron and
manganese flocks. Naturally occurring amount of iron and manganese may
not always be
enough to get the desired arsenic removal. In such cases, Iron may be
added to make Iron
to Arsenic ratio 20:1 to ensure Arsenic removal reasonably efficient.
Periodic
backwashing of the sand media is required to remove excess iron and
manganese, as well
as other particulate contaminants removed from the feed water.
Backwashing is
accomplished by reversing the flow of water through the filter bed to
flush out
particulates. The backwash waste contains elevated concentrations of Fe
and Mn as well
as Arsenic and other contaminants.


55
3.Process waste characteristics5

The Arsenic treatment plants produce two different types of wastes:
sludge and spent
media. Depending upon arsenic concentration and the characteristics of
the waste, each of
these wastes can pose disposal challenges and has the potential for being
classified as
hazardous. The problems are both scale and technology dependent.

 Arsenic wastes (i.e., liquids) are defined as hazardous if their
toxicity characteristic
(TC) exceeded 0.05 mg/l of arsenic according to USEPA. The Toxicity
Characteristic
Leaching Procedure (TCLP) is a method by which solid waste is evaluated
to determine
if it is hazardous. If waste contains less than 0.5% dry-weight solids,
then the liquid is
defined as the TCLP extract and concentrations in it are compared against
the TC level to
determine if it is hazardous. It is to be noted that there is no
Bangladesh standard for
TCLP.
If the waste contains more than 0.5 % dry-weight solids, then a TCLP that
conservatively
simulates leaching from a landfill is used to determine if the TC level
would be exceeded.
TC and TCLP results from residuals produced by the treatment technologies
under
consideration have to be evaluated. The TCLP test, as most solid waste
demands, are
performed at pH 4 and 7 is deionized water. In Bangladesh, the leaching
of solid waste
would be due to rain water which has pH value in the prescribed range.

Quantitative information on the different kinds of residuals produced by
various
treatment processes per million liter of drinking water produced are
available in
literature ( Chwirka 1999)6. For the Fe/Mn removal plants, the reported
values of dry
solid is about 22kg per million liter and concentration of As is about
1900 mg/kg. These
are only indicative values and the numbers would of course vary according
to Fe and As
content of the source water.

TCLP characteristics of the dry solids are reported to be around
.04(mg/L) which is much
below the TCLP standard limits and hence can be disposed of in landfills.
The solids can
also be immobilized by burial in unused land (e.g., homesteads/roads etc)
which is
recommended in a protocol in Bangladesh.
The backwash water containing Fe rich flocks may be temporarily stored in
a lined tank
until the flocks settle. The supernatant liquid can then be discharged to
land or water
bodies as the As concentration is estimated to be less than 0.2 mg/L (see
table below).
The settled flock removed periodically can be dried and disposed in
landfills or according
to protocol prescribed from time to time. Exhausted filter media can also
be disposed off
in landfills as Arsenic content in the media is expected to be low.


1.   MacPhee, M. J., Charles, G. E., Cornwell, D. A., Treatment of
Arsenic Residuals from Drinking Water
     Removal Processes, EPA/600/R-01/033 (2001)

2.   Chwirka, J., Residuals Generation, Handling and Disposal. In Arsenic
Treatment Options and
     Residuals Handling Issues. Draft Final Report. AWWA, Denver (1999).



56
Table- AII : National Standards – Waste Water Discharge Quality Standards
for Industrial
         Units and Projects: Quality at Discharge Point (From ECR
Schedule-10)

                                                           Location of
Final Disposal

Parameter                                   Unit           Inland Surface
Public           Irrigated
                                                           Water1
Sewer1          Land1
Ammonia(free ammonia)                       mg/L           5
5               15
Ammoniacal Nitrogen(as N)                   mg/L           50
75              75
Arsenic(As)                                 mg/L           0.2
0.5             0.2
BOD5 20oC                                   mg/L           50
250             100
Boron(B)                                    mg/L           2
2               2
Cadmium(Cd)                                 mg/L           0.05
0.5             0.5
Chloride(Cl-)                               mg/L           600
600             600
Chromium (hexavalent Cr)                    mg/L           0.1
1.0             1.0
Chromium(total Cr)                          mg/L           0.5
1.0             1.0
COD                                         mg/L           200
400             400
Copper(Cu)                                  mg/L           0.5
3.0             3.0
Cyanide(CN)                                 mg/L           0.1
2.0             0.2
Dissolved Oxygen(DO)                        mg/L           4.5-8
4.5-8           4.5-8
Dissolved Phosphorus(P)                     mg/L           8
8               10
Electrical Conductivity                     µMho/cm        1200
1200            1200
Fluoride(F)                                 mg/L           7
15              10
Iron(Fe)                                    mg/L           2
2               2
Lead(Pb)                                    mg/L           0.1
0.1             0.1
Manganese(Mn)                               mg/L           5
5               5
Mercury(Hg)                                 mg/L           0.01
0.01            0.01
Nickel(Ni)                                  mg/L           1.0
1.0             1.0
Nitrate(N molecule)                         mg/L           10.0
Undetermined 10.0
Oil and Grease                              mg/L           10
20              10
pH                                          -              6-9
6-9             6-9
Phenol Compounds(C6H5OH)                    mg/L           1.0
5               1
Radioactive Materials                                      As determined
by Bangladesh Atomic Energy
                                            -              Commission
Selenium(Se)                                mg/L           0.05     0.05
0.05
Sulfide(S)                                  mg/L           1       2
2
Temperature– Summer                         oC             40       40
40
Temperature– Winter                         oC             45      45
45
Total Dissolved Solids(TDS)                 mg/L           2100    2100
2100
Total Kjeldahl Nitrogen(N)                  mg/L           100      100
100
Total Suspended Solids(TSS)                 mg/L           150     500
200
Zinc(Zn)                                    mg/L           5.0     10.0
10.0

Notes: (1) Land Surface Water refers to any pond, tank, water body, water
hole, canal, river, spring or
estuary.
Public Sewer refers to any sewer connected with fully combined processing
plant including primary and
secondary treatment.
Irrigated Land refers to an appropriately irrigated plantation area of
specified crops based on quantity and
quality of wastewater




57
Annex-III: Bangladesh Drinking Water Quality Standards
                        Schedule – 3 (ECR 97)
                     Standard for Water (Rule 12)




                                                         58
59
     Annex-IV: Stakeholders’ Consultation and Disclosure


          Proceedings of the stakeholder consultation workshop on
‘Environmental Management Framework (EMF)’ and ‘Social Management
                            Framework (SMF)’
                                     of
      Bangladesh Rural Water Supply and Sanitation Project (BRWSSP)




                                                                      60
                   A Report on the Workshop Proceedings

A total of 45 invited participants from the concerned
Agencies/Organization participated
in the workshop held on October 10, 2011. The participation list and the
invitation are
appended with this report.

The Opening Session :

The beginning : Mr. Moniruzzamn, Assistant Chief, DPHE extended welcome
to all at
the participants at the workshop in which Mr. S.M. Ihtishamul Huq,
Chairman, PPT of
BRWSSP and Mr. Nuruzzaman, Chief Engineer, DPHE were also present. The
Workshop started through self introduction.

Welcome speech of Chairman, PPT of BRWSSP: The workshop started with the
welcome speech by the Chairman, PPT of BRWSSP. In the opening speech, Mr.
S.M.
Ihtishamul Huq briefed the participants on the background of upcoming
BRWSSP. He
noted that the implementation of ‘Rural piped water supply scheme’
through Public
private partnership (PPP) model for safe water delivery in the rural
Bangladesh under
completed Bangladsh water supply program project (BWSPP) was one of the
most
challenging attempts on the part of DPHE. In total 21 Rural piped water
supply schemes
were commissioned all over the country under BWSPP. The obstacles faced
and the
challenges in terms of social, economic, financial and technical issues
were formidable.
He also acknowledged the commitment and support from DPHE field level
Officials and
dedication of the concerned sponsors, LGIs that made the piloting
successful. He opined
that during planning to implementation stage a lot of ‘social and
environmental’ issues
should be solved through well organized effort and valid documentary
evidences both
the from the point of view of Government and the development partner. He
stated that
this workshop is organized to present and share the key documents on
‘social and
environmental management framework. to the concerned stakeholders.

He welcomed the participants for active participation in the workshop to
make it
worthwhile through sharing of their practical experience and learnt
lessons including the
piloting under BWSPP. He also stated that input provided by the
participants can l make
a positive contribution to the upcoming project.

Mr. Motaleb, Sr. Water Supply Engineer, the World Bank, Dhaka Office :

Mr. Motaleb appreciated the well done performance of the sponsors those
involved under
BWSPP for implementation of ‘Rural piped water supply scheme’ in the
rural areas of



61
Bangladesh. He drew the notice of all participants to participate very
actively on the
presentable documents of BRWSSP on policy of ‘Social and Environmental
Safe Guard’.



Chief Guest, Chief Engineer, DPHE:
Mr. Nuruzzaman, Chief Engineer, DPHE, as a Chief Guest of the workshop
welcomed
the participants in the workshop and made their attention on these two
important issues
under upcoming BRWSSP. He strongly informed the participants that the
Government of
Bangladesh through DPHE is interested for early implementation of the
upcoming
‘Bangladesh Rural Water supply and Sanitation Project (BRWSSP)’.

He also expressed his joys that through the labor intensive but result
oriented
documentary support provided both by the World Bank Country Office and
PPT,
BRWSSP under DPHE and hope that this will accelerate the quality
implementation of
BRWSSP. He also thanked the World Bank for providing support for
conducting this
workshop in the World Bank premises as well as to make funding for the
upcoming
project. He welcomed the participants for active participation in the
workshop.

Mr. Arif Ahmed, Task Team Leader, BRWSSP : Mr. Arif requested the
participants
that the participants to go through the key issues during the discussion
and sharing of
their ideas on the relevant specific issues lying under the discussion.
He also noted that
the participants are welcome to put comments on the presentation.
 Key presentation of the said two documents: 10.25 -12.00




Environmental Management Framework (EMF)

Dr. M. Khaliquzzaman, Environmental Specialist, WB briefed the audience
on the World
Bank’s safeguards requirements especially on the OP 4.01 for
Environmental Assessment (EA).
Discussion on EMF are described below:

The project components have environmental safeguard issues which are
addressed by the
EMF. As per World Bank guidelines, the projects components are to be
designed and
implemented by integrating the national policies, guidelines, codes of
practice and
procedures proposed in this EMF. The objectives are to ensure that the
activities
undertaken in the project:
               Enhance positive environmental outcomes;
               Prevent negative environmental impacts;
               Identify and mitigate with appropriate measures, the
adverse impacts that
               might arise;
               Obtain Environmental Clearance form DOE; and
               Ensure compliance with the World Bank’s environmental
safeguards
               policies.


62
The present Policies, Acts, Rules & Regulations with respect to the
Environmental issues
in the country are under the custodianship of the Ministry of Environment
and Forest
(MOEF)/Department of Environment (DoE). The activities under the project
are covered
by the Policies, Acts, Rules & Regulations under ECA 95 and ECR 97.

The main purpose of the Bank’s safeguard policies are to (i) avoid harm
to the
environment and affected people and provide affected people an
opportunity to
participate in the development process; (ii) improve project design and
performance; and
(iii) protect the reputation of the Bank. The current set of safeguard
policies cover a broad
range of topics from environmental assessment to natural habitats,
forests, resettlement,
and Indigenous Peoples and others. The policies are the reflection of
international
conventions and internationally accepted principles of good practice in
project
preparation and implementation. Similar principles, supporting the
aspirations for
sustainable development, are generally reflected in policies in most
client countries;
however, implementation is often weak and variable. Out of Bank’s
safeguards policies
only OP 4.01 related to environment is triggered in the Project.
Considering the
environmental impacts according to WB policy, the project has been
classified in the B
category.

Mr. Naveed Ahmed, presented the key Social safeguard policies that are
likely to be
triggered in the project which are related to The World Bank Operational
Policies on

       Involuntary Resettlement (OP 4.12)
       Indigenous Peoples (OP 4.10) and
        Gender (OP 4.20).

The Social Management Framework (SMF) is proposed to deal with social
safeguard
issues that are likely to arise under the proposed Bangladesh Rural Water
Supply and
Sanitation Project (BRWSSP). This project will implement by the
Department of Public
Health Engineering DPHE under the Ministry of Local Government Rural
Development
& Cooperatives (LGRD & C) of Government Bangladesh (GOB). The activities
under
this multi-component project will be implemented over a five-year period
across
Bangladesh.

The operational policies will provide guidance on mitigation and
minimization of
negative impacts due to land acquisition requisition etc .The nature and
magnitude of
impacts will be determined on a continuing basis with finalization of
facility location and
engineering designs. However it is expected that the project will have
low severity of
impact in terms of negative social outcomes. As the impact details become
available, the
proposed SMF will provide the basis to prepare and implement Resettlement
Plans (RPs),
Indigenous Peoples Plans (IPPs) and Gender Action Plan, as and when
required to
mitigate adverse impacts due to the physical facilities development. The
SMF will be
applicable to the activities financed by the World Bank




63
The SMF is intended to provide the necessary bases to determine
applicability of the
World Bank safeguard policies, identify the safeguards impacts, and
prepare and
implement RPs, IPPs and GAP as and when required. The core principle
behind the SMF
is to avoid, minimize and mitigate issues relating to land
acquisition/resettlement,
impacts on indigenous people, and ensure that the negative impacts of the
projects on
women are minimized. As proposed here, it also provides general policies,
guidelines,
and procedures for integration of social safeguard issues into selection,
design and
implementation of the civil works..The objective of the SMF is to help
‘DPHE’ to ensure
that the project:
o Enhances social outcomes of the activities implemented for the physical
facilities
  development under the project.
o Identifies and mitigates adverse impacts that the selected development
interventions
  might cause on people, including protection against loss of livelihood
activities, with
  culturally, socially and economically appropriate measures; and
o To ensure the implementation of the project in complience with the
World Bank’s
  social safeguard policies.


Requirements On Environmental Clearance In Bangladesh

In Bangladesh, the EA procedure has three tiers which are; (i) Screening;
(ii) Initial
Environmental Examination (lEE); and (iii) Detailed EIA. The rural piped
water supply
subprojects in BRWSSP can be classified in the Orange-B category (ECA97,
Schedule-1,
item-28), need to obtain the clearance from the DOE in two stages i.e.,
(i) Initial Stage in
which a Site Clearance Certificate (SCC) is obtained and (ii) an advanced
Stage in which
an Environmental Clearance Certificate (ECC) is obtained. However DOE may
provide
clearance to EMF for projects with multiple sub-projects with small
environmental
footprints. If the clearance is obtained for the EMF, then clearance for
individual
subprojects may not be necessary.

Discussions: 12.10 -12.50

As per the presentation by the concerned two subject matter specialist of
The World
Bank, Country Office, Bangladesh an explicit, issue based clear cut
discussion was made
by the ‘attendance and presenters’ through open ‘question and answering’
method.

Most of the participants were participated in this session and could able
to gain their
‘clear understanding’ on the key issues that discussed through the key
documents of
BRWSSP. They also opined that in selecting the site, topmost priority
will be given so
that negative impact on environmental and social is minimum and
amppropriate
measures will be taken to mitigate the impact.


Recommendation and Closing Remarks (12.45-1.00 pm) : The following
recommendation was made through the workshop :



64
Disclosure of the documents : The PMU will disclose the SMF and EMF
documents on
the DPHE website. The PMU will ensure that copies of the documents and
their
executive summaries in Bangla will be made available at the project
sites, DPHE local
offices and DPHE Head Office in Dhaka, so that the document is accessible
to the
general public. The PMU will inform the people through notification in
two local
newspapers about the stakeholders’ consultation on the SMF and EMF and
their
availability.
Following persons put their closing remarks thanking all for their
fruitful and result
oriented participation in the workshop :
       Mr. Nuruzzaman, Chief Engineer, DPHE.
       Mr. S.M. Ihtishamul Huq, the Chairman, PPT of BRWSSP.

The workshop was ended by vote of thanks by Mr. Arif Ahmed, Task Team
Leader,
BRWSSP.




65
                     The Invitation Card of Workshop



 Invitation for stakeholder consultation workshop on exposure of
‘Environmental
 Management Framework (EMF)’ and ‘Social Management Framework (SMF)’ of
                                     BRWSSP

I have the pleasure to inform you that a stakeholder consultation
workshop is going to be
held on ‘Environmental Management Framework (EMF)’ and ‘Social Management
Framework (SMF)’ of BRWSSP those prepared by the ‘Project Preparation
Team
(PPT)’ of DPHE on Monday, October 10, 2011 at 10:00 am at the Conference
room
‘Jamuna’ of The World Bank Office at E-32 Agargaon, Sher-e-Bangla Nagar,
Dhaka-1207.

Engr. Md. Nuruzzaman, Chief Engineer, Department of Public Health
Engineering
(DPHE) has kindly consented to be the Chief Guest on the Occasion.

You are cordially invited to attend the workshop.


                                                                   S.M.
Ihtishamul Huq

Project Director
                        Bangladesh Rural Water Supply and Sanitation
Project [Proposed]
                                               Department of Public Health
Engineering




66
                                  Program Schedule
Date : Monday, October 10, 2011                       Venue : Conference
Room ‘Jamuna’
                                                                 The
World Bank Office
                                                     E-32 Agargaon, Sher-
e-Bangla Nagar,

Dhaka.

 09:30 –       Registration
 09:45
 09:45 –       Guest /Participants take their seat
 10:00
 10:00 –       Recitation from the Holy Quran
 10:05
 10:05 –       Welcome Address and introduction of the Workshop
 10:15
 10:15 –       Address by Chief Guest
 10:25
 10:25 –       Understanding of The World Bank’s OP 4.01 for
Environmental Assessment
 10:35
               (EA)
 10:35 –       Understanding of The World Bank’s OP 4.12 for land
acquisition and
 10:45
               displacement
 10:45 –       Tea Break
 11:00
 11:00 –       Presentation of Environmental Management Framework (EMF)
 11:30
 11:30 –       Presentation of Social Management Framework (SMF)
 12:00
 12:00 –       Open Discussion on EMF & SMF
 12:45
 12:45 –       Lunch and Prayer
 01:30




67
List of participants




                       68
69
70
71
Note : The attendance list of the participants is attached in the
Annexure as a ready
reference.



72
                         Documentation on Disclosure

The scanned copy of the advertisement in two daily newspapers published
on December
22, 2011is given below. Although, the advertisement is in Bangla, the
keywords (i.e.,
BRWSSP, EMF, website link address etc) are also given in English.




73

				
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